Saturn Points Program Terms and Conditions
Effective Date: 05/11/2026
Last Updated: 11/08/2026
These Saturn Points Program Terms and Conditions (“Points Program Terms” or “Terms”) govern Saturn’s points programs, including programs operated during Season 1 and Season 2, and any future points programs or seasons that Saturn expressly designates as subject to these Terms.
These Terms supplement the Saturn Terms and Conditions, the Saturn Privacy Policy, and any other applicable Saturn terms, policies, rules, or disclosures. The relationship between these documents is described in Section 4.
By participating in a covered Program, undertaking Qualifying Activity, accepting Points, generating or sharing a Referral Code, referring another person, using a Referral Code, or otherwise engaging with a covered Program, you agree to these Terms and the applicable Program Rules.
Provisions concerning referrals apply where a Program offers a referral component and to participants acting in the relevant referral capacity. Participation in a points program does not, by itself, make you a Referrer or Referred User.
1. Definitions
For purposes of these Terms:
“Account” means a Saturn user account in good standing.
“Affiliate” means any entity that directly or indirectly controls, is controlled by, or is under common control with Saturn.
“AML Requirements” means any anti-money laundering, counter-terrorist financing, anti-corruption, anti-bribery, financial crime, sanctions, export-control, identity-verification, fraud-prevention, or similar requirements, policies, procedures, or controls adopted by Saturn or required by applicable law.
“Eligible Participant” means a person who satisfies all eligibility requirements applicable to the relevant Program under these Terms, the Saturn Terms, the applicable Program Rules, and any other applicable Saturn policies.
“Excluded Jurisdiction” means, for a particular Program, any jurisdiction in which participation is prohibited or restricted under applicable law, the Saturn Terms, the applicable Program Rules, or an official restriction published by Saturn. For participation in a Referral Program, Excluded Jurisdictions additionally include the United States, the European Economic Area, the United Kingdom, Canada, Singapore, Hong Kong, the People’s Republic of China, and any Sanctioned Jurisdiction.
“KYC” means know-your-customer, customer identification, identity verification, diligence, screening, and related compliance checks required or requested by Saturn.
“Participant” means a person who participates in a covered Program, including, where applicable, a Referrer or Referred User.
“Points” or “Saturn Points” means non-transferable, non-redeemable, off-chain promotional points awarded or recorded under a Saturn points program covered by these Terms. Points include points associated with Season 1, Season 2, and any future program or season that Saturn expressly designates as covered by these Terms. Different types of Points may remain subject to different calculation methods, rules, and treatment.
“Points Program” or “Program” means a Saturn points program or season covered by these Terms, including any referral component that Saturn offers as part of that program or season.
“Program Period” means the period during which a particular Program, season, campaign, qualifying activity, or referral offer is active, as specified in the applicable Program Rules or otherwise determined and communicated by Saturn.
“Program Rules” means the official rules, terms, criteria, schedules, and disclosures that Saturn publishes or expressly incorporates for a particular Program, season, campaign, or referral offer. Program Rules may address qualifying activities, calculation methods, earning rates, referral bonuses, attribution, caps, eligibility requirements, registration requirements, deadlines, and other program-specific matters. They include the earning and referral mechanics previously published by Saturn for the relevant Program Period, subject to any valid amendments.
“Prohibited Person” means any person or entity that Saturn determines is not permitted to participate in the relevant Program, including any person or entity that is:
(a) located, organized, resident, domiciled, or ordinarily resident in an Excluded Jurisdiction applicable to that Program;
(b) subject to sanctions administered or enforced by any applicable sanctions authority;
(c) listed on, owned or controlled by a person listed on, or acting on behalf of a person listed on, any sanctions or restricted-party list;
(d) prohibited from participating under applicable law;
(e) a minor or otherwise lacking legal capacity;
(f) using a VPN, proxy, false identity, nominee, or other method to evade eligibility controls; or
(g) otherwise determined by Saturn to present legal, regulatory, compliance, fraud, reputational, or platform-integrity risk.
“Promotional Content” means statements, posts, messages, advertisements, websites, videos, audio, or other materials used to promote a Program, Referral Code, or referral opportunity.
“Qualifying Activity” means activity by an Eligible Participant that Saturn determines qualifies for Points under the applicable Program Rules, product terms, or other official rules expressly applicable to that activity.
“Qualifying Referral” means a referral that satisfies all applicable requirements in Section 8 and the relevant Program Rules.
“Referred User” means an Eligible Participant who is referred to Saturn through a valid Referral Code and satisfies the requirements for a Qualifying Referral.
“Referrer” means an Eligible Participant who receives a Referral Code and refers another eligible person to Saturn under a Referral Program.
“Referral Code” means a unique referral link, code, or other referral mechanism issued by Saturn to a Referrer.
“Referral Program” means a referral component expressly offered by Saturn under a covered Program. A Program does not include a referral component unless Saturn expressly offers one.
“Sanctioned Jurisdiction” means any country, region, territory, or jurisdiction subject to comprehensive sanctions or embargoes administered or enforced by the United States, the United Kingdom, the European Union, the United Nations, or any other applicable sanctions authority.
“Saturn Terms” means the Saturn Terms and Conditions (https://saturn.credit/legal/terms-conditions), as amended from time to time.
