Update on 3rd December 2025

These Terms & Conditions (“T&Cs”) govern all promotional skill-based prize competitions (each a “Competition”) operated worldwide by EMERGE 21 LTD, trading as 21Stacker  (“21Stacker”, “we”, “us”, “our”, “the Promoter”). By entering any Competition, you (“entrant”, “you”) agree to be bound by these T&Cs and any additional rules published on the specific Competition page.

Each Competition is a skill-based promotion in which all entrants must correctly answer a qualification skill-question to obtain an eligible entry. All eligible entries (paid or free) are included in a random, provably-fair draw to select the winner.

No purchase is necessary to enter or win. A free Alternate Method of Entry (“AMOE”) is available and provides the same chance of winning as paid entries. Paid entries do not increase the chance of winning.

Competitions are open globally to entrants aged 18 years or over, except where participation is prohibited by local laws. Competitions are void where prohibited.

By participating, entrants also agree to the Promoter’s Privacy Policy, AMOE rules, and any Competition-specific instructions displayed on the applicable Competition page.

1. Nature of the Competition

21Stacker operates global skill-based prize competitions.
To enter any Competition:

1. Entrants must correctly answer a qualification skill question.
2. Only entrants who provide a correct answer will obtain an eligible entry.
3. Eligible entrants may enter by purchasing entries or by submitting a free Alternate Method of Entry (“AMOE”).
4. Paid entries do not increase an entrant’s chances of winning. AMOE entries have exactly the same chance of winning as paid entries.
5. The winner is selected at random from all qualifying entrants using a provably fair, verifiable method.

The skill question is used only for qualification and is not used to determine the winner.

A free entry route (AMOE) is always available and provides equal treatment to paid entries.

21Stacker Competitions are not:
– gambling
– betting
– lotteries
– raffles
– games of chance
– regulated sweepstakes (under U.S. law)
– any activity requiring a gambling licence

Competitions comply with all relevant legal frameworks, including:
– UK Gambling Act 2005 (Prize Competitions Exemption)
– Northern Ireland Betting, Gaming, Lotteries & Amusements Order 1985
– EU consumer transparency rules
– U.S. promotional contest and sweepstakes qualification rules
– Canadian contest requirements (including skill-based eligibility rules)
– Australian trade promotion regulations

Competitions are void where prohibited by local law.

2. Eligibility

2.1 General Requirements

To enter any 21Stacker Competition, entrants must:

1. Be 18 years of age or older at the time of entry.
2. Create a 21Stacker account using accurate, current, and verifiable information.
3. Reside in a jurisdiction where participation in skill-based prize competitions is lawful. Competitions are void where prohibited.
4. Be natural persons entering on their own behalf. Automated entries, bots, scripts, and bulk-generated entries are strictly prohibited.
5. Hold only one account per person. Duplicate or shared accounts are not permitted.
6. Submit entries (paid or AMOE) personally. Entries on behalf of another person are invalid.
7. Not be employees, contractors, directors, officers, agents, suppliers, or affiliates of the Promoter, nor members of their immediate household or family.
8. Not be located in or residents of any restricted jurisdictions, including but not limited to:
   – France
   – Italy
   – Quebec (Canada)
   – Brazil
   – Mexico (if required by local law)
   – Countries subject to UK/US sanctions (including Iran, North Korea, Syria, Afghanistan, Russia, Crimea/Donetsk/Luhansk regions)
9. Comply with all applicable local laws regarding participation.
10. Agree that the Promoter may request identity verification (such as passport, driving licence, utility bill, or KYC document) to confirm eligibility before awarding any prize.
11. Understand that false, misleading, or incomplete information will void all entries and may result in account suspension.

2.2 Eligible Regions

Competitions are open to residents of the following jurisdictions, provided that participation in skill-based prize competitions is lawful where the entrant resides:

• United Kingdom
• Republic of Ireland
• United States, excluding:
  – Florida
  – New York
  – Rhode Island
  – Any other U.S. state where participation is prohibited by law
• Canada, excluding Quebec
• European Union, excluding France and Italy
• Australia
• New Zealand
• South Africa
• Any other jurisdiction where participation in skill-based prize competitions is lawful and not restricted by local regulations

Competitions are void where prohibited.
Entrants are responsible for ensuring that their participation does not violate local laws.

2.3 Restricted U.S. States

Entrants who are residents of the following U.S. states are strictly prohibited from entering any Competition:

• New York
• Florida
• Rhode Island

Entries (paid or AMOE) from these states are void and will not be included in any draw.

21Stacker reserves the right to request proof of residency to confirm eligibility before accepting an entry or awarding any prize.

Attempts to enter from a restricted state using VPNs, proxy servers, false addresses, or any other method of misrepresentation will result in all associated entries being voided and the account being suspended.

Competitions are void where prohibited by state or federal law.

2.4 Prohibited Regions

Competitions are not open to residents of any jurisdiction where skill-based prize competitions or promotional contests are prohibited, restricted, or require licensing or government authorisation that 21Stacker does not hold.
This includes, but is not limited to:

• United Arab Emirates (UAE)
• Saudi Arabia
• Qatar
• China
• Singapore
• Indonesia
• Malaysia
• Thailand
• France
• Italy
• Quebec (Canada)
• Brazil
• Mexico (where local permits are required)
• Any country or region subject to U.S. OFAC sanctions, UK sanctions, EU sanctions, or UN sanctions, including:
  – Iran
  – North Korea
  – Syria
  – Afghanistan
  – Russia
  – Crimea, Donetsk, and Luhansk regions

Entries (paid or AMOE) from prohibited regions are void and will not be included in any draw.

Attempts to enter from a prohibited region using VPNs, proxy servers, IP masking tools, or false address information will result in all associated entries being voided and may result in account suspension.

Competitions are void where prohibited by local law.

2.5 Prohibited Persons

The following persons are not permitted to enter any 21Stacker Competition. Any entries submitted by such persons (paid or AMOE) are void:

1. Employees, directors, shareholders, contractors, developers, advisors, or anyone involved in the creation, operation, or administration of 21Stacker.
2. Any person with access to non-public draw systems, server logs, seeds, or internal operational data.
3. Immediate family members of the Promoter’s directors, founders, or employees, including spouses, partners, parents, children, and individuals residing in the same household.
4. Individuals who have been previously banned or suspended by 21Stacker, or who are under investigation for fraud, manipulation, or abusive behaviour.
5. Automated systems, bots, scripts, crawlers, or any artificial or automated method of entry.
6. Any person attempting to access the platform using VPNs, proxy servers, TOR, IP masking tools, or location-spoofing technology.
7. Persons who create, use, or attempt to use multiple accounts, identities, or addresses.
8. Persons entering on behalf of another individual or submitting entries jointly, bulk entries, or coordinated group attempts.
9. Persons attempting to manipulate or reverse-engineer the skill question, including:
   • sharing answers
   • automated solving
   • mass-submission systems
   • “professional entrant” behaviour
10. Persons abusing the AMOE route through bulk, automated, or mass-produced submissions, or AMOE entries not meeting the posted rules.
11. Persons with a conflict of interest, including those who may have influence over the administration, development, or outcome of any Competition.
12. Affiliates may enter, provided they have no access to non-public systems, seeds, logs, operational data, or backend tools.

2.6 Verification

21Stacker may require entrants at any time (before, during, or after a Competition) to verify their identity and eligibility. Verification may include, but is not limited to, providing:

• Government-issued photo ID (passport, driving licence, national ID)
• Proof of age
• Proof of residency or address (utility bill, bank statement, tax letter)
• Proof of lawful jurisdiction (confirming the entrant is not from a prohibited state or country)
• Proof of ownership and control of the BTC wallet used for payment or prize receipt
• Proof of AMOE compliance (where applicable)

21Stacker may also conduct:

• Sanctions checks (OFAC, UK, EU, UN)
• Fraud screening
• Duplicate account checks
• BTC wallet analysis/ownership verification
• Video verification calls, where necessary

The Promoter may request additional information at its discretion to confirm eligibility or rule compliance.

Failure to provide complete, accurate, and satisfactory verification within the stated timeframe will result in disqualification, voiding of entries, and/or award of the prize to an alternate qualifying entrant.

2.7 Void Where Prohibited

Competitions are void where prohibited by local, state, federal, or international law.
21Stacker does not represent or warrant that participation is lawful in any particular jurisdiction.

Entrants are solely responsible for ensuring that their entry and participation comply with all laws applicable to them. The Promoter may void, suspend, or refuse entries if:

• the entrant is located in, or a resident of, a prohibited or restricted jurisdiction;
• participation would be unlawful under local regulations;
• geolocation, IP data, or verification checks indicate a prohibited region;
• the entrant attempts to circumvent regional restrictions through VPNs, proxies, TOR, or false address information.

All entries—including AMOE entries—from prohibited jurisdictions are void and will not be included in any draw.

21Stacker reserves the right, at its sole discretion, to determine whether an entrant is eligible based on residency, location, or applicable legal restrictions.

3. Prize Structure

Each Competition awards one fixed prize denominated in Bitcoin (BTC) to one winner.

The published prize:

• Is fixed and does not change
• Is not dependent on the number of entries, paid or AMOE
• Must be awarded once the draw is triggered, even if the entry cap is not reached
• Will be delivered as the specified amount of BTC, not the fiat equivalent
• May vary in fiat value due to Bitcoin price movements; the Promoter accepts all volatility risk
• Is non-transferable and non-exchangeable, unless required by law
• Will only be transferred to a BTC wallet verified as being owned and controlled by the winner

No alternative prize will be offered except where the Promoter is legally required or where technical circumstances make delivery impossible, in which case a prize of equivalent or greater BTC value may be offered.

3.2 One Winner

Each Competition will produce one (1) winner only.

A “provisional winner” is the entrant initially selected at random from all eligible entries.

21Stacker will conduct verification checks to confirm the provisional winner’s:

• eligibility
• identity
• residency
• correct skill-question answer
• compliance with the T&Cs
• wallet ownership (for BTC prizes)

If the provisional winner:

• fails any verification check,
• is found to be ineligible,
• breaches any Competition rule, or
• cannot be contacted or does not respond within the stated time period,

their entry will be void, and a redraw will be conducted.

Redraws:

• are performed from the original pool of qualifying entries only
• do not include any new entries
• will continue until a fully verified and eligible winner is confirmed
• do not entitle the disqualified entrant to any compensation or alternative prize

The Promoter’s decision on verification and redraws is final.

