General Terms and Conditions

v1.0.0 · 15 March 2026

1. Introduction

These General Terms and Conditions (hereinafter: the "GTC") govern the conditions for the use of the digital infrastructure, website, smart contracts, token pre-sale, vesting mechanism, and all related functional and technical elements connected to The Penguin Coin crypto-asset project (hereinafter: the "Project") (hereinafter collectively: the "Service").

The purpose of these GTC is to set out, within transparent, detailed, and legally clear frameworks, the content of the legal relationship between the Service Provider and the User, the rights and obligations of the parties, the rules of liability, as well as the risks and conditions related to the use of the Service.

The term "Service" used in these GTC is a contractual-technical collective term referring to the entirety of the digital system, infrastructure, and technical solutions related to the operation of the Project. The use of this term does not affect the legal qualification of the activity under the applicable laws.

The The Penguin Coin token issued within the framework of the Project (hereinafter: the "Token") is a blockchain-based digital asset serving meme-related, community, and experimental purposes. Point 4.2 of these GTC shall govern the legal qualification of the Token, its classification under MiCA, as well as the detailed rules regarding the rights attached to the Token (and the rights not arising from it). The statements regarding legal qualification are based on the Service Provider's current interpretation and do not constitute any official classification, authorization, or approval by a competent authority.

The Service Provider operates a Governance mechanism as defined in point 7.5 of these GTC, which provides voting functionality on the website exclusively to successfully registered Users.

The Governance may extend exclusively to the use of the Tokens placed in the Treasury and issued by the Service Provider, as well as to certain technical or operational matters of the Project.

The Governance does not qualify as a voting right in the corporate law sense, does not create any ownership relationship, does not grant any right to dividends or profit-sharing, and does not result in any right of control over the Service Provider.

In the course of its operation, the Service Provider shall act in compliance with the applicable laws of the European Union and Hungary, including in particular the rules relating to crypto-assets, electronic commerce, consumer protection, and taxation.

These GTC do not constitute any official approval, authorization, or regulatory qualification, and the Token does not benefit from any special official guarantee or investor protection safeguard.

The use of the Service is based exclusively on the User's voluntary decision. The Service Provider does not provide investment, financial, legal, or tax advice and does not carry out crypto-asset service provider activities (Crypto-Asset Service Provider – CASP) under Regulation (EU) 2023/1114 (MiCA), in particular it does not provide:

• crypto-asset custody and administration services,
• operation of a trading platform,
• exchange of crypto-assets,
• execution or transmission of orders,
• portfolio management,
• investment advice.

The information published on the website, in the white paper, in marketing materials, on social media, or through any communication channel is for information purposes only and does not constitute an investment offer, investment solicitation, financial promotion, or promise of return.

By using the Service, the User expressly acknowledges and accepts that:

• acquiring the Token grants a vesting position (a future on-chain delivery entitlement), and the transfer of the Tokens to the User's Wallet shall take place via smart contract based on the cliff and vesting schedule set out in Chapter 8 of these GTC;
• the acquisition and holding of the Token may involve significant technological, market, and regulatory risks;
• following the closing of the Pre-sale, the Service Provider undertakes, pursuant to point 8.2.3 of these GTC, to ensure the technical tradability of the Token on a DEX (by creating a liquidity pool); the timing and conditions of performance are set out in Chapter 8, and circumstances beyond reasonable control as defined therein may delay implementation;
• the Service Provider shall be liable for delays or failures resulting from such circumstances only to the extent permitted by law;
• the Service Provider does not guarantee the size of the liquidity pool, the duration of its maintenance, the trading volume, the stability of the price, or the future liquidity of the Token;
• decentralized trading is market-based, and its price is determined exclusively by supply and demand;
• acquiring the Token does not guarantee future profit, increase in value, or liquidity;
• the User declares that they comply with the applicable jurisdictional and compliance requirements, with particular regard to the exclusions and restrictions set out in Chapter 6 of these GTC;
• the use of the Service is based on the User's own decision and assumption of risk;
• the Service Provider shall not be liable for changes in the market value of the Token, the development of supply and demand, price volatility resulting from the specific characteristics of the decentralized trading environment, or the operation of third parties, including in particular the blockchain network, external protocols, or decentralized platforms;
• the liability of the Service Provider may be limited exclusively to the extent permitted by applicable law, and the limitation of liability shall not affect liability for damage caused intentionally or with gross negligence, or liability in cases where it cannot be excluded by law;
• the Service does not constitute investment or financial advice.

The operation of blockchain-based systems involves technological, cybersecurity, and market risks. The Service Provider shall not be liable for disruptions and damages resulting from the operation of blockchain networks operated by third parties, external protocols, infrastructure providers, or force majeure events.

In connection with any defects in smart contracts developed by the Service Provider or operated by it, the Service Provider limits its liability to the extent permitted by the relevant laws; such limitation of liability shall not extend to damages caused intentionally or with gross negligence, or to cases in which the exclusion of liability is not valid under the law.

If the User does not agree with any provision of these GTC, they shall refrain from using the Service.

2. Definitions

For the purposes of these GTC, the following terms shall have the meanings set out below:

2.1. MiCA Regulation

"MiCA Regulation": Regulation (EU) 2023/1114 of the European Parliament and of the Council on markets in crypto-assets. The terms used in these GTC that are defined in the MiCA Regulation shall, unless otherwise provided, have the meanings set out in the MiCA Regulation.

2.2. Crypto-asset

"Crypto-asset": a digital representation of value or rights within the meaning of Article 3(1), point 5 of the MiCA Regulation, which may be transferred and stored electronically using distributed ledger technology (DLT) or similar technology.

2.3. Token (The Penguin Coin)

"Token": the crypto-asset named The Penguin Coin, issued by the Service Provider on the BASE network (Ethereum Layer 2 infrastructure). The Token:

• does not embody any ownership interest, claim, or promise of return;
• does not entitle its holder to dividends or interest;
• does not create any membership or governance relationship under corporate law;
• does not qualify as a financial instrument within the meaning of Directive 2014/65/EU (MiFID II).

2.4. Service Provider

"Service Provider": the legal entity defined in Chapter 3 of the GTC, which issues the Token and operates the Digital system.

2.5. User

"User": a natural person who has reached the age of 18 and participates in the Pre-sale or uses the Digital system in their own name and at their own responsibility.

2.6. Asset-referenced token (ART)

"Asset-referenced token" or "ART": a type of crypto-asset within the meaning of Article 3(1), point 6 of the MiCA Regulation. In the Service Provider's view, the "The Penguin Coin" Token does not qualify as an asset-referenced token.

2.7. E-money token (EMT)

"E-money token" or "EMT": a type of crypto-asset within the meaning of Article 3(1), point 7 of the MiCA Regulation. In the Service Provider's view, the "The Penguin Coin" Token does not qualify as an e-money token.

2.8. Pre-sale

"Pre-sale": the time-limited and quantity-limited pre-sale phase of the Token, during which the User may acquire entitlement to the future allocation of Tokens in accordance with the terms of these GTC.

2.9. Stage

"Stage": a sales phase of the Pre-sale with a defined duration and linked to a predetermined quantity of Tokens.

2.10. Vesting

"Vesting": a blockchain-based technical mechanism that determines the method and timing schedule of the transfer to Users of Tokens acquired within the framework of the Pre-sale or Giveaway.

Under the Vesting mechanism:

• the Tokens are not transferred immediately to the User's Wallet;
• a technical entitlement relating to a future transfer of Tokens ("vesting position") is recorded for the User;
• the transfer of the Tokens on the blockchain is automatically carried out by the Smart Contract (including, where applicable, a separate vesting contract) in accordance with the predetermined conditions and schedule.

Vesting is exclusively a technical mechanism and does not qualify as a custody arrangement, fiduciary asset management, repayment undertaking, or financial service.

2.11. On-chain transfer

"On-chain transfer": the technical crediting of the Token on the blockchain to the Wallet address provided by the User.

2.12. Ensuring the technical tradability of the Token (DEX)

"Ensuring the technical tradability of the Token": enabling the Token to be exchanged on a decentralized exchange (DEX), in particular through the creation of a liquidity pool.

2.13. DEX (Decentralized Exchange)

"DEX": a decentralized, smart contract-based crypto-asset trading system that enables the exchange of crypto-assets without a central intermediary.

2.14. CEX (Centralized Exchange)

"CEX": a centrally operated crypto-asset trading platform run by a third party.

2.15. Liquidity pool

"Liquidity pool": a smart contract-based pool of assets operating on a decentralized exchange, which enables the automatic exchange of crypto-assets according to a predetermined algorithm.

2.16. Secondary market

"Secondary market": Token trading carried out between third parties following the closing of the Pre-sale.

2.17. Wallet

"Wallet": a blockchain-compatible digital wallet suitable for receiving, storing, and transferring crypto-assets. The unique blockchain identifier belonging to the Wallet is the "wallet address", to which the on-chain transfer of the Token is made.

2.18. Smart Contract

"Smart Contract": self-executing program code running on a blockchain, related to the issuance of the Token, the Vesting mechanism, and the related technical processes.

2.19. Gas fee

"Gas fee": the network fee payable for a transaction executed on the blockchain network.

2.20. Hard fork

"Hard fork": a significant modification of the blockchain protocol that may result in a break in the compatibility of the network.

2.21. Oracle

"Oracle": a technical solution or external data source that provides off-chain data to the Smart Contract.

2.22. Know Your Customer (KYC)

"Know Your Customer" or "KYC": the set of customer identification, identity verification, and compliance screening procedure(s), the purpose of which is in particular to identify the User, verify the data provided, and assess compliance with the applicable legal and compliance requirements. The KYC procedure may be carried out directly by the Service Provider and/or with the involvement of a third-party service provider engaged by the Service Provider.

2.23. AML

"AML" (Anti-Money Laundering): the set of compliance measures aimed at preventing money laundering and terrorist financing.

2.24. Sanctions list

"Sanctions list": a restrictive measures list published by the European Union, the United Nations, or another competent authority.

2.25. Giveaway

"Giveaway": a promotional Token distribution mechanism under which certain Users may receive Tokens or NFTs upon fulfilling specified conditions.

2.26. NFT

"NFT" (Non-Fungible Token): a blockchain-based digital asset with a unique identifier that is non-interchangeable.