“Wallet” means a blockchain wallet address used in connection with a Program or to which Saturn attributes relevant activity or Points.
2. The Programs
These Terms govern the covered points programs operated by Saturn Holdings Ltd. (“Saturn,” “we,” “us,” or “our”).
A Program may permit Eligible Participants to receive Points in connection with Qualifying Activity on or through the Saturn platform (the “Platform”). Where expressly offered, a Program may also permit Eligible Participants to receive Points in connection with Qualifying Referrals.
These Terms cover programs operated during Season 1 and Season 2 and future programs or seasons that Saturn expressly designates as subject to these Terms.
Each Program may have its own Program Rules. Participation in one Program does not automatically establish eligibility for another Program, season, campaign, referral offer, or event.
Referring to different point types collectively as “Points” does not combine their balances, establish equal value or treatment, create an exchange or conversion ratio, or require Saturn to treat them identically.
Including an existing Program or season within these Terms does not, by itself, change its previously applicable earning formulas, referral rates, attribution rules, or recorded balances. Any adjustment or amendment remains subject to the applicable terms, Sections 5 and 21, and applicable law.
3. Acceptance
By participating in a Program, including by undertaking Qualifying Activity, accepting Points, generating or sharing a Referral Code, or using a Referral Code, you acknowledge that you have read, understood, and agree to be bound by:
(a) these Terms;
(b) the applicable Program Rules;
(c) the Saturn Terms;
(d) the Saturn Privacy Policy; and
(e) where applicable, your Participation Agreement or other agreement with Saturn.
If you do not agree to the applicable terms, you must not participate in the relevant Program.
Participation in a completed season, or the existence of a historical Points balance, does not by itself establish acceptance of subsequently introduced obligations. The application of updates remains subject to applicable notice, acceptance, and legal requirements.
4. Relationship to Other Agreements
These Terms supplement and do not replace the Saturn Terms, the Saturn Privacy Policy, or any other applicable agreement between you and Saturn.
The following principles apply when interpreting these documents:
(a) Mandatory applicable law takes precedence over any inconsistent contractual provision.
(b) Program Rules control the program-specific mechanics they expressly address, including qualifying activities, calculation methods, earning rates, referral bonuses, attribution, caps, Program Periods, and registration deadlines.
(c) Program Rules may establish additional eligibility requirements. They do not waive restrictions imposed by applicable law or the Saturn Terms merely because those restrictions are not repeated.
(d) These Terms control other matters specific to the covered points programs if they conflict with the Saturn Terms.
(e) Separate terms expressly applicable to a token allocation, distribution, claim, or other event govern that event. These Terms do not themselves create rights under such an event.
(f) The Saturn Terms continue to govern access to and use of Saturn’s services generally.
A Program Rule concerning Points, an earning rate, or a referral bonus must not be interpreted as creating a token entitlement or overriding applicable legal, sanctions, KYC, AML, or geographic restrictions.
5. Modification of Terms
Saturn may modify these Terms or the applicable Program Rules by posting an updated version on its website or through the official channel used for the relevant Program and, where required by applicable law, providing notice to participants.
Updates will take effect on the date stated in the applicable notice or updated document, subject to any notice or acceptance requirements imposed by applicable law.
Your continued participation after an update takes effect constitutes acceptance of the revised terms to the extent permitted by applicable law.
Changes affecting earlier activity or historical Points remain subject to Section 21 and applicable law. Publication of an updated document does not, by itself, establish that an amendment validly applies to earlier activity.
6. Eligibility
Participation in a Program is available only to Eligible Participants.
To participate, you must:
(a) be at least the age of majority in your jurisdiction of residence and satisfy any minimum-age requirement in the Saturn Terms;
(b) have full legal capacity to agree to these Terms;
(c) maintain an Account in good standing where an Account is required for the relevant Program;
(d) satisfy all applicable eligibility, KYC, AML, sanctions-screening, fraud-prevention, and compliance requirements required by Saturn;
(e) not be a Prohibited Person;
(f) not be located, incorporated, resident, domiciled, ordinarily resident, or accessing the relevant Program from an applicable Excluded Jurisdiction;
(g) not use a VPN, proxy, nominee, agent, false identity, inaccurate information, or other method to evade geographic, identity, or eligibility restrictions;
(h) comply with these Terms, the applicable Program Rules, the Saturn Terms, and applicable law; and
(i) satisfy any additional eligibility requirements established for the relevant Program.
Referrers and Referred Users must maintain Accounts in good standing and satisfy the eligibility requirements applicable to the Referral Program.
Saturn may require participants to complete eligibility, identity-verification, KYC, AML, sanctions-screening, fraud-prevention, and compliance checks before Points are awarded, confirmed, or considered for any separate event.
Saturn may require both the Referrer and the Referred User to complete the same or substantially similar checks before a referral is treated as a Qualifying Referral.
Saturn may determine eligibility in its sole discretion and may deny, suspend, revoke, reverse, or withhold Points if Saturn determines that a person is not eligible or has violated the applicable terms.
