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Newton Survey Promotion (the “Promotion”)

Official Rules and Regulations

This Promotion is sponsored by Newton Crypto Ltd. (“Newton”)

PROMOTION RULES

NO PURCHASE IS NECESSARY:   THE PROMOTION IS INTENDED TO BE CONDUCTED ONLY IN CANADA (EXCLUDING QUEBEC) AND SHALL BE CONSTRUED AND EVALUATED ACCORDING TO APPLICABLE CANADIAN LAW. VOID IN WHOLE OR IN PART WHERE PROHIBITED BY LAW. ENTRY IN THE PROMOTION CONSTITUTES ACCEPTANCE OF THESE PROMOTION RULES (THE “PROMOTION RULES”).

PROMOTION PERIOD: The promotion period will begin at 12:01 am Eastern Time (“ET”) on Wednesday, June 11th, 2025, and will end at 11:59 pm ET on Wednesday, June 25th, 2024 (the “Promotion Period”), after which time the Promotion will be closed and no further entries shall be accepted.

ELIGIBILITY: To enter and be eligible to win, the entrant must:

• be an existing registered Newton platform user at the time of entry and/or at the time the Prize is awarded; 
• be a resident of Canada (excluding Quebec);
• be the age of majority, or older, in your province/territory of residence at the time of entry;
• be the original recipient of the invitation e-mail containing the link to the Promotion survey; and
• have meet the entry requirements set out below (each an “Entrant”).

Employees, officers and directors of Newton and its partners and associate companies, and each of their advertising and promotional agencies and their respective affiliates and associates, and such individuals’ immediate family members and persons with whom such individuals are domiciled, are not eligible to enter or participate in the Promotion. For the purposes of the Promotion Rules, “immediate family” refers to the father, mother, brothers, sisters, children, husband, wife or partner of such an employee, agent and/or representative.

Newton shall have the right at any time to require proof of identity and/or eligibility to participate in the Promotion. Failure to provide such proof may result in disqualification. All personal and other information requested by and supplied to Newton for the purpose of the Promotion must be truthful, complete, accurate and in no way misleading. Newton reserves the right, in its sole discretion, to disqualify the Entrant, should the Entrant at any stage supply untruthful, incomplete, inaccurate or misleading personal details and/or information.

HOW TO ENTER: No purchase necessary. Limit of one (1) entry during the Promotion

Period. To obtain one (1) entry, eligible Entrants will need to click on the link included in the Promotion e-mail and complete the Promotion survey during the Promotion Period.

PRIZES/DRAW: Four (4) prizes available to be won in Canada (excluding Quebec), each consisting of a $25 Newton account credit (a “Prize”). The Prize is non-exchangeable, non-transferable, non-refundable, and must be accepted as awarded with no substitutions. Newton reserves the right, for any reason and in its sole discretion, to substitute and/or modify the Prize with another prize that is of equal or greater value. The Prize will be sent to the selected Entrant(s) that satisfied the requirement of this Promotion (each a “Winner”) via e-mail. An unclaimed Prize or Prize forfeiture will not be rewarded. No responsibility is assumed for any delivery returned as undeliverable. Winner(s) bears all risks to the Prize upon delivery.

Four (4) entries will be selected via random drawing from among eligible entries received during the Promotion Period on or around Monday, June 30th, 2025 at approximately 4:00pm ET in Toronto, ON (“Draw Date”). All Prizes will be distributed within ten (10) business days of identifying the Winner(s).

ODDS: The odds of being selected as a potential Winner are dependent upon the number of eligible entries received by Newton during the Promotion Period. Maximum of one Prize per Entrant.

