> For the complete documentation index, see [llms.txt](https://the-loyalty-link.gitbook.io/super-freak/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://the-loyalty-link.gitbook.io/super-freak/faqs/disclamer.md).

# Disclamer

(Under Construction)

Please read the following disclaimer carefully. If you are in any doubt as to the action you should take, you should consult your own independent legal, financial, tax, accounting and other professional advisors.

This document, the Super Freak White Paper, is provided for general information and educational purposes only. It does not constitute, and should not be interpreted as, legal, tax, accounting, financial, investment, regulatory or other professional advice.

This White Paper does not constitute a prospectus, offering memorandum, financial promotion, investment recommendation, securities offering, solicitation, invitation or offer to buy or sell shares, securities, financial instruments, collective investment products, derivatives, virtual assets, cryptoassets, tokens, NFTs or any other investment product in Hong Kong or in any other jurisdiction.

Unless expressly stated otherwise, Super Freak is owned, operated and/or made available by **The Loyalty Link Limited**, a company incorporated under the laws of Hong Kong, with registered office at **2108, Metro Centre 2, 21 Lam Hing Street, Kowloon Bay, Hong Kong**, registered with the Hong Kong Companies Registry under company number **\[Company Number]** and, where applicable, business registration number **\[Business Registration Number]**.

References to “Super Freak”, “the Platform”, “we”, “us”, “our” or “the Company” refer to **\[Hong Kong Company Name]**, unless the context requires otherwise.

Super Freak is designed, operated and legally positioned as a **Web2 gaming, loyalty, fan engagement, promotional and digital membership platform**.

The Platform may use blockchain, smart contracts, NFTs, digital certificates or other distributed ledger technologies as a **technical transparency and certification layer** to enhance authenticity, traceability, automation, auditability and public verification of selected platform activities.

The use of blockchain technology does not change the legal nature of the Platform. Super Freak remains a Web2 gaming, loyalty, promotional and fan engagement platform. The Company does not operate as a gambling platform, betting platform, casino, lottery business, financial platform, investment platform, crypto exchange, virtual asset trading platform, payment institution, money service operator, wallet provider, custodian, broker, dealer or financial intermediary.

The information contained in this White Paper may not be exhaustive, may be amended from time to time, and does not imply the creation of any contractual, fiduciary, advisory, investment, agency, employment, joint venture or partnership relationship between the reader and the Company.

***

### 1) No Offer, No Solicitation, No Advice

**No securities or financial product offer.**\
This White Paper is not a prospectus, offering document, advertisement, invitation or document of offer within the meaning of the Securities and Futures Ordinance, Cap. 571 of Hong Kong, the Companies Ordinance, Cap. 622 of Hong Kong, or any equivalent law in any other jurisdiction.

**No investment solicitation.**\
Nothing in this White Paper constitutes or should be interpreted as an offer, invitation, recommendation, promotion or solicitation to acquire, purchase, subscribe for, sell, exchange or otherwise deal in securities, financial instruments, investment products, collective investment schemes, derivatives, virtual assets, cryptoassets, tokens, NFTs or any other investment product.

**No regulated investment activity intended.**\
Nothing in this White Paper is intended to constitute dealing in securities, advising on securities, asset management, providing automated trading services, operating a collective investment scheme, operating a virtual asset trading platform, issuing a regulated stablecoin, operating a stored value facility, money service operation or any other regulated financial service in Hong Kong or elsewhere.

**No financial, legal or tax advice.**\
The information contained herein is provided for information purposes only. Users, members, holders and participants should obtain independent professional advice before taking any action connected with Super Freak, digital memberships, digital collectibles, platform points, rewards, activities, promotional campaigns, prize draws or platform participation.

**No reliance.**\
No person should rely on this White Paper as the basis for an investment, financial, tax, legal or commercial decision. Any participation in Super Freak is undertaken at the user’s own risk.

**No warranties.**\
The Company makes no representation or warranty, express or implied, as to the accuracy, completeness, reliability, suitability, availability or fitness for any purpose of the information contained in this White Paper. Information may change without notice.

***

### 2) Web2 Gaming, Loyalty and Fan Engagement Platform

Super Freak is primarily a Web2 platform focused on gaming, loyalty, community engagement, digital memberships, fan activities, brand activations, rewards and promotional experiences.

The Platform is designed to allow users to participate in entertainment, loyalty and engagement activities such as challenges, contests, quests, feedback campaigns, digital memberships, experience redemptions, community missions, leaderboard activities, reward systems and promotional prize draws.

The Platform is not designed to provide financial returns, speculative gains, passive income, investment exposure, tradable financial products, betting opportunities or gambling services.

