Terms and Conditions of a Giveaway on the Social Network Instagram

(here in after referred to as the “Terms”)

1. General Provisions

1.1. This giveaway (hereinafter referred to as the “Giveaway”) is organized by KORONAPAY EUROPE LTD (hereinafter referred to as the “Organizer”), registered at: 28th October Street 359, World Trade Center, 5th Floor, 3107 Limassol, Cyprus.

1. General Provisions

1.2. The Giveaway is conducted for the purpose of promoting the official KoronaPay Europe page on the social network Instagram.

1.3. Participation in the Giveaway is free of charge. No purchase of goods or services is required to participate.

1.4. The Giveaway is conducted within the territory of the EEA and the United Kingdom.

1.5. The Giveaway period runs from 19 December to 28 December 2025 (inclusive).

1.6. The Giveaway is not sponsored, endorsed, administered by, or associated with Meta Platforms, Inc., Instagram, or any of their affiliated entities.

1.7. The Organizer is fully responsible for conducting the Giveaway, including drafting the Terms, setting restrictions, selecting winners, and awarding prizes.

2. Giveaway Participants

2.1. Eligible participants are legally capable individuals who are at least 18 years old and reside in one of the EEA countries or the United Kingdom.

2.2. Employees of the Organizer and members of their families are not eligible to participate.

2.3. Participation in the Giveaway constitutes full and unconditional acceptance of these Terms.

3. Conditions of Participation

3.1. To participate in the Giveaway, a Participant must:

follow the official KoronaPay Europe Instagram page;
find the Giveaway post on the official KoronaPay Europe Instagram page and like the post;
leave a comment under the post stating what the Participant values about Korona transfers (for example — delivery speed). The comment may be in any language.
3.2. Comments containing insults, hate speech, extremist statements, illegal content, spam, or comments unrelated to the post topic are not allowed and will be excluded from participation.

4. Selection of Winners

4.1. Each valid comment will be assigned a sequential number. These numbers will be used to conduct the Giveaway using a random number generator.

4.2. Five (5) winners will be randomly selected from all valid comments using a random number generator.

4.3. Before announcing the winners, the Organizer verifies compliance with the participation conditions: subscribed to Koronapay Europe Instagram page, liked the post.

4.4. The Giveaway results may be published on KoronaPay Europe’s social media pages or sent to winners via direct message.

5. Prizes and Procedure for Receiving Them

5.1. Each of the five (5) winners is entitled to a cash prize of EUR 20 (twenty euros).

5.2. In three (3) business days the winners will be notified via Instagram direct messages and asked to provide their email address. Further instructions on how to get the prize would be sent via email.

5.3. Prizes are transferred to the winners’ personal bank accounts (IBANs).

5.4. If it is impossible to contact the winner within ten (10) calendar days after the announcement of the results (for example, the winner does not respond to private messages on Instagram or does not provide the necessary information), the Organizer has the right to declare the prize unclaimed. Then the Organizer may select a new winner from among the remaining Participants in the manner prescribed by Section 4 of these Terms.

6. Liability and Limitations

6.1. The Organizer is not liable for:

inability to participate due to technical issues with social networks or internet connection;
errors in the participant’s information that prevent the participant from receiving the prize (including incorrect contact information, IBAN, etc.);
any losses incurred by the participant because of participating in the Giveaway, except in cases explicitly provided by law.

6.2. The Organizer reserves the right to:

change the terms or conditions of the Giveaway without adversely affecting the participants' rights;
exclude participants if fraudulent activity is detected (e.g., use of fake accounts, automated services, mass registrations, etc.);
cancel the Giveaway in the event of force majeure (including, but not limited to, disruptions to social media, significant regulatory changes, natural disasters, military action, etc.).

6.3. The winner is solely responsible for declaring and paying all taxes, fees and other mandatory payments that may arise in connection with receiving the prize, in accordance with the laws of their country of residence, unless otherwise expressly provided by applicable law.

7. Personal Data Processing

7.1. The controller of Participants' personal data is the Organizer.

Participants may contact us with any questions regarding the processing of their personal data by email at dpo@koronapay.eu.

