GROOW Progress Contest Official Rules, Terms & Conditions

Article 1 - Organiser

This contest is organised by Via Victoria Advisors SRL (“Groow”, “the Organiser”, “the Company”), operator of the Groow educational microlearning platform at groow.life.

As required by Government Ordinance no. 99/2000 (Art. 42), these Rules are available free of charge to any person who requests them. To request a copy: hello@groow.life, subject line: “Progress Contest Rules Request”. Groow must be able to provide a copy to ANPC, the Ministry of Economy, or the Ministry of Internal Affairs within 5 (five) business days of any official request.

Article 2 - Legal Basis & Classification

These Official Rules have been prepared in compliance with the following legislation. Each legal reference is stated explicitly so that participants, regulators, and authorities can verify compliance independently.

2.1 Primary Romanian Legislation

2.2 European Union Legislation

Note on classification (Art. 46 OG 99/2000): The winner of this contest is determined exclusively by the Progress Score - an objective metric of learning performance (ability, knowledge, perspicacity). There is no random draw, no element of chance. This classifies the contest as a “concurs de abilități” under Art. 46, exempting it from the notarisation requirement of Art. 43. Via Victoria Advisors SRL confirms this classification as its good-faith legal assessment and recommends obtaining independent Romanian legal advice before the contest is publicly announced.

Article 3 - Eligibility

3.1 Who May Participate

The Groow Progress Contest is open to any natural person worldwide who satisfies all of the following conditions at the time of contest participation and at the time the prize is awarded:

• Is at least 18 years of age.
• Holds a valid groow.life account with a verified email address.
• Has made at least one qualifying course purchase that has fully settled through the payment processor (see Art. 6).
• Has not violated these Rules, the Groow Terms of Service, or any applicable law in connection with their account.
• Resides in a country where participating in skill-based prize contests of this nature is lawful under local law.

3.2 Who May Not Participate

The following persons are ineligible regardless of Progress Score, and will be disqualified if discovered to have participated:

• Current and former employees, directors, shareholders, officers, legal representatives, and contractors of Via Victoria Advisors SRL, whether engaged on a full-time, part-time, freelance, or advisory basis.
• Any individual directly involved in the development, administration, technical operation, content creation, or marketing of the groow.life platform, including course contributors and influencer partners who received compensation from Groow during the contest period.
• Any auditor, legal adviser, or third party engaged by Via Victoria Advisors SRL specifically to verify this contest.
• Immediate family members of any excluded person: spouse, domestic partner, parents, siblings, and children.
• Household members of any excluded person: any person sharing the same permanent residential address, regardless of family relationship.
• Any person who holds or has held more than one groow.life account.

If a disqualified person is discovered at any point - including after the prize has been awarded - the prize is forfeited and passed to the next eligible participant on the leaderboard. Groow reserves the right to recover costs if a disqualified winner has already received the prize through material misrepresentation.

Article 4 - Contest Period & Duration

4.1 Start Date

The contest starts on the date these Rules are first published on groow.life. That date must be inserted in the field on the cover page before publication. The contest start date is the date from which Progress Score points are counted. Points earned from course purchases or completions before the start date do not count toward the Progress Score.

OG 99/2000 requires a defined start date. The start date field on the cover page must be completed before these Rules are published. Publishing Rules without a start date is non-compliant.

4.2 End Trigger - The Prize Becomes Available

The contest ends and the prize becomes available when BOTH of the following conditions are satisfied simultaneously (“the Dual Trigger”). Both must be true at the same time - neither alone is sufficient.

When Groow confirms that both T-1 and T-2 are satisfied simultaneously, Groow will announce the confirmed Prize Award Date at least 14 calendar days in advance. The leaderboard closes at 23:59:59 UTC on the Prize Award Date. No further points are awarded after that moment.

4.3 Hard Deadline

If the Dual Trigger (T-1 and T-2) has not been satisfied by 31 December 2028, the contest closes on that date with no prize awarded. Groow will announce this outcome on groow.life within 7 days. No compensation, alternative prize, or refund is owed to any participant solely because the prize was not awarded. Course purchases remain valid and all courses remain accessible.

Why 2028? The contest needs a maximum duration to be legally valid under OG 99/2000 (which requires a defined end condition) and to avoid creating an open-ended financial liability for Via Victoria Advisors SRL. December 31, 2028 gives approximately 2.5 years from a 2026 launch for both triggers to be met, which is generous based on the financial projections showing 100K users within 12 months of launch. If growth is slower than projected, the hard deadline protects Groow from an indefinitely accumulating prize obligation.

4.4 Announcement Timeline

Article 5 - The Progress Score

The Progress Score is the single metric that determines the contest ranking. It is calculated automatically by the groow.life platform in real time, is visible to every registered user on the public leaderboard, and is composed exclusively of one type of verified action: course completions. Points are awarded for completing courses, not for purchasing them. Sharing actions are not included in this version of the contest.

This formula is fixed from the contest start date and cannot be changed during the contest period. Any amendment to this formula requires a minimum 14-day public notice period and applies only to future actions, not retroactively.

5.1 Standard Courses - Points

Groow courses are classified as either Standard or Premium. This classification determines the completion points earned - not the price of the course. The price of any course is a commercial decision made by Groow independently of these Rules and may change at any time without affecting the points structure described here.

