Comforto Pre-Launch Campaign

1. Definitions

1.1. "Available Points" or "Available Balance" means the portion of a Participant's Points that may be spent on Raffle Tickets or other in-Campaign expenditures. The Available Balance decreases when Points are spent and is visible only to the respective Participant.

1.2. "Big Prize Pool" means any future aggregate promotional reward pool announced by the Operator in connection with the Campaign or Phase 2, currently referenced with a stated promotional value of up to USD $500,000. The final composition, allocation methodology, timing, categories, and eligibility criteria for such pool may be specified or amended by the Operator closer to launch.

1.3. "Campaign" means the Comforto Pre-Launch Campaign, encompassing Phase 1 and Phase 2 as described in these Terms.

1.4. "Comforto Token" means any token-based or digital-asset-related reward element that the Operator or its affiliates may decide to include in a later-stage reward structure, subject to separate terms, legal review, and applicable law at the relevant time in connection with the Comforto platform.

1.5. "Daily Missions" means the set of daily tasks available to Participants each calendar day during Phase 1, consisting of the Daily Check-in, Daily Quiz, and Social Mission.

1.6. "KYC" or "Know Your Customer" means any identity verification, eligibility verification, or compliance check that the Operator may require at the reward-claim stage, in connection with fraud prevention, sanctions screening, or in connection with later onboarding to the live Comforto platform. KYC is not required for ordinary participation in Phase 1 unless expressly stated otherwise.

1.7. "Level" means the numerical rank derived from a Participant's Total Earned using the formula set forth in Section 4.5 of these Terms.

1.8. "Milestone" means a predefined threshold of cumulative activity (referrals completed, missions completed, or Total Earned reached) that triggers bonus Points or Sure Prize eligibility.

1.9. "Mission" means any task or activity made available by the Operator through the Platform that a Participant may complete to earn Points. Missions include Daily Missions, One-Time Missions, and Social Missions.

1.10. "One-Time Mission" means a Mission that may be completed only once per Participant for the duration of the Campaign.

1.11. "Operator" means Coingarage s.r.o., a company organized under the laws of the Czech Republic, with its registered office at Krakovská 583/9, Nové Město, 110 00 Prague, Czech Republic, identification number 11667974.

1.12. "Participant" means any natural person who has successfully registered for the Campaign through the Platform and who meets the eligibility requirements set forth in Section 2.

1.13. "Phase 1" means the pre-launch stage of the Campaign conducted through the separate campaign microsite, during which Participants may register, earn Points, complete Missions, participate in referral and engagement mechanics, and unlock or reserve certain campaign rewards.

1.14. "Phase 2" means any later stage designated by the Operator in connection with the launch of the live Comforto platform or later reward claiming, fulfilment, onboarding, or platform-related activities. Phase 2, if launched, may be subject to separate platform terms and other legal documentation.

1.15. "Platform" means, for the purposes of these Terms, the campaign microsite, dashboard, and associated digital interfaces through which Participants access and engage with the Campaign, accessible at hey.comforto.ai. For the avoidance of doubt, this Platform is separate from any current or future live Comforto / Coingarage service platform account environment.

1.16. "Points" or "pts" means the non-monetary units of value awarded to Participants for completing Missions, Referrals, Milestones, Wheel Spins, and other Campaign activities. Points have no cash value, are non-transferable, and cannot be purchased with fiat currency or cryptocurrency.

1.17. "Privacy Policy" means the Operator's privacy policy governing the collection, processing, and storage of personal data in connection with the Campaign, available at Privacy Policy.

1.18. "Raffle" or "Weekly Raffle" means the weekly promotional prize draw conducted each Sunday during Phase 1 among holders of valid Raffle Tickets.

1.19. "Raffle Ticket" means a non-transferable entry into the Weekly Raffle, earned through Daily Mission completion, Leaderboard placement, or Points expenditure as set forth in Section 9.

1.20. "Referral" means the act of a Participant inviting a new user to register for the Campaign using the Participant's unique referral code or link.

1.21. "Referral Code" means the unique alphanumeric code or URL assigned to each Participant for the purpose of tracking Referrals.

1.22. "Social Mission" means a Daily Mission requiring a Participant to engage with designated social media content and submit proof of such engagement through the Platform.

1.23. "Streak" means the number of consecutive calendar days on which a Participant has completed the Daily Check-in.

1.24. "Sure Prize" means a guaranteed prize that a Participant becomes eligible for upon reaching a specified Milestone, the value of which is as displayed on the Platform at the time the Milestone is achieved.

1.25. "Total Earned" means the cumulative total of Points validly earned by a Participant since registration. Total Earned is not reduced by ordinary spending of Available Points, but may be adjusted, corrected, or reduced by the Operator in cases of fraud, abuse, invalid activity, technical correction, or other justified enforcement action under these Terms.

1.26. "Wheel Spin" or "Wheel" means the randomized prize mechanism available to Participants through the Platform, offering prizes from among eight (8) weighted segments.

2. Eligibility

2.1. Minimum age. Participation in the Campaign is open only to natural persons who are at least eighteen (18) years of age at the time of registration. By registering, each Participant represents and warrants that they have reached the age of legal majority in their jurisdiction of residence, and in no event less than eighteen (18) years.

