Gravity Points Referral Program Terms and Conditions

Effective Date: 05/11/2026
Last Updated: 05/11/2026

These Terms and Conditions, together with any terms, policies, rules, or disclosures incorporated by reference, govern participation in the Saturn Gravity Points Referral Program described below.

These Referral Program Terms are supplemental to, and form part of, the Saturn Terms and Conditions available at https://saturn.credit/legal/terms-conditions, the Saturn Privacy Policy, and any other applicable Saturn terms, policies, or disclosures. If there is a conflict between these Referral Program Terms and the Saturn Terms and Conditions, these Referral Program Terms will control solely with respect to the Referral Program.

By participating in the Referral Program, generating or sharing a Referral Code, referring another person, using a Referral Code, claiming or accepting Gravity Points, or otherwise engaging with the Referral Program, you agree to these Referral Program Terms.

1. Definitions

For purposes of these Referral Program 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 in these Referral Program Terms, the Saturn Terms and Conditions, and any other applicable Saturn policies.

Excluded Jurisdiction means the United States, the European Economic Area, the United Kingdom, Canada, Singapore, Hong Kong, the People’s Republic of China, any Sanctioned Jurisdiction, and any other jurisdiction designated by Saturn from time to time as restricted or ineligible for participation in the Referral Program.

Gravity Points or Points means non-transferable, non-redeemable, off-chain promotional points that may be awarded by Saturn in connection with eligible user activity, subject to Saturn’s terms, policies, and discretion.

KYC means know-your-customer, customer identification, identity verification, diligence, screening, and related compliance checks required or requested by Saturn.

Program Period means the period during which the Referral Program is active, as determined by Saturn in its sole discretion.

Prohibited Person means any person or entity that Saturn determines is not permitted to participate in the Referral Program, including any person or entity that is:
(a) located, organized, resident, domiciled, or ordinarily resident in an Excluded Jurisdiction;
(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.

Qualifying Activity means activity by an Eligible Participant that Saturn determines qualifies for Gravity Points under the applicable Saturn points rules, campaign rules, product terms, or other official Saturn materials.

Qualifying Referral means a referral that satisfies all requirements in Section 8.

Referred User means an Eligible Participant who is referred to Saturn through a valid Referral Code and who 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 the Referral Program.

Referral code means a unique referral link, code, or other referral mechanism issued by Saturn to a Referrer.

Referral Program or Program means the Saturn Gravity Points Referral Program described in these Referral Program Terms.

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 available at https://saturn.credit/legal/terms-conditions, as amended from time to time.


2. The Program.  

These Referral Program Terms govern the Gravity Points Referral Program (the “Program”) operated by Saturn Holdings Ltd. (“Saturn,” “we,” “us,” or “our”). The Program permits eligible participants to refer other eligible persons to the Saturn platform (the “Platform”) and to receive Gravity Points (as defined below) in connection with qualifying referrals, subject to the terms set forth herein.

3. Acceptance.  

By participating in the Program, including by generating or sharing a Referral Code or accepting a Referral Code, you (“you” or, in the relevant capacity, a “Referrer” or “Referred User”) acknowledge that you have read, understood, and agree to be bound by these Referral Program Terms, by the Saturn Terms (as defined in Section 1), by the Saturn Privacy Policy, and, where applicable, by your Participation Agreement with Saturn. If you do not agree to any provision of these Referral Program Terms, you must not participate in the Program.

4.  Relationship to Other Agreements.  

These Referral Program Terms supplement and do not replace any other agreement between you and Saturn. In the event of a conflict between these Referral Program Terms and any other agreement with respect to matters specific to the Program, these Referral Program Terms control.

5.  Modification of Terms.  

Saturn may modify these Referral Program Terms at any time by posting an updated version at https://app.saturn.credit/portfolio and, where required by applicable law, providing notice to participants. Your continued participation in the Program following the posting of revised Referral Program Terms constitutes your acceptance of those revisions.

6. Eligibility

Participation in the Referral Program is available only to Eligible Participants outside the United States, the European Economic Area, the United Kingdom, and any Sanctioned Jurisdiction or other Excluded Jurisdiction.

