PT Luno Indonesia Ltd ("Luno") has agreed to offer the Luno Trading Challenge Program to Luno customers in Indonesia (the "Program"). The Program comprises (i) a monthly cashback rewards program, as described in Sections 1 to 7, (ii) the Top Volume Awards, as described in Sections 8 to 11, and (iii) a linked prize draw (the "Lucky Draw"), as described in Sections 12 to 19. Without limiting the applicability of Luno's Terms of Use, Privacy Policy, and General Rewards and Promotions Terms, you agree to be bound by the following terms and conditions when participating in the Program (the "Terms"). You agree to accept any decision made by Luno under these Terms as final and binding.

1. Program Details

Customers who meet the eligibility criteria set out in Section 5 (each, an "Eligible Customer") may obtain cashback rewards (the "Rewards"), as Luno may determine at its sole discretion and in accordance with predetermined reward levels. Any reference to a "transaction" or "transactions" eligible for Rewards under this Program refers exclusively to trades that are successfully executed as "Taker" orders on the Luno Exchange ("Exchange") feature.

In addition to the Rewards described above, the Program includes the Top Volume Awards and the Lucky Draw. The Top Volume Awards are governed by Sections 8 to 11. The Lucky Draw is governed by Sections 12 to 19 and applies only to transactions conducted during the Draw Period defined in Section 12. 

For the avoidance of doubt:

• transactions that provide liquidity to the order book, specifically all "Maker" orders and any trades conducted via the "Instant Buy/Sell" feature, are expressly excluded from this Program and will not qualify for Rewards, Top Volume Awards or Lucky Draw entries; and

• only Taker order transactions involving crypto-to-fiat trading pairs (e.g. BTC/IDR, USDT/IDR) are eligible under this Program. Transactions involving crypto-to-crypto trading pairs (e.g. BTC/USDT, ETH/USDT) are not eligible under this Program, whether or not such trading pairs are available on the Exchange as at the date of these Terms or become available at any point during the Program Period.

  
  

2. Program Period

The Program will run from 15 September 2026 until and including 30 November 2026 (the "Program Period").

The Lucky Draw described in Sections 12 to 19 has the same qualifying window as the Program Period. Only transactions conducted during the Draw Period defined in Section 12 earn Lucky Draw entries. 

Times are determined by the timestamps recorded on Luno's systems.

3. Program Levels and Rewards

For comprehensive details regarding the Reward benefits afforded to participants of the Program, please refer to the summary table presented below. Please note that all cashback amounts are offered up to a defined maximum and subject to the monthly Limit defined below.

All customer levels, accumulated transaction volumes, and earned cashback are subject to a monthly reset at the beginning of each calendar month. “Monthly Taker Transaction Volume” means the total IDR value of an Eligible Customer’s qualifying Taker transactions, as defined in Sections 1, 4 and 6, executed within the relevant Reward Calculation Period defined in Section 7.

In the event that the maximum cashback amount ("Limit") is reached at any point within a calendar month, no further cashback rewards shall accrue or be payable beyond such Limit for the remainder of that month.

4. Program Mechanics: Taker vs. Maker Orders 

This Program exclusively rewards trading activity classified as "Taker" transactions on the Exchange.

• Taker Orders: A Taker order is an order that is executed immediately against an existing order on the order book.

• Maker Orders: A maker order is a limit order that is placed on the order book and is not immediately matched with an existing order.

Only volume generated from Taker Orders will be considered for reward calculation under this Program.

5. Eligibility Criteria

Participation in the Program is limited to Luno customers who meet all of the following criteria (each, an "Eligible Customer"):

5.1. Luno customers who have been verified and are located in Indonesia.

5.2. Customers who comply with all of Luno's Terms of Use.

5.3. Customers who perform qualifying Taker transactions on the Exchange during the Program Period and meet the qualifying threshold for the relevant component: for cashback, the minimum Monthly Taker Transaction Volume in Section 3; for a Top Volume Award, a ranking position under Section 10; and for the Lucky Draw, at least one entry under Section 15.

5.4. Customers who are at least 18 years old and have verified their identity to at least KYC Level 3.

5.5. For the avoidance of doubt, the Monthly Taker Transaction Volume shall only include transactions on crypto-to-fiat trading pairs (e.g. BTC/IDR, USDT/IDR), and shall exclude any transactions on crypto-to-crypto trading pairs (e.g. BTC/USDT, ETH/USDT).

5.6. Transaction volumes cannot be combined across multiple accounts. Where Luno identifies multiple accounts controlled by, or acting in concert with, the same person, Luno may treat those accounts as a single participant or exclude all of them.