Course prices are not part of this contest regulation. Groow may change the price of any Standard or Premium course at any time. What remains fixed for the duration of this contest is the points formula: Standard courses always earn 20 completion points; Premium courses always earn a defined multiple of that. A participant who completed a course at any price retains the points that applied at the time of their completion. Future price changes do not retroactively alter points already earned.

Standard courses are all courses on groow.life that are not designated as Premium. They earn a flat 20 completion points when the quiz is passed with a score of 70% or higher, regardless of their price at the time of purchase.

5.2 Premium Courses - Multiplier System

Premium courses are courses designated as Premium by Groow. Each Premium course is assigned a Multiplier at the time it is added to the catalogue. The Multiplier is an integer that expresses how many times the Standard completion point value (20 pts) that course is worth.

Formula: Premium Course Completion Points = 20 × Multiplier.

The Multiplier assigned to each Premium course is published on the groow.life course listing page. Groow may add new Premium courses with any Multiplier at any time by publishing the Multiplier with the course listing. The Multiplier for an existing course may change; if it does, completions before the change retain the points that applied at the time of completion, and completions after the change earn points at the new Multiplier.

Current Premium course as of the contest start date: the Crypto course in Romanian - Multiplier 5× = 100 completion points. All other courses currently available are Standard = 20 completion points each.

5.3 Bundle Purchases - Bonus Points

Groow offers courses as individual purchases and as bundles. Bundles are groups of courses sold together. To encourage learners to commit to a full learning path, completing all courses within a bundle earns a bonus on top of individual course completion points. The bonus scales with the number of courses in the bundle.

The number of courses in a bundle is the number published on the groow.life bundle listing page at the time of purchase. Groow will always state clearly how many courses a bundle contains and which tier of bundle bonus applies.

Bundle bonus calculation example: a bundle contains 4 courses - 3 Standard courses and 1 Premium course (Multiplier 5×). A participant who completes all 4 courses earns: (3 × 20 pts Standard completion) + (1 × 100 pts Premium completion) + 25 pts bundle bonus (4-course tier) = 60 + 100 + 25 = 185 points total from this bundle.

Bundle point values for all available bundles are published on groow.life at the time of purchase. When Groow adds new bundles in the future, their point values will be published with the bundle listing. The bundle bonus structure above applies to all current and future bundles automatically.

5.4 What Does NOT Earn Points

The following actions explicitly generate zero Progress Score points:

• Quiz attempts that do not result in a passing score of 70% or higher.
• Any action performed using a bot, script, automated tool, or any form of artificial account activity.
• Actions taken on accounts subsequently found to be in breach of any eligibility or integrity rule.

5.5 Point Immutability and Correction

Points are awarded server-side and logged in an immutable audit trail. Points cannot be manually increased via the platform front end. They can only be reduced in the following circumstances:

• A settled payment is reversed, disputed, or charged back: the corresponding points are cancelled immediately and permanently.
• An account is found to be in breach of eligibility or integrity rules: all points are voided.
• A technical error awarded more points than the rules permit: Groow will correct the error, notify the participant by email, and document the correction in the audit log.

5.6 Tiebreaker

If two or more participants have an identical Progress Score when the leaderboard closes, the following sequence is applied in strict order. The first step that produces a different result between the tied participants determines the higher rank.

Step 1 - Completion ratio

Number of courses completed ÷ total courses purchased (as a percentage). The participant with the higher ratio ranks higher.

Step 2 - Average quiz score

Average percentage score across all passed quizzes. The participant with the higher average ranks higher.

Step 3 - Earlier first completion

The participant who reached their first course completion during the contest period earliest, by UTC timestamp as recorded server-side, ranks higher.

Step 4 - Sudden Death Quiz

If Steps 1–3 are exhausted without separating all tied participants, each remaining tied participant is invited by email to complete a Sudden Death Quiz within 72 hours of notification. The Sudden Death Quiz is governed by the following rules:

• A purpose-built set of 10 questions drawn from across the full Groow course catalogue, covering topics from multiple course categories. Questions are not drawn from any publicly available quiz pool.
• Delivered via a secure, time-stamped individual link sent to each tied participant's registered email address. Each link is unique and can be used only once.
• Administered once only. There is no second attempt for any reason.
• Scored on percentage of correct answers. The participant with the highest score ranks higher.
• A participant who does not respond to the Sudden Death Quiz invitation within 72 hours is treated as having scored 0% and ranks below any participant who attempted it.
• If two participants score identically on the Sudden Death Quiz, Step 5 applies.

The 72-hour window is chosen to accommodate participants across all global time zones. The invitation email will specify the exact UTC deadline. Groow recommends participants complete the quiz as soon as possible after receiving the invitation, as no extensions will be granted regardless of circumstance.

Step 5 - Groow's discretion (absolute final resolution)

If after the Sudden Death Quiz two or more participants remain perfectly tied - identical Progress Score, identical completion ratio, identical average quiz score, identical first completion timestamp, and identical Sudden Death Quiz score - Groow may, at its sole discretion, award an additional Grand Prize so that all remaining tied participants receive the prize. This is not an obligation but a reserved right exercised only in this extreme scenario. Under normal circumstances, one Grand Prize is awarded to Rank 1.

Groow will publish the outcome of any tiebreaker process on groow.life within 14 days of the leaderboard closing, including the first names and countries of all participants who reached the Sudden Death Quiz stage and their scores on that quiz.

