“SPENN the Wheel” (herein referred to as the “Promotion”) refers to a series of promotional schemes designed by SPENN Rwanda Limited (herein referred to as “SPENN”) to recognize and reward the loyalty of SPENN account users. 

By participating in the Promotion, all Participant(s) agree to be bound by these Terms and Conditions. SPENN’s decision regarding any matter related to the Promotion will be conclusive and binding upon the Participant(s). 

1. Timeline The Promotion will be made available to the Participants on certain dates or time frames as it shall be announced through the SPENN App. These dates or time frames will be hereinafter referred to as “the Term”. 
2. All SPENN account users will receive notifications through SMS and/or in-app messages when a new Term and, therefore, a new launch of the Promotion is available. 
3. Engagement, Triggering Actions, and/or entries made before or after the specified dates and time of the Promotion, will not be considered as entries for the Promotion. 

1. 1. Who can participate? The Promotion is open to all SPENN users who meet the following requirements: Participants must be 18 years or older. 
   2. Participants must be a resident of Rwanda. 
   3. Participants must have a SPENN account. 
   4. Participants must be fully KYC-verified. 
   5. Participants must have logged into his/her SPENN account within the last two (2) years. 
   6. Participants must have installed and use the SPENN App on their Android device. The Promotion is not available to users who do not use the SPENN App on an Android device or who operate using the USSD service. 
   7. From time to time, participation in the Promotion may be subject to performing a certain action(s) during a certain time frame through the SPENN App, such as buying airtime, paying bills, or transfers to a different SPENN account or to third parties, for example. SPENN shall announce this special condition of the Promotion, be it via in-app communication, SMS, and/or any other channels usually employed by SPENN when communicating with SPENN users. The alluded action(s) will be hereinafter referred to as “Triggering Action”. 
   9. Persons who meet the above criteria shall be referred to as “Participant(s)” herein. 

1. Who cannot participate? 

1. SPENN account users who are employees of SPENN or employees of any company/business that has a direct relationship with SPENN or for the purpose of successfully executing this Promotion, or be in a position to interfere with the outcome of this Promotion whether legally or illegally due to access to confidential, privileged or unpublished information connected to this Promotion. 
2. Legal entities/Companies/Businesses including sole proprietorships. 
3. SPENN account holders who have not been fully KYC verified. 
4. SPENN account holder who has not logged into their SPENN account within the last two (2) years. 

1. 1. Rewards By participating in SPENN the Wheel, each Participant is eligible to win one of the following cash rewards at every spin: 
   2. In particular releases of the Promotion there may be different rewards that will be either added to those listed in Clause 4.1. or will replace them. These other rewards may be in the form of discount codes with third parties or other promotional benefits offered to SPENN users. However, when a different reward is to be redeemed, exchanged, validated, spent, or consumed at or with a third party, it may be subject to the third party’s contractual terms and conditions and SPENN accepts no responsibility and shall not be liable in any form whatsoever for any defects, damages, or losses suffered by the Participant(s) or any third party in connection to the said reward. SPENN shall communicate in such cases the type of possible rewards and whether these replace or add up to the rewards listed in Clause 4.1, via in-app communication, SMS, and/or any other channels usually employed by SPENN when communicating with SPENN users It will always be possible to spin and not win any reward at all, with disregard for the version of the Promotion released. 

1. Low cash reward: 25 RWF 
2. Medium cash reward: 50 RWF 
3. High cash reward: 150 RWF 
4. Top cash reward: 1,000 RWF. 

1. Rules of Promotion SPENN account users who are eligible to participate in the Promotion will receive a notification through SMS or on their SPENN App. 
2. The notification shall be sent each day in the Term at the time when the Promotion is made available. In case of particular releases of the Promotion, such notification may be in form of in-app banner or by any other means deem fit by SPENN at its sole discretion. 
3. The notification shall expire after 24 hours from the time it was sent. 
4. SPENN shall not impose any fees for participation in the Promotion. 
5. In case any Triggering Action(s) is requisite for participation in a particular release of the Promotion, eligible Participants who performed any Triggering Action during the Term will be 

