These Platform Terms and who we are
These End-User Platform Terms (the “Platform Terms”) govern your access to and use of the Bundle platform, and your holding, redemption and transfer of Badges. They form a binding contract between you and Bundle Limited (“Bundle”, “we”, “us”), a company incorporated in the Abu Dhabi Global Market with company number 32063.
You accept these Platform Terms when you claim your first Badge. If you do not accept them, you must not claim a Badge and must not use the Bundle platform. Your continued use of the platform after any change notified under clause 21 constitutes acceptance of the amended Platform Terms.
Bundle is not the brand whose campaign led to your Badge. A Member Brand designs and conducts its own campaign, decides which action qualifies for a Badge, and communicates that campaign through its own channels. Bundle issues the Badge, holds the contractual relationship with you from the moment you claim it, and is solely responsible for the Floor Value, the Enhanced Buy-Back and every payment made to you. The Member Brand has no involvement in, authority over, or responsibility for any of those matters.
Bundle pays all amounts due to you from its own corporate revenue account. Bundle does not hold money belonging to any Member Brand, does not hold money belonging to you, and does not make any payment to you on behalf of any other person.
Definitions
- “Badge”
- a non-fungible digital record issued by Bundle to an End User and recorded on a public, independently verifiable and tamper-evident ledger, which is issued upon completion of a Qualifying Action, carries a Floor Value, and may be redeemed or transferred in accordance with these Platform Terms.
- “Bundle Platform”
- the websites, applications, wallet interfaces and related services operated by Bundle through which Badges are claimed, held, redeemed and transferred.
- “Campaign”
- a promotional activity configured by a Member Brand using the Bundle Platform and conducted by that Member Brand through its own channels.
- “Campaign Terms”
- the terms published by a Member Brand with its Campaign, which govern that Campaign and the Qualifying Action.
- “Enhanced Buy-Back”
- an offer made by Bundle at its discretion to purchase a Badge from its holder at an amount exceeding the Floor Value of that Badge, made following a Reward Distribution Event.
- “End User”
- you, being a natural person who claims, holds, redeems or transfers a Badge.
- “Floor Value”
- the amount, expressed in United States dollars, which Bundle will pay to the holder of a Badge on redemption, determined at the point of redemption and displayed to the holder before the holder confirms the redemption in accordance with clause 7, without condition other than verification of identity and account details under clause 10.
- “Member Brand”
- a company or brand that configures a Campaign using the Bundle Platform and conducts it through its own channels.
- “Qualifying Action”
- the action specified by a Member Brand in its Campaign Terms, the completion of which entitles the person completing it to a Badge.
- “Recipient”
- an End User selected at a Reward Distribution Event to receive an Enhanced Buy-Back offer.
- “Reward Distribution Event”
- an event conducted by Bundle at which Badges are selected for an Enhanced Buy-Back offer, the selection being made in the manner described in clause 9.
- “Verifiable Random Function”
- the cryptographic function used by Bundle to produce the selection at a Reward Distribution Event, the output of which is recorded on a public, independently verifiable and tamper-evident ledger.
References to a statute or subsidiary legislation are to the Singapore instrument as amended or replaced from time to time. Headings are for convenience and do not affect interpretation. “Including” and “in particular” are not words of limitation.
Eligibility
You may use the Bundle Platform only if you are:
- a natural person aged 18 years or over, and where the Campaign through which the Badge was issued promotes goods or services which a person of that age could not lawfully purchase, a person of the minimum age at which those goods or services may lawfully be purchased;
- resident in Singapore, or otherwise located in Singapore, at the time you complete a Qualifying Action and claim the Badge issued for it. This paragraph (b) does not apply to a Badge you receive as a gift under clause 11;
- acting on your own behalf and not on behalf of any other person; and
- not a person to whom the provision of these services is prohibited under any applicable law or sanctions regime.
You may not use the Bundle Platform if you are an employee, officer, contractor or agent of Bundle, of any Member Brand whose Campaign you participated in, or of any service provider engaged in the operation of a Campaign or a Reward Distribution Event, or an immediate family member of any such person residing in the same household.
You may hold only one Bundle account. Bundle may close duplicate accounts and may withhold payment in respect of Badges held in a duplicate account.