Why no random draw? This contest is classified as a skill contest under Art. 46 OG 99/2000. A random draw at any stage - even as a final tiebreaker - would risk reclassifying the entire contest as an advertising lottery, requiring notarisation and Ministry of Economy registration. Every step of this sequence is therefore skill-based or timestamp-based. Even Step 5 is not a draw - it is Groow's discretion to award additional prizes rather than exclude equally deserving learners.

5.7 Future Point-Earning Features - Amendment Framework

Groow intends to expand the Groow platform with new features over time. Some of these features may be suitable for inclusion in the Progress Score. This section defines the legal and procedural framework under which new point-earning categories can be added to the contest without requiring a full rewrite of these Rules.

5.7.1 Categories of features that may be added

The following types of platform features are pre-approved in principle for potential future inclusion as Point-Earning Features, subject to the Amendment Notice process below:

• Certificate actions: verified sharing of course completion certificates on professional networks or job platforms.
• Community actions: verified contributions to a learner community (e.g. answering questions, writing course reviews meeting minimum quality standards).
• Streak actions: maintaining a defined learning streak (consecutive days of course activity) over a minimum threshold.
• Referral actions: referring new users who subsequently make a qualifying course purchase. Note: this category requires additional anti-fraud measures specific to referrals, which will be published with the Amendment Notice.
• Leaderboard milestone bonuses: bonus points for reaching defined leaderboard ranks at specified milestone dates.
• Event-based actions: completion of a time-limited learning challenge or curated course collection published by Groow.

5.7.2 Notice requirements by change type

Different types of changes to the Progress Score system carry different notice requirements, based on their materiality to participants already competing:

5.7.3 Conditions for all scoring changes

Regardless of the notice tier, every change to the Progress Score system must satisfy all of the following:

1. The change is published on groow.life with the effective date clearly stated.
2. For changes requiring 3 days' notice or more: an email is sent to all registered groow.life users at the time of publication.
3. The change applies only to actions taken on or after the effective date. It never applies retroactively.
4. The change does not cancel or reduce any points a participant has already earned. Existing scores can only be reduced for the reasons specified in Art. 5.5 (payment reversal, eligibility breach, or technical error correction).

5.7.4 What participants can rely on

• Points already earned under the rules in force at the time of earning cannot be reduced by the addition of a new feature.
• The minimum engagement thresholds in Art. 6 Gate 4 (150 points minimum, 3 completions minimum, 30% completion ratio) apply to the total score including any new features added via Amendment Notices.
• If a new feature creates a significant advantage for participants who adopt it early, Groow will consider whether adjustments to the minimum thresholds are warranted. Any such adjustments follow the 30-day notice requirement in Art. 13.1.
• Features that have not been added via a valid Amendment Notice do not generate Progress Score points, regardless of any informal communication from Groow.

Why this clause exists: Groow is a growing platform and it would be commercially and legally wrong to lock the contest into a rigid formula that cannot evolve. However, participants need certainty that the rules will not change arbitrarily mid-contest. This framework gives Groow flexibility while guaranteeing participants a minimum of 3 days' advance notice before any change takes effect, and ensuring all changes are additive (never subtractive) to existing scores.

Article 6 - Prize Award Conditions (Eligibility Gates)

To receive the prize, the provisional winner (the participant finishing at Rank 1 on the leaderboard when it closes) must satisfy all six eligibility gates simultaneously. These gates are cumulative - passing one does not exempt the participant from any other. A failure at any gate, discovered at any point before or after prize award, results in immediate disqualification and the prize passing to the next eligible participant on the leaderboard.

Gate 1 - Platform Trigger (Contest End Condition)

The prize does not become available until the Dual Trigger defined in Art. 4.2 is confirmed by Groow. This gate cannot be waived or accelerated.

• Trigger T-1: the groow.life platform has reached 100,000 unique verified registered users. “Verified” means the account has a confirmed email address, is not a duplicate, and has logged in and viewed course content at least once.
• Trigger T-2: cumulative net course revenue since the contest start date has reached USD 50,000. Net revenue for this purpose = gross sales minus payment processing fees and chargebacks. Influencer commissions, contributor shares, and charity donations are not deducted.
• Both T-1 and T-2 must be satisfied simultaneously. If T-1 is reached first, T-2 must then be reached before the prize becomes available, and vice versa.
• Groow confirms trigger satisfaction via an internal audit of the platform database. The confirmation is published on groow.life as the “Prize Award Date Announcement” with at least 14 days' advance notice before the leaderboard closes.
• No eligibility verification (Gates 2–6) begins until Gate 1 is confirmed. No prize is awarded, discussed, or offered before that point.

Gate 1 is the foundational trigger. It protects Groow financially (the prize is only awarded when it is covered by revenue) and protects participants (they know the prize is real and will be awarded, not withheld arbitrarily).

Gate 2 - Identity Integrity

The provisional winner must be a single identifiable natural person with one verified groow.life account. This gate addresses multi-account fraud, fake identity fraud, and excluded person participation.

