1. Overview

1.1 PT Luno Indonesia Ltd ("Luno") offers a tiered loyalty programme for eligible Luno customers in Indonesia ("Luno Priority" or the "Programme").

1.2 The Programme comprises:

(a) tiered membership status, as described in Sections 5 and 6;

(b) a Monthly Tier Bonus, as described in Section 8;

(c) Cashback, as described in Section 9; and

(d) service and access Benefits, as described in Sections 10 to 12.

1.3 Without limiting the applicability of Luno's Terms of Use, Privacy Policy, and the General Rewards and Promotions Terms, you agree to be bound by these terms and conditions when participating in the Programme (the "Rules"). You agree to accept any decision made by Luno under these Rules as final and binding, save in the case of manifest error.

2. Definitions

2.1 For the purposes of these Rules:

"Benefits" means any rewards, services, privileges, incentives, cashback, promotional offers, or other features made available under the Programme, whether monetary or non-monetary.

"Business Day" means a day other than a Saturday, Sunday or public holiday in Indonesia, on which commercial banks are open for general business in Indonesia.

"Bundle" means Luno's bundled crypto asset products, including the Luno Large Cap Bundle and any similar product made available from time to time.

"Cashback" means the monetary Benefit described in Section 9.

"Customer" means the holder of a Luno account, whether a natural person or a legal entity, and "you" is construed accordingly.

"Eligible Customer" means a Customer who satisfies every criterion in Section 4 at the relevant time.

"Eligible Transaction Volume" means, in respect of a Qualifying Month, the aggregate IDR value of an Eligible Customer's Qualifying Transactions executed and completed during that Qualifying Month, as recorded in Luno's systems, calculated so that the value of each Qualifying Transaction is added to the aggregate regardless of whether it is a buy or a sell.

"Group" means, in relation to a legal entity, that entity together with any other entity that controls it, is controlled by it, or is under common control with it.

"Instant Buy/Sell" means Luno's Instant Buy and Instant Sell features, including the Multi-buy, Repeat Buy and Bundle features.

"Luno Platform" means the Luno website, mobile applications and any other interface through which Luno makes its services available to customers in Indonesia.

"Monthly Tier Bonus" or "Bonus" means the monetary Benefit described in Section 8.

"OTC" means any transaction executed through Luno's over-the-counter desk, or by negotiated, brokered or otherwise off-order-book arrangement, whether or not settled on the Luno Platform.

"Participant" means an Eligible Customer who is taking part in the Programme at the relevant time. An Eligible Customer whose participation has been suspended or terminated under Section 22, or who has left the Programme under Section 22.3, is not a Participant.

"Promo Code" means a Bitcoin promotional code issued by Luno in satisfaction of a monetary Benefit under Section 16.

"Qualifying Month" means a calendar month in respect of which Eligible Transaction Volume is assessed under Section 6.

"Qualifying Transaction" means a completed buy or sell of a Supported Crypto Asset executed by an Eligible Customer through Instant Buy/Sell on the Luno Platform, including a purchase or disposal executed through the Multi-buy, Repeat Buy or Bundle features, and excludes every transaction described in Section 13.

"Relationship Manager" or "RM" means a Luno employee or authorised contractor allocated to an Eligible Customer under Section 11.

"Status Benefits" means the Benefits described in Sections 10, 11 and 12.

"Supported Crypto Asset" means a crypto asset that Luno makes available for buying and selling on the Luno Platform in Indonesia from time to time.

"Tier" means a membership tier of the Programme as set out in Section 5.

2.2 Headings are for convenience only and do not affect interpretation. References to a Section are to a section of these Rules. "Including" and "for example" are not words of limitation. References to IDR are to Indonesian Rupiah.

3. Programme Period

3.1 The Programme is ongoing and has no fixed end date. It operates on a calendar-month cycle.

3.2 The Programme is subject to suspension, modification and termination in accordance with Section 23. Termination of the Programme does not create any entitlement to compensation.

