Promotions and Prize Draws

Official page for active Cashletics promotions, prize draws and campaign rules.

B BLOCK · FOR USERS

Promotional & Prize Rules

Lucky Wheel · Prize Draw with Entry Tickets · Physical Prizes

PR-001-EN

cashleticsapp.com/legal.php · Campaign-specific rules template GDPR-compliant ✔

1. Legal Status of the CP System

1.1 Definition of CP (Cashletics Point)

The CP (Cashletics Point) used in the Cashletics application is a virtual, in-app point with the following characteristics:

1.2 Relationship between XP, coins and CP

CP can also be earned by completing the PiggyRun skill-based mini-game — the reward is based on the player's skill performance, under pre-announced conditions and server-side limits. Use of PiggyRun is voluntary and is not a condition of participation in the prize draw.

1.3 Piggy Coin and source protection

CP earned through the regular use of PiggyRun, and CP credited when exchanging Piggy Coins verified on the server, is the same as CP earned for free. Piggy Coins cannot be bought for money. Neither CP nor Piggy Coins can be used — directly or indirectly — for entry tickets.

2. Legal Opinion — Gambling Law Classification

2.1 Criteria for gambling classification under Hungarian law

Under Section 1(1) of Act XXXIV of 1991 (Gambling Act), gambling is a game in which the player, (1) in return for paying money or providing something of monetary value, (2) depending on chance, (3) becomes entitled to a cash prize or another prize of monetary value.

The Gambling Act only applies if all three conditions are met simultaneously. The analysis below demonstrates that the Cashletics promotional system does NOT meet these conditions cumulatively.

2.2 Condition 1 — Paying money or providing something of monetary value

"Paid participation" under the Gambling Act means that a player may only participate in exchange for money or equivalent consideration.

In the case of Cashletics:

• Entry tickets are given exclusively for the free, intended use of the app (Section 4.0): for regular opening and for completing the tutorial. Payment, a purchased product, a Pro subscription or CP does not lead to a ticket, either directly or through exchange.

• The ways of earning CP and Piggy Coins (financial entries, step count, PiggyRun, ads) do not affect participation in the prize draw.

2.3 Condition 3 — Prize of monetary value

The prize is a physical prize, which qualifies as a prize of monetary value. The classification is therefore based not on the nature of the prize but solely on the fact that participation does not involve paying money or providing anything of monetary value.

2.4 (No longer in effect from 28 November 2026)

2.5 Summary — legal classification

2.6 Random reward packages (loot boxes)

Random reward packages (loot boxes). In the app, reward packages with random content (loot boxes) can be obtained exclusively free of charge — as a daily login streak reward or as a seasonal reward; loot boxes cannot be obtained for money or in any other way linked to a purchase. A loot box may only contain in-app virtual content: cosmetic items (skins, character elements), Piggy Coin or in-game items. A loot box contains no entry tickets. The rarity categories of the contents and a description of the opening odds are published by the Provider within the app. Opening a loot box cannot be tied to any monetary consideration; its contents are not money, not a cash equivalent and cannot be redeemed for cash.

Obtaining and opening a loot box cannot be tied to monetary consideration in any form, so the “stake” element of the statutory definition of gambling is absent; the random element alone — without consideration — does not create a licensing obligation.

3. Daily Lucky Wheel — Mechanism and Legal Classification

3.1 How the lucky wheel works

3.2 Legal classification — lucky wheel

The daily lucky wheel is also outside the scope of the Gambling Act because:

• Participation is free — no paid participation.

• The prize is exclusively CP or XP, a virtual in-app point — not cash or a cash equivalent.

• Virtual points have no market value and cannot be converted to cash.

