Official rules of the „FINOVO. VARA. CULTURA.” campaign

The „FINOVO. VARA. CULTURA.” promotional campaign (the „Campaign”) is organised by SC Innovative Professional Services SRL, a company incorporated under Romanian law, with registered office in Romania, Cluj County, Cluj-Napoca, Calea Florești no. 4, registered with the Trade Registry under no. J2019000294124, sole registration code RO40506547, e-mail echipa@finovo.ro, legally represented by Barbu Nicolae as representative/DPO, mobile 0742 412 440 (the „Organiser” or „Finovo”), operator of the www.finovo.ro platform.

For any request regarding the protection of personal data, Participants may contact the Organiser at the dedicated address echipa@finovo.ro, in accordance with Art. 13.

Participants in the Campaign are required to comply with the terms and conditions of these official rules (the „Rules”). The Rules are drawn up and will be made public, free of charge, to any requester on www.finovo.ro and upon request, in accordance with applicable Romanian legislation, including Government Ordinance no. 99/2000 on the marketing of products and market services, as subsequently amended and supplemented („GO 99/2000”).

The Organiser reserves the right to amend or supplement these Rules during the Campaign, under the conditions of Art. 18, while observing the rights already acquired by Participants up to the moment of the amendment.

The Campaign takes place online, on the territory of Romania, between 1 July 2026 and 31 August 2026 (the „Campaign Period”), structured in 2 (two) independent monthly rounds: the July Round and the August Round. Each round has its own entry mechanism, its own validation period and its own draw, in accordance with Art. 9.

The Rules are publicly available, in a form authenticated by a notary, at least 5 working days before the Campaign start date, in accordance with the requirements of GO 99/2000.

Participant – any natural person who cumulatively meets the eligibility conditions of Art. 4 and who fully completes, within a calendar month, the participation mechanism described in Art. 5, for at least one of the Campaign Rounds.

New account – the account created by the Participant on www.finovo.ro in the calendar month of the Round in which they wish to take part, using real, complete and correct identification data of the account holder. An account created or activated before the start of the calendar month of that Round is not considered a „new account” for that round.

Cultural activity – any cultural event, product or service in which the Participant took part, or which they purchased, during the calendar month of the relevant Round, including but not limited to: a cinema film screening, a theatre, opera or ballet performance, a concert, a festival, buying and reading a book, visiting a museum or an exhibition. Proof of the cultural activity (ticket, invoice, receipt, booking confirmation or other equivalent document) remains in the Participant's possession and is not uploaded to the platform nor sent to the Organiser except where the Participant is designated a winner, in accordance with Art. 10.

Official post – the post published by the Organiser on the official @Finovo Instagram and/or Facebook page, dedicated exclusively to the relevant Campaign Round, expressly identified as such in the post and/or by using the tag #FinoVaraCultura.

Valid comment – the single comment posted by the Participant directly on the Official Post of the relevant Round, containing exclusively one of the words or emojis accepted under Art. 7, and which remains public, visible and unedited from the moment of posting until the completion of winner validation for that round.

Winner – the Participant drawn at random under Art. 9 and validated under Art. 10.

Reserve – the Participant included in the ordered reserve list generated at the time of the draw, under Art. 9, who may acquire winner status under the conditions of Art. 11.

Valid contact details – the phone number and/or e-mail address linked to the Participant's Finovo account, through which they can be effectively identified and contacted by the Organiser.

Any natural person (the „Participant”) who cumulatively meets the following conditions may enter the Campaign: has reached the age of 18 at the date of entry; is domiciled or resident in Romania; holds or creates a new, valid account on www.finovo.ro, in accordance with Art. 3 and Art. 5; fully and unconditionally accepts these Rules, in accordance with Art. 20.

The following are not entitled to participate: the Organiser's employees, employees of affiliated or partner companies involved in organising and running the Campaign, and their first-degree relatives (parents, children, siblings, spouse).

A single natural person, uniquely identified by CNP (personal numeric code), may win at most one prize over the entire Campaign, regardless of the number of rounds entered or accounts created.

A Participant may complete a single valid entry per round. Entry in the July Round and entry in the August Round are independent of each other and each is subject to a separate draw, in accordance with Art. 9; entries from the two rounds are not combined when calculating the chances of winning within the same draw.