2a. Single account requirement

• The winner must hold exactly one groow.life account. Holding multiple accounts under any circumstance, whether or not the other accounts were used for contest scoring, constitutes disqualification.
• Multi-account detection: Groow checks whether any other registered account shares the same verified email address, the same payment card or bank account number, the same device fingerprint (browser fingerprint or mobile device ID), or the same IP address used for account creation.
• If any link is found between the provisional winner's account and another account, both accounts are suspended and reviewed. If the link is confirmed as intentional multi-accounting, both accounts are disqualified.
• Edge case - shared household devices: if two members of the same household legitimately share a device (same device fingerprint), they must contact hello@groow.life before the leaderboard closes to register the shared device situation. Groow will note this in the audit record. Undisclosed shared devices found during the final audit will be treated as multi-account fraud.

2b. Email verification

• The account must have a verified email address (confirmed via the groow.life verification link sent at registration).
• Temporary, disposable, or role-based email addresses (e.g. from providers such as Mailinator, Guerrilla Mail, YOPmail, or aliases using “info@”, “admin@”, “support@”) are not valid for contest participation. Such accounts are flagged automatically and excluded from the leaderboard.
• If a participant's email provider is flagged as a known disposable domain, the account's contest participation is suspended pending manual review (not automatic disqualification - the participant may provide an alternative verified email).

2c. Age

• The winner must be at least 18 years of age at the time of the Prize Award Date.
• Groow may request proof of age (government-issued ID) during winner verification. Failure to provide proof of age within the specified timeframe (Art. 10) results in forfeiture.

2d. Excluded persons (Art. 3.2)

• The winner must not be an excluded person as defined in Art. 3.2. This includes all employees, directors, shareholders, contractors, and platform contributors of Via Victoria Advisors SRL, plus their immediate family members and household members.
• Groow cross-references the winner's name and contact details against its internal records of employees, contractors, and contributors as part of the final audit.
• If the winner is found to be an excluded person at any point, including after the prize has been offered, the disqualification is retroactive and the prize passes to the next eligible rank.

Gate 3 - Payment Integrity

Every Progress Score point must be backed by a real, settled, and unreversed financial transaction. This gate prevents chargeback fraud, stolen card fraud, and synthetic identity payment fraud.

3a. Minimum settled payment

• The winner's account must have at least one (1) fully settled course purchase from the contest period. “Fully settled” means the transaction has cleared through the payment processor, the funds have been received by Groow, and the transaction has not been subject to a dispute, chargeback, or reversal in any form.
• Points from a purchase are held in “pending” status for 3–5 business days after the transaction date while settlement is confirmed. Pending points are visible on the participant's dashboard but are clearly marked as “pending” and do not count toward the active leaderboard score until settlement is confirmed.

3b. Chargeback and reversal policy

• Any reversal, dispute, or chargeback of a settled payment - initiated at any time, including after the leaderboard closes - immediately cancels all Progress Score points earned from that purchase.
• An account with one chargeback during the contest period is automatically suspended from leaderboard participation pending review. The chargeback is noted in the account audit record.
• An account with two or more chargebacks during the contest period is permanently disqualified from the contest, even if one or more chargebacks are later reversed.
• Groow is not obligated to notify the participant before cancelling chargeback-related points, as the chargeback itself constitutes the participant's instruction to reverse the transaction.

3c. Payment fraud detection

• Purchases made with payment instruments later identified as fraudulent (stolen credit cards, synthetic identity payments, or payments associated with confirmed fraud investigations) will result in immediate cancellation of associated points and account disqualification.
• Groow's payment processor applies risk scoring to each transaction. Transactions flagged as high-risk are held in pending status until manually reviewed by Groow. The participant is not notified of a pending review in order to prevent interference.
• Accounts with more than 5 course purchases within any single 1-hour window are automatically flagged for payment fraud review (see Art. 7.2).

Gate 4 - Minimum Learning Engagement

The Groow Progress Contest rewards learning, not spending. A participant who purchases every available course but completes none cannot win. This gate ensures the winner has genuinely engaged with the platform as a learner. All three conditions below must be met simultaneously.

4a. Minimum Progress Score

• The winner's total Progress Score must be at least 150 points at the time the leaderboard closes.
• Rationale: a participant who completes one 5× Premium course earns 100 pts, and needs at least 2 Standard completions (40 pts) plus a bundle bonus (up to 25 pts) to reach 150 pts. This threshold requires completing several courses across the catalogue, not just one.

4b. Minimum completions

• The winner must have completed at least 3 (three) courses with a quiz score of 70% or higher.
• “Completed” means the quiz was attempted and passed with a score of 70% or higher.
• Completions from before the contest start date do not count toward this minimum.
• Rationale: completing 3 distinct courses demonstrates sustained learning engagement across the catalogue, not a single burst of activity.

4c. Minimum completion ratio

• At least 30% of all courses purchased by the winner must have been completed (quiz ≥70%) as of the leaderboard closing date.
• Calculation: (number of courses completed with quiz ≥70%) ÷ (number of distinct courses purchased) ≥ 30%.
• Example: if the winner purchased 10 courses, at least 3 must be completed. If 15 courses purchased, at least 5 must be completed.
• Courses purchased in the same bundle are each counted individually for both the numerator (if completed) and denominator (all purchased).
• Rationale: without this ratio, a participant could buy many courses and complete only the minimum 3, earning high bundle bonuses while neglecting most of their catalogue. The ratio ensures the leaderboard reflects genuine breadth of learning.

