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Official Rules

Price Predictor — Daily Prediction Game

Opening / Acceptance

NO PURCHASE, DEPOSIT, TRADE, OR PAYMENT OF ANY KIND IS NECESSARY TO ENTER OR WIN. Playing Price Predictor is entirely free. Purchase or trading activity will not increase your chances of winning — chances are determined solely by number of plays, which itself requires no payment. By participating, you agree to these Official Rules (the "Rules") and to the applicable Kraken Terms of Service referenced in Section 13.

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").

Payward Europe Solutions Ltd. ("PESL") is the separately regulated entity EEA clients face for underlying Kraken trading services; PESL is not the T&C sponsor of this Promotion.

Section 2 — Eligible Areas (PHASE 1 — operative at launch)

The Promotion is open to eligible customers residing in the European Economic Area ("EEA"), excluding the Netherlands. Residents of the United Kingdom are not eligible to participate. Void where prohibited.

Denmark: prize value will be stated in DKK for Danish participants.

Spain: a 10% gambling tax applies to aggregate prize value under Spanish law.

Section 3 — Promotion Period

The Promotion runs in recurring monthly cycles (each, a "Draw Period"). The start and end date of each Draw Period, and the date on which the draw for that Draw Period is conducted, will be determined by Sponsor and published on the official Rules page for this Promotion; these dates are not fixed in these Rules and are subject to change from one Draw Period to the next at Sponsor's discretion.

Section 4 — How to Enter

Entry is automatic and free. Every time an eligible participant plays the daily prediction game (governed by separate Official Rules) during a Draw Period, they receive one entry ("ticket") into that month's draw, regardless of whether their prediction is correct. There is no separate or additional step required to enter the draw beyond playing. No payment, deposit, trade, or fee of any kind unlocks additional entries; entries cannot be purchased at any price.

Section 5 — Winner Selection

One winner is selected per Draw Period by random drawing from all eligible tickets issued during that Draw Period, weighted only by number of plays (more plays = proportionally more tickets = proportionally higher odds; no bonus weighting for correct predictions, streaks, or any other factor). Sponsor exercises no discretion over the outcome of the draw. If the initially selected participant does not meet the eligibility criteria in Section 8, the next eligible candidate is considered, and so on, until a winner is confirmed.

Section 6 — Prize / Reward Details

One (1) winner per Draw Period receives one (1) BTC, credited directly to the winner's Kraken account.

Approximate retail value (ARV) as of August 14, 2026: approximately USD 63,500, based on the market price of BTC on Kraken as of that date. Actual value at time of award will differ due to BTC price volatility.

The prize is non-transferable and may not be exchanged, redeemed for cash, or substituted, except that Sponsor reserves the right, in its sole discretion, to substitute a prize of equal or greater value in the event BTC cannot be awarded for any reason.

Section 7 — Kraken Account and KYC Requirement

To receive the Prize, a participant must, before the end of the applicable Draw Period and before prize fulfilment, have: (a) an individual Kraken account in good standing; and (b) completed at least Intermediate KYC verification, plus any additional verification required by Kraken or applicable law in the participant's jurisdiction. This requirement applies to prize fulfilment only and is not a condition of entry or participation.

Section 8 — Eligibility

Open only to individual Kraken Pro accountholders residing in an Eligible Area (Section 2) who are of legal age in their jurisdiction of residence, and who are not: (a) Kraken/Payward employees, contractors, or their immediate family members; (b) accounts flagged for fraud; (c) closed, API-only, institutional, corporate, or account-managed accounts. A winning candidate found ineligible at verification is disqualified and replaced per the backup sequence in Section 5; no re-draw occurs unless the entire backup list is exhausted, in which case the draw is re-run in full from a recounted eligible ticket pool. By participating you agree to these Rules and to the 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 or automated means to inflate entries, operates multiple accounts to circumvent entry limits, or otherwise engages in conduct that threatens the integrity of the draw.

Section 10 — Winner Notification and Prize Fulfilment

The winner will be notified via an in-app notification and via email within fourteen (14) business days of the draw. If a winner does not respond or complete verification within thirty (30) days of notification, they will be deemed to have forfeited the Prize and a backup candidate will be considered per Section 5. The winner's handle may be announced via lifecycle communications on an anonymized basis unless the winner consents to further disclosure.

Section 11 — Consents and Data / Privacy

By participating, you consent to Sponsor's processing of your account, gameplay, and (if selected as winner) identity-verification 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, including malfunctioning hardware, software, or network connectivity, that affect a participant's ability to play or receive an entry. Sponsor's obligations 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 (Phase 1): EEA Terms of Service (https://www.kraken.com/legal/eea-terms), including Section 15.

Section 14 — Taxes

Participants are solely responsible for any tax consequences arising from the Prize, including any applicable prize or gambling tax in their jurisdiction of residence (e.g., Spain's 10% gambling tax on aggregate prize value; Denmark and Austria prize-tax thresholds noted in Section 2). 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 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.

Schedule A — Phase 2 Expansion (Adds United States) — NOT YET CLEARED, DO NOT PUBLISH

Upon activation of Phase 2, Section 2 (Eligible Areas) is replaced in full with:

"The Promotion is open to eligible customers residing in the European Economic Area ('EEA') (excluding the Netherlands, unless the carve-out in Section 2 has been lifted by this point), the United States (excluding Maine, New York, and Florida), and other jurisdictions where Kraken services are available. Residents of the United Kingdom are not eligible to participate. Void where prohibited."

Sponsor entity changes from Phase 1: none. Sponsor remains Tulip HoldCo Ltd.; governing law remains England and Wales. Dispute resolution cross-reference adds the Global Terms of Service (https://www.kraken.com/legal/global-terms) for US participants, alongside the EEA Terms of Service for EEA participants.