By participating in a Referral Program, and throughout that participation, each Referrer represents, warrants, and covenants that:
(a) the Referrer is not a Prohibited Person and is not acting, directly or indirectly, on behalf of, or for the account or benefit of, a Prohibited Person;
(b) the Referrer is not soliciting, and will not solicit, refer, target promotion to, or knowingly accept referrals from, any Prohibited Person, and has no reason to believe that a Referred User introduced by the Referrer is a Prohibited Person;
(c) the Referrer is not engaged in, and will not engage in, any “directed selling efforts” within the meaning of Rule 902(c) of Regulation S under the U.S. Securities Act of 1933, as amended, with respect to any securities or other interests of Saturn or its Affiliates;
(d) the Referrer is not, and will not hold itself out as, a broker, dealer, investment adviser, finder, solicitor, promoter, agent, representative, employee, partner, joint venturer, or fiduciary of Saturn, and is not entitled to act on behalf of Saturn;
(e) the Referrer is not registered, and is not required to be registered, with a governmental authority by reason of participating in the Referral Program;
(f) the Referrer’s participation does not and will not violate any law, regulation, rule, contract, court order, or other applicable obligation;
(g) all information the Referrer provides to Saturn is and will remain true, accurate, complete, and current; and
(h) the Referrer will comply with these Terms, the applicable Program Rules, the Saturn Terms, and applicable law.
Each Referrer reaffirms these representations and warranties whenever the Referrer shares a Referral Code, posts Promotional Content, or accepts referral-related Points.
A breach of these representations or warranties constitutes a breach of these Terms, including for purposes of Section 22 and Section 30.
7. Program Overview
Eligible Participants may receive Points through Qualifying Activity specified in the applicable Program Rules.
The applicable Program Rules determine:
(a) which activities qualify;
(b) how Points are calculated and attributed;
(c) applicable earning rates, multipliers, bonuses, and caps;
(d) relevant Program Periods and deadlines;
(e) any Account or Wallet requirements; and
(f) whether a referral component is offered and, if so, its applicable rates and conditions.
Where a Referral Program is offered, an eligible Referrer may receive Points based on qualifying activity or Points earned by eligible users they directly refer, as specified in the applicable Program Rules.
Any bonus for a Referred User must also be expressly specified in those Program Rules.
These Terms do not establish a universal referral percentage, bonus percentage, earning rate, or multiplier. Rates published for one Program or season do not automatically apply to another.
For an existing Program, the earning and referral mechanics previously published by Saturn for the relevant Program Period remain part of the applicable Program Rules unless validly amended. The adoption of these general Terms does not, by itself, change those mechanics.
A Referral Program has one referral layer only. Referrers may receive referral-related Points only in respect of eligible users they directly refer. Referrers will not receive Points or other benefits based on referrals made by their Referred Users, downstream referrals, sub-referrals, teams, networks, pools, groups, or other indirect referral activity.
No person is entitled to Points merely for recruiting, inviting, or referring another person. Referral-related Points may be awarded only if the Referred User independently satisfies the applicable eligibility requirements and completes bona fide Qualifying Activity.
8. Qualifying Referrals
Where a Referral Program is offered, a referral will be a Qualifying Referral only if all applicable conditions below are satisfied:
(a) the Referrer is an Eligible Participant and maintains an Account in good standing;
(b) the Referred User is an Eligible Participant and maintains an Account in good standing;
(c) the Referred User is not a Prohibited Person;
(d) the Referred User is not located, resident, incorporated, organized, or accessing the Program from an applicable Excluded Jurisdiction;
(e) the Referred User uses the Referrer’s valid Referral Code in the manner required by Saturn;
(f) the Referral Code is used before the Referred User creates an Account or within another referral attribution window expressly specified by Saturn;
(g) the Referred User completes required eligibility, KYC, AML, sanctions-screening, fraud-prevention, and compliance checks to Saturn’s satisfaction;
(h) the Referred User engages in bona fide Qualifying Activity;
(i) the referral does not involve self-referral, duplicate accounts, fraudulent accounts, Sybil accounts, bot accounts, nominee accounts, controlled accounts, coordinated accounts, or other abusive activity;
(j) the referral is not generated through spam, misleading promotion, paid advertising, unauthorized incentives, deceptive marketing, mass messaging, unlawful scraping, bots, or other prohibited conduct;
(k) neither the Referrer nor the Referred User has violated these Terms, the applicable Program Rules, or the Saturn Terms; and
(l) Saturn determines, in its sole discretion, that the referral qualifies.
Saturn’s determination of whether a referral is a Qualifying Referral is final and binding, except to the extent prohibited by applicable law.
These referral conditions do not require non-referral activity to involve a Referrer, Referred User, or Referral Code.
9. Program and Referral Caps
Saturn may impose additional caps, limits, throttles, eligibility rules, attribution rules, or anti-abuse controls, including:
(a) a maximum number of Referred Users per Referrer;
(b) a maximum amount of referral-related Points per Referrer;
(c) a maximum amount of bonus Points per Referred User or other Participant;
(d) a maximum amount of total Points that may be earned through a Program;
(e) daily, weekly, monthly, seasonal, geographic, Account-level, device-level, IP-level, Wallet-level, or household-level limits; and
(f) other limits Saturn determines are appropriate for legal, regulatory, fraud-prevention, platform-integrity, or operational reasons.
Any applicable cap applies regardless of the number of Accounts, Wallets, devices, identities, handles, addresses, links, campaigns, or referral methods used by a person.