1. 1. within forty-eight (48) hours after the end of the Term, through SMS or in-app notification, and be given the option to spin the wheel on the screen interface. 
   2. Eligible Participant(s) must tap the notification sent through SMS or In-App to participate in the Promotion. SPENN can not guarantee access to the Promotion if the user has disabled notifications of the SPENN App on their device. 
   3. By tapping on the notification, the eligible Participant(s) is automatically directed to the Promotion page which has a wheel-spinning interface. The Participant(s) is subsequently required to spin the wheel on the screen interface in order to potentially win a reward. 
   4. SPENN reserves the right to decide the number of spins a Participant can spin the wheel on each release of the Promotion or after each Triggering Action(s) performed by the user if such action is requisite of eligibility. 
   5. The spin wheel shall be divided into multiple reward sections, each section representing a cash and/or a different type of reward to be won, or no reward at all. 
   6. Once the Participant completes the wheel spin(s), the reward corresponding to the section where the arrow on the wheel points will be awarded to the Participant(s). Cash rewards will be automatically disbursed to the Participant(s) SPENN account. 
   7. If the arrow on the wheel does not point to any reward, the Participant(s) will not be eligible to win any reward and must wait for the next notification to participate in the Promotion. 
   8. SPENN reserves the right to disqualify any Participant if there are reasonable grounds to believe that the Participant has breached any of the Terms and Conditions stated herein, the terms and conditions generally applicable to SPENN users and SPENN Services, or committed fraud or any other illicit act or omission or by any other means act dishonestly to participate in this Promotion or obtain any benefit from this Promotion or from SPENN or I&M Bank Rwanda. 
   9. The reward selected by the arrow on the wheel after the wheel has been spun by the Participant shall be final, non-negotiable, and non-challengeable. 
   10. To the fullest extent permitted by law, the reward winners agree that their names and/or photographs may be published or announced in any media publication for publicity and advertising purposes and such usage will not grant the winners any further compensation. 

1. 1. Disqualification of winners and/or participants SPENN may withhold the rewards at its sole discretion or disqualify Participant(s) at any stage of the Promotion for the following reasons: The winner and/or Participant has committed fraudulent and illegal transactions on his/her account or acted fraudulently with regard to the Promotion. 

1. 1. 1. The winner and/or Participant has deviated from the rules of the Promotion and has attempted to manipulate, misuse, or circumvent the outcome of the Promotion to be entitled to participate in the Promotion. 
      2. The winner and/or Participant lacks legal capacity under applicable laws and in accordance with the provisions of the Terms and Conditions; or falls under the category of Participants prohibited under Clause 3 from participating in the Promotion. 
      3. It will be unlawful under the applicable local laws and regulations to award the reward(s) to the winner. 

1. Personal Data Protection Our Data Privacy Policy shall apply to all SPENN App users and SPENN customers and it covers all matters that are related to how we collect, use, share and protect your data. All our partners with whom we share your information must meet the requirements set out in this policy. See https://www.spenn.com/privacy-policy/ 