2.27. Leaderboard

"Leaderboard": a ranking system used within the Giveaway that may establish eligibility based on Users' activity.

2.28. Excluded Jurisdiction

"Excluded Jurisdiction": a country or territory where the sale of the Token or participation in the Pre-sale is prohibited or restricted by law.

3. Service Provider Details

3.1. Company Details

Name of the Service Provider: AURIS Technologies Limited Liability Company Legal form: Limited Liability Company (Kft.) Country of the Service Provider: Hungary Registered office: 2093 Budajenő, Pátyi utca 49. Company registration number / record number: 13-09-245633 Registering authority: Company Registry Court of the Budapest-Environs Regional Court Tax number: 32997457-1-13

The Service Provider acts as an independent legal entity. The contractual relationship established under these GTC is created exclusively between the Service Provider and the User.

3.2. Contact Details

Contact email address(es): info@thepenguincoin.com or info@aurisnet.io Official website: https://thepenguincoin.com The Service Provider handles and responds to user inquiries electronically. The Service Provider investigates complaints in accordance with the applicable consumer protection laws.

3.3. Legal Status of the Service Provider

The Service Provider issues a digital token (The Penguin Coin) and operates the related online infrastructure and technical solutions, including in particular: the pre-sale of the token (Pre-sale), promotional programs (e.g. Giveaway), the operation of Smart Contract mechanisms related to the token.

The Service Provider is both the issuer of the token and the organizer of the public offering (Pre-sale). Point 4.2 of these GTC shall govern the legal qualification of the Token, its classification under MiCA, as well as the rights attached to the Token (and the rights not arising from it). The Service Provider does not hold a credit institution, financial enterprise, investment services, or fund management license, and does not carry out any such licensed activity. The Service Provider does not provide investment, financial, or legal advice. The issuance of the Token qualifies as a crypto-asset issuance falling within the scope of Regulation (EU) 2023/1114 of the European Parliament and of the Council (MiCA Regulation). The Service Provider shall act in accordance with the disclosure and information obligations prescribed by the MiCA Regulation for the relevant category of the Token, including the preparation and publication of the white paper relating to the crypto-asset issuance. The legal qualification of the crypto-asset is in all cases subject to the applicable laws and the interpretation of the competent supervisory authority. Any community-based or platform-level voting mechanism (Governance) available within the framework of the Project does not qualify as corporate decision-making and does not create any ownership or financial entitlement.

3.4. Involvement of Third Parties

The Service Provider is entitled to involve third parties in certain technical, administrative, compliance, or IT processes of the Service. In particular, but not limited to, the following service providers may be engaged:

• blockchain infrastructure providers,
• Smart Contract developers and audit service providers,
• hosting and cloud service providers,
• payment processing service providers (e.g. crypto payment infrastructure),
• invoicing and accounting service providers,
• registration and identification (KYC) service providers,
• anti-money laundering (AML) compliance service providers,
• analytics, monitoring, and security service providers,
• marketing and communication partners.

Blockchain transactions are carried out through a decentralized network over which the Service Provider does not exercise full control. The involvement of third parties does not in itself create a direct contractual relationship between the User and the third party; such a relationship may arise in particular if the User accepts the third party's own terms and conditions.

4. Nature of the Service and Legal Qualification

4.1. Nature of the Project and the Token

The „The Penguin Coin" Project is a blockchain-based digital infrastructure implementing a community-based, experimental, and meme-type crypto-asset issuance on the BASE network. The Token is a blockchain-based crypto-asset serving a community and meme-related function. The Project does not qualify as an investment program, collective investment scheme, investment fund, alternative investment fund, or any kind of financial arrangement. In the Service Provider's view, the acquisition of the Token does not qualify as an investment. The User participates in the Pre-sale based on their own decision and assumption of risk, acknowledging that the Token does not provide any promise of return or any entitlement to financial yield. The payment made during the Pre-sale does not result in the immediate transfer or delivery of the Token. The User may become entitled to the future allocation of the Token through the vesting mechanism if the conditions set out in Chapter 8 of these GTC are fulfilled.

4.2. Legal Qualification

The Token:

• in the Service Provider's view, does not qualify as a financial instrument;
• does not qualify as a security;
• does not qualify as electronic money;
• does not qualify as an asset-referenced token (ART);
• does not qualify as an e-money token (EMT);
• does not qualify as a collective investment scheme or an alternative investment fund;
• does not represent any ownership interest in the Service Provider;
• does not create any claim against the Service Provider;
• does not entitle its holder to dividends, revenue, profit-sharing, or any kind of financial return.

In the Service Provider's view, the Token may be classified as an "other crypto-asset" under Regulation (EU) 2023/1114 (MiCA), as it does not qualify as an asset-referenced token (ART), does not qualify as an e-money token (EMT), and does not embody a financial instrument. This classification is based on the current interpretation of the characteristics of the Token and does not constitute any official classification, authorization, or approval. The acquisition of the Token does not create an investment relationship between the Service Provider and the User and does not establish any entitlement to financial return or yield. The Token does not grant any governance, corporate, or ownership rights over the Service Provider.

4.3. Legal Nature of the Treasury

The treasury created within the framework of the Project primarily serves for the management of The Penguin Coin Tokens issued by the Service Provider; however, it may also contain other blockchain-based assets that are technically necessary for its operation, including in particular native blockchain assets required for the payment of network transaction fees (gas fees). The management of the Tokens placed in the treasury serves exclusively technical and operational purposes related to the functioning of the Project. The operation of the treasury: does not qualify as investment fund management; does not qualify as portfolio management or asset management service; does not qualify as custody service; does not result in a financial services relationship.

The Tokens placed in the treasury do not constitute collective investment assets composed of funds paid by Users.

4.4. Price, Liquidity, and Tradability

The Service Provider undertakes to create a liquidity pool in order to ensure the technical tradability of the Token on a decentralized exchange (DEX). The detailed terms and deadlines of this undertaking are set out in Chapter 8 of these GTC. The Service Provider's obligation extends exclusively to the technical creation of the liquidity pool; the possibility of trading on the decentralized market, the level of liquidity, and the development of the price are based on market factors. The Service Provider does not provide any guarantee regarding: – the depth of the liquidity pool, – the volume of secondary market trading, – the stability of the price, – the continuation of market demand, – the continuous maintenance of the liquidity pool or the participation of third parties.

Decentralized trading is market-based, and its price is determined exclusively by supply and demand.

4.5. Exclusion of Advice

The Service Provider does not provide investment, financial, legal, or tax advice. The published information is for information purposes only and does not constitute an investment offer or promise of return.

5. Risk Disclosure

5.1. General Risks

The User acknowledges and accepts that the acquisition, holding, and use of the Token may involve numerous risks, including, but not limited to, the following: the price of the Token may fluctuate extremely; the User may lose all or part of the consideration paid for acquiring the Token; the Service Provider does not provide any guarantee regarding the depth of the liquidity pool; there is a risk of technological, smart contract, blockchain, or network errors affecting the operation of the Project, the Token, or the treasury; the operation of the Project and the possible tradability of the Token may be affected by regulatory changes or legal restrictions; the acquisition of the Token does not establish any entitlement to financial return or yield; past objectives or communicated future objectives do not constitute any promise of return or price guarantee.

5.2. Pre-sale and Vesting

The User acknowledges and accepts that by purchasing during the Pre-sale, they acquire a vesting position entitling them to the future, scheduled on-chain receipt of the Tokens. Tokens acquired during the Pre-sale are not transferred immediately to the User's wallet; the transfer of the Tokens takes place in accordance with the vesting mechanism set out in Chapter 8 of these GTC. The vesting mechanism is a Smart Contract-based technical solution that ensures the time-scheduled release of the Tokens. The vesting structure does not qualify as: – a custody arrangement, – a repayment undertaking (excluding the refund obligation applicable in the event of exercising the right of withdrawal under point 8.3 of these GTC), – fiduciary asset management, – a financial or investment service.

The User acknowledges that the acquisition of the Token does not create any ownership, dividend, or yield entitlement against the Service Provider; the detailed rules regarding the rights and limitations attached to the Token are set out in point 4.2 of these GTC.

5.3. Technological and Security Risks

The User acknowledges that: the Token and the Pre-sale process operate on blockchain- and smart contract-based infrastructure, which partly depends on third-party systems; wallet hacking, loss of a private key, smart contract error, blockchain malfunction, or any other technical error may result in the loss of Tokens.

The Service Provider shall not be liable for damages that: result from deficiencies in the User's own wallet, device, or security practices, arise from third-party blockchain infrastructure or the operation of an external service provider, are the consequences of unavoidable technical events beyond the Service Provider's control.

The Service Provider's liability in connection with possible defects of smart contract(s) developed by it or operated by it is limited to the extent permitted by the applicable laws. This limitation does not affect liability for damages caused intentionally or with gross negligence, nor cases of liability that cannot be excluded by law.

5.4. Regulatory Risks

The User acknowledges that: the sale and holding of the Token may be subject to applicable laws and regulatory requirements; in certain jurisdictions, participation may be prohibited or restricted; the User declares and undertakes that they do not participate in the Pre-sale or the Giveaway program from a jurisdiction where such participation is prohibited or restricted.

The detailed rules regarding Excluded Jurisdictions and the conditions of participation are set out in Chapter 6 of these GTC. If the User makes a false declaration or participates from an excluded jurisdiction, the legal consequences arising therefrom shall be borne by the User. In such case, the Service Provider shall be entitled to refuse participation or suspend the account.

5.5. Liquidity and Market Entry Risk

The User acknowledges and accepts that: during the Pre-sale period, the Token is not tradable on any decentralized or other secondary trading system; the Service Provider undertakes to create a liquidity pool on a decentralized exchange (DEX), planned to be on the Uniswap protocol or a functionally equivalent decentralized trading system, no later than five (5) weeks after the closing of the Pre-sale program, in order to ensure the technical tradability of the Token; the Service Provider's obligation extends exclusively to the technical creation of the liquidity pool and the provision of the possibility of decentralized trading; the timing of the creation of the liquidity pool may be delayed by technical, regulatory, or other circumstances beyond the Service Provider's reasonable control; in the event of delay arising from such circumstances, the Service Provider's liability shall be limited to the extent permitted by law; the Service Provider does not provide any guarantee regarding: – the depth of the liquidity pool, – the duration of its maintenance, – the volume of secondary market trading, – the stability of the price, – the future market liquidity of the Token; decentralized trading is market-based, and the price is determined exclusively by supply and demand; the market price of the Token may differ significantly from the price applied during the Pre-sale, and the Service Provider does not guarantee any financial return whatsoever.

