THE "SPRING RAFFLE" CAMPAIGN RULES

1. Organiser

The " SPRING TOMBOLA " campaign is organized by SC APUSENI MOUNTAINS RESEARCH CO SRL, a Romanian legal entity with registered office in Sântion village, com. Sântion, nr.1/K, Bihor county, registered at the Trade Register Office of the Bihor Court under no.J05/1250/2015, CUI RO34860301, owner of the trademark Synergy Therm.

2. Place and period of the campaign "SPRING TOMBOLA"

The " SPRING TOMBOLA " campaign will run from 14.02.2024-30.05.2024 exclusively on www.synergytherm.com.

3. Right of participation

Any natural person of Romanian nationality, residing in Romania and who is at least 18 years of age at the time of registration can participate in the " SPRING TOMBOLA " campaign. As an exception to the above, employees belonging to SC APUSENI MOUNTAINS RESEARCH CO SR , as well as their first and second degree relatives and legal entities as defined by Romanian law, cannot participate in the raffle.

4. Registration for the "SPRING TOMBOLA" campaign and eligibility conditions

Any person who purchases "Synergy Therm" brand cosmetic products worth at least 200 lei in a single order placed on the website www.synergytherm.com, can enter the "SPRING TOMBOLA" campaign.

An order worth at least 200 lei, for which a tax invoice is issued, entitles the participant to enter the " SPRING TOMBOLA " campaign only once. A participant can register several times for the "SPRINGTOMBOLA " campaign based on several orders of "Synergy Therm" brand cosmetic products worth at least 200 lei for a single purchase.

The participant in the " SPRING TOMBOLA " campaign will register with the data completed on the website www.synergytherm.com at the time of placing the order consisting of name, surname, delivery address of the order, telephone number and e-mail address.

In order to complete the registration procedure, the participant will declare on his/her own responsibility, by ticking the boxes, that he/she is at least 18 years old, that he/she consents to his/her personal data being collected, processed, stored and transmitted by the organiser and that he/she agrees with the campaign rules. Failure to provide the participant's consent to the above mentioned information makes it impossible to complete the registration to the "SPRING TOMBOLA" campaign.

For the draw of 29.03.2024 of the campaign "SPRING TOMBOLA", any person who purchases cosmetics brand "Synergy Therm" worth at least 200 lei for a single order placed on the website www.synergytherm.com, between 14.02.2024-28.03.2024 at 23.59.

For the draw on 30.04.2024 of the campaign "SPRING TOMBOLA", any person who purchases cosmetics brand "Synergy Therm" worth at least 200 lei for a single order placed on the website www.synergytherm.com, between 29.03.2024-29.04.2024 at 23.59.

For the draw of 31.05.2024 of the campaign "SPRING TOMBOLA",

Any person who buys cosmetics brand "Synergy Therm" worth at least 200 lei in a single order placed on the website www.synergytherm.com during the period 30.04.2024-30.05.2024 at 23.59 hours can register.

Persons registered in the "SPRING TOMBOLA" campaign who were not designated as winners in the first draw on 29.03.2024, will automatically participate in the following draws of the campaign on 30.04.2024 and 31.05.2024 respectively, provided that they were not designated as winners in the draw on 30.04.2024, without any further formalities or procedures to be followed.

In order to claim the prizes, the winners must meet the following eligibility requirements: be at least 18 years of age, have an original/clear copy of the tax invoice/ a photograph proving the purchase of "Synergy Therm" minimum amount of 200 lei, matching the identification data registered on the website.l www.synergytherm.com, with the identification data mentioned in the identity card, are not employees belonging to SC APUSENI MOUNTAINS RESEARCH CO SRL , nor their first and second degree relatives, nor legal persons as defined by Romanian law.

Registration to the " SPRING TOMBOLA " campaign implies the participant's full, express and unequivocal acceptance and acceptance of these rules.

5. Prizes of the " SPRING TOMBOLA " campaign

The "SPRING TOMBOLA" campaign offers 3 prizes. The prizes awarded in the three draws are: JACQUEMUS ladies' bag in the draw of 29.03.2024, SAINT LAURENT ladies' bag in the draw of 30.04.2024 and GUCCI ladies' bag in the draw of 31.05.2024. The total commercial value of the prizes of the "SPRING TOMB " campaign is 11.475 lei.