4. Physical Prize Draw — Participation Rules

4.0 Earning entry tickets

Entry tickets are given exclusively for the four free activities listed in Section 8.3 of the Terms of Use: seven days of Cashletics in a week, seven days of PiggyRun in a week, 15 active days in a month (opening Cashletics or PiggyRun) and the first completion of the tutorial. For the 15 days in a month, a day counts if the user opens Cashletics or PiggyRun on that Budapest calendar day; for the weekly tickets, opening the named app counts. From 28 November 2026 the app issues only standard entry tickets. Earning tickets does not depend on step data, health permissions, financial entries, ads, payment or a Pro subscription, and it is the same for every user. The Lucky Wheel, ads, referrals, the shop, chests, Pro and CP give no entry tickets. A new ticket source (for example levelling up) may only be introduced by amending these Rules and with notice under Section 14 of the Terms of Use. The start date of ticket earning is governed by Section 8.3 of the Terms of Use.

4.1 Draw mechanism

4.2 Winner notification and prize delivery

• The winner is notified by email on the day of the draw (and, once FCM is activated, also by in-app push notification).

• The winner must confirm acceptance of the prize within 15 days by emailing support@cashleticsapp.com; the name and postal address required for delivery must be provided in this confirmation email (data processing: Section 7).

• If the winner does not respond within 15 days, the prize lapses and a new draw may be held.

• Prize delivery is by post or in person — shipping costs: to be determined per campaign.

• The Organiser (Mózer Ferenc) shall fulfil all personal income tax obligations arising from the prize under Hungarian tax law (Act CXVII of 1995, Section 76). In the Organiser's view, on this basis the prize is free of personal tax liability for the winner, who has no separate tax declaration obligation in respect of the prize. The Organiser shall confirm the above tax classification with a tax adviser's opinion before launching the promotion. Upon delivery of the prize, the Organiser shall provide the winner with a tax certificate stating the legal title, HUF value of the prize and the amount of personal income tax withheld. Non-Hungarian residents should consult their local tax adviser regarding any applicable tax obligations in their jurisdiction.

4.3 Types of entry tickets and their per-campaign use

Types of entry tickets. From 28 November 2026 the app issues only standard entry tickets. Standard tickets cannot be converted into silver or gold tickets. A campaign accepts standard, silver and gold tickets obtained before 28 November 2026 only if its terms expressly allow earlier tickets and the given ticket type. Earlier ticket types are not weighting multipliers within the same draw: the campaign terms determine which type can be used in which prize-category draw. The odds per ticket (participation unit) and the campaign-specific conditions are published in the app before the campaign starts; no campaign starts without this publication.

Per-campaign ticket type. The Provider determines per campaign which ticket type(s) may be used in a given draw. This is included in the in-app publication of the campaign, and the system verifies server-side that only the ticket type(s) authorised for the given campaign can be used.

4.4 Excluded Persons, Manual Crediting and Integrity of the Draw

Excluded persons. The Service Provider may not take part in the draw, nor may any natural person holding access of any level to the administration interface of the application — including the controller, the developer acting as processor, and any further person listed in the access matrix in clause 2.1 of SZ-001 — nor the close relatives of such persons within the meaning of Section 8:1(1) point 1 of the Hungarian Civil Code. The exclusion applies even where, at the time of the draw, the access consists solely of a temporary entitlement granted for pre-release testing (DPA-003, clause 3.9.6).

Manual crediting. The manual crediting of XP, CP, coins, Piggy Coin, items, loot boxes or any other value may take place solely with the Data Controller's prior, written and traceable approval, with mandatory justification. Every manual crediting is recorded in the administrator audit log (ROPA-001, item 17): the designation of the operation, the justification, the identifier and role of the acting administrator, the identifier of the user concerned, the previous and the new value, and the timestamp.

Integrity of the draw. Manual crediting may not be used to confer an unjustified advantage on any participant in the draw. Where a manual crediting directly or indirectly affects the number of entry tickets or eligibility for the draw, this shall be expressly recorded in the approval. The draw is conducted by server-side random number generation (Cloud Functions), which cannot be influenced through administrator rights.