5.6. Special Warning

The User declares that: they have understood the risks described in this Chapter; they have made an independent decision to participate in the Pre-sale based on their own assessment; they are aware that the acquisition of the Token is a transaction involving a distinctly high-risk digital asset with an uncertain outcome.

The Service Provider's liability is limited within the framework permitted by law and, without prejudice to the obligations expressly undertaken in these GTC, does not extend to damages arising from changes in the market value of the Token, market volatility, the lack of liquidity or secondary market demand, or the development of trading volume.

This limitation of liability does not affect the Service Provider's obligation expressly undertaken in these GTC to ensure the technical tradability of the Token on a decentralized exchange (point 8.2.3).

6. Eligibility and Territorial Restrictions

6.1. General Eligibility

The Service – including in particular participation in the Pre-sale, the Giveaway, and the Governance mechanism – is available exclusively to natural persons who: have legal capacity under the laws of their own jurisdiction; have reached the age of 18; do not fall under any Excluded Jurisdiction(s) specified in this Chapter; and are not subject to any applicable international or European Union sanctions restrictions.

The Service is not available from certain countries or territories for legal, regulatory, sanctions-related, or risk management reasons. The Service Provider may restrict the availability of the Service by technical means (in particular through geoblocking) in accordance with Chapter 7.

By registering and/or using the Service, the User declares that they satisfy the above eligibility requirements.

6.2. Excluded Jurisdictions

The Service – including participation in the Pre-sale and the Giveaway – is not available to persons subject to the following jurisdictions:

Due to strict securities and crypto-asset regulation:

• United States of America
• Canada
• United Kingdom
• Japan
• Singapore
• South Korea

Due to full or partial prohibition of crypto-assets:

• China
• Algeria
• Morocco
• Tunisia
• Bangladesh
• Bolivia
• Nepal
• Nigeria
• Pakistan
• Myanmar
• Lebanon

Jurisdictions subject to international sanctions:

• Iran
• North Korea
• Syria
• Cuba
• Russia
• Belarus
• Venezuela
• Crimea region
• Donetsk region
• Luhansk region

The Service Provider is entitled to modify the scope of the Excluded Jurisdictions for legal, regulatory, sanctions-related, or risk management reasons. The Service Provider shall publish information about such modification in advance where prior notice is reasonably possible, and in all other cases without undue delay.

6.3. Sanctions and Compliance Declaration

The User declares and warrants that: they are not listed on sanctions lists published by the European Union or the United Nations (UN), and are not subject to restrictive measures related thereto; they are not subject to terrorism financing, money laundering, or other international restrictive measures; they do not act directly or indirectly on behalf of any person or entity subject to the above restrictions.

If any of the above declarations prove to be false, or if the participation gives rise to legal/sanctions-related risk, the Service Provider shall be entitled to restrict the use of the Service, reject the registration, or suspend participation within the framework of these GTC and the applicable laws.

6.4. KYC/AML and Refusal of Participation

The Service Provider is entitled to refuse or suspend the use of the Service – including registration and participation in the Pre-sale/Giveaway – for compliance reasons (KYC/AML, sanctions, and risk management), in particular if: the User does not meet legal or compliance requirements; there are reasonable grounds to assume that the User falls under an Excluded Jurisdiction; the participation raises anti-money laundering, sanctions-related, or other legal risks; the User has made a false declaration or has seriously breached the provisions of these GTC (in particular by conduct aimed at circumventing the territorial restrictions).

In such cases, the Service Provider shall be entitled to suspend the transaction, refuse participation, and freeze the vesting position or suspend the on-chain transfer of the Tokens within the limits permitted by law. The Service Provider shall not be obliged to provide a detailed justification of its decision if providing such justification would violate the law, jeopardize crime prevention/AML purposes, or would not be reasonably expected for compliance/risk management reasons.

6.5. Restriction of Technical Access

The Service Provider is entitled to: apply geoblocking based on IP address and geolocation; carry out sanctions and risk screening related to the Wallet address (including the involvement of a third-party service provider); and restrict access by other technical means.

Conduct aimed at circumventing the technical restriction (in particular the use of a VPN, proxy, or other anonymizing tool for the purpose of concealing access from Excluded Jurisdictions) shall constitute a serious breach of these GTC and may result in the rejection of registration, suspension of participation, or the freezing of the vesting position.

7. Registration and User Account

7.1. Eligibility for Participation

Successful registration is a prerequisite for participation in the Pre-sale, the Giveaway program, and the Governance mechanism. Only a natural person is eligible to register if they: have reached the age of 18; act in their own name and at their own responsibility; do not fall within the scope of the Excluded Jurisdictions specified in Chapter 6 of these GTC; are not listed on any applicable international or European Union sanctions list.

The Service Provider is entitled to verify eligibility for participation on the basis of the conditions set out in Chapter 6, and may refuse, suspend, or restrict registration or participation for legal, compliance, or risk management reasons.

7.2. Registration Process

In order to create an account, the User must provide: their username; a valid email address; their country (the Excluded Jurisdictions listed in Chapter 6 are not included among the selectable countries); a password that complies with the security requirements specified by the Service Provider.

Confirmation of the email address is a condition for the validity of the registration. During registration, the User must declare that: they have reached the age of 18; they have read, understood, and accepted the provisions of these GTC.

A condition of registration is that the User connects their own Wallet to their user account. The connection of the Wallet does not provide the Service Provider with access to the private keys or with any right of disposal over the Wallet. Sanctions and compliance screening of the Wallet is carried out with the involvement of a third-party service provider.

7.3. Geoblocking and Compliance Checks

When accessing the website, the Service Provider may examine the User's geographical location by technical means based on IP address and geolocation. If the system identifies access originating from one of the Excluded Jurisdictions specified in Chapter 6 of these GTC, the website shall not redirect the User to the registration interface, and the Service shall not be available. In such case, the system shall display information stating that the Service is not available in the given country and shall provide a reference to the detailed rules set out in Chapter 6. Sanctions and compliance screening of the Wallet is carried out following the connection of the Wallet, with the involvement of a third-party service provider. If, based on the Wallet screening or any other compliance review, participation is not permitted, the registration cannot be completed and the User Account shall not be created. The Service Provider is not obliged to provide the detailed reasons for denying access or rejecting registration if providing such reasons would violate the law, jeopardize crime prevention or compliance purposes, or would not reasonably be expected for risk management reasons.

7.4. Provision of Accurate Data and Suspension of the Account

The User is required to provide true, accurate, and up-to-date data. If the User: provides false or misleading data; attempts to circumvent the geographical restriction by using a VPN, proxy, or other technical means; is subject to sanctions or jurisdictional restrictions; seriously breaches the provisions of these GTC, the Service Provider shall be entitled to suspend or delete the User's account, refuse or suspend their further participation in the Pre-sale or Giveaway, and—where justified by the nature of the breach and permitted by law—freeze the vesting position or suspend the on-chain transfer of the Tokens.

The suspension or deletion of the account does not affect the Service Provider's right to enforce, in separate proceedings, any damage arising from the User's unlawful conduct. The lawful exercise of the right of withdrawal shall not qualify as a breach of contract.

7.5. Participation in Governance

A successfully registered User is entitled to participate in the Governance mechanism published by the Service Provider on the website. Governance is a community participation and opinion-expression mechanism operated within the framework of the Project, which enables Users to make proposals or express their opinion by voting on certain matters related to the operation of the Project. Governance may extend in particular, but not exclusively, to the following matters: the use of the Tokens placed in the Treasury and issued by the Service Provider; certain technical or operational project decisions; community initiatives or development directions of the Project.

The Governance mechanism: does not provide any ownership interest in the Service Provider; does not create any membership relationship under corporate law; does not provide any right to dividends, profit-sharing, or any other financial entitlement; does not create any governance or decision-making right over the Service Provider.

Voting results adopted within the framework of Governance do not qualify as corporate resolutions binding on the management body of the Service Provider and may be taken into account only within the framework determined by the Service Provider and at the Service Provider's discretion.

Participation in Governance does not depend on: participation in the Pre-sale; holding the Token; purchasing the Token.

Participation in the Governance mechanism is subject exclusively to successful registration. The Service Provider is entitled to amend the operating rules, framework, or topics of the Governance mechanism, or to terminate the mechanism in whole or in part, if justified by technical, operational, or legal circumstances.

7.6. Data Processing

The processing of personal data provided during registration, as well as the data processed during compliance and technical checks, shall be carried out in accordance with the Service Provider's Privacy Policy.

8. Pre-sale Terms

8.1. Duration and Structure of the Pre-sale

The total duration of the Pre-sale shall be a maximum of 20 (twenty) weeks. The Pre-sale consists of 10 (ten) base stages and—if necessary—one additional 11th (eleventh) stage. Each stage shall last: until the full sale of the specified token quantity, or for a maximum of 2 (two) weeks, whichever occurs earlier.

If the full quantity of Tokens allocated to the given stage is sold out before the expiry of the 2-week period, the Smart Contract shall automatically close that stage and start the next one. If the token quantity is not fully sold during the 2-week period, the stage shall automatically close upon the expiry of the 2-week deadline, and the next stage shall automatically start. Tokens not sold in the given stage shall remain at the treasury address(es) allocated for the Pre-sale; they shall not be offered again for sale later within the framework of the Pre-sale and shall not become available in secondary market trading. The 11th stage shall be activated only if the first 10 stages are closed before the expiry of the total 20-week period. The 11th stage shall last at most until the end of the total 20-week period. If the token quantity of all 11 stages is fully sold before the expiry of the 20-week period, the Pre-sale shall close earlier. In such case, no further Token purchases shall be possible after the closing of the Pre-sale. The conditions of participation in the Pre-sale and the rules of registration are set out in Chapter 7 of these GTC.