3.3 All times are determined by the timestamps recorded on Luno's systems, in GMT+7.

4. Eligibility criteria

4.1 General. Participation in the Programme is limited to Customers who meet all of the following criteria at all relevant times:

(a) the Customer holds either:

(i) an individual Luno account, where the account holder is a natural person aged at least 18 years who has verified their identity to at least KYC Level 3; or

(ii) a business or corporate Luno account, where the account holder is a legal entity established and registered in Indonesia that has satisfied Luno's business verification (KYB) requirements in full;

(b) the Customer is verified and located in Indonesia;

(c) the account is active and in good standing, meaning an account not suspended, restricted, dormant, or flagged for AML, sanctions or fraud review;

(d) the Customer complies with Luno's Terms of Use and all applicable laws; and

(e) the Customer achieves the Eligible Transaction Volume required for a Tier under Section 5.

4.2 Business and corporate accounts — additional requirements. In addition to Section 4.1, where the Customer is a legal entity:

(a) each individual who accepts these Rules or operates the account must be duly authorised to do so on behalf of the entity, and Luno may require evidence of that authority at any time;

(b) the entity must have disclosed its ultimate beneficial owners to Luno and must notify Luno promptly of any change;

(c) the entity must hold a valid tax identification number (NPWP);

(d) the entity must nominate a single email address registered with Luno for Programme communications and for delivery of Benefits under Section 16, and is responsible for keeping that address current and for controlling access to it; and

(e) any Benefit issued in respect of the account is the property of the entity and not of any individual who operates the account. Luno is not responsible for any dispute between an entity and any individual as to entitlement to a Benefit.

4.3 One account per Customer. Eligible Transaction Volume cannot be combined or aggregated across multiple accounts in order to reach a Tier threshold. A legal entity may hold only one Luno account for the purposes of the Programme. Where an entity holds more than one account, Luno may nominate a single account for Programme purposes or exclude the additional accounts.

4.4 Business and corporate accounts within the same Group.

(a) Each business or corporate account is assessed independently on its own Eligible Transaction Volume, may qualify for its own Tier, and may receive its own Benefits. Eligible Transaction Volume is not aggregated across entities within the same Group, and Section 20 does not apply to entities within the same Group solely by reason of common ownership or control.

(b) Section 4.4(a) does not limit Sections 19 and 20. Where Luno reasonably considers that accounts were opened, or entities established or used, principally to multiply Benefits rather than for a genuine commercial purpose, Luno may aggregate those accounts and treat them as a single participant, or exclude them from the Programme.

4.5 Excluded persons. A Customer is excluded from the Programme if they:

(i) participate using fake or fraudulent details;

(ii) fail to maintain an account in good standing at the time a Benefit is calculated, issued or delivered;

(iii) are an employee, officer, director, or contractor of Luno, its parent company, or any of its subsidiaries;

(iv) are an immediate family member of a person in category (iii); or

(v) are a legal entity that is a member of Luno's Group, or that is controlled by, or of which a director, officer or ultimate beneficial owner is, a person in category (iii) or (iv).

4.6 Eligibility is assessed continuously. A Customer who ceases to satisfy any criterion in this Section 4 ceases to be an Eligible Customer with immediate effect, and Section 22 applies.

5. Programme Tiers

5.1 The Programme consists of the following Tiers. A Customer's Tier is determined by their Eligible Transaction Volume in a Qualifying Month, assessed in accordance with Section 6.

5.2 Gold, Platinum and Diamond members additionally receive the Status Benefits described in Sections 10 to 12.

5.3 A Customer qualifies for the highest Tier whose minimum threshold their Eligible Transaction Volume meets or exceeds. A Customer is entitled to the Benefits of one Tier only in respect of any Qualifying Month. Benefits of different Tiers do not combine.