To participate in the Referral Program, you must:

(a) be at least the age of majority in your jurisdiction of residence;
(b) have full legal capacity to agree to these Referral Program Terms;
(c) maintain an Account in good standing;
(d) satisfy all 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 Saturn from an 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 Referral Program Terms, the Saturn Terms, and all applicable laws; and
(i) satisfy any additional eligibility requirements established by Saturn.

Saturn may require both the Referrer and the Referred User to complete the same or substantially similar eligibility, identity-verification, KYC, AML, sanctions-screening, and fraud-prevention checks before any referral is treated as a Qualifying Referral or before any Gravity Points are awarded.

Saturn may determine eligibility in its sole discretion and may deny, suspend, revoke, reverse, or withhold any Gravity Points if Saturn determines that a person is not eligible or has violated these Referral Program Terms.

By participating in the Referral Program, and on a continuing basis throughout the Referrer’s participation, each Referrer represents, warrants, and covenants to Saturn 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 any Referred User the Referrer introduces 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 any of 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 for any purpose; (e) the Referrer is not registered, and is not required to be registered, with any governmental authority by reason of participating in the Referral Program; (f) the Referrer’s participation in the Referral Program does not and will not violate any law, regulation, rule, contract, court order, or other obligation applicable to the Referrer; (g) all information the Referrer has provided and will provide to Saturn in connection with the Referral Program is and will remain true, accurate, complete, and current; and (h) the Referrer will at all times comply with these Referral Program Terms and all applicable laws. Each Referrer reaffirms each of the foregoing representations and warranties on each occasion the Referrer shares a Referral Code, posts Promotional Content, or accepts the credit of Gravity Points under the Referral Program. A breach of any of the foregoing representations and warranties constitutes a breach of these Referral Program Terms for all purposes, including for purposes of Section 30 (Indemnification) and Section 22 (Withholding, Reversal, Cancellation, and Clawback).

7. Program Overview

Under the Referral Program, an eligible Referrer may receive Gravity Points based on qualifying Gravity Points earned by eligible users they directly refer to Saturn.

Subject to these Referral Program Terms, the Saturn Terms, and any applicable campaign rules:

(a) a Referrer may receive Gravity Points equal to 10% of the qualifying Gravity Points earned by each eligible Referred User directly referred by that Referrer; and
(b) a Referred User may receive a 5% bonus on their own qualifying Gravity Points.

The Referral Program has one referral layer only. Referrers may receive referral-related Gravity Points only in respect of eligible users they directly refer. Referrers will not receive Gravity Points or any other benefit based on referrals made by their Referred Users, downstream referrals, sub-referrals, teams, networks, pools, groups, or any other indirect referral activity.

No person is entitled to any Gravity Points merely for recruiting, inviting, or referring another person. Referral-related Gravity Points may be awarded only if the Referred User independently satisfies all eligibility requirements and earns qualifying Gravity Points through bona fide Qualifying Activity, as determined by Saturn.

8. Qualifying Referrals

A referral will be a Qualifying Referral only if all of the following conditions 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, incorporated, resident, domiciled, ordinarily resident, or accessing Saturn from an 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 otherwise within the referral attribution window specified by Saturn;
(g) the Referred User completes all required eligibility, KYC, AML, sanctions-screening, and fraud-prevention checks to Saturn’s satisfaction;
(h) the Referred User engages in bona fide Qualifying Activity;
(i) the referral is not a self-referral, duplicate account, fraudulent account, Sybil account, bot account, nominee account, controlled account, coordinated account, or otherwise abusive account;
(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 Referral Program Terms 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.

9. Referral Cap

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 Gravity Points per Referrer;
(c) a maximum amount of bonus Gravity Points per Referred User;
(d) a maximum amount of total Gravity Points that may be earned through the 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 referral cap applies regardless of the number of Accounts, wallets, devices, identities, handles, addresses, links, campaigns, or other referral methods used by a person.

10. No Multi-Level Marketing, Pyramid, or Network Compensation

The Referral Program is intended to reward limited, direct, eligible referrals associated with bona fide user activity. It is not a multi-level marketing program, pyramid program, chain-referral program, investment program, revenue-sharing program, passive-income program, or compensation plan.