Any paid membership, digital pass, subscription, merchandise purchase, product purchase or service purchase is intended to provide access, entertainment, utility, community benefits, brand experiences, loyalty participation or digital membership features. It is not intended to provide gambling participation, investment exposure, financial return or speculative opportunity.

Super Freak may be accessible through websites, mobile applications, dashboards, third-party integrations, blockchain infrastructure, APIs or other digital interfaces. These interfaces are intended to support the Platform’s Web2 gaming, loyalty and fan engagement functions.

***

### 3) Blockchain Transparency Layer

The Company may use blockchain, smart contracts, NFTs, digital certificates or distributed ledger technologies as an optional technical infrastructure layer.

Blockchain technology may be used, for example, to:

* certify digital memberships, badges, collectibles or access credentials;
* record participation, achievements, rewards or redemptions;
* provide transparent proof of activity or ownership;
* automate selected platform rules;
* create verifiable digital certificates;
* make certain records publicly auditable;
* improve transparency in reward allocation;
* reduce disputes between users, brands and the Platform;
* increase trust in gamified activities and promotional mechanics.

Blockchain is used by Super Freak to enhance authenticity, traceability, transparency, automation and public auditability of selected platform activities.

The use of blockchain technology does not transform the Platform into a crypto exchange, virtual asset trading platform, financial service, investment platform, payment institution, wallet provider, gambling platform or betting service.

Any blockchain component used by Super Freak is intended to serve a technical, operational and transparency function only.

Such use is not intended to create, and should not be interpreted as creating:

* securities;
* financial instruments;
* investment products;
* derivatives;
* collective investment schemes;
* stablecoins;
* e-money;
* stored value facilities;
* payment instruments;
* virtual asset exchange services;
* custodial wallet services;
* brokerage services;
* banking services;
* money transmission services;
* gambling products;
* betting products;
* wagering products.

Users participate in the Platform for entertainment, loyalty, community, promotional, fan engagement and brand experience purposes only.

***

### 4) No Financial Services, No Crypto Services, No Custody

The Company does not intend to provide, and users must not interpret the Platform as providing, any of the following services:

* banking services;
* payment account services;
* money transmission services;
* fiat-to-crypto conversion;
* crypto-to-fiat conversion;
* virtual asset exchange services;
* token swap services;
* trading pair services;
* order book services;
* brokerage or dealing services;
* investment advisory services;
* asset management services;
* securities trading services;
* custodial wallet services;
* private key management;
* seed phrase management;
* staking services;
* lending services;
* borrowing services;
* yield services;
* liquidity pool services;
* derivatives, options, futures or structured products.

The Company does not receive, hold, manage or control user fiat funds, cryptoassets, virtual assets, securities, private keys, seed phrases or custodial wallets.

The Company does not act as a financial intermediary, virtual asset intermediary, money service operator, stored value facility issuer, payment institution, stablecoin issuer or regulated financial service provider.

If any feature, mechanic, payment flow or blockchain component were to require financial, virtual asset, payment, banking, custody, money service or investment licensing, the Company may modify, restrict, geoblock, suspend, cancel or redesign such feature rather than operate it as a regulated service.

***

### 5) No Wallet Management and No Sensitive Crypto Data

The Company does not manage user wallets, private keys, seed phrases or custodial wallet credentials.

The Company does not ask users to provide seed phrases, private keys or wallet recovery credentials.

Users must never share seed phrases, private keys, passwords, wallet recovery credentials or sensitive wallet access information with the Company, its staff, partners, contractors, support channels or any third party claiming to act on behalf of the Company.

Where the Platform uses embedded wallet infrastructure, account abstraction, social login, custodial-like user experience or blockchain abstraction, such infrastructure may be provided by independent third-party technology providers. The Company’s role is limited to providing the user interface and platform experience, unless expressly stated otherwise.

The Company is not responsible for loss of access, user errors, compromised devices, phishing, malicious signatures, wrong addresses, blockchain failures or third-party wallet provider failures.

Blockchain transactions, where applicable, may be irreversible. Users are responsible for verifying any wallet address, transaction, signature, connection or authorization before taking action.

***

### 6) No Gambling, Betting or Wagering

Super Freak is not a gambling, betting, wagering, casino, lottery business, sportsbook or real-money gaming platform.

Users are not required to stake money, cryptoassets, tokens or anything of monetary value on the outcome of any game, prediction, contest, activity, challenge, ride, quest, feedback campaign, community mission or promotional activity.

The Platform does not allow users to win money as a result of gambling, betting, wagering or games of chance.