8.1.1. Data Required for Participation in the Pre-sale

As a condition for starting a purchase in the Pre-sale, in addition to the data provided during registration, the User must provide the Service Provider with their full name and exact residential address. The User shall ensure that the data provided in this way are true, accurate, and up to date. The Service Provider shall be entitled to refuse or suspend participation in the Pre-sale if the User fails to provide the required data, or provides false, incomplete, or misleading data.

8.2. Allocation of Tokens and Vesting

Tokens acquired within the framework of the Pre-sale shall not be transferred immediately to the User's Wallet. By executing the purchase transaction on the blockchain, the User acquires a vesting entitlement (hereinafter: the "Vesting Position") for the future, scheduled receipt of the purchased Tokens.

8.2.1. Cliff Period

Each individual Token purchase starts a separate, individual vesting schedule. The cliff period related to the Vesting Position is 25 (twenty-five) weeks, starting from the time of execution of the purchase transaction on the blockchain. During the cliff period: the Tokens shall not be transferred, no partial release shall occur, the User shall not be entitled to transfer or trade the Tokens.

The existence of the cliff period does not depend on the date of closing of the Pre-sale and shall not be shortened even if the technical tradability on a decentralized exchange is ensured earlier than that.

8.2.2. Vesting (Release Period)

Following the expiry of the cliff period, the vesting (release) period shall begin in the 26th (twenty-sixth) week from the purchase. The duration of the vesting period is 1 (one) week, i.e. 7 (seven) calendar days. 100% of the purchased Token quantity shall be released during the vesting period according to a linear schedule. The release shall take place daily and automatically by the Smart Contract. The quantity released daily shall be 1/7 of the total purchased Token quantity. Upon the daily release, the Tokens shall be transferred to the User's Wallet on that day and, from that moment, shall become transferable in accordance with the rules of the blockchain. The possibility of trading the Tokens also depends on the technical availability of the prevailing market infrastructure (in particular: a decentralized exchange liquidity pool). The User acknowledges that the characteristics of the blockchain network (including in particular network congestion, delayed finalization of transactions, and the operation of external infrastructure providers) may temporarily delay the technical execution of the release. Such delay—provided that it occurs without fault on the part of the Service Provider—shall not in itself constitute a breach of contract.

8.2.3. Ensuring Decentralized Tradability

The Service Provider undertakes to create a liquidity pool on a decentralized exchange (DEX) no later than 5 (five) weeks after the closing of the Pre-sale in order to ensure the technical tradability of the Token. The above deadline shall be calculated from the actual date of closing of the Pre-sale program, regardless of whether the closing occurs upon expiry of the maximum 20-week period or upon earlier full sale of the stages. The creation of the liquidity pool shall constitute a contractual obligation of the Service Provider. The obligation shall be deemed performed if: the Token becomes technically tradable on a decentralized exchange, and the liquidity pool is created and is accessible on-chain.

The Service Provider shall not be liable for price, liquidity, or trading conditions resulting from the operation of the decentralized market. The deadline for the creation of the liquidity pool may be extended only in circumstances beyond the Service Provider's reasonable control, including in particular, but not limited to: legal or regulatory restriction, blockchain network malfunction, operational disruption of an external infrastructure provider, force majeure event.

If such circumstances exist, the Service Provider shall inform Users without undue delay. The Service Provider shall be entitled to modify the undertaking set out in this point 8.2.3.—as an essential condition of the Pre-sale—only in the event of a legal/regulatory prohibition or force majeure, and shall be obliged, with due regard to the legitimate interests of Users, to apply an equivalent alternative technical solution that reasonably ensures access to the Tokens and their technical tradability. Any future listing on a centralized exchange (CEX) is designated exclusively as a long-term objective and does not form part of the Service Provider's contractual obligations.

8.2.4. Separation of Vesting and Tradability

The timing of vesting is linked exclusively to the date of purchase and does not depend on: the stage number, the date of closing of the Pre-sale, the date of creation of the liquidity pool.

The User acknowledges that an earlier purchase results in an earlier expiry of the cliff period and thus an earlier start date of vesting.

8.2.5. Legal Nature of the Vesting Position

The Vesting Position is exclusively a technical entitlement, recorded by the Smart Contract, to the future, scheduled receipt of the Tokens. The Vesting Position does not qualify as: a custody arrangement, a repayment undertaking (excluding the case of the right of withdrawal under point 8.3), fiduciary asset management, a financial or investment service, an interest-bearing or yield-generating arrangement.

8.3. Right of Withdrawal

In the Service Provider's view, the Token offered within the framework of this Pre-sale does not qualify as an asset-referenced token or an e-money token under Regulation (EU) 2023/1114 of the European Parliament and of the Council ("MiCA Regulation"), but falls into the category of "other crypto-assets" under the MiCA Regulation. In accordance with Article 13 of the MiCA Regulation, a retail holder who acquires the Token directly from the Service Provider shall be entitled to withdraw from the agreement for the purchase of the Token without giving any reason.

8.3.1. Withdrawal Period

The withdrawal period is 14 (fourteen) calendar days, starting from the day on which the User consented to the purchase of the Token, i.e. executed the purchase transaction.

8.3.2. Method of Exercising the Right of Withdrawal

In order to exercise the right of withdrawal, the User must send a clear statement to the Service Provider: – by completing the withdrawal form available on the Service website, or – by sending an email to the official email address of the Service Provider.

Messages sent through social media platforms (in particular, but not limited to: Discord, Telegram, X, Facebook, Instagram, TikTok) shall not qualify as valid withdrawal statements. In the withdrawal statement, the User must provide at least the data necessary for identification (in particular: the registered email address and/or the transaction ID), as well as the data necessary for the refund.

8.3.3. Finality of Blockchain Transactions and Performance of the Refund

The User acknowledges that transactions executed on the blockchain are by their nature irreversible; therefore, the exercise of withdrawal shall not be implemented by "reversing" the original transaction initiated by the User, but by a separate refund transaction performed by the Service Provider. The Service Provider shall be obliged to refund all payments received from the retail holder without delay, but no later than within 14 (fourteen) days from receipt of the withdrawal statement. The refund shall be made in the same crypto-asset and by using the same means of payment as used by the User in the original transaction, unless the User expressly agrees to the use of another means of payment, provided that this does not result in any fee, cost, or other payment obligation for the User. The refund shall be made in the amount of crypto-assets originally paid, irrespective of any change in its fiat value in the meantime. The User is obliged to ensure the accuracy of the wallet address and other data necessary for the refund. The Service Provider shall not be liable for the failure or loss of the refund if this is attributable to an incorrect, incomplete, or non-user-controlled wallet address provided by the User, provided that the refund transaction was properly initiated by the Service Provider.

8.3.4. Legal Effects of Withdrawal

If the right of withdrawal is exercised, the User's Vesting Position shall be deleted and the entitlement related to the Tokens shall cease. The User acknowledges that, following acceptance of the withdrawal, they shall not be entitled to the allocation of Tokens, their release (vesting), or the exercise of any further entitlement related to the Tokens.

8.3.5. Other Provisions

The exercise of the right of withdrawal does not affect the Service Provider's right to enforce, in separate proceedings, any damage arising from the User's unlawful conduct, abuse, or breach of contract.

8.4. Price Structure and Consequences of Modification or Termination of the Pre-sale

The price of the Tokens is predetermined and fixed in each stage. By making a purchase, the User acknowledges that the Tokens do not provide future capital gains, return, or guaranteed market value. The token quantity determined for each stage indicates the maximum quantity that may be sold, which does not guarantee that the full token allocation of the given stage will be sold.

The Service Provider shall be entitled to modify, suspend, or terminate the launch, continuation, or closing of any stage of the Pre-sale in the event of technical, legal, regulatory, or other circumstances beyond the Service Provider's reasonable control. If the modification, suspension, or termination affects a payment already made by the User, the Service Provider shall be obliged to refund that part of the consideration paid by the User in relation to which the Vesting Position is not created or cannot be exercised due to the modification/suspension. If the Pre-sale is cancelled in its entirety for any reason, the Service Provider shall, in accordance with Article 14(3) of the MiCA Regulation, ensure that all payments collected from Users are refunded no later than within 25 (twenty-five) calendar days following the date of cancellation. The refund shall be made in the crypto-asset used in the original transaction and by using the original means of payment, unless the User expressly agrees to a different solution, provided that this does not result in any fee or additional cost for the User.

8.5. Risk and Legal Declaration

Participation in the Pre-sale shall be governed, with respect to the legal qualification of the Token, by point 4.2 of these GTC, and with respect to the related risks, by the provisions of Chapter 5. The User declares that their participation does not violate any applicable law or regulatory requirement under the law of their own jurisdiction. The User acknowledges that the use of blockchain-based systems may involve technological and market risks, including in particular network congestion, transaction errors, price volatility, as well as risks arising from loss of access to the wallet or crypto-asset used by the User, incorrect addressing, or unauthorized access by third parties. The Service Provider shall not be liable for losses arising from the User's own conduct, the operation of a third-party service provider, or the operational characteristics of the blockchain network. The Service Provider's liability may not be excluded or limited in cases where this is expressly prohibited by applicable law.

8.6. General Provisions

The Service Provider may modify, suspend, or terminate the conditions and structure of the Pre-sale—including in particular the number and timing of stages, the available token quantity, and the manner of technical implementation—exclusively for legal, regulatory, security, or technical reasons, or in the event of unforeseeable circumstances that materially affect the conduct of the Pre-sale under its original conditions. The Service Provider shall inform Users of the modification in advance where the nature of the modification allows this; in other cases, it shall do so without undue delay. If the modification materially affects the User's rights or obligations, the User shall be entitled, until the effective date of the modification, to terminate their participation in the Pre-sale and request the refund of the payment made up to that point. The refund option under this point is a contractual remedy and is not identical to the right of withdrawal under point 8.3 (MiCA). Participation in the Pre-sale is subject to the successful completion of KYC/AML and other compliance checks. The Service Provider shall be entitled to make participation conditional, suspend it, or refuse it until the necessary checks have been completed, or if their outcome does not allow participation. The User acknowledges that the Service Provider does not provide registration if the compliance checks (in particular: geoblocking and sanctions list screening) are unsuccessful, and without registration participation in the Pre-sale is not possible. The Service Provider does not guarantee that the Pre-sale is lawfully available in all countries or jurisdictions. Only a User may participate in the Pre-sale who is entitled, under the law of the jurisdiction of their residence, place of stay, or nationality, to participate in a program of this type, and who does not fall within the scope of the Excluded Jurisdictions specified in Chapter 6. The User is obliged to verify that participation in the Pre-sale is lawful under the laws applicable to them and is not subject to any prohibition, restriction, or licensing requirement. The User acknowledges that participation by circumventing eligibility or compliance requirements, in particular by providing false data or by using a VPN or similar technical solution, constitutes a breach of these GTC, and the legal consequences arising therefrom shall be borne by the User. The Service Provider shall not be liable for legal consequences arising from the inaccuracy of the data provided by the User or from failure to comply with jurisdictional requirements, unless this is attributable to the intentional or grossly negligent conduct of the Service Provider. The provisions of this Chapter 8 shall apply independently and separately; if any provision proves to be invalid or unenforceable, this shall not affect the validity of the remaining provisions.