10. No Multi-Level Marketing, Pyramid, or Network Compensation
Referral Programs are intended to reward limited, direct, eligible referrals associated with bona fide user activity. They are not multi-level marketing programs, pyramid programs, chain-referral programs, investment programs, revenue-sharing programs, passive-income programs, or compensation plans.
Participants engaging in referral activity may not:
(a) receive benefits for indirect, downstream, second-level, team, pool, network, or sub-affiliate referrals;
(b) receive benefits merely for recruiting, inviting, enrolling, or signing up another person;
(c) require or request payment, investment, purchases of tokens or digital assets, purchases of securities, or fees from another person as a condition of participating in the Referral Program;
(d) represent that a Program provides passive income, investment returns, yield, guaranteed rewards, guaranteed airdrops, guaranteed token allocations, or future monetary value;
(e) organize referral pools, referral farms, paid sign-up groups, Sybil networks, or similar structures;
(f) sell, rent, trade, broker, assign, sublicense, or otherwise commercialize Referral Codes or referral opportunities; or
(g) make statements or take actions that characterize a Program as a pyramid, MLM, investment, income, compensation, or network-marketing opportunity.
Saturn may disqualify participants, withhold or reverse Points, terminate Accounts, or take other appropriate action if referral activity resembles or contributes to a multi-level marketing, pyramid, chain-referral, abusive, deceptive, or unlawful scheme.
11. Saturn Points
Points are promotional points maintained by Saturn for internal tracking purposes only. Points are not digital assets, tokens, securities, commodities, stored value, e-money, fiat currency, virtual currency, payment instruments, deposits, property, or financial instruments.
Points:
(a) have no monetary value;
(b) are not transferable;
(c) are not redeemable for cash or any other asset;
(d) may not be sold, exchanged, assigned, pledged, hypothecated, brokered, lent, rented, sublicensed, or otherwise transferred;
(e) do not confer ownership, equity, governance, voting, dividend, revenue-sharing, profit-sharing, liquidation, redemption, claim, or creditor rights;
(f) do not represent a right to receive any token, digital asset, security, commodity, or other asset;
(g) do not represent an investment in Saturn or any project, protocol, product, or ecosystem;
(h) may be modified, reduced, reversed, suspended, discontinued, expired, or cancelled as described in the applicable terms; and
(i) may be subject to additional rules, eligibility requirements, caps, exclusions, or adjustments established by Saturn.
Saturn may determine, calculate, adjust, reconcile, or correct Points in its sole discretion, subject to the applicable terms and applicable law.
Displayed Points may be provisional, estimated, pending, subject to reconciliation, or subject to further eligibility and anti-abuse review.
No participant may rely on a Points balance as final, vested, guaranteed, accrued, payable, redeemable, or legally enforceable unless Saturn expressly states otherwise in writing.
References to Points being “earned” or “awarded” describe program accounting and do not create a right to payment, redemption, or another benefit.
12. No Token Rights or Token Allocation Commitment
Participation in a Program, accrual of Points, or registration of a Wallet does not, by itself, entitle any person to receive a token or other asset.
Neither these Terms nor participation in a Program constitutes a promise or commitment by Saturn to conduct a token generation event, token launch, distribution, airdrop, allocation, sale, listing, or other token-related event.
Any token-related event that Saturn announces or conducts is subject to its separately applicable terms, conditions, eligibility criteria, legal requirements, regulatory analysis, sanctions screening, KYC, tax review, and restrictions.
Points may be considered, may be only one factor considered, or may be disregarded entirely in connection with such an event.
Saturn may determine, in its sole discretion and subject to applicable terms and law, that some or all Points will not be relevant to a token allocation, distribution, or other event. Saturn may also determine that particular persons, jurisdictions, Accounts, Wallets, or activity types are ineligible regardless of Points balances.
Where Saturn requires Wallet registration in connection with Points, you must register the Wallet that earned the relevant Points. Registering a different Wallet does not, by itself, transfer Points or any associated eligibility to that Wallet.
Registration does not guarantee eligibility, an allocation, or a token claim. A registration receipt records the submitted registration; it does not establish an entitlement to tokens or other assets.
Participants may not state, imply, or suggest that Points guarantee or create a right to a token, airdrop, allocation, distribution, investment return, monetary value, or financial benefit.
Nothing in this Section modifies rights or obligations expressly established under separately applicable terms for a particular token-related event.
13. Referral Codes
Saturn may issue a Referral Code to an eligible Referrer. Referral Codes are owned or controlled by Saturn and may be modified, disabled, suspended, revoked, or reissued at any time.
A Referrer may share a Referral Code only in accordance with these Terms, the applicable Program Rules, and applicable law.
A Referrer is responsible for all use of their Referral Code and all statements, claims, posts, messages, websites, advertisements, and other materials associated with it.
Saturn may refuse to attribute a referral if:
(a) the Referral Code was not used properly;
(b) the Referred User had already created an Account and the applicable Program Rules do not permit later attribution;
(c) the Referred User used another referral code or attribution method;
(d) multiple Referrers claim attribution for the same user;
(e) the referral was generated through prohibited conduct;
(f) the referral failed applicable eligibility, KYC, AML, sanctions-screening, fraud-prevention, or anti-abuse review; or
(g) Saturn determines that attribution would be inaccurate, abusive, unlawful, or inconsistent with the applicable Program Rules.