Unless expressly stated otherwise in specific promotional rules, rewards are non-cash goods, experiences, digital benefits, access rights, merchandise, community perks or brand-related prizes.

The Platform does not offer casino games, slot-machine-style games, roulette, poker, blackjack, mahjong, dice games, sportsbook betting, financial betting, binary options, prediction markets or any game designed to replicate or replace gambling.

All gamified activities are intended to be free-to-play, promotional, skill-based, community-based, merit-based, loyalty-based, participation-based or engagement-based, unless a specific activity is governed by official promotional rules and, where required, the appropriate promotional licence.

The Company may suspend, redesign, geoblock or cancel any activity that could be interpreted as gambling, betting, wagering, unauthorized lottery or otherwise inconsistent with the Platform’s legal positioning.

***

### 7) Promotional Draws and Trade Promotion Competition Licence

From time to time, Super Freak may organize promotional prize draws, lucky draws or trade promotion competitions connected with brand campaigns, digital memberships, loyalty activities, community engagement, fan experiences or promotional initiatives.

Where a promotional activity conducted in Hong Kong involves prizes allocated by chance for the purpose of promoting a trade, business, product or service, the Company may apply for a **Trade Promotion Competition Licence** before launching the relevant promotion.

This licence may be required for promotional lucky draws or similar trade promotion activities conducted in Hong Kong. It is not a gambling licence and does not convert Super Freak into a gambling, betting, casino, lottery business or wagering platform.

Promotional draws shall remain ancillary, occasional and promotional in nature.

Unless expressly permitted under applicable law and official rules:

* no cash prize shall be offered;
* no prize shall be redeemable for cash from the Company;
* no user shall be required to pay a gambling stake;
* no user shall be allowed to wager money;
* no activity shall be presented as a way to make money;
* no betting, gambling, casino or wagering mechanics shall be used;
* no slot machines, roulette wheels, betting slips, casino chips, dice, playing cards or similar gambling symbols shall be used as core mechanics.

Each promotional draw may be governed by specific Official Rules defining:

* eligibility;
* age requirements;
* territory restrictions;
* entry method;
* free entry method, where required;
* promotional period;
* prize details;
* winner selection process;
* winner notification;
* publication requirements;
* prize delivery;
* tax responsibility;
* shipping responsibility;
* substitution rights;
* disqualification grounds;
* fraud prevention rules;
* cancellation or amendment rights.

The Company may geoblock, exclude, suspend, redesign or cancel promotional activities in jurisdictions where such activities would be prohibited, restricted, unclear, subject to burdensome licensing or inconsistent with the Company’s compliance-first positioning.

***

### 8) Free-To-Play and Gamified Activities

Super Freak activities are intended to be free-to-play, entertainment-based, promotional, skill-based, participation-based, community-based, loyalty-based or merit-based.

Activities may include, by way of example:

* quests;
* challenges;
* contests;
* rides;
* prediction-style games without monetary staking;
* feedback campaigns;
* community missions;
* leaderboard activities;
* points collection;
* reward redemption;
* digital membership activities;
* brand engagement campaigns;
* fan participation mechanics;
* content contribution;
* social engagement;
* promotional prize draws where lawfully permitted.

Unless expressly stated otherwise, users do not purchase a chance to win a monetary prize.

Any purchase connected with the Platform is intended to relate to access, membership, digital utility, merchandise, content, entertainment, fan engagement, community participation, brand experiences or other non-financial benefits.

The Company may modify, suspend, limit, withdraw or redesign any activity to preserve its non-gambling, non-financial, Web2 gaming and loyalty positioning.

***

### 9) Points, Credits, Tokens and Rewards

Any points, credits, scores, badges, ranks, tokens, digital units or similar elements used inside Super Freak are intended to function as internal gaming, loyalty, scoring, reward, access or participation mechanics.

They are not intended to be money, e-money, deposits, securities, financial instruments, investment products, derivatives, fiat-referenced stablecoins, stored value facilities or general-purpose payment instruments.

Unless expressly stated otherwise:

* points are usable only inside the Super Freak ecosystem;
* points have no guaranteed monetary value;
* points are not redeemable for cash from the Company;
* points do not represent deposits;
* points do not grant ownership in the Company;
* points do not grant dividends;
* points do not grant interest;
* points do not grant revenue share;
* points do not grant profit participation;
* points do not create any right to repayment;
* points do not create any expectation of profit;
* points may expire, be modified, limited, suspended or cancelled according to Platform rules.

The Company may modify, limit, suspend or discontinue points, rewards, scoring systems, leaderboards or redemption mechanics for legal, technical, security, fraud prevention, operational or business reasons.

