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Impact.

2.1 Eligibility & Registration

2.1.1 You must be at least 16 years old to create and use an account on the Service. If you are under the age of 18, you represent that you have obtained permission from a parent or legal guardian where required by applicable law.

2.1.2 You agree to:

•       create only one personal account, unless otherwise approved by the Company

•       provide accurate, current, and complete information during registration

•       keep your account information up to date at all times

2.1.3 Accounts are personal to you and may not be transferred, sold, or shared with others.

2.1.4 We may require account verification, including but not limited to:

•       email or phone confirmation

•       one-time passcode (OTP) delivered via SMS to a registered phone number

•       two-factor authentication

•       CAPTCHA or identity verification

2.1.5 Phone Number Registration:

You may provide a phone number during registration. This number may be used to:

•       verify your identity via one-time passcode (OTP) delivered by SMS

•       enable or recover access to your account

•       satisfy eligibility requirements for features restricted to U.S. residents, including GivWin. Providing a phone number is optional at registration but required for certain features. You represent that any phone number you provide belongs to you and that you are authorized to receive SMS messages at that number. Standard messaging and data rates from your carrier may apply.

2.1.6 We reserve the right to deny, suspend, or revoke access if verification fails or if fraudulent activity is suspected.

2.1.7 If you register using third-party authentication providers (such as Apple or Google), you authorize us to receive certain account information as permitted by those providers.

2.2 Account Security

2.2.1 You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account.

2.2.2 You agree:

•       not to share your password or authentication credentials with any third party

•       to use appropriate security measures, such as strong passwords and enabling two-factor authentication where available

2.2.3 We will never ask you to provide your password via email, message, or phone.

2.2.4 If you suspect unauthorized access to your account, you must notify us immediately. We may:

•       suspend or restrict access

•       require credential updates

•       investigate suspicious activity

2.2.5 We may also implement security measures such as session revocation or additional verification if unusual activity is detected.

2.3 Password Management

2.3.1 You may update your password at any time through your account settings.

2.3.2 If you forget your password:

you may request a reset using the available recovery options, which may include

•       a link sent to your registered email address or

•       a one-time passcode (OTP) sent via SMS to your registered phone number;

•       reset links or codes may expire after a limited time.

2.3.3 Following a password reset or detection of suspicious activity, we may:

•       log out active sessions

•       temporarily restrict certain features

•       require re-authentication

2.3.4 We may enforce password requirements, including minimum complexity and restrictions on reuse.

2.4 Profile & Account Information

2.4.1 You may update certain profile information within the Service, such as display name or profile image.

2.4.2 You agree that:

•       your profile information must be accurate and lawful

•       you will not impersonate any person or entity

•       you will not use offensive, abusive, or unlawful content in your profile

2.4.3 We reserve the right to remove or restrict profile content or accounts that violate these Terms.

2.4.4 You must maintain at least one valid and accessible contact method, such as an email address, or verified phone number, to receive important communications, including account security alerts and one-time passcodes (OTPs)

2.4.5 You are responsible for maintaining access to and securely storing any important information associated with your account, including rewards or redemption details provided through the Service.

2.5 Session Management & Inactivity

2.5.1 You may sign out of your account at any time. When using shared devices, you are responsible for signing out after use.

2.5.2 For security purposes, we may:

•       automatically log you out after periods of inactivity

•       require re-authentication after changes to critical account settings

•       terminate active sessions if suspicious activity is detected

2.5.3 We may classify accounts as inactive after prolonged periods of non-use. In such cases, we may:

•       limit access to certain features

•       deactivate the account

•       notify you prior to any material action where possible

2.6 Account Deactivation & Termination

2.6.1 You may request to deactivate or delete your account through the Service or by contacting us.

2.6.2 We may provide a limited period during which your account can be restored before permanent deletion.

2.6.3 After deletion:

•       your access to the Service will be terminated

•       any data, content, rewards, or benefits associated with your account may be permanently deleted or become inaccessible

•       certain data may be retained where required for legal, security, or operational purposes, as described in our Privacy Policy

2.6.4 You acknowledge and agree that:

•       you are solely responsible for saving or securely storing any reward-related information, including but not limited to gift card codes, redemption details, or other benefits obtained through the Service

•       the Company is not responsible for any loss of such information resulting from account deletion, app uninstallation, device changes, or loss of access to your account

•       we are not obligated to recover, restore, or reissue any rewards, codes, or associated data once your account has been deleted or access is lost

2.6.5 We reserve the right to suspend or terminate accounts at any time in cases including, but not limited to:

•       violation of these Terms

•       suspected fraud or abuse

•       security risks

•       legal or regulatory requirements

2.7 Communications & Notices

2.7.1 By creating an account, you agree to receive communications related to the Service, including:

•       security alerts

•       verification messages

•       service updates

•       policy changes

2.7.2 You may opt out of marketing communications where applicable, but you will continue to receive essential service-related messages.

2.7.3 You are responsible for maintaining accurate contact information to ensure you receive important notices.

2.7.4 Material changes to these Terms will be communicated with at least 30 days’ advance notice where reasonably practicable, via the Service or email. Your continued use of the Service after the effective date constitutes acceptance of the revised Terms.

2.7.5 SMS Communications: If you provide a phone number, we may use it to deliver:

•       one-time passcodes (OTPs) for account verification and login

•       security alerts related to your account

•       service notifications where you have opted in to SMS communications.

You may opt out of non-essential SMS communications at any time. You will continue to receive OTPs and security-critical messages while your phone number is registered with the Service. Standard messaging and data rates from your carrier may apply to all SMS messages. To opt out of SMS messages at any time, reply STOP. For assistance, reply HELP.

2.8 Prohibited Account Activities

2.8.1 You agree not to:

•       create accounts on behalf of others without authorization

•       buy, sell, transfer, or share accounts

•       use automated tools, bots, or scripts to create or access accounts

•       attempt to bypass security measures or access restricted areas of the Service

2.9 Changes to Account Terms

2.9.1 We may update this section from time to time. If changes are material, we will provide at least 30 days’ advance notice, such as through the Service or via email.

2.9.2 Your continued use of the Service after such changes constitutes acceptance of the updated Terms.

2.10 Contact for Account Issues

2.10.1 If you have questions regarding your account, you may contact us through the support channels provided within the Service or via our official contact methods described in Section 14.

3.1 Rewards System Overview

3.1.1 The Service provides a rewards system consisting of:

•       Coins — redeemable virtual rewards

•       Status Points — non-redeemable engagement points

3.1.2 These are collectively part of the in-app reward system and are subject to these Terms.

3.1.3 Coins and Status Points:

•       are not money and have no independent monetary value

•       cannot be transferred, sold, or exchanged outside of the Service

•       may be modified, restricted, or discontinued at any time at the Company’s discretion, subject to applicable law

3.2 Coins (Redeemable Rewards)

3.2.1 Earning Coins

3.2.1.1 Users may earn Coins through engagement with the Service, including but not limited to:

•       interacting with advertising content

•       participating in in-app campaigns or promotions

•       referral programs

•       other activities defined within the Service

3.2.1.2 The Company reserves the right to:

•       modify earning methods at any time

•       limit or deny Coins in cases of suspected fraud, abuse, or technical manipulation

3.2.2 Nature of Coins

3.2.2.1 Coins:

•       have no cash value

•       cannot be redeemed for money

•       cannot be transferred, sold, or exchanged between users

•       may only be used within the Service for available rewards

3.2.2.2 Coins do not expire by default. However, the Company reserves the right to introduce expiration or usage conditions in the future with at least 30 days’ advance notice to affected users.

3.2.3 Redemption of Coins

3.2.3.1 Coins may be redeemed within the Service for available rewards, including but not limited to:

•       digital gift cards and other features or programs, which may be subject to additional terms defined in these Terms

•       participation in community engagement initiatives (e.g., GivWin), which may provide users with access to rewards or benefits as defined within the Service

3.2.3.2 Redemption is subject to:

•       availability of rewards

•       minimum thresholds displayed in the Service

•       account eligibility and good standing

3.2.3.3 We may impose limits on redemption, including:

•       daily or periodic redemption caps

•       restrictions based on user activity or account status

3.2.3.4 Such limits may be applied to prevent fraud, abuse, or misuse of the Service.

3.3 Status Points (Non-Redeemable) & Streak System

3.3.1 Nature & Purpose

3.3.1.1 Status Points:

•       are non-redeemable

•       have no monetary value

•       cannot be exchanged for Coins, gift cards, or external value

3.3.1.2 They are used solely to:

•       determine user status levels

•       unlock or provide access to in-app features or privileges

3.3.2 Earning Status Points

3.3.2.1 Users may earn Status Points through engagement within the Service, including:

•       browsing or interacting with content

•       maintaining daily activity streaks by meeting defined engagement thresholds within a specified time period

•       participating in features or campaigns

•       referrals

3.3.3 Expiration & Status Updates

3.3.3.1 Status Points:

•       expire 12 months after they are earned; expiration always occurs at the end of the corresponding calendar month in which the points were originally earned

•       are subject to periodic recalculation and updates

3.3.3.2 User status levels:

•       are determined dynamically based on available Status Points

•       are upgraded immediately when the user reaches the threshold for a higher level

•       may be downgraded at the end of the month if the user’s available Status Points fall below the threshold for their current level

3.3.3.3 Privileges associated with status levels:

•       are defined within the Service

•       may change at any time at the Company’s discretion

3.3.4 Daily Activity Streak

3.3.4.1 Status Points may be awarded based on a user’s daily activity streak.

3.3.4.2 A daily activity streak is achieved when a user meets the required engagement threshold within a defined time period (for example, earning a minimum number of Coins within a 24-hour period), as determined by the Service.

3.3.4.3 When a user qualifies for a streak:

•       their streak count increases

•       Status Points are awarded progressively based on consecutive qualifying days

•       a maximum number of Status Points per day may apply

3.3.4.4 If the user does not meet the required threshold within the defined period:

•       the streak may reset

•       progression may restart from the initial level

3.3.4.5 All thresholds, timing rules, and reward structures are defined within the Service and may be updated at any time.

3.4 Fraud, Abuse & Adjustments

3.4.1 We reserve the right to:

•       deny, adjust, or revoke Coins or Status Points

•       cancel redemptions

•       restrict access to rewards

3.4.2 Such actions may be taken in cases including, but not limited to:

•       fraud or suspected fraud

•       abuse of the reward system

•       use of bots, automation, or manipulation

•       account sharing or misuse

•       technical errors or system anomalies

3.4.3 Users found in violation of these Terms may forfeit rewards without compensation.

3.5 Modifications to Rewards System

3.5.1 We reserve the right to:

•       modify, suspend, or discontinue any part of the rewards system

•       change earning methods, redemption options, or availability

•       introduce new limits, conditions, or expiration rules

3.5.2 Changes may be made at any time, with or without notice, unless otherwise required by law.

4.1 Ads & Rewarded Advertising

4.1.1 General

4.1.1.1 The Service may include advertising content that allows users to earn rewards through interaction (“Rewarded Ads”).

4.1.1.2 Participation in Rewarded Ads is voluntary and subject to availability.

4.1.2 Reward Eligibility

4.1.2.1 To qualify for rewards from a Rewarded Ad, users must:

•       view or interact with the advertisement as required by the Service

•       complete the advertisement or required interaction as defined within the Service

4.1.2.2 Rewards may not be granted if:

•       the advertisement is not fully completed

•       the interaction does not meet the required conditions

•       technical or network issues prevent proper validation

4.1.3 Nature of Rewards

4.1.3.1 Rewarded Ads may grant users:

•       Coins

•       Status Points, in certain cases as defined within the Service

4.1.3.2 The amount of rewards:

•       may vary depending on the advertisement, campaign, or provider

•       is determined by the Service and third-party advertising partners

•       may be presented as an estimated or maximum value (e.g., “Earn up to [X] Coins”)

4.1.3.3 Actual rewards may differ based on:

•       ad content

•       completion criteria

•       advertiser conditions

•       other factors outside the Company’s control

4.1.4 Reward Limitations

4.1.4.1 Certain Rewarded Ads:

•       may only grant rewards once per user, regardless of repeated views

•       may be subject to frequency limits or availability restrictions

•       may be modified, limited, or removed at any time

4.1.5 No Guarantee of Rewards

4.1.5.1 The Company does not guarantee that:

•       any specific advertisement will be available

•       any specific reward amount will be granted

•       rewards will be issued in all cases

4.1.5.2 Rewards are conditional upon successful validation of the required interaction.

4.1.6 Errors, Delays & Support

4.1.6.1 In some cases, rewards may not be correctly granted due to:

•       technical errors

•       network issues

•       third-party provider failures

•       validation or tracking issues

4.1.6.2 If a user believes a reward was not properly granted, they may contact support through the Service.

4.1.6.3 The Company will review such requests at its discretion but:

•       does not guarantee correction, adjustment, or issuance of rewards

•       reserves the right to determine eligibility based on available system data and third-party verification

4.1.7 Third-Party Advertising

4.1.7.1 Rewarded Ads are provided by third-party advertising partners.

4.1.7.2 The Company:

•       does not control the content, availability, or performance of such advertisements

•       is not responsible for advertiser actions, offers, or representations

4.2 Referral Program

4.2.1 General

4.2.1.1 The Service may include a referral program (the “Referral Program”) that allows registered users (“Referrers”) to invite other individuals (“Referees”) to join the Service.