2.2. Excluded territories. The Campaign is not open to residents, citizens, or persons physically located in the following territories:

• The United States of America, including its territories and possessions;
• Countries and regions subject to comprehensive sanctions imposed by the European Union, the United Nations, or Czech national authorities, including but not limited to: the Democratic People's Republic of Korea (North Korea), the Islamic Republic of Iran, the Syrian Arab Republic, the Republic of Cuba, the Republic of the Sudan, and the Crimea region of Ukraine;
• Indonesia, Nigeria, India, Bangladesh, and Vietnam.

Citizens and residents of the above countries will not be enabled to claim any rewards because they may not successfully undergo the KYC/AML identification procedure and may not become regular Clients of the Operator.

The Operator reserves the right to update this list at any time to reflect changes in applicable sanctions regimes or regulatory requirements. It is the Participant's sole responsibility to ensure that their participation in the Campaign is lawful in their jurisdiction of residence.

2.3. One account per person. Each natural person may register and maintain only one (1) Campaign account. The creation or maintenance of multiple accounts by the same natural person, whether directly or through proxies, aliases, or third parties, is strictly prohibited.

2.4. Valid email required. Registration requires a valid, functioning email address that belongs to and is controlled by the Participant. The Operator reserves the right to verify email ownership through magic link authentication or other reasonable means.

2.5. Excluded persons. The following persons are not eligible to participate in the Campaign:

• Employees, officers, directors, and agents of Coingarage S.r.o. and its parent companies, subsidiaries, and affiliates;
• Immediate family members (spouse, domestic partner, parent, child, sibling, and their respective spouses) of persons described above;
• Any person who has been previously disqualified from a Campaign operated by the Operator;
• Any person whose participation would cause the Operator to violate applicable law, regulation, or sanctions.

2.6. Compliance responsibility. The Participant is solely responsible for determining whether their participation in the Campaign, the receipt of Points, or the acceptance of prizes complies with all laws and regulations applicable in their jurisdiction of residence. The Operator makes no representation that participation is lawful in any particular jurisdiction.

3. Registration and Campaign Profile

3.1. Registration process. To participate in the Campaign, a prospective Participant must: navigate to the Platform landing page; submit a valid email address; receive and click a magic link sent to the submitted email address; and upon authentication, access the Campaign dashboard.

Registration for the Campaign creates only a Campaign profile for purposes of participation in the pre-launch Campaign. It does not create a customer account for the live Comforto platform and does not create a contractual relationship for platform services.

3.2. Username selection. During onboarding, each Participant may select a display name ("Username") that will be visible on Leaderboards and other public-facing Campaign features of the Platform. Usernames must not contain offensive, misleading, unlawful, infringing, or impersonating content. The Operator reserves the right to reject, modify, or remove any Username at its sole discretion.

3.3. Referral code attribution. During the onboarding process, a Participant may enter another Participant's Referral Code to establish a referral relationship. Referral attribution is recorded at the time of onboarding and cannot be changed after initial registration. If no Referral Code is entered during onboarding, the Participant will not be attributed to any referrer.

3.4. Campaign profile security. Each Participant is solely responsible for maintaining the security and confidentiality of access to their Campaign profile. The Operator authenticates Participants through magic-link technology sent to the registered email address. Any activity occurring under a Participant's Campaign profile shall be deemed to have been performed by that Participant, unless the Participant proves misuse not caused by the Participant.

3.5. Prohibition on multiple accounts and automation. Participants are strictly prohibited from:

• Creating, operating, or maintaining more than one Campaign account;
• Using bots, scripts, automated tools, or any software to interact with the Platform, complete Missions, generate Referrals, or otherwise earn Points;
• Allowing any other person to access or use their account;
• Using virtual private networks (VPNs), proxy servers, or similar technologies for the purpose of circumventing geographic restrictions or creating the appearance of multiple distinct users;
• Using disposable, temporary, or fraudulent email addresses.

Violation of this Section 3.5 shall constitute grounds for immediate suspension or termination of the Participant's account and forfeiture of all accrued Points and prizes, as set forth in Section 12.

4. Points System

4.1. General. The Campaign employs a points-based engagement system. Participants earn Points by completing Missions, generating Referrals, reaching Milestones, and through other activities as described in these Terms and on the Platform. Points are the sole measure of a Participant's engagement and standing in the Campaign.

4.2. Two balances. Each Participant's Campaign profile maintains two distinct Point balances:

• Total Earned: The cumulative total of valid Points earned by the Participant since registration. Total Earned is not reduced by ordinary spending of Available Points and is used as the basis for Level calculation and All-Time Leaderboard ranking. Total Earned may, however, be adjusted, corrected, or reduced in cases of fraud, abuse, invalid activity, technical correction, or other justified enforcement action under these Terms.
• Available Points: The Participant's spendable Point balance, equal to Total Earned minus all Points spent and minus any valid reversals, deductions, or corrections. Available Points are used to acquire additional Raffle Tickets and for other in-Campaign expenditures. Available Points are visible only to the Participant.

4.3. No monetary value. Points are promotional units issued solely for purposes of the Campaign. Points:

• Have no cash value, monetary equivalent, or exchange rate;
• Cannot be purchased with fiat currency, cryptocurrency, or any other form of payment;
• Are not transferable between Participants or to third parties;
• Cannot be sold, bartered, exchanged, or assigned;
• Cannot be redeemed for cash except as expressly provided in connection with specific prizes;
• Do not constitute property, a financial instrument, a security, or a stored-value instrument under any applicable law;
• Expire or become void upon termination of the Campaign or the Participant's account, whichever occurs first.