Bundle verifies age and identity before making any payment. If you cannot satisfy the verification requirements in clause 10, Bundle cannot pay you, and the Badge will remain in your account until verification is completed or the Badge expires under clause 7.6.
Your account and wallet
When you claim your first Badge, Bundle creates an account for you and a wallet controlled through that account. The wallet is provided through a third-party embedded wallet service.
You must give accurate information when creating your account and must keep it current. Bundle may suspend an account and withhold payment where information given is inaccurate, incomplete or cannot be verified.
You must notify Bundle promptly if you believe your account has been accessed without your authority. Bundle is not liable for loss arising from unauthorised access to your account except to the extent caused by Bundle.
Bundle may close your account on thirty days notice. Bundle may close an account immediately without notice in the circumstances set out in clause 18.
Badges
A Badge is a promotional reward. It is issued to you because you completed a Qualifying Action. The issuance, holding and redemption of a Badge can be independently verified.
A Badge is not, and must not be treated by you as:
- an investment, a security, a share, a debenture, a unit in a collective investment scheme, a derivatives contract or any other capital markets product;
- a digital payment token, a medium of exchange, or a means of paying for goods or services provided by any person other than through redemption to Bundle under clause 7;
- a deposit, an account balance, or any form of stored value; or
- an asset with a market price, an expected return, or any value other than the Floor Value and, where applicable, an Enhanced Buy-Back amount offered by Bundle.
Bundle makes no representation that a Badge will appreciate in value. The only amounts you can obtain in respect of a Badge are the Floor Value and, if you are selected under clause 9, an Enhanced Buy-Back amount. There is no secondary market for Badges, and you must not offer, advertise, list or sell a Badge to any person other than Bundle.
You are not required to pay Bundle anything at any time. There is no fee to claim a Badge, to hold a Badge, to redeem a Badge, to take part in a Reward Distribution Event, or to accept an Enhanced Buy-Back offer.
Claiming a Badge
After you complete a Qualifying Action, Bundle sends you an invitation to claim your Badge. Every completed Qualifying Action produces a Badge. There is no selection, no allocation and no element of chance at this stage. If you complete the Qualifying Action, you receive a Badge.
You claim the Badge by following the instructions in the invitation and accepting these Platform Terms. From the point of claim, your relationship in respect of the Badge is with Bundle alone.
You must claim your Badge within the period stated in the invitation. Unclaimed Badges lapse at the end of that period and carry no value thereafter.
Bundle may decline to issue or may cancel a Badge where the Qualifying Action was not genuinely completed, was completed through automated means, was completed in breach of the Campaign Terms, or was reversed, cancelled or refunded.
Floor Value
Every Badge is redeemable and every holder who redeems receives a payment. The amount you receive, the Floor Value, is determined at the moment you redeem. Before you confirm a redemption, Bundle displays the exact amount you will receive, so you always know what you are getting before you decide. The amount is not decided by chance and is not affected by the outcome of any Reward Distribution Event.
You may redeem a Badge at the applicable Floor Value at any time from the moment you claim it until the cut-off time stated in the Campaign Terms. Redemption is unconditional. You do not need to hold the Badge for any period, take part in any event, or reach any threshold.
On redemption, Bundle pays the Floor Value to your nominated Singapore bank account or e-wallet through a licensed payment service provider. Payment is made within ten business days of successful verification under clause 10.
Once a Badge is redeemed it is cancelled. It cannot be reinstated, and it cannot be selected at any later Reward Distribution Event.
If you choose to keep a Badge rather than redeem it, you keep the right to redeem it at the Floor Value at any time before the cut-off described in clause 7.6. You are never required to pay anything in order to keep a Badge. You should note that a Badge which is not redeemed before that cut-off lapses under clause 7.6.
A Badge may be redeemed only during the Campaign cycle in which it was issued. That cycle ends on the date of the Reward Distribution Event held for that Campaign, as stated in the Campaign Terms. You may redeem the Badge at its Floor Value at any time between issuance and the cut-off time stated in the Campaign Terms. Bundle will remind you before the cycle ends. A Badge which has not been redeemed by the end of the cycle, and which is not bought back under clause 8, lapses at that point and carries no value afterwards.
Enhanced Buy-Back
If you keep a Badge instead of redeeming it, the Badge may be selected at a Reward Distribution Event for an Enhanced Buy-Back offer. An Enhanced Buy-Back is an offer by Bundle to buy your Badge from you at an amount greater than its Floor Value.
