BY PARTICIPATING IN THIS PROMOTION, YOU AGREE TO THESE OFFICIAL TERMS AND CONDITIONS (“TERMS”) AND THE KRAKEN.COM TERMS OF SERVICE, WHICH EACH FORM A BINDING CONTRACT. PLEASE READ THEM CAREFULLY BEFORE PARTICIPATING.

A DEPOSIT AND QUALIFYING TRADE ARE REQUIRED TO RECEIVE THE REWARD.

THIS PROMOTION IS A NON-DISCRETIONARY CASHBACK PROMOTION AND IS NOT A GAME OF CHANCE.

1. SPONSOR

This promotion (“Promotion”) is sponsored by Tulip HoldCo Ltd., located at 2nd Floor, Water's Edge Building, Wickhams Cay II, Road Town, Tortola, British Virgin Islands (“Sponsor,” “Kraken,” “we,” “us,” or “our”).

2. PROMOTION OVERVIEW

The Promotion is a single promotional program running during the Promotion Period.

Eligible participants who satisfy the qualifying conditions described below will receive guaranteed xStocks rewards, subject to the applicable limits and conditions.

3. ELIGIBLE AREAS

The Promotion is open only to eligible individuals who:

• are legal residents of Ukraine;
• reside in areas where Kraken services and eligible xStocks products are lawfully available;
• are not residents of restricted or sanctioned territories;
• successfully complete required identity verification requirements; and
• otherwise comply with these Terms and the Kraken Terms of Service.

Residents of non-government controlled regions of Ukraine, including but not limited to Crimea and certain restricted areas of Donetsk and Luhansk Oblasts, are not eligible.

Persons or entities subject to sanctions or trade restrictions administered by Ukraine, the European Union, the United Kingdom, the United States, or other applicable authorities are not eligible.

The Promotion is void where prohibited or restricted by law.

4. PROMOTION PERIOD

The Promotion begins at 00:00 EEST on July 15, 2026 and ends at 23:59 EEST on August 31, 2026 (“Promotion Period”).

Sponsor reserves the right to modify, suspend, or terminate the Promotion at any time in its sole discretion.

5. ELIGIBILITY REQUIREMENTS

To participate in the Promotion, participants must:

• be at least 18 years of age or the age of majority in their jurisdiction of residence;
• maintain a valid Kraken Consumer and/or Kraken Pro account;
• complete Intermediate-level identity verification (KYC);
• maintain an account in good standing throughout the Promotion Period and reward distribution process;
• agree to the Kraken Terms of Service and these Terms.

6. HOW TO PARTICIPATE AND WIN

6.1 How to Participate

To qualify, participants must during the Promotion Period:

• purchase eligible goods from participating Varus retail locations, via varus.ua, or through the Varus mobile application;
• deposit at least USD $11 to Kraken via fiat;
• execute at least one USD $11 trade on Kraken;
• complete Intermediate-level identity verification (KYC).

6.2 Rewards

• The first 5,000 new trading users will each receive USD $11 in xStocks.
• 1,000 allocations are available for each eligible xStocks category.

6.3 Eligible Categories and xStocks Rewards

Rewards will be distributed in xStocks associated with the following eligible Varus purchase categories:

• Fruits & apples → Apple (AAPLx)
• Snacks → Netflix (NFLXx)
• Energy drinks → Tesla (TSLAx)
• Household products → Amazon (AMZNx)
• Soft drinks → Coca-Cola (KOx)

Sponsor reserves the right to modify, substitute, suspend, or remove any supported ticker at any time.

6.4 Reward Distribution

Eligible rewards will be credited directly to participants’ Kraken accounts within thirty (30) days following successful verification of eligibility.

Sponsor may request additional documentation or verification before issuing rewards.

7. RESTRICTIONS AND PROHIBITED CONDUCT

Participants may be disqualified if Sponsor determines, in its sole discretion, that they have:

• violated these Terms or the Kraken Terms of Service;
• engaged in fraudulent, deceptive, abusive, or manipulative conduct;
• submitted duplicate, altered, forged, or invalid receipts;
• created multiple accounts to circumvent participation limits;
• engaged in wash trading, self-dealing, or non-bona fide trading activity;
• used VPNs, proxies, scripts, bots, or automated systems;
• violated applicable laws or regulations.

Sponsor reserves the right to withhold, deny, reverse, or claw back rewards at any time.

8. XSTOCKS DISCLOSURES

xStocks products are subject to availability, eligibility restrictions, and applicable laws and regulations.

xStocks are not bank deposits and are not insured by any government deposit insurance program.