4.4. Methods of earning Points. Points may be earned through the following activities, subject to the terms set forth in the respective sections of these Terms:

• Referrals (Section 5);
• Daily Missions (Section 6);
• One-Time Missions (Section 6);
• Milestones (Section 6);
• Streak bonuses (Section 6);
• Wheel Spins (Section 7);
• Level-up sharing bonuses;
• Any additional activities introduced by the Operator during the Campaign.

4.5. Level system. Each Participant's Level is derived from their Total Earned according to the following formula:

Cumulative Points required for Level L = 50L + 5L^2

A Participant's Level is computed as: L = floor((-50 + sqrt(2500 + 20 × Total Earned)) / 10)

Level determines a Participant's position on the All-Time Leaderboard and serves as a measure of Campaign engagement and status. The Level formula is applied uniformly to all Participants.

4.6. Adjustment of Point values. The Operator reserves the right, at its sole discretion and at any time, to:

• Modify the number of Points awarded for any Mission, Referral, Milestone, Wheel Spin segment, or other activity;
• Introduce new Point-earning activities or discontinue existing ones;
• Adjust the Level formula;
• Set or modify caps on the number of Points that may be earned through any single activity or within any time period.

Any material changes to Point values will be communicated to Participants through the Platform. Previously earned Points will not be retroactively adjusted.

5. Referral Program

5.1. Referral mechanics. Each Participant receives a unique Referral Code upon registration. When a new user registers for the Campaign using a Participant's Referral Code, the referring Participant earns Points according to the following two-tier structure:

Tier 1 (Direct Referral): The Participant earns one hundred (100) Points when a person they directly referred successfully registers for the Campaign.

Tier 2 (Second-Degree Referral): The Participant earns twenty (20) Points when a person referred by their Tier 1 Referral successfully registers for the Campaign.

5.2. Quality bonuses. In addition to the tiered referral Points, a Participant earns the following quality bonuses when their direct (Tier 1) Referral engages with the Campaign:

• First Mission bonus: Twenty-five (25) Points when a Tier 1 Referral completes their first Mission.
• First Referral bonus: Fifty (50) Points when a Tier 1 Referral generates their first successful Referral.

5.3. Referral Milestones. Participants earn bonus Points upon reaching cumulative referral Milestones, as follows:

The Operator reserves the right to modify Milestone thresholds and bonus values at any time, with prospective effect only.

5.4. Prohibited referral practices. The following referral practices are strictly prohibited:

• Self-referrals, including registering additional accounts using one's own Referral Code;
• Creating fake, fictitious, or bot accounts for the purpose of generating Referral Points;
• Distributing Referral Codes through unsolicited bulk email (spam), unsolicited bulk messaging, or any other method that violates applicable anti-spam legislation, including Regulation (EU) 2016/679 (GDPR) and Directive 2002/58/EC (ePrivacy Directive);
• Incentivizing Referrals through the promise or payment of monetary compensation outside of the Campaign mechanics;
• Misrepresenting the Campaign, its prizes, or the Operator in connection with Referral solicitations;
• Using paid advertising to promote Referral Codes without the prior written consent of the Operator.

5.5. Not multi-level marketing. The Referral Program is strictly limited to two (2) tiers of promotional attribution as described in Section 5.1. It does not constitute multi-level marketing, a pyramid scheme, or a chain referral scheme within the meaning of applicable consumer protection law. No Participant is required to make any financial investment, purchase any product or service, or pay any fee to participate in the Referral Program. Referral Points are awarded solely for valid registrations and related Campaign engagement mechanics, not for purchases.

5.6. Disqualification of fraudulent referrals. The Operator reserves the right, at its sole discretion, to:

• Void any Referral that the Operator determines, in its reasonable judgment, to have been generated through fraudulent, deceptive, prohibited, or invalid means;
• Deduct or correct Points awarded for voided Referrals from the Participant's Total Earned and Available Balance;
• Suspend or terminate the Campaign account of any Participant engaged in fraudulent referral activity, with forfeiture of all related Points and reward eligibility.

6. Missions

Daily Missions

6.1. Daily Mission structure. Each calendar day during Phase 1, Participants may complete the following Daily Missions:

The base daily total for completing all three (3) Daily Missions is fifty (50) Points. Upon completion of all three (3) Daily Missions in a single calendar day, the Participant additionally earns one (1) Raffle Ticket for the current Weekly Raffle.

6.2. Daily Check-in and Streaks. The Daily Check-in is performed by logging into the Platform. Upon check-in, the Participant's Streak counter is incremented by one (1). If a Participant fails to check in on a calendar day, their Streak resets to zero (0) on the following day. Streak bonuses are awarded as follows:

The Daily Check-in also grants the Participant one (1) free Wheel Spin, as described in Section 7.

6.3. Daily Quiz. Each day, the Platform presents a multiple-choice question related to cryptocurrency, artificial intelligence, or the Comforto platform. Participants earn twenty (20) Points for completing the quiz. The Operator determines quiz content at its sole discretion.