Daily lucky wheel. The daily lucky wheel described in clause 3 falls within the scope of these rules; the related server-side record (daily_spin) is subject to the same controls.

5. Ads and Entry Tickets — No Link

5.1 Rewarded ad mechanism

5.2 Logical chain — why this is not paid participation

1. For watching an ad the user receives CP, which from 28 November 2026 cannot be exchanged for entry tickets. Entry tickets are given exclusively for the activities under Section 4.0. There is therefore no direct or indirect link between ads and participation in the prize draw. The discounted PiggyRun programmes (Terms of Use Section 8.2) give no entry tickets.

6. Physical Prize — Type, Value and Campaign

6.1 Prize characteristics

6.2 Campaign announcement procedure

• Before each draw campaign begins, the app publishes the draw date, exact prize description and value, the entry ticket type(s) usable in the given campaign, entry ticket redemption/use conditions, and the rule that entry tickets are given exclusively for the free activities under Section 4.0.

• Campaign terms cannot be modified after announcement.

• The publication location of previous campaign data and winners is determined per campaign (e.g. in the app’s “Winners” section).

7. Data Processing in Connection with Prize Draws

7.1 Categories of data processed

7.2 Firestore data structure reference

7.3 Data subject rights in connection with prize draws

• A deletion request may be submitted at any time. The data required for delivering the prize (name, postal address) cannot be deleted until delivery, as the processing is necessary for the performance of the contract (GDPR Article 17(3)(b)), and the data of the accounting document until the end of the retention period under the Hungarian Accounting Act; this does not prevent the deletion of the other data.

• The record of draw participation (in pseudonymised form) cannot be deleted — required for legal claims.

• Data processing requests: privacy@cashleticsapp.com

8. Governing Law and Dispute Resolution

These rules are governed by Hungarian law. In the event of disputes arising from the interpretation or application of these rules — if the parties cannot reach an out-of-court settlement — the exclusive jurisdiction of Hungarian courts applies.

Users wishing to submit a consumer complaint may contact the Hungarian National Consumer Protection Authority (nfh.hu) or the consumer protection office of their local district authority. Users outside Hungary may contact the relevant consumer protection authority in their country of residence.

9. Transitional Provisions for the Amendment of 28 November 2026

9.1 CP earned before 28 November 2026 is kept and, from the effective date, can be redeemed for Pro time on the user's own account.

9.2 CP earned for free — including CP earned for rewarded ads — can be exchanged for entry tickets until 23:59 (Budapest time) on 27 November 2026 at the latest. Purchased CP cannot be exchanged for entry tickets.

9.3 Entry tickets obtained before 28 November 2026 — irrespective of their origin, including those obtained from the Lucky Wheel and from Pro time obtained with CP — remain valid and can be used in campaigns announced after the effective date under the terms of each campaign, in accordance with Section 4.3. From 28 November 2026, standard tickets cannot be converted into silver or gold tickets. Whether an earlier ticket can be used in a campaign is determined by the terms of that campaign; we cannot guarantee this in advance. CP you keep can be used for Pro time.

9.4 Entries submitted before 28 November 2026 will be drawn under the rules in force at that time.

9.5 Pro time obtained with CP runs until it expires, but from 28 November 2026 it gives no extra spin of the Lucky Wheel and no entry tickets.

9.6 Had any purchase been made before the sale of CP packs was stopped on 5 November 2026, the Service Provider would settle it individually, without disadvantage to the user. (According to the Google Play report, there were no paid orders until 5 November 2026.)

9.7 No prize draw campaign will start on or before 28 November 2026.

10. Governing Language and Version Control

Signatures

Next scheduled review: 1 August 2027, or per campaign

This document is a campaign-specific promotional/prize rules template. It does not constitute the final rules of an announced prize draw by itself. Before each campaign starts, campaign-specific fields must be completed, approved and published.