Minimum thresholds by rank

Rank 1 must satisfy the Grand Prize threshold (≥150 pts, ≥3 completions, ≥30% ratio). If the Rank 1 participant does not meet the threshold, the Grand Prize passes to the next eligible participant who does. If a ranked participant does not meet their tier's minimum threshold, the prize for that rank passes to the next eligible participant below them on the leaderboard who does. This cascade continues until the prize is awarded or the top 10 are exhausted.

Gate 5 - Behaviour Integrity

The winner's account must be free of confirmed fraud flags. This gate catches attack patterns that may not have triggered automatic disqualification during the contest but are detected during the final audit.

5a. No confirmed multi-account activity

• No other groow.life account shares the winner's device fingerprint, payment instrument, or verified email address.
• No pattern of coordinated activity between the winner's account and other accounts (e.g. one account refers purchases to another, accounts that logged in from the same device within 24 hours of each other, accounts with sequential registration IDs and identical behaviour patterns).
• If multi-account activity is suspected but not confirmed, the account enters a review suspension (Art. 7.2) rather than automatic disqualification. The review is completed before the prize is confirmed.

5b. No quiz integrity violations

• No pattern of identical incorrect answers across multiple attempts suggests systematic answer harvesting (attempting to reverse-engineer correct answers by recording wrong ones across sessions).
• No evidence of quiz answers being shared externally or sourced from third-party cheat sheets, assessed against the quiz question pool randomisation records.

5c. No velocity or automation anomalies

• No confirmed bot or automated tool activity: all quiz submissions were made with human-consistent timing, mouse movement patterns, and CAPTCHA completion records.
• No account creation and first purchase within a 10-minute window (confirmed bot registration pattern).
• No more than 5 course purchases within any 1-hour window during the contest period (velocity fraud pattern).

5d. No payment fraud

• No purchases on the account were made with payment instruments subsequently confirmed as stolen, fraudulent, or associated with synthetic identities.
• No purchases originated from IP addresses or payment instruments on Groow's active fraud watchlist at the time of the transaction.

5e. No coordinated fraud ring activity

• The winner has not participated in any scheme in which multiple persons coordinate their accounts to concentrate points into one account.
• Indicators that trigger a coordinated ring review include: the winner's account is the destination of multiple referrals from accounts created on the same day; the winner's device fingerprint appeared on other accounts within 48 hours of those accounts' registrations; or a third-party complaint with specific evidence of coordination.

Gate 6 - Winner Verification

This gate is the final check, conducted by Groow manually after the leaderboard closes. It is the last line of defence against fraud that passed all automated checks during the contest.

6a. Response within 14 days

• The provisional winner must respond to Groow's notification email within 14 calendar days, confirming acceptance of the prize and willingness to complete the verification process.
• If no response is received within 14 days, or the response is a declination, the prize passes to the next eligible participant. Groow will contact each subsequent rank in the same way until a verified winner is confirmed or the top 10 are exhausted.

6b. Identity document submission

• The winner must provide a clear, unaltered copy of a valid government-issued photo ID (passport or national identity card) within 7 calendar days of confirming acceptance.
• The document must be valid (not expired). The name and date of birth must match the groow.life account details exactly. If there is a legal name change (e.g. after marriage), the winner must provide supporting documentation.
• Groow applies basic document verification to detect digitally altered or fabricated documents. Submission of an altered document is grounds for immediate disqualification and may constitute fraud under applicable Romanian and EU law.

6c. Final score audit

• Groow conducts a full cross-reference audit of the winner's Progress Score log against the payment ledger (Gate 3), course completion log (Gate 4), quiz timestamp log (Gate 5b), and device fingerprint history (Gate 5a). This audit is described in detail in Art. 10.3.
• If the audit reveals any discrepancy between the displayed leaderboard score and the verified point log, the verified log is authoritative. If the discrepancy resulted in the winner having fewer points than displayed, and this changes their rank, the correct rank is applied.

6d. Tax confirmation

• Before the prize is physically booked or delivered, the winner provides their country of fiscal residence to allow Groow to determine the applicable tax treatment (Art. 9). For Romanian-resident winners, Groow confirms the tax withholding amount and procedure. For non-Romanian-resident winners, Groow provides the prize value documentation.

Gate 6 typically takes 14–21 days from leaderboard close to prize confirmation. The prize is not booked or delivered until all six gates have been formally cleared. Groow will keep the winner informed of progress at each step.

Article 7 - Fraud Prevention & System Integrity

This article documents every known fraud vector against the Groow Progress Contest system and the specific technical or procedural defence against each. Participants should be aware that all of these defences are active throughout the contest period.

7.1 Automatic Disqualification Triggers

The following trigger immediate, automatic disqualification without prior warning. The affected account is notified by email within 24 hours:

7.2 Review Suspension Triggers

The following trigger an account suspension pending manual review. The participant is notified by email within 24 hours. Review is completed within 5 business days. If no violation is found, the account is reinstated with full points restored.

• More than 5 course purchases within any 1-hour window on a single account.
• Account creation and first purchase within 10 minutes of each other.
• Three or more accounts sharing the same device fingerprint (triggers review of all linked accounts).
• IP address associated with a confirmed VPN or proxy service (triggers identity re-verification, not automatic disqualification).
• A step-change in Progress Score that is statistically inconsistent with the account's prior activity pattern.
• A verified complaint from another participant alleging a specific, documented fraud method.