6.4. Social Mission. Each day, the Platform designates a social media post or content item for engagement. The Participant must engage with the content on the designated social media platform and submit a link to their engagement (e.g., comment URL, reply URL) as proof through the Platform. Social Mission submissions enter a pending verification status and are processed as follows:

• Submissions are auto-approved after a delay of approximately one (1) to two (2) hours;
• The Operator reserves the right to manually review, flag, reject, or reverse any Social Mission submission at any time;
• Fraudulent or low-quality submissions may result in Point reversal and further action under Section 12.

One-Time Missions

6.5. One-Time Missions. The following Missions may be completed once per Participant for the duration of the Campaign:

Activity Milestones

6.6. Activity Milestones. Participants earn bonus Points upon reaching cumulative daily mission completion Milestones:

Operator's Rights Regarding Missions

6.7. Modification of Missions. The Operator reserves the right, at its sole discretion, to:

• Add, remove, or modify Missions, including their descriptions, requirements, and Point values;
• Change the number, type, or frequency of Daily Missions;
• Modify verification criteria for Social Missions;
• Introduce new categories of Missions.

Changes will be communicated through the Platform. Points already earned through completed Missions will not be retroactively adjusted.

7. Wheel Spin

7.1. General. The Wheel Spin is a free promotional engagement mechanic within the Campaign. No real-money stake, purchase, or deposit is required to participate. The Wheel Spin is provided as an ancillary promotional feature of the Campaign.

7.2. Free daily spin. Each Participant receives one (1) free Wheel Spin per day, triggered upon completion of the Daily Check-in. The free spin is awarded as part of the Streak check-in flow described in Section 6.2.

7.3. Additional spins. Participants may acquire additional Wheel Spins by spending Available Points. The cost per additional spin is as set forth on the Platform (initially fifty (50) Points per spin). Additional spins are purchased with earned Points only; real-money purchases of spins are not available and are not permitted.

7.4. Wheel segments and probabilities. The Wheel consists of eight (8) segments with the following rewards and approximate probabilities:

7.5. Determination of results. Wheel Spin results are determined exclusively by a server-side random number generator (RNG) maintained by the Operator. The visual animation displayed on the Participant's device is illustrative only and does not influence the outcome. The Operator's server records shall be the sole and authoritative record of all Wheel Spin results.

7.6. Promotional nature. The Wheel Spin is intended to operate as a free ancillary promotional mechanic of the Campaign. Free spins are provided at no cost as part of Campaign participation, and additional spins, where available, may be acquired only through earned Points that have no cash value and cannot be purchased with real money. Nothing in these Terms is intended to offer or operate the Wheel Spin as gambling, a lottery, or any similar regulated activity.

8. Leaderboard

8.1. All-Time Leaderboard. The All-Time Leaderboard ranks all Participants by Level (derived from Total Earned). Since Level is a monotonic function of Total Earned, the All-Time Leaderboard is equivalent to ranking by Total Earned. The All-Time Leaderboard displays the top twenty-five (25) Participants globally and each Participant's neighborhood (approximately five (5) Participants above and five (5) below their own position).

8.2. Weekly Leaderboard. The Weekly Leaderboard ranks Participants by Levels gained during the current week. The Weekly Leaderboard resets each Monday at 00:00 UTC (or such other time as the Operator may designate). The Weekly Leaderboard determines eligibility for bonus Raffle Tickets as set forth in Section 9.2.

8.3. Display. Both Leaderboards display Participant Usernames, Levels, and rankings. The Participant's Available Points balance is never displayed to other Participants.

8.4. Anti-manipulation. Any attempt to artificially inflate Leaderboard position through prohibited conduct as described in Section 12 shall result in disqualification and forfeiture. The Operator reserves the right to:

• Remove Participants from the Leaderboard who are suspected of manipulation;
• Adjust rankings to account for disqualified or fraudulent accounts;
• Withhold prizes from Participants whose Leaderboard position is attributable to prohibited conduct.

9. Weekly Raffle

9.1. Classification. The Weekly Raffle is intended to operate as a free promotional prize draw conducted as part of the Campaign. No purchase, payment, deposit, or other monetary consideration is required to obtain Raffle Tickets. Raffle Tickets are earned through Campaign activities or through spending of earned Points that have no cash value and cannot be purchased.

9.2. How Raffle Tickets are earned. Participants may earn Raffle Tickets through the following means during each weekly cycle:

The maximum number of Raffle Tickets obtainable through Daily Missions, Leaderboard bonuses, and Points spending is seventeen (17) per week. Additional tickets may be earned through Streak bonuses and Wheel Spins.

9.3. Weekly cycle. Each Weekly Raffle operates on the following cycle:

• Monday (00:00 UTC): The Weekly Leaderboard resets. All Raffle Tickets from the preceding week are voided. A new weekly cycle begins.
• Monday through Saturday: Participants complete Missions, earn Points, and accumulate Raffle Tickets for the current week.
• Sunday: The Weekly Leaderboard locks. Bonus Raffle Tickets are awarded based on final Weekly Leaderboard positions. The Raffle draw is conducted. Winners are announced through the Platform.
• Following Monday: All Raffle Tickets are reset. No Raffle Tickets carry over to the following week.