5.7. You will be excluded from the Program if you (i) participate using fake or fraudulent details, (ii) fail to maintain an account in good standing, meaning an account not flagged for AML or fraud review, at the time a Reward, Award or prize is calculated or delivered, (iii) are an employee, officer, director, or contractor of Luno, its parent company, or any of its subsidiaries, or (iv) are an immediate family member of a person in category (iii).

5.8. Participation in the Program is limited to individual Luno accounts. Business accounts, corporate accounts, and any account held by or on behalf of a legal entity are not eligible for any Reward, Award or Lucky Draw entry, and volume transacted through such an account is excluded from all calculations under these Terms, including Monthly Taker Transaction Volume under Section 3, Cumulative Taker Transaction Volume under Section 8, and entries under Section 15.

6. Non-Qualifying Transactions

The following transaction types are explicitly excluded from Reward calculation under this Program:

• Maker Orders: Any transaction executed as a maker is ineligible for Rewards.

• Instant Buy/Sell: Transactions made through Luno's "Instant Buy/Sell" feature are not eligible for Rewards.

• Send and Receive: Sending and receiving crypto will not be eligible for Rewards.

• Luno Large Cap Bundle: Transactions executed in the Luno Large Cap Bundle will not be eligible for Rewards.

• Multi-buy and Repeat Buy: Transactions executed through Luno’s Multi-buy or Repeat Buy features will not be eligible for Rewards.

• Self-Trading: Any form of market manipulation, including, but not limited to, self-trading (executing trades with oneself to create a false impression of market activity), is strictly prohibited and will result in immediate disqualification from the Program and potential account suspension.

• Crypto-to-Crypto Trading Pairs: Any transaction on a crypto-to-crypto trading pair (e.g. BTC/USDT, ETH/USDT) is excluded from this Program, regardless of order type, and regardless of whether such pairs are currently available or later enabled on the Exchange.

Transactions that are cancelled, failed, or not completed, and transactions deemed fraudulent, manipulative, or abusive, will not be counted. 

7. Reward Calculation and Distribution

Reward Calculation Period: Rewards will be calculated on a monthly basis, commencing on the first calendar day of the month and concluding on the last calendar day of the month (the "Reward Calculation Period"). By way of example, for Taker transactions in September 2026, your Taker Transaction Volume and Reward will be calculated from 15 September 2026 until and including 30 September 2026.

Reward Metric: Rewards will be calculated based on the total eligible Taker volume transacted by the Customer within the Reward Calculation Period. The Reward tiers and corresponding cashback percentages are set out in Section 3, and may be updated at Luno’s discretion.

Reward Payout: Accrued Rewards for a given month will be distributed within 20 business days following the end of the Reward Calculation Period. The Reward will be sent to the Customer's registered email address with Luno in the form of a Bitcoin promo code. It is the Customer's responsibility to ensure their registered email address on Luno is correct and to redeem the promo code.

First Reward Calculation Period: The Program commences on 15 September 2026. The first Reward Calculation Period therefore runs from 15 September 2026 until and including 30 September 2026.

7A. Announcement of monthly top cashback recipients

Luno may announce the five Eligible Customers who received the highest cashback Rewards in each Reward Calculation Period across Luno Indonesia's social media pages and Telegram channel.

Luno will publish the Customer's name in masked form together with their Luno referral code as an identifier, in the format set out in Section 19, including the Reward amounts.

7B. Public leaderboard

7B.1 Luno may display a leaderboard on the Program landing page or article showing the positions of up to ten Eligible Customers by Cumulative Taker Transaction Volume during the Program Period.

7B.2 Where a Customer appears on the leaderboard, Luno will display that Customer's name in masked form together with their Luno referral code as an identifier, in the format set out in Section 19, and their position and the transaction volume.

7B.3 The leaderboard is indicative only. Positions shown on the leaderboard do not create any entitlement and are not a determination of any Award.

7B.4 A displayed position may change, including after the close of the Program Period, where a transaction is cancelled, refunded, reversed or corrected, or in the case of manifest error. The final determination of Cumulative Taker Transaction Volume and rankings is made under Section 10 and prevails over anything displayed on the leaderboard.

8. Top Volume Awards — Overview

As part of the Program, Luno will award prizes to the five Eligible Customers with the highest cumulative eligible Taker transaction volume across the Program Period (each, an "Award").

"Cumulative Taker Transaction Volume" means the total IDR value of an Eligible Customer's qualifying Taker transactions, as defined in Sections 1, 4 and 6, executed across the whole Program Period. It is not subject to the monthly reset in Section 3.

The Top Volume Awards are additional to, and do not affect, your entitlement to Rewards under Sections 3 and 7. An Eligible Customer may receive one Award only.