Any blockchain representation of points, badges, certificates or rewards is intended to serve certification, transparency, traceability or automation purposes only.

***

### 10) Digital Memberships, NFTs and Digital Collectibles

Super Freak may issue, display or support digital memberships, digital passes, NFTs, digital collectibles, access credentials, badges, certificates, memorabilia or other digital items.

These items are intended to function as utility, access, loyalty, certification, entertainment, fan engagement or community participation tools.

They may represent:

* membership access;
* platform status;
* community participation;
* achievements;
* reward eligibility;
* experience-related benefits;
* digital memorabilia;
* authenticity certificates;
* proof of participation;
* brand engagement.

They are not sold or promoted as investments.

Unless expressly stated otherwise, digital items issued or displayed through Super Freak:

* do not grant equity in the Company;
* do not grant voting rights;
* do not grant governance rights;
* do not grant dividends;
* do not grant interest;
* do not grant revenue share;
* do not grant profit participation;
* do not create a right to repayment;
* do not represent a deposit;
* do not represent money or e-money;
* do not guarantee resale value;
* do not guarantee liquidity;
* do not guarantee market value;
* do not guarantee financial return.

Any resale or transferability feature, where technically available, is ancillary and not promoted by the Company as an investment opportunity.

Unless expressly stated otherwise, purchasing or receiving a digital item gives the user access only to the specific utility described by the Platform or applicable rules. It does not transfer copyright, trademark rights, image rights, publicity rights, commercial rights or other intellectual property rights in any associated brand, athlete, celebrity, creator, team, event, artwork, design or content.

***

### 11) Third-Party Payments and External Providers

The Company does not itself process card payments, bank payments, fiat-to-crypto conversions, crypto-to-fiat conversions, wallet creation, custody, exchange, settlement or payouts.

Any such services, if available, are provided by independent third-party providers under their own terms and policies.

Users may be required to accept third-party terms, privacy policies, payment terms, KYC/AML rules, refund rules, chargeback rules, transaction limits and eligibility requirements.

The Company is not responsible for any refusal, delay, suspension, fee, refund, chargeback, account limitation, KYC request, AML request, technical failure, downtime, exchange rate, network fee or other decision made by a third-party provider.

The Company may integrate third-party providers for technical convenience, user experience, payment processing, fraud prevention, identity verification, wallet abstraction, infrastructure, hosting, analytics, logistics or customer support.

The use of third-party providers does not mean that the Company itself provides regulated payment, financial, crypto, custody, exchange or wallet services.

***

### 12) Abuse, Fraud and Platform Integrity

Users are prohibited from engaging in:

* fake accounts;
* multi-accounting;
* bot activity;
* reward farming;
* sybil attacks;
* manipulation of rankings or leaderboards;
* self-dealing;
* fake referrals;
* fake engagement;
* exploit abuse;
* fraudulent submissions;
* false identity;
* circumvention of geoblocking;
* use of VPNs to bypass restrictions;
* use of stolen payment instruments;
* use of stolen accounts;
* infringement of third-party intellectual property;
* manipulation of promotional draws;
* manipulation of contest results;
* abuse of bugs or technical errors;
* any other conduct that damages the integrity of the Platform.

The Company may monitor activity patterns and apply controls such as account review, entry cancellation, reward cancellation, leaderboard adjustment, cooldowns, account suspension, geoblocking, manual review, automated fraud detection and disqualification.

Violations may result in account suspension, reward cancellation, loss of eligibility, disqualification from activities, cancellation of entries, removal from leaderboards, blocking of access, reporting to third-party providers or authorities, and other remedies available under applicable law.

***

### 13) Contests, Challenges, Rides and Feedback Activities

Contests, rides, challenges, feedback campaigns and similar activities are intended to be based on skill, participation, creativity, contribution, verified actions, quality of feedback, community involvement, brand engagement or other criteria described in the applicable rules.

They are not intended to constitute betting, gambling, lotteries, games of chance, financial speculation or investment activity.

Each activity may be governed by specific rules defining:

* eligibility;
* entry period;
* scoring criteria;
* judging criteria;
* deadlines;
* prizes or rewards;
* disqualification grounds;
* intellectual property treatment;
* user-generated content rules;
* dispute procedures.

By submitting content, feedback, media, text, images, videos, designs, comments or other user-generated content, users grant the Company a non-exclusive, worldwide, royalty-free licence to use, reproduce, display, publish, adapt and promote such content in connection with the Platform, unless otherwise stated.