9.4. Draw mechanism. Winners are selected through random selection among all valid Raffle Tickets issued for the relevant weekly cycle. Each valid Raffle Ticket represents one entry. A Participant holding multiple Raffle Tickets has a proportionally higher probability of selection. The selection is performed using a computerized random selection process maintained by the Operator.

9.5. Weekly Raffle prizes. Prizes for each Weekly Raffle are determined at the sole discretion of the Operator and may include merchandise, digital rewards, subscriptions, platform-related benefits, and other promotional items. Prize types and values may vary from week to week and are announced through the Platform. Unless the Operator expressly states otherwise, Weekly Raffle prizes are recurring promotional rewards whose fulfilment, delivery, or redemption may occur during Phase 1 or at a later stage designated by the Operator, subject to eligibility checks, verification where required, and these Terms.

9.6. Ticket void. Raffle Tickets that are not drawn in a given week are voided at the start of the next weekly cycle. There is no accumulation or carry-over of Raffle Tickets between weekly cycles.

10. Rewards and Prizes

Prize Structure

10.1. General structure. The Campaign may include the following categories of rewards or benefits:

• Recurring promotional rewards connected to ongoing Campaign mechanics, including Weekly Raffles or similar recurring promotions;
• Milestone-based rewards or "Sure Prizes" unlocked during Phase 1;
• A future promotional reward pool or later-stage reward allocation connected to Phase 2, as announced by the Operator.

10.2. The Operator may make available recurring promotional rewards during Phase 1, including merchandise, subscriptions, digital rewards, gift cards, platform-related perks, or other campaign incentives. The specific type, value, quantity, and timing of such rewards may vary and may be announced on the Platform.

10.3. Sure Prizes. Sure Prizes are milestone-based promotional rewards that may become unlocked when a Participant reaches a milestone designated by the Operator. Sure Prize values and categories are as displayed on the Platform at the time the relevant milestone is achieved. A Sure Prize is regarded as locked only once the relevant milestone has been validly achieved and recorded in the Participant's Campaign account.

10.4. Big Prize Pool / future reward pool. The Campaign may refer to a future aggregate reward pool, currently advertised with a stated promotional value of up to USD $500,000, expected to be connected to Phase 2. The final categories, composition, allocation methodology, timing, and eligibility rules for any such future reward pool may be announced, amended, or further specified by the Operator closer to launch.

10.5. Rewards may include physical items, digital rewards, subscriptions, travel-related rewards, consumer electronics, experience-based rewards, platform-related benefits, gift cards, software/tool subscriptions, and other promotional items designated by the Operator.

10.6. Token-related rewards. Certain future rewards may, if separately announced by the Operator, include token-based or digital-asset-related benefits. Any such reward remains subject to separate legal review, separate terms where applicable, and all legal and regulatory requirements in force at the relevant time. Nothing in these Terms constitutes an offer to sell, issue, subscribe for, purchase, or invest in any token, crypto-asset, security, or financial product.

10.7. Claiming and fulfilment. Unless expressly stated otherwise by the Operator for a specific reward, rewards are not automatically transferred during Phase 1. Claiming, fulfilment, redemption, delivery, or activation of rewards may occur only at the time, in the manner, and under the conditions separately specified by the Operator, including during Phase 2 where applicable.

10.8. The Operator may require identity verification, eligibility verification, fraud-prevention review, jurisdictional checks, or other compliance checks before fulfilling, delivering, or releasing a reward. Such verification is not a condition of ordinary participation in Phase 1, but may be required at the reward-claim stage or in connection with later onboarding to the live platform.

10.9. No guaranteed Phase 2 entitlement. Participation in Phase 1, accumulation of Points, Leaderboard position, Referrals, or the unlocking of campaign status does not by itself guarantee successful onboarding to the live platform, eligibility to receive all future rewards, or eligibility to receive token-based rewards in any jurisdiction.

10.10. Prize substitution. The Operator reserves the right to substitute any reward with another reward of equal or greater reasonable promotional value where necessary due to availability, legal, regulatory, operational, or fulfilment reasons.

10.11. Tax responsibility. Each Participant is solely responsible for all taxes, duties, levies, and other public charges arising from the receipt of any reward, in accordance with applicable law.

10.12. Non-transferability. Unless expressly stated otherwise by the Operator, rewards are non-transferable, non-exchangeable for cash, and non-substitutable at the Participant's request.

10.13. Forfeiture. A Participant forfeits reward eligibility if: the Participant's account is terminated for breach of these Terms; the Participant fails to complete required verification within the timeframe specified by the Operator; the Participant fails to satisfy the conditions applicable to the specific reward; or the Participant is found to have engaged in prohibited conduct under Section 12.

11. Phase 1 to Phase 2 Transition

11.1. Phase 1 and Phase 2 are separate stages. Phase 1 is a standalone pre-launch promotional campaign. Phase 2, if launched, is expected to be connected to the live Comforto platform and may involve separate onboarding, identity verification, and acceptance of separate platform terms.

11.2. No automatic platform account. Participation in Phase 1 does not create a user account on the live Comforto platform and does not create a contractual relationship for platform services.

11.3. Upon conclusion of Phase 1: the Operator may lock and record each Participant's final Campaign status, including Points, rank, milestone achievements, or other relevant Campaign metrics; no further Points may be earned through Phase 1 mechanics unless otherwise announced by the Operator; the Operator may use the recorded Phase 1 status as one of the inputs for later benefits, reward allocation logic, or onboarding priority, if so announced.