5.4 Luno may introduce additional Tiers, revise qualification thresholds, revise Cashback rates or caps, revise Bonus amounts, modify Benefits, or discontinue any Tier, in accordance with Section 27.

6. Tier assessment, effect, upgrade and downgrade

6.1 Assessment. Tier qualification is assessed after the end of each calendar month, based on the Eligible Transaction Volume achieved during that month (the Qualifying Month).

6.2 Monetary Benefits are earned in the Qualifying Month and paid the following month. The Monthly Tier Bonus and Cashback payable in respect of a Qualifying Month are calculated by reference to the Eligible Transaction Volume achieved in that same Qualifying Month, at the rate and amount applicable to the Tier achieved in that Qualifying Month, and are issued in the following calendar month in accordance with Section 16. By way of example, Cashback earned on Eligible Transaction Volume in July is calculated on July volume at the Tier achieved in July, and is issued in August.

6.3 Status Benefits apply prospectively. The Status Benefits corresponding to the Tier achieved in a Qualifying Month take effect on the first Business Day of the following calendar month and continue until the next assessment takes effect, unless earlier suspended or withdrawn under these Rules.

6.4 No carry-forward. Eligible Transaction Volume resets at the beginning of each calendar month. Volume does not accumulate, carry forward, or roll over between months. Unused Cashback capacity does not carry forward.

6.5 Upgrades. An Eligible Customer who achieves a higher Tier threshold in a Qualifying Month moves to that Tier for the purposes of Sections 6.2 and 6.3. Upgrades are not applied intra-month.

6.6 Downgrades and removal. If an Eligible Customer's Eligible Transaction Volume in a Qualifying Month falls below the threshold for their current Tier, they move to the Tier corresponding to the volume actually achieved, which may be Standard. A downgrade may be by more than one Tier. Luno may remove a Customer from the Programme where they no longer satisfy Section 4.

6.7 New and reinstated Customers. A Customer who becomes an Eligible Customer part-way through a calendar month is assessed on their Eligible Transaction Volume for the remainder of that month. Thresholds are not pro-rated.

6.8 Account closure or suspension. If an Eligible Customer's account is closed, suspended or restricted, their Tier lapses immediately and any Benefit not yet issued is subject to Section 22.

7. Benefits — general

7.1 Depending on the applicable Tier, Eligible Customers may receive one or more of: the Monthly Tier Bonus; Cashback; Priority Dashboard access; Priority Relationship Manager services; exclusive campaigns and promotional offers; early access to selected products or features; and any other Benefit designated by Luno from time to time.

7.2 Benefits are personal to the Eligible Customer and are non-transferable. They cannot be sold, assigned, ceded, pooled, gifted or exchanged, and a Promo Code may only be redeemed into the Luno account of the Eligible Customer to whom it was issued.

7.3 Other than the Monthly Tier Bonus and Cashback, which are issued in the form set out in Section 16, Benefits have no cash value and cannot be exchanged for cash or crypto assets.

7.4 Benefits are provided on an "as available" basis. Luno may vary, suspend or withdraw any Status Benefit in accordance with Section 27.

7.5 No Benefit constitutes financial, investment, tax or legal advice, or a recommendation to acquire, hold or dispose of any crypto asset. Section 25 applies.

8. Monthly Tier Bonus

8.1 An Eligible Customer who achieves Gold, Platinum or Diamond in a Qualifying Month is entitled to the Monthly Tier Bonus for that Tier, as set out in Section 5.1, in respect of that Qualifying Month.

8.2 One Monthly Tier Bonus only is payable per Eligible Customer per Qualifying Month.

8.3 The Bonus will be issued in accordance with Section 16, provided that:

(a) the Eligible Customer remains an Eligible Customer at the time of issue;

(b) the relevant Tier qualification has been verified by Luno;

(c) the account remains active and in good standing; and

(d) issue is not prohibited by applicable law or regulatory requirement.