9. Giveaway Terms

9.1. Purpose and General Nature of the Giveaway

The purpose of the Giveaway is to incentivize and reward Users during the term of the Pre-sale. Within the framework of the Giveaway, a total of up to 6,900,000 (six million nine hundred thousand) Tokens may be distributed exclusively on the basis of the Mini Game Leaderboard under point 9.2.1, and, in addition, the top-ranked participants of certain Leaderboards may receive unique NFTs.

The Giveaway does not qualify as an investment offer, financial incentive program, collective investment scheme, or gambling activity. Participation in the Giveaway does not create any ownership, corporate, or financial legal relationship between the Service Provider and the User.

The outcome of the Giveaway is based exclusively on objective, performance-based and activity-based criteria; no random selection, drawing, or randomized decision-making takes place, therefore the Giveaway does not qualify as gambling or as a promotional activity requiring official authorization.

The details of the processing of data related to wallet connection are set out in the Privacy Policy. The Service Provider processes Users' personal data within the scope and in the manner defined in the Privacy Policy.

The Service Provider does not guarantee that the Giveaway is lawfully available in every country or jurisdiction, or that it complies with the laws applicable there. Participation in the Giveaway is permitted exclusively for Users who are entitled, under the jurisdiction of their own residence, place of stay, or nationality, to participate in a program of this type, and who do not fall under the "Excluded Jurisdictions" defined in Chapter 6.

This does not affect the application of the mandatory consumer protection rules of the jurisdiction of the User's residence.

The User is obliged to independently verify that participation in the Giveaway is lawful under the laws applicable to them and is not subject to any prohibition, restriction, or licensing requirement.

If the Giveaway qualifies as a prohibited, restricted, or licensed activity in any jurisdiction, the Service Provider shall be entitled to restrict participation or exclude the User.

To the extent permitted by law, the Service Provider shall not assume liability for any legal consequences, official proceedings, fines, or other disadvantages arising from failure to comply with jurisdictional requirements.

The Tokens distributed within the framework of the Giveaway form part of the Project's predetermined token supply and do not qualify as a new crypto-asset issuance.

9.2. Methods of Participation and Reward Structure

A prerequisite for participation in the Giveaway is that the User successfully registers on the Service website in accordance with the conditions set out in Chapter 7 of these GTC. During registration, the User must provide the requested data—username, email address, and country—truthfully and completely.

Registration and participation in the Giveaway are subject to the rules regarding the Excluded Jurisdictions defined in Chapter 6 of these GTC, as well as the successful completion of the geoblocking and compliance checks under point 7.3.

Following successful registration, the User is entitled to connect their own wallet address to their user account, which is a technical prerequisite for participation in the Giveaway.

The Giveaway is implemented through three separate Leaderboard systems. The Leaderboards remain active throughout the full term of the Pre-sale and may be terminated only for a substantial, unforeseen reason determined by the Service Provider (e.g. technical error, legal obligation, security reason). The Service Provider shall inform Users of such measure as soon as possible. The Mini Game Leaderboard shall become available already before the Pre-sale.

Any claim related to participation in the Giveaway and eligibility for rewards is linked to the person (wallet address), and until the time of distribution it may not be transferred, assigned, or claimed by any third party.

Following successful distribution, the Tokens and NFTs shall become accessible and tradable in accordance with the Smart Contract and the DEX listing and vesting rules defined in point 9.3 of these GTC.

9.2.1. Mini Game Leaderboard

• The User may actively play the Mini Game even before the Pre-sale, but may appear on the Leaderboard only after successful registration and wallet connection as described in Chapter 7.
• The Mini Game Leaderboard remains active throughout the full term of the Pre-sale and closes automatically on the day the Pre-sale program closes.
• The outcome of the Mini Game is based exclusively on the User's performance and activity; the outcome of the game is not influenced by any random mechanism or drawing. The Mini Game serves exclusively entertainment and promotional purposes.
• The Mini Game Leaderboard is established on the basis of the scores achieved during the Mini Game and is updated continuously.
• Based on the scores, the top 500 (five hundred) Users are entitled to the distribution of 6,900,000 Tokens. The quantity of Tokens distributed depends on the ranking achieved on the leaderboard.
• In addition to the Tokens, the top 10 ranked participants of the Mini Game Leaderboard shall each receive a unique NFT. The NFTs comply with the ERC-721 standard and are therefore transferable.
• The 6,900,000 Tokens are distributed exclusively on the basis of the Mini Game Leaderboard. No Tokens may be acquired from any other Leaderboard system.
• The Service Provider is entitled to correct, delete, or disregard scores resulting from technical error, bug, exploit, or any other improper use.

9.2.2. Pre-sale Purchase Leaderboard

• The Leaderboard ranks Users on the basis of the quantity of Tokens purchased during the Pre-sale.
• The top 10 ranked participants shall each be entitled to one unique NFT. The NFTs comply with the ERC-721 standard and are therefore transferable.
• No Tokens are distributed on the basis of this Leaderboard; the 6,900,000 Tokens are linked exclusively to the Mini Game Leaderboard.

9.2.3. Referral (Sharing) Leaderboard

• During the Pre-sale, the Smart Contract records the User's public wallet address and generates a unique referral link.
• Purchases made through the referral link increase the User's ranking on the Referral Leaderboard.
• The top 10 ranked participants shall each be entitled to one unique NFT. The NFTs comply with the ERC-721 standard and are therefore transferable.
• No Tokens are distributed on the basis of this Leaderboard.

9.3. Distribution of Tokens and NFTs, DEX Listing, and Tradability

The Leaderboard systems shall automatically close on the day the Pre-sale program closes. Eligibility shall be determined on the basis of the final ranking at the time of closing.

9.3.1. Distribution of NFTs

The NFTs due to the top-ranked participants of the Leaderboards shall be distributed without delay to the wallet addresses of the eligible Users after the results have been finalized. Following crediting, the NFTs shall be immediately transferable at the blockchain level. The secondary market tradability of the NFTs depends on third-party marketplaces and market demand, for which the Service Provider provides no guarantee.

9.3.2. Giveaway Tokens – Vesting Structure

The top 500 ranked participants of the Mini Game Leaderboard are entitled to Tokens within the framework of the Giveaway. The Giveaway Tokens shall not be transferred immediately to the Users' wallets. On the day the Pre-sale closes, the eligible Users acquire a Smart Contract-based vesting entitlement for the future, scheduled receipt of the Tokens.

Cliff period: In the case of Giveaway Tokens, the cliff period is 5 (five) weeks, beginning on the day following the closing date of the Pre-sale. During the cliff period: no Token shall be transferred, no partial release shall occur, the User shall not be entitled to transfer or trade the Tokens.

Vesting period: Following the expiry of the cliff period, the 4 (four)-week vesting period shall begin. 100% of the total Token quantity acquired within the framework of the Giveaway shall be released over 28 (twenty-eight) calendar days according to a linear schedule. The release shall take place daily and automatically by the Smart Contract. The quantity released daily shall be 1/28 of the total Token quantity to which the User is entitled. Upon the daily release, the Tokens shall be transferred to the eligible User's wallet and, from that moment, shall be transferable at the blockchain level.

9.3.3. Separation of Vesting and Tradability

The vesting timing of the Giveaway Tokens is linked exclusively to the time of closing of the Pre-sale and does not depend on: the date on which technical tradability on a decentralized exchange is ensured, the actual date of creation of the liquidity pool.

The Service Provider undertakes to create a liquidity pool on a decentralized exchange (DEX) no later than 5 (five) weeks after the closing of the Pre-sale in order to ensure the technical tradability of the Token, in accordance with point 8.2.3 of these GTC.

If the creation of the liquidity pool is delayed due to circumstances beyond the Service Provider's reasonable control, this shall not affect the vesting timing, which shall begin automatically after the expiry of the 5th week calculated from the closing of the Pre-sale.

The actual market tradability of the Tokens depends on the technical availability of the prevailing market infrastructure and on market supply and demand conditions.

9.4. Legal Nature of the NFT

The NFT, as a blockchain-recorded digital token, may be freely transferred and traded in accordance with the relevant technical conditions.

The NFT does not provide: any ownership right in the Service Provider or its affiliated undertakings; any revenue share, royalty, dividend, or any financial return whatsoever; any financial, investment, or security-type entitlement; any exclusive or transferable intellectual property right over the related digital content.

The copyrights and other intellectual property rights relating to the visual, graphic, or other digital content connected to the NFT shall remain with the Service Provider or the relevant right holder.

By holding the NFT, the owner of the NFT acquires a non-exclusive, personal, and non-commercial right to use and display the related digital content. Commercial use is permitted only with the prior written consent of the Service Provider.

The NFT is created and transferred in the manner defined by the Smart Contract. The storage of the metadata or digital content related to the NFT may take place partly or entirely on external infrastructure.

The Service Provider does not guarantee the secondary market value, liquidity, or future tradability of the NFTs.

9.5. Abuse, Manipulation, and Exclusion

The Service Provider shall be entitled to exclude any User from the Giveaway if fraud, abuse, or manipulation is detected or reasonably suspected, in particular in the following cases: use of an automated tool, bot, script, or other artificial score-generating method; coordinated use of multiple wallets for the purpose of artificially influencing the ranking; use of the referral system for artificial traffic generation; breach of any provision of these GTC.

