Price Predictor — Daily Prediction Game

Opening / Acceptance

Price Predictor is a free daily prediction game. No purchase, deposit, trade, or other financial action of any kind is required to play or to receive an Ink Points reward. By playing Price Predictor, you agree to these Official Rules (the "Rules") and to the Kraken Terms of Service referenced in Section 13 below.

Section 1 — Sponsor

Tulip HoldCo Ltd., 2nd Floor, Water's Edge Building, Wickhams Cay II, Road Town, Tortola, British Virgin Islands ("Sponsor," "Kraken," "we," or "us").

For clients in the European Economic Area, trading services are separately provided by Payward Europe Solutions Ltd. ("PESL"); for clients in Australia, by BitTrade Pty Limited; in each case as the regulated entity clients face for underlying Kraken services, distinct from Sponsor's role as administrator of this promotion.

Section 2 — Eligible Areas

The Promotion is open to eligible customers residing in the European Economic Area ("EEA"), the United States (excluding Maine and New York), Canada (excluding Quebec), Australia, and other jurisdictions where Kraken services are available and Price Predictor has been enabled. Residents of the United Kingdom are not eligible to participate. Void where prohibited.

Section 3 — Promotion Period

The Promotion is ongoing, commencing upon launch and continuing on a rolling daily basis until suspended or terminated by Sponsor. Each calendar day (00:00:00–23:59:59 UTC) constitutes one "Play Period."

Section 4 — How to Enter / How to Participate

To participate, an eligible individual must: (a) hold an individual Kraken Pro account in good standing; (b) access the Price Predictor feature within the Kraken Pro application; and (c) select "Higher" or "Lower" as their prediction for the direction of the Reference Asset's price over the applicable ten (10) second window. Each eligible account may play once per Play Period. "Reference Asset" means BTC, or such other digital asset as Sponsor may designate for a given Play Period.

No purchase, deposit, trade, or other financial transaction of any kind is required to play. Participation is fully decoupled from trading volume and financial activity.

Section 5 — Prize Distribution

A correct prediction results in an automatic, guaranteed award of Ink Points, drawn from the following fixed distribution: 5 Ink Points (70% of correct predictions); 10 Ink Points (20%); 20 Ink Points (8%); 50 Ink Points (2%). An incorrect prediction results in no Ink Points award for that Play Period. The specific award amount for a correct prediction is determined automatically and immediately upon result determination; Sponsor exercises no discretion over the outcome.

Section 6 — Prize / Reward Details

Reward: Ink Points as described in Section 5. Ink Points have no cash value, are not redeemable for cash, cryptocurrency, or any other item of value, and are non-transferable, consistent with the Kraken Ink Points Program Terms (incorporated by reference).

Section 7 — Kraken Account and KYC Requirement

Participation requires an individual Kraken Pro account in good standing. No minimum KYC tier is required to play or to receive an Ink Points award, as Ink Points carry no monetary value. Sponsor may require additional verification where necessary to comply with applicable law or to administer the Promotion.

Section 8 — Eligibility

Open only to individual accountholders described in Section 2 who are of legal age in their jurisdiction of residence. Not open to: (a) Kraken/Payward employees, contractors, or their immediate family members; (b) accounts flagged for fraud; (c) closed accounts; (d) API-only, institutional, corporate, or account-managed accounts. By participating you agree to these Rules and to the applicable Kraken Terms of Service referenced in Section 13.

Section 9 — Disqualification

Sponsor reserves the right to disqualify any participant who: submits fraudulent information; uses bots, scripts, or automated means to play; circumvents the one-play-per-day limit through multiple accounts or otherwise; or engages in any conduct Sponsor deems, in its sole discretion, to be a threat to the integrity of the Promotion.

Section 10 — Notification and Fulfilment

Ink Points are credited automatically to the participant's account immediately following each Play Period. No separate winner notification process applies, as every correct prediction results in an automatic award.

Section 11 — Consents and Data / Privacy

By participating, you consent to Sponsor's processing of your account and gameplay data for purposes of administering the Promotion, in accordance with Kraken's Privacy Policy. Sponsor may disclose participant information to service providers assisting with administration, and as required by applicable law.