8.4 Luno may withhold, adjust, reverse or recover any Bonus where eligibility was determined by reference to transactions that are subsequently cancelled, reversed, refunded, disputed, or reasonably suspected to be fraudulent, manipulative or abusive. Section 16.8 applies.

9. Cashback

9.1 Where Cashback is available under a Tier:

(a) Cashback is calculated on the Eligible Customer's Eligible Transaction Volume for the Qualifying Month, at the rate specified for the Tier achieved in that Qualifying Month;

(b) where a maximum monthly Cashback amount is specified for the Tier in Section 5.1, Cashback is subject to that maximum, and where the maximum is reached at any point within a Qualifying Month, no further Cashback accrues or is payable for the remainder of that month. Where no maximum is specified for a Tier, no maximum applies;

(c) Cashback is issued in accordance with Section 16;

(d) Cashback is calculated on the IDR value of Qualifying Transactions as recorded in Luno's systems and excludes transaction fees, spreads, taxes and any transaction category designated as non-qualifying under Section 13; and

(e) Cashback is rounded down to the nearest IDR 1 before conversion under Section 16.4.

9.2 Luno may withhold, adjust, reverse or recover Cashback where:

(a) transactions are cancelled, reversed or refunded, including after issue;

(b) fraud, manipulation or abuse is detected or reasonably suspected;

(c) an operational, technical or calculation error occurs;

(d) the Eligible Customer ceases to be an Eligible Customer before issue; or

(e) issue would breach applicable law or a regulatory requirement.

10. Priority Dashboard

10.1 Gold, Platinum and Diamond members are granted access to the Priority Dashboard, a view within the Luno Platform showing Tier status, Eligible Transaction Volume, Benefit history and related information.

10.2 Information displayed on the Priority Dashboard is indicative only and is provided for convenience. It does not create any entitlement and is not a determination of any Tier or Benefit.

10.3 A displayed figure may change, including after the end of a Qualifying Month, where a transaction is cancelled, refunded, reversed or corrected, or in the case of manifest error. Luno's final determination under Section 15 prevails over anything displayed on the Priority Dashboard.

10.4 Luno may vary the content, functionality or availability of the Priority Dashboard at any time.

11. Priority Relationship Manager service

11.1 Gold, Platinum and Diamond members may be allocated a Relationship Manager as a dedicated service contact point for account, product and service matters. Where the Eligible Customer is a legal entity, the RM deals only with individuals authorised under Section 4.2(a).

11.2 Scope and limits. The RM service is a customer service Benefit. The RM:

(a) does not provide financial, investment, tax, accounting or legal advice, and nothing an RM says constitutes a recommendation to acquire, hold or dispose of any crypto;

(b) will not execute transactions on your behalf, accept trading instructions, or manage your account or assets;

(c) cannot vary these Rules, waive any Luno policy, guarantee any Tier, Benefit or outcome, or override any compliance, risk or fraud control;

(d) cannot provide preferential treatment in respect of any regulatory, AML, sanctions or fraud process; and

(e) is not available on a guaranteed-response basis unless Luno separately publishes a service level for the Programme.

11.3 Security. An RM will never ask you for your password, one-time passcode, PIN, private key, seed phrase, recovery details, or any payment. An RM will only contact you through Luno's official communication channels associated with your account. If you receive a communication purporting to be from a Luno RM that departs from this Section, do not respond and report it to Luno immediately.

11.4 Luno may allocate, reallocate, change or withdraw an RM at any time, and may suspend the RM service where a Customer or its representative engages in abusive, threatening or harassing conduct toward Luno personnel.

12. Exclusive campaigns, early access and other Benefits

12.1 Luno may from time to time make exclusive campaigns and promotional offers available to some or all Tiers. Each such campaign is governed by its own terms and conditions, which prevail over these Rules in respect of that campaign to the extent expressly stated.