The Service Provider shall determine the Leaderboard results on the basis of the Smart Contract data and the technical log data recorded in the system. In the event of a dispute, the Service Provider shall decide on the basis of the available technical data and log files.

9.6. Limitation of Technical Liability

To the fullest extent permitted by the applicable laws, the Service Provider shall not be liable for deviations or damages resulting from technical or operational circumstances beyond the Service Provider's control, in particular: deviations resulting from blockchain network congestion, delay, or external network errors; operational disruptions resulting from errors in infrastructure, servers, hosting, APIs, or other services provided by third parties; compatibility problems of external wallet providers; technical characteristics arising from the operation of a decentralized network.

The Service Provider shall not be liable for changes or discrepancies in the ranking system resulting from external technical circumstances or errors arising on the User's side.

This limitation of liability shall not apply in the event of intentional or grossly negligent conduct of the Service Provider, nor in cases where the exclusion of liability is not permitted by law.

Participation in the Giveaway takes place partly in a decentralized technological environment, which involves specific technical risks.

9.7. Tax Responsibility

Tokens and NFTs acquired within the framework of the Giveaway may give rise to tax obligations under the tax laws of the jurisdiction of the User's residence or tax domicile. The extent and nature of such tax obligations depend on local laws and the User's individual circumstances, and may change.

The determination, declaration, and fulfilment of tax obligations are exclusively the User's responsibility. The Service Provider does not provide tax advice and assumes no liability for taxes payable by the User, including late payment penalties, interest, or other sanctions.

The User acknowledges that the Service Provider does not guarantee that the acquisition of Tokens or NFTs will be legally consequence-free from the perspective of tax authorities, and by participating, the User accepts that all tax risks are borne at their own responsibility.

9.8. Modification, Suspension, Termination

The Service Provider reserves the right to modify, suspend, or terminate the structure of the Giveaway, the number of Leaderboards, the amount of rewards, the timing, or the conditions of participation for substantial, objective, and reasonable cause—in particular in the event of legal, regulatory, technical, security, or unforeseen market circumstances.

The Service Provider shall inform Users of planned modifications at least 7 days in advance. In the event of measures required for urgent technical or security reasons, the Service Provider shall be entitled to act with immediate effect, while providing information simultaneously.

The User shall be entitled to terminate their participation in the Giveaway until the modification enters into force.

To the extent permitted by law, the modification, suspension, or termination shall not give rise to any obligation on the part of the Service Provider to pay damages.

Participation in the Giveaway does not qualify as a service provided for consideration and in itself does not create any automatic financial claim or guaranteed entitlement against the Service Provider.

10. Technical and Security Risks

10.1. General Technological Risks

The Service is based on blockchain technology, Smart Contract-based solutions, and infrastructure operated by third parties (including in particular, but not limited to: node providers, wallet providers, browser extensions, hosting providers, and cloud service providers).

The User acknowledges that: the Service is under continuous development, and temporary errors, delays, or operational changes resulting therefrom shall not in themselves constitute a breach of contract; blockchain technology is a continuously evolving, decentralized system that carries technological and operational risks; the operation of Smart Contracts is based on program code which, even if audited, may contain unforeseen errors or vulnerabilities; transactions executed on the blockchain are irreversible, and the Service Provider is not capable of unilaterally modifying or revoking them; the operation of the network infrastructure and decentralized protocol is not under the exclusive control of the Service Provider; congestion, delay, hard fork, protocol-level change, or other technical event may occur in the operation of the blockchain network, which may affect the functioning of the Service.

The Service Provider does not guarantee the continuous, error-free, and uninterrupted operation of the system; however, it shall take reasonable measures to maintain technical stability.

10.2. Blockchain, Smart Contract, and External Data Source Risks

The User expressly accepts that operations related to the Tokens, NFTs, and the Giveaway mechanism are carried out by Smart Contract through a decentralized blockchain network.

To the extent permitted by law, the Service Provider shall not be liable in particular for damages or losses arising from the following events: Smart Contract risks outside the Service Provider's sphere of control, as well as unforeseen vulnerabilities or unexpected operation occurring in a decentralized environment; consequences of a blockchain fork, chain split, protocol update, or other network change; failed, delayed, or irreversible transactions; error, delay, or manipulation of external data sources, oracle providers, or API integrations; delays resulting from network congestion or significant changes in transaction fees; transaction costs (gas fees) determined by the blockchain network, the payment of which shall be borne by the User; operational malfunction of validators, node operators, or other network participants; blockchain-level attacks (including, for example, a so-called 51% attack).

By their nature, transactions executed on the blockchain are irreversible; the Service Provider is neither entitled nor technically able to modify or delete them.

10.3. Wallet and User Security

The User is responsible in particular for: the secure handling and proper protection of the wallet; the confidential storage of private keys, seed phrases, and other authentication data; the use of a wallet solution that is technically compatible with the Service; providing and verifying the correct wallet address during transactions.

The Service Provider does not have access to the User's private keys, seed phrase, or authentication data, and is technically incapable of exercising control over a lost, deleted, or compromised wallet.

To the extent permitted by law, the Service Provider shall not be liable in particular for damages arising from the following events: loss of the wallet or termination of access thereto; leakage of the private key or seed phrase; phishing, social engineering, malware, or other malicious attack; a transaction initiated by the User to an incorrect address.

10.4. Cyberattacks and Security Incidents

The Service Provider applies reasonable technical and organizational measures for the security of the Service. The User acknowledges that it cannot be guaranteed that the system will be entirely free from risks, including in particular, but not limited to, the following events: hacker attacks, unauthorized access, denial-of-service (DDoS) attacks, data manipulation or system errors, other malicious interference, force majeure events, including natural disasters, energy supply disruptions, global network outages, governmental or regulatory measures.

To the extent permitted by law, the Service Provider shall not be liable for damages arising from such events where they result from circumstances beyond the Service Provider's reasonable control or influence. The User acknowledges that the technical risks listed in points 10.1–10.3 and the responsibilities related to wallet management shall remain applicable in connection with system security.

10.5. Third-Party Service Providers

For the operation of the Service, the Service Provider may use infrastructure and services provided by third parties, including in particular, but not limited to, APIs, hosting and cloud services, as well as external exchange or trading infrastructure.

To the extent permitted by law, the Service Provider shall not be liable for errors or damages arising in particular from the following events: downtime or operational faults of third-party service providers; API errors or malfunctions of external systems; outages of hosting or cloud infrastructure; errors of the trading infrastructure after any potential listing of the Tokens; any other malfunction of an external system outside the Service Provider's sphere of control.

The limitation of liability under this point shall not apply if the damage results from the intentional or grossly negligent conduct of the Service Provider.

10.6. Technical Changes and Developments

The Service Provider is entitled to modify, update, or replace the technical structure of the Service, its Smart Contract solutions, network integrations, or operational mechanisms if this is necessary for the development of the Service, the enhancement of its security, ensuring legal compliance, or technical optimization.

The User acknowledges that such modifications may result in temporary operational disruption, compatibility problems, or system downtime. Such temporary disruption resulting from reasonably justified technical changes shall not in itself constitute a breach of contract.

10.7. Limitation of Liability

The use of the Service is at the User's own risk.

To the extent permitted by the applicable laws, the Service Provider shall not be liable for indirect, consequential, or incidental damages, in particular where such damages arise from events related to the technical, security, blockchain, or third-party service issues set out in points 10.1–10.6 of this Chapter.

The limitation of liability under this point shall not apply to damages caused intentionally or with gross negligence by the Service Provider, nor to cases in which the exclusion or limitation of liability is not permitted by law.

11. Financial and Market Risks

11.1. General Financial Risks

The Service and activities related to the Tokens—particularly, but not limited to, the Pre-sale, Giveaway, and Smart Contract operations—carry significant financial and market risks.

The User acknowledges that the Token is not issued as an investment instrument, and the Service Provider does not offer any investment opportunity. In the Service Provider's view, the Token does not qualify as a security, collective investment scheme, or other regulated financial instrument.

The acquisition of the Token: does not guarantee any return, price increase, or profit; does not establish any corporate law ownership rights or any entitlement to dividends or profit-sharing; does not provide any financial claim against the Service Provider or any third party.

The detailed terms relating to the Pre-sale, the vesting mechanism, and the ensuring of technical tradability on a DEX are set out in Chapter 8 of these GTC.

The User expressly acknowledges that: the market price of the Token may fluctuate significantly; the liquidity of the Token depends on market supply and demand, over which the Service Provider has no control; in the event of low liquidity, significant price volatility, wide spreads, or limited saleability may occur; in extreme cases, the market value of the Token may be lost in full.

The Service Provider does not provide investment, financial, or tax advisory services. The User makes financial decisions related to the use of the Service at their own responsibility.

11.2. Price and Liquidity Risk

The secondary market price of the Token depends on the development of supply and demand, market sentiment, and the general market conditions of crypto-assets.

The User acknowledges that: the price of the Token may fluctuate significantly within a short period of time; in the event of low market activity, limited liquidity, significant price differences (spread), or partial execution may occur; when selling the Token, slippage or the application of an unfavorable price may occur; the Service Provider is not able to guarantee or maintain the volume of secondary market trading.

The ensuring of the technical tradability of the Token on a decentralized exchange shall take place after the closing of the Pre-sale, within the deadline specified in point 8.2.3 of these GTC; however, the liquidity pool created on the decentralized exchange and the ensuring of the technical tradability of the Token do not mean that the market value, trading volume, continuous tradability, or liquidity of the Token is guaranteed.

A decrease in price, a low level of liquidity, or a lack of market interest shall not in itself constitute a breach of contract.

Any future listing on a centralized exchange is exclusively a future plan of the Service Provider, which does not qualify as a contractual undertaking, and its implementation is not guaranteed.

11.3. Market and Regulatory Risks

The operation of the Service and the Token may be affected by the general economic, financial, and regulatory conditions of the crypto-asset market.

The User acknowledges that: changes in law, official measures, or new regulatory requirements may restrict or modify the use, distribution, or availability of the Token; certain countries may introduce restrictions or prohibitions concerning crypto-assets; changes in the regulatory environment may adversely affect the market value or tradability of the Token; a general downturn in the crypto-asset market or extreme market events may result in a significant decrease in the value of the Token.