4.2.1.2 Participation in the Referral Program is limited to users in good standing and is subject to these Terms.

4.2.1.3 The Referral Program and its conditions may be modified, restricted, or discontinued at any time at the Company’s discretion.

4.2.2 Invitation Methods

4.2.2.1 When inviting others to join the Service:

•       a unique referral link associated with your account may be generated

•       you may share this link using available communication methods (e.g., messaging, email, or social media)

4.2.2.2 The Company does not control or guarantee the delivery of referral links shared through third-party platforms.

4.2.3 Referral Tracking

4.2.3.1 Each referral link contains a unique identifier used to attribute registrations to the Referrer.

4.2.3.2 A referral will be considered valid only if:

•       the Referee registers using the referral link within the timeframe defined within the Service

•       the Referee completes required qualifying actions (such as initial engagement or earning Coins), as defined within the Service

4.2.3.3 Referral attribution and validation are determined by the Company based on available system data.

4.2.4 Rewards

(a) Referrer Rewards

4.2.4.1 If the applicable referral conditions are met, the Referrer may receive rewards, which may include:

•       Coins

•       Status Points

4.2.4.2 The type and amount of rewards are defined within the Service and may change at any time.

(b) Referee Rewards

4.2.4.3 In some cases, Referees may receive welcome rewards, including Coins, upon registration and completion of required activities, if such rewards are made available or announced within the Service.

4.2.4.4 Eligibility, timing, and conditions for such rewards are determined within the Service.

(c) Limits

4.2.4.5 The Company may impose limits on the Referral Program, including:

•       maximum number of referrals per user

•       limits per device, account, or time period

•       eligibility requirements based on user activity or account status

4.2.5 Fraud & Abuse

4.2.5.1 The Company reserves the right to deny, withhold, adjust, or revoke referral rewards in cases of suspected fraud or abuse, including but not limited to:

•       self-referrals

•       creation of fake or duplicate accounts

•       use of bots, automation, or manipulation

•       misleading or deceptive referral practices

4.2.5.2 Accounts involved in such activity may be restricted or suspended in accordance with these Terms.

4.2.6 User Responsibilities

4.2.6.1 By participating in the Referral Program, you agree:

•       to use the program in a lawful and responsible manner

•       to send invitations only to individuals who are likely to welcome such communication

•       not to engage in spam, bulk messaging, or unsolicited outreach

4.2.7 Disclaimer

4.2.7.1 The Company does not guarantee:

•       successful delivery of referral invitations

•       successful tracking or attribution of referrals in all cases

•       availability or issuance of rewards

4.2.7.2 Referral rewards are conditional upon proper validation of referral activity.

4.2.8 Changes to Referral Program

4.2.8.1 The Company may modify, suspend, or discontinue the Referral Program, including:

•       reward structures

•       eligibility criteria

•       validation requirements

4.2.8.2 Continued participation in the Referral Program constitutes acceptance of such changes.

4.3 Hot Deals

4.3.1 Overview

4.3.1.1 The Service may include a “Hot Deals” feature that allows users to submit, view, and interact with content (“Hot Deals”) within the Service.

4.3.1.2 Hot Deals may enable user engagement through actions such as viewing, liking, and reporting, and may provide opportunities for users to earn rewards based on engagement, as defined within the Service.

4.3.2 Submission of Hot Deals

4.3.2.1 Registered users may submit Hot Deals through the Service.

4.3.2.2 By submitting a Hot Deal, you agree that:

•       your submission will be subject to review and moderation by the Company

•       your Hot Deal may be approved, rejected, or removed at the Company’s discretion

•       you may not be able to edit or delete a submitted or published Hot Deal

4.3.2.3 Submission requirements, formats, and conditions are defined within the Service and may be updated at any time.

4.3.3 Moderation & Publication

4.3.3.1 All submitted Hot Deals are subject to moderation before publication.

4.3.3.2 The Company may:

•       approve or reject any submission

•       assign categories or classifications

•       determine the duration of visibility or availability

•       remove or unpublish content at any time

4.3.3.3 Approved Hot Deals are published at 12:00 AM following their approval. The Company is not obligated to publish any submitted Hot Deal.

4.3.4 User Interaction

4.3.4.1 Users may interact with published Hot Deals through features such as:

•       viewing

•       liking or unliking

•       reporting content

4.3.4.2 Interaction rules may include:

•       users may only like a Hot Deal once

•       duplicate or manipulated interactions may be restricted or removed

•       reported content may be reviewed and subject to moderation actions

4.3.5 Reporting & Enforcement

4.3.5.1 Users may report Hot Deals for inappropriate or non-compliant content.

4.3.5.2 The Company may:

•       review reported Hot Deals

•       temporarily hide or restrict content

•       permanently remove content

•       restrict or ban users from submitting future Hot Deals

4.3.5.3 Actions taken are at the Company’s discretion based on internal policies and system data.

4.3.6 Rewards & Eligibility

4.3.6.1 Each published Hot Deal competes for a period of 7 days from the date of publication. At the end of each day, the Hot Deal published exactly 7 days earlier is evaluated for a reward. The Hot Deal with the highest number of likes at the end of its 7-day period may receive the defined reward, subject to meeting the minimum engagement threshold.

4.3.6.2 Rewards:

•       may include Coins and, in some cases, Status Points

•       are subject to eligibility criteria defined within the Service

•       require a minimum number of likes, as defined within the Service, to qualify

4.3.6.3 The calculation of rewards:

•       is based on system-recorded engagement data

•       may depend on configurable time periods and conditions

•       may consider comparative performance among Hot Deals

4.3.7 No Guarantee of Rewards

4.3.7.1 The Company does not guarantee that:

•       any submitted Hot Deal will receive engagement

•       any Hot Deal will qualify for rewards

•       any specific number of likes or interactions will result in rewards

4.3.7.2 Rewards are conditional upon meeting all applicable criteria and validation requirements.

4.3.8 Accuracy & System Limitations

4.3.8.1 Reward calculations and engagement tracking are based on system data.

4.3.8.2 In some cases, inaccuracies may occur due to:

•       technical errors

•       delayed or incomplete tracking

•       system or network limitations

4.3.8.3 The Company reserves the right to:

•       determine final reward eligibility

•       adjust or deny rewards where inconsistencies or errors are identified

4.3.8.4 Users may contact support if they believe an error has occurred; however, the Company does not guarantee correction or issuance of rewards.

4.3.9 Content Responsibility

4.3.9.1 By submitting a Hot Deal, you represent and warrant that:

•       you have the right to share the content

•       the content does not violate any laws or third-party rights

•       the content is not misleading, harmful, or inappropriate

4.3.9.2 The Company is not responsible for user-generated content and does not guarantee its accuracy or reliability.

4.3.10 Feature Changes

4.3.10.1 The Company may modify, suspend, or discontinue the Hot Deals feature at any time, including:

•       submission rules

•       moderation processes

•       reward mechanisms

•       visibility and ranking logic

4.4 Gift Cards

4.4.0 This section applies to gift cards obtained through the redemption of Coins within the Service (“Redeemed Gift Cards”). Additional terms may apply to other types of gift cards that may be introduced in the Service in the future.

4.4.1 Fulfillment & Delivery

4.4.1.1 Gift cards are provided through authorized third-party providers and are delivered digitally within the Service.

4.4.1.2 Users are responsible for:

•       accessing their account to retrieve gift card details

•       securely storing any codes or redemption information

4.4.2 User Responsibility

4.4.2.1 You acknowledge and agree that:

•       once a gift card or code is displayed or delivered, you are solely responsible for its safekeeping

•       the Company is not responsible for lost, stolen, or inaccessible gift card codes

•       deletion of the app, loss of device access, or account deletion may result in permanent loss of access to gift card information

4.4.2.2 We are not obligated to reissue or recover any gift card codes once delivered.

4.4.3 Merchant Terms

4.4.3.1 All gift cards are subject to the terms, conditions, and policies of the issuing merchant, including:

•       expiration dates

•       usage restrictions

•       regional limitations

4.4.3.2 You are responsible for reviewing and complying with the merchant’s terms.

4.4.3.3 The Company is not responsible for:

•       acceptance of gift cards by merchants

•       merchant-specific restrictions or expiration

•       issues arising from use of the gift card

4.4.3.4 Any disputes must be resolved directly with the issuing merchant.

4.4.4 Finality

4.4.4.1 All redemptions are final. Gift cards cannot be refunded, exchanged, or reversed once issued.

4.5 GivWin (Community Engagement Initiative)

4.5.1 Overview & Nature of GivWin

4.5.1.1 The Service may include a feature known as “GivWin,” which is a community engagement initiative centered on creating real impact in local communities. Each GivWin is built around a specific community cause, event, or initiative. Users participate by engaging with and supporting that cause. As a gesture of appreciation for their contribution, participating users receive the opportunity to be selected for a reward. The community impact is the primary purpose of GivWin; the reward is secondary and offered as an expression of appreciation.

4.5.1.2 Participation in GivWin is voluntary and does not require any monetary payment.

4.5.1.3 Coins used within GivWin represent in-app engagement value and may be contributed by users to support community-related activities. Such contributions do not constitute a purchase, payment, or donation in a legal or financial sense.

4.5.1.4 Each GivWin may have specific conditions, limits, and requirements, which are defined within the Service.

4.5.2 Types of GivWin

4.5.2.1 GivWin may be offered in different formats, including but not limited to:

(a) Community GivWin

4.5.2.2 Users may contribute Coins to support community-related activities and receive participation associated with such contributions. Community GivWin events may be restricted to users who have reached a specific membership level within the Service, as displayed within the app. Membership levels are cumulative, meaning a user at a higher level automatically meets requirements for lower-level GivWins. AMOE participants are exempt from membership level requirements.

(b) Campaign or Promotional GivWin

4.5.2.3 Certain GivWin campaigns may be offered for promotional or onboarding purposes (e.g., QR campaigns), where participation is granted without the use of Coins.

(c) Volunteer GivWin

4.5.2.4 Separate GivWin instances may be conducted for volunteers as part of appreciation initiatives. These are independent from other GivWin activities and do not share participation pools. Volunteer GivWin is open to recognized volunteers aged 16 and older. Volunteers under 18 must have verifiable parental or guardian consent on file with the Company, collected during volunteer onboarding.

4.5.3 Eligibility Requirements

4.5.3.1 To participate in any GivWin, users must:

•       be registered users of the Service

•       be at least 18 years of age (Community GivWin and Campaign GivWin), or at least 16 years of age with verifiable parental or guardian consent on file (Volunteer GivWin only)

•       be residents of the United States

4.5.3.2 Participation may require:

•       verification of a valid U.S. phone number associated with the user’s account, which may be confirmed via one-time passcode (OTP) delivered by SMS;

•       confirmation of identity and residency upon selection as a potential winner.

4.5.3.3 The Company reserves the right to disqualify any participant who does not meet these requirements.

4.5.3.4 GivWin is void where prohibited or restricted by law. It is the participant’s sole responsibility to determine whether participation is lawful in their jurisdiction.

4.5.3.5 Phone Number Purpose for GivWin:

A valid U.S. phone number is required for GivWin participation. This requirement serves to:

•       verify the user’s U.S. residency status

•       enable winner contact and identity confirmation after selection

•       support fraud prevention and account integrity.

Users without a verified phone number on their account may be prompted to add and verify one before participating. For AMOE participants, the phone number associated with the ClkN’Collect account must be provided on the postcard submission.

4.5.4 Participation Methods

(a) Participation via Coins (Community GivWin)

4.5.4.1 Users may participate by contributing Coins where applicable:

•       Coins are deducted from the user’s balance at the time of participation

•       each participation generates a unique participation identifier

•       multiple participations may be allowed, subject to limits defined within the Service

4.5.4.2 Coins used for participation may be applied by the Company toward supporting community-related activities associated with the GivWin.

(b) Alternative Method of Entry (AMOE)

4.5.4.3 For Community GivWin only, users may participate without using Coins through an alternative method of entry (“AMOE”). AMOE is not available for Campaign GivWin or Volunteer GivWin. AMOE participation is a two-step process: (1) submit a postcard to request a free participation credit, and (2) log into the app and activate that credit before the GivWin closes. Both steps must be completed for the entry to be valid.

4.5.4.4 To participate without using Coins, send a postcard to:

4.5.4.5 The postcard must include:

•       Full Name

•       Email Address

•       ClkN’Collect User ID

●     U.S. Phone Number (associated with your ClkN’Collect account)

•       Name of the GivWin

•       Postcard must be received by the same deadline defined within the Service for the applicable GivWin (refer to the GivWin closing date displayed in the app)

4.5.4.6 Each valid postcard submission will receive one (1) participation per postcard. If a user intends to submit multiple postcards for the same GivWin, each postcard must clearly indicate its sequence number out of the total number of postcards the user plans to send (for example, writing “3 out of 5” means that postcard is the 3rd card and the user intends to send 5 postcards in total). This numbering helps the Company identify and follow up on any missing submissions in the sequence.