Participants may not:

(a) receive any benefit for indirect, downstream, second-level, team, pool, network, or sub-affiliate referrals;
(b) receive any benefit merely for recruiting, inviting, enrolling, or signing up another person;
(c) require or request payment, investment, purchase of tokens, purchase of digital assets, purchase of securities, or payment of a fee as a condition to participate;
(d) represent that the 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 Code or referral opportunities; or
(g) make any statement or take any action that could characterize the Program as a pyramid, MLM, investment, income, compensation, or network-marketing opportunity.

Saturn may disqualify any participant, withhold or reverse Gravity Points, terminate Accounts, or take any other action Saturn considers appropriate if Saturn determines that referral activity resembles or contributes to a multi-level marketing, pyramid, chain-referral, abusive, deceptive, or unlawful scheme.

11. Gravity Points

Gravity Points are promotional points maintained by Saturn for internal tracking purposes only. Gravity Points are not digital assets, tokens, securities, commodities, stored value, e-money, fiat currency, virtual currency, payment instruments, deposits, property, or financial instruments.

Gravity 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 any ownership, equity, governance, voting, dividend, revenue-sharing, profit-sharing, liquidation, redemption, claim, or creditor right;
(f) do not represent any right to receive any token, digital asset, security, commodity, or other asset;
(g) do not represent any investment in Saturn or any project, protocol, product, or ecosystem;
(h) may be modified, reduced, reversed, suspended, discontinued, expired, or cancelled by Saturn as described in these Referral Program 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 Gravity Points in its sole discretion. Displayed Gravity Points may be provisional, estimated, pending, subject to reconciliation, or subject to further eligibility and anti-abuse review.

No participant may rely on any Gravity Points balance as final, vested, guaranteed, accrued, earned, payable, redeemable, or legally enforceable unless and until Saturn expressly states otherwise in writing.

12. No Token Rights or Token Allocation Commitment

Participation in the Referral Program does not entitle any person to receive any token or other asset.

Saturn has not promised, agreed, or committed to conduct any token generation event, token launch, token distribution, airdrop, allocation, sale, listing, or other token-related event. Saturn may never create, launch, sell, distribute, or allocate any token.

If Saturn or any other person ever conducts a token allocation, distribution, launch, or related event, any such event would be subject to separate terms, conditions, eligibility criteria, legal requirements, regulatory analysis, sanctions screening, KYC, tax review, and restrictions. Gravity Points may be considered, may be only one factor considered, or may be disregarded entirely in connection with any such event.

Saturn may determine, in its sole discretion, that some or all Gravity Points will not be relevant to any future token allocation, distribution, or other event. Saturn may also determine that certain persons, jurisdictions, Accounts, wallets, or activity types are ineligible for any future token-related event, regardless of Gravity Points balances.

Participants may not state, imply, or suggest that Gravity Points guarantee or create a right to any future token, airdrop, allocation, distribution, investment return, monetary value, or financial benefit.

13. Referral Code

Saturn may issue a Referral Code to an eligible Referrer. Referral Code are owned or controlled by Saturn and may be modified, disabled, suspended, revoked, or reissued at any time.

A Referrer may share their Referral Code only in accordance with these Referral Program Terms and applicable law. A Referrer is responsible for all use of their Referral Code and all statements, claims, posts, messages, websites, advertisements, content, and other materials associated with their Referral Code.

Saturn may refuse to attribute a referral to a Referrer if:

(a) the Referral Code was not used properly;
(b) the Referred User had already created an Account;
(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 Saturn’s 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 Program.

Saturn is not responsible for lost, delayed, misdirected, corrupted, malfunctioning, blocked, incomplete, inaccurate, or improperly attributed Referral Code, clicks, codes, referrals, sign-ups, Accounts, or Gravity Points.

14. Referrer Disclosure Obligations

A Referrer who publicly or privately promotes Saturn, the Referral Program, Gravity 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.

A compliant disclosure may include:

Referral disclosure: I participate in Saturn’s referral program and may receive Gravity Points equal to 10% of qualifying Gravity Points earned by eligible users I directly refer. Gravity Points have no cash value and do not guarantee tokens.