It is the User's responsibility to inform themselves about the laws, tax obligations, and financial requirements of the country of their residence or activity. The Service Provider shall not be liable for consequences arising from failure to comply with such obligations.

11.4. Nature of the Tokens and NFTs

The Tokens and NFTs shall be credited to the User within the framework of the Service, at the time they become available, in their then-current condition.

The User acknowledges that: the market value of the Tokens and NFTs is variable, and the Service Provider provides no guarantee regarding their continued value, price, liquidity, or availability; the acquisition of the Tokens and NFTs does not in itself create any ownership, dividend, yield, or other financial right in the Service Provider.

11.5. Limitation of Liability

The use of the Service is at the User's own responsibility.

To the fullest extent permitted by applicable law, the Service Provider shall not be liable for financial damages or losses arising from: price fluctuations of the Tokens or the limited nature of their liquidity; risks related to the tradability of the Token, market events, or regulatory changes; the technical, security, and force majeure risks detailed in Chapter 10; error or manipulation of external data sources (oracle, API); market or financial consequences resulting from the operation of the Pre-sale vesting mechanism and other Smart Contract operations.

The limitation of liability under this point does not affect mandatory liability cases under the law, in particular liability for damage caused intentionally or with gross negligence by the Service Provider.

12. Intellectual Property

12.1. General Provision

The intellectual property rights and content related to the Service are owned by the Service Provider, or the Service Provider is authorized to use them, including in particular, but not limited to: the name and logo of the The Penguin Coin token; all graphic, visual, digital, or printed content, icons, illustrations, animations, and design elements; the Smart Contract code of the Token, the backend and frontend software solutions, and the related documentation; the trademarks and branding elements used on the website, social media platforms, or marketing materials; the NFTs related to the Token, game interfaces, and any other digital assets.

All intellectual property rights are reserved by the Service Provider. The intellectual property rights may be protected under the applicable Hungarian, European Union, and international laws.

12.2. Prohibition of Unauthorized Use

The User expressly acknowledges that, without the authorization of the Service Provider, the following are strictly prohibited and qualify as infringement: the use of the name, logo, or any graphic element of the Token; the copying, distribution, modification, public publication, or any commercial use of the visual, graphic, or branding elements of the Service; the reproduction, integration, or use in any manner of any digital content, NFT, Smart Contract interface, game interface, or other digital asset in another product or service.

For such infringements, the User shall be liable in accordance with the applicable laws, to the extent of their fault.

12.3. Limited Right of Use

The Service Provider grants the User a non-exclusive, non-transferable, non-commercial right of use with respect to the Token, logo, and graphic elements, which may be used exclusively for personal or community activity within the framework of the Service (e.g. profile picture, community sharing). This right may not be transferred and does not create any ownership right or other intellectual property right. Commercial use or any activity creating the appearance of representation of the Service Provider is subject to authorization.

12.4. Trademark and Copyright Notice

All trademarks, logos, names, icons, and graphic elements used by the Service Provider may be protected by copyright or other intellectual property rights and are entitled to protection under the applicable laws.

The User expressly acknowledges that the Service Provider may enforce all such intellectual property rights, including, for example: civil law or other legal actions; action against infringements on online platforms, social media, and all digital distribution channels.

In the event of a breach of the usage restrictions set out in points 12.2 and 12.3, the Service Provider may take action using all available legal means.

13. Taxation and VAT

13.1. General Tax Responsibility

The User is responsible for determining, declaring, and paying any tax obligations related to the use of the Service, participation in the Pre-sale, the acquisition of Tokens or NFTs within the framework of the Giveaway, as well as the subsequent holding, transfer, sale, or other use of the Tokens and NFTs.

This includes in particular, but is not limited to: the tax obligations relating to the purchase of Tokens during the Pre-sale; any income tax, gift tax, or other tax implications of Tokens and NFTs acquired within the framework of the Giveaway; capital gains arising from the sale of Tokens or NFTs on the secondary market; financial results realized after the technical tradability of the Token on a decentralized exchange has been ensured; any related contributions, duties, or other public charges.

The Service Provider does not provide tax, accounting, or financial advice and assumes no responsibility for determining, declaring, or fulfilling the User's tax obligations. The Service Provider is not obliged to inform the User about the details of the tax rules, requirements, or changes applicable to them.

13.2. Tax and VAT Qualification of the Pre-sale and Token Transactions

In the Service Provider's view, The Penguin Coin qualifies as a crypto-asset falling within the "other crypto-asset" category under Regulation (EU) 2023/1114 (MiCA). The Token does not qualify as a security, electronic money (EMT), asset-referenced token (ART), collective investment scheme, or traditional financial instrument.

The Service Provider considers the acquisition of Tokens within the framework of the Pre-sale as the acquisition of a digital crypto-asset in exchange for consideration. The Pre-sale does not qualify as an investment service, financial intermediary activity, or collective investment structure.

The Service Provider shall determine the applied tax and VAT treatment on the basis of the Hungarian and European Union laws in force at the time of performance or invoice issuance, as well as the applicable official and judicial practice.

The tax and VAT treatment of transactions related to the Tokens and the Service may differ across jurisdictions. The Service Provider shall act in accordance with the laws applicable to its own operations. The User is responsible for determining and fulfilling their tax obligations under their own jurisdiction.

The Service Provider reserves the right to modify the applied tax or VAT treatment for the future in the event of a change in law, official guidance, or court decision.

13.3. Handling of VAT and Other Public Charges

Unless expressly indicated otherwise, the consideration displayed within the framework of the Service means the full (gross) amount payable by the User. The Service Provider shall determine the applicable tax qualification and any tax liability on the basis of the laws applicable at the time of the transaction.

The Service Provider shall perform the invoicing and documentary recording of transactions on the basis of the laws and the applicable official practice in force at the time of performance. In the case of a consumer contract, the consideration of a transaction already completed for a fixed gross amount may not subsequently be increased, unless this is expressly permitted by mandatory law.

Unless otherwise provided by law, the Service Provider shall not qualify as a withholding agent, tax agent, tax intermediary, or tax advisor of the User, and shall not undertake any obligation to withhold tax advances, file returns, or provide data on behalf of the User.

13.4. EU and Non-EU Users

Tax obligations related to the Tokens and the Service—particularly income tax, withholding tax, or other public charge obligations—may be determined under the rules of the jurisdiction of the User's residence or tax domicile. The User is obliged to become familiar with the tax rules of their own jurisdiction and to fulfil the obligations arising therefrom.

The applicable tax and accounting rules may differ for Users within and outside the European Union.

The Service Provider shall determine the tax qualification of the Tokens and the Service, and any treatment of public charges, on the basis of the laws applicable to its own operations. The Service Provider does not provide tax advice and assumes no responsibility for the tax or accounting qualification applicable to the User under their own jurisdiction.

13.5. E-invoicing and Documentary Records

If the Service Provider issues an invoice or electronic receipt, this serves the accounting and administrative recording of the transaction and does not in itself qualify as proof embodying any investment or ownership right.

The e-invoice or receipt: does not qualify as proof relating to an investment instrument, security, or participation; does not create any rights or guarantees beyond those expressly specified in these GTC; shall not in itself be regarded as any undertaking regarding the market value, future price, or secondary market demand of the Token; does not qualify as a binding statement regarding the legal or tax qualification of the Token.

The tax treatment applied on the invoice is based on the laws and legal interpretation applicable at the time of issuance.

13.6. Taxation of Giveaway and Secondary Market Gains

In certain jurisdictions, Tokens and NFTs acquired within the framework of the Giveaway may qualify as income subject to income tax, a gift, or another taxable benefit, regardless of whether they were acquired without consideration. Depending on the applicable laws, the time of acquisition may qualify as a taxable event if the acquired asset has a determinable market value.

The subsequent sale, transfer, or secondary market trading of the Tokens or NFTs may result in taxable capital gains or other taxable income.

The determination and fulfilment of these obligations are the responsibility of the User in accordance with the rules of their own jurisdiction.

13.7. Final Tax Declaration

The User declares and accepts that: they act in their own name and at their own responsibility; the source of the funds used for the transactions is lawful; they do not participate in the Service for the purpose of tax evasion or any unlawful purpose; they are aware of the tax obligations applicable to them; and they assume full responsibility for fulfilling them.

The User further declares that they do not use the Service for money laundering, terrorist financing, circumvention of international sanctions, tax evasion, or any other unlawful activity, and acknowledges that the Service Provider is entitled to carry out checks in accordance with the applicable anti-money laundering and sanctions laws.

To the fullest extent permitted by applicable law, the Service Provider shall not be liable for determining, declaring, or paying the User's own tax obligations, or for consequences arising from the failure to do so, unless the damage results from the intentional or grossly negligent conduct of the Service Provider.

The User shall be liable under the applicable laws for damages and official burdens directly and verifiably incurred by the Service Provider as a result of the User's false or misleading declarations or unlawful conduct.

14. Amendments

14.1. Reasons for and Framework of Amendments to the GTC

The Service Provider is entitled to unilaterally amend, supplement, or update these GTC if this is justified by an objective, reasonable, and sufficiently substantiated circumstance, in particular in the following cases: due to a change in legislation or regulation, an official requirement, or a court decision; a change affecting the security or lawfulness of the operation of the Service, its technological solutions, Smart Contracts, or IT infrastructure; an amendment necessary for user security, data protection, prevention of abuse, or risk management; a technical or administrative clarification resulting from the development of the Service that is not detrimental to Users.

The amendment may not result in a situation with which a User acting lawfully is not reasonably able to comply, nor may it adversely affect the User's rights guaranteed by law or impose an unjustified or disproportionate burden on the User. In making the amendment, the Service Provider shall take into account the legitimate interests of Users, in particular financial obligations and the conditions for using the Service.

The Service Provider shall publish the amended GTC on the official online interface of the Service in a clearly visible and permanently accessible manner before its entry into force. The GTC shall in all cases be issued with a version number, and the version number and its effective date shall be indicated at the end of the document (version history).

The amendment of these GTC does not affect the application of the mandatory consumer protection laws of the User's place of residence.

14.2. Entry into Force and Obligation to Notify

The amended GTC shall become accessible by being published on the Service Provider's website.

If the amendment affects the User's rights, obligations, or financial burdens ("material amendment"), the Service Provider shall be obliged to notify Users at least 7 days before the amendment enters into force, and the amendment may enter into force no earlier than after the expiry of the 7-day notice period.