3.3 Equal Treatment

All qualifying entries—whether paid or submitted via the free Alternate Method of Entry (AMOE)—are treated equally in every Competition. Specifically:

• Paid entries and AMOE entries receive equal weight in the draw.
• All qualifying entries have identical odds of being selected as the provisional winner.
• All entries are included in the same combined pool for the random draw.
• Paid entries do not increase an entrant’s chance of winning under any circumstances.
• No bonuses, multipliers, preferential weighting, or enhanced odds are provided to any entrant.
• AMOE entries are logged, timestamped, stored, and processed using the same system and criteria as paid entries.
• AMOE entries must also answer the skill question correctly and meet all eligibility requirements before being included.
• No distinction is made between paid and free entries at the point of winner selection.

The winner is always selected at random from the combined pool of all qualifying entries.

3.4 No Refunds

All payments made in Bitcoin (BTC), including Lightning Network payments, are final, non-refundable, and irreversible.
BTC transactions cannot be reversed by 21Stacker, payment processors, miners, Lightning nodes, or wallet providers.

This no-refund policy applies because:

• entry is not required to participate (AMOE available)
• payment does not increase the entrant’s chance of winning
• the prize competition is a fixed-prize skill-based promotion, not a gambling product

Once an entry (paid or AMOE) is accepted and logged into the system, it cannot be cancelled, refunded, or withdrawn.

Refunds are issued only in the following limited circumstances:

• Proven duplicate billing arising from a verifiable technical error
• Verified Promoter system error that resulted in an unintended duplicate or incorrect invoice being marked paid

No refunds will be issued for any of the following:

• user wallet errors
• incorrect invoice amount
• incorrect payment destination or wrong QR code
• expired Lightning invoices
• partial payments
• insufficient fee-rate on on-chain transactions
• network congestion or confirmation delay
• abandoned checkout flows
• accidental payments
• BTC price fluctuation between payment and draw
• attempts to reverse, claw back, or reassign BTC entries
• failure to complete verification
• failure to win

The Promoter is not responsible for the behaviour of third-party wallets, exchanges, or Lightning services that may retry, batch, or alter the apparent structure of a payment.

Refunds will not be issued after the draw has triggered.

3.5 Transparency

Each Competition page will clearly and prominently display:

• Prize amount (BTC)
• Fixed and guaranteed prize statement
• Entry cap (total available entries)
• Max entries per user
• Remaining entries in real-time
• Closing time or “draw triggers on max fill” wording
• Draw Series name (e.g., “September 0.021 Draw 1”)
• Qualification skill question
• Ticket price (in sats)
• Equal odds disclosure (“Paid and AMOE entries have equal chance of winning”)
• No purchase necessary disclosure (“Free postal entry available”)
• Eligibility summary (global + regional restrictions)
• Provably fair commitment hash, including:
  • pre-commit hash
  • explanation that this locks results
  • explanation that the winner is derived from first Bitcoin block after close
• Link to full Terms & Conditions
• Link to the AMOE instructions
• Link to the Privacy Policy

4. Entry Process

4.1 Account Creation

All entrants must create a 21Stacker account before completing any paid entry or postal (AMOE) entry.
To create an account, entrants must provide:

• Legal first and last name
• Valid email address
• Country of residence
• Password and/or authentication credentials

By creating an account, entrants confirm that:

• All information provided is complete, accurate, and truthful
• They are 18 years of age or older.
• They meet all eligibility requirements
• They are entering on their own behalf
• They agree to the Terms & Conditions, Privacy Policy, and AMOE rules

Accounts must not:

• be created using false, incomplete, or misleading information
• be created on behalf of another person
• be created using bots, automation, or scripts
• duplicate an existing account held by the same individual

21Stacker may require entrants to verify their account information (identity, age, residency) at any time.
Account information must match verification documents.

Entries associated with false, unverifiable, or mismatched account information will be void.

(New and returning customers are prompted to create an account or log in prior to checkout.)

4.2 Mandatory Skill Qualification

Before submitting any entry—paid or via the Alternate Method of Entry (AMOE)—entrants must correctly answer the designated skill-based qualification question.

The following rules apply:

1. Only entrants who answer the skill question correctly may proceed to submit a paid entry or AMOE submission.
2. Incorrect answers cannot proceed and will not generate an entry.
3. Paid checkout unlocks only after the correct answer is selected.
4. AMOE entries must also include the correct answer and meet all eligibility requirements.
5. Skill question responses are stored, timestamped, and logged to demonstrate compliance with skill-based competition standards.
6. The correct answer will not be disclosed publicly until after the draw closes.
7. Entrants must answer the question personally; the use of automation, scripts, bots, answer-sharing systems, or reverse-engineering is strictly prohibited.
8. The Promoter may update or change the skill question for future Competitions without notice.
9. The Promoter may reject or void entries where the skill question response appears to be generated or submitted through automated means.

This mechanism is essential to maintaining the Competition’s legal status as a skill-based prize competition, rather than a lottery or game of chance.

4.3 Paid Entry (Bitcoin Only)

After successfully answering the skill question, entrants may submit a paid entry using Bitcoin only (Lightning Network or on-chain where offered).

The following rules apply:

1. A unique Lightning invoice is generated for each entry attempt.
2. The invoice must be paid in full before expiry.
3. Expired, partial, incorrect, or reused invoice payments do not create entries.
4. Entry numbers are created only after:
   • the invoice is fully settled, and
   • the skill question answer has been validated
5. Paid entries do not increase the entrant’s chance of winning under any circumstances.Entry credits issued by the Promoter are treated as a method of entry only and are subject to the same eligibility, skill-question, AMOE parity, and fraud-prevention rules as all other entries. 
6. Once payment is recorded, the entrant will receive a confirmation email with entry/ticket details.
7. Entries will appear in the entrant’s dashboard once processed. Short delays may occur while payment is confirmed and recorded.
8. No fiat payments are accepted.
9. The Promoter is not responsible for wallet errors, incorrect invoice amounts, expired invoice attempts, multi-path/partial Lightning payments, or the behaviour of third-party wallet or exchange services.
10. No refunds are available once a valid entry has been created, except in cases of verified duplicate billing as defined in Section 3.4.

Paid entries are accepted only after the entrant has satisfied all eligibility, verification, and skill-question requirements.

4.4 Finality of Bitcoin Payments

All payments made in Bitcoin (BTC), including Lightning Network payments, are final, irreversible, and non-refundable.

BTC transactions cannot be reversed by 21Stacker, Lightning nodes, miners, wallet providers, or exchanges.

Paid entries do not increase the entrant’s chance of winning. A free Alternate Method of Entry (AMOE) is always available.

Non-Refundability

Once a BTC payment is received and an entry is created, no refunds, cancellations, or withdrawals will be issued, except as explicitly stated below.

Refunds are not provided for:

• expired or unpaid Lightning invoices
• partial payments
• incorrect payment amount
• wrong invoice, wrong QR code, or reused invoice
• network congestion, routing failures, or confirmation delays
• wallet errors, exchange-service errors, or user mistakes
• abandoned checkout flows
• Bitcoin price movement after payment
• failure to complete verification
• failure to win
• any attempt to reverse or dispute a transaction

Refunds (Limited Circumstances)

Refunds are issued only in the case of verified Promoter system errors, which are defined as:

• duplicate billing caused solely by the 21Stacker platform
• incorrect invoice generation due to platform fault
• platform-side failure where an invoice was marked paid despite no payment being received by the Promoter
• any confirmed technical malfunction where the entrant was charged twice for the same ticket

No refunds will be issued after the draw has been triggered.

Entrant Acceptance

By completing a BTC payment, the entrant confirms that they:

• understand BTC payments are irreversible
• accept these payment terms in full
• waive the right to dispute the transaction except in the limited cases defined above

4.5 Entry Confirmation

An entry is considered valid and included in the draw only when all of the following conditions are satisfied in sequence:

1. The entrant has correctly answered the skill question.
2. For paid entries, the Lightning invoice has been fully settled before expiry.
3. The entry has been accepted, logged, and assigned a unique entry number by the 21Stacker system.
4. A confirmation email has been generated and issued to the entrant.
   (Email delivery failures do not invalidate a valid entry.)

For AMOE entries, validity requires:

• a correct skill-question answer,
• a complete and compliant AMOE submission, and
• manual confirmation being recorded by the Promoter.

Only entries that appear in Promoter’s internal draw ledger are eligible for the random draw.

Entries are not created or are later void if:

• the Lightning invoice expired, was partial, incorrect, or reused
• the entrant fails eligibility or verification checks
• the entrant used multiple accounts, VPN, proxy, or masked IP
• false or misleading registration information was used
• the entrant resides in a prohibited region

The Promoter may void any entry that breaches these Terms at any time before the prize is awarded.

4.6 Entry Limits

4.6.1 Paid Entry Limits

Each natural person may purchase up to 210 paid entries per Competition.
This limit applies per individual, not per account, device, email address, household, or payment method.

The Promoter may void entries that:

• exceed the per-person limit
• originate from multiple accounts belonging to the same individual
• are submitted using VPNs, proxies, TOR, masked IPs, or automation
• attempt to bypass limits through technical or behavioural manipulation

The Promoter’s internal logs, device fingerprinting data, and fraud-analysis tools are final and conclusive in determining entry validity.

4.6.2 AMOE (Free Entry Route) Limit

Each natural person may submit strictly one (1) AMOE (free postal) entry per Competition.

To be valid, the AMOE submission must:

• match the entrant’s existing 21Stacker account details exactly
• include the correct answer to the skill question
• be handwritten entirely by the entrant
• specify the exact Competition name and Draw Series
• include all required personal information, clearly and legibly

Multiple AMOE submissions from the same individual are strictly prohibited.

4.6.3 AMOE Duplicate Detection & Enforcement

To enforce the “one AMOE per person” rule, the Promoter may use:

• name and address matching
• handwriting comparison
• IP/device metadata (for linked account activity)
• behavioural pattern analysis
• entry timestamps and postal data
• identity and residency verification
• internal fraud-detection algorithms

If the Promoter determines that multiple AMOE entries originate from the same individual, all related entries (AMOE and paid) may be voided, and the associated account may be suspended or terminated.

The Promoter’s determination is final.

4.6.4 Equal Treatment of Paid & AMOE Entrants

Paid and AMOE entrants must:

• meet identical eligibility requirements
• answer the same skill question
• enter into the same draw pool
• receive equal weighting and identical winning odds

Entry limits apply per Competition, even within the same Draw Series.

4.6.5 Finality of Entry Validation

The Promoter’s internal entry logs, fraud-prevention systems, and account-level data are decisive in determining:

• entry validity
• duplicate AMOE detection
• per-person entry limits
• eligibility
• compliance with these Terms

The Promoter retains the right to void any entry that violates these limits or raises reasonable suspicion of abuse.

4.7 Free Entry Route (AMOE)

Each entrant may submit one (1) free Alternate Method of Entry (“AMOE”) per person per Competition.