The Badge that is selected is determined by a Verifiable Random Function, and Bundle cannot predict or control which Badge will be selected. Bundle draws this to your attention expressly so that you understand the nature of the feature before deciding whether to keep a Badge.
An Enhanced Buy-Back is an offer, not an entitlement. If your Badge is selected, Bundle will notify you and state the amount offered and the period within which you may accept. You may accept or decline at your discretion. If you decline, or do not respond within the stated period, you keep your Badge and may redeem it at the Floor Value at any time before the cut-off described in clause 7.6.
Bundle decides whether to hold a Reward Distribution Event, when to hold it, how many Badges to select, and what amount to offer. Bundle is under no obligation to hold any Reward Distribution Event or to make any Enhanced Buy-Back offer to you.
The Enhanced Buy-Back is a feature of the Bundle Platform. It is operated by Bundle alone. No Member Brand decides who is selected, decides what is offered, or has any involvement in it.
How selection is made, notified and published
Selection is made by a Verifiable Random Function whose input and output are recorded on a public, independently verifiable and tamper-evident ledger. The record is public, is timestamped, and can be inspected and verified independently by you, by any other End User, and by any regulator or auditor, at any time.
Every Reward Distribution Event is conducted under Bundle’s supervision and in the presence of a scrutineer who is independent of Bundle and is not otherwise involved in the conduct of the event. The scrutineer is a public accountant registered under the Accountants Act 2004. The scrutineer witnesses the determination and issues a statement in respect of it.
Bundle makes and keeps accurate records of each Reward Distribution Event for at least five years after the determination to which they relate. Those records cover the time, date, location and method of every determination, the distribution of all Enhanced Buy-Backs, and the details of any Enhanced Buy-Back which is not taken up and the manner in which it was dealt with. The scrutineer statement forms part of those records. Bundle makes those records available for inspection by the Gambling Regulatory Authority throughout that period.
Bundle publishes particulars of the results of every Reward Distribution Event, either within seven days after the determination in a major newspaper circulating generally throughout Singapore, or for a minimum period of two months after the determination on the Bundle website. Bundle also obtains a statement from the scrutineer certifying the scrutineer’s witnessing of the event, Bundle’s compliance with the publication requirement, Bundle’s making of the records described in clause 9.4, and Bundle’s compliance with the notification requirement in clause 9.8. That statement forms part of the records kept under clause 9.4. Bundle applies this clause to every Reward Distribution Event whatever the total value of the Enhanced Buy-Backs offered.
At each Reward Distribution Event Bundle also selects a reserve list of Badges, using the same Verifiable Random Function and in the same determination witnessed by the scrutineer. A Badge on the reserve list is used only where a Recipient cannot be contacted using the details held on their account, does not complete verification under clause 10, or declines the Enhanced Buy-Back. In that event the holder of the next Badge on the reserve list is notified and offered the Enhanced Buy-Back in place of the original Recipient.
Bundle does not notify you if your Badge is placed on the reserve list, and does not publish the reserve list. You are notified only if your Badge is reached under clause 9.6. Placement on the reserve list gives you no entitlement, and the Floor Value of your Badge is unaffected whether or not your Badge is reached.
Bundle notifies each Recipient individually, using the contact details held on the Recipient account, within seven days after the determination of the results of the Reward Distribution Event, and arranges without delay for the Enhanced Buy-Back to be given to each Recipient who accepts it.
Bundle retains records of Badge issuance, redemption, Reward Distribution Events and payments for the period stated in clause 9.4 and, where any dispute is outstanding, until that dispute is resolved.
Rewards advertised, displayed or otherwise communicated in connection with any Campaign form part of a shared reward pool made available across the Bundle Platform, and are not reserved for, or allocated exclusively to, Participants who accessed the Bundle Platform through any particular brand or Campaign. A Reward displayed in connection with a given brand or Campaign may accordingly be distributed to a Participant who accessed the Bundle Platform through a different brand or Campaign.
Verification and payment
Before Bundle makes any payment to you, you must complete identity verification through Bundle’s verification provider. This is required to confirm your age, your identity and your entitlement to be paid, and to allow Bundle to meet its obligations under applicable law.