For character-limited platforms, a Referrer may use a shorter disclosure if it is clear and conspicuous, such as:

Referral disclosure: I may earn Gravity Points if you use my link. Points have no cash value and do not guarantee tokens.

Where character or formatting constraints make the short-form disclosure above impracticable, a Referrer may instead include, in the body of the communication, a recognized advertising marker (such as “#ad”) together with a brief reference to the Referrer’s participation in the Referral Program. The marker must appear before any “more” cutoff or link-preview boundary, and must not be the only disclosure where the platform permits a fuller statement.

A Referrer may not hide the disclosure in a profile bio, terms page, hashtag string, image alt text, link preview, comment thread, or location that 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, the Referral Program, Gravity Points, and any Referral code are truthful, accurate, not misleading, capable of substantiation, and consistent with official Saturn materials.

Referrers may not:

(a) state or imply that Gravity Points have monetary value;
(b) state or imply that Gravity Points are transferable or redeemable;
(c) state or imply that Gravity 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,” “token entitlement,” or similar terms in connection with the Program;
(f) make price predictions, valuation claims, listing claims, exchange claims, or liquidity claims;
(g) claim or imply that any token exists, will exist, will be launched, will be listed, or will be distributed;
(h) claim or imply that Saturn endorses the Referrer or the Referrer’s statements;
(i) impersonate Saturn or any Saturn employee, representative, partner, investor, affiliate, or agent;
(j) use Saturn trademarks, logos, branding, images, names, domains, handles, or other identifiers except as expressly authorized by Saturn;
(k) create websites, landing pages, social-media accounts, groups, channels, advertisements, or other materials that 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;
(n) target, solicit, or onboard persons in Excluded Jurisdictions;
(o) use paid advertising, sponsored posts, influencer campaigns, affiliate networks, ad networks, or paid traffic sources;
(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 any applicable platform rules, advertising rules, consumer-protection rules, financial-promotion rules, securities laws, privacy laws, or other applicable laws.

Saturn may monitor public promotional activity and may require removal, correction, or modification of any content related to the 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, Gravity Points, the Referral Program, any future token, or any potential allocation or distribution.

Saturn may report, request removal of, or disassociate from third-party content that Saturn determines is false, misleading, unlawful, non-compliant, reputationally harmful, or inconsistent with these Referral Program Terms.

17. Prohibited Conduct

Participants may not engage in any conduct that Saturn determines is abusive, fraudulent, misleading, unlawful, manipulative, or inconsistent with the integrity of the Referral 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 Gravity Points;
(d) using bots, scripts, automation, emulators, device farms, click farms, account farms, or Sybil techniques;
(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 Code, identities, wallets, or Gravity Points;
(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 the Referral Program for unlawful gambling, sweepstakes, lottery, prize promotion, or contest activity;
(p) using the Referral 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 the Referral Program and Saturn’s platform.

18. Compliance, KYC, AML, and Sanctions Screening

Saturn may require any Referrer, Referred User, or other participant to provide information or documentation requested by Saturn 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, fraud-risk indicators, and other compliance or risk sources.

Saturn may deny, suspend, restrict, terminate, or reverse participation in the Referral Program if Saturn determines that a participant:

(a) is a Prohibited Person;
(b) is located in, resident in, organized in, ordinarily resident in, or accessing Saturn from an Excluded Jurisdiction;
(c) is subject to sanctions or other legal restrictions;
(d) fails to satisfy KYC, AML, sanctions-screening, fraud-prevention, or compliance requirements;
(e) provides inaccurate, incomplete, misleading, or unverifiable information;
(f) presents legal, regulatory, compliance, fraud, security, platform-integrity, or reputational risk; or
(g) otherwise violates these Referral Program Terms.

Saturn may withhold, freeze, cancel, reverse, or claw back Gravity Points while conducting any compliance, sanctions, fraud, or eligibility review.

19. Geographic Restrictions

The Referral Program is not available to persons or entities in the United States, the European Economic Area, the United Kingdom, Sanctioned Jurisdictions, or any other Excluded Jurisdiction.