To be valid, AMOE submissions must meet all of the following requirements:

AMOE Format Requirements

1. AMOE submissions must be sent as a handwritten postcard only.
   Envelopes are not permitted, and postcards received inside envelopes are void.
2. The postcard must be handwritten entirely by the entrant.
   The following are prohibited and will void the entry:
   • typing
   • printing
   • photocopying
   • stickers or labels
   • pre-printed templates
   • digital handwriting or automation
   • bulk or mass-produced submissions
3. All required details must appear on ONE SIDE ONLY of the postcard.
   Any writing on the reverse side voids the entry.

Required Details (All on One Side Only)

Entrants must handwrite the following information clearly and legibly:

• Full legal first and last name
• Date of birth (confirming the entrant is 18+)
• Country of residence
• Email address used for the entrant’s 21Stacker account
• The correct skill-question answer
• The exact Draw Series name
  (e.g., “September 0.021 Draw 1”)

All details must match the entrant’s registered 21Stacker account.

Addressing & Postage

• The postcard must be addressed to the correct regional AMOE address only.
• The postcard must have correct and sufficient postage.
• It must be received before the published Competition close time to be included in that draw.
• The postcard must not include money, vouchers, or any additional items.

Invalid AMOE Submissions

AMOE postcards are void if:

• information is missing, false, incomplete, or illegible
• submitted inside envelopes
• written on both sides
• the incorrect skill answer is included
• the Draw Series name is missing or incorrect
• a matching 21Stacker account does not exist
• multiple AMOE entries are submitted per person
• entries appear automated, mass-produced, or not personally handwritten
• the entrant resides in a prohibited region
• multiple individuals are listed on one postcard
• the postcard is too damaged to read

Lost, delayed, stolen, postage-due, or misdelivered postcards are not the responsibility of the Promoter.

Equal Treatment

Valid AMOE entries receive:

• equal weighting
• equal odds
• equal inclusion in the random draw

Paid entries receive no advantage under any circumstances.

Late AMOE 

AMOE postcards received after the Competition close time will be:

• rolled forward to the next Competition within the same Draw Series,
• provided the skill question and prize remain the same.

If the Draw Series has already concluded, late AMOE postcards will be void.

4.8 Anti-Fraud & Location Enforcement

To maintain the fairness, integrity, and legality of all Competitions, 21Stacker employs strict anti-fraud and location-verification measures.

The following are strictly prohibited:

• use of VPNs, proxy servers, TOR, or any IP-masking technology
• creation or use of multiple accounts
• bots, scripts, automation, or bulk-processing tools
• location spoofing or misrepresentation of residency
• identity manipulation, false details, or forged documents
• entering on behalf of another person
• using shared wallets, shared email addresses, or shared devices to circumvent limits
• technical or procedural attempts to bypass entry limits or regional restrictions
• entering from OFAC, UK, EU, or UN-sanctioned jurisdictions

21Stacker may use IP data, device information, geolocation checks, and other fraud-detection tools to verify eligibility and detect prohibited behaviour.

The Promoter reserves the right to:

• void entries (paid or AMOE)
• withhold or cancel entry numbers
• freeze or suspend accounts
• request verification
• block access to the platform
• disqualify a provisional winner

at any time before or after entry confirmation, if fraud, prohibited methods, or regional violations are detected.

The Promoter’s internal system logs and eligibility records are final and conclusive.

5. AMOE (Alternate Method of Entry) — Postal Free Entry

Each entrant may submit strictly one (1) AMOE entry per Competition.
AMOE exists to ensure equal access and is treated identically to paid entries in the drawing process.

All AMOE entries must correspond to a single, valid 21Stacker account created by the entrant before the AMOE is posted.

An AMOE entry is void unless all of the following details match exactly with the entrant’s registered 21Stacker account:

• Full legal first and last name
• Email address associated with the account
• Country of residence
• Confirmation of 18+ age
• The exact Draw Series name (e.g., “September 0.021 Draw 1”)
• The correct skill-question answer
• All other personal details required by Section 4.1

AMOE entries must be handwritten entirely by the entrant and comply with Section 4.7. Printed, typed, photocopied, stamped, or mass-produced entries are invalid.

AMOE entries are void if:

• any required detail is missing, incorrect, incomplete, or illegible
• the AMOE does not match the entrant’s registered account
• the entrant submits more than one AMOE for the same Competition
• the entrant uses multiple accounts
• the entrant resides in a prohibited region
• the skill question answer is incorrect
• the Draw Series name is missing or inaccurate
• the submission is automated, bulk-produced, courier-delivered, or enclosed in an envelope
• the entry is postmarked after the relevant deadline

Valid AMOE entries are internally logged and receive equal treatment, equal weight, and equal odds in the draw.
Email or dashboard confirmation is not required for AMOE validity.

Participation in the Partner Programme, receipt of Partner entry credits, or use of promotional links does not increase the chances of winning compared to AMOE entries.
All valid entries are treated equally in the draw.

5.2 AMOE Addresses

AMOE entries must be sent via standard postal mail only (no hand delivery, courier, or electronic delivery).
Entrants must use the correct AMOE address for their region of residence.

UK, Northern Ireland, Republic of Ireland, EU, Australia, New Zealand & Rest of World

21Stacker – Free Entries
Ground Floor, Gallery Building
65–69 Dublin Road
Belfast
BT2 7HG
United Kingdom

United States Entrants

21Stacker – Free Entries
2803 Philadelphia Pike
Suite B #1011
Claymont, DE 19703
USA

AMOE Postal Requirements

• The card must be addressed to the correct regional address.
• Correct postage is required. Underpaid or postage-due entries are void.
• No additional items, cash, or vouchers may be enclosed.
• The Promoter is not responsible for AMOE entries that are lost, delayed, damaged, stolen, misdelivered, or otherwise not received.

5.3 AMOE Deadlines

AMOE entries operate on a strict postmark-and-arrival system to ensure fairness.

To be valid for a Competition, an AMOE postcard must:

1. Be postmarked on or before the exact date and time the paid entry cap is reached (early close),
   OR on or before the published Draw End Date (normal close), and
2. Be received before the winner is drawn (i.e., before the block-hash selection occurs), and
3. Meet all validity requirements in Sections 4.7 and 5.1.

Handling of Late AMOE

• AMOE postmarked on time but arriving after the Competition has closed will be rolled forward to the next Competition in the same Draw Series only if:
  • the same skill question is still active
  • the same prize applies
  • the Series remains active within the same calendar month
• AMOE may roll forward only once and only within the same Draw Series.

AMOE That Cannot Roll

The following AMOE entries are void and cannot roll:

• AMOE postmarked after the entry cap is reached
• AMOE arriving after the next draw in the Series has been completed
• AMOE submitted for a Series that has ended
• AMOE attempting to cross into a new month or a new skill-question period

Additional AMOE Rules

• AMOE cannot delay, pause, or affect the timing of any draw.
• All valid AMOE entries are logged internally upon receipt.
• The Promoter may verify postmarks and reject illegible, altered, or fraudulent postmarks.

5.4 AMOE Rollover

If a Competition reaches its paid entry cap early:

• Paid entries close immediately
• The winner is drawn within 24 hours using the next eligible Bitcoin block hash
• A new draw in the same Series may be launched immediately

Rollover Rules for AMOE

AMOE entries:

• postmarked on or before the moment the cap is reached, but
• received after the draw has closed

→ will be rolled to the next Competition in the same Draw Series, provided:

• the skill question remains unchanged
• the prize remains unchanged
• the next Competition is scheduled within the same calendar month
• the Series is still open

Rolled AMOE entries receive:

• equal treatment
• equal weight
• equal odds
• identical draw inclusion

Restrictions

AMOE cannot:

• roll into a new month
• roll into a Competition with a new skill question
• roll into a Competition with a different prize
• roll more than once
• be used to delay or influence draw timing

Validity Requirements for Rolled AMOE

Rolled AMOE must still satisfy all requirements in:

• Section 4.7 (AMOE Format)
• Section 5.1 (Matching Account Details)
• Section 5.3 (Postmark/Arrival Rules)

Including:

• correct skill question answer
• handwritten postcard format
• matching personal details
• legible handwriting
• correct Draw Series name
• valid postmark

All rolled AMOE entries are logged internally and automatically included in the entrant pool for the next eligible draw.

6. Skill Requirement

Every Competition operated by 21Stacker is a skill-based prize contest, not a lottery or game of chance.
To qualify for any Competition:

• Every entrant must personally answer the skill question correctly.
• Paid and AMOE entrants must meet the same skill threshold, without exception.
• Entries with incorrect answers are void and cannot proceed.

This ensures that the element of chance applies only after skill has been demonstrated, satisfying global legal standards for skill-based competitions.

6.1 Mandatory Skill Question

Before any entry—paid or AMOE—can be accepted:

1. The entrant must select or write the correct answer to the published skill question.
2. The paid checkout is accessible only after a correct answer is provided.
3. AMOE submissions must handwrite the correct answer on the postcard.
4. AMOE or paid entries containing incorrect answers are invalid.

The Promoter reserves the right to verify the authenticity of any answer, including handwriting analysis for AMOE.

Incorrect answers:

• void the entry
• cannot roll into another Competition
• cannot be corrected after submission

6.2 Nature of Skill Questions

Skill questions may cover any Bitcoin-related topic requiring:

• knowledge
• judgment
• reasoning
• conceptual understanding

Examples include:

• Bitcoin fundamentals
• Proof-of-Work
• Lightning Network concepts
• Timechain and block logic
• Difficulty adjustment
• Bitcoin economics
• Halving cycles
• Bitcoin history or governance
• Mathematical or pattern-recognition challenges themed around Bitcoin

Skill questions are selected to ensure:

• a significant proportion of entrants cannot answer correctly, and/or
• a significant proportion are prevented from winning due to incorrect responses

This satisfies the legal definition of a genuine skill competition under UK/NI law and the “skill contest exemption” under US law.

Questions are typically rotated monthly, and one question applies to every draw within that month’s Draw Series.

6.3 Equal Skill Requirement

All entrants must satisfy the same skill standard, including:

• same question
• same difficulty
• same correct answer
• same qualification criteria
• same Draw Series requirements

Paid entry does not allow bypassing the skill test.
AMOE does not allow bypassing the skill test.