7.3 Technical Integrity Measures

The following technical measures are permanently active during the contest period:

• Quiz question randomisation: questions are drawn from a pool of at least 3× the number shown. No two users receive the same question set in the same session.
• CAPTCHA on quiz submission: every quiz submission requires a CAPTCHA challenge to prevent automated submissions.
• Server-side point calculation: all point-awarding events are validated server-side against the payment ledger and course completion log. Points cannot be awarded via unsecured front-end API calls.
• Immutable audit log: every point-awarding event is stored with: action type, UTC timestamp, account ID, course ID, payment reference, and quiz attempt number. This log is the authoritative record and cannot be altered through the platform interface.
• Device fingerprinting: every login and purchase is fingerprinted. Fingerprints are cross-referenced across all accounts daily.

7.4 Right of Appeal

A participant who has been disqualified may appeal in writing to hello@groow.life within 14 calendar days of receiving the disqualification notice. The appeal must include a specific factual explanation of why the disqualification was in error. Groow will respond within 10 business days. Groow's decision on appeal is final. Filing an appeal does not reinstate leaderboard participation during the review period.

Article 8 - The Prize

8.1 Grand Prize - One Maldives Trip (Rank 1)

One (1) Grand Prize is awarded to the participant finishing at Rank 1 on the leaderboard: a five-day trip to the Maldives for two (2) people, subject to all eligibility Gates in Art. 6.

Tiebreaker note: the five-step tiebreaker sequence in Art. 5.6 - culminating in the Sudden Death Quiz - is designed to always produce a single Rank 1 winner. Only in the statistically near-impossible event that all five steps are exhausted without resolution may Groow, at its sole discretion, award an additional prize to tied participants (Art. 5.6 Step 5).

8.2 Why No Prize Draw is Used for Tied Participants

This contest is classified as a skill contest under Article 46 of Government Ordinance no. 99/2000. The classification depends entirely on the winner being determined by ability, knowledge, and perspicacity - not by chance. Introducing a random draw at any stage, including as a tiebreaker, would risk reclassifying the contest as an advertising lottery (loterie publicitară) under Art. 41–43 of the same law, which requires notarisation and a deposit of the rules with the Ministry of Economy before the contest starts. Groow has designed the tiebreaker sequence in Art. 5.6 to avoid any random element at every step, culminating in the Sudden Death Quiz (Step 4) and Groow's reserved discretion to award additional prizes (Step 5) rather than ever resorting to chance.

If Groow ever considers introducing a random element for any prize - including a future prize not covered by these Rules - independent Romanian legal advice must be obtained before any public announcement, as it could change the legal classification of the entire contest.

8.3 Milestone Prizes - Ranks 2 to 10

Participants finishing in ranks 2 to 10 receive travel vouchers, subject to meeting the minimum engagement thresholds in Art. 6 Gate 4:

• Rank 2-3: USD 300 travel voucher each (requires ≥100 points and ≥2 completions).
• Ranks 4–10: USD 100 travel voucher each (requires ≥50 points and ≥1 completion).
• If a ranked participant does not meet their tier's minimum threshold, their prize passes to the next eligible participant below them on the leaderboard.

8.4 Prize Conditions

• The prize must be accepted as offered. No cash equivalent, substitution, or exchange is available for any element.
• The prize is non-transferable. The winner may choose who accompanies them as the second traveller. The prize (in whole or in part) may not be sold or transferred to another person.
• The resort is selected by Groow. Groow will make reasonable efforts to accommodate the winner's preferences, but the final selection is at Groow's discretion.
• The winner and their travel companion must hold valid travel documents (passport, visa if required) for entry into the Republic of Maldives. Groow accepts no responsibility for documentation failures.
• Travel insurance is not included. Groow strongly recommends the winner obtains comprehensive travel insurance before travel.
• Groow is not liable for any loss, injury, delay, cancellation, or expense incurred during the trip that is beyond Groow's direct control.

Article 9 - Tax Obligations

Prize income is taxable under Romanian fiscal law. The following rules apply based on the Codul Fiscal (Legea nr. 227/2015, Art. 108–110) and confirmed by ANAF guidance.

9.1 Romanian-Resident Winners

If the prize winner is a natural person with fiscal residence in Romania, the following applies:

• The prize constitutes income from a promotional contest (“venituri din concursuri”) under Art. 108 Codul Fiscal.
• Groow (Via Victoria Advisors SRL), as the organiser and payer of the prize, is obligated to calculate, withhold, and pay income tax to ANAF on behalf of the winner.
• Tax rate: 10% applied to the net taxable amount.
• Net taxable amount = prize value (in RON at the exchange rate on the prize award date) minus RON 600 (the non-taxable threshold per Art. 110 Codul Fiscal).
• Example: prize value USD 5,000 → RON 25,000 (indicative). Tax = 10% × (RON 25,000 − RON 600) = 10% × RON 24,400 = RON 2,440 (≈ USD 490). Groow bears this cost as a contest expense.
• The winner receives the trip net of this tax. The tax is a final withholding tax - the winner does not need to declare this income separately in their annual tax return (Declarația Unică) under Art. 110(5) Codul Fiscal.
• Groow will pay the withheld tax to ANAF by the 25th of the month following the month of prize award.