Users must not submit unlawful, defamatory, infringing, misleading, offensive, discriminatory, violent, obscene, fraudulent or third-party-infringing content.

Judging, scoring, moderation and reward decisions are final and binding, except in cases of manifest error, fraud or mandatory legal rights.

***

### 14) Prediction-Style Games

Prediction-style games, where offered, are intended as free-to-play, points-based, promotional, entertainment-based or community engagement activities.

They are not intended to constitute betting, wagering, gambling, sports betting, financial prediction markets, binary options, derivatives or investment products.

Users may not stake fiat currency, cryptoassets, tokens or anything of monetary value on the outcome of an event.

Points, rewards or benefits connected to prediction-style games are not redeemable for cash from the Company.

Prediction-style activities may be based on community opinion, fan engagement, entertainment, sports-related interaction, brand interaction or other non-financial participation mechanics.

The Company may exclude certain events, sports, territories, users or prize structures where prediction activities could be subject to local gambling, betting, sports integrity, financial services, consumer protection or promotional gaming laws.

Prediction-style features may be limited, suspended, geoblocked, modified or withdrawn for legal, compliance, operational or reputational reasons.

***

### 15) Marketplace and Secondary Transfers

If the Platform enables digital item transfers, listings, discovery or secondary interactions, the Company’s role is limited to providing technical interface, metadata display, access verification, user experience tools or transfer-related infrastructure.

The Company does not intend to operate a centralized virtual asset trading platform, financial marketplace, securities exchange, broker-dealer service, investment platform, order book, clearing system, settlement system or payment settlement system.

The Company does not custody user assets or funds in connection with user-to-user transactions.

The Company does not guarantee that a buyer will pay, a seller will deliver, a transaction will settle, a counterparty will perform, or that any item will meet expectations.

Unless otherwise required by law, user-to-user items are transferred “as is” and “as available”. The Company provides no warranties regarding authenticity, condition, merchantability, fitness for purpose, legal transferability or value of user-listed assets.

Users may not list, sell, transfer or promote illicit, counterfeit, stolen, non-transferable, infringing, misleading, unsafe, regulated, sanctioned or otherwise prohibited items.

Any marketplace commission or platform fee, where applicable, is consideration for technical, platform, listing, access, discovery or facilitation services. It is not a brokerage fee for securities, financial instruments or regulated virtual assets.

The Company may suspend, restrict or discontinue secondary transfer features where necessary to preserve the Platform’s non-financial, Web2 gaming and loyalty positioning.

***

### 16) Intellectual Property and Digital Item Licence

All Super Freak names, logos, trademarks, software, source code, smart contracts, UI/UX, databases, designs, graphics, text, content, documentation and platform materials belong to the Company or its licensors.

Unless expressly stated otherwise, acquiring a digital membership, digital collectible, NFT, badge, pass or certificate does not transfer copyright, trademark rights, image rights, publicity rights, commercial rights or other intellectual property rights in the associated content.

Unless otherwise specified, digital item holders receive a limited, personal, non-exclusive, non-commercial, revocable licence to display the associated content for personal use and, where technically available, to transfer the relevant digital item.

Commercial use of artwork, brand assets, logos, names, images, athlete likenesses, celebrity likenesses or third-party IP requires express written permission.

Any use of third-party brands, teams, athletes, creators, celebrities, events, logos, trademarks or imagery is subject to authorization. No partnership, endorsement, sponsorship or approval should be inferred unless expressly stated.

IP complaints may be submitted to **\[legal/contact email]**. The Company may remove content, restrict assets, suspend accounts or take other measures upon valid notice or reasonable suspicion of infringement.

***

### 17) Privacy and Data Protection

The Company processes personal data in accordance with the Personal Data (Privacy) Ordinance, Cap. 486 of Hong Kong, and applicable data protection laws in other relevant jurisdictions.

Where the Platform is offered to, or monitors the behaviour of, users located in the European Economic Area, the Company may also be subject to the EU General Data Protection Regulation.

Where the Platform is offered to, or monitors the behaviour of, users located in the United Kingdom, the Company may also be subject to the UK GDPR and the UK Data Protection Act 2018.

The Company may act as data user under Hong Kong law and, where applicable, controller under GDPR/UK GDPR for account data, platform activity data, support data, analytics data, communications data and reward/redemption data.

The Company does not collect private keys, seed phrases, wallet recovery credentials or unnecessary sensitive crypto custody data.

The Company aims to collect only the personal data reasonably necessary for:

* account creation;
* platform operation;
* user authentication;
* fraud prevention;
* abuse prevention;
* reward delivery;
* customer support;
* analytics;
* legal compliance;
* business administration;
* promotional campaign management;
* prize delivery;
* territory restriction management.