Participants may not access or participate in the Referral Program from an Excluded Jurisdiction. Participants may not refer persons located in, resident in, incorporated in, organized in, ordinarily resident in, or accessing Saturn from an 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 an Excluded Jurisdiction must immediately stop participating in the Referral Program and notify Saturn. Saturn may suspend, restrict, terminate, or cancel participation if a participant becomes ineligible.

Saturn may modify the list of Excluded Jurisdictions at any time.

20. Tax Matters

Participants are solely responsible for determining and satisfying any tax obligations that may arise from participation in the Referral Program, receipt or accrual of Gravity Points, or any related activity.

Saturn does not provide tax advice. Participants should consult their own tax advisors regarding the tax consequences of participating in the Referral Program.

Saturn may request tax forms, certifications, or other information from participants. Saturn may report information to tax authorities, withhold amounts, suspend participation, or take other actions if Saturn determines that tax reporting, withholding, or compliance obligations may 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 the Referral Program at any time, with or without notice, subject to applicable law.

Saturn may make changes prospectively or retroactively where Saturn determines that retroactive changes are necessary or appropriate for legal, regulatory, compliance, fraud-prevention, security, technical, platform-integrity, or fairness reasons.

Saturn is not liable for any modification, suspension, restriction, or termination of the Referral Program or any resulting loss, reduction, cancellation, or non-accrual of Gravity Points.

22. Withholding, Reversal, Cancellation, and Clawback

Saturn may withhold, deny, reduce, reverse, cancel, expire, or claw back Gravity Points if Saturn determines that:

(a) the Gravity Points were awarded in error;
(b) the underlying referral was not a Qualifying Referral;
(c) the underlying activity was not Qualifying Activity;
(d) the Referrer or Referred User was not eligible;
(e) the Referrer or Referred User failed KYC, AML, sanctions-screening, fraud-prevention, or compliance review;
(f) the Gravity Points resulted from prohibited conduct;
(g) the participant violated these Referral Program Terms or the Saturn Terms;
(h) the participant made false or misleading promotional claims;
(i) the participant failed to make required referral disclosures;
(j) the participant engaged in conduct that may create 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 necessary or appropriate under applicable law or Saturn policy.

Saturn may take these actions without compensation, payment, replacement, or liability.

23. Communications and Notices

Saturn may provide notices regarding the Referral Program by posting on Saturn’s website, posting through official Saturn channels, updating these Referral Program Terms, sending email or in-app notifications, or using any other method Saturn considers appropriate.

Participants are responsible for reviewing these Referral Program 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 Referral Program Terms.

24. Privacy

Saturn may collect, use, disclose, and retain personal information in connection with the Referral Program as described in the Saturn Privacy Policy and any other applicable privacy notices.

Referral Program participation may involve the processing of information such as Account information, identity-verification information, referral attribution data, device data, IP address, location indicators, compliance-screening data, fraud-risk indicators, wallet information, and activity data.

Saturn may disclose information to service providers, compliance vendors, analytics providers, fraud-prevention providers, sanctions-screening providers, identity-verification providers, professional advisors, regulators, law enforcement, tax authorities, or other persons where Saturn determines disclosure is necessary or appropriate.

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 and to 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 the Referral Program does not grant any license or right to use Saturn intellectual property except for the limited right to share a valid Referral Code in accordance with these Referral Program Terms.

Participants may not:

(a) register or use domain names, social-media handles, usernames, keywords, advertisements, search terms, app names, business names, or other identifiers containing or confusingly similar to Saturn marks;
(b) imply affiliation, sponsorship, approval, endorsement, agency, employment, or partnership with Saturn;
(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 any permission to use Saturn intellectual property at any time.

26. Relationship of the Parties

Participation in the Referral Program does not create any employment, agency, partnership, franchise, joint venture, fiduciary, representative, broker, dealer, investment adviser, solicitor, promoter, or other special relationship between Saturn and any 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 use of the Referral Program.

27. Assumption of Risk

Participants further acknowledge that:

(a) laws and regulations may change;
(b) Saturn’s products, services, campaigns, and programs may change;
(c) Gravity Points may be modified, discontinued, or cancelled;
(d) Saturn may determine that certain activities, persons, jurisdictions, or Accounts are ineligible; and
(e) participation in the Referral Program may not result in any benefit.