11.4. If Phase 2 is launched, it may include: access to the live Comforto platform; separate registration and onboarding steps; identity verification or other compliance checks; separate platform terms and other legal documentation; later-stage reward claiming or fulfilment; new points, loyalty, or engagement mechanics connected to actual platform usage.

11.5. No one-to-one carry-over. Unless expressly announced otherwise by the Operator, Phase 1 Points do not carry over on a one-to-one numerical basis into Phase 2. The Operator may, however, recognize Phase 1 rank, status, or unlocked benefits in a different form during Phase 2.

11.6. The Operator intends, but does not guarantee, to launch Phase 2. The timing, scope, feature set, onboarding structure, reward logic, and availability of Phase 2 may be determined, postponed, modified, staged, or cancelled at the Operator's discretion.

11.7. If Phase 2 is materially delayed, materially changed, staged differently than originally anticipated, or not launched at all, the Operator may determine alternative arrangements for reserved rewards or later-stage benefits and will communicate any material decision through the Platform or by email.

12. Prohibited Conduct

12.1. Prohibited activities. Participants shall not engage in any of the following activities:

• Creating, operating, or maintaining multiple Campaign accounts;
• Using bots, scripts, macros, automated tools, browser extensions, or any other software or technology to automate interactions with the Platform, complete Missions, spin the Wheel, or earn Points;
• Generating fake, fraudulent, or fictitious Referrals, including self-referrals;
• Distributing Referral Codes through unsolicited bulk communications (spam);
• Manipulating or attempting to manipulate the Leaderboard, Raffle, Wheel Spin, or any other Campaign mechanism through technical means, collusion, or other deceptive practices;
• Exploiting bugs, glitches, vulnerabilities, or errors in the Platform, whether known or unknown, to gain an unfair advantage or to earn Points, Raffle Tickets, or prizes to which the Participant would not otherwise be entitled;
• Selling, trading, purchasing, or offering to sell, trade, or purchase Campaign accounts, Points, Raffle Tickets, or prizes;
• Impersonating another Participant, the Operator, or any third party;
• Submitting false, misleading, or fraudulent Social Mission proofs;
• Circumventing or attempting to circumvent geographic restrictions, eligibility requirements, or KYC requirements;
• Engaging in any activity that violates applicable law, regulation, or these Terms;
• Interfering with the proper operation of the Platform, including denial-of-service attacks, injection attacks, or other security exploits;
• Reverse-engineering, decompiling, or disassembling any component of the Platform.

12.2. Consequences. Upon determination, at the Operator's sole discretion, that a Participant has engaged in prohibited conduct, the Operator may take one or more of the following actions:

• Issue a warning to the Participant;
• Deduct Points, including from Total Earned, attributable to the prohibited conduct;
• Void Raffle Tickets earned through prohibited conduct;
• Suspend the Participant's account temporarily or indefinitely;
• Permanently terminate the Participant's account;
• Disqualify the Participant from current and future Raffles;
• Forfeit all accrued Points, Raffle Tickets, Sure Prizes, and other prize eligibility;
• Pursue legal remedies available under applicable law.

The Operator's determination of prohibited conduct is made in its sole discretion and is final. The Operator is not required to provide prior notice or an opportunity to cure before taking action under this Section 12.2.

12.3. Reporting. Participants are encouraged to report suspected prohibited conduct by other Participants to the Operator at support@coingarage.io. Reports may be submitted anonymously.

13. Intellectual Property

13.1. Operator's intellectual property. All intellectual property rights in and to the Platform, including but not limited to the Comforto name, logo, branding, Comfy mascot, Campaign design, software, content, and materials, are and shall remain the exclusive property of the Operator or its licensors. No right, title, or interest in the Operator's intellectual property is transferred to any Participant by virtue of participation in the Campaign.

13.2. User-generated content. By submitting any content to the Platform (including Social Mission proofs, Usernames, and any other user-generated material), the Participant: represents and warrants that they own or have the necessary rights to the submitted content; grants the Operator a worldwide, non-exclusive, royalty-free, sublicensable, transferable license to use, reproduce, modify, display, distribute, and create derivative works of the submitted content for purposes related to the Campaign, the Platform, and the Operator's promotional activities; acknowledges that this license survives termination of the Participant's account and the Campaign.

13.3. Share cards and generated content. The Platform may generate shareable images, cards, or other content incorporating the Participant's Campaign data (such as Level, rank, and referral information) combined with Comforto branding. Participants are granted a limited, non-exclusive, revocable license to share such generated content on social media and other platforms for personal, non-commercial purposes in connection with the Campaign. This license does not extend to modifying the Operator's branding or trademarks.

14. Privacy and Data Protection

14.1. Privacy Policy. The collection, processing, and storage of personal data in connection with the Campaign is governed by the Operator's Privacy Policy, available at Privacy Policy. The Privacy Policy forms an integral part of these Terms. By participating in the Campaign, each Participant confirms that they have read and understood the Privacy Policy.