The value of xStocks may fluctuate and participants may lose value.

Nothing in this Promotion constitutes investment advice, financial advice, or a recommendation to purchase, sell, or hold any financial product or digital asset.

Sponsor makes no representations regarding future performance or value of any xStocks product.

xStocks are issued by Backed Assets (JE) Limited (a Jersey private limited company) and offered to eligible Kraken customers via Payward Digital Solutions Ltd. ("PDSL"), a company licensed to conduct digital asset business by the Bermuda Monetary Authority. xStocks are not, nor will they be registered with any local securities regulators. Not available in the U.S. or to U.S. persons. Geo restrictions apply. Read Kraken's xStocks Risk Disclosure at kraken.com/legal/xstocks as well as the Base Prospectus and related Final Terms for xStocks at https://assets.backed.fi/legal-documentation to learn more.

9. PRIVACY

By participating, you consent to Sponsor’s collection, use, processing, and sharing of personal information for purposes including:

• administering the Promotion;
• verifying eligibility;
• complying with legal and regulatory obligations;
• fraud prevention;
• reward distribution;
• administration of the Promotion.

Information collected in connection with the Promotion is subject to Kraken’s Privacy Notice located at:

https://kraken.com/legal/privacy

Communications strictly necessary for administration of the Promotion and your Kraken account will be sent in accordance with the Kraken Terms of Service. Consent to receive marketing communications from Kraken is separate from participation in this Promotion and will be sought through a separate mechanism. Participation in this Promotion does not constitute consent to receive marketing communications.

10. DISCLAIMERS

Sponsor is not responsible for:

• lost, delayed, incomplete, corrupted, or misdirected submissions;
• internet, technical, platform, or connectivity failures;
• unauthorized intervention;
• human error;
• receipt-upload failures;
• interruptions caused by third-party systems;
• acts beyond Sponsor’s reasonable control.

Sponsor does not guarantee uninterrupted access to Kraken services or partner systems.

Crypto assets and tokenized assets involve risk and may fluctuate in value. Kraken does not guarantee any profit, return, or investment performance.

Nothing in these Terms constitutes investment advice, financial advice, or a recommendation to buy, sell, hold, or trade any asset.

11. LIMITATION OF LIABILITY

By participating in this Promotion, you agree to and hereby release and hold harmless Tulip HoldCo Ltd. and its affiliates, officers, directors, employees, and agents (collectively, "Kraken") from any damage, injury, death, loss, claim, action, demand, or other liability ("Claims") that may arise from your acceptance, possession, and/or use of any reward or your participation in this Promotion, regardless of whether such Claims exist at the time of entry or arise at any time thereafter.

TO THE EXTENT PERMITTED BY APPLICABLE LAW: (1) 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 US DOLLARS (USD $25.00). ATTORNEYS' FEES ARE NOT RECOVERABLE; (2) YOU WAIVE ALL RIGHTS TO SEEK PUNITIVE, INCIDENTAL, CONSEQUENTIAL, OR SPECIAL DAMAGES, OR LOST PROFITS; AND (3) YOUR REMEDIES ARE LIMITED TO A CLAIM FOR MONEY DAMAGES ONLY.

• All claims shall be resolved individually. Class actions and representative actions are waived.

12. GOVERNING LAW AND DISPUTE RESOLUTION

Dispute resolution and governing law are governed by the Kraken Terms of Service applicable to you, available at https://www.kraken.com/legal/global-terms, including all dispute resolution and governing law provisions contained therein.

By participating, you agree to those provisions as they apply to your relationship with Kraken. If you are uncertain which Terms of Service apply to you, please visit https://www.kraken.com/legal.

13. TAXES

Participants are solely responsible for any taxes, reporting obligations, duties, or governmental fees associated with receipt or use of rewards.

Sponsor may require participants to provide additional tax documentation prior to reward distribution.

14. GENERAL TERMS

Sponsor reserves the right to:

• modify these Terms;
• suspend or terminate the Promotion;
• substitute rewards;
• amend eligible categories or supported xStocks;
• invalidate entries or rewards;
• interpret these Terms in its sole discretion.

Sponsor’s decisions are final and binding.

If any provision of these Terms is determined unenforceable, the remaining provisions shall remain in full force and effect.

In the event of any conflict between marketing materials and these Terms, these Terms control.

15. CONTACT

Questions regarding the Promotion may be directed through Kraken Support at:

https://support.kraken.com