12.2 Early access to selected products or features is provided on an "as is" and "as available" basis. Such products or features may be incomplete, may contain errors, may change, and may be withdrawn without notice. No warranty of any kind is given in respect of them.

12.3 Participation in a campaign or early access programme is optional, and eligibility for it does not create an entitlement to any future campaign or early access.

13. Non-qualifying transactions

13.1 The following are excluded from Eligible Transaction Volume and do not count toward any Tier, Bonus or Cashback:

(a) transactions executed on the Luno Exchange, whether as maker or taker;

(b) OTC transactions;

(c) transactions on crypto-to-crypto trading pairs, regardless of the feature used and regardless of whether such pairs are currently available through Instant Buy/Sell or are later enabled;

(d) cancelled, failed, incomplete, expired or rejected transactions;

(e) reversed, refunded or charged-back transactions;

(f) deposits, top-ups and withdrawals of fiat currency;

(g) sending or receiving crypto assets to or from another wallet, including transfers between Luno accounts;

(h) crypto asset balances already held;

(i) promotional credits, bonus amounts, rewards, airdrops and any value received under this or any other Luno promotion, and the redemption of any Promo Code;

(j) self-trading and any other form of market manipulation;

(k) transactions that Luno reasonably determines are abusive, fraudulent, manipulative, or undertaken without genuine economic purpose and principally to qualify for or increase Benefits; and

(l) any transaction category designated by Luno as ineligible from time to time, effective on publication.

13.2 Bundles. Purchases and disposals of a Bundle executed by the Eligible Customer through Instant Buy/Sell are Qualifying Transactions. Any rebalancing, reconstitution or internal reallocation of assets within a Bundle that is carried out automatically rather than on the Eligible Customer's instruction is not a Qualifying Transaction and is excluded from Eligible Transaction Volume.

14. Interaction with other Luno promotions

14.1 Participation in the Programme does not prevent participation in any other Luno promotion.

14.2 Stacking is permitted. The same Qualifying Transaction may count toward Benefits under this Programme and toward rewards under another Luno promotion, and a Customer may receive both, unless the terms of that other promotion expressly state otherwise.

14.3 Where the terms of another Luno promotion expressly exclude stacking with this Programme, those terms prevail in respect of that promotion.

15. Calculation, valuation and records

15.1 All calculations under these Rules are made by reference to Luno's own systems and records, which are determinative save in the case of manifest error.

15.2 The IDR value of a Qualifying Transaction is the IDR consideration recorded by Luno at the time the transaction is executed.

15.3 Timestamps recorded on Luno's systems (GMT+7) determine the calendar month in which a transaction falls.

15.4 Luno's calculation of Eligible Transaction Volume, its determination of Tier, and its calculation of any Benefit are final, save in the case of manifest error.

15.5 Luno may recalculate and correct any Tier or Benefit at any time where a transaction is cancelled, refunded, reversed or corrected, or where an error is identified, including after a Benefit has been issued.

16. Issue of Benefits, withholding, recovery and set-off

16.1 Form and timing. The Monthly Tier Bonus and Cashback will be distributed in the form of a Bitcoin Promo Code, sent to the Eligible Customer's email address registered with Luno, within twenty (20) Business Days following the end of the Qualifying Month.

16.2 Where the Eligible Customer is a legal entity, the Promo Code will be sent to the email address nominated under Section 4.2(d) and may be redeemed only into that entity's Luno account.

16.3 It is the Customer's responsibility to ensure that the email address registered with Luno is correct and current, and to redeem the Promo Code. Luno is not liable for any failure to receive a Promo Code due to spam filtering, junk email, an incorrect or out-of-date email address, or any other cause not attributable to Luno.

16.4 Conversion. The Benefit is calculated in IDR under Sections 8 and 9 and converted to Bitcoin at the Luno rate prevailing at the time the Promo Code is generated. The value of Bitcoin may rise or fall after that time, and Luno is not responsible for any such change.