You agree to accept any decision made by Luno in respect of the Top Volume Awards as final and binding.

9. Top Volume Awards — Prizes

There are 5 prizes and 5 winners in total, as follows: 

Prize specifications are based on the models available at the time of awarding. Luno is not responsible for changes in product specifications or manufacturer price fluctuations. 

Apple Inc. is not a sponsor of, participant in, or in any way associated with the Program. All product names and trademarks are the property of their respective owners and are used for identification only.

10. Top Volume Awards — Ranking and Ties

At the end of the Program Period, Luno will rank Eligible Customers by Cumulative Taker Transaction Volume in descending order and award prizes in the order set out in Section 9.

Where two or more Eligible Customers have an identical Cumulative Taker Transaction Volume, the higher rank is awarded to the Customer who reached that volume first, determined by Luno's record of execution times.

If a ranked Customer is ineligible or disqualified, the Award passes to the next-ranked Customer.

Luno may void some or all of a Customer's volume for the purposes of this Section where Luno reasonably considers that transactions were entered into without genuine economic purpose and principally to generate volume. The indicators in Section 17 apply.

Luno's calculation of Cumulative Taker Transaction Volume and its determination of rankings are final, save in the case of manifest error.

11. Top Volume Awards — Contacting and Announcing Winners

Award recipients will be contacted directly via email within 10 business days after the Program Period ends. Luno is not liable for any recipient's failure to receive notices due to spam, junk email or other reasons. A recipient must respond within 5 calendar days of that notification, and may be required to complete a release form and provide valid identification and a delivery address in Indonesia before receiving a prize. If a recipient's identity cannot properly be verified, or if a recipient does not respond within that period, the prize will be forfeited and may pass to the next-ranked Customer.

Luno may announce the Top Volume Awards across Luno Indonesia's social media pages and Telegram channel. Luno will publish the recipient's name in masked form together with their Luno referral code as an identifier, in the format set out in Section 19.

12. Lucky Draw — Overview and Draw Period

As part of the Program, Luno will run a prize draw in which Indonesian-resident Luno customers can win prizes (the "Lucky Draw"). Customers who meet the eligibility criteria in Section 14 (the "Participant") will be entered into a single draw to win one of the prizes listed in Section 13. You agree to accept any decision made by Luno in respect of the Lucky Draw as final and binding. 

The Lucky Draw will commence on 15 September 2026 at 00:00 (GMT+7) and run until 30 November 2026 at 23:59 (GMT+7) (the "Draw Period"). Times are determined by the timestamps recorded on Luno's systems.

The Lucky Draw is additional to, and does not affect, your entitlement to Rewards under Sections 3 and 7. 

13. Lucky Draw — Prizes

There are 2 prizes and 2 winners in total, as follows:

• 1st prize: AirPods Pro 3 (1 unit) 

• 2nd prize: AirPods 4 (1 unit)

A Participant may win one prize only.

Prize specifications are based on the models available at the time of awarding. Luno is not responsible for changes in product specifications or manufacturer price fluctuations.

14. Lucky Draw — Eligibility

In addition to the criteria in Section 5, participation in the Lucky Draw is limited to Luno customers who are residents of Indonesia and are at least 18 years old. A Participant must have verified their identity to at least KYC Level 3 and must otherwise be compliant with Luno's Terms of Use. 

You will be excluded from the Lucky Draw if you (i) participate using fake or fraudulent details, (ii) fail to maintain an account in good standing, meaning an account not flagged for AML or fraud review, at the time of the draw, (iii) are an employee, officer, director, or contractor of Luno, its parent company, or any of its subsidiaries, or (iv) are an immediate family member of a person in category (iii).

Customers who receive a Top Volume Award under Sections 8 to 11 are not eligible for a Lucky Draw prize.

15. Lucky Draw — Entries

Entries are counted automatically. To participate:

• Qualifying Trades: Execute Taker orders on crypto-to-fiat trading pairs on the Exchange during the Draw Period (a "Qualifying Trade").

• Entry Calculation: The value of all Qualifying Trades made during the Draw Period is accumulated, and each full IDR 5,000,000 of that accumulated total equals 1 entry. The value of each Qualifying Trade is added to the accumulated total regardless of whether it is a buy or a sell.

• Carry Forward: There is no minimum value for an individual Qualifying Trade. Values accumulate across transactions throughout the Draw Period and need not be made on the same day. For example, an IDR 3,000,000 Taker buy followed by an IDR 2,000,000 Taker sell on a later date reaches IDR 5,000,000 in total and earns 1 entry.

• Residual Amounts: Any part of the accumulated total that does not complete a further full IDR 5,000,000 at the close of the Draw Period earns no entry and does not carry forward beyond the Draw Period.