Participation in the Campaign is free and involves no fee, payment or mandatory purchase to the Organiser. To validly enter a monthly round of the Campaign, the Participant must complete, within the calendar month of that round, cumulatively, the following 3 (three) actions:

Step 1 – Creating the account. The Participant creates a new account on www.finovo.ro in the calendar month of the round they wish to enter, i.e. July 2026 or August 2026, in accordance with the „new account” definition in Art. 3. Accounts created before the start of the calendar month of that round are not eligible for it.

Step 2 – Doing a cultural activity. The Participant carries out, in the calendar month of the relevant round, at least one cultural activity (of any value, minimum 1 Leu), as defined in Art. 3. Proof of the cultural activity is not sent or uploaded to any platform at the time of entry; it is kept by the Participant and presented to the Organiser only where the Participant is designated a winner, within the validation procedure described in Art. 10.

Step 3 – Comment on social media. The Participant leaves a single valid comment, in accordance with Art. 7, on the Official Post of the relevant round, consisting of a single word or emoji from the list accepted by the Organiser, describing the type of cultural activity done under Step 2 (for example: „film”, „theatre”, „book”, „festival”, or equivalent emojis).

The 3 (three) actions above must be completed cumulatively, in the same calendar month, for the entry to be considered valid and included in the draw for that round, in accordance with Art. 6 and Art. 9.

An entry is considered valid if, cumulatively, the 3 (three) actions in Art. 5 were fully completed, in the same calendar month of the round, by a person meeting the eligibility conditions of Art. 4.

The draw provided for in Art. 9 is carried out exclusively from the list of Participants with entries validated by the Organiser before the draw, and not from the entire database of accounts registered on the platform.

Where the same natural person (identified by CNP, identification data, contact details, device or other consistent technical elements) creates and uses several accounts and/or makes several comments/activities within the same round, all these entries are combined into a single valid entry in the draw for that round; multiple participation does not increase the chances of winning.

The Organiser reserves the right to invalidate, before the draw, any entry for which there are reasonable indications of fake accounts, incomplete or manifestly incorrect identification data, or other forms of manipulation of the participation mechanism, applying, as the case may be, Art. 15.

The comment in Step 3 (Art. 5) must be posted exclusively on the Official Post of the relevant round, identified by the Organiser under Art. 3. Comments left on other posts, on posts of unofficial accounts, or on the Official Post of another round are not taken into account.

For validity, the Participant must leave a single comment on the Official Post of the relevant round. If a Participant leaves several comments, only the first valid comment posted chronologically is taken into account, and the others are ignored.

Only comments consisting of a single word or a single emoji are accepted, chosen from the list published by the Organiser together with the Official Post (for example: „film”, „theatre”, „book”, „festival”, „museum”, „concert”, or equivalent emojis). Comments that do not follow this format, or that contain other words, links, commercial mentions or inappropriate content are not considered valid comments.

The comment must remain public, visible and unedited from the moment of posting until the completion of winner validation for that round, in accordance with Art. 10. Editing or deleting the comment, deleting/deactivating the social media account, or setting the account or comment to private/restricted before validation is complete, results in invalidation of the entry, or, if the Participant has already been drawn, their disqualification under Art. 11.

Where the Organiser cannot verify the comment's visibility for reasons not attributable to it (for example, the Participant's account is restricted, private or set so that the comment cannot be publicly verified), the Organiser may ask the Participant for a proving screenshot or temporary viewing access; refusal or inability to provide this proof within the deadline communicated by the Organiser is treated as non-completion of Step 3.

In each of the 2 (two) monthly rounds of the Campaign, 10 (ten) prizes are awarded, each of an individual guaranteed net value of 150 Lei, granted as a bank transfer to the winning Participants.

July 2026 Round: 10 prizes × 150 Lei net. August 2026 Round: 10 prizes × 150 Lei net.

The total value of prizes awarded over the entire Campaign is 3,000 Lei net guaranteed, plus, as the case may be, applicable tax obligations under Art. 12.

Prizes cannot be replaced with other goods/services and cannot be awarded in any way other than that provided for in this Article.

The draw of the winners of each round is carried out by the Organiser, by electronic means, using the random.org platform or an equivalent mechanism of verifiable random generation, within the first 5 working days of the close of the calendar month of the relevant round.

The draw is carried out exclusively from the list of Participants with entries validated under Art. 6, a list locked/closed at the end of the calendar month of the round, at 23:59:59.

The draw process is documented by the Organiser through a screenshot and/or random.org verification link, stating the total number of entries included in the draw, the exact time and date of the draw and the responsible person on the Organiser's side, documentation kept for the entire duration provided for in Art. 13 and published, in summary form, on the official Campaign channels, for transparency.