All prizes in the " SPRING TOMBOLA " campaign are non-transferable, cannot be exchanged for other goods or products and cannot be awarded in cash.

The " SPRING TOMBOLA " campaign is not administered, supported or sponsored by Facebook. Any information provided by participants goes to Synergy Therm not Facebook. Any suggestions, complaints or requests for information should be addressed to the organiser.

The winner of each prize will be contacted by telephone. If for any reason the winner cannot be contacted by telephone following three unsuccessful attempts by the organizer, the winner will be contacted by a message on the e-mail address with which he/she registered on the website, with 2 working days to confirm that he/she wishes to claim the prize won, failure to confirm will invalidate him/her as a winner.

Prize winners are entitled to claim their prize within 5 working days of the draw.

Prizes will be shipped by the organizer to the winners via express courier service. The costs of shipping the prizes will be borne entirely by the organiser.

6. Drawing of the winners of the " SPRING TOMBOLA " campaign

On 29.03.2024 the first draw of the winners of the " SPRING TOMBOLA " campaign will take place.

Two persons will be designated as winners, to be selected by random drawing from among all eligible participants registered under these Rules. An automated system (random.org) will be used for the draw and the moment of the draw will be filmed and posted on the organizer's social media page on Instagram @synergythermcosmetics.

Winners will be checked in the order in which they were drawn for eligibility and compliance with these rules.

Failure to meet the eligibility conditions, non-compliance with these rules, or refusal to claim the prize by the first person designated as the winner of the draw, shall invalidate that person as the winner, will result in verification of the eligibility conditions of the second person designated as the winner.

Failure to meet the eligibility conditions, non-compliance with these rules, or refusal to claim the prize by the second person designated as the winner of the draw, shall invalidate that person as the winner and make it impossible to award the prize.

Announcement of the invalidation of a winner will be made on the organizer's social media page on Instagram @synergythermcosmetics.

Refusal to claim the prize is the manifestation of the winner's will manifested by the lack of response to the e-mail sent by the organizer within 2 working days of the communication, respectively refusal to receive the parcel by which the prize was sent.

The organizer is released from any liability and is not obliged to compensate persons designated as winners who have not met the eligibility requirements, have not complied with these rules, or have refused to claim the prizes won.

If the person designated as the winner does not meet the eligibility conditions, does not comply with these rules, or has refused to claim the prize won, the prize cannot be awarded, meaning that on 01.04.2024 the draw will resume exclusively for the prize that could not be awarded to the person designated as the winner in the draw of 29.03.2024.

On 30.04.2024 the second draw of the winners of the " SPRING TOMBOLA " campaign will take place.

Two persons will be designated as winners, to be selected by random drawing from among all eligible participants registered under these Rules. An automated system (random.org) will be used for the draw, and the moment of the draw will be filmed and posted on the organizer's social media page on Instagram @synergythermcosmetics.

Winners will be checked in the order in which they were drawn for eligibility and compliance with these rules.

Failure to meet the eligibility conditions, non-compliance with these rules, or refusal to claim the prize by the first person designated as the winner of the draw, shall invalidate that person as the winner, will result in verification of the eligibility conditions of the second person designated as the winner.

Failure to meet the eligibility conditions, non-compliance with these rules, or refusal to claim the prize by the second person designated as the winner of the draw, shall invalidate that person as the winner and make it impossible to award the prize.

Announcement of the invalidation of a winner will be made on the organizer's social media page on Instagram @synergythermcosmetics.

Refusal to claim the prize is the manifestation of the winner's will manifested by the lack of response to the e-mail sent by the organizer within 2 working days of the communication, respectively refusal to receive the parcel by which the prize was sent.

The organizer is released from any liability and is not obliged to compensate persons designated as winners who have not met the eligibility requirements, have not complied with these rules, or have refused to claim the prizes won.

If the person designated as the winner does not meet the eligibility conditions, does not comply with these rules, or has refused to claim the prize won, the prize cannot be awarded, meaning that on 01.05.2024 the draw will resume exclusively for the prize that could not be awarded to the person designated as the winner in the draw on 30.04.2024.