14.2. Data collected. In connection with the Campaign, the Operator may collect and process the following categories of personal data: email address (registration and authentication); username (selected by the Participant); campaign activity data (Missions completed, Points earned, Referrals generated, Wheel Spin results, Leaderboard positions, Raffle participation); referral relationships; IP address and device information (for security, fraud prevention, and analytics); communication records (support inquiries, reports under Section 12.3). Where later required for reward fulfilment, fraud prevention, eligibility verification, or later onboarding, identity or verification data requested by the Operator.

14.3. Legal basis. The Operator processes personal data on the following legal bases under Regulation (EU) 2016/679 (GDPR): performance of a contract (processing necessary for administration of the Campaign under these Terms); legitimate interests (processing necessary for fraud prevention, security, analytics, abuse prevention, and improvement of the Campaign); consent (processing based on the Participant's explicit consent, where applicable); legal obligation (processing required by law where identity verification, sanctions screening, tax handling, or other mandatory compliance obligations apply at the reward-claim stage or in connection with later onboarding).

14.4. GDPR rights. Participants have the right to access, rectify, erase, restrict processing, port their data, and object to processing, as provided under GDPR. Requests should be directed to support@coingarage.io or through the mechanism specified in the Privacy Policy.

14.5. Data retention. Personal data is retained for the duration of the Campaign and for such additional period as required by applicable law or necessary for the Operator's legitimate interests (including fraud prevention and dispute resolution). Specific retention periods are set forth in the Privacy Policy.

14.6. Email communications. By registering for the Campaign, the Participant consents to receiving transactional and Campaign-related email communications from the Operator (e.g., magic link authentication, prize notifications, Campaign updates). Marketing communications are sent only with the Participant's separate consent and include an unsubscribe mechanism, in compliance with Directive 2002/58/EC (ePrivacy Directive) and applicable national law.

15. Limitation of Liability

15.1. Platform availability. The Operator provides the Platform on an "as is" and "as available" basis. The Operator does not guarantee uninterrupted, error-free, or secure access to the Platform. Scheduled and unscheduled maintenance, technical failures, network issues, and other events may result in temporary unavailability of the Platform or its features.

15.2. No guarantee of results. The Operator does not guarantee any particular outcome, reward, or result from participation in the Campaign. Leaderboard positions, Raffle outcomes, and Wheel Spin results are determined by the Campaign mechanics and, where applicable, randomized selection processes.

15.3. Token value fluctuations. To the extent that any prize consists of or is denominated in COMFY Tokens or other digital assets, the Operator is not responsible for fluctuations in the market value of such tokens. The value of digital assets is inherently volatile and may increase or decrease after the time of distribution. The Operator makes no representation or guarantee regarding the future value of any token-based prize.

15.4. Technical errors. In the event of a technical error affecting a Raffle draw, Wheel Spin, Points calculation, or other Campaign mechanism, the Operator's sole obligation is to make commercially reasonable efforts to correct the error. The Operator may, at its sole discretion, void affected results and conduct a new draw or calculation.

15.5. Maximum liability. To the maximum extent permitted by applicable law, the Operator's aggregate liability to any Participant arising out of or in connection with the Campaign, whether in contract, tort (including negligence), strict liability, or otherwise, shall not exceed the greater of: (a) the value of prizes actually claimed and received by that Participant; or (b) one hundred euros (EUR 100).

15.6. Exclusion of certain damages. To the maximum extent permitted by applicable law, the Operator shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of profits, loss of data, loss of opportunity, or damage to reputation, arising out of or in connection with the Campaign.

15.7. Force majeure. The Operator shall not be liable for any failure or delay in performing its obligations under these Terms to the extent that such failure or delay is caused by events beyond the Operator's reasonable control, including but not limited to: natural disasters, epidemics, pandemics, war, terrorism, civil unrest, government actions, sanctions, regulatory changes, power outages, telecommunications failures, cyberattacks, and disruptions to third-party services.

15.8. Consumer rights preserved. Nothing in this Section 15 shall be construed to limit or exclude the Operator's liability to the extent that such limitation or exclusion is prohibited by mandatory provisions of applicable law, including but not limited to mandatory provisions of the Czech Civil Code (Act No. 89/2012 Coll.) and Directive 2011/83/EU (Consumer Rights Directive).

16. Modification and Termination

Modification

16.1. Right to modify Terms. The Operator reserves the right to modify these Terms at any time. Material modifications will be communicated to Participants through the Platform and/or by email to the registered email address at least seven (7) calendar days before they take effect, unless a shorter notice period is required by law or urgent circumstances.

16.2. Acceptance of modified Terms. Continued participation in the Campaign after the effective date of any modification constitutes acceptance of the modified Terms. A Participant who does not agree with a modification may withdraw from the Campaign by discontinuing participation and, if applicable, by requesting account deletion.

16.3. Modification of Campaign mechanics. Without limiting Section 16.1, the Operator reserves the right to modify at any time, with or without prior notice:

• Point values for Missions, Referrals, Milestones, and other activities;
• Mission types, frequency, and content;
• Wheel Spin segment probabilities and rewards;
• Raffle mechanics, ticket earning methods, and prize compositions;
• Leaderboard calculation methods and display;
• Level system formula and progression;
• Any other Campaign mechanic or feature.

Where practicable, the Operator will provide advance notice of material changes to Campaign mechanics through the Platform.