Saturn is not responsible for lost, delayed, misdirected, corrupted, malfunctioning, blocked, incomplete, inaccurate, or improperly attributed Referral Codes, clicks, referrals, sign-ups, Accounts, or Points.
14. Referrer Disclosure Obligations
A Referrer who publicly or privately promotes Saturn, a Referral Program, Points, a Referral Code, or any Saturn product or service must clearly and conspicuously disclose their participation in the Referral Program and the nature and amount or formula of the potential referral benefit.
The disclosure must be made in each promotional communication where the audience may not reasonably understand that the Referrer may receive a benefit.
The disclosure must be difficult to miss, easily understandable, and placed close to the referral claim or Referral Code.
The disclosure must accurately identify the applicable benefit and rate or calculation method under the relevant Program Rules. A Referrer must not present a rate from another Program or season as applicable.
For character-limited platforms, a Referrer may use a shorter disclosure if it is clear, conspicuous, and sufficient under applicable law, such as:
Referral disclosure: I may earn Saturn Points if you use my link. Points have no cash value and do not guarantee tokens.
A short-form disclosure does not excuse disclosure of the applicable rate or formula where required by applicable law or Saturn’s instructions.
Where a recognized advertising marker such as “#ad” is used, it must appear before any “more” cutoff or link-preview boundary and must be accompanied by an explanation of the referral relationship where required.
A Referrer may not hide a required disclosure in a profile biography, terms page, hashtag string, image alt text, link preview, comment thread, or another location users are unlikely to notice.
A disclosure such as “#partner,” “#ambassador,” “#thanks,” “#Saturn,” “not financial advice,” or “DYOR” alone is not sufficient.
If a communication is visual, the disclosure must appear visually. If a communication is audible, the disclosure must be audible. If a communication is both visual and audible, the disclosure should appear in both forms.
Saturn may require Referrers to use specific disclosure language, remove or correct non-compliant content, provide copies or records of promotional materials, or cease promotional activity.
15. Marketing and Promotional Conduct
Referrers must ensure that all statements about Saturn, a Program, Points, and Referral Codes are truthful, accurate, not misleading, capable of substantiation, and consistent with official Saturn materials.
Referrers may not:
(a) state or imply that Points have monetary value;
(b) state or imply that Points are transferable or redeemable;
(c) state or imply that Points guarantee a token allocation, airdrop, distribution, payment, return, profit, yield, or other financial benefit;
(d) state or imply that participation is an investment opportunity;
(e) use terms such as “profit,” “return,” “yield,” “passive income,” “free money,” “guaranteed airdrop,” “guaranteed allocation,” “risk-free,” or “token entitlement” to mischaracterize a Program;
(f) make price predictions, valuation claims, exchange claims, or liquidity claims in connection with referral promotion;
(g) make false, misleading, unauthorized, or unsubstantiated claims about a token’s existence, launch, listing, distribution, or availability, or misrepresent official Saturn announcements;
(h) claim or imply that Saturn endorses the Referrer or the Referrer’s statements;
(i) impersonate Saturn or any employee, representative, partner, investor, affiliate, or agent;
(j) use Saturn trademarks, logos, branding, images, names, domains, handles, or other identifiers except as expressly authorized;
(k) create websites, landing pages, social-media accounts, groups, channels, advertisements, or other materials that misleadingly suggest they are official Saturn materials;
(l) make false, exaggerated, or misleading claims about Saturn, its products, its roadmap, its regulatory status, its investors, its partners, or its business;
(m) provide financial, investment, legal, tax, accounting, or regulatory advice in connection with referral promotion;
(n) target, solicit, or onboard persons in applicable Excluded Jurisdictions;
(o) use paid advertising, sponsored posts, influencer campaigns, affiliate networks, ad networks, or paid traffic sources for referral promotion;
(p) use spam, mass direct messages, unsolicited emails, auto-posting, bots, scraping, fake engagement, purchased followers, engagement pods, or deceptive growth tactics;
(q) offer side payments, rebates, discounts, tokens, assets, cash, gifts, or other incentives to induce use of a Referral Code;
(r) engage in harassment, abusive conduct, unlawful conduct, hate speech, deceptive conduct, or conduct that may harm Saturn’s reputation; or
(s) violate applicable platform rules, advertising rules, consumer-protection rules, financial-promotion rules, securities laws, privacy laws, or other applicable laws.
Saturn may monitor promotional activity and require the removal, correction, or modification of content related to a Referral Program.
16. No Endorsement of Third-Party Content
Saturn does not endorse and is not responsible for posts, replies, quote tweets, comments, messages, videos, websites, groups, chats, advertisements, or other content created by Referrers, Referred Users, or other third parties.
Only statements made by Saturn through official Saturn channels should be considered official Saturn communications.
Participants should not rely on third-party statements regarding Saturn, Points, a Program, a token, or a potential allocation or distribution as statements made or authorized by Saturn.
Saturn may report, request removal of, or disassociate from third-party content that it determines is false, misleading, unlawful, non-compliant, reputationally harmful, or inconsistent with the applicable terms.
17. Prohibited Conduct
Participants may not engage in conduct that Saturn determines is abusive, fraudulent, misleading, unlawful, manipulative, or inconsistent with the integrity of a Program.