You must provide accurate payment details for a bank account or e-wallet held in your own name. Bundle will not pay to an account held in the name of another person.
Amounts payable to you are expressed in United States dollars. Payments are made through a licensed payment service provider. Where payment is made to you in another currency, the conversion is carried out by the payment service provider or by your bank or e-wallet provider at the rate it applies, and Bundle is not responsible for that rate. Bundle is not responsible for delays, fees or rejections attributable to your bank, your e-wallet provider or the payment service provider, but will use reasonable efforts to assist you in resolving them.
Bundle uses third-party service providers for identity verification, payment processing, hosting, analytics and security, and certain features of the Bundle Platform depend on them. You may be required to satisfy requirements imposed by those providers. Bundle is not responsible for any act, omission, delay or failure of a third-party service provider, except to the extent that responsibility cannot be excluded under applicable law.
Bundle may withhold payment where it reasonably suspects fraud, breach of these Platform Terms, or a legal obligation preventing payment, and will notify you where it is permitted to do so.
Where Bundle notifies you that you are entitled to receive a payment and you do not complete the required verification within sixty (60) days of that notification, Bundle reserves the right to lapse your entitlement to that payment.
You are responsible for any tax payable by you in respect of amounts received from Bundle, and Bundle does not provide tax advice. Bundle will deduct or withhold from any payment any amount it is required by law to deduct or withhold, and will account for that amount to the relevant authority. Where Bundle makes any such deduction it will tell you the amount and the reason for it.
Transferring a Badge
You may transfer a Badge to another person as a gift. The recipient does not need to hold a Bundle account at the time of transfer, and does not need to be located in or resident in Singapore.
A transfer is a gift. You must not sell a Badge, offer a Badge for sale, or accept any consideration for a Badge from any person other than Bundle.
On transfer, the Badge retains its Floor Value and the transferee acquires all rights in respect of it, including the right to redeem it and eligibility for selection at a Reward Distribution Event. You retain no rights in a Badge you have transferred.
To redeem a Badge, or to accept an Enhanced Buy-Back, the holder must hold a Bundle account and complete verification under clause 10. Bundle pays the holder by the methods available in the holder’s country of residence, and payment is subject to any legal restriction applying in that country.
Bundle may limit the number or frequency of transfers, and may refuse or reverse a transfer where it reasonably suspects that the transfer forms part of an arrangement to trade Badges, to circumvent clause 3.3, or otherwise to breach these Platform Terms.
Age and responsible participation
The Bundle Platform is not directed at, and must not be used by, persons below the age in clause 3.1(a). Bundle verifies age before payment and will cancel any Badge and close any account where the holder is below that age.
Bundle does not permit any person to pay to take part in a Reward Distribution Event, and you are never required to pay Bundle any amount. If at any point you are asked to pay in order to keep a Badge, to take part in a Reward Distribution Event, or to receive a payment, the request did not come from Bundle and you should report it to us immediately using the details in clause 22.
If you feel that your use of the Bundle Platform has become difficult to control, you may ask us to close your account and we will do so. Free and confidential support is available in Singapore from the National Council on Problem Gambling, whose current helpline and website are published on its website and are signposted from the Bundle support pages.
Things you must not do
You must not:
- use any automated means, script, bot or emulator to complete Qualifying Actions, claim Badges or interact with the Bundle Platform;
- open or control more than one account, or use another person’s identity or payment details;
- attempt to influence, predict, manipulate or interfere with a Reward Distribution Event or with the Verifiable Random Function;
- sell, offer for sale, list, auction or advertise a Badge, or acquire a Badge for consideration from any person other than Bundle;
- present, describe or promote a Badge to any other person as an investment or as an asset with an expected return;
- complete a Qualifying Action that you know or suspect to involve unlawful activity;
- use any means to disguise your location in order to complete a Qualifying Action or claim a Badge under a Campaign for which you are not eligible; or
- use the Bundle Platform in breach of any applicable law.
If you breach clause 13.1, Bundle may cancel affected Badges, withhold payment, suspend or close your account, and where appropriate report the matter to the competent authorities. Bundle will notify you of the action taken and the reason, unless prevented from doing so by law.
Personal data
Bundle collects and uses your personal data in accordance with the Personal Data Protection Act 2012.
