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Loyalty Programme Terms (Draft)

Version and effective date: 21 August 2026

Legal draft — pending legal review. This text does not replace each Merchant's approved terms or professional review before publication.

These Loyalty Programme Terms govern the user’s (the “Member”) participation in the programme identified during enrolment (the “Programme”).

the participating Merchant operates the Programme, offers the benefits and is responsible for its commercial rules. LoyalPass provides the Merchant with the digital-pass technology.

1. Enrolment and acceptance

By ticking the acceptance box and completing enrolment, the Member accepts these Terms and the Programme-specific rules displayed by the Merchant before or during enrolment. Marketing consent is optional and is not required to participate. The Programme is available only to people aged 18 or over; by joining, you confirm that you meet that requirement.

2. How the Programme works

  • The Merchant visibly determines how stamps, points or rewards are earned and redeemed, including eligible products, requirements, limits and expiry dates.
  • Points, stamps and rewards are not money, do not earn interest, and cannot be sold, transferred or exchanged for cash unless mandatory law requires otherwise.
  • The Member must present their pass or identifier before the transaction where the Merchant requires it. The Merchant may correct balances for manifest errors, duplicates, documented fraud or abuse.

3. Changes, suspension and closure

The Merchant may modify the Programme only for specified valid reasons: legal compliance, security or fraud prevention, error correction, technical or supplier changes, or a reasonable commercial need to maintain the Programme.

Where a material change adversely reduces how benefits are earned or redeemed, the Merchant will give clear notice at least 30 days in advance through the pass information, Programme page, email or another available channel. Changes will not apply retroactively to rewards already redeemed or reduce points, stamps or rewards already earned, except for fraud, manifest error or a legal obligation.

If the Merchant closes the Programme, it will give at least 30 days to redeem benefits already earned, unless fraud, security or law requires immediate suspension or closure.

4. Permitted use and fraud

The pass is personal. You may not create duplicate accounts, manipulate balances, use automation, claim unearned benefits or interfere with the Service. The Merchant may suspend an account while investigating fraudulent or abusive use and, if confirmed, cancel only the affected benefits and close participation.

5. Privacy and communications

The Merchant is normally the controller of Member data used to operate the Programme. LoyalPass normally acts as processor for the Merchant and as an independent controller only for its own security, support, billing and compliance activities where applicable. Consult the Privacy Policy and the Merchant’s specific information before participating.

Messages necessary for the pass, Programme, security or an already earned benefit may be sent without marketing consent where an applicable legal basis exists. Promotional messages require a separate choice where law requires it and can be stopped at any time.

6. Availability and liability

LoyalPass provides a technology tool and does not guarantee uninterrupted availability of Apple Wallet, Google Wallet, mobile networks or third-party services. The Merchant remains responsible for delivering the benefits it offers under the applicable rules. Nothing in these Terms excludes or limits rights that cannot be excluded by law.

7. Complaints and applicable law

Questions about rewards, balances and commercial operation should first be addressed to the Merchant. Questions about the platform may be sent to dkylabs@gmail.com.

Where Spanish consumer law applies, its mandatory rules apply and the Member retains the rights granted by law.

8. Changes to these Terms

LoyalPass and the Merchant may update these Terms in line with section 3. The current version and its date will be available on this page. The Spanish version prevails for Programmes offered in Spain; the English version is an informative translation unless expressly stated otherwise.

Document version: consumer-terms-es-2026-08-21-draft-1

Daniel Yilong Keye

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