Prohibited conduct includes:
(a) self-referrals;
(b) referring yourself through multiple Accounts, Wallets, devices, identities, or nominees;
(c) creating or controlling multiple Accounts to generate Points in violation of applicable Program Rules or anti-abuse requirements;
(d) using bots, scripts, automation, emulators, device farms, click farms, account farms, or Sybil techniques to manipulate participation or Points;
(e) using VPNs, proxies, remote desktops, false geolocation, false identity information, or other means to evade eligibility or geographic restrictions;
(f) buying, selling, renting, lending, assigning, transferring, or brokering Accounts, Referral Codes, identities, Wallets, or Points in connection with prohibited program activity;
(g) coordinating with others to fabricate Qualifying Activity;
(h) using stolen, false, misleading, or unauthorized identity or account information;
(i) exploiting bugs, technical vulnerabilities, pricing errors, display errors, attribution errors, or other system errors;
(j) manipulating, gaming, or abusing Saturn products, campaigns, Points formulas, referral attribution, or eligibility systems;
(k) submitting false, incomplete, or misleading information to Saturn;
(l) violating applicable laws or third-party rights;
(m) engaging in phishing, malware, credential harvesting, wallet draining, spoofing, impersonation, or social engineering;
(n) targeting persons who are not eligible to participate;
(o) using a Program for unlawful gambling, sweepstakes, lottery, prize promotion, or contest activity;
(p) using a Program for money laundering, terrorist financing, sanctions evasion, fraud, market manipulation, or other unlawful activity; or
(q) assisting, enabling, encouraging, or facilitating any of the foregoing.
Saturn may interpret prohibited conduct broadly to protect the integrity of its Programs and Platform, subject to applicable law.
18. Compliance, KYC, AML, and Sanctions Screening
Saturn may require a Participant to provide information or documentation requested for eligibility, KYC, AML, sanctions-screening, fraud-prevention, tax, legal, regulatory, or compliance purposes.
Saturn may screen participants against sanctions lists, restricted-party lists, politically exposed person databases, adverse media, geographic-risk indicators, device-risk indicators, Wallet-risk indicators, and other compliance or risk sources.
Saturn may deny, suspend, restrict, terminate, or reverse participation if it determines that a Participant:
(a) is a Prohibited Person;
(b) is located in, resident in, organized in, or accessing the relevant Program from an applicable Excluded Jurisdiction;
(c) is subject to sanctions or other legal restrictions;
(d) fails required KYC, AML, sanctions-screening, fraud-prevention, or compliance checks;
(e) provides inaccurate, incomplete, misleading, or unverifiable information;
(f) presents legal, regulatory, compliance, fraud, security, platform-integrity, or reputational risk; or
(g) otherwise violates the applicable terms.
Saturn may withhold, freeze, cancel, reverse, or claw back Points while conducting compliance, sanctions, fraud, or eligibility reviews, subject to applicable terms and law.
19. Geographic Restrictions
Participants must comply with the geographic restrictions applicable to the relevant Program under applicable law, the Saturn Terms, these Terms, and the applicable Program Rules.
Referral Programs are not available to persons or entities in the United States, the European Economic Area, the United Kingdom, Canada, Singapore, Hong Kong, the People’s Republic of China, any Sanctioned Jurisdiction, or another jurisdiction designated as excluded for the relevant Referral Program.
Participants may not access or participate in a Program from a jurisdiction excluded for that Program.
Referrers may not refer persons located in, resident in, incorporated in, organized in, or accessing the Referral Program from an applicable Excluded Jurisdiction.
Saturn may use IP address checks, device data, geolocation tools, identity data, residency information, blockchain analytics, payment data, Wallet data, Account data, attestations, and other information to determine geographic eligibility.
A person who relocates to or becomes resident in a jurisdiction excluded for a Program must stop participating in that Program and notify Saturn. Saturn may suspend, restrict, terminate, or cancel participation if a Participant becomes ineligible.
Saturn may modify geographic restrictions, subject to applicable law and any applicable notice requirements.
20. Tax Matters
Participants are solely responsible for determining and satisfying tax obligations arising from participation in a Program, receipt or accrual of Points, or related activity.
Saturn does not provide tax advice. Participants should consult their own tax advisors regarding the tax consequences of participation.
Saturn may request tax forms, certifications, or other information. Saturn may report information to tax authorities, withhold amounts, suspend participation, or take other actions if it determines that tax reporting, withholding, or compliance obligations apply.
The absence of tax reporting or withholding by Saturn does not mean that no tax obligations apply.
21. Program Changes, Suspension, and Termination
Saturn may modify, suspend, restrict, extend, shorten, or terminate a Program at any time, with or without notice, subject to applicable law and any applicable notice requirements.
Saturn may make changes prospectively or retroactively where it determines that retroactive changes are necessary or appropriate for legal, regulatory, compliance, fraud-prevention, security, technical, platform-integrity, or fairness reasons, to the extent permitted by applicable law and the terms applicable to the affected activity.
A change to one Program or season does not automatically change another Program or season unless Saturn expressly states that it does and the change is validly made.
To the maximum extent permitted by applicable law, Saturn is not liable for a modification, suspension, restriction, or termination of a Program or resulting loss, reduction, cancellation, or non-accrual of Points.