Together with the draw of the 10 main winners of each round, an ordered list of at least 10 (ten) reserves is generated, using the same random mechanism, used under the conditions of Art. 11.

Validating a drawn winner involves the cumulative verification of: (a) meeting the eligibility conditions of Art. 4; (b) keeping the Step 3 comment visible, in accordance with Art. 7, until validation is complete; (c) the actual performance of the Step 2 cultural activity; and (d) the correctness of the identification data provided.

To award the prize, the winner will be contacted through the valid contact details linked to the Finovo account, within a maximum of 3 (three) working days of the draw, and will be asked, within 5 (five) working days of contact, for a statement/proof of the bank account (IBAN) opened in the winner's name, in order to make the bank transfer of the prize. The prize is transferred exclusively to the IBAN account opened in the name of the validated winner; the Organiser does not transfer the prize to an account held by another person.

Verification of the correspondence between the identity of the Participant on social media and the identity of the Finovo account holder, and of the indicated bank account, is carried out by the Organiser proportionately and reasonably, taking into account that the username displayed on social media may differ from the person's legal name; in the event of apparent discrepancies, the Organiser may request reasonable clarification or additional proof from the Participant before rejecting validation.

If a drawn winner: does not respond within the deadlines indicated above; does not confirm or keep the Step 3 comment visible; cannot prove the Step 2 cultural activity; refuses or cannot provide the requested documents; or is found not to meet the eligibility conditions, the prize is redistributed to the next Reserve on the list generated at the draw, in accordance with Art. 11.

Payment of the prize is made by bank transfer within a maximum of 5 working days of the completion of the winner's validation, but no later than 15 calendar days from the close of the month of the relevant round. Any bank fees charged by the issuing bank for the transfer are borne by the Organiser; fees charged, as the case may be, by the recipient's bank are borne by the winner.

The reserve list generated under Art. 9 is ordered; reserves are contacted in the strict order of their position on the list, as a prize becomes available for redistribution under Art. 10.

Each contacted Reserve has 3 (three) working days from contact to respond and a further 5 (five) working days to provide the documents set out in Art. 10; the same validation conditions of Art. 10 apply accordingly.

A Reserve acquires winner status only upon successful completion of the validation procedure of Art. 10. If a Reserve cannot be validated, the Organiser contacts the next Reserve on the list, in order, until the reserve list is exhausted or the number of prizes available for that round is validated.

If the reserve list is exhausted without all the round's prizes being validated/awarded, the remaining unawarded prizes are not carried over to another round and remain at the Organiser's disposal, with public notice of this situation on the official Campaign channels.

Income consisting of prizes awarded to natural persons within the Campaign is subject to the applicable tax regime, in accordance with Law no. 227/2015 on the Tax Code, as subsequently amended and supplemented, in force at the date each prize is awarded.

To the extent that the tax legislation in force at the date the prize is awarded provides for favourable tax treatment (a non-taxable threshold, exemption or other facility), it applies according to the conditions and limits set by law at that time. The Organiser cannot guarantee, through these Rules, a fixed or invariable tax treatment, as this depends on the legal regulations applicable at the date of payment, which may be amended independently of the Organiser's will.

To the extent that, under the law applicable at the date the prize is awarded, tax on prize income is due, it is calculated, withheld and paid to the budget by the Organiser, as income payer, the amounts communicated as „guaranteed net prize” in Art. 8 representing the amounts actually received by the winner, regardless of the tax calculation method applicable under the law.

The Organiser, SC Innovative Professional Services SRL, acts as a personal data controller within the meaning of Regulation (EU) 2016/679 (GDPR), for the data processing carried out within the Campaign.

Categories of data processed: surname, first name, contact details (phone, e-mail), data linked to the Finovo account, the content of the comment posted under Art. 7 and the associated public username, and, exclusively for winners and validated reserves, a copy of the identity card, CNP, proof of the cultural activity and bank account details (IBAN).

Purposes of processing: organising and running the Campaign, validating entries and winners, awarding prizes and fulfilling the Organiser's legal tax and financial-accounting reporting obligations.

Legal basis of processing: (a) performance of the Rules, accepted by the Participant by entering the Campaign, for the data needed to organise the Campaign, validate and award prizes; (b) compliance with a legal obligation of the Organiser, for data processed for tax and accounting purposes (including the copy of the identity card/CNP and bank details).