Termination of the Campaign

16.4. Right to suspend or terminate. The Operator reserves the right to suspend or terminate the Campaign, in whole or in part, at any time and for any reason, including but not limited to: regulatory or legal requirements; technical or operational issues; insufficient participation; commercial considerations; force majeure events.

16.5. Effect of Campaign termination. In the event of Campaign termination:

• The Operator will make commercially reasonable efforts to provide advance notice through the Platform;
• Points earned prior to termination may be honored for prizes earned and verified before the termination date, at the Operator's discretion;
• Sure Prizes earned and confirmed prior to termination will be honored, subject to the Operator's ability to fulfill them;
• Raffle Tickets for incomplete weekly cycles will be voided;
• The Operator's obligations under these Terms shall survive termination only to the extent expressly stated herein.

Termination of Individual Participation

16.6. Right to terminate individual participation. The Operator reserves the right to suspend or terminate any individual Participant's account and participation at any time, with or without cause, including for violation of these Terms.

16.7. Effect on Points and prizes. Upon termination of an individual Participant's account:

• If terminated for cause (violation of these Terms): all Points, Raffle Tickets, and prize eligibility are forfeited;
• If terminated without cause by the Operator: the Participant retains eligibility for prizes already earned and verified prior to termination, subject to compliance with KYC requirements;
• If the Participant voluntarily withdraws: the Participant forfeits all Points, Raffle Tickets, and unclaimed prizes.

17. Dispute Resolution

17.1. Governing law. These Terms and any dispute arising out of or in connection with them shall be governed by and construed in accordance with the laws of the Czech Republic, without regard to its conflict of laws principles.

17.2. Jurisdiction. Subject to mandatory consumer protection provisions of applicable law, any dispute arising out of or in connection with these Terms that is not resolved through the good faith resolution process described in Section 17.3 shall be submitted to the exclusive jurisdiction of the courts of the Czech Republic.

17.3. Good faith resolution. Before commencing any formal proceedings, the parties shall attempt to resolve any dispute in good faith through direct communication. A Participant with a complaint or dispute shall first contact the Operator at support@coingarage.io with a clear description of the issue. The Operator will acknowledge receipt within ten (10) business days and will make commercially reasonable efforts to resolve the matter within thirty (30) calendar days of receipt.

17.4. Consumer protection. Nothing in these Terms shall deprive a Participant who qualifies as a consumer under applicable law of the protection afforded by mandatory provisions of the law of their habitual residence, in accordance with Regulation (EC) No. 593/2008 (Rome I) Article 6. Participants who are consumers within the meaning of Directive 2011/83/EU (Consumer Rights Directive) retain all rights afforded to them under that Directive and its national implementing legislation, including the right to seek redress before the courts of their Member State of domicile.

17.5. Consumer complaint mechanisms. Participants who qualify as consumers may also use any out-of-court consumer complaint or dispute-handling mechanisms available under applicable law.

18. Miscellaneous

18.1. Severability. If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be modified to the minimum extent necessary to render it valid and enforceable, or if modification is not possible, severed from these Terms. The invalidity, illegality, or unenforceability of any provision shall not affect the validity, legality, or enforceability of the remaining provisions.

18.2. Entire agreement. These Terms, together with the Privacy Policy and any supplemental terms published on the Platform, constitute the entire agreement between the Operator and each Participant with respect to the Campaign and supersede all prior or contemporaneous communications, representations, or agreements, whether oral or written, relating to the Campaign.

18.3. Waiver. The failure of the Operator to enforce any provision of these Terms shall not constitute a waiver of such provision or the right to enforce it at a later time. A waiver of any provision is effective only if made in writing and signed by an authorized representative of the Operator.

18.4. Assignment. The Operator may assign or transfer its rights and obligations under these Terms, in whole or in part, to any affiliate, successor, or acquirer without the Participant's consent. The Participant may not assign or transfer their rights or obligations under these Terms without the Operator's prior written consent.

18.5. Language. These Terms are drafted in English. In the event of any discrepancy between the English version and any translation, the English version shall prevail.

18.6. No employment or agency relationship. Nothing in these Terms creates an employment, agency, partnership, joint venture, or franchise relationship between the Operator and any Participant.

18.7. Notices. Notices to Participants will be provided through the Platform, by email to the registered email address, or by such other means as the Operator deems appropriate. Notices to the Operator should be directed to support@coingarage.io.

18.8. Contact information.

Coingarage s.r.o.
Krakovská 583/9, Nové Město
110 00 Prague
Czech Republic
Company ID: 11667974
Email: support@coingarage.io

Annex A - Excluded Territories

The following territories are excluded from Campaign participation pursuant to Section 2.2:

1. United States of America (including territories and possessions)
2. Democratic People's Republic of Korea (North Korea)
3. Islamic Republic of Iran
4. Syrian Arab Republic
5. Republic of Cuba
6. Republic of the Sudan
7. Crimea region (Ukraine)
8. Indonesia
9. Nigeria
10. India
11. Bangladesh
12. Vietnam

This list may be updated by the Operator in accordance with applicable EU, UN, and Czech national sanctions lists.

Annex B - Sure Prize Schedule

The following Milestones qualify for Sure Prizes. Specific prize values are as displayed on the Platform at the time the Milestone is achieved.

This schedule may be updated by the Operator. The current schedule is always available on the Platform.