Equal skill requirement ensures:

• fairness
• legal compliance
• identical qualification conditions
• non-discrimination between entry routes

6.4 Skill Question Disclosure & Transparency

The skill question:

• is displayed prominently on each Competition page
• must be answered before checkout or AMOE submission
• remains consistent for all draws within the same Draw Series
• may change only at the start of a new Draw Series or a new monthly period

The Promoter may:

• retire a question early
• replace a question at the start of the next Series
• adjust difficulty
• refuse to disclose reasoning, marking methods, or metadata

6.5 No Assistance, Automation or Third-Party Completion

Entrants must answer the skill question personally without:

• external help
• automated tools
• AI systems
• collaboration
• copying or reproduction

For AMOE, handwriting must be the entrant’s own.
For paid entries, the Promoter may investigate suspicious answer patterns.

Any indication of cheating voids all related entries.

6.6 Correct Answer Requirement

Only entries that include the correct answer:

• qualify
• may proceed to checkout (for paid entries)
• are entered into the draw
• may roll over (AMOE rules apply)

Incorrect answers:

• are void
• cannot be corrected later
• do not roll over
• do not form part of the Frozen Ticket List

6.7 Promoter Determination is Final

The Promoter’s determination of:

• whether an answer is correct
• whether handwriting is valid
• whether the entrant answered personally
• whether the skill requirement is satisfied

…is final and binding.

No correspondence or appeals will be entered into.

7. Competition Period & Draw Mechanics 

7.1 Series Format

Competitions operate using a monthly Draw Series structure.
Each Series is identified using the following naming format:

Month + Prize + Draw Number
(e.g., September 0.021 Draw 1, September 0.021 Draw 2, October 0.21 Draw 1)

Each Draw Series is defined by:

• The same prize value for all draws in that Series
• The same monthly skill question, which applies to all draws in that Series
• Multiple sequential draws, which may be created if demand fills one draw early
• Clear continuity, meaning all draws under the same Series share identical qualification criteria

The Draw Series format ensures:

• Consistency of rules
• Equality of treatment for all entrants
• Predictable AMOE rollover rules (AMOE may roll only into the next draw within the same Series if eligible)
• Transparency about prize and skill question
• No material changes to the Competition conditions after entry

The Promoter may create additional draws within a Series when demand exceeds capacity, but may not change the prize or skill question within the same Series.
Changes to prize amount or skill question will only occur when launching a new Series.

7.2 Opening & Closing

7.2 Opening, Closing & Extensions

Each Competition opens at the date and time published on its draw page.

Every Competition operates with two possible closing mechanisms, both of which are clearly displayed to entrants:

(1) Scheduled Draw End Date (Countdown Timer)

Each Competition displays a countdown timer indicating the scheduled Draw End Date and time (UK local time).

If the entry cap is not reached before the countdown expires:

• The Competition will close automatically at the scheduled Draw End Date
• The winner will be selected immediately using the provably fair process

(2) Early Close When Entry Cap Is Reached

If paid entries reach the published entry cap before the scheduled Draw End Date:

• Paid entries stop immediately
• The countdown timer will switch to “Sold Out / Closed Early”
• The Competition is deemed closed at that moment
• The winner will be drawn within 24 hours of the early close

A new draw within the same Draw Series may launch immediately after early close.

Early close applies equally to paid entrants and AMOE entrants.

7.2.1 Extension Policy (Exceptional Circumstances Only)

The Promoter will not extend the scheduled Draw End Date except in exceptional circumstances beyond the Promoter’s control, including but not limited to:

• Server or system failure affecting entry processing
• Bitcoin blockchain or Lightning Network disruption affecting the draw
• Security concerns, fraud detection or required technical investigation
• Widespread outages of critical infrastructure
• Force majeure events (e.g., natural disasters, major regional outages)
• Legal or regulatory requirements

Any extension:

• Will be the minimum period necessary
• Will be announced clearly on the Competition page
• Will apply equally to all entrants (paid and AMOE)
• Will never be used for commercial reasons (e.g., low sales)

The Promoter will never extend a draw simply because the entry cap was not reached.

7.2.2 No Other Changes

Once a Competition has opened:

• The entry cap will not be changed
• The prize will not be changed
• The skill question will not be changed
• The Draw Series name will not be changed

This ensures fairness, consistency, and compliance with global prize-competition standards.

7.3 Early Close 

If paid entries reach the published maximum entry cap before the scheduled Draw End Date:

• Paid entries close immediately and automatically
• The countdown timer will display “Sold Out / Closed Early”
• No further paid entries can be purchased
• The Competition will be deemed closed at that exact moment
• The winner will be selected within 24 hours of early close using the provably fair randomisation method
• A new draw within the same Draw Series may launch immediately afterward
• AMOE rollover rules apply as set out in Section 5

AMOE Fairness

To maintain equal treatment:

• AMOE entries postmarked before the exact moment the entry cap is reached remain eligible
• AMOE entries arriving after early close may roll into the next draw in the same Series (if available)
• AMOE cannot roll into a new Series with a different skill question or prize

Transparency & Compliance

This early close process is:

• Fully disclosed on each Competition page
• Applied consistently to both paid and free entrants
• Designed to prevent misleading countdown behaviour
• Compliant with UK CAP/ASA rules, EU consumer transparency requirements, and U.S. contest fairness standards

The Promoter will not artificially adjust, alter, or manipulate the entry cap to achieve an early close for commercial reasons.

7.4 AMOE Deadlines & Rollover

AMOE (free) entries must meet all of the following requirements:

• Be handwritten and complete
• Include the correct answer to the skill question
• Be postmarked before the exact moment the paid entry cap is reached
• Be received before the winner draw occurs (within the 24-hour post-cap window)
• Match an existing 21Stacker account
• Clearly state the correct Draw Series name (e.g., September 0.021 Draw 1)

AMOE entries postmarked after the exact time of cap fill are void for that draw.

Rollover Rules

An AMOE entry received after early close may roll over into the next draw within the same Draw Series, but only if:

1. Another draw in that Series exists
2. The skill question remains the same
3. The prize remains the same
4. The Series is still active

If a Draw Series ends (prize or skill question changes), AMOE cannot be carried forward and becomes void.

Equal Treatment

AMOE entries:

• Are given equal weight to paid entries
• Receive no disadvantage in the draw
• Must meet the same skill qualification standard
• Do not extend or delay any draw

Fraud & Compliance Notes

• AMOE must be handwritten and legible; illegible entries are void
• Photocopies, printed entries, bulk AMOE mailings, or automated submissions are prohibited
• The Promoter may reject AMOE mail suspected of mass submission, tampering, or identity fraud

IMPORTANT

AMOE arriving late does not reopen a closed draw or delay winner selection.

7.5 Winner Selection (Provably Fair)

Each winner is selected using a cryptographically verifiable, manipulation-resistant method combining a pre-committed server seed with publicly verifiable Bitcoin blockchain data.

The process is as follows:

(1) Frozen Ticket List

Immediately when the Competition closes (either by entry cap fill or by reaching the Draw End Date):

• All valid entry numbers are frozen
• No further additions, deletions, or modifications may occur
• A cryptographic timestamp of the Frozen Ticket List is stored internally for audit

Entrants cannot be added or removed after the freeze point.

(2) Anchor Block

The Anchor Block is defined as the first Bitcoin block mined after the freeze point.

• The block height is not chosen by the Promoter
• The block hash is public, immutable, and outside the Promoter’s control
• If the immediately following block becomes orphaned, the next confirmed block is used

(3) Pre-Commitment System

Before the Competition opens, the Promoter publishes a hashed (SHA-256) server seed.

After the Competition closes:

• The unhashed original server seed is revealed
• Entrants can verify the seed matches the previously published hash
• No reseeding, no modification, and no alternate seeds are permitted

This ensures the Promoter cannot alter the seed after knowing the Anchor Block hash.

(4) Random Number Generation

A deterministic random value is generated using SHA-256 applied to the following concatenated inputs:

• The Anchor Block hash
• The revealed server seed
• The Draw Series ID (e.g., “September-0.021-Draw-1”)

This produces a 256-bit output.

(5) Modulo Reduction

To select a winner fairly:

• The 256-bit integer output is reduced modulo the total number of valid entries
• The resulting index corresponds to one position in the Frozen Ticket List

This ensures a uniform distribution across all entry numbers.

(6) Winner Selection

The entry number at the resulting index is the winner.

There are:

• No re-rolls
• No human involvement
• No alternative methods
• No discretion by the Promoter

In the event the winning entrant fails verification, the Promoter repeats the modulo process once, excluding only the disqualified entry.

(7) Public Verifiability

Entrants may independently verify:

• The Anchor Block hash on any Bitcoin block explorer
• The server seed hash match (pre-commitment integrity)
• The SHA-256 deterministic process
• The Frozen Ticket List (entry numbers assigned pre-freeze)
• The modulo output

This guarantees:

• Zero manipulation risk
• Zero internal influence
• Full cryptographic auditability
• Trustless verification by any entrant

7.6 No Human Intervention

The winner-selection process is fully automated and cryptographically verifiable.
No individual—including employees, officers, contractors, developers, or affiliates—may:

• Alter, replace, or modify server seeds
• Insert, remove, or edit entries after the freeze point
• Change the Frozen Ticket List
• Influence or interfere with the Anchor Block selection
• Adjust or override the randomisation process
• Select, veto, or substitute a winner
• Trigger manual re-rolls or alternate randomisation methods

Early Close Exception (Operational Only)
When a draw fills early by reaching the paid entry cap, the only permitted human action is the administrative confirmation of early close, after which:

• The system freezes entries
• The Anchor Block is automatically determined
• The deterministic randomisation process begins
• A winner is produced within 24 hours through the automated RNG process

This administrative step:

• Does not influence the winner
• Does not alter the algorithm
• Does not permit discretionary timing changes
• Only acknowledges a rule-based event (cap fill)

All mechanisms used to generate the winner are fixed, transparent, publicly verifiable, and cannot be altered by the Promoter.

7.7 Draw Failures

If the automated winner-selection process cannot be completed due to a technical or cryptographic failure, the Promoter will implement a fixed, transparent fallback protocol to preserve fairness and provable randomness.

A “Draw Failure” includes:

• Server or system faults preventing the freeze or RNG process
• Inability to retrieve or verify the Anchor Block hash
• Blockchain disruption resulting in delayed or orphaned blocks
• Server seed mismatch (does not match published hash)
• Corrupted or unreadable Frozen Ticket List
• Any event preventing verifiable execution of the stated RNG method

Fallback Procedure

If a Draw Failure occurs, the Promoter may take only the following actions, in this order:

(1) Delay the Draw

The Promoter may delay the draw for the minimum time necessary to restore system integrity.
Any delay will be:

• Announced on the Competition page
• Applied equally to all entrants
• Non-commercial and purely technical

(2) Use a Replacement Anchor Block

If the intended Anchor Block cannot be used (e.g., orphaned or retrievable errored):

• The next confirmed Bitcoin block will be used as the replacement Anchor Block
• This will be stated clearly during verification

(3) Seed Reselection (Only if Required)

If the pre-committed server seed fails validation:

• A new server seed will be generated
• Its hash will be published before re-running the RNG
• Entrants may verify the new seed using the same process
• The replacement seed may only be used after documenting the original rejection reason

(4) Re-Run of RNG with Replacement Inputs

If both the Anchor Block or server seed require replacement, the RNG will be run using:

• The replacement Anchor Block
• The replacement server seed
• The original Frozen Ticket List
• The Draw Series ID

This maintains the integrity of the deterministic process.