Data recipients: the Organiser's authorised staff, processors/service providers of the Organiser (for example, IT/hosting service providers, payment/bank transfer services), and the competent public authorities (for example, ANAF), to the extent required by law. Data is not transferred outside the European Economic Area, except where a service provider of the Organiser ensures adequate transfer guarantees, in accordance with GDPR.

Storage period: the data needed to organise and validate the Campaign is kept for the duration of the Campaign and for a maximum of 60 days after its completion, needed to resolve any complaints under Art. 19; data collected for tax/accounting purposes (including the copy of the identity card/CNP) is kept for the legal archiving period of tax and financial-accounting documents, i.e. a maximum of 10 years after the completion of the Campaign, in accordance with applicable tax and accounting legislation, and is stored encrypted.

Rights of data subjects: Participants have the right of access, rectification, erasure, restriction, portability and objection regarding their personal data, as well as the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing (ANSPDCP). These rights may be exercised by sending a request to echipa@finovo.ro.

The data of persons mentioned/tagged in the Step 3 comments (Art. 5) is not actively collected or processed by the Organiser at the time of entry; any subsequent processing of such persons' data, if needed, will be carried out in compliance with GDPR principles and, as the case may be, with separate notice/consent of the data subject.

The Campaign and the participation mechanisms described in Step 3 (Art. 5 and Art. 7) are in no way sponsored, administered, endorsed or associated with Meta Platforms Inc., Facebook or Instagram. Participants provide the requested information exclusively to the Organiser, and not to the Meta/Facebook/Instagram platforms, which are entirely released from any liability related to the Campaign.

Any question, complaint or request related to the Campaign must be addressed exclusively to the Organiser, at the contact details indicated in these Rules, and not to the social media platforms used for social validation.

The Organiser reserves the right to disqualify, at any time during the Campaign, including after the draw or prize payment, any Participant found, on the basis of reasonable evidence, to have attempted to defraud the Campaign mechanism, including but not limited to: using multiple accounts or false identities to obtain additional entries/chances of winning; posting comments, shares or other simulated, automated social interactions or ones generated by bots or third-party artificial interaction services; deleting, editing or hiding the valid comment before validation is complete, under Art. 7; presenting documents, proof of cultural activity or identification data that are false, forged or do not correspond to reality; any other form of manipulation of the entry, draw or validation process.

Disqualification of a Participant or of a Winner entails loss of the right to the prize and, if the prize has already been paid, the Organiser's right to request its return, without prejudice to the Organiser's other rights or legal actions.

The Organiser is not responsible for: a Participant's inability to access the platform or social media for reasons beyond the Organiser's control, including technical problems of internet providers or the third-party Meta/Instagram/Facebook platforms; delays in transferring prizes caused by errors or incomplete or incorrect data provided by the Participant, including an incorrect IBAN or a closed bank account; the inability to verify the authenticity of the data or proof provided, beyond the reasonable diligence exercised under Art. 10; acts of fraud committed by Participants, under Art. 15.

For the purpose of these Rules, force majeure means any event that cannot be controlled, remedied or foreseen by the Organiser and whose occurrence makes it impossible for the latter to fulfil the obligations undertaken through the Rules, including the unavailability of the Meta/Instagram/Facebook platforms or of the random.org platform. If a force majeure situation prevents or delays, in whole or in part, the performance of the Rules, the Organiser will be released from liability for fulfilling the affected obligations, for the entire period during which such fulfilment is prevented or delayed, and Participants will be publicly informed of this situation.

The Campaign may end early, may be suspended or amended by the Organiser, on objective and duly justified grounds, with prior public notice to Participants, by posting on the official Campaign channels, at least 24 hours before the change becomes applicable, and while observing the rights already acquired by Participants up to that moment.

Any disputes arising between the Organiser and Participants will be resolved amicably; if this is not possible, the disputes will be submitted for resolution to the competent courts at the Organiser's registered office.

Any complaints regarding the running of the Campaign may be sent to echipa@finovo.ro within a maximum of 15 calendar days from the public declaration of the winners of a round; complaints sent after this deadline are no longer taken into account.

By taking part in the Campaign, Participants expressly declare that they have become aware of the provisions of these Rules, including the participation mechanism in Art. 5, the comment rules in Art. 7, the tax regime in Art. 12 and the processing of personal data in Art. 13, and that they agree with them fully and unconditionally.

The Rules are available free of charge, for the entire duration of the Campaign, to any requester, at www.finovo.ro and at the Organiser's registered office.

These Rules were drafted and authenticated by the notary public [to be completed] under number [to be completed] of [to be completed], in accordance with the law.