Points Program Terms

These Points Program Terms (“Points Terms”) govern the Freeport Points program (“Points Program”) offered through the Freeport Markets application and any related websites, interfaces, content, and services (collectively, the “Services”). The Services are operated by Freeport Markets, Inc., a Delaware corporation (“Freeport,” “we,” “us,” or “our”).

Participation in the Points Program is voluntary and discretionary. By participating in the Points Program, you accept these Points Terms in addition to our Terms of Service and Privacy Policy, each of which is incorporated by reference. If you do not agree, you must not participate in the Points Program.

PLEASE READ THESE POINTS TERMS CAREFULLY. THEY ARE WRITTEN TO BE BROAD. THE POINTS PROGRAM IS A DISCRETIONARY ENGAGEMENT FEATURE. POINTS HAVE NO GUARANTEED VALUE, ARE NOT A FINANCIAL PRODUCT, AND CONFER NO RIGHTS, CLAIMS, OR EXPECTATIONS AGAINST FREEPORT.

1. Nature of Points

Freeport Points (“Points”) are a non-monetary, non-transferable, promotional credit that exists solely within the Services and is granted at Freeport’s sole discretion.

Points are NOT:

• A currency, security, commodity, derivative, deposit, e-money, gift card, prepaid instrument, stored-value instrument, or other financial product.
• Cash, a cash equivalent, or convertible to cash on demand.
• A debt, liability, deposit, account balance, asset, claim, receivable, or obligation of Freeport or any of its affiliates.
• Property of any participant. You have no ownership, title, vested right, or property interest in any Points credited to your account.
• A promise of, indication of, or commitment to any future airdrop, token issuance, token generation event (“TGE”), distribution, dividend, allocation, equity interest, revenue share, or other financial benefit.

Points have no inherent or guaranteed monetary value and are not redeemable for cash. Any reference to “value,” “$0.01 per point,” “redemption value,” “face value,” or similar language in the Services is for internal calibration and illustration only and does not create any obligation, representation, warranty, or commitment by Freeport. The reference value of Points may change at any time, in any direction, with or without notice.

2. No Investment, No Future Distribution

Participation in the Points Program is not an investment in Freeport, an offer of securities, or an offer to sell or solicitation to buy any security, token, instrument, or asset. Points are not, and should not be construed as, an indication of, expectation of, or commitment to:

• Any future airdrop, token launch, token generation event, network token, governance token, utility token, or similar distribution.
• Any future cash payout, redemption-for-cash program, equity grant, profit share, revenue share, or financial distribution.
• Continued availability, value, or operation of the Points Program in any form.

You should not participate in the Points Program with any expectation of receiving a financial return or future asset. You acknowledge that nothing in the Services, including the existence of Points or any communication from Freeport, constitutes a representation or commitment to a future TGE, airdrop, or distribution event of any kind.

3. Discretionary Adjustment of Points

Freeport may, at any time and in its sole and absolute discretion, with or without notice, and with or without cause, take any of the following actions with respect to any Points or any participant:

• Add, credit, deduct, debit, void, freeze, reverse, expire, recalculate, or adjust the Points credited to any account, in any amount.
• Reset, suspend, terminate, or zero-out the Points balance of any user.
• Decline, cancel, or reverse any redemption, in whole or in part.
• Investigate any account, activity, redemption, or pattern of behavior we determine, in our discretion, may be inconsistent with the spirit or terms of the Points Program.

Reasons we may adjust Points include, without limitation:

• Suspected, attempted, or actual non-bonafide farming, gaming, or exploitation of the Points Program (including without limitation wash trading, self-dealing, multi-account abuse, automated activity, sybil patterns, collusion, and activity that does not reflect genuine economic intent).
• Errors, calculation defects, technical issues, system bugs, oracle or data-feed issues, or third-party service failures.
• Violation or suspected violation of these Points Terms, the Terms of Service, the Privacy Policy, applicable law, or any platform policy.
• Cancellation, reversal, dispute, refund, or chargeback of any underlying transaction or activity that gave rise to the Points.
• Account closure, sanctions screening, KYC failure, or compliance reasons.
• Any other reason we, in our sole discretion, deem appropriate, INCLUDING FOR NO REASON AT ALL.

You acknowledge and agree that Freeport does not need to demonstrate cause, fault, bad faith, materiality, or proportionality before adjusting Points, and that no adjustment, reversal, forfeiture, or termination of Points gives rise to any claim, refund, compensation, damages, or remedy of any kind.

4. Earning and Redemption Rules

All earning rules (including rates, eligible activities, multipliers, streaks, quests, badges, chests, referrals, caps, thresholds, and eligibility requirements) and all redemption rules (including catalog availability, redemption costs, fulfillment, identity verification, geographic restrictions, and shipping) are determined by Freeport in its sole discretion and may change at any time without notice.

Redemption is subject to availability, eligibility, identity verification (where required), and applicable law. Some redemption items may require Know-Your-Customer (“KYC”) completion, age verification, or compliance review. Freeport may decline any redemption for any reason or no reason.

Points may not be transferred, sold, gifted, assigned, pledged, encumbered, or used as collateral. Any attempted transfer or assignment is void.

5. Changes to the Points Program

Freeport may, at any time and in its sole discretion, with or without notice:

• Modify, change, suspend, pause, or terminate the Points Program in whole or in part.
• Change earning rates, multipliers, streak rules, quest definitions, badge thresholds, chest mechanics, referral payouts, redemption catalog, redemption costs, exchange ratios, eligibility, or any other parameter of the Points Program.
• Change, modify, replace, or rebrand the unit, name, value reference, or denomination of Points.
• Update these Points Terms by posting an updated version and revising the “Last Updated” date.

Your continued participation in the Points Program after any change constitutes your acceptance of the change. If you do not agree, you must stop participating in the Points Program.

We are not obligated to grandfather any earning rate, redemption price, or program benefit, and prior participation does not give rise to any expectation of continued treatment.

6. Termination of Program; Forfeiture

Freeport may terminate the Points Program in whole or in part at any time, in its sole discretion, with or without notice. Upon termination, all unredeemed Points will be deemed forfeited and will have no value. You will have no claim, right, refund, compensation, or remedy of any kind for forfeited Points.

If your account is suspended, terminated, or closed for any reason, all Points credited to your account may be forfeited at our sole discretion.

Points expire if not used within any period that Freeport may, in its sole discretion, establish.

7. No Securities; No Money Transmission; Not a Deposit

Freeport offers the Points Program as a discretionary engagement feature. The Points Program is not, and is not intended to be, a securities offering, money transmission, money services business, banking activity, gift-card program, prepaid-access program, deposit-taking activity, or other regulated financial activity. Points are not deposits and are not insured by any government deposit insurance program (including the FDIC) or any private insurance.

8. Tax

Where Points result in a redemption that has fair market value, you may be responsible for any applicable taxes. Freeport may, where required by law, report any income or value associated with Points or redemptions to relevant tax authorities. We do not provide tax advice; consult a qualified tax professional regarding your obligations.

9. Eligibility; Geographic and Sanctions Restrictions

The Points Program is offered only to users who are eligible to use the Services under the Terms of Service, including without limitation the eligibility, geographic, and sanctions provisions of those Terms. Freeport may, at any time and in its sole discretion, restrict or block participation in the Points Program in any jurisdiction.

10. No Warranties; Limitation of Liability

THE POINTS PROGRAM IS PROVIDED “AS IS” AND “AS AVAILABLE.” TO THE MAXIMUM EXTENT PERMITTED BY LAW, FREEPORT DISCLAIMS ALL WARRANTIES, EXPRESS, IMPLIED, OR STATUTORY, REGARDING THE POINTS PROGRAM, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AVAILABILITY, ACCURACY, AND NON-INFRINGEMENT.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, FREEPORT AND ITS AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, AGENTS, CONTRACTORS, AND LICENSORS WILL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF POINTS, REDEMPTION OPPORTUNITY, EXPECTED VALUE, GOODWILL, OR DATA, ARISING OUT OF OR RELATING TO THE POINTS PROGRAM, EVEN IF ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

NOTHING IN THESE POINTS TERMS LIMITS ANY LIABILITY THAT CANNOT BE EXCLUDED UNDER APPLICABLE LAW.

11. Governing Law; Disputes

These Points Terms are governed by the laws of the State of Delaware, and, where applicable, the federal law of the United States, without regard to conflict-of-laws principles. Any dispute arising out of or relating to the Points Program is subject to the binding individual arbitration, class action waiver, and jury trial waiver provisions in the Terms of Service.

12. General

• Entire Agreement. These Points Terms, together with the Terms of Service and Privacy Policy, are the entire agreement between you and Freeport regarding the Points Program.
• Severability. If any provision is held unenforceable, it will be modified to the minimum extent necessary or severed, and the remaining provisions will remain in full force and effect.
• No Waiver. Failure to enforce any provision is not a waiver of that provision.
• Assignment. You may not assign these Points Terms. We may assign them in connection with a merger, acquisition, reorganization, financing, or sale of assets.
• Conflict. In the event of a conflict between these Points Terms and the Terms of Service, these Points Terms govern with respect to the Points Program.
• Headings. Headings are for convenience only and do not affect interpretation.

13. Contact Information

Questions or concerns regarding these Points Terms can be directed to:

Email: partners@freeportmarkets.com