On 31.05.2024 the third draw for the winners of the " SPRING TOMBOLA " campaign will take place.

Two persons will be designated as winners, to be selected by random drawing from among all eligible participants registered under these Rules. An automated system (random.org) will be used for the draw and the moment of the draw will be filmed and posted on the organizer's social media page on Instagram @synergythermcosmetics.

Winners will be checked in the order in which they were drawn for eligibility and compliance with these rules.

Failure to meet the eligibility conditions, non-compliance with these rules, or refusal to claim the prize by the first person designated as the winner of the draw, shall invalidate that person as the winner, will result in verification of the eligibility conditions of the second person designated as the winner.

Failure to meet the eligibility conditions, non-compliance with these rules, or refusal to claim the prize by the second person designated as the winner of the draw, shall invalidate that person as the winner and make it impossible to award the prize.

Announcement of the invalidation of a winner will be made on the organizer's social media page on Instagram @synergythermcosmetics.

Refusal to claim the prize is the manifestation of the winner's will manifested by the lack of response to the e-mail sent by the organizer within 2 working days of the communication, respectively refusal to receive the parcel by which the prize was sent.

The organizer is released from any liability and is not obliged to compensate persons designated as winners who have not met the eligibility requirements, have not complied with these rules, or have refused to claim the prizes won.

If the person designated as the winner does not meet the eligibility conditions, does not comply with these rules, or has refused to claim the prize won, the prize cannot be awarded, meaning that on 03.06.2024 the draw will be resumed exclusively for the prize that could not be awarded to the person designated as the winner in the draw on 31.05.2024.

Winners will be announced on the day of the draw on the organizer's social media page on Instagram @synergythermcosmetics. " TOMBOLA SPRINGS " will be kept public on the www.synergytherm.com for 30 days from the date of the last draw.

7.Protection of personal data

By signing up to the " TOMBOLA SPRINGS " each participant expressly and unequivocally consents to the collection, processing, storage and transmission by the organiser of his/her personal data, consisting of name, surname, delivery address, telephone number, e-mail address, registration on the website, etc.l www.synergytherm.com, Instagram or Facebook social media accounts, profile picture, a photo of the prize won. In the event that the winners wish to have their prize winnings sent to an address other than the delivery address provided on the website www.synergytherm.com at the time of placing the order, expressly and unequivocally consents to the organizer collecting, processing, storing and transmitting this personal data.

The storage and processing of these personal data is carried out for the following purposes: for the purpose of awarding and claiming the prizes of the " SPRING TOMBOLA " campaign, advertising, marketing and publicity. These personal data will be transmitted to commercial partners, institutions and public authorities.

The duration of processing of personal data coincides with the duration of the competition and implicitly the designation and announcement of winners.

Personal data will be kept for 1 year from the date of the winners' draw, unless other retention periods are required by law.

The organizer will keep the winners' personal data confidential and will use them only for the purposes set out in the Rules. Participants have the right to refuse, at any time, free of charge and without any justification, that the data they have provided in connection with their participation in the " SPRING TOMBOLA " campaign be processed for direct marketing purposes or be disclosed to third parties for such purposes. Participants have the right to object to the processing of their personal data at any time, on justified grounds relating to their personal situation.

Lawfulness of the processing of personal data

The controller processes personal data of data subjects under the following conditions: (a) the data subject has consented to the processing of his or her personal data for one or more specific purposes; (b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; (c) processing is necessary for compliance with a legal obligation incumbent on the controller; (d) processing is necessary to protect the vital interests of the data subject or of another natural person; (e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; (f) processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where the interests or fundamental rights and freedoms of the data subject require the protection of personal data, in particular where the data subject is a child.

Rights of data subjects

According to Regulation 679/2016, data subjects have the following rights:

Right to information the data subject has the right to receive information about the controller's data, the personal data that are processed, the purpose for which and the manner in which the personal data are processed.

Right of access to data the data subject shall have the right to obtain from the controller confirmation as to whether or not personal data relating to him or her are being processed and, if so, access to those data and to the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipients to whom personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the period for which personal data are expected to be stored or, if this is not possible, the criteria used to determine this period; (e) the existence of the right to request the controller to rectify or erase personal data or to restrict the processing of personal data concerning the data subject or the right to object to processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of an automated decision-making process including profiling, as well as relevant information on the logic used and on the significance and expected consequences of such processing for the data subject.