• Hard Cap: Each Participant is limited to a maximum of 1,000 entries in total for the entire Draw Period, reached at an accumulated total of IDR 5,000,000,000. Qualifying Trades made after reaching this limit will not result in additional entries, and will otherwise be processed as normal, including for the purposes of Rewards under Section 3 and Awards under Section 8.

• Reversals or Cancellations: Where a transaction is later cancelled, refunded, or reversed, its value will be removed from the accumulated total, which may reduce a Participant's entry count, including where this occurs after the draw.

  
  

16. Lucky Draw — Non-Qualifying Transactions

In addition to the transactions listed in Section 6, the following will not earn Lucky Draw entries:

• Maker orders on the Exchange, notwithstanding that no such transaction counts toward Rewards under Section 3 either;

• Transactions on crypto-to-crypto trading pairs, whether as Maker or Taker;

• Transactions made through Luno's Instant Buy or Instant Sell features;

• Deposits, top-ups, and withdrawals;

• Sending or receiving crypto assets to or from another wallet; and

• Crypto asset balances already held before the Draw Period.

  
  

17. Lucky Draw — Selecting winners

Participants will automatically be entered into the draw. Winners will be selected randomly via an online randomiser platform after the conclusion of the Draw Period, in the prize order set out in Section 13. 

• If a Participant is drawn more than once, they will receive the prize of the highest value and a redraw will occur for the remaining prize.

• If a drawn Participant is ineligible or disqualified, a redraw will occur.

• Participants whose accounts are not in good standing, or who are suspected of gaming behaviour including wash trading, API manipulation, or the use of automated scripts, will be disqualified, and the determination of such shall be at Luno's sole discretion.

Without limiting the above, Luno may void some or all of a Participant's entries where Luno reasonably considers that Qualifying Trades were entered into without genuine economic purpose and principally to generate entries. Indicators include repeated buying and selling of the same or substantially similar assets within a short period with no material change in the Participant's net position, sequences of transactions in round amounts at or around IDR 5,000,000 that produce no corresponding change in portfolio composition, matching of a Participant's own orders on the order book, and coordinated activity across two or more accounts. 

The draw will be held after the end of the Program Period.

18. Lucky Draw — Contacting winners

Winners will be contacted directly via email within 10 business days after the Draw Period ends. Luno is not liable for any winner's failure to receive notices due to spam, junk email or other reasons. A winner must respond within 5 calendar days of that notification, and may be required to complete a release form and provide valid identification and a delivery address in Indonesia before receiving a prize. If a winner's identity cannot properly be verified, or if a winner does not respond within that period, the prize will be forfeited. 

Luno will never ask for your password, one-time passcode, private key, seed phrase, or any payment as a condition of releasing a prize.

19. Lucky Draw — Announcing winners  

Winners may be announced across Luno Indonesia's social media pages and Telegram channel, and by email to Participants, but Luno is not obliged to announce winners on any particular channel.

If you are selected as a winner, you agree to Luno publishing your name in masked form, together with your Luno referral code as an identifier, on those channels. Names are masked by showing the first and last character of each part of your name and replacing the characters in between with asterisks. A winner named John Doe would be announced as "J**n D*e - ABC123". The identifier is published so that Participants can confirm that an announcement is genuine.

Announcements will only be made through Luno Indonesia's official channels. Luno will never request a password, one-time passcode, private key, seed phrase, or payment in connection with a prize, as set out in Section 18.

20. Awarding the prizes 

Prizes will be delivered to the winner's address in Indonesia via a third-party logistics provider within 60 business days of Luno receiving a confirmed delivery address, at no delivery cost to the winner. Luno does not deliver outside Indonesia. Prizes cannot be transferred, sold or ceded to someone else and cannot be exchanged for cash or crypto assets. Any product warranty is subject to the manufacturer's terms.

A recipient's account must satisfy Section 5 at the time of delivery. If it does not, the prize is forfeited.

21. Subject to change

Luno reserves the right to hold, void, cancel, suspend, adjust, or amend the Program or its Terms at any time.

22. Personal Risk 

To the extent permitted by law, Luno does not accept any responsibility for any damage, loss, liabilities, injury, costs, expenses or claims (whether in contract, tort or otherwise) suffered by the participants of the Program or any third parties arising out of or in connection with participating in the Program or accepting the Rewards.

23. Personal Data

Any personal information provided to Luno for the purposes of the Program will be handled strictly in accordance with the Luno Privacy Policy.

24. Governing Law

These Terms are governed by and interpreted in accordance with the laws of Indonesia, and any disputes arising from the Program will be subject to the exclusive jurisdiction of the courts of Indonesia.