9.2 Non-Romanian-Resident Winners

If the prize winner is a natural person with fiscal residence outside Romania, the following applies:

• Romania may or may not have a Double Taxation Convention (DTC) with the winner's country of residence. Where a DTC applies, its terms govern the allocation of taxing rights.
• In the absence of a DTC, the prize income may be treated as income from abroad (“venituri din străinătate”) under Romanian fiscal law, in which case the withholding obligation may not apply to Groow and the winner is responsible for declaring and paying applicable taxes in their country of residence.
• Groow will provide the winner with a written statement of the prize value in USD (and in RON at the official exchange rate on the award date) to assist with any tax declarations the winner must make.
• The winner is solely responsible for all tax obligations in their country of residence. Groow accepts no liability for the winner's tax compliance obligations outside Romania.

Tax treatment is subject to change if Romanian or EU tax law changes before the prize is awarded. Groow recommends both Romanian and non-Romanian winners seek independent tax advice. This section reflects the tax rules in force as of the date these Rules are published and as confirmed by ANAF guidance.

Article 10 - Winner Notification & Verification

10.1 Notification Process

1. Groow contacts the provisional Grand Prize winner (Rank 1) by email to the address on their groow.life account within 48 hours of the leaderboard closing.
2. The winner must respond in writing to hello@groow.life within fourteen (14) calendar days confirming acceptance of the prize.
3. If no response is received within 14 days, or if the winner declines, the prize is offered to the next eligible participant on the leaderboard. This process repeats until a winner is confirmed or the top 10 are exhausted.

10.2 Identity Verification Documents

Groow requires the following before confirming the prize:

• A clear copy (scan or photograph) of a valid government-issued photo ID (passport or national identity card). The document must be valid (not expired) at the time of submission.
• The name, date of birth, and country on the document must match the information on the groow.life account.
• If the winner's legal name differs from their account display name, they must explain the discrepancy in writing.
• Groow applies basic document verification to detect digitally altered submissions. Submission of an altered document is grounds for immediate disqualification and may constitute fraud under applicable law.

10.3 Final Score Audit

Before confirming the prize, Groow conducts a final audit of the winner's Progress Score log, cross-referencing:

• Every point-awarding event against the payment ledger (Gate 3) and the course completion log (Gate 4).
• Quiz submission timestamps against the minimum time rule (Gate 5).
• Device fingerprint and IP history for any multi-account signals (Gate 2).

Any discrepancy found during the audit may result in disqualification, regardless of how long the contest has been running.

10.4 Data Handling of Identity Documents

• Identity documents are used exclusively for winner verification purposes.
• Documents are stored encrypted and are deleted within 12 months of prize delivery.
• If the winner requests immediate deletion after verification, Groow will verify, delete, and provide a written confirmation receipt.
• Identity document data is not shared with third parties except the travel booking agent who requires it to issue flights.

10.5 Winner Publicity

By accepting the prize, the winner agrees to the following:

• Groow will publish the winner's first name and country on groow.life and social media channels (as required by OG 99/2000 Art. 42). No surname, email address, or other personal data will be published without the winner's explicit written consent.
• The winner may be asked (but is not obligated) to provide a short testimonial or photograph for use on groow.life and Groow's social media. Declining this request does not affect prize delivery.

Article 11 - Data Protection & Privacy

11.1 Data Controller

Via Victoria Advisors SRL (CUI 43358097), Strada Neagoe Vodă, Nr. 18-22, Bloc 6/2, Scara A, Etaj 3, Ap. 13, Sectorul 1, București, Romania is the data controller for all personal data processed in connection with this contest.

11.2 Data Collected and Lawful Basis

11.3 Retention Periods

• Account and contest data: retained for the duration of the contest plus 3 years for legal and audit purposes, then deleted.
• Payment records: retained for 5 years from the transaction date (Romanian accounting law obligation).
• Identity documents (winner only): deleted within 12 months of prize delivery, or immediately upon verified written request.
• Device fingerprints and fraud detection logs: retained for 2 years from the end of the contest.

11.4 Your Rights

As a data subject under GDPR, you have the following rights:

• Right of access (Art. 15): request a copy of all data we hold about you.
• Right of rectification (Art. 16): request correction of inaccurate data.
• Right of erasure (Art. 17): request deletion of your data, subject to legal retention obligations.
• Right to data portability (Art. 20): receive your data in a structured, machine-readable format.
• Right to object (Art. 21): object to processing based on legitimate interests (device fingerprinting).
• Right to lodge a complaint: with ANSPDCP (Autoritatea Națională de Supraveghere a Prelucrării Datelor cu Caracter Personal) at www.dataprotection.ro.

To exercise any right, contact: hello@groow.life with subject line “GDPR Request - Progress Contest”. Groow responds within 30 days.

Article 12 - Consumer Rights (Distance Contract)

Course purchases on groow.life are distance contracts for digital content, governed by GEO nr. 34/2014 (transposing EU Directive 2011/83/EU). This article explains how the right of withdrawal applies to digital content and why groow.life courses are non-refundable once accessed.

12.1 Non-Refundable Digital Content - The Legal Basis

Under Article 16(m) of EU Directive 2011/83/EU (as transposed by GEO 34/2014), the 14-day withdrawal right that applies to most distance contracts does NOT apply to digital content - including online courses - where the following two conditions are both satisfied:

Both conditions are satisfied on groow.life at the point of purchase. Before completing any course purchase, the buyer is required to actively tick a checkbox (not pre-ticked) confirming: (a) consent to immediate access to the course content, and (b) acknowledgment that accessing the content means the right of withdrawal is lost. This is standard practice across all major digital content platforms (Udemy, Coursera, Netflix, Spotify) and is fully compliant with Romanian and EU consumer law.