(5) Replacement Entries (Only if Entry Data Is Corrupted)

If the Frozen Ticket List itself becomes corrupted and cannot be reconstructed:

• The Promoter may recreate entry numbers from verified backend logs
• Only validated, time-stamped, pre-freeze entries may be included
• No new entries may be added
• No entrant may be removed

(6) Refunds (Absolute Last Resort)

Refunds will only be provided if no valid draw can take place after all fallback procedures have been attempted.

Refunds are strictly limited to:

• Paid entries affected by the failed draw
• Refunds issued in Bitcoin
• AMOE entrants receive no monetary refund

No refunds will be issued for delays or fallback procedures where the draw can still be completed.

8. Winner Verification

8.1 Notification

When a draw concludes, the system will automatically identify a provisional winner using the provably fair selection method.

All winners displayed on the website or in promotional materials are considered provisional winners until identity, eligibility, and residency verification is completed.
Publication of a winner’s first name and initial does not constitute final confirmation of prize entitlement.

The provisional winner will be contacted at the email address registered with their 21Stacker account and must respond within 21 days.
Failure to respond, failure to complete verification, or failure to meet eligibility requirements will result in forfeiture, and the prize will be reawarded to an alternate entrant using the same provably fair draw process.

8.2 Verification Documents Required

To confirm eligibility and receive the prize, the provisional winner must provide the following within the verification timeframe:

(1) Government-Issued Photo Identification

Acceptable forms include:

• Passport
• Driver’s licence
• National identity card

ID must be:

• Valid and not expired
• Clear and readable
• An exact match to the name on the winner’s 21Stacker account

(2) Proof of Residential Address (dated within the last 90 days)

Acceptable forms include:

• Utility bill
• Bank or credit-card statement
• Government-issued letter
• Tax notice
• Formal tenancy/lease agreement (last 6 months)

Requirements:

• Full name and address must match the 21Stacker account
• Documents must be official and unaltered
• Screenshots are accepted only if clearly legible

(3) Bitcoin Wallet Details for Prize Delivery

The winner must provide:

• A valid Bitcoin mainnet address (for on-chain prizes), OR
• A valid Lightning invoice (for Lightning-delivered prizes), as specified in the Competition details.

Additional requirements:

• The winner is solely responsible for ensuring wallet compatibility
• 21Stacker cannot resend or recover BTC sent to an incorrect or incompatible address
• Exchange/custodial wallets are used entirely at the entrant’s own risk

8.3 Residency & Eligibility Checks

As part of winner verification, the Promoter confirms that the provisional winner meets all eligibility requirements for the Competition. This includes verification of:

(1) Age Requirement

• Winners must be 18 years or older at the time of entering.
• Age is verified only at the winner stage using government-issued ID.

(We do not require age or DOB during account registration.)

(2) Residency

The Promoter verifies that the provisional winner:

• Resides in an eligible jurisdiction at the time of entry
• Provides proof of residential address dated within the last 90 days
• Did not enter from a prohibited or restricted region (e.g., UAE, Singapore, NY/FL/RI in the U.S.)

Temporary or non-residential addresses do not qualify.

(3) Compliance With Regional Laws

Verification includes confirming that the winner is not:

• Located in a prohibited country
• Subject to sanctions restrictions
• A resident of U.S. states requiring sweepstakes registration (NY, FL, RI)
• Entering in breach of mandatory local laws

(4) No VPN, Proxy, or Location Masking

The Promoter confirms that the entrant did not:

• Use VPNs, proxies, TOR, or other masking technologies
• Misrepresent geographic location
• Attempt to circumvent regional restrictions

Evidence of location masking results in automatic forfeiture.

(5) No Identity Manipulation or Multiple Accounts

Verification ensures the provisional winner:

• Entered using a single account
• Provided accurate identity information during verification
• Did not use aliases, false identities, or borrowed details
• Did not circumvent entry limits or AMOE restrictions

Forfeiture Clause

If the provisional winner fails any part of the eligibility verification, or refuses to provide required documentation:

The prize is forfeited, and an alternate winner will be selected using the same provably fair method.

8.4 Forfeiture

A provisional winner will forfeit the prize if any of the following occur:

(1) Failure to Respond

• The winner does not respond to the Promoter within 21 days of notification
• The winner fails to maintain an active, reachable email address

(2) Failure to Complete Verification

• The winner does not submit required identity and residency documents
• Documents are incomplete, illegible, expired, altered, or unverifiable
• The winner refuses additional verification reasonably requested by the Promoter

(3) Eligibility or Residency Conflicts

• The winner is found to be under 18
• The winner resides in or accessed the service from a prohibited region
• The winner used VPNs, proxies, TOR, or location masking
• The winner entered in breach of regional laws (e.g., NY, FL, RI residents)

(4) Fraud or Inconsistent Information

Forfeiture applies if the winner:

• Provided contradictory identity or residency information
• Used multiple accounts
• Submitted falsified or manipulated documents
• Entered using another person’s identity
• Attempted to manipulate the Competition, AMOE, or draw process

(5) Failure to Provide a Valid Bitcoin Address

• The winner fails to provide a valid BTC on-chain address or Lightning invoice
• The address is incompatible with the method used for that specific draw
• The winner provides an incorrect, invalid, or unusable wallet address

Bitcoin payments are final — if BTC is sent to an address supplied by the winner and is lost due to wallet error, the prize cannot be reissued.

(6) Breach of These Terms

Any material breach of these Terms & Conditions, or any conduct that in the Promoter’s reasonable opinion compromises the fairness or integrity of the Competition, results in automatic forfeiture.

9. Prize Delivery

9.1 Bitcoin Prizes Only

All prizes awarded in any 21Stacker Competition are paid exclusively in Bitcoin (BTC). No fiat currency, vouchers, store credit, or alternative prize formats are available unless explicitly stated on the Competition page.

Prizes may be delivered using:

(a) The Bitcoin Lightning Network

Used for:

• Smaller BTC prizes
• Prizes designed for instant settlement
• Prizes where Lightning is explicitly stated in the Competition details

(b) The Bitcoin Mainnet (On-Chain)

Used for:

• Larger BTC prizes
• Prizes requiring on-chain confirmation
• Prizes where on-chain delivery is specified

The Promoter determines the appropriate delivery method for each Competition based on value, network conditions, and operational requirements.

Transparency Requirement

Each Competition page will clearly disclose whether the prize will be delivered:

• On-chain, or
• Via Lightning,
  so entrants understand wallet requirements in advance.

Entrant Responsibility

Entrants are solely responsible for ensuring that:

• Their wallet supports the required delivery method
• They provide a valid, correct, and compatible BTC address or Lightning invoice
• They maintain secure access to their wallet

No Alternative Formats

Bitcoin prizes cannot be:

• Converted to fiat
• Delivered to alternative payment systems
• Substituted with other cryptocurrencies
• Reissued if sent to an incorrect or incompatible address provided by the winner

Legal Compliance

This structure satisfies global prize competition rules by:

• Keeping prize delivery method clear and unambiguous
• Ensuring transparency under UK/NI ASA/CAP rules, EU consumer law, and U.S. contest fairness standards
• Preventing disputes over prize format or valuation

9.2 Finality of Delivery

A prize is considered fully delivered when:

(a) On-Chain Delivery

The Promoter broadcasts the Bitcoin transaction to the Bitcoin mainnet and a valid transaction ID (TXID) is generated.
At the moment of broadcast:

• The prize is deemed delivered
• Network confirmation times are outside the Promoter’s control
• The transaction cannot be cancelled, reversed, or retrieved

(b) Lightning Delivery

For Lightning Network payments, the prize is considered delivered when:

• The Lightning invoice supplied by the winner is successfully paid
• A valid Lightning payment hash is generated

Once the payment is completed, the Promoter has no ability to reverse or reissue the prize.

Finality Clause 

Bitcoin transactions (on-chain or Lightning):

• Are final
• Are irreversible
• Cannot be cancelled, refunded, or resent
• Cannot be recovered if sent to an incorrect or incompatible address provided by the winner

The winner is solely responsible for ensuring their BTC address or Lightning invoice is correct and compatible with the delivery method used.

Network Disclaimer

The Promoter is not responsible for:

• Network congestion
• High fees
• Delayed confirmations
• Stuck or pending transactions
• Routing failures on Lightning
• Wallet-side issues or delays

Once the transaction (on-chain or Lightning) is broadcast or paid, the Promoter’s prize obligation is complete.

9.3 Incorrect Wallets

The winner is solely responsible for providing a correct, valid, and compatible Bitcoin wallet address or Lightning invoice that matches the delivery method used for the prize.

A prize may be permanently lost and cannot be recovered if the winner submits:

(a) An incorrect or invalid Bitcoin address

Including but not limited to:

• Mistyped addresses
• Wrong network (e.g., BCH, BSV, Liquid, testnet)
• Unsupported wallet formats
• Addresses that do not exist

(b) An incompatible wallet

Such as:

• Custodial wallets that block or reject certain transactions
• Wallets that do not support Lightning payments
• Wallets that do not support on-chain transactions
• Wallets with insufficient liquidity or routing capacity (Lightning)

(c) A Lightning invoice

That is:

• Expired
• Incorrectly formatted
• Incorrect amount
• Non-routable
• Linked to a wallet unable to receive the prize

Finality Clause

If BTC is sent to a wallet address or Lightning invoice provided by the winner, and the payment:

• Fails
• Is misrouted
• Is unrecoverable
• Is rejected by the wallet
• Is sent to an incorrect or incompatible address

→ The prize cannot be reissued, refunded, replaced, or otherwise compensated.

Bitcoin transactions are irreversible.

No Liability

The Promoter is not liable for:

• Lost funds caused by user error
• Wallet malfunctions
• Exchange restrictions
• Custodian rejection
• Lightning routing issues
• Incorrect invoice generation
• Incompatibility with the chosen prize delivery method

The Promoter’s responsibility ends when the BTC transaction is broadcast (on-chain) or successfully paid (Lightning).

9.4 Taxes

General Rule

All winners are solely responsible for any and all personal, local, state, federal, or international taxes arising from receiving a Bitcoin prize.

The Promoter does not provide tax advice and does not calculate, withhold, or remit taxes on behalf of winners, except where legally required.

Non-U.S. Winners

For winners outside the United States:

• Tax treatment depends on the laws of the winner’s country of residence.
• Bitcoin prizes may be considered capital assets, and future disposals may create capital gains tax obligations.
• Winners must determine their own reporting requirements and retain records of the Bitcoin’s fair market value (FMV) at the time of delivery.

The Promoter accepts no liability for any tax owed.

U.S. Winners

For winners who are U.S. residents, the Promoter is required under U.S. federal law to collect tax information and issue tax forms where applicable. This process applies even though the Promoter is a non-U.S. business.

(1) IRS Form W-9 Requirement

Before a prize can be awarded, any U.S. resident winner must submit a valid, completed IRS Form W-9 to the Promoter.
This form is required to:

• Verify the winner’s identity
• Confirm U.S. residency
• Provide a Taxpayer Identification Number (TIN/SSN)
• Enable mandatory IRS reporting

The Promoter cannot issue a prize to a U.S. winner without a completed W-9.

(2) 1099-MISC Reporting Requirement (Prizes ≥ $600 USD FMV)

If the fair market value (“FMV”) of the prize is $600 USD or more, the Promoter is required to:

• Issue an IRS Form 1099-MISC to the winner
• File the same form with the IRS

The FMV is calculated based on the USD value of the Bitcoin at the time the prize is delivered, using a reputable pricing index selected by the Promoter.

The winner is solely responsible for reporting this amount as taxable income to the IRS.

(3) IRS Filing Deadlines

The Promoter will:

• Furnish Form 1099-MISC to the winner by January 31 of the year following the prize
• File the corresponding Form 1099-MISC with the IRS electronically within statutory deadlines

These obligations apply even though the prize is paid in Bitcoin.

(4) Failure to Comply With U.S. Tax Requirements

A U.S. provisional winner will forfeit the prize if they:

• Fail to submit a W-9
• Submit an incomplete or inaccurate W-9
• Provide false or unverifiable tax information
• Refuse or fail to comply with mandatory IRS reporting procedures

In such cases, the Promoter will select an alternate winner using the same provably fair draw method.

(5) Record Retention

The Promoter may retain U.S. tax documentation (W-9, 1099-MISC, FMV calculations, and associated records) for the period required by U.S. law, typically 3–7 years, and will store such documents securely in accordance with applicable data protection standards.

(6) No Tax Withholding

The Promoter does not withhold, deduct, or remit taxes on behalf of U.S. winners.
Winners are solely responsible for reporting the taxable value of the prize and for paying any federal, state, or local taxes due.

(7) Non-U.S. Entities Awarding Prizes to U.S. Residents

U.S. federal tax law requires all prize promoters — including foreign companies — to comply with IRS reporting rules when awarding prizes to U.S. residents.
Participation by U.S. residents constitutes consent to:

• Provide necessary tax information
• Receive required IRS forms
• Accept tax obligations arising from the prize

Record Keeping

Winners are solely responsible for maintaining accurate and complete tax records relating to their prize. This includes, but is not limited to:

• Prize confirmation or award notification
• Bitcoin transaction ID (TXID) or Lightning payment hash
• The fair market value (“FMV”) of the Bitcoin at the time of delivery
• Any IRS Form 1099-MISC or equivalent tax documents issued
• Any correspondence relating to tax reporting obligations

Winners must retain these records for the period required by the tax laws of their jurisdiction.
The Promoter is not responsible for maintaining tax records on behalf of any winner.

Promoter Record Retention

The Promoter may retain tax-related records as required by law, including but not limited to:

• IRS Form W-9 (U.S. winners)
• IRS Form 1099-MISC filings
• FMV calculation records
• Proof of delivery (TXID/payment hash)
• Verification documentation
• Internal prize award logs

These records may be stored for the statutory period required by applicable laws (typically 3–7 years), after which they will be securely deleted.

Data Protection & Legal Override

Where tax documentation must be retained by law:

• The Promoter cannot delete such data upon user request until the statutory retention period expires.
• This complies with UK GDPR, EU GDPR, and U.S. federal tax regulations, which override erasure rights (e.g., GDPR Article 17(3)(b)).

Winner Responsibility Clarification

The Promoter does not:

• Track the winner’s tax basis
• Calculate capital gains
• Store tax records for winners
• Provide tax reporting for non-U.S. jurisdictions
• Advise winners on tax positions or obligations

Winners must consult a qualified tax professional regarding their own reporting and compliance.

Liability Disclaimer

The Promoter is not responsible or liable for any tax obligations arising from a prize, including but not limited to:

• Calculation of taxes owed by the winner
• Filing or reporting of taxes in any jurisdiction
• Income tax, capital gains tax, or equivalent obligations
• Penalties, fines, interest, or enforcement actions
• Tax consequences arising from Bitcoin price volatility
• Changes in tax law or tax treatment in the winner’s jurisdiction
• Misreporting or underreporting by the winner
• Any adverse consequences resulting from the winner’s failure to comply with local, state, federal, or international tax laws

Winner Responsibility

Winners are solely responsible for:

• Determining the tax implications of receiving a Bitcoin prize
• Maintaining accurate tax records
• Filing all necessary tax returns
• Paying any taxes due
• Complying with the laws of their country or region of residence

No Tax Advice

The Promoter:

• Does not provide tax advice
• Does not act as a tax agent or advisor
• Does not guarantee or represent how any prize will be treated by tax authorities
• Does not advise on capital gains calculations or taxable events

Winners should seek independent advice from a qualified tax professional.

10. Partner Programme

21Stacker operates an partner programme (“Partner Programme”) allowing approved partners (“Partners”) to earn commissions on referred paid entries. Participation is subject to these T&Cs and any additional Partner Agreement, policy, or instruction published within the Partner Dashboard.

Partners are independent promoters and not employees, contractors, agents, or representatives of 21Stacker.

10.1 Commission Structure (21% Lifetime Commissions)

21Stacker offers a 21% lifetime commission on all qualifying paid entries from customers referred by an approved Partner.

10.1.1 Qualifying Commissions

Partners earn 21% commission for life on:

• All future paid entries purchased by a customer linked to that Partner
• Across all current and future 21Stacker Competitions
• Provided the Partner remains in good standing and compliant

10.1.2 Non-Qualifying Commissions

Commissions are not earned on:

• AMOE (free postal) entries
• Invalid, fraudulent, or failed transactions
• Cancelled, reversed, or refunded orders
• Entries from prohibited jurisdictions
• Entries made by the Partner themselves (unless expressly permitted)

10.1.3 Lifetime Attribution Logic

A customer becomes permanently attributed to an Partner when:

• The customer first visits via the Partner’s unique link and
• Creates an account within the cookie/tracking window

Lifetime attribution persists regardless of:

• time elapsed
• device changes
• login state
• browser settings
• competition entered

Lifetime commissions cease if:

• The Partner breaches programme rules
• The customer deletes their account
• The Partner account is terminated or deactivated

10.2 Tracking, Cookies & Attribution

21Stacker uses cookies and similar technologies for core functionality, analytics, and Partner tracking.

• Non-essential cookies require user consent in UK/EU.
• Standard Partner cookie duration is 30 days unless otherwise stated.
• First-click attribution applies unless fraud is detected.
• Tracking may be impacted by VPNs, ad blockers, private browsing, or user-side settings.

21Stacker is not responsible for untracked referrals or lost commissions resulting from user-side interference.

See the Cookie Policy for further details.

10.3 Payout Terms (Bitcoin Only)

All Partner commissions are paid exclusively in Bitcoin (BTC). No fiat payout options are available.

Partners must provide a valid and compatible Bitcoin address (Lightning or on-chain, depending on payout type). The Promoter is not responsible for failed or lost payouts caused by:

• Invalid or incorrectly supplied Bitcoin addresses
• Expired Lightning invoices
• Wallets unable to receive the payment format
• Blockchain congestion or Lightning routing issues

Monthly Payout Schedule

Partner commissions are paid once per calendar month, typically at the end of the month.
However, payouts are only processed after all Competitions contributing to that month’s commissions have:

1. Closed
2. Completed the winner-selection process
3. Successfully delivered the prize to the verified winner

If any Competition in the period remains pending, under review, or unpaid, the Promoter may delay or batch Partner payouts until completion without liability.

No specific payout date within the month is guaranteed.

Conditions That May Delay Payouts

The Promoter may temporarily withhold, delay, or suspend payouts in cases involving:

• Prize-delivery verification
• AMOE audits
• Fraud or irregular behaviour review
• Partner account verification
• Regulatory or legal compliance checks
• Bitcoin network instability or abnormal fees
• Operational issues affecting one or more draws

Partners have no entitlement to interest or compensation for delayed payouts.

BTC Price Volatility

The Promoter is not responsible for:

• Changes in Bitcoin value during payout processing
• Loss of value caused by network congestion or delays
• Exchange-rate variations between commission calculation and payout

Partner commissions are calculated in sats at the time of entry purchase and paid in sats.

Network Fees

Bitcoin or Lightning Network fees may be deducted from payout amounts where necessary.

Finality of Bitcoin Payments

BTC transactions are final and irreversible.
Once transmitted, the Promoter:

• Cannot resend
• Cannot recover lost funds
• Assumes no liability for affiliate wallet errors

Fraudulent Commissions

Any commissions generated through fraudulent means — including bot traffic, fake accounts, cookie stuffing, or incentivised manipulation — will be:

• Cancelled
• Withheld
• Removed from lifetime attribution
• Potentially result in account termination

10.31 Partner Entry Credit (Onboarding Only) 

Partners must comply with all global advertising disclosure rules, including but not limited to FTC (USA), ASA/CAP (UK), and EU marketing laws.

Required disclosures include statements such as:

• “As a 21Stacker Partner, I earn a commission on purchases.”
• “#ad #affiliate #sponsored #partner”
• “Partner link: I may earn 21% if you buy entries.”

Disclosures must be:

• Clear and prominent
• Placed adjacent to the promotional link
• Visible before a user clicks
• Included in every post, story, video, or advertisement

Failure to disclose commissions may result in suspension or termination.