4.5.4.7 AMOE participation:

•       is processed and validated by the Company

•       results in a free participation credit being added to the user’s ClkN’Collect account (Step 1 complete); the user must then log into the app and activate that credit before the GivWin closes (Step 2) for the entry to be valid

•       provides equal opportunity of selection as participation through Coins

•       is limited to the specific GivWin for which it is submitted

•       must be submitted separately for each participation

4.5.4.8 Additional conditions:

•       AMOE participation is not automatic and requires manual validation

•       AMOE participation may only be reflected within the Service after applicable conditions are met, including minimum participation thresholds where applicable

•       AMOE participation does not carry forward to future GivWin activities

•       Participation Limits

4.5.4.9 Each GivWin may define:

•       maximum participations per user

•       limits per device, account, or participation method

4.5.4.10 These limits apply to all participation methods, including Coins and AMOE.

4.5.5 Participation Mechanics

4.5.5.1 Each participation generates a unique identifier (e.g., a multi-digit number) used for tracking and selection.

4.5.5.2 Users may:

•       have multiple participations where permitted

•       view their participation identifiers within the Service

4.5.5.3 All participation records are maintained by the system and used for selection purposes.

4.5.6 Minimum Participation Threshold & Cancellation

4.5.6.1 Each Community GivWin defines both a minimum and a maximum total number of participations across all participants. The GivWin will not proceed if the minimum threshold is not reached. Participation closes automatically once the maximum threshold is reached, regardless of remaining time. Where AMOE credits have not been activated before the GivWin closes for either reason, they will be forfeited.

4.5.6.2 If the minimum threshold is not met:

•       the GivWin may be cancelled

•       Coins used for participation will be refunded

•       AMOE participation will not carry forward and must be resubmitted for future GivWin activities

4.5.7 Winner Selection Process

4.5.7.1 Each GivWin will have one (1) winner, unless otherwise specified.

4.5.7.2 The winner is selected through a transparent process that may include:

•       a live selection event using a spinning mechanism

•       sequential selection of digits to form a participation identifier

•       validation that the final selected identifier corresponds to a valid participation

4.5.7.3 If a selected sequence does not correspond to a valid participation, additional selections may be performed until a valid participation is identified.

4.5.7.4 The selection process:

•       may be conducted live (including livestream)

•       may be recorded for transparency

•       results in the publication of the winning participation identifier within the Service

4.5.8 Winner Verification & Claim

4.5.8.1 The selected winner must complete a verification process, which may include:

•       confirmation of identity

•       confirmation of age (18+ for Community GivWin and Campaign GivWin; 16+ for Volunteer GivWin, with parental or guardian verification required for winners under 18)

•       confirmation of U.S. residency

4.5.8.2 If the selected participant:

•       fails to complete verification

•       is found ineligible

•       does not comply with these Terms

4.5.8.3 ...the Company may disqualify the participant and schedule a new selection process.

4.5.9 Prize & Fulfillment

4.5.9.1 Rewards may include, but are not limited to:

•       physical goods

•       digital items

•       other benefits

4.5.9.2 The Company is responsible for fulfilling rewards and may deliver them:

•       in person, where applicable

•       through standard shipping or delivery methods

4.5.9.3 If a reward becomes unavailable, the Company may substitute it with an item of equal or similar value.

4.5.9.4 No cash alternative will be provided.

4.5.10 Sponsor Involvement

4.5.10.1 Certain GivWin activities may involve sponsors who:

•       support events or initiatives

•       provide rewards or resources

•       receive visibility or acknowledgment

4.5.10.2 The Company is not responsible for the actions, products, or services of sponsors.

4.5.11 User Responsibilities & Conduct

4.5.11.1 Users agree not to:

•       create multiple accounts to gain advantage

•       manipulate participation processes

•       engage in fraudulent or abusive behavior

4.5.11.2 Violation of these rules may result in:

•       disqualification

•       loss of participation

•       account restrictions

4.5.12 No Guarantee & Limitation

4.5.12.1 The Company does not guarantee:

•       that any user will be selected as a winner

•       that any GivWin will reach completion

•       availability of participation or rewards

4.5.12.2 All decisions made by the Company regarding GivWin are final and binding.

4.5.13 Modifications & Changes

4.5.13.1 The Company reserves the right to:

•       modify GivWin rules or structure

•       suspend or cancel any GivWin

•       change participation methods, limits, or rewards

4.5.13.2 Changes may occur at any time, subject to applicable law.

4.5.14 Privacy & Transparency

4.5.14.1 The Company may:

•       publish the winning participation identifier

•       provide access to recorded selection events for transparency

4.5.14.2 Personal information of participants will not be publicly disclosed without consent, except as required by law.

4.5.14.3 Content related to GivWin may be archived or removed over time.

4.6 Suggest a Gift

4.6.1 Overview

4.6.1.1 The Service may include a feature that allows users to suggest potential gifts or prizes for future GivWin activities (“Suggested Gifts”).

4.6.1.2 This feature enables users to submit suggestions and, where applicable, participate in voting on suggested gifts.

4.6.1.3 Suggested Gifts are for consideration only and do not guarantee selection or inclusion in any GivWin.

4.6.2 Gift Submission

4.6.2.1 Registered users may submit a Suggested Gift through the Service.

4.6.2.2 By submitting a Suggested Gift, you acknowledge and agree that:

•       your submission may be reviewed, approved, rejected, or removed at the Company’s discretion

•       submission does not guarantee that the suggested gift will be used in any GivWin

•       you may not be able to edit or delete your submission after it is submitted

4.6.2.3 Submission requirements, including required fields, formats, and file limitations, are defined within the Service and may be updated at any time.

4.6.3 Moderation & Visibility

4.6.3.1 All Suggested Gifts are subject to moderation before being displayed within the Service.

4.6.3.2 The Company may:

•       approve or reject any Suggested Gift

•       categorize or classify submissions

•       hide or display submissions on the platform

•       remove any submission at any time

4.6.3.3 The Company is not obligated to display or use any Suggested Gift.

4.6.4 Voting on Suggested Gifts

4.6.4.1 Where voting is available:

•       users may vote on Suggested Gifts within a defined time period

◦       one vote per Suggested Gift

◦       one vote within a defined voting period

4.6.4.2 Voting results:

•       may be used by the Company as a reference in selecting gifts

•       are visible to all users within the Service; the number of likes on each Suggested Gift is publicly displayed

4.6.4.3 Voting does not guarantee that a Suggested Gift will be selected. The Company retains full discretion over final selection decisions.

4.6.5 Selection of Gifts

4.6.5.1 The Company retains full discretion to determine:

•       whether a Suggested Gift will be used

•       which gift will be selected for a GivWin

•       when and how a gift is used

4.6.5.2 Selection may consider factors including, but not limited to:

•       user voting

•       availability

•       relevance

•       operational or business considerations

4.6.6 User Responsibilities

4.6.6.1 By submitting a Suggested Gift, you represent and warrant that:

•       you have the right to share any provided content (including images or links)

•       the content does not violate any laws or third-party rights

•       the submission is accurate and not misleading

4.6.6.2 You agree not to submit content that is:

•       fraudulent

•       inappropriate

•       infringing

•       harmful or deceptive

4.6.7 No Guarantee & Limitation

4.6.7.1 The Company does not guarantee:

•       that any Suggested Gift will be reviewed or approved

•       that any Suggested Gift will be displayed

•       that any Suggested Gift will be selected or used

4.6.7.2 All decisions regarding Suggested Gifts are final and at the sole discretion of the Company.

4.6.8 Feature Changes

4.6.8.1 The Company reserves the right to:

•       modify or discontinue the Suggested Gift feature

•       change submission, moderation, or voting rules

•       restrict or limit user participation

4.6.8.2 Changes may occur at any time.

5.1 Company Ownership

5.1.1 The Service and all of its content, features, and functionality — including but not limited to software, text, graphics, logos, icons, images, audio clips, data compilations, and the overall design and structure of the Service — are owned by Chapeau LLC, its licensors, or other providers, and are protected by United States and international copyright, trademark, patent, trade secret, and other intellectual property laws.

5.1.2 “ClkN’Collect,” the Company logo, and all related names, logos, product and service names, designs, and slogans are trademarks of Chapeau LLC. You must not use such marks without the prior written permission of the Company.

5.2 License to Use the Service

5.2.1 Subject to your compliance with these Terms, the Company grants you a limited, non-exclusive, non-transferable, revocable license to access and use the Service for your personal, non-commercial purposes.

5.2.2 This license does not include the right to:

•       copy, reproduce, distribute, or publicly display any part of the Service

•       modify, create derivative works from, or reverse engineer any part of the Service

•       use any data mining, robots, or similar data gathering or extraction methods

•       download any portion of the Service except as expressly permitted

5.2.3 Any use of the Service not expressly permitted by these Terms is a breach of these Terms and may violate copyright, trademark, and other applicable laws.

5.3 User-Generated Content License

5.3.1 By submitting, posting, or displaying any User Content on or through the Service, you grant the Company a worldwide, non-exclusive, royalty-free, sublicensable, and transferable license to use, reproduce, distribute, prepare derivative works of, display, and perform your User Content in connection with the Service and the Company’s business operations, including for the purposes of promoting and redistributing part or all of the Service.

5.3.2 You represent and warrant that:

•       you own or have the necessary rights, licenses, and permissions to submit User Content and to grant the license above

•       your User Content does not infringe any third-party intellectual property rights, privacy rights, or any other rights

•       your User Content complies with these Terms and all applicable laws

5.3.3 You retain ownership of your User Content. The Company does not claim ownership over User Content you submit. However, by submitting User Content, you acknowledge that the Company may use it in accordance with the license above without compensation to you.

5.4 Feedback

5.4.1 If you provide the Company with any feedback, suggestions, or ideas regarding the Service (“Feedback”), you grant the Company a perpetual, irrevocable, worldwide, royalty-free license to use, incorporate, and exploit such Feedback for any purpose without restriction or compensation to you.

5.5 Copyright Infringement

5.5.1 If you believe that any content on the Service infringes your copyright, please contact us through the support channels provided within the Service with sufficient detail to identify the allegedly infringing material and your contact information.

6.1 General Use of the Service

6.1.1 You agree to use the Service in a lawful, responsible, and respectful manner.

6.1.2 You must comply with:

•       these Terms

•       all applicable laws and regulations

•       any additional rules provided within the Service

6.2 Prohibited Activities

6.2.1 You agree not to engage in any of the following activities:

(a) Fraud & Manipulation

•       creating multiple accounts to gain unfair advantage

•       manipulating rewards, Coins, Status Points, or participation systems

•       attempting to exploit bugs, errors, or unintended functionality

•       falsifying information, including identity or eligibility

(b) Abuse of Features

•       abusing GivWin participation mechanisms

•       submitting false, misleading, or harmful content (e.g., Hot Deals, Suggested Gifts)

•       interfering with voting, engagement, or ranking systems

•       attempting to bypass participation limits or restrictions

(c) Automation & Unauthorized Access

•       using bots, scripts, or automated systems to interact with the Service

•       attempting to access systems, data, or accounts without authorization

•       reverse engineering or attempting to extract source code

(d) Spam & Misuse

•       sending unsolicited messages, spam, or bulk communications

•       misusing referral systems or invitations

•       engaging in deceptive or misleading promotional practices

(e) Harmful or Illegal Conduct

•       uploading or sharing content that is illegal, offensive, or infringing

•       violating intellectual property rights

•       engaging in harassment, abuse, or harmful behavior toward others

6.3 Account Integrity

6.3.1 You are responsible for:

•       maintaining accurate account information

•       safeguarding your account credentials

•       all activity conducted under your account

6.3.2 You may not:

•       share your account with others

•       allow unauthorized access to your account

6.4 Enforcement & Actions

6.4.1 The Company reserves the right to take action in response to violations of these Terms, including:

•       denying or restricting access to features

•       removing or disabling content

•       adjusting or revoking Coins, Status Points, or participations

•       disqualifying users from GivWin or other activities

•       suspending or terminating accounts

6.4.2 Actions may be taken:

•       with or without prior notice

•       based on system data, reports, or internal review

6.5 No Circumvention

6.5.1 You may not attempt to:

•       circumvent restrictions or limitations within the Service

•       recreate access after suspension or termination

•       use alternative accounts or methods to bypass enforcement actions

6.6 Reporting Violations

6.6.1 Users may report suspected violations through the Service.

6.6.2 The Company may investigate and take action at its discretion.

6.7 Company Discretion

6.7.1 The Company retains full discretion to determine:

•       whether a violation has occurred

•       what actions are appropriate

•       how rules are interpreted and enforced

6.7.2 All decisions made by the Company are final, subject to applicable law.

7.1 Right to Suspend or Terminate

7.1.1 The Company reserves the right to suspend, restrict, or terminate your access to the Service, in whole or in part, at any time.

7.1.2 Such actions may be taken:

•       with or without prior notice

•       temporarily or permanently

•       at the Company’s discretion, subject to applicable law

7.2 Grounds for Suspension or Termination

7.2.1 Your account or access to the Service may be suspended or terminated for reasons including, but not limited to:

•       violation of these Terms

•       suspected fraud, abuse, or manipulation

•       failure to meet eligibility requirements (e.g., age, residency)

•       provision of false or misleading information

•       misuse of rewards, GivWin participation, referral systems, or other features

•       security concerns or unauthorized access

•       compliance with legal or regulatory obligations

7.3 Effects of Suspension

7.3.1 If your account is suspended:

•       your access to certain or all features may be restricted

•       you may be prevented from participating in GivWin or other activities

•       rewards, Coins, Status Points, or participations may be temporarily limited or withheld

7.4 Effects of Termination

7.4.1 If your account is terminated:

•       your right to access and use the Service will immediately end

•       your account and associated data may be deleted or made inaccessible

•       any Coins, Status Points, rewards, or participations associated with your account may be forfeited

7.4.2 The Company is not obligated to restore or recover any such data or rewards after termination.

7.5 Disqualification from Activities

7.5.1 The Company may disqualify users from specific activities, including GivWin, without terminating the entire account.