This is the same legal mechanism used by every major digital content platform in the EU. It does not reduce your consumer rights - it applies the specific exception the law provides for digital content that you have chosen to access immediately.

12.2 Refund Policy

Groow course purchases are non-refundable once the buyer has accessed any part of the course content (video, audio, quiz, or text), subject to the following:

• Non-refundable: a course that has been accessed (any content opened, any video started, any quiz attempted) cannot be refunded. The withdrawal right is lost at the moment of first access, in accordance with Art. 16(m) of EU Directive 2011/83/EU.
• Technical failure exception: if a course is inaccessible due to a confirmed technical error on groow.life (not the buyer's device or network), Groow will offer either a full refund or a replacement credit at its discretion. To report a technical failure: hello@groow.life, subject “Technical Issue - [course name].”
• Duplicate purchase: if a buyer accidentally purchases the same course twice, the second purchase will be refunded on request within 14 days of the purchase date. Contact hello@groow.life with proof of the duplicate transaction.
• Courses not yet accessed: if a buyer has purchased a course but has not accessed any content, they may request a refund within 14 days of purchase. This situation is expected to be rare given that groow.life courses are accessible immediately upon purchase.

Contest implication: any refund cancels the Progress Score points associated with that purchase. Points from refunded purchases are removed from the leaderboard immediately and permanently. This applies regardless of the reason for the refund.

12.3 Checkout Consent Requirement

In compliance with Art. 16(m) of EU Directive 2011/83/EU and GEO 34/2014, every course purchase on groow.life includes a mandatory active-consent step at checkout. The buyer must tick the following confirmation before payment is processed:

This consent must be: actively given (the checkbox must not be pre-ticked); separate from acceptance of the general Terms of Service; stored by Groow with a timestamp as evidence of the consumer's informed consent; and shown in plain language before the payment button is presented.

12.4 Unfair Terms Protection

Under Legea nr. 193/2000 (transposing EU Directive 93/13/EEC), any term in these Rules that creates a significant imbalance in the parties' rights and obligations to the detriment of the consumer will be null and void. These Rules have been drafted to comply with this requirement. The non-refundable policy in Art. 12.2 does not create an unfair imbalance - it applies the specific statutory exception provided by EU Directive 2011/83/EU Art. 16(m) for digital content that the consumer has explicitly consented to access. In the event of any ambiguity in these Rules, the interpretation most favourable to the participant applies.

Article 13 - General Provisions

13.1 Modifications

Groow reserves the right to modify these Rules at any time. The notice period required before a modification takes effect depends on its type and materiality, as follows:

• All modifications are published on groow.life on the date of notice, with the effective date clearly stated.
• For modifications requiring 3 days' notice or more: an email is sent to all registered groow.life users at the time of publication.
• All modifications apply only from their effective date. No modification applies retroactively to actions already taken or points already earned.
• Continued participation after the effective date of any modification constitutes acceptance of the modified Rules.

13.2 Contest Cancellation

Groow reserves the right to cancel the contest if circumstances beyond its reasonable control prevent it from being conducted fairly or lawfully. Circumstances that may justify cancellation include (but are not limited to): a change in applicable law rendering the contest illegal; a material technical failure affecting score integrity; or a force majeure event. In the event of cancellation, no prize is awarded and no compensation is owed to participants solely for the non-award of the prize. Course purchases are unaffected by cancellation.

13.3 Groow's Reserved Rights

• Groow reserves the right to disqualify any participant whose behaviour, in Groow's reasonable judgement, constitutes an attempt to game, manipulate, or exploit the contest system, even if the specific method is not described in these Rules.
• Groow's decisions on all matters relating to the contest - including Progress Score calculations, eligibility determinations, and prize award - are final and binding, except where an appeal right is explicitly granted in Art. 7.4.
• Groow is not responsible for entries or data lost due to technical failures, internet outages, or other circumstances beyond its reasonable control.

13.4 Governing Law & Disputes

• These Rules and the contest are governed by Romanian law, supplemented by applicable EU regulations.
• Any dispute that cannot be resolved amicably shall be referred to the competent courts of Bucharest, Romania.
• Participants have the right to address consumer protection complaints to ANPC (Autoritatea Națională pentru Protecția Consumatorilor) at www.anpc.ro. ANPC has supervisory authority over commercial promotional activities in Romania under OG 99/2000.
• Alternative dispute resolution: under G.O. nr. 38/2015 (implementing EU Directive 2013/11/EU), consumers have the right to use accredited ADR entities listed at www.anpc.ro before or instead of court proceedings.

13.5 Severability

If any provision of these Rules is found to be invalid, illegal, or unenforceable under applicable law, that provision will be severed. The remaining provisions continue in full force and effect. The severed provision will be replaced with a valid provision that most closely achieves the original purpose.

13.6 Availability of Rules

As required by OG 99/2000 Art. 42: “Regulamentul de participare/desfășurare este disponibil în mod gratuit oricărui solicitant.” These Rules are available free of charge to any person requesting them: