Great Freedom Fest

(Last updated on August 15, 2026)

Remittance lucky draw campaign — terms and conditions of participation

Important — please read before entering

This is a promotional prize draw run in Dubai under Promotion Permit No. 26IRS-000000053 issued by the Department of Economy and Tourism. Entering costs you nothing beyond the transfer you were already making. It is not a lottery, wager, bet or game of chance for consideration. You are not required to pay any entry fee, buy a ticket, or pay any additional or increased fee, charge, commission or foreign exchange margin in order to enter. Every remittance you make during the Campaign is charged at Aspora’s standard published tariff, exactly as it would be if this Campaign did not exist. The Prize is funded entirely from Aspora’s marketing budget and is not funded from customer payments.

If you win the AED 100,000 Grand Cash Prize, you will be asked to give your consent to your name and photograph being published on the Aspora app and website. You are not asked for that consent when you enter, and you are not asked for a photograph unless you are selected as the Winner. That consent is mandatory so that Aspora can ensure full transparency with the wider audience who participated in this promotional campaign. Giving it, and keeping it in place, is a condition of receiving the Prize: if you decline it, or withdraw it before the Prize has been paid, you will not receive the Prize and it will be awarded to the next eligible participant drawn through the same lucky draw process (clause 10 and the separate Publicity Consent Note). Nothing about your Aspora account, your pricing or your service is affected either way.

Aspora will never ask you to pay a fee, share a one-time passcode (OTP), PIN, password, card number or account credential in order to claim a prize. Any message, call or person asking you to do so is attempting to defraud you. Report it immediately to help@aspora.com or through the in-app Help centre.

1. The Promoter, the Campaign and these Terms

1.1 The promoter of this Campaign is Aspora Information Technology Services LLC SOC (trading as “Aspora”), under Trade License No. 1620032, with its registered office at Rigga Business Centre - 1001-04, Office No 1004-178, Deira, Al Muraqqabat, Dubai, UAE (the “Promoter” or “Aspora”).

1.2 This Campaign is conducted under Promotion Permit No. 26IRS-000000053 issued by the Department of Economy and Tourism, Government of Dubai (“DET”), and is subject to the conditions of that permit. Where any provision of these Terms conflicts with a condition of the Promotion Permit, the permit condition prevails.

1.3 These terms and conditions (the “Terms”) govern the “Great Freedom Fest” promotional campaign (the “Campaign”) operated by the Promoter through the Aspora mobile application (the “App”) during the Campaign Period.

1.4 The Campaign Period begins at 00:01 (GST, UTC+4) on 14 August 2026 and ends at 23:59 (GST, UTC+4) on 31 August 2026 (the “Campaign Period”). Entries received outside the Campaign Period will not be counted, irrespective of the reason.

1.5 By completing a Qualifying Transaction during the Campaign Period you confirm that you have read, understood and agree to be bound by these Terms, and that you satisfy the eligibility criteria in clause 3. You are not asked to give the Publicity Consent at that stage; it is requested only if you are selected as the Winner, as set out in clause 10.

1.6 These Terms are supplemental to, and do not replace, the Aspora Terms of Service and the Aspora Privacy Policy applicable to your use of the App, which continue to apply in full. In the event of a conflict, these Terms prevail in respect of the Campaign only.

1.7 These Terms are published in Arabic and English. In the event of any discrepancy or inconsistency between the two versions, the Arabic version shall prevail.

2. Definitions

In these Terms, capitalised terms have the following meanings:

Term	Meaning
Draw	The random selection of the Winner conducted in accordance with clause 7.
Eligible Participant	A person who satisfies every criterion in clause 3 and who has validly entered in accordance with clause 4.
Entry	One chance to be selected in the Draw, allocated in accordance with clause 4.
Grand Cash Prize	The single cash prize of AED 100,000 described in clause 5.1 and clause 6.
Prize	The Grand Cash Prize.
Publicity Consent	The consent given by the Winner under the Publicity Consent Note referred to in clause 10, which is requested only after the Draw.
Qualifying Transaction	An outward remittance of not less than AED 50, or its foreign currency equivalent, initiated by an Eligible Participant through the App during the Campaign Period at the Promoter’s standard published tariff and successfully settled to the beneficiary, and which is not an Excluded Transaction under clause 4.4.
Sanctioned Person	A person who is the target of, or owned or controlled by a person who is the target of, financial sanctions administered by the United Arab Emirates, the United Nations Security Council, the United States, the United Kingdom or the European Union.
Winner	An Eligible Participant selected in the Draw and confirmed as such under clause 8.

3. Eligibility

3.1 To be eligible to enter, you must, at the time of entry and at all times until any Prize is delivered to you:

(a) be a natural person aged eighteen (18) years or over;

(b) be lawfully resident in the United Arab Emirates and hold a valid Emirates ID;

(c) hold a registered personal Aspora App account in your own name in respect of which all customer due diligence, identification and verification requirements have been fully completed and accepted by the Promoter before the relevant Qualifying Transaction;

(d) hold an account which is in good standing and which is not suspended, restricted, dormant, frozen, subject to a lien, or the subject of any fraud, chargeback, dispute or financial crime investigation;

(e) not be a Sanctioned Person, and not be resident or located in a jurisdiction subject to comprehensive sanctions; and

(f) be capable of receiving the relevant Prize lawfully in the United Arab Emirates.

3.2 The following persons are not eligible to enter and their Entries will be void:

(a) employees, officers, directors, secondees, contractors, consultants and agents of the Promoter and of any company in the Promoter’s group, and members of their immediate families (spouse, parent, child or sibling) and persons living in the same household;

(b) employees, officers and agents of any supplier of a Prize, of any advertising, media, creative or fulfilment agency engaged in connection with the Campaign, and members of their immediate families;

(c) officials and employees of DET and of any other governmental or regulatory authority involved in the authorisation or supervision of the Campaign; and

(d) any person whose participation would place the Promoter in breach of any applicable law, licence condition or regulatory requirement.

3.3 Entry is limited to one natural person per Emirates ID. Where the Promoter reasonably determines that a person has entered using more than one App account, more than one Emirates ID, or the identity or documents of another person, all Entries associated with that person will be void and the Promoter may close the relevant accounts.

3.4 Corporate, business, merchant and joint accounts are not eligible.

3.5 The Promoter will screen each Winner against applicable sanctions, politically exposed persons and adverse media lists before releasing any Prize. The Promoter may withhold or cancel a Prize where release would, in the Promoter’s reasonable opinion, breach applicable law or its financial crime obligations, and shall have no liability for doing so.

4. How to enter — and the fact that entry is free

4.1 Entry is free. No payment, ticket purchase, subscription, entry fee or additional charge of any kind is required to enter the Campaign or to be selected in the Draw. No fee, charge, commission, spread or foreign exchange margin applied to any transaction is increased, varied or added by reason of the Campaign. All transactions are priced at the Promoter’s standard published tariff, which is available in the App.

4.2 To enter, you must complete at least one (1) Qualifying Transaction, being an outward remittance of not less than AED 50 through the App which is successfully settled to the beneficiary.

4.3 Subject to completing a Qualifying Transaction, you will be allocated one (1) Entry only per person for the whole Campaign Period. An Entry cannot be bought, sold, transferred, assigned, gifted or exchanged, and has no monetary value.

4.4 Excluded Transactions. The following do not count as Qualifying Transactions and any Entry generated by them will be cancelled:

(a) transactions which are cancelled, failed, rejected, refunded, recalled, reversed, charged back or not settled to the beneficiary, whether before or after the Draw;

(b) transactions funded wholly by in-app promotional credit, refunds or referral rewards;

(c) transactions which the Promoter reasonably suspects to be connected with fraud, money laundering, terrorist financing, sanctions evasion or any other unlawful purpose; and

(d) transactions made in breach of the Aspora Terms of Service.

4.5 The Promoter’s records of transactions, Entries and consents shall be the primary evidence of those matters in the absence of manifest error. This does not affect your right to question a decision or to complain under clause 15.

4.6 Entry does not increase, and must not be understood as increasing, the likelihood of any customer receiving any other benefit, pricing advantage or service from the Promoter.

5. The Prize

5.1 The Grand Cash Prize. There is one (1) Grand Cash Prize of AED 100,000 in the entire Campaign. It is awarded to one (1) Eligible Participant selected at random. Your chance of winning depends on the total number of valid Entries received, which is not known in advance.

5.2 Where the Prize becomes impossible to provide for reasons beyond the Promoter’s reasonable control, the Promoter may, with the prior approval of DET, substitute a prize of equal or greater value, and will notify affected participants through the App.

5.3 Except as expressly stated in these Terms, and save for rights which cannot be excluded under applicable law, the Promoter gives no warranty, representation or guarantee in respect of any Prize.

6. The Grand Cash Prize — additional conditions

6.1 The Grand Cash Prize of AED 100,000 will be paid exclusively by electronic bank transfer to a bank account held with a bank licensed in the United Arab Emirates in the sole name of the Winner. The Promoter will not pay the Grand Cash Prize in physical cash, will not pay it to a joint account, a third party, a business account, a money services account or an account outside the United Arab Emirates, and will not split it between accounts or persons.

6.2 Before the Grand Cash Prize is paid, the Winner must:

(a) complete the verification steps in clause 8.4 and satisfy the enhanced screening in clause 6.3;

(b) produce their original Emirates ID, passport and residence visa;

(c) provide a bank account validation letter or equivalent evidence issued by the bank confirming that the account is held in the Winner’s sole name, together with the IBAN;

(d) sign the Promoter’s Prize Acceptance, Release and Tax Declaration Form, including the tax residency declaration; and

(e) provide such further information or documentation as the Promoter reasonably requires to discharge its legal and regulatory obligations.

6.3 Because of the amount involved, the Grand Cash Prize is subject to enhanced due diligence, including screening against sanctions, politically exposed person and adverse media sources, and internal financial crime approval. The Promoter may withhold or cancel the Grand Cash Prize where payment would, in the Promoter’s reasonable opinion, breach applicable law, a sanctions restriction or the Promoter’s financial crime obligations, and shall have no liability for doing so.

6.4 Fraud control on bank details. The Promoter will collect the Winner’s bank details only through the authenticated in-App channel or in person at a Promoter office, and will independently verify them with the Winner using a call-back to the telephone number registered on the Winner’s account. The Promoter will not accept bank details, or a change of bank details, sent by email, SMS, social media or messaging application. Any request purporting to come from the Promoter that asks you to send bank details by those means, or that asks you to pay anything in order to receive the Grand Cash Prize, is fraudulent.

6.5 Payment will be initiated within 30 (thirty) business days of the Winner satisfying clauses 6.2 and 6.3. Settlement timing thereafter depends on the receiving bank and is outside the Promoter’s control.

6.6 The Grand Cash Prize is paid gross, subject only to any deduction or withholding required by applicable law under clause 9. The Promoter will not gross up any such deduction.

6.7 The Winner is solely responsible for any bank charge, transfer charge or currency conversion cost applied by the receiving bank, and for any cost of subsequently transferring or remitting the Grand Cash Prize to any other person, account or jurisdiction, together with any tax or regulatory consequence of doing so.

7. The Draw

7.1 The Draw will be conducted on 15 September 2026.

7.2 The Winner of the Grand Cash Prize will be selected at random using a certified random number generator whose seed, algorithm and output are logged and retained, in a manner that gives every valid Entry an equal chance of selection.

7.3 The Draw will be conducted as per applicable laws and the Draw will be recorded and the record retained as per applicable laws.

7.4 One or more reserve Winners will be drawn for the Grand Cash Prize and will be called upon, in the order drawn, if a Winner is disqualified, cannot be verified, does not claim within the period in clause 8.3, or forfeits a Prize, including under clause 8.5.

7.5 The result of the Draw is final. Save in the case of manifest error or as required by DET or applicable law, the Promoter will not enter into correspondence regarding the outcome of the Draw.

8. Notification, verification and claiming

8.1 Winner will be notified within 5 (five) business days of the Draw by in-App notification and by email and SMS to the contact details registered on the Winner’s Aspora account. It is your responsibility to keep those details current.

8.2 Fraud warning. Aspora will never contact you to request payment of a fee, tax, deposit, courier charge, “processing charge” or “release charge” in order to give you a Prize, and will never ask you for a one-time passcode (OTP), PIN, password, full card number, CVV or account credentials. Aspora will never ask you to make a transfer in order to receive a Prize, and will never ask you to send your bank details by email, SMS, social media or a messaging application. Aspora will confirm your bank details with you by telephoning the number registered on your account. Any request that does not follow that process is a fraud attempt. Do not comply. Report it to help@aspora.com.

8.3 A Winner must respond to the notification and complete the verification steps in clause 8.4 within fourteen (14) days of the date the notification is first sent. A Winner who fails to do so forfeits the Prize absolutely, and a reserve Winner will be substituted.

8.4 Before any Prize is released, the Winner must: (a) confirm acceptance of the Prize; (b) produce original identification documents for verification; (c) sign the Prize Acceptance, Release and Tax Declaration Form; (d) give the Publicity Consent under clause 10 for the use of their photograph and name on the App, the Aspora website and the channels described in clause 10.4; and (e) satisfy the screening in clause 3.5.

8.5 At the point of notification the Promoter will invite you to upload a photograph for publication under clause 10. Uploading a photograph, and consenting to its publication, is a condition of receiving the Prize. A Winner who does not upload a photograph, or who asks the Promoter not to publish one, will forfeit the Prize, and the Prize will be awarded to the next eligible participant drawn in accordance with clause 7.4.

8.6 The Promoter may require a Winner to attend in person at a location in the United Arab Emirates nominated by the Promoter for verification and, if applicable, prize handover, at the Winner’s own cost.

9. Taxes, duties and levies — your responsibility

9.1 You are solely and exclusively responsible for all taxes, duties, levies, charges, withholdings, social contributions, filings, declarations and reporting obligations of any nature which arise, in any jurisdiction, in connection with your participation in the Campaign or your receipt, ownership, use or disposal of any Prize.

9.2 This includes, without limitation, any liability arising in your country of tax residence, your country of citizenship, or any jurisdiction in which you are otherwise subject to tax, whether or not that jurisdiction is the United Arab Emirates. If you are or may be tax resident outside the United Arab Emirates, a Prize may be taxable income in that jurisdiction, may be taxable at a special or higher flat rate applicable to winnings, and may be taxable without the benefit of any personal allowance, exemption or deduction.

9.3 The Grand Cash Prize is a material sum and the tax consequences of receiving it can be significant. The Promoter therefore urges the Winner of the Grand Cash Prize to obtain independent professional tax advice in every jurisdiction in which the Winner may be taxable before accepting and, in any event before remitting or transferring it to another jurisdiction. Remitting the Grand Cash Prize to another country may itself carry tax, exchange control and reporting consequences for which you alone are responsible.

9.4 The Promoter does not provide tax advice and makes no representation, warranty or statement whatsoever as to the tax treatment of any Prize in any jurisdiction. You are strongly advised to obtain your own independent professional tax advice before accepting a Prize.

9.5 The Promoter may deduct or withhold from any Prize any amount which it is required or, acting reasonably, considers itself required to deduct or withhold under any applicable law, and shall have no obligation to gross up or compensate you for that deduction.

9.6 The Promoter may, as a condition of releasing a Prize, require you to provide: (a) a tax residency declaration and any taxpayer identification number; (b) satisfactory evidence that any applicable tax has been paid or provided for; and (c) a written indemnity in the Promoter’s standard form in respect of your tax obligations.

9.7 You shall indemnify and hold the Promoter harmless against any tax, penalty, interest, cost or expense which the Promoter incurs as a result of your failure to comply with your tax obligations or as a result of any incorrect or incomplete declaration made by you under clause 9.6.

9.8 The Grand Cash Prize is a payment of money and is not a supply for value added tax purposes. Any value added tax for which the Promoter is accountable in connection with the Campaign is borne by the Promoter and does not increase or reduce the Prize.

10. Publicity — use of your name and photograph

10.1 It is a condition of receiving the Prize, and not a condition of entering the Campaign, that you give the Publicity Consent set out in the separate Aspora Lucky Draw Publicity Consent Note, which is presented to you in the App only if you are selected as the Winner and which forms part of these Terms. If you do not give that consent, you will not receive the Prize and the Prize will be awarded to the next eligible participant drawn in accordance with clause 7.4.

10.2 If you win the Grand Cash Prize the Promoter may publish your full name, your photograph and your Emirate of residence on the App and on the Aspora website.

10.3 Supplying a photograph. The Promoter will invite you to upload a photograph only if you are notified as the Winner. No photograph is requested from any participant who is not selected in the Draw. The Promoter will never use your identification document photograph, your customer due diligence image or any image held for verification purposes. If you do not submit the photograph, or if you withdraw your consent to its publication, you will not receive the Prize. The Prize will accordingly be provided to the next eligible candidate selected randomly as part of the lucky draw following the same process.

10.4 Publication on any other channel — including social media, paid advertising, press releases and media interviews — requires a further consent, which is also mandatory and which is requested as part of the Publicity Consent Note only if you are selected as the Winner. If you do not give that consent, or if you withdraw it, clause 10.5 applies.

10.5 You may withdraw the Publicity Consent at any time, at no cost, through the App or by contacting help@aspora.com. If you withdraw it before the Draw, your Entry will be withdrawn and you will no longer participate. If you withdraw it after the Draw has taken place, the Prize will be awarded to the next eligible participant drawn in accordance with clause 7.4.

10.6 The Promoter will not publish the amount or value of any Prize alongside your name and photograph, and will not publish your full residential address, contact details, account details or transaction history.

10.7 Publication will remain in place for no longer than 1 (one) month from first publication, after which it will be removed.

11. Your personal data

11.1 The Promoter is the data controller in respect of personal data processed for the Campaign. Personal data is processed in accordance with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, the Aspora Privacy Policy available at https://www.aspora.com/privacy-policy, and these Terms.

11.2 The Promoter processes: your identification and contact details; Emirates ID and verification data; transaction data used to determine eligibility and allocate Entries; consent records; any photograph you upload for publication, which is stored separately from your identity verification records; and, if you win, your name, photograph and Emirate of residence. The purposes are administering the Campaign, verifying eligibility, conducting the Draw, awarding and delivering the Prize, publishing winner announcements, complying with the Promotion Permit and with legal, tax, regulatory and financial crime obligations, and handling complaints and disputes.

11.3 The legal bases are: performance of the contract constituted by these Terms; compliance with the Promoter’s legal and regulatory obligations; the Promoter’s legitimate interests in the integrity of the Draw and the prevention of fraud; and, in respect of the publication of your name and photograph, your consent.

11.4 Personal data may be disclosed to: DET and other competent authorities; the Promoter’s group companies; the bank through which the Grand Cash Prize is paid; the Promoter’s sanctions, PEP and adverse media screening providers; the licensed financial institution through which remittances are executed; and the Promoter’s auditors, professional advisers and technology service providers. Personal data may be transferred outside the United Arab Emirates, including to India, USA, and the United Kingdom, subject to appropriate safeguards as required by applicable law.

11.5 Campaign records, including consent records, will be retained as per applicable laws from the end of the Campaign Period in order to evidence compliance with the Promotion Permit and applicable law, and for longer where required by law.

11.6 You have the rights of access, rectification, erasure, restriction, objection, portability and withdrawal of consent, as set out in the Aspora Privacy Policy. To exercise them, or to contact the Data Protection Officer, write to dpo@aspora.com.

12. Financial crime, fraud and abuse

12.1 The Promoter may, at any time and in its reasonable discretion, disqualify a participant, cancel Entries, withhold a Prize or require the return of a Prize where it reasonably suspects: fraud, deception or impersonation; manipulation of the Campaign or the Draw; use of automated means, bots, scripts, emulators or multiple accounts; collusion; breach of these Terms or of the Aspora Terms of Service; or any connection with money laundering, terrorist financing, sanctions evasion or other unlawful activity.

12.2 The Promoter may report any such matter to the police, the Central Bank of the United Arab Emirates, DET, the UAE Financial Intelligence Unit or any other competent authority, and may suspend or close the relevant Aspora account.

12.3 Where a Prize has already been delivered and clause 12.1 applies, the Promoter may recover the Prize.

13. Changes to the Campaign

13.1 The Promoter may amend these Terms, or suspend, shorten, extend, modify or cancel the Campaign, only where it is necessary to do so:

(a) to comply with applicable law, a condition of the Promotion Permit, or a direction of DET, the Central Bank of the United Arab Emirates or any other competent authority;

(b) because of an event beyond the Promoter’s reasonable control which prevents the Campaign being run as planned; or

(c) because fraud, technical failure or manipulation has affected or would affect the integrity or fairness of the Campaign.

13.2 Any such change will be notified through the App and on the Aspora website as soon as reasonably practicable, together with the reason for it.

13.3 No amendment, suspension or cancellation will deprive a person of a Prize to which they have already become entitled. The Promoter will not make retrospective changes to eligibility or to the Prize once the Campaign Period has begun.

14. Liability

14.1 Nothing in these Terms excludes or limits the Promoter’s liability for: (a) fraud or fraudulent misrepresentation; (b) death or personal injury caused by the Promoter’s negligence; (c) gross negligence or wilful misconduct; or (d) any other liability which cannot lawfully be excluded or limited under the applicable laws of the United Arab Emirates.

14.2 Subject to clause 14.1, the Promoter is not liable for:

(a) any indirect, incidental, special or consequential loss, or any loss of profit, revenue, opportunity, goodwill or anticipated saving;

(b) any act or omission of a bank, correspondent bank, fulfilment provider or licensed financial institution, including any delay, charge, deduction or refusal by a receiving bank in relation to the Grand Cash Prize;

(c) any tax consequence of a Prize;

(d) any failure, interruption, delay or error in any telecommunications network, internet connection, device, app store or payment system which prevents or delays an Entry, a notification or a Prize claim, except to the extent caused by the Promoter; or

(e) any loss suffered as a result of a participant’s failure to keep their contact details up to date or to respond within the periods in clause 8.

14.3 Subject to clause 14.1, the Promoter’s total aggregate liability to any participant in connection with the Campaign shall not exceed: (a) in the case of a Winner, the value of the Prize won by that Winner as stated in clause 5; and (b) in the case of any other participant, AED 1,000.

15. Complaints

15.1 Please come to us first. If you are dissatisfied with any aspect of the Campaign, raise your complaint through the in-App Help centre or by writing to help@aspora.com. The Promoter will acknowledge your complaint promptly and provide a final response within thirty (30) days. Where your complaint concerns a financial service provided by the Promoter, the Promoter will provide a final response within fifteen (15) calendar days, and shorter periods apply to certain categories of complaint under the Central Bank of the UAE Consumer Protection Regulation and Standards.

15.2 Complaints about how this promotion was advertised or run. This Campaign is conducted under Promotion Permit No. 26IRS-000000053 issued by the Department of Economy and Tourism, Government of Dubai. If your complaint is about the way the Campaign has been advertised, described or conducted, including the fairness of the Draw, the clarity of these Terms or the way winners are selected and notified, you may complain to the Consumer Protection Department of the Department of Economy and Tourism. Its service is free, and complaints are generally resolved within five working days.

Online: consumerrights.gov.ae
Mobile: the Dubai Consumer application
Telephone and WhatsApp: 600 545 555
Legal basis: Federal Law No. 15 of 2020 on Consumer Protection and its Executive Regulation, Cabinet Decision No. 66 of 2023

15.3 Complaints about a financial service. Where your complaint concerns a financial service provided to you by the Promoter, and the Promoter is a Licensed Financial Institution licensed by the Central Bank of the UAE, you may refer the complaint to Sanadak, the independent financial and insurance Ombudsman Unit established by the Central Bank of the UAE in 2023, once you have received our final response or if we have not responded within the period in clause 15.1. Our final response will tell you whether your complaint is one Sanadak can consider. Submitting a complaint is free for consumers. A fee of AED 500 applies to an appeal, and is refunded where the appeal is determined in your favour. A complaint may be submitted up to three years from the date of the conduct complained of, or up to two years from the date on which you became aware of it.

Online: sanadak.gov.ae, using the Request Support form
Telephone: 800 SANADAK (800 72 623 25)
In person: Sanadak Unit, Emirates Institute of Finance Building, Ground Floor, Sultan Bin Zayed the First Street, Abu Dhabi

15.4 Complaints about your personal data. If your complaint concerns how we have collected, used, published or retained your personal data, including anything in clause 11 or in the Publicity Consent Note, you may complain to the UAE Data Office, the federal data protection authority established under Federal Decree-Law No. 44 of 2021, which handles complaints and grievances relating to Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data. You may contact our Data Protection Officer at dpo@aspora.com at any time.

15.5 Complaining costs you nothing. Raising a complaint with us, or with any of the bodies above, is free, does not affect your Entry, does not affect any Prize you have won, and does not affect your Aspora account, your pricing or the service you receive. Nothing in this clause 15 limits your rights under Federal Law No. 15 of 2020 on Consumer Protection or your right to bring proceedings before the competent courts.

16. General

16.1 Not a lottery or gambling activity. The Campaign is a promotional marketing activity conducted under Promotion Permit No. 26IRS-000000053. It is not a lottery, raffle for consideration, wager, bet or commercial gaming activity, and no consideration is given by any participant for the chance to win.

16.2 No person other than a participant and the Promoter has any right to enforce these Terms.

16.3 If any provision of these Terms is or becomes invalid, illegal or unenforceable, it shall be severed and the remaining provisions shall continue in full force.

16.4 A failure or delay by the Promoter in exercising any right under these Terms is not a waiver of that right.

16.5 The Promoter may assign or transfer its rights and obligations under these Terms to any company in its group or to a successor in business, provided that this does not adversely affect a participant’s entitlement to a Prize.

16.6 Governing law and jurisdiction. These Terms and any dispute arising out of or in connection with them are governed by the federal laws of the United Arab Emirates and the laws of the Emirate of Dubai. The courts of the Emirate of Dubai shall have exclusive jurisdiction, save that this does not limit any right you may have to complain to a regulator or ombudsman.

16.7 Contact. Questions about the Campaign should be addressed to help@aspora.com, or through the in-App Help centre.

Promotion Permit No. 26IRS-000000053 issued by the Department of Economy and Tourism, Government of Dubai.

Consent to the use of your name, photograph and winner story

A. In short

If you win the AED 100,000 Grand Cash Prize we may show your name and your photograph on the Aspora app and website so that other customers can see who won. Agreeing to this is required in order to receive the Prize. We will not ask you for this consent, or for a photograph, unless you are selected as the winner.

You can change your mind at any time. If you withdraw your consent before the draw, your entry is withdrawn. If you withdraw it after the draw, the prize will be awarded to the next eligible participant.

We can only publish a photograph if you give us one, and giving us one is part of entering. We will ask you to upload a photograph if you win. We will never use the photograph from your Emirates ID or from any document you gave us for identity checks. If you do not upload a photograph or do not wish to provide consent for publication of the same on our app / website as the winner, you will not receive the prize and it will be awarded to the next eligible participant. Giving the consents in this Note is required in order to receive the prize, but whether you give your consent is entirely your choice. Choosing not to give your consent means you will not receive the prize, but it will not change anything about your Aspora account, your pricing or the service you receive.

B. Who is asking, and about what

B.1 The controller of your personal data for this purpose is Aspora Information Technology Services LLC SOC (trading as “Aspora”), under Trade License No. 1620032, with its registered office at Rigga Business Centre - 1001-04, Office No 1004-178, Deira, Al Muraqqabat, Dubai, UAE (“we”, “us”, “Our”).

B.2 This consent relates to the “Great Freedom Fest” promotional campaign conducted under DET Promotion Permit No. 26IRS-000000053 (the “Campaign”). It should be read together with the Campaign Terms and Conditions and the Aspora Privacy Policy.

B.3 You give these consents when you are selected to receive the Prize. If you are not selected as a winner, no such consent will be required and nothing will be published about you.