7.5.2 Disqualification may occur if:

•       eligibility requirements are not met

•       rules for a specific activity are violated

•       suspicious or fraudulent behavior is detected

7.5.3 Disqualified users may lose associated rewards or participations without compensation.

7.6 User-Initiated Termination

7.6.1 You may stop using the Service at any time.

7.6.2 You may also request deletion of your account through the Service.

7.6.3 Upon account deletion:

•       access to your account will be permanently removed

•       associated data, rewards, and participation records may be deleted or become inaccessible

7.6.4 You are responsible for retaining any important information (e.g., gift card codes) prior to deletion.

7.7 Reinstatement

7.7.1 The Company is not obligated to reinstate any suspended or terminated account.

7.7.2 Requests for reinstatement may be reviewed at the Company’s discretion.

7.8 Survival

7.8.1 The following provisions shall survive termination of these Terms or your account and shall remain in full force and effect:

•       Section 5 — Intellectual Property

•       Section 8 — Disclaimers & Limitation of Liability

•       Section 9 — Indemnification

•       Section 11 — Governing Law

•       Section 12 — Dispute Resolution & Binding Arbitration

•       Any other provisions that by their nature should survive termination, including limitations of liability and disclaimers

8.1 “As-Is” Service

8.1.1 THE SERVICE IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED.

8.1.2 To the maximum extent permitted by law, the Company makes no warranties or representations of any kind, whether express or implied, including but not limited to:

•       availability or uninterrupted access to the Service

•       accuracy, reliability, or completeness of any content or data

•       performance or functionality of features, including rewards systems and GivWin

•       suitability of the Service for any particular purpose

8.2 No Guarantee of Rewards or Outcomes

8.2.1 The Company does not guarantee:

•       the availability of Coins, Status Points, rewards, or benefits

•       successful participation in any feature, including GivWin

•       that any user will receive or redeem rewards

•       that any Suggested Gift or Hot Deal will be used or promoted

8.2.2 All rewards, participation opportunities, and features are subject to availability and may be modified or discontinued at any time.

8.3 Third-Party Services & Content

8.3.1 The Service may include content, services, or integrations provided by third parties, including but not limited to:

•       advertisers and ad networks

•       affiliate programs (e.g., Amazon or similar partners)

•       gift card providers and merchants

•       sponsors or campaign partners

8.3.2 The Company:

•       does not control or guarantee third-party services

•       is not responsible for the availability, accuracy, or performance of such services

•       is not liable for any transactions, interactions, or disputes between users and third parties

8.3.3 Users are responsible for reviewing and complying with third-party terms and policies.

8.3.4 Where the Service includes affiliate program links, the Company may receive compensation from third-party purchases made through such links. The presence of such links does not constitute an endorsement of the third-party product or service. For full FTC disclosure regarding affiliate and advertising arrangements, see Section 13.12.

8.4 Rewards, Coins & System Errors

8.4.1 The Company is not responsible for:

•       errors in calculating or awarding Coins or Status Points

•       delays, omissions, or inaccuracies in rewards

•       technical failures affecting participation, tracking, or redemption

•       loss of rewards due to system issues, user actions, or account changes

8.4.2 In the event of an error, the Company reserves the right to:

•       correct the error

•       adjust balances or participation

•       reverse transactions or rewards

8.4.3 All such decisions are final, subject to applicable law.

8.5 GivWin & Participation Activities

8.5.1 The Company is not liable for:

•       inability to participate in any GivWin

•       cancellation, delay, or modification of any GivWin

•       disqualification due to failure to meet eligibility or verification requirements

•       failure to claim or receive a reward due to user error or incomplete information

8.5.2 Participation in GivWin and similar activities is at your own discretion and risk.

8.6 Limitation of Liability

8.6.1 TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL CHAPEAU LLC, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, OR LICENSORS BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF DATA, REWARDS, PARTICIPATION, PROFITS, OR GOODWILL, ARISING OUT OF OR IN CONNECTION WITH YOUR USE OF OR INABILITY TO USE THE SERVICE.

8.6.2 IN NO EVENT SHALL THE COMPANY’S TOTAL CUMULATIVE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATED TO THESE TERMS OR THE SERVICE EXCEED THE GREATER OF: (A) FIFTY U.S. DOLLARS ($50.00), OR (B) THE AMOUNT YOU PAID TO THE COMPANY IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM.

8.6.3 Some jurisdictions do not allow the exclusion of certain warranties or limitations on liability. In such jurisdictions, the above limitations shall apply to the fullest extent permitted by applicable law.

8.7 No Liability for User Content

8.7.1 The Company is not responsible for content submitted by users, including but not limited to:

•       Hot Deals

•       Suggested Gifts

•       any other user-generated content

8.7.2 The Company does not guarantee the accuracy, legality, or reliability of such content.

8.8 Force Majeure

8.8.1 The Company shall not be liable for any failure or delay in performance due to events beyond its reasonable control, including but not limited to:

•       natural disasters

•       technical failures or outages

•       governmental actions or regulatory changes

•       network or service interruptions

•       pandemics or public health emergencies

8.9 User Responsibility

8.9.1 You acknowledge that:

•       use of the Service is at your own risk

•       you are responsible for your actions, decisions, and participation within the Service

•       you are responsible for maintaining access to your account and any associated data

9.1 User Indemnification Obligation

9.1.1 You agree to defend, indemnify, and hold harmless Chapeau LLC, its officers, directors, employees, agents, licensors, and service providers from and against any and all claims, liabilities, damages, judgments, awards, losses, costs, expenses, or fees (including reasonable attorneys’ fees) arising out of or relating to:

•       your violation of these Terms

•       your use of the Service, including but not limited to any rewards earned or redeemed

•       your User Content, including any claim that your User Content infringes the rights of a third party

•       your participation in any feature, including GivWin, Hot Deals, or the Referral Program

•       your violation of any applicable law or regulation

•       your misrepresentation of your age, identity, or eligibility

9.2 Company Control of Defense

9.2.1 The Company reserves the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify us, and you agree to cooperate with our defense of such claims.

9.2.2 You agree not to settle any such matter without the prior written consent of the Company.

9.2.3 The Company will use reasonable efforts to notify you of any such claim upon becoming aware of it.

10.1 Purpose & Nature of GivWin

10.1.1 GivWin is designed as a community engagement initiative intended to encourage participation, support activities, and promote positive interaction within the Service.

10.1.2 GivWin is not intended to function as a lottery, raffle, sweepstakes, or gambling activity as defined under applicable federal or state law.

10.1.3 Participation in GivWin:

•       does not require any monetary payment

•       is based on user engagement within the Service

•       is structured as a promotional and community-based activity

10.1.4 Any rewards provided in connection with GivWin are offered as part of this engagement model.

10.2 No Purchase or Payment Requirement

10.2.1 Participation in GivWin does not require:

•       the purchase of goods or services

•       the payment of money

•       any form of financial consideration

10.2.2 Coins used within GivWin:

•       are earned through user engagement within the Service

•       do not represent monetary value

•       are not purchased or exchangeable for money

10.2.3 For Community GivWin, a free Alternative Method of Entry (AMOE) is available to ensure that participation is accessible without the use of Coins. AMOE is not available for Campaign GivWin or Volunteer GivWin, as those formats do not require Coins or any form of consideration to enter.

10.3 Equal Opportunity of Participation

10.3.1 Within the Community GivWin, all valid participation methods — including participation through Coins and participation through AMOE — provide an equal opportunity of selection, subject to compliance with these Terms. Campaign GivWin and Volunteer GivWin do not use AMOE; within those formats, all valid participations carry equal selection probability.

10.3.2 For Community GivWin, a free Alternative Method of Entry (AMOE) is available to ensure that participation is accessible without the use of Coins. AMOE is not available for Campaign GivWin or Volunteer GivWin, as those formats do not require Coins or any form of consideration to enter.

10.4 Eligibility Restrictions

10.4.1 Community GivWin and Campaign GivWin are open only to legal residents of the United States who are at least 18 years of age. Volunteer GivWin is open to legal residents of the United States who are at least 16 years of age and have been recognized as qualifying volunteers; participants aged 16 or 17 must have verifiable parental or guardian consent on file with the Company. For full details, refer to the GivWin Official Rules.

10.4.2 GivWin is void where prohibited or restricted by law.

10.4.3 It is the participant’s sole responsibility to determine whether their participation is lawful in their jurisdiction. The Company makes no representations that GivWin is appropriate or available in any particular jurisdiction outside those described above.

10.5 Transparency & Selection Integrity

10.5.1 The Company is committed to maintaining transparency in the GivWin process.

10.5.2 Selection of a winner:

•       is conducted using a defined and consistent selection mechanism

•       is based on participation identifiers generated within the Service

•       may be performed live and/or recorded for transparency

10.5.3 The Company implements measures to ensure that:

•       the selection process corresponds to valid participation

•       outcomes are determined in accordance with the defined process

10.6 Interpretation & Intent

10.6.1 GivWin is intended to operate as a promotional and community-based engagement feature.

10.6.2 Users agree that:

•       participation should not be interpreted as gambling or wagering

•       Coins and participation do not constitute stakes or bets

•       rewards are not winnings derived from gambling activity

10.6.3 The structure, terminology, and operation of GivWin are designed to reflect its intended purpose as an engagement initiative.

10.7 Compliance with Applicable Laws

10.7.1 The Company intends to operate GivWin in compliance with applicable laws and regulations.

10.7.2 If any part of GivWin is determined to be restricted or regulated in a particular jurisdiction:

•       participation may be limited or restricted

•       eligibility requirements may be adjusted

•       GivWin may be modified, suspended, or discontinued

10.7.3 Users are responsible for ensuring that their participation complies with applicable laws in their jurisdiction.

10.8 Company Rights & Adjustments

10.8.1 The Company reserves the right to:

•       modify the structure or operation of GivWin

•       adjust participation methods or conditions

•       introduce additional safeguards or requirements

•       suspend or cancel any GivWin where necessary

10.8.2 Such actions may be taken to maintain fairness and integrity, prevent misuse or abuse, or ensure legal and regulatory compliance.

10.9 No Misinterpretation

10.9.1 Users agree not to:

•       misrepresent GivWin as a gambling or betting activity

•       use the Service in a way that suggests financial wagering

•       attempt to exploit or reinterpret the system for unintended purposes

10.9.2 The Company may take action against any such misuse.

11.1 Applicable Law

11.1.1 These Terms and any dispute, claim, or controversy arising out of or relating to these Terms or the Service shall be governed by and construed in accordance with the laws of the State of Tennessee, without regard to its conflict of law principles.

11.1.2 The United Nations Convention on Contracts for the International Sale of Goods does not apply to these Terms.

11.2 Jurisdiction

11.2.1 To the extent that any dispute is not subject to arbitration as set forth in Section 12, you agree to submit to the exclusive personal jurisdiction of the state and federal courts located in the State of Tennessee for the resolution of any such dispute.

11.2.2 You waive any objection to venue or jurisdiction in such courts.

12.1 Informal Resolution

12.1.1 Before initiating any formal dispute, you agree to contact the Company through the support channels provided in the Service and attempt to resolve the dispute informally.

12.1.2 The parties agree to make a good faith effort to resolve any dispute within 30 days of the initial notice.

12.1.3 If the dispute is not resolved within that period, either party may proceed to arbitration as set forth below.

12.2 Binding Arbitration

12.2.1 Except as provided in Section 12.5 below, any dispute, claim, or controversy arising out of or relating to these Terms or the Service — including questions of arbitrability, the formation, validity, enforceability, interpretation, or breach of these Terms — shall be resolved exclusively through final and binding arbitration.

12.2.2 Arbitration shall be administered by the American Arbitration Association (“AAA”) under its Consumer Arbitration Rules, which are available at www.adr.org.

12.2.3 The arbitration shall be conducted by a single, neutral arbitrator. The seat of arbitration shall be in the State of Tennessee.

12.2.4 The arbitration may be conducted by telephone, video conference, or written submissions unless the arbitrator determines a live hearing is necessary.

12.3 Arbitration Fees

12.3.1 The allocation of arbitration fees shall be governed by the AAA Consumer Arbitration Rules.

12.3.2 If you are unable to afford the arbitration filing fee, the Company will consider in good faith a request for a fee waiver or reduction.

12.4 Arbitrator’s Authority

12.4.1 The arbitrator shall have the authority to grant any remedy that would be available in a court of competent jurisdiction, including injunctive or declaratory relief.

12.4.2 The arbitrator’s award shall be final and binding and may be entered as a judgment in any court of competent jurisdiction.

12.4.3 The arbitrator does not have authority to conduct class-wide proceedings and is limited to resolving the individual dispute between the parties.

12.5 Exceptions to Arbitration

12.5.1 Notwithstanding the foregoing, either party may bring an individual action in small claims court for disputes within that court’s jurisdiction.

12.5.2 Either party may seek emergency injunctive or equitable relief from a court of competent jurisdiction to prevent irreparable harm pending arbitration.

12.5.3 Nothing in this Section shall prevent either party from seeking such emergency relief.

12.6 Class Action Waiver

12.6.1 TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, YOU AND THE COMPANY AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, CONSOLIDATED, OR REPRESENTATIVE ACTION.

12.6.2 The arbitrator may not consolidate more than one person’s claims and may not otherwise preside over any form of a class or representative proceeding.

12.6.3 If this class action waiver is found to be unenforceable, then the entirety of the arbitration agreement in this Section 12 shall be null and void, and any disputes shall be resolved in court in accordance with Section 11.