16.5 Redemption and expiry. The period within which a Promo Code must be redeemed will be stated in the email by which it is issued. An unredeemed Promo Code expires at the end of that period and the Benefit is forfeited. The Eligible Customer's account must satisfy Section 4 at the time of redemption.

16.6 Luno is not obliged to issue any Benefit where doing so would breach applicable law, a regulatory requirement, a sanctions obligation, or a direction from a competent authority.

16.7 Luno may withhold issue of any Benefit pending completion of a fraud, AML, sanctions, security or compliance review, without prior notice where notice would prejudice that review.

16.8 Recovery and set-off. Where a Benefit has been issued in error, or where it is subsequently determined that the Eligible Customer was not entitled to it, Luno may (a) cancel an unredeemed Promo Code, (b) reverse or debit the equivalent amount from the Customer's Luno account, (c) deduct it from any future Benefit, or (d) recover it as a debt due from the Customer. Luno may exercise these rights without prior notice where necessary to prevent further loss, and will notify the Customer promptly afterwards.

17. Queries and claims

17.1 If you believe a Tier has been incorrectly assessed or a Benefit has not been issued correctly, you must notify Luno through an official support channel within thirty (30) calendar days of the date on which the Benefit was due to be issued.

17.2 Luno will investigate and respond within a reasonable period. Claims notified after the period in Section 17.1 may not be considered, except where applicable law requires otherwise or where the delay was not reasonably avoidable.

17.3 This Section does not limit any right you have under Indonesian consumer protection law.

18. Customer obligations

18.1 Participants must:

(a) maintain accurate and current account information, including the registered email address;

(b) comply with applicable laws;

(c) comply with Luno's Terms of Use and these Rules;

(d) complete any verification requested by Luno, including business verification and beneficial ownership verification for entity accounts;

(e) cooperate with any fraud, security, AML, sanctions or compliance investigation;

(f) not share, sell or transfer access to their account, any Promo Code or any Benefit; and

(g) report promptly any suspected impersonation of Luno or of an RM.

19. Fraud, abuse and misuse

19.1 Luno may suspend, cancel, withhold, reverse or deny any Benefit, and may remove a Customer from the Programme, if it reasonably believes the Customer has:

(a) engaged in wash trading or self-trading;

(b) manipulated trading activity or market prices;

(c) created or controlled multiple accounts in breach of these Rules;

(d) used automated scripts, bots or unauthorised API access to generate Eligible Transaction Volume, other than through Luno's own Repeat Buy, Multi-buy or Bundle features used in the ordinary course;

(e) engaged in fraudulent, deceptive or abusive conduct;

(f) attempted to artificially increase Eligible Transaction Volume;

(g) breached these Rules or Luno's Terms of Use; or

(h) otherwise attempted to obtain any Benefit improperly.

19.2 No genuine economic purpose. Without limiting Section 19.1, Luno may void some or all of a Customer's Eligible Transaction Volume where Luno reasonably considers that transactions were entered into without genuine economic purpose and principally to qualify for or increase Benefits. Indicators include repeated buying and selling of the same or substantially similar assets within a short period with no material change in the Customer's net position; sequences of transactions in round amounts at or around a Tier threshold that produce no corresponding change in portfolio composition; buying and selling patterns timed around month-end to reach a threshold; the configuration of Repeat Buy or Multi-buy instructions in a pattern that generates volume without a corresponding change in net position; and coordinated activity across two or more accounts.

19.3 Luno's determination under this Section is made in good faith on the basis of available information and is final, save in the case of manifest error.

19.4 Nothing in this Section limits any other right or remedy available to Luno, including account suspension or closure under the Terms of Use and any reporting obligation to a competent authority.

20. Multiple accounts and accounts acting in concert

20.1 Where Luno identifies multiple accounts controlled by, or acting in concert with, the same person, Luno may treat those accounts as a single participant, exclude all of them from the Programme, or void volume and Benefits attributable to any of them.