WINNER NOTIFICATION: Within two (2) business days of the Draw Date,

Newton, acting reasonably, will attempt to contact the potential Winner(s) of the

Promotion (“Winner Notification”). The selected Entrant must confirm receipt of the Winner Notification, and complete all steps outlined therein including the completion of a release and indemnity form (if requested). In the event a potential Winner cannot be contacted by 11:59 PM ET two (2) days after the Winner Notification or there is a return of any notification as undeliverable, or otherwise does not meet the eligibility or Promotion requirements, they may be disqualified and Newton reserves the right,

in its sole discretion, to follow the provisions and procedures referred above relating to selection and notification of a potential Prize winner, with the necessary amendments, until a qualified Prize winner has been duly selected, or there are no more eligible entries, whichever occurs first. Newton is not responsible for the failure for any reason whatsoever of a selected Entrant to receive notification or for Newton to receive a selected Entrant’s response.

No correspondence will be entered into except with Entrants requesting the Promotion Rules by mail or requesting the name(s) of the Winner, for which a self-addressed, postage paid envelope must be included. Requests should be addressed to

Newton’s [Marketing Department] at 180 John Street, Toronto, ON  M5T 1X5.

SKILL TESTING QUESTION: Before being declared a Winner, the potential Winner shall be required to correctly answer, without assistance of any kind, whether mechanical or otherwise, a time-limited mathematical skill-testing question to be administered in the Winner Declaration and Release form, to comply with the Promotion

Rules, and to sign and return the Release within the period specified by Newton.

RELEASE: By entering the Promotion, the Entrant agrees to release and to hold Newton and its parent companies, subsidiaries, affiliates, related and associated entities, employees, directors, officers, suppliers, agents, sponsors and administrators (the “Releasees”) harmless from any and all liability for any injuries, loss or damage of any kind to the Entrant or any other person, including personal injury, death, or property damage, resulting in whole or in part, directly or indirectly, from acceptance, possession, use or misuse of any Prize, participation in the Promotion, any breach of the Promotion Rules, or in any Prize-related activity. The Entrant agrees to fully indemnify Newton, and the Releasees from any and all claims by third parties relating to the Promotion, without limitation.

Newton assumes no responsibility or liability for lost, late, unintelligible/illegible, falsified, damaged, misdirected or incomplete entries, notifications, responses, replies or any Release, or for any computer, online, software, telephone, hardware or technical malfunctions that may occur, including but not limited to malfunctions that may affect the transmission or non-transmission of an entry. Newton is not responsible for any incorrect or inaccurate information, whether caused by website users or by any of the equipment or programming associated with or utilized in the Promotion or by any technical or human error which may occur in the administration of the Promotion. Newton assumes no responsibility for any error, omission, interruption, deletion, defect, delay in operation or transmission, communications line failure, theft or destruction or unauthorized access to, or alteration of, entries. Newton is not responsible for any problems, failures or technical malfunction of any telephone network or lines, computer online systems, servers, providers, computer equipment, software, e-mail, players, applications or browsers, on account of technical problems or traffic congestion on the Internet, at any website or application, or on account of any combination of the foregoing or otherwise. Newton is not responsible for any injury or damage to the Entrant or to any computer related to or resulting from participating or downloading materials in the Promotion. The entrant assumes liability for injuries caused or claimed to be caused by participating in the Promotion, or by the acceptance, possession of, use of, or failure to receive any Prize. Newton assumes no responsibility or liability in the event that the Promotion cannot be conducted as planned for any reason, including those reasons beyond the control of Newton, such as infection by computer virus, bugs, tampering, unauthorized intervention, fraud, technical failures, or corruption of the administration, security, fairness, integrity or proper conduct of the Promotion, the Promotion website(s) and/or the Promotion application(s). Newton assumes no responsibility for entries which fail to comply with the Promotion Rules. Newton assumes no responsibility for any failure of Newton’s website or application during the Promotion Period, including any problems or technical malfunctions of any computer on-line systems, servers, computer equipment, software, failure of any e-mail, notification or entry to be received on account of technical problems or traffic congestion on the Internet, any website, any application, or any combination thereon.