If you win, we will publish the following on the Aspora app and on the Aspora website only:

What	Detail
Your name	Your full name as it appears on your Emirates ID.
Your photograph	One still photograph of you, supplied by you when you are notified as a winner, or taken at a prize handover event with your agreement. We will never use your KYC or identity document photograph.
Your Emirate	Your Emirate of residence only (for example, “Dubai”). We will not publish your address or neighbourhood.
That you are the Winner	That you are the winner of the Campaign.
Where	The Aspora mobile application and the Aspora website at www.aspora.com. Nowhere else under this Consent 1.
For how long	For up to 1 month from first publication, after which it is removed.
Who else sees it	Our hosting, content delivery and app-store providers process the content in order to display it. We do not sell your data and we do not give it to advertisers.
Outside the UAE?	The content is hosted on infrastructure which may be located outside the United Arab Emirates, including in India, the United States and the United Kingdom. Appropriate safeguards are in place as required by law. The app and website are accessible globally.

We will not publish: your Emirates ID number, passport number, date of birth, residential address, telephone number, email address, account number, transaction history, the value of your prize, or any information about the people you send money to.

What you get for agreeing: the Prize. Nothing else about your relationship with Aspora depends on this consent.

If you do not agree: you will not receive the Prize, and it will be awarded to the next eligible participant drawn. Your account, your fees, your exchange rates, your transfer limits and every other aspect of your Aspora service remain exactly the same. You will not be contacted about this again in connection with this Campaign.

This consent is also required in order to win the Prize. In addition to Consent 1, we may use your full name, your photograph, your Emirate of residence and a short quotation or winner story provided by you:

in a press release issued by Aspora, and in resulting coverage by newspapers, magazines, online publications, radio and television in the United Arab Emirates, India, the United Kingdom and elsewhere;
on Aspora’s own social media accounts, including Instagram, Facebook, LinkedIn, X, YouTube and the Aspora WhatsApp channel;
in paid advertising, including in-app, web, social and out-of-home advertising; and
in Aspora’s internal and investor materials.

An important practical point about press and social media. Once a photograph and name have been issued to the media or posted on a social platform, they can be copied, shared, screenshotted, re-posted and indexed by search engines by people we have no control over. If you later withdraw this consent, we will stop using the material and will remove it from our own channels and ask the platforms and publications to do the same — but we cannot guarantee that every third-party copy will be removed. Please take this into account before agreeing.

E. Your confirmations

By giving these consents, you confirm that:

E.1 you are eighteen (18) years of age or older;

E.2 the photograph you provide is a photograph of you, you are the only identifiable person in it, and no other person’s consent is required for its use;

E.3 you own the photograph or have the right to allow us to use it, including the photographer’s permission, and its use by us will not infringe any third party’s intellectual property, image or privacy rights;

E.4 you are not aware of any legal, contractual, professional, employment, immigration or personal restriction which would make publication of your name or photograph unlawful, unsafe or harmful to you;

E.5 you understand that you receive no fee, royalty or other payment for the use of your name, photograph or story, and that you waive any claim to such payment; and

E.6 you have read the Campaign Terms and Conditions and the Aspora Privacy Policy.

If publication would put you at risk — for example because of your personal circumstances, safety, family situation, employer or immigration status — please contact us at help@aspora.com as soon as you are notified, and before you accept the Prize, and we will discuss your options with you in confidence.

F.1 You may withdraw either consent at any time and free of charge. You may withdraw by sending an email to help@aspora.com.

F.2 If you withdraw the consent at any time, your entry into the Campaign is withdrawn and you will not be eligible to receive the Prize. In the event the draw has already taken place the prize will be awarded to the next eligible participant following the similar process.

F.3 Withdrawal does not make unlawful any publication which took place while your consent was in force.

F.4 We will keep a record of this consent and of any withdrawal for five years in order to demonstrate to the Department of Economy and Tourism and any other competent authority that the Campaign was run lawfully. That retention is required by law and does not depend on your consent.

F.5 You also have rights of access, correction, erasure, restriction, objection and portability. To exercise them, or to contact our Data Protection Officer, write to dpo@aspora.com.