20.2 Indicators of accounts acting in concert include shared device or network identifiers, shared funding sources, shared beneficial ownership, common signatories or authorised representatives, and correlated transaction patterns.

20.3 This Section applies to business and corporate accounts subject to Section 4.4.

21. Compliance and regulatory requirements

21.1 Participation in the Programme remains subject to all applicable laws and regulations, including those relating to sanctions, anti-money laundering and counter-terrorism financing.

21.2 Luno may suspend, modify or terminate any Benefit, or a Customer's participation, where necessary to comply with applicable law, regulatory guidance, or a direction from a competent authority.

21.3 Luno may require a Customer to provide additional information or documentation as a condition of continued participation or of receiving any Benefit.

22. Suspension and removal of individual participation

22.1 Luno may suspend or terminate a Customer's participation in the Programme, with immediate effect and without prior notice where necessary, where:

(a) the Customer ceases to be an Eligible Customer;

(b) Section 19, 20 or 21 applies;

(c) the Customer's Luno account is suspended, restricted or closed for any reason; or

(d) continued participation would expose Luno to legal, regulatory or reputational risk.

22.2 On suspension or termination of participation, all Status Benefits cease immediately, any unredeemed Promo Code may be cancelled, and any Benefit not yet issued is forfeited unless Luno determines otherwise. Sections 16.8, 19, 24, 26, and 32 survive.

22.3 A Customer may leave the Programme at any time by notifying Luno through an official support channel. Leaving does not entitle the Customer to any Benefit not yet earned and issued.

23. Suspension, modification and termination of the Programme

23.1 Luno may suspend, modify or discontinue the Programme, in whole or in part, where reasonably necessary for operational reasons, security, fraud prevention, system maintenance, legal or regulatory compliance, or commercial reasons.

23.2 Section 27 applies to changes to the Programme and to these Rules.

23.3 Termination or modification of the Programme does not create any entitlement to compensation.

23.4 On termination of the Programme, Benefits earned in respect of a completed Qualifying Month and not yet issued will be issued in the ordinary course, subject to these Rules.

24. Taxes

24.1 Customers are solely responsible for determining and paying any taxes arising from participation in the Programme or receipt of any Benefit, except to the extent that applicable law requires Luno to withhold, deduct or report.

24.2 Where Luno is required to withhold or deduct, the Benefit will be issued net of that withholding or deduction, and Luno will report as required.

24.3 Luno may require a Customer to provide a tax identification number (NPWP) or, in the case of an individual, a population identification number (NIK), before issuing a Benefit.

24.4 Nothing communicated by Luno, including by an RM, constitutes tax advice. Customers should obtain independent tax advice.

25. Risk warning and no advice

25.1 Trading and investing in crypto assets is a high-risk activity. The value of crypto assets can rise and fall significantly in a short period and you may lose part or all of the value of your investment.

25.2 The Programme is a customer loyalty programme. It does not constitute financial or investment advice, or a recommendation to buy, hold or sell any crypto, or to transact at any particular volume.

25.3 Tier thresholds are not targets. Any decision to transact should be based on your own circumstances, objectives and risk tolerance, and not on a desire to reach a Tier threshold or to obtain a Benefit.

25.4 Luno does not encourage the purchase of crypto using debt or borrowed funds of any kind.

25.5 Benefits are issued in Bitcoin. The value of a Benefit in IDR terms may fall after it is issued. Section 16.4 applies.

26. Limitation of liability

26.1 To the maximum extent permitted by applicable law, Luno is not liable for any indirect, incidental, consequential, exemplary, punitive or special damages, or for any loss of profit, revenue, opportunity, data or goodwill, arising out of or in connection with the Programme.