10.5 Mandatory Competition Disclosures

Partners must include the following in all promotions:

• “No purchase necessary. Void where prohibited.”
• Link to official rules: 21stacker.com/terms
• Clear statement that prizes are paid in Bitcoin
• Statement that purchasing more entries increases odds but does not guarantee winning

Partner must not:

• Suggest guaranteed wins or financial returns
• Present 21Stacker as gambling, betting, or investment
• Misrepresent odds, prize allocation, or draw mechanics

10.6 Prohibited Affiliate Behaviour

Partners must not engage in:

• Spam, bulk messaging, or unsolicited DMs
• False, misleading, or prohibited claims
• Promotions targeted at minors
• Promotions in restricted jurisdictions
• Bidding on “21Stacker”, “Emerge21”, or protected keywords
• Creating fake or multiple accounts
• Incentivising purchases with unauthorised rewards
• Bot traffic, click-farms, cookie stuffing, or forced redirects
• Impersonation of 21Stacker or its staff
• Posting TXIDs, wallet addresses, or sensitive data

Violations may result in termination and forfeiture of unpaid commissions.

10.7 Content Standards

Partner content must not:

• Imply guaranteed financial gain
• Overstate odds or expected winnings
• Promote irresponsible entry behaviour
• Provide unverified or misleading claims
• Use gambling terminology or comparisons
• Violate platform advertising rules

21Stacker may require edits or removal of non-compliant content.

10.8 Fraud Prevention & Audit Rights

21Stacker reserves the right to audit:

• Partner traffic sources
• Conversion patterns
• Customer attribution
• IP/geolocation data
• Browser/device fingerprints
• Multi-account associations

If fraud is suspected, 21Stacker may:

• Suspend the Partner account
• Withhold or cancel commissions
• Remove lifetime attribution
• Terminate the affiliate
• Pursue legal action

10.9 Geographic Restrictions

Partners may not promote 21Stacker in:

• Prohibited regions listed in Section 2
• Jurisdictions with prize-competition bans
• Regions restricting cryptocurrency promotions

Partners are solely responsible for ensuring their activities comply with local laws.

10.10 Programme Modification, Suspension & Termination

21Stacker may, at its sole discretion:

• Modify commission rates (not retroactively)
• Change programme rules or requirements
• Suspend or terminate the Partner Programme
• Suspend an affiliate account for investigation
• Remove Partners who breach rules
• Forfeit commissions earned fraudulently

Material changes will be communicated via the Partner Portal or email.

10.11 Data Use & GDPR Compliance

Partners consent to the processing of personal data required to operate the programme, including:

• Name, contact details
• Tracking identifiers and attribution data
• IP and geolocation information
• Payout information (BTC wallet addresses)

Data is processed according to the Promoter’s Privacy Policy and applicable data-protection laws (including UK GDPR and EU GDPR).

10.12 No Agency or Employment Relationship

Participation in the Partner Programme does not create:

• Employment
• Agency
• Partnership
• Joint venture

Partners act independently and may not present themselves as representatives of 21Stacker.

11. Anti-Fraud & System Integrity

21Stacker maintains strict anti-fraud, abuse prevention, and system-integrity controls to ensure that all Competitions operate fairly, securely, and in compliance with global regulatory standards.

Any attempt to manipulate, disrupt, or unfairly influence a Competition will result in:

• disqualification,
• account suspension,
• forfeiture of entries, prizes, or commissions, and
• possible legal action.

The Promoter reserves the sole discretion to determine whether any behaviour constitutes fraud, abuse, or manipulation, even if such behaviour is not explicitly listed in this section.

Users must not attempt to circumvent, bypass, exploit, or reverse-engineer any part of the website, Competition logic, payment system, or draw mechanism.

The Promoter may request additional verification or documentation at any time.

11.1 Prohibited Conduct

The following activities are strictly prohibited and may result in immediate voiding of entries and/or account termination:

11.1.1 Multiple Accounts / Identity Fraud

• Creating more than one account per individual
• Using false names, aliases, mismatched personal details, or falsified ID
• Using disposable or temporary email addresses
• Attempting to bypass per-person entry limits
• Using another person’s identity, AMOE details, or payment method

11.1.2 VPNs, Proxies & Geolocation Manipulation

• Using VPNs, proxies, TOR, IP masking, or anonymisation tools
• Spoofing geolocation to appear in an eligible region
• Circumventing jurisdictional restrictions
• Submitting AMOE entries from ineligible regions

11.1.3 Automated, Scripted or Bot Entries

• Using automation tools, bots, scripts, browser macros
• Attempting to bypass the skill question
• Mass-submitting AMOE entries
• Using software or devices to artificially increase odds

11.1.4 Attempts to Influence Draw Outcome

• Coordinated purchasing or withholding of entries to manipulate draw tiers
• Organised group manipulation
• Payment flooding or deliberate Lightning invoice time-out exploitation

11.1.5 Payment Manipulation or Fraud

• Fake Lightning payments or replay attempts
• Attempting to reverse BTC transactions through custodians
• Exploiting pricing, invoice, or display errors
• Abuse of expired or partial payments

11.1.6 Partner Programme Abuse

• Self-referrals
• Fake, incentivised, or purchased referrals
• Cookie stuffing or forced redirects
• Creating AMOE entries linked to referral accounts
• Misleading promotional activity
• Abuse of Partner onboarding entry credits, including attempts to obtain multiple credits through duplicate accounts, Lightning addresses, devices, or coordinated activity.

11.1.7 AMOE Manipulation

• Submitting multiple AMOE entries
• Using multiple identities to bypass limits
• Submitting printed, photocopied, or typed AMOE entries
• Using AMOE from prohibited jurisdictions
• Coordinating AMOE submissions for unfair advantage

11.1.8 System Misuse or Interference

• Attempting to access the website backend, server, draw engine, or payment system
• Injecting malicious code or performing penetration tests
• DDoS attacks or automated request flooding
• Attempting unauthorised system modification

11.1.9 Provably Fair Manipulation Attempts

• Attempting to influence Bitcoin block selection
• Attempting to intercept, modify, or replace seed files
• Attempts to manipulate the randomisation process

11.2 Fraud Monitoring & Review

21Stacker may conduct manual and automated monitoring including:

• IP tracking and geolocation analysis
• Device fingerprinting
• Duplicate account detection
• Velocity checks (entry or payment speed anomalies)
• Behavioural analysis patterns
• Payment verification and BTC settlement analysis
• Affiliate referral chain auditing
• AMOE validation (handwriting, identity, origin)

If suspicious activity is detected, 21Stacker may:

• Withhold or delay entry numbers
• Freeze the user’s account
• Suspend affiliate payouts
• Void fraudulent commissions
• Require enhanced identity and residency verification
• Block access from specific devices, IPs, or regions

11.3 Draw Integrity Protection

If malicious activity or technical interference materially affects a Competition, 21Stacker may:

• Re-run the draw using new server seeds and a new Bitcoin block
• Invalidate compromised or corrupted entries
• Pause or reschedule the result announcement
• Conduct an internal audit before proceeding
• Issue refunds only where systemic failure is conclusively demonstrated

No refunds or compensation are provided for dissatisfaction with draw outcomes.

11.4 Right to Forfeit Prizes & Entries

The Promoter may permanently forfeit entries, prizes, or affiliate commissions if:

• Fraud or manipulation is confirmed
• Eligibility rules are breached
• Identity or residency cannot be verified
• Wallet address manipulation is attempted
• Technical or behavioural manipulation is detected

Once forfeited, the Promoter has no obligation to provide justification beyond confirming a rule breach.

Forfeited prizes will be:

• Re-awarded to an alternate verified entrant, or
• Handled as otherwise specified in the Competition rules.

11.5 Cooperation with Authorities

21Stacker may cooperate with:

• Law enforcement
• Cybercrime units
• Regulators
• Tax authorities
• AML/sanctions authorities

Information may be shared where legally required in cases involving:

• Identity fraud
• Payment fraud
• Large-scale system attacks
• Criminal activity
• Sanctions violations
• AML obligations

11.6 Right to Suspend or Delay Competitions

21Stacker may suspend, delay, or modify a Competition if:

• Fraud is suspected
• Technical faults occur
• Security risks arise
• System maintenance is required
• Bitcoin network abnormalities affect randomness

No compensation is offered for delays or suspensions.

11.7 No Compensation for Voided Entries

If entries, commissions, or accounts are voided due to rule violations:

• No refunds are issued
• No prizes are paid
• No commissions are owed
• No compensation is provided

This applies equally to paid entries and AMOE submissions.

11.8 User Responsibility for Account Security

Users are solely responsible for safeguarding their:

• Account credentials
• Email access
• Devices
• Bitcoin wallets

The Promoter is not liable for:

• Compromised accounts
• Misuse due to shared devices
• Loss caused by unauthorised third-party access

12. Limitation of Liability

To the maximum extent permitted by applicable law, the Promoter (Emerge21 Ltd T/A 21Stacker), its directors, officers, employees, contractors, partners, and agents shall not be liable for any loss, damage, cost, claim, or liability arising out of or in connection with:

• participation in any Competition,
• inability to participate,
• use of the website,
• failure of Bitcoin or Lightning payment systems, or
• reliance on any information provided by the Promoter.

This applies whether such liability arises in contract, tort (including negligence), statutory duty, or otherwise, even if foreseeable.

Nothing in these Terms affects any rights that cannot be excluded under UK, EU, U.S., or applicable consumer protection laws.

12.1 Technical & System-Related Failures

The Promoter is not liable for, and provides no warranty regarding:

• Server outages, downtime, maintenance, or disruptions
• Website errors, bugs, corrupted data, or system malfunctions
• Internet or mobile network connectivity issues experienced by entrants
• Lightning Network invoice delays, routing failures, or expiry
• Bitcoin network congestion, mempool backlogs, or delayed confirmations
• Stuck, pending, or failed blockchain transactions
• Device incompatibility, software conflicts, or browser malfunctions
• Losses caused by third-party service providers

Entrants assume all risks associated with the use of Bitcoin and the Lightning Network.

12.2 Entry, Payment & Processing Issues

The Promoter is not responsible for:

• Failed, expired, incorrect, or partially paid Lightning invoices
• Incorrect wallet addresses or Lightning invoices submitted by entrants
• Misspelled personal data or failure to provide correct verification information
• User-side configuration errors, device issues, or wallet incompatibility
• Duplicate or unsuccessful entries caused by user error
• Abandoned, cancelled, or incomplete checkouts
• AMOE submissions lost, delayed, or mishandled by postal services
• Entries that fail to process due to factors outside the Promoter’s control

A valid entry exists only when the system assigns an entry number.

12.3 Prize Value & Bitcoin Volatility

The Promoter is not liable for:

• Any increase or decrease in the value of Bitcoin
• Market volatility before or after prize delivery
• Losses resulting from transferring, selling, holding, or storing Bitcoin
• Fees or costs associated with receiving, claiming, or moving Bitcoin
• Exchange or custodial wallet failures
• Inability to access or recover Bitcoin due to lost private keys or wallet credentials

Once Bitcoin is sent to the winner’s verified address or Lightning invoice, the prize is considered fully delivered and final.

Bitcoin transactions are irreversible.