If personal data are transferred to a third country or an international organisation, the data subject has the right to be informed of the appropriate safeguards.

The controller shall provide a copy of the personal data undergoing processing. For any other copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject submits the request in electronic format and unless the data subject requests another format, the information shall be provided in a commonly used electronic format.

Right to rectification the data subject shall have the right to obtain from the controller, without undue delay, the rectification of inaccurate personal data concerning him or her. Taking into account the purposes for which the data have been processed, the data subject shall have the right to obtain the completion of personal data which are incomplete, including by providing an additional statement.

Right to erasure of data ("right to be forgotten") the data subject shall have the right to obtain from the controller the erasure of personal data relating to him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay if one of the following grounds applies: (a) the personal data are no longer necessary for the purposes for which they were collected or processed; (b) the data subject withdraws the consent on the basis of which the processing is carried out; (c) the data subject objects to the processing; (d) personal data have been unlawfully processed; (e) personal data must be deleted in order to comply with a legal obligation incumbent on the controller under Union law or the national law to which the controller is subject; (f) personal data were collected in connection with the provision of information society services

The right to restrict data processing the data subject shall have the right to obtain from the controller the restriction of the processing if one of the following applies: (a) the data subject disputes the accuracy of the data for a period allowing the controller to verify the accuracy of the data; (b) the processing is unlawful and the data subject objects to the erasure of the personal data and requests instead the restriction of their use; (c) the controller no longer needs the personal data for the purpose of processing but the data subject requests them for the establishment, exercise or defence of legal claims; or (d) the data subject has objected to the processing

Right to data portability the data subject shall have the right to receive personal data relating to him or her which he or she has provided to the controller in a structured, commonly used and machine-readable format and shall have the right to transmit such data to another controller, without hindrance on the part of the controller to whom the personal data were provided, if: (a) processing is based on consent; (b) processing is carried out by automatic means.

The right to oppose the data subject shall have the right to object at any time, on grounds relating to his or her particular situation, to the processing of personal data relating to him or her, including the creation of profiles on the basis of those provisions. The controller shall no longer process personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.

The right not to be subject to automated decisions, including profiling the data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the data subject or otherwise significantly affects him or her. This right cannot be exercised by the data subject if the decision: (a) is necessary for the conclusion or performance of a contract between the data subject and a data controller; (b) is authorised by Union law or national law applicable to the controller which also provides for appropriate measures to protect the rights, freedoms and legitimate interests of the data subject; or (c) is based on the explicit consent of the data subject.

The right to lodge a complaint with the National Supervisory Authority for Personal Data Processing or with the courts regarding the processing of personal data the data subject has the right to lodge a complaint with the National Supervisory Authority for Personal Data Processing or with the courts regarding the processing of personal data.

Processing of Personal Data concerning the processing of his personal data

The right to withdraw consent to the processing of personal data the data subject has the right to withdraw his or her consent to the processing of personal data, withdrawal of consent does not affect the lawfulness of the processing of personal data on the basis of the consent prior to the withdrawal of consent

The data subject may exercise these rights by sending a request to the Operator by e-mail to the following address office@synergytherm.com , or at its working point in Sântion village, com. Sântion, nr.1/K,, Bihor county.

8.Final provisions

Any disagreements regarding the validity of these rules or the results of the interpretation and execution of these rules or the results of the "SPRING TOMBOLA" campaign will be settled amicably. In the event that any disputes cannot be settled amicably, the parties shall apply to the courts at the organiser's premises SC APUSENI MOUNTAINS RESEARCH CO SRL.

The organiser accepts no liability in the event of false or misleading information being communicated to it. The only obligation assumed by the organiser is with regard to the awarding of prizes.

9. Amendments to the rules of the "SPRING TOMBOLA" campaign

The Organiser reserves the right to amend the provisions of these Rules at any time, should this become necessary. All amendments to these rules will be made public for public accountability.

ORGANIZER SC APUSENI MOUNTAINS RESEARCH CO SRL