Participants participate voluntarily and at their own risk.

28. No Warranties

The Referral Program and Gravity 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 any warranties of merchantability, fitness for a particular purpose, title, non-infringement, availability, accuracy, error-free operation, uninterrupted operation, security, or that any Gravity Points will be awarded, retained, or considered in any future event.

Saturn does not warrant that the Referral Program will meet any participant’s expectations or result in any 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 ANY INDIRECT, INCIDENTAL, CONSEQUENTIAL, SPECIAL, EXEMPLARY, PUNITIVE, ENHANCED, OR SIMILAR DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUES, GOODWILL, DATA, BUSINESS OPPORTUNITY, ANTICIPATED SAVINGS, GRAVITY POINTS, TOKEN ALLOCATION OPPORTUNITY, OR OTHER INTANGIBLE LOSS, ARISING OUT OF OR RELATING TO THE REFERRAL PROGRAM.

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, SATURN’S TOTAL LIABILITY ARISING OUT OF OR RELATING TO THE REFERRAL PROGRAM 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 any 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 the Referral Program;
(b) the participant’s promotional, marketing, or referral activity;
(c) the participant’s statements, posts, messages, websites, advertisements, or other content;
(d) the participant’s failure to provide required referral disclosures;
(e) the participant’s violation of these Referral Program Terms 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) any dispute between the participant and any Referred User or other third party.

Saturn may assume exclusive control of any defense at the participant’s expense. The participant may not settle any claim without Saturn’s prior written consent.

31. Dispute Resolution; Governing Law

These Referral Program Terms and any dispute, claim, or controversy arising out of or relating to the Referral Program will be governed by the laws specified in the Saturn Terms, without regard to conflict-of-laws rules.

Any dispute, claim, or controversy arising out of or relating to the Referral Program will be resolved in accordance with the dispute-resolution provisions of the Saturn Terms, including any arbitration agreement, class-action waiver, jury-trial waiver, venue provision, limitation period, or other dispute-resolution procedure contained in the Saturn Terms.

If the Saturn Terms do not specify governing law or dispute-resolution procedures, the following default provisions apply:

(a) these Referral Program Terms are governed by the laws of the British Virgin Islands, without regard to conflict-of-laws rules;
(b) any dispute will be resolved exclusively by binding arbitration administered by 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 the representative-action waiver in subsection (f) are essential to and non-severable from the 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 agreement to arbitrate set forth in this Section shall be null and void with respect to that dispute, and that dispute shall instead be resolved in any court of competent jurisdiction having venue under applicable law, provided that the jury-trial waiver in subsection (g) shall remain in full force and effect.

Nothing in this Section prevents Saturn from seeking injunctive or equitable relief in any court of competent jurisdiction to protect its intellectual property, confidential information, platform integrity, users, systems, or legal compliance.

32. Severability

If any provision of these Referral Program Terms is held to be invalid, illegal, or unenforceable, the remaining provisions will remain in full force and effect. The invalid, illegal, or unenforceable 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 Referral Program Terms.

33. No Waiver

Saturn’s failure or delay in exercising any right, remedy, power, or privilege under these Referral Program Terms does not operate as a waiver. Any waiver must be in writing and signed by Saturn.

A waiver of one breach or default does not constitute a waiver of any other breach or default.

34. Assignment

Participants may not assign, transfer, or delegate any rights or obligations under these Referral Program Terms without Saturn’s prior written consent.

Saturn may assign, transfer, or delegate these Referral Program 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.

35. Entire Agreement

These Referral Program Terms, the Saturn Terms, the Saturn Privacy Policy, and any other terms, policies, rules, or disclosures incorporated by reference constitute the entire agreement between Saturn and each participant regarding the Referral Program.

These Referral Program Terms supersede all prior or contemporaneous statements, understandings, representations, communications, or agreements regarding the Referral Program, except as expressly incorporated by reference.

36. Contact

Questions about the Referral Program may be directed to:

Saturn
Email: ops@saturn.foundation
Address: Trinity Chambers, P.O. Box 4301, Road Town, Tortola, British Virgin Islands