The Bitcoin Trading Challenge

These Terms and Conditions (the "Terms") govern The Bitcoin Trading Challenge (the "Promotion"), a skill-based trading contest run by the Sponsor identified in Section 1. Participation in the Promotion requires trading the BTC Perpetual Futures contract on Kraken Futures during the Promotion Period. Participants are ranked on realized profit and loss ("Realized PnL") generated on that contract, as described in Section 5. By participating in the Promotion, you accept these Terms in full and confirm that you have read and agree to the Kraken Terms of Service.

Risk Warning

Futures and derivatives trading involves a high degree of risk and is not suitable for all investors. Leverage can work against you. You may lose more than your initial deposit. Ensure you fully understand the risks before trading. Futures products are not available in all jurisdictions. In the European Economic Area, futures are offered by Payward Europe Digital Solutions (CY) Limited, authorised and regulated by the Cyprus Securities and Exchange Commission (CySEC), licence no. 342/17.

1. Sponsor

The Promotion is sponsored by Tulip HoldCo Ltd., 2nd Floor, Water’s Edge Building, Wickhams Cay II, Road Town, Tortola, British Virgin Islands (the "Sponsor" or "Kraken").

2. Eligible Areas

The Promotion is open to eligible customers residing in jurisdictions where Kraken Futures trading is available, excluding the United Kingdom, the European Economic Area, the United States, Canada, Australia, and New Zealand. Void where prohibited.

3. Promotion Period

The Promotion begins on 19 August 2026 at 00:00:00 UTC and ends on 19 September 2026 at 23:59:59 UTC (the "Promotion Period"). Only trading activity executed and settled within the Promotion Period will be counted. Kraken’s records of trade execution and settlement times are final and determinative.

4. How to Participate

To participate, an eligible customer must, during the Promotion Period:

• hold a Kraken account in good standing with access to Kraken Futures; and
• open and close one or more positions in the BTC Perpetual Futures contract (the "Qualifying Contract").

No separate registration or opt-in is required. Trading in any instrument other than the Qualifying Contract will not be counted toward a participant’s Realized PnL for the purposes of the Promotion.

A participant qualifies for a prize only if they achieve a minimum of USD 25 in aggregate net Realized PnL on the Qualifying Contract over the Promotion Period (a "Qualifying Participant"). Participants with aggregate net Realized PnL below USD 25 are not eligible for any prize, regardless of ranking.

5. Ranking and Winner Determination

"Realized PnL" means the aggregate net profit or loss realized on closed positions in the Qualifying Contract during the Promotion Period, calculated by Kraken in USD in accordance with its standard methodology, net of trading fees and funding payments. Unrealized profit or loss on open positions at the close of the Promotion Period is excluded.

Qualifying Participants will be ranked in descending order of Realized PnL. The highest Realized PnL is ranked first. Rankings are determined by Kraken in its sole discretion based on Kraken’s own books and records, which are final and binding.

In the event that two or more Qualifying Participants record identical Realized PnL, the participant who first reached that figure (by trade settlement timestamp) will be ranked higher.

Kraken will publish or otherwise make available the final rankings within a reasonable time after the end of the Promotion Period.

6. Prizes

The total prize pool for the Promotion is 1 BTC, allocated among Qualifying Participants as follows:

Prizes are awarded in Bitcoin (BTC) and credited to the winner’s Kraken account. Prizes are personal to the winner, are non-transferable, and may not be exchanged for cash or any other asset. The USD value of a BTC prize will fluctuate; the approximate retail value of each prize is the market value of the stated BTC amount at the time of distribution. Kraken reserves the right to substitute a prize of equal or greater value where the stated prize cannot be awarded for any reason.

Where a prize tier is shared among multiple participants, the tier amount is divided among those participants as set out in the table above. Where fewer Qualifying Participants exist than the number of ranked positions in a tier, unallocated prize amounts remain with the Sponsor and will not be redistributed unless Kraken determines otherwise in its sole discretion.

7. Kraken Account and KYC Requirement

To receive a prize, a participant must, before the end of the Promotion Period and before prize fulfilment, have: (a) a 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.