Bundle collects your personal data to create and operate your account, to verify your age and identity, to issue and administer Badges, to conduct Reward Distribution Events, to make payments to you, to meet its legal and regulatory obligations, and to detect and prevent fraud and abuse.
Bundle discloses your personal data to its identity verification provider, its payment service provider, its wallet infrastructure provider, its professional advisers, and any competent authority where required by law. Bundle does not disclose your personal data to any Member Brand.
Bundle transfers personal data outside Singapore to the service providers described in clause 14.3. Bundle takes appropriate steps to ensure that each recipient is bound to provide a standard of protection comparable to that under the Personal Data Protection Act 2012.
You may withdraw consent to the collection, use or disclosure of your personal data, and may request access to or correction of your personal data, by contacting Bundle using the details in clause 22. Withdrawal of consent may prevent Bundle from verifying your identity and therefore from paying you.
Bundle will send you marketing messages only where you have consented or where Bundle is otherwise permitted to do so, and every such message will carry an unsubscribe facility. Bundle observes the Do Not Call provisions of the Personal Data Protection Act 2012.
Bundle may invite you, on a voluntary basis, to allow your name or a statement about your experience to be used in Bundle publicity. You are under no obligation to agree, and your Floor Value, your Enhanced Buy-Back offer and your standing on the Bundle Platform do not depend on whether you agree.
Intellectual property
Bundle and its licensors own all intellectual property in the Bundle Platform, in the Badge artwork and design, and in all associated materials. Nothing in these Platform Terms transfers any such right to you.
Holding a Badge gives you the rights set out in these Platform Terms and nothing more. It does not give you ownership of, or any licence to commercially exploit, any artwork, mark or other content associated with the Badge or with any Member Brand.
You grant Bundle a non-exclusive, royalty-free licence to use any content you submit to the Bundle Platform for the purpose of operating the platform and administering your account.
Availability and third-party services
Bundle aims to keep the Bundle Platform available but does not guarantee uninterrupted availability. Bundle may suspend access for maintenance, security or regulatory reasons, and will give notice where it is practicable to do so.
Badges are recorded on a public, independently verifiable and tamper-evident ledger which Bundle does not own or control. Bundle is not responsible for the operation, availability, congestion, forking or discontinuation of that blockchain.
Bundle relies on third parties for wallet infrastructure, identity verification and payments. Bundle remains responsible to you for the performance of its obligations under these Platform Terms notwithstanding that it performs them through third parties.
Liability
You must indemnify Bundle against any loss, damage, cost or expense, including reasonable legal costs, arising from your breach of these Platform Terms, your misuse of the Bundle Platform, any false or inaccurate information you provide, any unauthorised activity on your account, or any breach by you of applicable law. This clause does not apply to the extent that the loss arises from Bundle’s own breach or negligence, and does not exclude or limit any right you have which cannot be excluded or limited under applicable law.
Nothing in these Platform Terms limits or excludes Bundle’s liability for death or personal injury caused by its negligence, for fraud or fraudulent misrepresentation, or for any liability that cannot lawfully be limited or excluded. Your statutory rights as a consumer, including under the Consumer Protection (Fair Trading) Act 2003 and the Unfair Contract Terms Act 1977, are not affected.
Subject to clause 17.1, Bundle is not liable to you for any loss of profit, loss of opportunity, loss of anticipated saving, or any indirect or consequential loss.
Subject to clause 17.1, Bundle’s total liability to you in respect of all claims arising out of or in connection with these Platform Terms, a Badge, or a Reward Distribution Event is limited to the greater of the aggregate Floor Value of the Badges you held at the time the liability arose and USD 1,000.
Bundle is not liable for the acts or omissions of any Member Brand, for the quality, safety or description of any goods or services supplied by a Member Brand, or for any representation made by a Member Brand about a Campaign that is inconsistent with the Campaign Terms or with these Platform Terms.
Suspension and termination
Bundle may suspend your access to the Bundle Platform, suspend payment, or close your account immediately where it reasonably believes that you have breached clause 3, clause 11 or clause 13, that your account has been compromised, or that continued provision of the service would place Bundle in breach of any law.
You may close your account at any time. Before doing so you should redeem any Badge you hold, because a Badge does not survive closure of the account through which it is held.