12.4 Fraud, Abuse, or Misuse

The Promoter is not liable for any losses resulting from:

• AMOE manipulation or misuse
• Multiple account creation
• Identity fraud, impersonation, or misrepresentation
• Automated, scripted, or bot activity
• Affiliate programme abuse
• Attempts to manipulate entry caps or draw outcomes
• Hacking, DDoS attacks, or cyberattacks beyond the Promoter’s reasonable control

If fraudulent or abusive behaviour is confirmed, entries and winnings may be void without refund or compensation.

12.5 Third-Party Services

The Promoter is not responsible for failures or omissions by:

• Internet or telecommunications providers
• Email service providers
• Hosting or cloud infrastructure providers
• Postal services (for AMOE submissions)
• Cryptocurrency exchanges or wallet providers
• Affiliate tracking platforms
• External APIs used for BTC rate display

The Promoter does not guarantee uninterrupted access to third-party systems.

12.6 Force Majeure

The Promoter is not liable for delays, disruptions, or inability to fulfil obligations caused by events outside its reasonable control, including:

• Natural disasters, fires, floods
• Acts of war, terrorism, civil disorder
• Global or regional outages of the Bitcoin or Lightning Network
• Cyberattacks, system compromises, or malicious interference
• Government restrictions, regulatory changes, or sanctions
• Labour disputes or supply-chain failures

The Promoter may delay or reschedule draws during such events.

12.7 Maximum Liability (Where Liability Cannot Be Excluded)

Where liability cannot be lawfully excluded, the Promoter’s total aggregate liability to any entrant for any claim arising from a Competition is limited to the lower of:

(a) the total amount paid by that entrant for entries into the affected Competition, or
(b) the equivalent value in BTC at the time of purchase.

This limitation applies per Competition, not cumulatively.

12.8 Non-Excludable Liability

Nothing in these Terms excludes or limits liability for:

• Death or personal injury caused by negligence
• Fraud or fraudulent misrepresentation
• Any statutory rights that cannot be excluded under applicable law

12.9 No Indirect or Consequential Losses

To the fullest extent permitted by law, the Promoter shall not be liable for:

• Loss of profits or revenue
• Loss of opportunity
• Business interruption
• Loss of reputation or goodwill
• Consequential, incidental, special, punitive, or exemplary damages
• Losses arising from the use or misuse of Bitcoin
• Losses arising from inability to access or recover private keys

This applies even if the Promoter was advised of the possibility of such losses.

13. Data Protection

The Promoter processes personal data in accordance with:

• UK GDPR
• EU GDPR (where applicable)
• Data Protection Act 2018 (UK)
• Applicable U.S. state privacy laws (e.g., CCPA/CPRA, Colorado, Virginia)
• Other relevant international data protection legislation

This section summarises how entrant data is processed for Competition administration.
For full details, see our Privacy Policy: [Insert Link].

13.1 Categories of Data Collected

We may collect and process the following personal data, limited strictly to what is necessary:

(1) Account Information

• Full name
• Email address
• Country and region of residence
• Login credentials
• IP, device, and location verification data

Date of birth is not collected at account creation.

(2) Entry Data

• Competition and entry records
• Skill question responses
• Timestamped logs of entry attempts
• BTC transaction identifiers for paid entries (never private keys)
• Browser and device metadata for security

(3) Verification Data (Winners Only)

• Government photo ID
• Proof of address (last 90 days)
• Bitcoin wallet address (on-chain or Lightning)
• Tax documentation for U.S. winners (W-9, 1099-MISC)

(4) AMOE Data

• Handwritten AMOE postcards
• Required personal details
• Skill question answers
• Draw Series identification

AMOE entries are not digitised beyond the minimum needed for validation and audit.

No Special Category Data

We do not intentionally collect sensitive data (e.g., health, biometric, racial, religious, or political data).

13.2 Lawful Basis for Processing

We process personal data under the following lawful bases:

• Contractual necessity: administering entries, validating eligibility, awarding prizes
• Legal obligations: tax reporting, record retention, anti-fraud, AML requirements
• Legitimate interests: platform security, fraud prevention, audit trails, ensuring fair administration
• Consent: email marketing, non-essential cookies, affiliate tracking
• Public interest transparency: publication of provisional winners

Entrants may withdraw consent at any time for marketing communications.

13.3 Purpose of Data Processing

Data is used for:

• Competition administration
• Verifying skill question responses
• Assigning and managing entry records
• Winner selection and eligibility checks
• Identity and residency verification
• Prize delivery (Bitcoin wallet address)
• Fraud detection and account security
• AMOE validation
• Affiliate attribution where consented
• Legal and regulatory compliance
• Maintaining accurate audit trails

Data is not used to make automated decisions with legal or significant effects on entrants.
Algorithmic winner selection does not involve profiling.

13.4 Data Storage & Security

We implement appropriate technical and organisational safeguards, including:

• Encryption (in transit and at rest)
• Secure document vaults for ID uploads
• Strict access controls and audit logs
• Encrypted backups
• Data minimisation and secure deletion protocols
• GDPR-compliant hosting and infrastructure providers

Winner ID documents are stored securely and accessed only by authorised personnel.

13.5 Data Sharing & Third-Party Processors

We may share personal data with:

• Hosting and infrastructure providers
• Email and support service providers
• Payment and fraud-prevention systems
• Affiliate tracking tools (subject to consent)
• Tax authorities (for U.S. winners only)
• Law enforcement or regulators where required by law

We do not sell personal data.

International Transfers

Data may be processed outside the UK/EU using:

• Standard Contractual Clauses (SCCs)
• UK International Data Transfer Addendum
• Adequacy decisions (where applicable)
• Additional safeguards where required

13.6 Retention Periods

Data is retained only for as long as necessary for legal, operational, and audit requirements:

• Entry data: up to 12 months after Competition close
• Winner verification data: 12 months (or longer if legally required)
• U.S. tax forms: 3–7 years per IRS requirements
• Affiliate tracking records: 12–36 months, depending on operational necessity
• AMOE postcards: securely destroyed after audit and draw completion
• Account data: retained until user requests deletion

Where deletion is not legally permitted (e.g., tax compliance), data is retained until statutory obligations expire.

13.7 Data Subject Rights

Entrants have the right to:

• Access their personal data
• Request correction of inaccuracies
• Request deletion (“right to be forgotten”)
• Restrict processing
• Object to processing based on legitimate interests
• Withdraw marketing consent
• Request data portability

Requests may require identity verification.

Winners cannot request deletion of data required by law until the legal retention period expires.

Entrants have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) or their local data protection authority.

13.8 Bitcoin Wallet & Transaction Data

• BTC wallet addresses are treated as personal data
• Used solely for prize delivery and audit purposes
• Not displayed publicly or shared with third parties
• Securely deleted after the retention period
• We never store private keys, seed phrases, or access credentials

Entrants remain fully responsible for their wallet security.

13.9 Children’s Data

Competitions are strictly 18+.
We do not knowingly collect data from minors.
Accounts suspected to belong to minors will be deleted.

13.10 Cookies & Tracking Technologies

Non-essential cookies (including analytics, marketing, and affiliate tracking) require explicit consent where required by UK/EU law.

See our Cookie Policy for full details.

13.11 Data Protection Queries

Entrants may contact:
support@21stacker.com
For:

• Privacy queries
• Data rights requests
• Deletion requests
• Verification of data handling

Where legally required, the Promoter will notify affected users and regulators of any qualifying data breach.

14. Governing Law & Promoter

14.1 Operating Entity

All Competitions and related services are operated and administered by a UK-registered company Emerge21 Ltd trading as 21Stacker (the “Promoter”).

“21Stacker” is a trading name of a UK private limited company.
All contractual obligations, prize liabilities, and administrative duties are undertaken by that company.

No separate legal entity exists under the name “21Stacker”.

The Promoter’s registered office is:

Ground Floor, Gallery Building
65–69 Dublin Road
Belfast
BT2 7HG
United Kingdom

14.2 Governing Law

These Terms & Conditions, all Competitions, and all contractual relationships with entrants are governed exclusively by the laws of:

Northern Ireland

This applies irrespective of the entrant’s place of residence, except where mandatory local consumer-protection laws apply and cannot legally be excluded.

14.3 Jurisdiction

By entering a Competition, entrants agree that:

• The courts of Northern Ireland shall have exclusive jurisdiction over any dispute arising out of or relating to these Terms or any Competition operated by the Promoter.
• This jurisdiction agreement does not override mandatory consumer rights in an entrant’s home country (e.g., GDPR rights for EU residents, IRS reporting rights for U.S. residents).

Mandatory rights remain unaffected.

14.4 Cross-Border Operations

By participating in a Competition, entrants acknowledge and agree that:

• All Competitions are operated from the United Kingdom.
• All draws, prize administration, and fulfilment originate from Northern Ireland.
• The contractual relationship is formed with a UK-registered business.
• Participation does not create any business presence, tax nexus, or legal establishment by the Promoter in an entrant’s jurisdiction.

Nothing in these Terms shall be interpreted as:

• Submission to foreign jurisdiction
• Agreement to foreign regulatory or tax regimes
• Acceptance of foreign licensing obligations

The Promoter maintains its operational and legal base solely within the UK.

14.5 Compliance With Local Laws

While Northern Irish law governs these Terms, entrants are responsible for ensuring that:

• Their participation is lawful in their jurisdiction
• They do not enter from a prohibited or restricted region
• They comply with any local tax reporting or regulatory requirements

Where mandatory consumer-protection laws apply to the entrant (e.g., EU consumer directives, U.S. state-level privacy or tax laws), those rights apply only to the extent they cannot legally be excluded.

This ensures alignment with:

• UK Consumer Rights Act
• EU Unfair Commercial Practices Directive
• U.S. state-level promotional contest rules
• Global consumer-protection norms

14.6 No Waiver of Legal Rights

Nothing in these Terms excludes or limits:

• Data protection rights under UK GDPR or EU GDPR
• Mandatory U.S. tax reporting obligations (e.g., Form 1099-MISC issuance)
• Statutory consumer protections that cannot be waived
• Liability for death or personal injury caused by negligence
• Liability for fraud or fraudulent misrepresentation

15. AMOE Addresses

UK AMOE Address
21Stacker – Free Entries
Ground Floor, Gallery Building
65–69 Dublin Road
Belfast
BT2 7HG
United Kingdom

US AMOE Address
21Stacker – Free Entries
2803 Philadelphia Pike
Suite B #1011
Claymont, DE 19703
USA

16. Contact

Registered Office Address: 

Ground Floor, Gallery Building
65–69 Dublin Road
Belfast
BT2 7HG
United Kingdom

Contact email: support@21stacker.com