A participant who does not satisfy these requirements within a reasonable time following notification will forfeit the prize, and Kraken may, in its sole discretion, award the prize to the next eligible ranked participant or retain it.

8. Eligibility

The Promotion is open only to participants who meet the requirements set out in Section 2 (Eligible Areas), who are of the age of majority in their jurisdiction of residence, and who are not otherwise prohibited from participating under any applicable law. Participation is subject to these Terms and to the Kraken Terms of Service. Employees, officers, and directors of Kraken and its affiliates, and their immediate family members, are not eligible to receive prizes.

Participants are responsible for ensuring that their participation is lawful in their jurisdiction. Where participation is prohibited or restricted by law, the Promotion is void in that jurisdiction.

9. Disqualification

Kraken may, in its sole discretion, disqualify any participant and withhold or reclaim any prize where it reasonably believes the participant has:

• provided false, misleading, or incomplete information;
• used multiple Kraken accounts, or accounts not registered in their own name, to participate;
• engaged in wash trading, self-matching, collusion, market manipulation, or any trading activity intended artificially to inflate Realized PnL;
• used bots, scripts, or automated means in a manner prohibited by the Kraken Terms of Service;
• attempted to circumvent geographic, product, or eligibility restrictions, including through the use of a VPN or similar tool; or
• otherwise breached these Terms or the Kraken Terms of Service.

Kraken’s determinations under this Section are final.

10. Winner Notification and Prize Fulfilment

Winners will be notified using the email address registered to their Kraken account within a reasonable time after the end of the Promotion Period. Winners are identified for the purposes of these Terms by their Kraken Account email address or Kraken Account ID.

Prizes will be credited to the winner’s Kraken account within a reasonable time following notification and completion of any verification required under Section 7. If a winner does not respond to notification, or fails to complete required verification, within a reasonable time, the prize may be forfeited and Kraken may award it to the next eligible ranked participant or retain it.

11. Consents and Approvals; Data and Privacy

By participating, you consent to Kraken processing your personal data for the purposes of administering the Promotion, verifying eligibility, determining rankings, and distributing prizes. Personal data is handled in accordance with the Kraken Privacy Policy.

By participating, you consent to Kraken disclosing your personal data to third-party service providers engaged to administer the Promotion, and to any disclosure required by applicable law or regulation.

Winners may be asked to consent to the publication of their Kraken account username or a pseudonymous identifier in connection with the announcement of results. Participation in the Promotion is not conditional on giving such consent.

12. Disclaimers

Kraken is not responsible for any failure, delay, interruption, or error in the Promotion arising from any cause beyond its reasonable control, including acts of God, war, civil unrest, government action, network or internet failure, exchange or platform outage, or any other force majeure event.

Kraken is not responsible for technical failures of any kind, including malfunctions of hardware, software, network connections, or trading systems, or for any lost, late, incomplete, or misdirected entries or communications.

Nothing in the Promotion or in any Promotion communication constitutes investment, financial, legal, or tax advice, or a recommendation to enter into any transaction.

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: Participation in the Promotion is subject to the Kraken Terms of Service available at https://www.kraken.com/legal/global-terms.

14. Taxes

Each participant is solely responsible for any and all taxes, levies, duties, and reporting obligations arising in connection with the receipt of a prize, in any jurisdiction. Kraken does not provide tax advice. Participants should consult their own tax adviser regarding the treatment of any prize received.

15. General Terms

Kraken reserves the right to modify, suspend, cancel, or terminate the Promotion, in whole or in part, at any time and for any reason, including where the Promotion cannot be conducted as planned or where its integrity is compromised.

All decisions of Kraken relating to the Promotion, including eligibility, rankings, disqualification, and prize allocation, are final and binding on all participants.

If any provision of these Terms is held to be invalid or unenforceable, that provision will be severed and the remaining provisions will continue in full force and effect.

These Terms constitute the entire agreement between the participant and the Sponsor in relation to the Promotion and supersede any prior representations or statements about the Promotion.