Payment processors, wallet infrastructure providers, hosting providers, analytics providers, logistics providers and other third-party service providers may act as independent controllers, data users or processors according to their own privacy policies and contractual roles.

Personal data may be processed or stored in Hong Kong, the European Union, the United States or other jurisdictions, subject to appropriate safeguards where required.

Users may have rights of access, correction, deletion, portability, objection, restriction and other rights under applicable data protection laws. Requests may be sent to **\[privacy/contact email]**.

The Platform is intended for users aged 18 or older. The Company does not knowingly collect personal data from minors.

Data security incidents will be assessed and handled in accordance with applicable data protection laws, contractual obligations and internal incident response procedures.

***

### 18) Consumer Protection and Fair Trading

The Company aims to describe products, memberships, rewards, experiences, benefits, platform features and promotional activities accurately and fairly.

The Company does not intend to mislead consumers by omitting material information regarding eligibility, availability, redemption limits, expiry, restrictions, partner conditions, shipping costs, taxes, technical requirements or legal limitations.

Unless expressly stated, descriptions of future features, benefits, rewards, partners, drops or platform utilities are indicative and may be changed, delayed, restricted, withdrawn or replaced.

Users are responsible for reviewing all applicable product pages, official rules, terms, eligibility criteria, redemption rules and territory restrictions before purchasing or participating.

The Company may correct errors, update descriptions, clarify terms, modify inaccurate information or cancel transactions affected by manifest errors, technical errors, display errors or obvious mistakes, to the extent permitted by law.

Nothing in this White Paper limits mandatory consumer rights that cannot be excluded under applicable law.

***

### 19) Rewards, Merchandise and Experiences

Rewards, goods, merchandise, digital items, experiences, access rights and benefits are subject to availability, eligibility, legal restrictions, production timing, partner confirmation and stock limitations.

The Company does not guarantee that any specific reward will remain available. Rewards may sell out, expire, be replaced, be restricted by territory or be withdrawn.

Shipping costs, customs duties, import VAT, local taxes, permits and delivery requirements may be borne by the recipient unless otherwise stated.

Production and shipping times are indicative only. Delays may occur due to suppliers, customs, carriers, events, force majeure or third-party issues.

Physical defects must be reported within 14 days of delivery unless mandatory consumer law provides otherwise. The Company may offer repair, replacement, equivalent reward, platform credit or other remedy at its discretion and subject to applicable law.

Damage caused by misuse, wear and tear, tampering, improper storage, accidents, third-party modification, user negligence or external causes is excluded unless mandatory law provides otherwise.

Experience-based rewards may be subject to scheduling, availability, third-party terms, travel restrictions, health and safety rules, event cancellation, identity verification and conduct requirements.

The Company is not responsible for travel costs, accommodation costs, visa requirements, insurance, missed transport, health restrictions or other personal expenses connected with experience-based rewards unless expressly stated in the applicable rules.

***

### 20) Worldwide Availability and Territory Restrictions

Super Freak may be accessible worldwide, but not all features, rewards, memberships, digital items, prize draws, contests, experiences or payment methods are available in all jurisdictions.

The Company may restrict access from certain countries, states, provinces, territories or regions where use of the Platform or participation in specific features would be prohibited, restricted, subject to licensing, commercially impracticable or legally uncertain.

Users are responsible for ensuring that their access to and use of the Platform is lawful in their jurisdiction.

Users must not use VPNs, false information, proxy accounts, nominee accounts or other means to circumvent territory restrictions, sanctions restrictions, age restrictions, eligibility requirements or platform rules.

The Company may apply geoblocking, account restrictions, campaign exclusions, prize delivery restrictions, payment restrictions or other controls to comply with applicable laws, partner requirements, platform rules or risk-based compliance decisions.

Participation is void where prohibited by law.

***

### 21) Regulatory Change and Feature Modification

Gaming, promotional, loyalty, digital asset, data protection, consumer protection, tax and platform laws are evolving.

The Company may update, modify, suspend, discontinue or replace any feature, activity, reward program, marketplace function, digital item, UI, policy, smart contract, technical integration or rule.

Where reasonably practicable, the Company will provide notice of material changes. Immediate changes may be made where required for security, legal compliance, fraud prevention, regulatory risk, partner requirements or operational continuity.

The Company may geoblock, redesign, suspend or cancel any activity if it could be interpreted as gambling, betting, unauthorized lottery, financial service, virtual asset service, payment service, stablecoin activity, stored value facility or other regulated activity in any relevant jurisdiction.

