Clutch Contest Rules (Prize Draw)

This is a courtesy English translation of a French-law prize-draw règlement. The French version is the only binding version (see §19). Apple Inc. and Google LLC are neither organizers nor sponsors of, and are not associated in any way with, this contest, which they do not sponsor, endorse, or administer. Any question, comment, or complaint should be directed to Rodger Studio, not to Apple or Google.

NO PURCHASE OR PAYMENT OF ANY KIND IS NECESSARY TO ENTER OR WIN. This contest is a promotional prize draw (French "loterie publicitaire") with no obligation to purchase and no financial sacrifice. Entry uses Points, an in-app currency that is only ever earned for free and can never be purchased. No purchase improves your chances of winning.

1. Organizer

This contest is organized and sponsored by Rodger Studio, a French société par actions simplifiée (SAS) with share capital of €14,492.00, registered with the Nanterre Trade and Companies Register under number 994 545 523, whose registered office is at 21 villa Marie-Justine, 92100 Boulogne-Billancourt (the "Organizer"). The Organizer is the sole organizer, administrator, and sponsor of the contest offered through the Clutch mobile application.

2. Nature of the contest

The contest is a promotional prize draw (French "loterie publicitaire", a promotional operation under article L.121-20 of the French Consumer Code) in which prizes are awarded solely by a random draw. It is run with no obligation to purchase and no financial sacrifice.

Because one of the four cumulative criteria that define a money-and-chance game under article L.320-1 of the French Internal Security Code (the participant's financial sacrifice) is absent, the contest is not a money-and-chance game (jeu d'argent et de hasard) and is not subject to the French gambling authority (ANJ). It is a developer-sponsored sweepstakes, not a lottery in the sense that would require gambling licensing. It is distinct from Clutch prediction markets: markets are binary (YES/NO) predictions staked in Credits and resolved by real-world events, whereas the contest is entered with Points and decided by a random draw. Taking part implies full and unreserved acceptance of these rules.

3. No purchase and no financial sacrifice

Participation is free. It involves no obligation to purchase and no financial sacrifice of any kind, not even a sum that is advanced and later refunded. No payment, in-app purchase, subscription (including any premium status), or other financial consideration, whether direct or indirect, is required to obtain Points, to obtain Tickets, or to receive a prize, and none of them increases a participant's chances of winning or the number of Tickets held.

Tickets are obtained only by spending Points. Points are earned by making correct predictions on Clutch markets; those predictions are staked in Credits, another in-app currency. Both Points and Credits are only ever obtained for free. Credits are granted in particular through:

• the signup bonus on account creation;
• the daily login bonus and login-streak milestones;
• referral bonuses for inviting friends;
• free rewarded video ads.

Neither Points nor Credits can ever be purchased, sold, exchanged, or converted into money, and they have no cash value.

4. Eligibility

Participation is open to any person who, at the time of entry, meets all of the following conditions:

• be a natural person aged 18 or over;
• reside in Metropolitan France or in one of the following French Overseas Departments: Guadeloupe, Martinique, Guyane, La Réunion, and Mayotte. The contest is not open anywhere else;
• hold a single (1) Clutch account. Creating multiple accounts to gain an advantage is prohibited and may result in disqualification and account closure;
• have a valid, reachable email address linked to the account so the Organizer can contact the participant if they win. A winner who cannot be reached may forfeit the prize;
• not be an employee, officer, or director of Rodger Studio, nor a member of their immediate family or household.

The Organizer may ask any participant to prove that they meet these conditions; failing which the participant is excluded and their entry gives no right to a prize.

5. How to enter

To enter a contest:

1. open the contest in the Clutch app;
2. obtain one or more Tickets by spending the fixed number of Points shown on the contest;
3. each Ticket is one entry in the draw. Holding more Tickets increases the chances of winning proportionally.

Because Points are always earned for free, entry is always free. A participant may obtain as many Tickets as they wish, subject to their available Points and to any per-participant Ticket limit stated on the contest.

6. Points spent on Tickets are non-refundable

Points spent to obtain Tickets are final and non-refundable, except if the contest is cancelled by the Organizer. If a contest is cancelled, all Points spent on Tickets for that contest are credited back to the participants who spent them. Points cannot be transferred, sold, or exchanged between users.

7. Duration

The opening date and closing date of each contest, as well as the draw date, are shown on the contest in the app and on this page. No Ticket can be obtained after the closing date.

8. How winners are determined (verifiable draw)

Winners are designated by a publicly verifiable random draw whose result depends solely on chance. The draw is bound to the public drand randomness beacon (network: quicknet) using a commit-before-draw method, so that anyone can reproduce and check the result and the Organizer cannot influence it:

1. before the contest opens, the Organizer publishes the method: the drand network, the round-selection rule (the first drand round whose timestamp is strictly after the closing time), the participant sort order, and the exact winner algorithm;
2. at close, the list of entrants is frozen and a commitment SHA256(participants) is published, where participants is the ordered list of each entry's anonymized identifier and ticket count;
3. at the predetermined round, the Organizer fetches that drand round, cryptographically verifies the beacon (BLS) against drand's public key, and computes the winner deterministically: seed = SHA256(randomness + contest id), index = seed modulo the total number of Tickets, and the winner is the entry whose cumulative Ticket range contains that index. For multiple winners, the computation repeats with seed_k = SHA256(randomness + contest id + k) over the remaining Tickets, excluding earlier winners; draw number k is rank k and receives the k-th prize;
4. after the draw, a proof (commitment hash, drand round and randomness, algorithm, computed index, and anonymized winner) is published on this page so anyone can independently reproduce and verify the outcome.