In the case of a non-material amendment that is exclusively technical, administrative, or favorable to Users, the GTC may enter into force on the day of publication.

The amended GTC shall apply to the continued use of the Service from its effective date.

14.3. Material Amendment and User Notification

An amendment shall qualify as a material amendment in particular if the change: affects the User's financial obligations; relates to the consideration, settlement, or payment terms; modifies the liability rules; affects the essential conditions of using the Service or the rules of access.

The Service Provider may fulfil the notification obligation by email, through the Service interface, or in the form of a prominent notice published on the website.

If the Service Provider fails to comply with its obligation to notify Users of a material amendment, the amendment may be applied against the User only from the time when proper notice has been given.

14.4. User Acceptance, Rejection, and Consequences

In the event of a material amendment, the Service Provider shall communicate the essence of the amended GTC and its effective date at least 7 days before its entry into force by notification sent to the registered email address, by information displayed on the Service interface, or by a prominent notice published on the website.

Within the specified period, the User is entitled to declare whether they accept or reject the amendment.

If the User does not make any declaration within the 7-day period and continues to use the Service after the amendment enters into force—including in particular participation in the Pre-sale or Giveaway—this shall qualify as acceptance of the amended GTC by implied conduct.

If the User expressly does not accept the material amendment, after the amendment enters into force they may not initiate new participation in the Pre-sale, Giveaway, or other promotional mechanism, and any new results achieved after the amendment enters into force shall not be recorded or taken into account.

Rejection of the amendment does not prevent the User from continuing to use the other functions of the platform.

Rejection of the amendment does not affect: previously achieved leaderboard results, entitlements existing on the basis of previously completed Giveaway or Pre-sale participation, Token or reward entitlements already acquired or due upon fulfilment of the conditions.

In the event of rejection of the amendment, the Service Provider shall not delete the User's account, but shall be entitled to apply the above restrictions.

15. Governing Law and Disputes

15.1. Governing Law

These GTC, as well as all legal relationships related to the use of the Service—including participation in the Pre-sale, the Giveaway, and transactions related to the Tokens—shall be governed by the law of the state of the Service Provider's registered seat, with due regard to the mandatory provisions of directly applicable legal acts of the European Union, excluding conflict-of-law (private international law) rules.

If the User is a natural person residing in a Member State of the European Union, the choice of governing law set out in these GTC shall not prejudice the rights granted to the User by the mandatory consumer protection rules of the state of their residence.

The User acknowledges that the law of the state of their residence or place of stay may impose additional obligations on them, the fulfilment of which is exclusively their responsibility.

15.2. Jurisdiction and Court Proceedings

Any disputes arising between the Service Provider and the User shall primarily be settled by negotiation and in the framework of good-faith consultation.

The User may, as a rule, assert their claim individually and is not entitled to act within the framework of collective or class action proceedings, unless this is mandatorily permitted by the applicable law.

If the consultation between the parties does not lead to a result: a User residing in an EU Member State is entitled to bring proceedings before the competent court of their place of residence; the Service Provider may bring proceedings against the User only before the court of the User's place of residence, provided that the User qualifies as a consumer and the proceedings are brought in accordance with consumer protection rules; in the case of a User residing outside the EU—without prejudice to mandatorily applicable private international law rules—the court having jurisdiction at the Service Provider's registered seat shall have competence.

These provisions do not restrict the rules of court jurisdiction arising from mandatorily applicable laws.

15.3. Alternative Dispute Resolution (ADR / ODR)

A natural person User residing in the EU is entitled, under consumer protection laws, to use alternative dispute resolution (ADR) procedures or an online dispute resolution platform (ODR), if permitted by the applicable law.

The Service Provider is entitled—but not obliged—to participate in alternative dispute resolution proceedings, unless this is required by mandatory law.

The parties may, by mutual written agreement, decide to use arbitration proceedings, provided that this does not restrict the User in exercising their rights arising from mandatory consumer protection rules.

15.4. Preservation of Liability and Risk Provisions

The provisions of this Chapter do not affect: the limitations of liability regarding the technological, blockchain, and Smart Contract risks set out in Chapter 10; the tax liability rules set out in Chapter 13; the User's declaration that they act exclusively in their own name and for their own benefit.

These provisions shall remain fully applicable also in the event of a dispute.

15.5. Electronic Acceptance

The Parties accept that the electronic acceptance of these GTC—including pressing the "I accept" button on the Service Provider's website, transaction activity carried out by the User, or other implied conduct (e.g. financial transactions, token purchases, etc.)—shall qualify as an agreement with full probative value.

These acts shall have all legal effects as if the User had signed the paper-based document by hand.

16. Payment Terms and Payment Process

16.1. Operation of the Payment System

The acquisition of Tokens within the framework of the Pre-sale is possible exclusively electronically, through an online payment system.

On the Service Provider's website, the User: selects the quantity of Tokens they wish to purchase or the amount in USDC to be paid; fills in the billing details requested by the Service Provider; and is then redirected to the interface of the payment service provider (Coingate) by activating the "Check Out" function.

The payment transaction is processed through the corporate payment infrastructure provided by Coingate. On Coingate, the User may complete the payment using crypto-assets (e.g. USDC or another supported crypto-asset).

Any fees applied by Coingate in connection with the processing of the payment transaction shall be borne by the Service Provider, unless any fee or network cost arises from the specific nature of the transaction or from the payment method, wallet, or blockchain network chosen by the User, and is charged directly to the User under the rules of the payment service provider or the blockchain network.

16.2. Third-Party Payment Service Provider

During the processing of the payment process, Coingate acts as an independent third party separate from the Service Provider.

The payment transaction is subject to the privacy policy and the provisions of the Shopper Disclaimer applicable to the system operated by Coingate.

The Service Provider does not qualify as a payment service provider and does not provide payment services.

The Service Provider's liability does not extend to delays or performance issues resulting from Coingate's operation, system error, compliance decision, transaction hold, or technical error.

This limitation of liability does not affect the Service Provider's liability arising from its intentional or grossly negligent conduct.

16.3. Finality of Transactions and Blockchain Specificities

Transactions executed on the blockchain are by their nature irreversible.

Before making the payment, the User is obliged to verify: the correctness of the wallet address; the amount to be paid; the selected network.

In the event of a transaction initiated to an incorrect address, on an incorrect network, or with an incorrect amount, the Service Provider shall not be obliged to refund the transaction, provided that the error did not originate from the Service Provider's system.

A refund of the transaction may take place in accordance with the exercise of the right of withdrawal, where the refund is lawfully initiated by the User, in accordance with point 8.3 of these GTC.

16.4. Invoicing and Tax Information

Following successful completion of the payment, the Service Provider shall issue an electronic invoice through the use of a third-party service, which the User shall receive at the email address attached to their profile.

On the invoice: the amount paid shall be indicated in USD; and the equivalent amount in official Hungarian Forint (HUF) applicable on that day shall also be displayed.

The invoice is a gross invoice on which the VAT rate is 0%, on the basis of the relevant Hungarian and European Union tax rules, with regard to the sale of crypto-assets.

The User is obliged to provide truthful data during registration. The Service Provider shall not be liable for invoicing problems arising from incorrect or incomplete data, provided that the error did not occur in the Service Provider's system.

16.5. Compliance and Refusal of Transactions

The Service Provider and the payment service provider (Coingate) are entitled to refuse or suspend the transaction if: suspicion of money laundering, fraud, or abuse arises; the User has provided false, incomplete, or misleading data; this is justified by a legal or regulatory obligation.

Such decisions shall qualify as measures based on legal, compliance, or risk management grounds.

17. Final Provisions

17.1. Completeness and Acceptance of the GTC

The User declares and accepts that these GTC constitute the complete and legally binding agreement with the Service Provider regarding the use of the Service, and contain all terms, rights, and obligations relating to the use of the Service.

The User acknowledges that acceptance of these GTC is a condition for the use of certain functions of the Service, including in particular participation in the Pre-sale and the Giveaway, as well as the handling of scores recorded on the Leaderboards.

If the User does not accept the amended GTC, they shall not be entitled to participate in the functions concerned; however, they may still browse the Service Provider's website and use the Mini Game function. Their new results on the Leaderboards shall not be recorded or taken into account, but their previous results and previously completed Giveaway or Pre-sale participations shall remain valid.

Electronic acceptance—including clicking the "I accept" button on the website, transaction activity, or other implied conduct (e.g. any participation in the Pre-sale or Giveaway)—shall have full probative value and shall legally qualify as acceptance of the GTC.

17.2. Invalidity and Partial Ineffectiveness

If any provision of these GTC proves to be invalid, null and void, unenforceable, or unlawful under any jurisdiction, this shall not affect the validity, effectiveness, or enforceability of the remaining provisions.

The parties undertake to replace the invalid or unenforceable provision with a legally valid and enforceable provision that comes as close as possible to the original intent of the parties.

17.3. User Responsibility and Acknowledgement

The User acknowledges that: acceptance of these GTC is legally binding and enforceable against them in relation to the Service Provider; in using the Service, they are obliged to comply with all provisions of the GTC, including the rules relating to taxation, liability, and intellectual property; the prior notice and declaration rules set out in Chapter 14 shall apply to the acceptance of material amendments, while non-material amendments shall enter into force upon publication on the website; only eligible natural persons defined in Chapter 6 may participate in the Pre-sale and Giveaway; the User declares that they participate in their own name, without representing a legal entity.

17.4. Notices and Communication

The Service Provider shall publish notices, amendments, or legal communications related to these GTC on its website, by email, or through communication channels integrated into the Service.

The User is obliged to regularly review the latest version of the GTC published by the Service Provider and acknowledges that the Service Provider fulfils its information obligation through such publication.

17.5. Final Declaration

All provisions of these GTC, including the final provisions, shall be interpreted in accordance with the applicable international, EU, and local laws.

The User acknowledges that the use of the Service is possible only upon acceptance of these GTC, and that all related legal consequences shall be borne by them, without prejudice to the consumer protection rights provided by the applicable laws.

The User uses the Service exclusively in their own name and at their own risk, and acknowledges that the Service Provider assumes no liability in accordance with the limitations of liability set out in Chapters 10, 11, and 13.