The Company does not intend to operate features that would require complex financial, gambling, betting, payment, custody or virtual asset licensing. If a feature would create such a requirement, the Company may remove, redesign, restrict or suspend it.

***

### 22) Technology Risks

The Platform may depend on websites, applications, APIs, databases, cloud providers, payment providers, wallet infrastructure providers, analytics providers, blockchain infrastructure, smart contracts, third-party integrations and user devices.

These systems may suffer bugs, exploits, hacks, downtime, data loss, outages, synchronization issues, cyberattacks, failed transactions or other failures.

The Company does not guarantee uninterrupted availability, error-free operation, compatibility with all devices or permanent availability of any feature.

Smart contracts, where used, may contain vulnerabilities, coding errors or unexpected behaviours. Audits, reviews or technical assessments do not eliminate risk and do not guarantee the absence of vulnerabilities.

Public blockchains and distributed networks may experience congestion, forks, outages, protocol changes, high fees, data availability issues or third-party infrastructure failures.

The Company is not responsible for failures caused by third-party infrastructure, public blockchains, wallet providers, payment providers, hosting providers, user devices or external systems outside its reasonable control.

***

### 23) No Investment and No Market Value Representation

No Platform feature, membership, point, digital item, collectible, reward or benefit should be purchased, received or used for investment purposes.

The Company does not guarantee:

* resale value;
* liquidity;
* secondary market availability;
* price appreciation;
* financial return;
* passive income;
* yield;
* buyback;
* profit participation;
* revenue share;
* capital appreciation;
* market demand;
* tradability.

Users participate in Super Freak for entertainment, membership, loyalty, community, promotional and fan engagement purposes only.

Any market value attributed by third parties to digital items, NFTs, collectibles, points, badges or rewards is outside the Company’s control and is not promoted, guaranteed or supported by the Company.

The Company may restrict, discourage, suspend or discontinue transferability or secondary market-related features where necessary to preserve the Platform’s non-financial, Web2 gaming and loyalty positioning.

***

### 24) Forward-Looking Statements

This White Paper may contain forward-looking statements, including statements regarding roadmaps, features, partnerships, launches, rewards, adoption, business plans, technology development, market strategy, promotional campaigns or future operations.

Forward-looking statements are based on current assumptions and expectations and are subject to risks, uncertainties and changes. Actual results may differ materially.

The Company does not guarantee that any roadmap, feature, integration, partnership, reward, experience, launch, campaign or business plan will be completed, released or made available.

The Company assumes no obligation to update forward-looking statements, except where required by applicable law.

***

### 25) Liability Limitations and Indemnity

To the maximum extent permitted by applicable law, the Company excludes liability for indirect, incidental, special, punitive, consequential or exemplary damages, including loss of profits, loss of revenue, loss of data, loss of goodwill, business interruption, third-party failures, technical failures, platform downtime, user errors, blockchain errors or loss arising from user misuse of the Platform.

To the maximum extent permitted by law, the Company’s aggregate liability shall be limited to the total amount actually paid by the relevant user directly to the Company in the preceding 12 months, excluding amounts paid to third-party providers, taxes, shipping fees or amounts paid to other users.

Nothing in this White Paper excludes liability that cannot be excluded under applicable law, including liability for fraud, intentional misconduct, death or personal injury caused by negligence, or other non-excludable liabilities.

Users agree to indemnify and hold harmless the Company, its directors, officers, employees, contractors, affiliates, licensors and partners from claims, damages, losses, liabilities, costs and expenses arising from user misuse of the Platform, breach of law, breach of rules, IP infringement, fraud, prohibited conduct, circumvention of restrictions or third-party claims.

The Company is not liable for failure or delay caused by events beyond its reasonable control, including natural disasters, war, terrorism, strikes, regulatory actions, internet outages, blockchain failures, cyberattacks, supplier failures, pandemics, force majeure events or third-party provider failures.

***

### 26) Governing Law, Jurisdiction and Dispute Resolution

This White Paper, the Platform and related policies are governed by the laws of Hong Kong, excluding conflict-of-law rules and international treaties to the extent lawfully excludable.

Subject to mandatory consumer protection rules and applicable law, the courts of Hong Kong shall have exclusive jurisdiction over disputes arising out of or in connection with this White Paper, the Platform and related policies.

Mandatory consumer rights, if applicable, remain unaffected.

Where agreed in specific terms or by separate agreement, disputes may be referred to arbitration administered by the Hong Kong International Arbitration Centre under the HKIAC Administered Arbitration Rules. The seat of arbitration shall be Hong Kong, the language shall be English, and the number of arbitrators shall be one unless otherwise agreed.