22. Withholding, Reversal, Cancellation, and Clawback
Saturn may withhold, deny, reduce, reverse, cancel, expire, or claw back Points if it determines that:
(a) the Points were awarded in error;
(b) for referral-related Points, the underlying referral was not a Qualifying Referral;
(c) the underlying activity was not Qualifying Activity;
(d) the Participant, or a Referrer or Referred User relevant to the award, was not eligible;
(e) a person required to complete KYC, AML, sanctions-screening, fraud-prevention, or compliance checks failed those checks;
(f) the Points resulted from prohibited conduct;
(g) the Participant violated these Terms, the applicable Program Rules, or the Saturn Terms;
(h) the Participant made false or misleading promotional claims;
(i) a Participant subject to referral disclosure obligations failed to provide required disclosures;
(j) the Participant engaged in conduct creating legal, regulatory, compliance, reputational, or platform-integrity risk;
(k) a technical, attribution, calculation, display, or system error occurred; or
(l) withholding, reversal, cancellation, expiration, or clawback is otherwise necessary or appropriate under applicable law or applicable Saturn policy.
Referral-specific conditions apply to referral-related Points and participants acting in the relevant referral capacity.
Saturn may take these actions without compensation, payment, replacement, or liability, to the maximum extent permitted by applicable law.
23. Communications and Notices
Saturn may provide notices regarding a Program by posting on its website, posting through official Saturn channels, updating these Terms or Program Rules, sending email or in-app notifications, or using another appropriate method, subject to applicable legal notice requirements.
Participants are responsible for reviewing applicable terms and official Saturn communications regularly.
Third-party statements, unofficial social-media posts, community messages, comments, replies, quote tweets, or other unofficial materials do not modify these Terms or the applicable Program Rules.
24. Privacy
Saturn may collect, use, disclose, and retain personal information in connection with a Program as described in the Saturn Privacy Policy and other applicable privacy notices.
Participation may involve processing Account information, identity-verification information, referral attribution data, device data, IP addresses, location indicators, compliance-screening data, fraud-risk indicators, Wallet information, registration information, and activity data.
Saturn may disclose information to service providers, compliance vendors, analytics providers, fraud-prevention providers, identity-verification providers, sanctions-screening providers, professional advisors, regulators, law enforcement, tax authorities, or other persons as described in the applicable privacy notices and permitted by law.
Participants may not collect, use, share, sell, scrape, or otherwise process personal information of prospective Referred Users except in compliance with applicable privacy and data-protection laws.
25. Intellectual Property
Saturn and its licensors retain all rights, title, and interest in Saturn’s names, trademarks, service marks, logos, trade dress, domain names, social-media handles, content, software, technology, products, services, and other intellectual property.
Participation in a Program does not grant a license or right to use Saturn intellectual property except as expressly authorized, including any limited permission to share a valid Referral Code in accordance with the applicable terms.
Participants may not:
(a) register or use domain names, business names, social-media handles, usernames, keywords, advertisements, search terms, application names, or other identifiers containing or confusingly similar to Saturn marks;
(b) imply affiliation, sponsorship, approval, endorsement, agency, employment, or partnership with Saturn without authorization;
(c) modify Saturn logos or branding;
(d) use Saturn intellectual property in a misleading, unlawful, or disparaging manner; or
(e) create materials that appear to be official Saturn materials without prior written approval.
Saturn may revoke permission to use its intellectual property at any time, subject to applicable agreements and law.
26. Relationship of the Parties
Participation in a Program does not create an employment, agency, partnership, franchise, joint venture, fiduciary, representative, broker, dealer, investment adviser, solicitor, promoter, or other special relationship between Saturn and a Participant.
Participants have no authority to bind Saturn, make statements on Saturn’s behalf, approve materials on Saturn’s behalf, accept terms on Saturn’s behalf, or represent that they act for Saturn.
Participants are independent persons solely responsible for their own statements, conduct, legal compliance, tax obligations, and participation.
27. Assumption of Risk
Participants acknowledge that:
(a) laws and regulations may change;
(b) Saturn’s products, services, campaigns, and Programs may change;
(c) Points may be modified, discontinued, or cancelled;
(d) Saturn may determine that particular activities, persons, jurisdictions, Accounts, or Wallets are ineligible; and
(e) participation may not result in any benefit.
Participants participate voluntarily and at their own risk.
28. No Warranties
The Programs and Points are provided on an “as is” and “as available” basis.
To the maximum extent permitted by applicable law, Saturn disclaims all warranties, representations, and conditions, whether express, implied, statutory, or otherwise, including warranties of merchantability, fitness for a particular purpose, title, non-infringement, availability, accuracy, error-free operation, uninterrupted operation, security, or that Points will be awarded, retained, or considered in a future event.
Saturn does not warrant that a Program will meet a Participant’s expectations or result in a reward, benefit, token allocation, distribution, or other outcome.
29. Limitation of Liability
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, SATURN AND ITS AFFILIATES, DIRECTORS, OFFICERS, EMPLOYEES, CONTRACTORS, AGENTS, SERVICE PROVIDERS, ADVISORS, AND REPRESENTATIVES WILL NOT BE LIABLE FOR INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, PUNITIVE, ENHANCED, OR SIMILAR DAMAGES, OR FOR LOSS OF PROFITS, REVENUES, GOODWILL, DATA, BUSINESS OPPORTUNITY, ANTICIPATED SAVINGS, POINTS, TOKEN ALLOCATION OPPORTUNITY, OR OTHER INTANGIBLE LOSS ARISING OUT OF OR RELATING TO A PROGRAM OR THESE TERMS.
TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, SATURN’S TOTAL LIABILITY ARISING OUT OF OR RELATING TO THE PROGRAMS AND THESE TERMS WILL NOT EXCEED USD $100.
THE LIMITATIONS IN THIS SECTION APPLY REGARDLESS OF THE THEORY OF LIABILITY, WHETHER BASED IN CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY, STATUTE, RESTITUTION, UNJUST ENRICHMENT, OR OTHERWISE, EVEN IF SATURN HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
30. Indemnification
To the maximum extent permitted by applicable law, each Participant will indemnify, defend, and hold harmless Saturn and its Affiliates, directors, officers, employees, contractors, agents, service providers, advisors, and representatives from and against claims, demands, actions, investigations, proceedings, damages, losses, liabilities, penalties, fines, costs, and expenses, including reasonable attorneys’ fees, arising out of or relating to:
(a) the Participant’s participation in a Program;
(b) the Participant’s promotional, marketing, or referral activity;
(c) the Participant’s statements, posts, messages, websites, advertisements, or other content;
(d) where applicable, the Participant’s failure to provide required referral disclosures;
(e) the Participant’s violation of these Terms, the applicable Program Rules, or the Saturn Terms;
(f) the Participant’s violation of applicable law or third-party rights;
(g) the Participant’s fraud, misrepresentation, negligence, willful misconduct, or prohibited conduct; or
(h) a dispute between the Participant and a Referred User or other third party.
Saturn may assume exclusive control of a defense at the Participant’s expense. The Participant may not settle a claim subject to this Section without Saturn’s prior written consent.
31. Dispute Resolution; Governing Law
These Terms and any dispute, claim, or controversy arising out of or relating to a Program will be governed by the laws specified in the Saturn Terms, without regard to conflict-of-laws rules.
Any such dispute, claim, or controversy will be resolved in accordance with the dispute-resolution provisions of the Saturn Terms, including any applicable arbitration agreement, class-action waiver, jury-trial waiver, venue provision, limitation period, or other dispute-resolution procedure.
If the Saturn Terms do not specify governing law or dispute-resolution procedures, the following default provisions apply:
(a) these Terms are governed by the laws of the British Virgin Islands, without regard to conflict-of-laws rules;
(b) disputes will be resolved exclusively by binding arbitration administered by the BVI International Arbitration Centre (BVI IAC) under its applicable rules;
(c) the seat of arbitration will be Road Town, Tortola, British Virgin Islands;
(d) the language of arbitration will be English;
(e) arbitration will be conducted by one arbitrator;
(f) each Participant waives any right to participate in a class action, class arbitration, collective action, private attorney general action, or representative proceeding; and
(g) each Participant waives any right to trial by jury.
The class-action waiver and representative-action waiver in subsection (f) are essential to and non-severable from the default agreement to arbitrate.
If a court of competent jurisdiction determines that either waiver is unenforceable in whole or in part with respect to a particular dispute, the default agreement to arbitrate set forth in this Section will be null and void with respect to that dispute. That dispute will instead be resolved in a court of competent jurisdiction having venue under applicable law, provided that the jury-trial waiver in subsection (g) remains effective to the extent permitted by applicable law.
Nothing in this Section prevents Saturn from seeking injunctive or equitable relief in a court of competent jurisdiction to protect its intellectual property, confidential information, platform integrity, users, systems, or legal compliance.
32. Severability
Except as expressly provided in Section 31, if a provision of these Terms is held to be invalid, illegal, or unenforceable, the remaining provisions will remain in full force and effect.
The affected provision will be modified to the minimum extent necessary to make it valid, legal, and enforceable or, if modification is not possible, severed from these Terms.
33. No Waiver
Saturn’s failure or delay in exercising a right, remedy, power, or privilege under these Terms does not operate as a waiver.
A waiver must be in writing and signed by Saturn.
A waiver of one breach or default does not constitute a waiver of another breach or default.
34. Assignment
Participants may not assign, transfer, or delegate rights or obligations under these Terms without Saturn’s prior written consent.
Saturn may assign, transfer, or delegate these Terms, in whole or in part, without notice or consent, including in connection with a merger, acquisition, reorganization, financing, sale of assets, corporate transaction, or by operation of law, subject to applicable law.
35. Entire Agreement
These Terms, the applicable Program Rules, the Saturn Terms, the Saturn Privacy Policy, and other terms, policies, rules, or disclosures expressly incorporated by reference constitute the entire agreement between Saturn and each Participant regarding the covered Programs.
Subject to Sections 2 and 4 and applicable law, these documents supersede prior or contemporaneous statements, understandings, representations, communications, or agreements regarding the same subject matter, except as expressly incorporated or preserved.
Previously published earning formulas, referral rates, attribution rules, and other program-specific mechanics preserved as Program Rules under these Terms are not displaced merely because this document uses general Saturn Points terminology.
36. Contact
Questions about the Programs or these Terms may be directed to:
Saturn
Email: ops@saturn.foundation
Address: Trinity Chambers, P.O. Box 4301, Road Town, Tortola, British Virgin Islands