Section 12 — Disclaimers

Sponsor is not responsible for technical failures of any kind, including malfunctioning hardware, software, or network connectivity, that may limit a participant's ability to play. Sponsor's obligations under this Promotion are subject to force majeure events beyond its reasonable control.

Section 13 — Limitation of Liability, Disputes, and Governing Law

By participating in the Promotion you agree to and hereby do release and hold Kraken harmless from any damage, injury, death, loss, claim, action, demand, or other liability (collectively, "Claims") that may arise from your acceptance, possession and/or use of any prize or your participation in this Promotion, regardless of whether such Claims, or knowledge of the facts constituting such Claims, exist at the time of entry or arise at any time thereafter.

BY PARTICIPATING IN THE PROMOTION, YOU AGREE THAT TO THE EXTENT PERMITTED BY APPLICABLE LAW: (1) ANY AND ALL DISPUTES, CLAIMS AND CAUSES OF ACTION THAT CANNOT BE RESOLVED BETWEEN YOU AND KRAKEN ARISING OUT OF OR CONNECTED WITH THE PROMOTION WILL BE RESOLVED INDIVIDUALLY, WITHOUT RESORT TO ANY FORM OF CLASS ACTION; (2) ANY AND ALL CLAIMS, JUDGMENTS AND AWARDS WILL BE LIMITED TO ACTUAL THIRD-PARTY, OUT-OF-POCKET COSTS INCURRED, (IF ANY), NOT TO EXCEED TWENTY FIVE DOLLARS ($25.00), BUT IN NO EVENT WILL ATTORNEYS' FEES BE AWARDED OR RECOVERABLE; (3) UNDER NO CIRCUMSTANCES WILL YOU BE PERMITTED TO OBTAIN ANY AWARD FOR, AND YOU HEREBY KNOWINGLY AND EXPRESSLY WAIVE ALL RIGHTS TO SEEK, PUNITIVE, INCIDENTAL, CONSEQUENTIAL OR SPECIAL DAMAGES, LOST PROFITS AND/OR ANY OTHER DAMAGES, OTHER THAN ACTUAL OUT-OF-POCKET EXPENSES NOT TO EXCEED TWENTY FIVE DOLLARS ($25.00), AND/OR ANY RIGHTS TO HAVE DAMAGES MULTIPLIED OR OTHERWISE INCREASED; (4) YOUR REMEDIES ARE LIMITED TO A CLAIM FOR MONEY DAMAGES (IF ANY) AND YOU IRREVOCABLY WAIVE ANY RIGHT TO SEEK INJUNCTIVE OR EQUITABLE RELIEF.

Any dispute arising under or related hereto (whether for breach of contract, tortious conduct or otherwise) will be governed by the laws of England and Wales, without reference to its conflicts of law principles. By participating in this Promotion, you agree that any dispute arising from or relating to this Promotion shall be determined by confidential binding arbitration only in London, England, by and under the LCIA rules, and judgment on the award rendered by the arbitrator(s) may be entered in any court having jurisdiction thereof. Notwithstanding the foregoing, Kraken may seek equitable relief in any court of competent jurisdiction.

Dispute resolution cross-reference: EEA participants — EEA Terms of Service (https://www.kraken.com/legal/eea-terms), including Section 15. Canadian participants — Canadian Terms of Service (https://www.kraken.com/legal/ca-terms). All other participants (US, Australia, and ROW) — Global Terms of Service (https://www.kraken.com/legal/global-terms).

Australian clients are served by BitTrade Pty Limited with respect to this Promotion.

Section 13A — Canada: Skill-Testing Question

A participant residing in Canada who correctly predicts the Reference Asset's direction and thereby qualifies for an Ink Points award must, prior to receipt, correctly answer, without assistance of any kind, a mathematical skill-testing question administered by Sponsor or its designee.

Section 14 — Taxes

Ink Points have no cash value and no tax reporting is anticipated to arise from their receipt on this basis alone. Participants are solely responsible for any tax consequences arising from participation. Kraken does not provide tax advice.

Section 15 — General Terms

Sponsor reserves the right to modify, suspend, or terminate the Promotion, or these Rules, at any time, for any reason, subject to applicable law. Sponsor's decisions regarding the administration of the Promotion are final. If any provision of these Rules is held invalid or unenforceable, the remaining provisions will continue in full force and effect.