To the extent permitted by applicable law, users waive participation in class, collective or representative proceedings.

***

### 27) Tax Notices

The Company’s revenues may be subject to Hong Kong profits tax and, where applicable, foreign direct or indirect taxes depending on the nature of the supply, place of supply, customer status, permanent establishment risk, source of profits and applicable tax rules.

Hong Kong does not generally impose VAT or GST, but foreign VAT, GST, sales tax, use tax, customs duties, withholding tax or other taxes may apply depending on the user’s jurisdiction and the relevant transaction.

Users located outside Hong Kong may be subject to local VAT, GST, sales tax, use tax, customs duties, income tax, capital gains tax, wealth tax, prize tax, withholding tax, reporting duties or other obligations.

Users are solely responsible for determining, reporting and paying any taxes arising from their purchase, sale, holding, transfer, redemption or receipt of rewards, prizes, digital items, memberships or marketplace proceeds.

Nothing in this White Paper constitutes tax advice. Users should seek independent tax advice in their country of residence, citizenship, domicile or business activity.

***

### 28) Hong Kong-Specific Notices

Unless expressly stated otherwise, the Company is not licensed, registered or supervised by the Securities and Futures Commission of Hong Kong as a licensed corporation, virtual asset trading platform operator, securities dealer, investment adviser, asset manager, automated trading service provider or intermediary.

The Company does not operate a virtual asset trading platform, exchange, order book, broker, dealer, investment platform or financial marketplace.

Unless expressly stated otherwise, the Company is not licensed, registered or supervised by the Hong Kong Monetary Authority as a bank, authorized institution, stored value facility issuer, retail payment system operator or fiat-referenced stablecoin issuer.

The Company does not accept deposits from the public, does not issue e-money, does not issue fiat-referenced stablecoins, does not operate payment accounts and does not promise repayment with interest or return.

The Company does not operate gambling, betting, wagering, casino, lottery business or sportsbook services.

Where a specific Hong Kong promotional draw requires a Trade Promotion Competition Licence, the Company may apply for such licence before conducting the promotion.

Except for simple promotional licensing such as a Trade Promotion Competition Licence where applicable, the Company does not intend to obtain or operate under financial, virtual asset, banking, payment, custody, gambling or betting licences.

If any activity, feature, reward, mechanic, digital item, blockchain component, payment flow or promotional campaign is considered to require licensing, registration, approval, exemption or notification under Hong Kong law or foreign law, the Company may modify, restrict, geoblock, suspend, cancel or redesign the relevant activity rather than operate it as a regulated financial, gambling, betting, payment, custody or virtual asset service.

The Platform’s blockchain use is limited to technical transparency, traceability, certification, automation and auditability functions. Such use does not alter the Platform’s Web2 gaming, loyalty, promotional and fan engagement positioning.

***

### 29) Language, Entire Agreement, Official Version and Contact

**Controlling language.**\
Unless otherwise stated, the English version of this White Paper and related terms prevails over translations.

**Entire framework.**\
This White Paper, Terms of Use, Privacy Policy, Cookie Policy, Game Rules, Promotional Rules, Reward Rules, Marketplace Rules and any specific program terms together constitute the applicable framework for the Platform.

**Severability.**\
If any provision is held invalid, unlawful or unenforceable, the remaining provisions remain valid and enforceable.

**Assignment.**\
The Company may assign, transfer or delegate its rights and obligations in connection with a merger, reorganization, sale of assets, corporate restructuring, financing, acquisition or change of control. Users may not assign their rights or obligations without the Company’s prior written consent.

**Updates.**\
The Company may update this White Paper and related policies from time to time. The latest official version published by the Company shall prevail over prior or unofficial versions.

**Official version.**\
The most up-to-date version of the Super Freak White Paper will be made available through the official Super Freak website or official documentation channels.

Versions obtained from third-party websites, unofficial links, screenshots, downloaded copies or outdated repositories may be incomplete, outdated or inaccurate.

Updated versions may override, clarify, supplement or contradict previous versions. Users should always refer to the latest official version before making any decision or using the Platform.

**Contact.**\
For legal notices: **<tech@theloyalty.link>**\
For privacy requests: **<tech@theloyalty.link>**\
For support: **<tech@theloyalty.link>**

Company: **The Loyalty Link Limited**\
Registered office: **2108, Metro Centre 2, 21 Lam Hing Street, Kowloon Bay, Hong Kong**\
Company number: **\[Company Number]**\
Business registration number: **\[Business Registration Number]**