26.2 To the maximum extent permitted by applicable law, Luno is not liable for any loss arising from: the unavailability, delay, error or malfunction of the Luno Platform or the Priority Dashboard; a delay in issuing or a failure to issue a Benefit where Section 16.6, 16.7 or 21 applies; the non-receipt, non-redemption or expiry of a Promo Code; any act or omission of a third party; or any change in the value of a crypto asset.

26.3 Nothing in these Rules excludes or limits liability where such exclusion or limitation is prohibited by applicable law, including any liability that cannot be excluded under Indonesian consumer protection law.

27. Changes to the Programme and these Rules

27.1 Luno may at any time amend these Rules, and may introduce, vary, suspend, withdraw or discontinue the Programme, any Tier, any Benefit, any qualification threshold, any Cashback rate or maximum, and any Monthly Tier Bonus amount.

27.2 A change takes effect on publication on the Luno Platform or through another official communication channel, unless Luno states a later effective date.

27.3 Luno will act in good faith in exercising its rights under this Section, and may inform Eligible Customers of a change through the channels described in Section 28. Luno is not obliged to give prior notice of any change.

27.4 Continued participation after the effective date constitutes acceptance of the change. A Customer who does not accept a change may leave the Programme under Section 22.3.

27.5 Notwithstanding Section 27.2, a change that reduces a Cashback rate or maximum, reduces a Monthly Tier Bonus, or increases a qualification threshold does not apply to a Qualifying Month that has already begun, and takes effect from the first day of the following calendar month. A Benefit already earned in respect of a completed Qualifying Month is not affected by a subsequent change.

28. Communications

28.1 Luno may communicate Programme-related information through the Luno Platform, email, SMS, WhatsApp, push notification, in-app message, or any other official communication channel associated with the account.

28.2 It is the Customer's responsibility to keep their contact details current and to monitor those channels. Because Benefits are delivered by email under Section 16, an out-of-date registered email address may result in a Benefit being forfeited under Section 16.5.

28.3 Luno will only communicate through its official channels. Luno will never request your password, one-time passcode, PIN, private key, seed phrase, or any payment in connection with the Programme.

29. Personal data

29.1 Any personal information provided to or generated by Luno for the purposes of the Programme will be handled strictly in accordance with the Luno Privacy Policy and applicable Indonesian data protection law.

29.2 Participation involves the processing of personal data for the purposes of: assessing Tier eligibility; calculating and issuing Benefits; allocating and operating the RM service; fraud, AML, sanctions and compliance monitoring; and regulatory reporting.

29.3 Where the Customer is a legal entity, this includes the personal data of its authorised representatives, signatories and ultimate beneficial owners. The entity is responsible for ensuring it has a lawful basis to provide that data to Luno and for informing those individuals accordingly.

29.4 Where an RM is allocated, that RM will have access to account information to the extent necessary to provide the service.

30. General

30.1 Severability. If any provision of these Rules is held invalid or unenforceable, the remaining provisions continue in full force.

30.2 No waiver. A failure or delay by Luno in exercising a right under these Rules is not a waiver of that right.

30.3 Assignment. Luno may assign or transfer its rights and obligations under these Rules to any member of its Group or to a successor. A Customer may not assign or transfer any right under these Rules.

30.4 No third-party rights. These Rules do not confer any right on a person who is not a party to them.

30.5 Force majeure. Luno is not liable for any failure or delay in performing its obligations under these Rules caused by an event beyond its reasonable control.

30.6 No partnership or advisory relationship. Nothing in these Rules creates a partnership, joint venture, agency, fiduciary or advisory relationship between Luno and any Customer.

31. Language

These Rules are made available in Bahasa Indonesia and in English. In the event of any inconsistency between the two versions, the Bahasa Indonesia version prevails.

32. Governing law and dispute resolution

32.1 These Rules are governed by and interpreted in accordance with the laws of Indonesia.

32.2 Any dispute arising from or in connection with the Programme is subject to the exclusive jurisdiction of the courts of Indonesia.