Clauses 5, 9.4, 9.9, 14, 15, 17, 19, 20 and 22 survive termination.
Complaints
A Campaign is conducted by the participating brand. Bundle does not manufacture, distribute, import, sell or supply the goods or services promoted, and is not responsible for their quality, safety or fitness for purpose or for any representation made about them. Complaints about the goods or services, about the Qualifying Action or about whether you completed it are matters for the participating brand. Complaints about your account, a Badge, a redemption, a transfer or a Reward Distribution Event are matters for Bundle.
If you are dissatisfied with any aspect of the Bundle Platform, a Badge, a payment or a Reward Distribution Event, contact Bundle using the details in clause 22. Bundle will acknowledge your complaint within five business days and respond substantively within twenty business days.
Transaction records shown on the Bundle Platform are treated as accurate unless you dispute them in writing within fifteen (15) business days of the transaction. Bundle may place a hold on a Badge or an amount which is the subject of a dispute or of suspected fraud for up to thirty (30) days, or for such longer period as is reasonably necessary to complete an investigation, and releases a disputed amount only where the dispute is resolved in your favour.
If your complaint concerns a Campaign, a Qualifying Action, or the goods or services of a Member Brand, you should raise it with that Member Brand. Bundle will assist you in identifying the correct contact.
If your complaint is not resolved to your satisfaction, you may refer it to any consumer dispute resolution or mediation scheme available to you in Singapore, and you may pursue any other remedy available to you. Nothing in these Platform Terms requires you to use any such scheme before bringing proceedings under clause 20, and nothing in them limits your statutory rights.
Governing law and jurisdiction
These Platform Terms and any dispute arising out of or in connection with them, including any non-contractual dispute, are governed by Singapore law.
The courts of Singapore have exclusive jurisdiction. Nothing in this clause affects any right you have to bring proceedings in the courts of the place where you are resident where that right cannot be excluded by agreement.
Bundle is incorporated in the Abu Dhabi Global Market. Bundle submits to Singapore law and to the jurisdiction of the Singapore courts in respect of these Platform Terms, and does not rely on its place of incorporation to displace either.
Changes to these Platform Terms
Bundle may amend these Platform Terms. Bundle will give you at least thirty days notice of any amendment that is materially adverse to you, by email and by notice on the Bundle Platform.
Contacting Bundle
| Purpose | Contact |
|---|---|
| General support and account queries | [email protected] |
| Complaints | [email protected] |
| Personal data requests and data protection officer | [email protected] |
| Registered office | 1405 Addax Port Office Tower, Reem Islands, Abu Dhabi, UAE |
General
These Platform Terms and the Campaign Terms applicable to a Campaign you participated in constitute the entire agreement between you and Bundle in respect of their subject matter. Where the Campaign Terms and these Platform Terms conflict on a matter concerning a Badge, a Floor Value, a Reward Distribution Event or an Enhanced Buy-Back, these Platform Terms prevail.
If any provision of these Platform Terms is found to be invalid or unenforceable, that provision is severed and the remainder continues in effect.
A failure or delay by Bundle in exercising any right under these Platform Terms does not operate as a waiver of that right.
Bundle may assign or novate its rights and obligations under these Platform Terms to any member of its group or to any acquirer of its business, provided that this does not reduce your rights. You may not assign your rights other than by transferring a Badge in accordance with clause 11.
A person who is not a party to these Platform Terms has no right under the Contracts (Rights of Third Parties) Act 2001 to enforce any of their provisions.
Schedule
Regulatory Notice
Badges are issued, and Reward Distribution Events are conducted, by Bundle Limited. The selection of Badges at a Reward Distribution Event involves an element of chance.
Bundle conducts this activity in reliance on the class licence conferred by Part 3 of the Gambling Control (Trade and Other Promotional Games and Lotteries - Class Licence) Order 2022. That class licence applies automatically on satisfaction of the qualifying criteria in that Order. No application to, registration with, or approval from the Gambling Regulatory Authority or any other authority is required for it, and none has been sought or obtained.
Nothing in this notice is to be read as an approval, endorsement or authorisation of Bundle, of any Member Brand, or of any Campaign by the Gambling Regulatory Authority or by any other authority.
There is no charge to claim, hold or redeem a Badge, and no charge to take part in a Reward Distribution Event.