7.2. As part of the Giveaway, the Organizer processes the following categories of personal data

for all Participants:

Participant’s Instagram account name (nickname);

Additionally for winners:

email address;
full name
banking details (IBAN) for prize money transfer.

7.3. Participants' personal data is processed for the following purposes:

organizing and conducting the Giveaway in accordance with these Terms;
verifying compliance with the participation requirements (subscription to the Organizer’s page, presence of comments);
determining the winners and notifying them of their winnings;
transferring cash prizes to the winners and fulfilling related obligations;
publishing information about the winners (nickname/account name) on the Organizer’s official social media pages;
preventing abuse and protecting the Organizer’s legitimate rights and interests (e.g., identifying fake accounts and mass registrations).

7.4. The legal basis for processing personal data is:

the Organizer’s legitimate interest (Article 6(1) (f) of the GDPR / UK GDPR), which consists of promoting its services and brand, informing users of the results of the Draw, and preventing fraud by publishing information about the winners and conducting investigations for fraudulent activities;
fulfilling the Organizer’s legal obligations (Article 6(1)© of the GDPR / UK GDPR), which includes storing information necessary for accounting and tax purposes.7.5. Personal data is not used for marketing without consent.

7.5. The Organizer does not use Participants' personal data collected during the Giveaway to send marketing materials (emails, advertising messages outside the Giveaway) unless the Participant has expressly and separately consented to this in accordance with the procedure established by the Organizer. Any such consent is voluntary and may be revoked by the Participant at any time.

7.6. Personal data retention periods:

Data related to participation in the Giveaway (nicknames and comments) will be stored by the Organizer for the duration of the Giveaway and until January 28, 2025, after its completion, for documentation purposes and the potential consideration of any inquiries or claims.

Winner’s data, including contact information and prize payment information, will be stored for the period necessary to comply with accounting and tax laws and to protect the Organizer’s rights.

Participants' comments and nicknames may continue to be displayed on Instagram in accordance with Instagram’s rules and privacy policy. Instagram controls the storage and deletion of such data.

7.7. Access to Participants' personal data is granted to:

authorized employees of the Organizer;
banks and/or payment institutions involved in transferring prizes to winners, which act as independent controllers of personal data and process it in accordance with their own laws and privacy policies.

7.8. The processing of Participants' personal data by Instagram is carried out independently of the Organizer and is governed by Instagram’s privacy policy and terms of use. The Organizer has no control over and is not responsible for Instagram’s independent data processing.

7.9. Participants have the following rights regarding their personal data (to the extent provided by applicable law):

the right to access their personal data;
the right to rectification (amendment) if the data is inaccurate or incomplete;
the right to erasure (the “right to be forgotten”) if there is no longer a legal basis for processing;
the right to restriction of processing;
the right to object to processing carried out based on the Organizer’s legitimate interests;
the right to data portability (where applicable).

To exercise these rights, Participants may contact the Organizer at the email address specified in Section 7.1 of these Terms.

7.10. More detailed information on the processing of personal data by the Organizer in other cases may be available in the Organizer’s Privacy Policy at: https://koronapay.com/static/legals/Privacy_Policy.html

7.11. Providing a nickname and comment is a requirement for participation in the Giveaway. Failure to provide this information will result in ineligibility. Providing an email address and bank account information (IBAN) is required to receive the prize and is requested only from winners; failure to provide this information will result in the prize being ineligible for payment.

7.12. Winners are selected using a random number generator. This automated data processing is solely for the purpose of randomly selecting winners and does not create any legal consequences for Participants or have any significant impact other than enabling individual Participants to receive a prize.

8. Miscellaneous

8.1. The Organizer reserves the right to amend these Terms. The updated version will take effect upon publication on the Organizer’s official website, unless otherwise stated.

8.2. The Organizer reserves the right not to award a prize to a participant who has violated the terms of these Terms, as well as in the event of detection of unfair actions specified in paragraph 6.2 of the Terms.

8.3. Participation in the Drawing means that you have read the Terms and agree with them in full.

8.4. These Terms are governed by the EU law.