12.7 Jury Trial Waiver

12.7.1 TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU AND THE COMPANY EACH WAIVE THE RIGHT TO A JURY TRIAL FOR ANY CLAIM OR DISPUTE ARISING UNDER OR RELATED TO THESE TERMS OR THE SERVICE.

12.8 Time Limitation on Claims

12.8.1 Any claim or cause of action arising out of or related to these Terms or the Service must be filed within one (1) year after such claim or cause of action arose.

12.8.2 If not filed within this period, the claim or cause of action is permanently barred.

13.1 Entire Agreement

13.1.1 These Terms, together with the Privacy Policy and any additional terms applicable to specific features of the Service, constitute the entire agreement between you and the Company regarding your use of the Service.

13.1.2 These Terms supersede all prior or contemporaneous communications, proposals, or agreements, whether oral or written, relating to the subject matter herein.

13.2 Severability

13.2.1 If any provision of these Terms is held to be invalid, illegal, or unenforceable by a court or arbitrator of competent jurisdiction, such provision shall be modified to the minimum extent necessary to make it enforceable.

13.2.2 If modification is not possible, the unenforceable provision shall be severed from these Terms. The remaining provisions shall continue in full force and effect.

13.3 Waiver

13.3.1 The failure of the Company to enforce any right or provision of these Terms shall not constitute a waiver of that right or provision.

13.3.2 No waiver shall be effective unless made in writing and signed by an authorized representative of the Company.

13.4 Assignment

13.4.1 You may not assign or transfer any of your rights or obligations under these Terms without the prior written consent of the Company.

13.4.2 The Company may assign these Terms or any rights hereunder without restriction, including in connection with a merger, acquisition, or sale of assets.

13.4.3 These Terms shall be binding upon and inure to the benefit of the parties and their respective permitted successors and assigns.

13.5 No Third-Party Beneficiaries

13.5.1 These Terms do not create any third-party beneficiary rights. Only the Company and you are parties to these Terms, and nothing herein is intended to confer any rights upon any third party.

13.6 Modifications to Terms

13.6.1 The Company reserves the right to modify these Terms at any time.

13.6.2 If changes are material, the Company will provide at least 30 days’ advance notice, such as through the Service or via email.

13.6.3 Your continued use of the Service after the effective date of any update constitutes your acceptance of the revised Terms.

13.6.4 If you do not agree to the updated Terms, you must stop using the Service.

13.7 Language

13.7.1 These Terms are written in English. To the extent any translated version of these Terms conflicts with the English version, the English version shall control.

13.8 Children’s Privacy (COPPA Compliance)

13.8.1 The Service is not directed to children under the age of 13. The Company does not knowingly collect, use, or disclose personal information from children under the age of 13, in compliance with the Children’s Online Privacy Protection Act (“COPPA”) and applicable law.

13.8.2 If we become aware that we have inadvertently collected personal information from a child under the age of 13 without verifiable parental consent, we will take immediate steps to delete such information from our records.

13.8.3 If you are a parent or legal guardian and believe your child under 13 has provided us with personal information without your consent, please contact us immediately through the support channels provided within the Service. We will investigate and, where confirmed, delete the information promptly.

13.8.4 Users between the ages of 13 and 15 are permitted to use the Service only with verifiable parental or guardian consent where required by applicable law.

13.9 App Store Terms

13.9.1 If you download or access the Service through a third-party platform (such as the Apple App Store or Google Play Store), your use of the Service is also subject to that platform’s terms of service, which are incorporated by reference. In the event of a conflict between these Terms and the platform’s terms, these Terms shall govern to the maximum extent permitted.

13.9.2 You acknowledge that:

•       the platform provider (e.g., Apple Inc. or Google LLC) is not a party to these Terms and bears no responsibility for the Service or its content

•       the platform provider has no obligation to provide maintenance or support services for the Service

•       in the event the Service fails to conform to any applicable warranty, you may notify the platform provider, and to the maximum extent permitted by law, the platform provider will have no other warranty obligation with respect to the Service

•       the platform provider is not responsible for addressing any claims by you or any third party relating to the Service

13.10 Accessibility

13.10.1 The Company is committed to making the Service accessible to as many users as possible, including users with disabilities. We strive to follow reasonable accessibility standards in the design and development of the Service.

13.10.2 If you experience difficulty accessing or using any part of the Service due to a disability or accessibility limitation, please contact us through the support channels provided within the Service. We will make reasonable efforts to accommodate your needs and improve your experience.

13.10.3 The Company’s accessibility efforts are ongoing. We do not guarantee that the Service meets all accessibility standards at all times, but we are committed to continuous improvement in this area.

13.11 California Residents — Additional Rights (CCPA)

13.11.1 If you are a resident of California, you may have additional rights under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”), as amended. These rights may include:

•       the right to know what personal information the Company collects, uses, discloses, or sells about you

•       the right to request deletion of personal information the Company has collected from you, subject to certain exceptions

•       the right to opt out of the sale or sharing of your personal information, where applicable

•       the right to correct inaccurate personal information the Company holds about you

•       the right to limit the use and disclosure of sensitive personal information

•       the right not to receive discriminatory treatment for exercising any of your privacy rights

13.11.2 To exercise any of your California privacy rights, please contact us through the support channels provided within the Service or at www.clkncollect.com. We will respond to verifiable consumer requests within the timeframes required by applicable law.

13.11.3 The Company does not sell personal information for monetary consideration. However, certain sharing of information with advertising and analytics partners may constitute “sale” or “sharing” under California law. For more information, please refer to our Privacy Policy.

13.11.4 California residents may also have rights under the California “Shine the Light” law (Civil Code Section 1798.83) regarding the disclosure of personal information to third parties for direct marketing purposes. To make such a request, please contact us through the channels described above.

13.12 FTC Affiliate & Advertising Disclosures

13.12.1 In compliance with the Federal Trade Commission (“FTC”) guidelines on endorsements and testimonials (16 C.F.R. Part 255), the Company discloses the following:

13.12.2 The Service may contain affiliate links, including but not limited to links associated with Amazon and other third-party merchants. If you click on an affiliate link and make a purchase, the Company may receive a commission or other compensation from the merchant at no additional cost to you.

13.12.3 The presence of affiliate links within the Service:

•       does not influence the Company’s editorial decisions or content

•       does not constitute an endorsement of the linked product, service, or merchant

•       is disclosed transparently in accordance with FTC requirements

13.12.4 The Service also features Rewarded Advertising content provided by third-party advertising partners. Users should be aware that:

•       advertising content is clearly distinct from organic content where reasonably practicable

•       the Company may receive compensation from advertisers in connection with Rewarded Ads

•       the inclusion of advertising content does not imply endorsement of any advertiser’s products or services

13.12.5 If you have questions about specific affiliate relationships or advertising arrangements within the Service, you may contact us through the support channels provided within the Service.

14.1 How to Contact Us

14.1.1 If you have any questions, concerns, or requests regarding the Service or these Terms, you may contact us through the available support channels.

14.1.2 Users may reach out to the Company through:

•       the in-app contact or support form (available to registered users and guests)

•       the contact form available on our website: www.clkncollect.com

14.2 Legal Notices

14.2.1 For legal notices required or permitted under these Terms, you agree that notice sent to the email address associated with your account, or posted within the Service, constitutes sufficient notice.

14.2.2 Legal notices to the Company should be submitted through the support channels described above, clearly marked as a legal notice.

14.3 Support Requests

14.3.1 Support requests may include, but are not limited to:

•       account-related inquiries

•       reward or participation issues

•       GivWin-related questions

•       technical support

•       reporting violations or concerns

14.3.2 The Company will review and respond to inquiries within a reasonable timeframe.

14.4 Communication Methods

14.4.1 Responses to user inquiries may be provided through:

•       email communication associated with the submitted request

•       in-app communication, where applicable

14.4.2 Users are responsible for providing accurate contact information to receive responses.

14.5 No Public Contact Information

14.5.1 To maintain service quality and reduce misuse, the Company may limit publicly available contact methods and rely primarily on structured contact forms for communication.

14.6 Updates to Contact Information

14.6.1 The Company reserves the right to update or modify contact methods at any time.

14.6.2 Any changes will be reflected within the Service or on the website.

— End of Terms of Service —

2.1 Account Information

2.1.1 When you create or use an account, we may collect:

•       email address

•       user ID

•       phone number (optional at registration, required for certain features)

•       one-time passcodes (OTPs) sent to a registered phone number for account verification and authentication

•       login credentials via third-party providers (e.g., Apple Sign-In, Google Sign-In)

2.1.2 Phone number verification may be required to access certain features, including GivWin participation. Where phone verification is used, we deliver a one-time passcode (OTP) via SMS to the registered number. We do not store OTP codes after they have been verified or expired. Phone numbers are used as described in Section 3 of this Privacy Policy.

2.2 Participation & Rewards Data

2.2.1 We collect and process data related to your activity within the Service, including:

•       Coins and Status Points balances

•       participation in GivWin and other features

•       streak activity and engagement

•       referral activity

•       redemption history, including gift card requests

2.3 Advertising & Device Data

2.3.1 We may collect information related to your device and interaction with advertisements, including:

•       device identifiers (e.g., advertising ID such as IDFA on iOS and GAID on Android)

•       device type, operating system, and app version

•       ad interaction data (e.g., views, completions, clicks)

2.3.2 We currently use non-personalized advertisements. This means we do not use your advertising ID to serve interest-based or behavioral ads at this time. If this changes, we will provide appropriate notice and obtain consent where required by applicable law.

2.3.3 On iOS devices, we may request your permission to track through Apple’s App Tracking Transparency (ATT) framework before accessing your advertising identifier. You may decline this request, which limits certain advertising-related functionality but does not affect your core use of the Service.

2.4 Approximate Location Data

2.4.1 We may collect approximate location information (such as IP-based location) to:

•       support fraud prevention

•       comply with geographic restrictions (e.g., U.S.-only features such as GivWin)

•       improve service functionality

2.4.2 We do not collect precise GPS or real-time location data.

2.5 User-Generated Content

2.5.1 We may collect content you submit through the Service, including:

•       Hot Deals submissions

•       Suggested Gifts submissions

•       messages, comments, and uploads

2.5.2 By submitting User Content, you grant the Company a license to use such content as described in the Terms of Service.

2.6 Contact & Communication Data

2.6.1 When you contact us, we may collect:

•       name

•       email address

•       message content and attachments

2.6.2 This applies to communications submitted via:

•       in-app contact forms

•       website contact forms

•       email or other direct communications

2.7 GivWin Verification Data

2.7.1 If you are selected as a potential winner in GivWin, we may collect additional information, including:

•       full legal name

•       email address

•       phone number (used to confirm U.S. eligibility and contact the winner)

•       mailing address

•       identity verification information (e.g., government-issued ID confirmation)

Phone number data collected at this stage is used solely for winner verification, fraud prevention, prize fulfillment, and legal compliance purposes, consistent with Section 2.1.

2.7.2 This data is used solely for eligibility verification, fraud prevention, prize fulfillment, and legal compliance purposes. For Volunteer GivWin winners under the age of 18, verification information will be collected from the parent or legal guardian, who will be required to confirm consent and receive the prize on behalf of the minor.

2.7.3 GivWin verification data is retained only as long as necessary for these purposes and will generally be deleted within 90 days of winner confirmation or disqualification, unless retention is required by applicable law.

2.8 AMOE (Postcard) Data

2.8.1 For Community GivWin, users may participate via the Alternative Method of Entry (AMOE) by submitting a postcard. Information submitted via postcard includes name, email address, user ID, and U.S. phone number, as described in the Terms of Service. AMOE is only available for Community GivWin; Campaign GivWin and Volunteer GivWin do not use this method.

2.8.2 This data is:

•       processed to validate eligibility and issue a free participation credit to the user’s ClkN’Collect account (Step 1). The user must then log into the app and activate that credit before the GivWin closes (Step 2). Unactivated credits are forfeited

•       used only for the specific GivWin for which it was submitted

•       generally discarded after processing is complete, unless retention is required by law

2.9 Technical & Usage Data

2.9.1 We may collect technical data related to your use of the Service, including:

•       app interactions and navigation patterns

•       session data and usage duration

•       performance and error logs

•       crash reports and diagnostic data

2.9.2 This data is used for internal analytics, quality assurance, and service improvement. It is not used to identify you personally.

2.10 Push Notification Data

2.10.1 If you enable push notifications, we may collect your device push token to deliver service-related and transactional notifications.

2.10.2 Push notifications are used for service-related and transactional purposes and may include limited promotional messages where you have provided consent or where permitted by applicable law.

2.10.3 You may opt out of push notifications at any time through your device settings or within the Service. Opting out does not affect your access to the core features of the Service.

2.10.4 We do not use push notification tokens for advertising targeting purposes.

2.11 Information We Do Not Collect

2.11.1 We do not knowingly collect:

•       precise GPS or real-time location data

•       financial information such as credit card or bank account numbers

•       biometric data

•       sensitive personal information beyond what is listed in Section 2.7 for GivWin verification

3.1 Core Service Operations

3.1.1 We use collected information to provide, operate, and maintain the Service, including:

•       creating and managing user accounts and authentication

•       calculating and distributing Coins, Status Points, and rewards

•       enabling participation in GivWin, Hot Deals, the Referral Program, and other features

•       processing gift card redemptions

•       processing AMOE postcard submissions for Community GivWin, issuing free participation credits, and supporting in-app activation of those credits

3.2 Safety, Security & Fraud Prevention

3.2.1 We use information to:

•       verify user eligibility and identity

•       detect, investigate, and prevent fraud, abuse, and violations of our Terms

•       enforce geographic restrictions on features such as GivWin

•       maintain the security and integrity of the Service

3.3 Communications

3.3.1 We use contact information to:

•       send transactional communications (e.g., account activity, reward confirmations, support responses)

•       send service-related notifications (e.g., policy updates, feature announcements)

•       send marketing communications, where you have provided consent or where permitted by applicable law

3.3.2 You may opt out of marketing communications at any time. You will continue to receive essential transactional and service-related messages.

3.3.3 SMS Communications:

Where you have provided a phone number, we may use it to send:

•       one-time passcodes (OTPs) for authentication and account verification

•       security alerts

•       service-related SMS notifications where you have opted in. We do not use phone numbers for marketing SMS without your explicit consent. You may opt out of non-essential SMS communications at any time. Standard messaging and data rates from your carrier may apply. To opt out of SMS messages at any time, reply STOP. For assistance, reply HELP.

3.4 Advertising

3.4.1 We use advertising and device data to:

•       display advertisements within the Service

•       measure ad performance and validate reward delivery

•       operate the Rewarded Ads feature

3.4.2 We currently use non-personalized advertising. Advertising data shared with partners such as AdMob, Unity, and Meta is used solely for the purposes described in Section 4.2.

3.5 Analytics & Improvement

3.5.1 We use technical and usage data to:

•       analyze how users interact with the Service

•       identify and resolve technical issues

•       improve features, performance, and user experience

•       conduct internal research and development

3.6 Legal & Compliance

3.6.1 We use information to:

•       comply with applicable laws, regulations, and legal obligations

•       respond to lawful requests from courts, regulators, or government authorities

•       enforce our Terms of Service and other agreements

•       protect the rights, property, and safety of the Company, users, and the public

3.7 Business Transfers

3.7.1 In the event of a merger, acquisition, reorganization, or sale of all or substantially all of the Company’s assets, your information may be transferred to the acquiring entity as part of that transaction.

3.7.2 We will notify you via email or a prominent notice within the Service before your information becomes subject to a materially different privacy policy as a result of any such transaction.

4.0.1 We do not sell your personal information for monetary consideration. However, as described below, certain sharing of data with advertising partners may constitute “selling” or “sharing” under California law (see Section 9 for California-specific rights).

4.0.2 We may share your information only in the circumstances described in this Section.

4.0.3 We do not sell or share your personal information with third parties or affiliates for their own marketing purposes.

4.1 Service Providers

4.1.1 We may share information with trusted third-party service providers who assist us in operating the Service, including:

•       cloud hosting and infrastructure providers

•       analytics and performance monitoring providers

•       customer support and communication platforms

•       identity verification and fraud detection providers

4.1.2 These providers are authorized to use your information only as necessary to perform services on our behalf and are contractually required to maintain appropriate security and confidentiality.

4.2 Advertising Partners

4.2.1 We may share limited data with advertising partners to display advertisements and measure ad performance. Our current advertising partners include:

•       Google AdMob — Privacy Policy: https://policies.google.com/privacy

•       Unity Ads — Privacy Policy: https://unity.com/legal/privacy-policy

•       Meta Audience Network — Privacy Policy: https://www.facebook.com/privacy/policy

4.2.2 Data shared with advertising partners may include device identifiers and ad interaction data. We currently use non-personalized advertising. If we transition to personalized advertising, we will provide appropriate notice and obtain consent where required.

4.2.3 We do not combine advertising data with personally identifiable information such as your name or email address for advertising purposes.

4.2.4 Each advertising partner operates under its own privacy policy. We encourage you to review their policies to understand how they handle data. You may opt out of interest-based advertising through your device settings (iOS: Settings > Privacy > Tracking; Android: Settings > Google > Ads).

4.3 Reward & Gift Card Providers

4.3.1 We may share necessary information with authorized third-party providers to:

•       issue and deliver digital rewards

•       process and fulfill gift card redemptions

4.3.2 Information shared is limited to what is necessary to fulfill the specific reward transaction and is subject to the provider’s own privacy policy.

4.3.3 Once a gift card or reward code is delivered within the Service, users are solely responsible for securely storing any associated codes or redemption information. The Company does not store gift card codes after delivery and is not responsible for lost, deleted, or inaccessible reward information following delivery to the user’s account.

4.4 Affiliate Partners

4.4.1 The Service may include affiliate links (e.g., Amazon Associates). When you interact with an affiliate link, the affiliate partner may receive information such as a referral identifier necessary to track the referral and process any applicable commission.

4.4.2 We do not receive personal information such as your name, email address, or contact details from affiliate partners in connection with your interactions with affiliate links. Data flow to affiliate partners is limited to referral tracking identifiers only.

4.4.3 Affiliate partners operate under their own privacy policies. For Amazon, please refer to: https://www.amazon.com/gp/help/customer/display.html?nodeId=GX7NJQ4ZB8MHFRNJ

4.4.4 The Company may receive compensation from affiliate partners in connection with purchases made through affiliate links. This does not affect the price you pay.

4.5 GivWin & Prize Fulfillment

4.5.1 If you are selected as a GivWin winner, we may share your verification information with:

•       prize fulfillment partners or shipping providers, as necessary to deliver your reward

•       sponsors, where applicable and with your acknowledgment, solely for fulfillment purposes

4.5.2 Such sharing is limited to the minimum information necessary to complete prize delivery and comply with applicable legal requirements.

4.6 Legal Requirements & Protection

4.6.1 We may disclose your information where required by law or where we believe in good faith that disclosure is necessary to:

•       comply with a legal obligation, court order, or lawful government request

•       enforce our Terms of Service or other agreements

•       protect and defend the rights, property, or safety of the Company, our users, or the public

•       detect, prevent, or address fraud, security issues, or technical problems

4.7 Business Transfers

4.7.1 As described in Section 3.7, your information may be transferred in connection with a merger, acquisition, or sale of assets. We will notify you before any such transfer results in your information being subject to a materially different privacy policy.

4.8 With Your Consent

4.8.1 We may share your information for purposes not described in this Section with your explicit prior consent. You may withdraw such consent at any time.

5.1 General Retention Principles

5.1.1 We retain personal information for as long as necessary to fulfill the purposes for which it was collected, as described in this Privacy Policy, or as required by applicable law.

5.1.2 When determining retention periods, we consider:

•       the nature and sensitivity of the data

•       the purposes for which we process it

•       applicable legal or regulatory obligations

•       legitimate business interests such as fraud prevention and dispute resolution

5.2 Retention Periods by Data Type

5.2.1 Phone number data: retained for the duration of your account and for up to 3 years after account deletion, consistent with account data retention, for fraud prevention, legal claims, and dispute resolution. OTP codes are ephemeral and are not stored after verification or expiration.

5.2.2 The following approximate retention periods apply to key categories of data:

•       Account data: retained for the duration of your account, plus up to 3 years after account deletion, to support fraud prevention, legal claims, and dispute resolution.

•       Rewards and transaction data (Coins, redemptions, GivWin participation): retained for up to 5 years after the transaction date, for tax, legal, and audit purposes.

•       GivWin verification data: retained for up to 90 days following winner confirmation or disqualification, unless longer retention is required by law.

•       AMOE postcard data (Community GivWin only): retained only for as long as necessary to validate the postcard and issue a free participation credit (Step 1), then deleted. Unactivated credits that expire when a GivWin closes do not extend the retention period. Parental or guardian consent records for Volunteer GivWin participants under 18 are retained for the duration of the volunteer relationship and a reasonable period thereafter, consistent with applicable law.

•       Advertising and device data: retained in accordance with the applicable advertising partner’s data retention policy and applicable law.

•       Technical and usage data: retained for up to 2 years for analytics and service improvement purposes.

•       Support and communication data: retained for up to 3 years following the closure of the relevant support request.

•       Push notification tokens: retained while you have push notifications enabled. Deleted promptly when you opt out or delete your account.

5.3 Account Deletion

5.3.1 Upon account deletion:

•       we will delete or anonymize personal information that is no longer required

•       certain data may be retained where required by applicable law, for fraud prevention, or to resolve active disputes

•       anonymized or aggregated data that cannot reasonably identify you may be retained indefinitely for analytics purposes

5.3.2 Deletion requests will be processed within 30 days, unless an extension is required and permitted by applicable law.

6.1 Security Measures

6.1.1 We implement reasonable and appropriate technical and organizational measures to protect your personal information against unauthorized access, loss, destruction, alteration, or disclosure.

6.1.2 These measures include, but are not limited to:

•       encryption of data in transit using industry-standard TLS/HTTPS protocols

•       access controls limiting data access to authorized personnel on a need-to-know basis

•       regular security assessments and monitoring of our systems

•       secure data storage with appropriate access restrictions

6.1.3 The accuracy and completeness of data processing may depend on system functionality, third-party service availability, and factors outside the Company’s control. We do not warrant that all data processing will be error-free or uninterrupted.

6.2 Limitations

6.2.1 No method of data transmission over the internet or method of electronic storage is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security.

6.2.2 You are responsible for:

•       maintaining the security of your account credentials

•       ensuring that devices used to access the Service are adequately secured

•       notifying us promptly if you suspect unauthorized access to your account

6.3 Data Breach Notification

6.3.1 In the event of a data breach that is reasonably likely to result in harm to you, we will notify affected users in accordance with applicable law, including:

•       Tennessee law (Tenn. Code Ann. § 47-18-2107), which requires notification within 45 days of discovery of a breach

•       other applicable state or federal breach notification requirements

6.3.2 Notification will be provided via:

•       email to the address associated with your account

•       prominent notice within the Service

•       other methods as required by applicable law

6.3.3 We will also notify applicable regulatory authorities where required by law.

7.1 Website Cookies

7.1.1 Our website (www.clkncollect.com) may use cookies and similar technologies to:

•       enable core website functionality

•       improve user experience and remember preferences

•       support analytics and performance monitoring

•       serve and measure advertisements

7.1.2 You may control cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the website.

7.1.3 We may use the following categories of cookies:

•       Strictly Necessary: required for the website to function. Cannot be disabled.

•       Analytics: help us understand how visitors use the website (e.g., Google Analytics).

•       Advertising: used to deliver and measure advertisements.

7.2 In-App Tracking & SDKs

7.2.1 The mobile application uses third-party software development kits (SDKs) that may collect data from your device. These include advertising SDKs (AdMob, Unity Ads, Meta Audience Network) and analytics SDKs.

7.2.2 These SDKs may collect:

•       advertising identifiers (IDFA on iOS, GAID on Android)

•       device and hardware information

•       app usage and interaction data

•       crash and diagnostic information

7.2.3 Each SDK operates under its own data practices and privacy policy, as listed in Section 4.2. We encourage you to review those policies.

7.3 iOS App Tracking Transparency (ATT)

7.3.1 In accordance with Apple’s App Tracking Transparency framework, if you use an iOS device, we will request your permission before accessing your IDFA or tracking your activity across apps and websites.

7.3.2 If you decline the ATT prompt:

•       we will not access your advertising identifier for tracking purposes

•       certain advertising-related features may be limited

•       your core use of the Service will not be affected

7.3.3 You may change your ATT preference at any time via: iOS Settings > Privacy & Security > Tracking.

7.4 Android Advertising Settings

7.4.1 On Android devices, you may opt out of personalized advertising via: Settings > Google > Ads > Opt out of Ads Personalization. You may also reset your advertising ID at any time in the same menu.

8.1 General Rights

8.1.1 Depending on your location and applicable law, you may have the following rights regarding your personal information:

•       Right to Access: the right to request confirmation of whether we process your personal information and, if so, to receive a copy of that information.

•       Right to Correction: the right to request correction of inaccurate or incomplete personal information.

•       Right to Deletion: the right to request deletion of your personal information, subject to certain legal exceptions.

•       Right to Data Portability: the right to receive a copy of your personal information in a structured, commonly used, machine-readable format, where technically feasible.

•       Right to Object: the right to object to processing of your personal information where we rely on legitimate interests as our legal basis.

•       Right to Withdraw Consent: where processing is based on your consent, the right to withdraw that consent at any time, without affecting the lawfulness of prior processing.

•       Right to Opt Out of Marketing: the right to opt out of marketing communications at any time.

•       Right to Opt Out of Targeted Advertising: the right to opt out of the sale or sharing of your personal information for advertising purposes, as described in Section 9.

8.2 How to Exercise Your Rights

8.2.1 To exercise any of the above rights, you may:

•       access and update account information directly within the Service

•       delete your account through the app settings

•       contact us through the in-app support form or via www.clkncollect.com

8.2.2 We will respond to verifiable requests within 45 days of receipt, as required by applicable law. If additional time is needed, we will notify you within the initial 45-day period and may extend our response by an additional 45 days where permitted by law.

8.2.3 We may need to verify your identity before processing your request to protect your information from unauthorized disclosure or deletion.

8.3 Data Portability

8.3.1 We currently do not provide an automated data export tool within the Service. If you submit a data portability request, we will provide your personal information in a commonly used format (such as CSV or JSON) within the response timeframe described in Section 8.2.2, to the extent technically feasible.

8.3.2 We are committed to building self-service data access tools in future updates to the Service.

8.4 Opt-Out of Communications

8.4.1 You may opt out of marketing communications at any time by:

•       updating your communication preferences within the Service

•       following the unsubscribe instructions in any marketing email

•       contacting us through the contact methods described in Section 13

8.4.2 You will continue to receive transactional and service-related messages even if you opt out of marketing communications.

8.5 Non-Discrimination

8.5.1 We will not discriminate against you for exercising any of your privacy rights. You will not be denied access to the Service, offered a different quality of service, or penalized in any way solely because you exercised a right described in this Section.

This Section applies only to residents of California and supplements the rights described elsewhere in this Privacy Policy.

9.1 Rights Under the CCPA / CPRA

9.1.1 If you are a California resident, you have the following additional rights under the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”):

•       Right to Know: the right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources, the business purpose for collection, and the categories of third parties with whom we share it.

•       Right to Delete: the right to request deletion of personal information we have collected from you, subject to certain exceptions.

•       Right to Correct: the right to request correction of inaccurate personal information.

•       Right to Opt Out of Sale or Sharing: the right to opt out of the “sale” or “sharing” of your personal information. See Section 9.3 below.

•       Right to Limit Use of Sensitive Personal Information: the right to limit the use and disclosure of sensitive personal information to what is necessary to perform the services you requested.

•       Right to Non-Discrimination: the right not to receive discriminatory treatment for exercising any of your CCPA/CPRA rights.

9.2 Categories of Personal Information Collected

9.2.1 Under Identifiers (OTP clarification): email address, user ID, device identifiers, IP address, phone number (including phone numbers used for OTP-based verification). No OTP codes themselves are retained after verification or expiration.

9.2.2 In the preceding 12 months, we have collected the following categories of personal information as defined under the CCPA:

•       Identifiers: email address, user ID, device identifiers, IP address, phone number.

•       Commercial information: rewards history, Coins balance, gift card redemptions, referral activity.

•       Internet or other electronic network activity: app usage data, ad interaction data, session data.

•       Geolocation data (approximate): IP-based approximate location.

•       Inferences: engagement patterns and activity levels derived from usage data.

•       Sensitive personal information (limited): identity verification data collected from GivWin winners only, as described in Section 2.7.

9.3 Sale or Sharing of Personal Information

9.3.1 We do not sell your personal information for monetary consideration.

9.3.2 However, sharing certain data (such as device identifiers and ad interaction data) with advertising partners such as AdMob, Unity, and Meta for advertising and analytics purposes may constitute “sharing” under the CPRA.

9.3.3 To opt out of the sharing of your personal information for cross-context behavioral advertising, you may:

•       use the opt-out controls described in Sections 7.3 and 7.4 for device-level advertising opt-outs

•       contact us through the contact methods described in Section 13 to submit a “Do Not Sell or Share My Personal Information” request

9.3.4 We do not knowingly sell or share the personal information of users under the age of 16.

9.4 “Shine the Light” Disclosure

9.4.1 Under California Civil Code Section 1798.83, California residents may request information about our disclosure of personal information to third parties for their direct marketing purposes.

9.4.2 To make such a request, please contact us through the contact methods described in Section 13.

9.5 How to Exercise California Rights

9.5.1 California residents may submit rights requests by:

•       contacting us through the in-app support form

•       contacting us through the website contact form at www.clkncollect.com

9.5.2 We will acknowledge receipt of your request within 10 business days and provide a substantive response within 45 days, extendable by an additional 45 days where necessary.

9.5.3 We may need to verify your identity before processing your request. We will not require you to create an account to submit a request if you do not already have one.

10.1 Age Restriction

10.1.1 The Service is not directed to children under the age of 13. We do not knowingly collect, use, or disclose personal information from children under the age of 13, in compliance with the Children’s Online Privacy Protection Act (“COPPA”) and applicable law.

10.1.2 Users between the ages of 13 and 15 may use the Service only with verifiable parental or guardian consent where required by applicable law.

10.1.3 Community GivWin and Campaign GivWin are restricted to users aged 18 and older. Volunteer GivWin is available to users aged 16 and older who have been recognized as qualifying volunteers, provided that users aged 16 or 17 have verifiable parental or guardian consent on file with the Company.

10.2 Discovery of Under-Age Data

10.2.1 If we become aware that we have inadvertently collected personal information from a child under the age of 13 without verifiable parental consent, we will take immediate steps to:

•       delete such information from our records

•       terminate the associated account

•       take such other steps as required by applicable law

10.3 Parental Rights

10.3.1 If you are a parent or legal guardian and believe your child under 13 has provided us with personal information without your consent, please contact us immediately through the contact methods described in Section 13.

10.3.2 We will investigate and, where confirmed, promptly delete the information.

11.1 Types of Communications

11.1.1 We may send the following types of communications:

•       Transactional communications: account activity, reward confirmations, GivWin notifications, support responses.

•       Service-related notifications: policy updates, feature announcements, security alerts.

•       Marketing communications: promotional content, campaign announcements, new features, where you have provided consent or where permitted by applicable law.

•       Push notifications: if enabled, device-level notifications for the above purposes.

11.2 Managing Communication Preferences

11.2.1 You may manage your communication preferences at any time by:

•       updating notification settings within the Service

•       following the unsubscribe instructions in any email

•       disabling push notifications through your device settings

11.2.2 Opting out of marketing communications will not affect your receipt of transactional or service-related messages, which are necessary for the operation of the Service.

12.1 Updates

12.1.1 We may update this Privacy Policy from time to time to reflect changes in our practices, the Service, or applicable law.

12.1.2 For material changes, we will provide at least 30 days’ advance notice before the changes take effect, via:

•       email notification to the address associated with your account

•       a prominent notice within the Service

•       an updated “Last Updated” date at the top of this Privacy Policy

12.1.3 For non-material changes, we may update this Privacy Policy with notice only via the updated “Last Updated” date.

12.2 Acceptance

12.2.1 Your continued use of the Service after the effective date of any updated Privacy Policy constitutes your acceptance of the changes.

12.2.2 If you do not agree to a material update, you should stop using the Service and may request deletion of your account as described in Section 8.

13.1 How to Reach Us

13.1.1 If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, you may contact us through:

•       the in-app contact or support form (available to registered users and guests)

•       the contact form on our website: www.clkncollect.com

13.1.2 We will acknowledge receipt of privacy-related requests within 10 business days and respond substantively within the timeframes required by applicable law (generally 30–45 days).

13.2 Privacy-Specific Requests

13.2.1 For requests specifically related to your privacy rights (access, deletion, correction, portability, opt-out), please use the contact channels above and clearly identify your request as a “Privacy Rights Request.”

13.2.2 We may need to verify your identity before processing privacy rights requests.

13.3 Updates to Contact Information

13.3.1 The Company reserves the right to update or modify contact methods at any time. Any changes will be reflected within the Service or on the website.

— End of Privacy Policy —

GivWin may be offered in three (3) distinct formats, each with its own purpose, participation structure, and entry method rules. All types are governed by these Rules unless a specific type provision states otherwise.

2.1 Community GivWin (Coin-Contribution Format)

2.1.1 Overview

The Community GivWin is the primary GivWin format. Its purpose is to rally users around a specific real-world community cause — such as supporting a local charitable activity, community event, or social initiative. Each Community GivWin highlights the cause or event it supports, giving users the opportunity to be part of something meaningful. Users participate by contributing Coins, which may be directed by the Company toward supporting that community activity. As a gesture of appreciation for their contribution, participating users receive the opportunity to be selected for a reward. The cause and its community impact are the focus; the reward is the appreciation, not the purpose.

2.1.2 How It Works

1.    Users review an active Community GivWin within the Service. Each GivWin displays the community cause or event it supports, along with details including the participation period, minimum and maximum number of participations, participation cost in Coins, and the associated appreciation reward.

2.    The user contributes Coins from their in-app balance. Coins are deducted at the time of contribution.

3.    Each valid contribution generates a unique participation identifier (a multi-digit number), which is recorded in the system and viewable by the user within the Service.

4.    Multiple participations are permitted, subject to per-GivWin limits defined within the Service.

5.    Coins contributed may be applied by the Company toward supporting the community-related activity associated with that GivWin.

2.1.3 Participation via AMOE

Because Coins constitute consideration, an AMOE is legally required for Community GivWin. Users who prefer not to use Coins may participate free of charge through the Alternative Method of Entry (AMOE). See Section 4.4 of these Rules for full AMOE instructions. AMOE participation provides an equal opportunity of selection and is subject to the same eligibility requirements.

2.1.4 Membership Level Requirement

Some Community GivWin events may be restricted to users who have reached a specific membership level within the Service (for example, Silver or above). Where a membership level requirement applies, it will be clearly displayed on the GivWin within the app prior to and during the participation period. Users who have not reached the required level will not be able to participate using Coins.

Membership levels are cumulative: each level includes all benefits and access rights of the levels below it. A user at a higher level automatically meets the requirement for any GivWin set to a lower level.

AMOE participants are exempt from membership level requirements. This exemption ensures the free entry path remains accessible to all eligible users regardless of membership status.

2.1.5 Coin Refund on Cancellation

If a Community GivWin is cancelled due to insufficient participation or any other reason, all Coins contributed by participating users will be refunded to their respective in-app balances. AMOE submissions will not be refunded (as no payment was made) and will not carry forward to future GivWin activities.

2.2 Campaign GivWin (Promotional Giveaway Format)

2.2.1 Overview

The Campaign GivWin is a promotional giveaway offered in connection with specific campaigns, onboarding events, partnerships, or other promotional activities (including, for example, QR code scan campaigns). Participation is granted automatically upon completion of a defined free promotional action — no Coins and no payment of any kind are required.

2.2.2 No Alternative Entry

The Campaign GivWin is a free promotional giveaway — no Coins, no purchase, and no payment of any kind are required to participate. Because entry is already free, no Alternative Method of Entry (AMOE) is available or required for this format. The winner draw takes place within a short time of the campaign launch, sometimes on the same day.

2.2.3 How It Works

1.    The Company launches a Campaign GivWin in connection with a specific promotional event or activity (e.g., scanning a QR code, attending an event, completing an onboarding flow).

2.    Users who complete the required free promotional action are automatically entered and receive one (1) participation identifier per qualifying action, unless otherwise stated.

3.    No Coin contribution and no payment of any kind is required to receive participation through this format.

4.    The winner draw may occur on the same day or within a short time after the campaign launch, as specified within the Service for that GivWin.

5.    Campaign GivWins may have specific start and end dates, geographic restrictions, or eligibility conditions beyond the standard requirements set out in Section 3.

2.2.4 Sponsor Involvement

Campaign GivWins may be supported by a sponsor who provides the reward, resources, or associated event. Where a sponsor is involved:

•       The Company will identify the sponsor within the Service for that GivWin.

•       The Company is not responsible for the sponsor’s actions, products, services, or representations.

•       Sponsor involvement does not alter the equal-chance selection process described in Section 5.

2.3 Volunteer GivWin (Volunteer Appreciation Format)

2.3.1 Overview

The Volunteer GivWin is a separate GivWin format conducted exclusively as a volunteer appreciation initiative. It is offered to individuals who have been recognized by the Company as qualifying volunteers in connection with Company-recognized activities, events, or programs. The Volunteer GivWin is independent from all other GivWin formats and does not share a participation pool with Community or Campaign GivWins.

2.3.2 No Alternative Entry

The Volunteer GivWin is a closed appreciation initiative open exclusively to individuals recognized by the Company as qualifying volunteers. No Alternative Method of Entry (AMOE) is available for this format. Participation is assigned directly by the Company to eligible volunteers — no entry submission of any kind is required or accepted from non-volunteers.

2.3.3 Eligibility

In addition to the standard eligibility requirements in Section 3, participation in a Volunteer GivWin requires:

•       The participant must have been recognized by the Company as a qualifying volunteer for the relevant activity or event.

•       Participation is by Company recognition only — volunteers do not submit any entry. The Company generates and assigns participation identifiers directly to eligible volunteers.

•       The Company determines, in its sole discretion, which volunteers qualify for a given Volunteer GivWin.

•       No person who is not a recognized qualifying volunteer may participate in a Volunteer GivWin, regardless of how they attempt to enter.

2.3.4 Age Requirements & Minor Volunteers

Volunteer GivWin is open to recognized qualifying volunteers aged 16 and older. This lower minimum age reflects the nature of volunteer programs, which frequently include students and young participants, and differs from the 18+ requirement applicable to Community and Campaign GivWins.

Volunteers under the age of 18 must have verifiable parental or guardian consent on file with the Company before participating in any Volunteer GivWin. Consent is collected by the Company as part of the volunteer onboarding or registration process and must be provided in written form, either digitally or as a signed hard copy. A volunteer under 18 without consent on file will not be assigned a participation identifier and will not be eligible to receive a prize.

If a selected winner is under the age of 18, the prize will be fulfilled to their parent or legal guardian on their behalf. The parent or guardian will be required to complete the winner verification process in place of the minor.

Volunteers under the age of 16 are not eligible to participate in any GivWin, consistent with the minimum age of use for the Service.

2.3.5 No Coin Contribution Required

Volunteer GivWins are free to enter. No Coins and no payment of any kind are required. Participation identifiers are generated and assigned to qualifying volunteers by the Company.

2.3.6 Independent Participation Pool

The Volunteer GivWin maintains a fully independent participant pool. Selection outcomes from a Volunteer GivWin do not affect, and are not affected by, any concurrent Community or Campaign GivWin.

The following eligibility requirements apply to all GivWin types. Additional type-specific requirements are set out in Section 2 above.

3.1 General Eligibility

To participate in any GivWin, you must:

•       Be a registered user of the ClkN’Collect Service.

•       Be at least 18 years of age at the time of participation (Community GivWin and Campaign GivWin). For Volunteer GivWin, be at least 16 years of age; participants aged 16 or 17 must have verifiable parental or guardian consent on file with the Company (see Section 2.3.4).

•       Be a legal resident of the United States at the time of participation.

•       Have a valid U.S. phone number registered with or verifiable through your account. Phone number verification may be required to access GivWin participation features and, if selected, to confirm eligibility as a winner.

•       Be in good standing with no active suspension, restriction, or violation pending under the Terms of Service.

3.2 Age Verification

By participating in a Community GivWin or Campaign GivWin, you represent and warrant that you are at least 18 years of age. For Volunteer GivWin, you represent that you are at least 16 years of age and, if under 18, that verifiable parental or guardian consent is on file with the Company. The Company reserves the right to require age verification at any time, including upon selection. Participants who cannot verify their age or provide required consent will be disqualified.

3.3 Residency Verification

If selected as a potential winner, you will be required to confirm your U.S. residency. Acceptable forms of confirmation may include a government-issued ID or other documentation acceptable to the Company. Failure to confirm residency will result in disqualification.

3.4 Phone Number Requirement

A valid U.S. phone number is required for GivWin participation. This requirement exists to:

•       Verify your eligibility as a U.S. resident.

•       Enable winner contact and identity confirmation.

•       Assist in fraud prevention and account integrity.

If your account does not have a verified phone number, you may be prompted to add and verify one before participating. For AMOE participants (Community GivWin only), a phone number associated with your ClkN’Collect account must exist or be provided on the postcard.

3.5 Exclusions

The following individuals are not eligible to participate in any GivWin:

•       Officers, directors, employees, and contractors of Chapeau LLC.

•       Immediate family members (spouse, parent, child, sibling) and household members of the above.

•       Any person who has been suspended or banned from the Service.

•       Any person who has previously won a GivWin within any exclusion window specified for that GivWin within the Service.

3.6 Geographic Restriction

GivWin is available to legal U.S. residents only. It is void where prohibited or restricted by applicable law. It is each participant’s sole responsibility to determine whether participation is lawful in their jurisdiction.

4.1 Community GivWin — Participation via Coins

For Community GivWins, users with a sufficient Coin balance may participate as follows:

1.    Open the active Community GivWin within the Service.

2.    Review the prize, participation cost in Coins, and closing date.

3.    Select the number of participations (where multiple are permitted).

4.    Confirm your contribution. Coins will be deducted from your balance immediately.

5.    Your unique participation identifier(s) will be generated and displayed in the Service.

Coin balance requirements: You must have a sufficient Coin balance to cover the participation cost. Partial contributions are not accepted.

Multiple participations: Subject to per-GivWin limits defined within the Service. Each participation generates a separate, unique identifier.

4.2 Campaign GivWin — Participation via Promotional Action

For Campaign GivWins, participation is granted by completing the required free promotional action as described in the Service for that specific campaign (e.g., scanning a QR code, completing an onboarding step). No Coins and no payment are required. No AMOE is available or applicable for this format.

4.3 Volunteer GivWin — Participation by Company Recognition

For Volunteer GivWins, no entry action is required by the participant. The Company identifies qualifying volunteers and assigns participation identifiers directly. Volunteers do not need to submit anything to be entered. No Coins, no payment, and no AMOE are available or applicable for this format.

4.4 Alternative Method of Entry (AMOE) — Community GivWin Only

4.4.1 How to Submit an AMOE Entry

Participating via AMOE is a two-step process. Both steps must be completed for your entry to be valid: Step 1 — Send a handwritten postcard by standard U.S. mail to:

ClkN’Collect — GivWin AMOE

[MAILING ADDRESS TO BE INSERTED]

4.4.2 Required Postcard Content

Your postcard must include all of the following, written legibly:

•       Full Legal Name

•       Email Address (associated with your ClkN’Collect account)

•       ClkN’Collect User ID

•       U.S. Phone Number (associated with or verifiable through your account)

•       Name of the Community GivWin you are entering

•       Sequence Number: if you plan to send more than one postcard for the same GivWin, write the sequence of this postcard out of the total you intend to send (e.g., “2 of 5”). This numbering helps the Company identify and follow up on any missing submissions in your sequence.

4.4.3 Deadline

Your postcard must be received by the Community GivWin Closing Date shown within the Service for the applicable GivWin. Postcards received after this date will not be processed.

4.4.4 AMOE Processing & Validation

AMOE participation requires two steps. Please note:

•       Step 1 — Postcard receipt and validation: Each postcard must be received, reviewed, and validated by the Company before any participation credit is issued. This step is not automatic and requires manual processing.

•       Step 2 — In-app activation: Once the Company validates your postcard and confirms your eligibility, a free participation credit will be added to your ClkN’Collect account. You must then log into the app and actively use this free participation credit before the GivWin closes. The GivWin closes when either the maximum total number of participations is reached or the GivWin period ends, whichever comes first. Free participation credits that are not activated before the GivWin closes will not be entered into the draw and will be forfeited.

•       Once validated, your participation will be reflected in the Service and will carry the same equal opportunity of selection as Coin-based participation.

•       Invalid postcards (missing information, illegible, received after deadline) will not receive a participation identifier.

•       The Company will use reasonable efforts to contact you at the email address provided if a postcard is found to be incomplete or unclear.

4.4.5 AMOE Participation Limits

Each postcard constitutes one (1) free participation credit. AMOE participants are subject to the same per-GivWin maximum participation limits as Coin-based participants. Note that each Community GivWin defines both a minimum and maximum total number of participations across all participants. The GivWin will not proceed if the minimum is not reached; participation closes once the maximum is reached, regardless of remaining time. AMOE credits must be activated before the GivWin closes for either reason.

4.4.6 No Carry-Over

AMOE participations are valid only for the specific Community GivWin for which they are submitted. They do not carry forward to future GivWin activities and must be resubmitted separately for each GivWin.

4.5 Equal Opportunity of Selection

Within each GivWin type, all valid participations are assigned a unique participation identifier and have an equal probability of being selected in the winner draw. The method of obtaining participation does not affect the likelihood of selection.

5.1 Minimum Participation Threshold

Each Community GivWin defines both a minimum and a maximum total number of participations across all participants. The draw will not be conducted if the minimum threshold is not reached. Participation closes automatically once the maximum threshold is reached, regardless of remaining time. If the minimum threshold is not met by the GivWin Closing Date (or when the GivWin closes early at the maximum):

•       The GivWin may be cancelled or extended at the Company’s discretion.

•       Coins contributed to a cancelled Community GivWin will be refunded to participants’ balances.

•       AMOE submissions will not carry forward and must be resubmitted for any rescheduled or future GivWin.

5.2 Selection Mechanism

The winner is selected through a transparent, defined process:

1.    Each valid participation is assigned a unique multi-digit identifier within the Service.

2.    At the conclusion of the GivWin period, a digit-by-digit spinning mechanism is used to sequentially generate a participation identifier.

3.    The system checks whether the generated identifier corresponds to a valid participation.

4.    If the generated identifier is valid, the holder of that participation is selected as the potential winner.

5.    If the generated identifier does not correspond to a valid participation, additional selections are made until a valid identifier is matched.

5.3 Transparency & Live Selection

•       The selection process may be conducted live, including via livestream, and/or recorded for transparency purposes.

•       Recorded selection events may be made accessible within the Service.

•       The winning participation identifier will be published within the Service following the draw.

•       Personal information of participants will not be publicly disclosed without consent, except as required by law.

5.4 Number of Winners

Unless otherwise specified for a particular GivWin within the Service, there will be one (1) winner per GivWin draw.

6.1 Verification Process

The selected participant will be notified through the Service and/or the contact information associated with their account. To claim a reward, the selected winner must complete a verification process that may include:

•       Confirmation of identity (e.g., government-issued ID).

•       Confirmation of age (18 or older for Community and Campaign GivWin; 16 or older for Volunteer GivWin, with parental or guardian verification required for winners under 18).

•       Confirmation of U.S. residency.

•       Confirmation of a valid U.S. phone number.

•       Any additional verification required by the Company or applicable law.

6.2 Verification Deadline

The winner must complete verification within the timeframe specified in the notification or within the Service. Failure to respond or complete verification within the stated period may result in disqualification.

6.3 Disqualification & Re-Draw

The Company may disqualify a selected participant and conduct a new selection if:

•       The participant fails to complete the required verification within the deadline.

•       The participant is found to be ineligible under Section 3.

•       The participant is found to have violated these Rules or the Terms of Service.

•       The participant cannot be contacted through the information on file.

A new selection will be conducted using the same process described in Section 5 until a valid, eligible winner is confirmed.

7.1 Prize Description

Prizes may include, but are not limited to:

•       Physical goods (e.g., electronics, merchandise, household items).

•       Digital items (e.g., gift cards, digital vouchers).

•       Experiences or other benefits as defined within the Service.

The specific prize for each GivWin will be described within the Service prior to and during the participation period.

7.2 Prize Substitution

If a prize becomes unavailable due to supply, logistical, or other constraints, the Company may substitute it with a prize of equal or similar value. The Company will make reasonable efforts to provide a comparable item.

7.3 No Cash Alternative

No cash equivalent, cash alternative, or cash substitution will be provided for any prize under any circumstances.

7.4 Prize Delivery

Prizes will be delivered to the confirmed winner through methods that may include:

•       In-person delivery, where applicable (e.g., at an event).

•       Standard shipping or courier delivery to a confirmed U.S. address.

•       Digital delivery within the Service or via email (for digital prizes).

The winner is responsible for providing accurate delivery information. The Company is not responsible for prizes that are undeliverable due to incomplete or incorrect information provided by the winner.

7.5 Tax Responsibility

Winners are solely responsible for all applicable federal, state, and local taxes associated with any prize received. The Company may be required to report prize values to tax authorities in accordance with applicable law. Winners may be required to provide tax identification information before a prize is delivered.

8.1 Prohibited Activities

Participants agree not to engage in any of the following:

•       Creating multiple accounts to increase the number of participations beyond permitted limits.

•       Using automated tools, bots, scripts, or other unauthorized means to generate participations.

•       Submitting false, misleading, or fraudulent information in connection with any participation method, including AMOE.

•       Attempting to manipulate the selection process or system data.

•       Sharing accounts or acting on behalf of another person without authorization.

•       Attempting to enter a Volunteer GivWin without being a recognized qualifying volunteer.

•       Any other activity that constitutes fraud, misuse, or abuse of the GivWin system.

8.2 Consequences of Violations

•       Immediate disqualification from the applicable GivWin.

•       Forfeiture of any Coins used for participation, without refund.

•       Suspension or termination of their ClkN’Collect account.

•       Legal action where warranted.

9.1 Right to Modify

•       Participation methods, limits, and costs.

•       Eligibility requirements.

•       Prize description and fulfillment methods.

•       Selection process and timeline.

•       These Rules.

9.2 Right to Cancel

The Company may suspend or cancel any GivWin at any time due to:

•       Insufficient participation.

•       Technical issues or system errors.

•       Legal or regulatory requirements.

•       Fraud, abuse, or manipulation affecting the integrity of the GivWin.

In the event of cancellation of a Community GivWin, Coins contributed will be refunded. AMOE submissions will not carry forward.

9.3 Company Decisions Final

All decisions made by the Company regarding GivWin — including eligibility determinations, selection outcomes, and prize fulfillment — are final and binding, subject to applicable law.

9.4 Limitation of Liability

To the maximum extent permitted by applicable law, the Company is not liable for:

•       Any inability to participate due to technical issues or device limitations.

•       Lost, late, incomplete, or undeliverable AMOE postcards (Community GivWin).

•       Errors in processing participations or recording identifiers.

•       Cancellation, modification, or suspension of any GivWin.

•       Any indirect, incidental, or consequential damages arising from participation or non-participation.

Participation in GivWin involves the collection and processing of personal information as described in the ClkN’Collect Privacy Policy. Key points:

10.1 Data Collected for GivWin

•       Participation records and identifiers are stored within the Service.

•       Phone number verification data is used to confirm U.S. eligibility.

•       For selected winners, additional verification data (name, address, phone number, ID confirmation) is collected solely for eligibility verification, fraud prevention, prize fulfillment, and legal compliance.

•       AMOE postcard data (name, email, User ID, phone number) is processed to assign a free participation credit (Community GivWin only) and is discarded after processing, unless retention is required by law. For Volunteer GivWin participants under the age of 18, parental or guardian consent records are retained for the duration of the volunteer relationship and for a reasonable period thereafter, consistent with applicable law.

10.2 Winner Information

The winning participation identifier will be published within the Service. The winner’s personal name and other identifying information will not be publicly disclosed without their consent, except as required by law.

10.3 Data Retention

GivWin-related verification data is retained for up to 90 days following winner confirmation or disqualification, unless longer retention is required by applicable law. Participation records and transaction data are retained for up to 5 years for legal and audit purposes.

10.4 Privacy Policy

For complete information about how we collect, use, and protect your personal information, please refer to the ClkN’Collect Privacy Policy available at www.clkncollect.com.

These Rules are governed by the laws of the State of Tennessee, without regard to its conflict of law principles. Any disputes arising under these Rules are subject to the dispute resolution provisions set out in Section 12 of the ClkN’Collect Terms of Service, including the binding arbitration and class action waiver provisions contained therein.

•       The in-app contact or support form (available to registered users and guests)

•       The contact form on our website: www.clkncollect.com

--- End of GivWin Official Rules ---

ClkN’Collect | Chapeau LLC | www.clkncollect.com