The randomness does not exist at the moment of closing, so the Organizer can neither know it in advance, nor switch to a different round afterwards, nor alter the list of entrants without breaking the published commitment. The result of the draw, thus verifiable by anyone, is final. The exact, byte-level specification of the algorithm (encoding of the randomness and the contest id, canonical serialization of the participant list, byte order of the integer conversion, and numbering of k) is published with each contest's proof, so the result can be reproduced identically.

9. Prizes

Prizes are funded entirely by the Organizer as a marketing cost and are never pooled from participants' Points. Each contest defines an ordered list of one or more prizes; the nature, number, and estimated retail value of each prize [to be completed for each contest] are shown on the contest.

A prize cannot be exchanged, transferred, replaced, or converted into cash, except at the Organizer's decision if a prize is unavailable (it is then replaced by a prize of equivalent value). Any taxes, duties, or fees related to awarding or delivering a prize are borne by the Organizer, except bank fees relating to any cash prize, which remain the winner's responsibility.

10. Claiming a prize

Winners are notified in the app and by email (participants should check their spam folder). Each winner has thirty (30) days from the announcement of the result to claim the prize.

• to receive a prize, the winner must confirm eligibility, provide a valid delivery address in Metropolitan France or a covered Overseas Department, and verify their identity and age (18 or over). The Organizer may verify the winner's age and identity;
• a winner who does not claim within the deadline, cannot be reached, declines the prize, or fails verification forfeits the prize;
• a forfeited prize is redistributed to a replacement winner designated by the same verifiable draw method (using the next drand round and excluding prior winners).

11. Odds of winning

Each participant's chance of winning is proportional to the number of Tickets they hold relative to the total number of Tickets entered in the contest. The odds are not predetermined and depend on the total number of Tickets. No purchase or payment increases these odds.

12. Reimbursement of participation costs

Participation takes place entirely within the app and incurs no specific cost. Any internet connection costs incurred to participate, and any cost incurred to request these rules, are reimbursed on written request to the Organizer (see Contact), on a flat-rate basis of a local call of up to ten (10) minutes at the applicable reduced rate, together with proof (dates, times, and duration of connection) and bank details. One reimbursement request per participant and per contest is accepted; internet access is otherwise ordinary and not specific to the contest.

13. Personal data

Rodger Studio, as data controller, processes participants' personal data in accordance with Regulation (EU) 2016/679 (GDPR) and French Act No. 78-17 of 6 January 1978 as amended.

• Purposes and legal basis: managing the contest, designating winners, and delivering prizes, on the basis of performing the contest the participant takes part in; and, where applicable, sending marketing information, solely on the basis of the participant's separate, revocable consent.
• Recipients: the Organizer and, where applicable, its technical and delivery providers, bound by confidentiality.
• Retention: data is kept for the duration of the contest and prize delivery, plus applicable legal periods; data processed for marketing is kept for at most three (3) years from the last contact.
• Anonymity: the draw and the published proof use only anonymized participation identifiers; no data identifying a participant by name is made public.
• Rights: each participant has the rights of access, rectification, erasure, objection, restriction, and portability, exercised with the Organizer (see Contact), and may lodge a complaint with the CNIL (www.cnil.fr).

For more information, see the Privacy Policy for Clutch.

14. Communication about winners

The Organizer may, subject to the winner's prior express consent, mention their first name or username for communication relating to the contest. This consent is in no way a condition for awarding the prize and may be refused or withdrawn at any time without affecting the prize.

15. Filing, availability, and acceptance of the rules

These rules are filed with [commissaire de justice to be completed] [deposit reference to be completed]. They can be viewed free of charge on this page and will be sent free of charge to anyone who requests them from the Organizer (see Contact). Merely taking part entails full and unreserved acceptance of these rules.

16. Amendment, postponement, and cancellation

The Organizer may shorten, extend, postpone, amend, or cancel a contest if circumstances require, in particular in the event of force majeure or fraud, without incurring liability. If a contest is cancelled, Points spent on Tickets are credited back as stated in section 6.

17. Fraud and liability

• the Organizer may, at its sole discretion, disqualify any participant who tampers with the operation of the app, uses multiple or farmed accounts, colludes, uses automated or fraudulent means, or otherwise acts inconsistently with these rules. Tickets and any pending prize associated with such an account may be forfeited;
• the Organizer is not liable for technical failures, errors, omissions, interruptions, delays, or defects in the app, network, or any related systems, or for any resulting damage;
• in the event of a dispute over the identity of a participant, the authorized holder of the Clutch account is deemed to be the participant.

18. Governing law, disputes, and mediation

These rules are governed by French law. Any complaint must first be sent to the Organizer, who will seek an amicable solution. In accordance with the French Consumer Code, the participant may use a consumer mediator free of charge. Failing an amicable resolution, the dispute falls to the competent French courts, without prejudice to the mandatory consumer-protection rules of the participant's place of residence.

19. Language

These rules are written in French, which is the only authentic version. Any translation is provided for information and for the reader's convenience.

20. Contact

For any question about these rules, any reimbursement request, or any request concerning personal data:

Rodger Studio

Email: contact@rodgerstudio.com