Newton reserves, in its sole discretion, to terminate the Promotion, in whole or in part, and/or modify, amend or suspend the Promotion, and/or the Promotion Rules in any way, at any time, for any reason without prior notice.

PUBLICITY: Unless prohibited by law, the Winner agrees that by accepting a Prize, Newton may use the Winner’s name, likeness, photo, video, city of residence, biographical information, prize information and/or statements about this Promotion for publicity purposes with no compensation, notification or permission.

TAMPERING: All entries are subject to verification. By participating in the Promotion, the Entrant agrees to be bound by the Promotion Rules. The Entrant further agrees to be bound by the decisions of Newton, which shall be final and binding in all respects. Newton reserves the right, in its sole discretion, to disqualify any Entrant found to be:

1. violating the Promotion Rules;

2. tampering or attempting to tamper with the entry process or the operation of the Promotion, the Promotion website, the Promotion application or any related promotional website or application;
3. using any automated, script, macro, robotic or other program(s) to enter or otherwise participate in the Promotion; or

4. acting in an unsportsmanlike or disruptive manner, or with intent to annoy, abuse, threaten or harass any other person.

CAUTION: ANY ATTEMPT TO DELIBERATELY DAMAGE THE PROMOTION WEBSITE, THE PROMOTION APPLICATION OR OTHERWISE UNDERMINE THE LEGITIMATE OPERATION OF THE PROMOTION MAY BE A VIOLATION OF CRIMINAL AND CIVIL LAWS. SHOULD SUCH AN ATTEMPT BE MADE, NEWTON RESERVES THE RIGHT TO SEEK REMEDIES AND DAMAGES TO THE FULLEST EXTENT PERMITTED BY LAW, INCLUDING BUT NOT LIMITED TO CRIMINAL PROSECUTION.

INTELLECTUAL PROPERTY: All intellectual property, including but not limited to trade-marks, trade-names, logos, designs, promotional materials, web pages, source codes, drawings, illustrations, slogans and representations used in connection with the Promotion are the property of Newton and/or its affiliates. All rights are reserved. Unauthorized copying or use of any copyrighted material or intellectual property without the express written consent of its owner is strictly prohibited.

COLLECTION OF INFORMATION: By entering the Promotion, the Entrant understands and agrees that Newton will collect, use and disclose their personal information for the purposes of administering the Promotion and to analyze and to improve Newton’s product and service offerings, as well as in accordance to the Privacy Policy as applicable to their Newton account https://www.newton.co/privacy. Any questions regarding Newton’s Privacy Policy or the treatment of your personal information should be directed to Newton Crypto Ltd. at 180 John Street, Toronto, ON M5T 1X5.

CONSTRUCTION: The Promotion is void where prohibited by law and is subject to all applicable federal, provincial and municipal laws and regulations. The Promotion Rules are subject to change without notice in order to comply with any applicable federal, provincial and municipal laws or the policy of any other entity having jurisdiction over Newton. All issues and questions concerning the construction, validity, interpretation and enforceability of the Promotion Rules or the rights and obligations as between the entrant and Newton in connection with the Promotion shall be governed by and construed in accordance with the laws of the province of Ontario including procedural provisions without giving effect to any choice of law or conflict of law rules or provisions that would cause the application of any other jurisdiction’s laws. All dollar amounts referred to in the Promotion Rules are stated in Canadian Dollars.

Invalidity or unenforceability of any provisions, in part or in full of these Promotion Rules shall not affect the validity or enforceability for the remainder of the rules. The Promotion Rules shall be interpreted as if the invalid or unenforceable provisions were not included, should such provisions exist.

In the event of any discrepancy or inconsistency between the terms and conditions of the Promotion Rules and disclosures or other statements contained in any Promotion related materials, including but not limited to the Promotion entry form, or point of sale, television, print or online advertising, the terms and conditions of the Promotion Rules shall prevail, govern and control.