1. 1. Limitation of Liability Subject to any statutory limitations, no claim by the Participant(s) against a third party may be the subject of a claim against SPENN/I&M Bank Rwanda. 
   2. SPENN/I&M Bank Rwanda accepts no responsibility and shall not in any circumstance whatsoever be liable to the Participant(s) or any third party for any lawsuit brought against the Participant(s) in consequence of participation in or development of the Promotion, or any reward won under this Promotion. 
   3. To the fullest extent permitted by law, by participating in this Promotion, the Participant(s) agrees to indemnify and hold harmless SPENN/I&M Bank Rwanda, their holding, affiliates and/or subsidiaries, its officers, agents, employees, successors and assigns from and against any loss, damages, actions, claims, expenses and any other liabilities of any nature suffered or sustained by SPENN/ I&M Bank Rwanda arising from third parties or through the Participant(s)’ participation in this Promotion, breach of this Terms and Conditions therein, any related activity and/or acceptance, receipt, possession or use and misuse of any reward. 
   4. To the extent permitted by law, SPENN/I&M Bank Rwanda will not be liable in any way whatsoever, for any claims arising from loss, injury, damage, or costs, suffered by Participant(s) in relation to this Promotion or the rewards offered, including but not limited to claims relating to defects in the rewards or any losses caused by such defects or losses arising from incorrect or inaccurate information provided by the Participants and/or winner(s). 
   5. SPENN/ I&M Bank Rwanda shall not be liable to the Participant(s), if SPENN/ I&M Bank Rwanda is unable to perform its obligations under these Terms and Conditions, due (directly or indirectly) to the failure of any machine, transmission link, industrial dispute, or anything outside the control of SPENN/ I&M Bank Rwanda, its agents or subcontractors. 

1. 1. By accepting these Terms and Conditions and entering this Promotion, the Participant(s) undertakes that such decision is made of his/her free will and volition and such Participant(s) shall be legally responsible and liable for any loss, damage or legal expenses suffered by the Participant(s) because he/she took part in this Promotion. 

1. 1. Variations To the extent not contrary to the applicable law, SPENN reserves the right and may at any time at its discretion vary, alter, suspend, cancel, change, amend or refuse to renew this Promotion, its Terms and Conditions and the rewards without prior consent or approval of the Participant(s). 
   2. Notification of variation or amendment to an ongoing release of the Promotion shall be given to Participant(s) in writing and without undue delay, either by direct email, SMS text, In-App message, or other agreed digital communication method. 
   3. Varied or amended rewards, and/or Terms and Conditions will become binding and effective immediately without affecting the outstanding obligations and rights of the Participant(s) as a SPENN user and/or Participant in this Promotion. 
   4. All Participant(s) waive any rights that they may have or purport to have and acknowledge that no claim in respect of any variation of the Terms and Conditions is enforceable against SPENN following the moment the amendment is notified to the SPENN users and/or Participant(s) of this Promotion. 

1. Notices 10.1. Notwithstanding Clause 9.2 herein, the parties hereby acknowledge that any communications under these Terms and Conditions shall be in writing. Notices and correspondences between the parties may be sent by email or by registered mail/courier to the receiving party. Such notices or correspondences shall be deemed to have been received 3 days after dispatch, in the case of registered mail/courier by handing the said correspondence to a reputable courier service for immediate delivery to the addressee in a properly addressed package. 

1. 1. Maintenance The Participant(s) agrees that SPENN/ I&M Bank Rwanda accepts no responsibility and shall not in any circumstance be liable to the Participant(s), winner(s) or any third party for the maintenance, registration and/or upkeep of the reward won under this Promotion. 

1. 1. Severance If any one or more of the provisions in these Terms and Conditions are deemed invalid, illegal, void, or unenforceable in any respect by law or a competent court, the validity, legality, and enforceability of the remaining provisions of these Terms and Conditions shall not in any way be prejudiced, affected, or impaired. 

1. 1. Governing Law and Jurisdiction These Terms and Conditions shall be governed by and construed in accordance with the laws of Rwanda. 
   2. If any dispute arises between the parties, hereto relating to the interpretation and/or application of this Terms and Conditions, which cannot be resolved by mutual consultation, such dispute shall be referred to arbitration in accordance with Law No. 005/2008 of 14 February 2008 on arbitration and conciliation in commercial matters, or any statutory modification for the time being in force. The venue of such arbitration shall be at Kigali, Rwanda. 

1. 1. Tax Implication For cash rewards or cash equivalent, SPENN/ I&M Bank Rwanda shall deduct from the winner’s cash reward payment any applicable withholding tax at the percentage rate as at the time of cash reward payment was made. 

1. 1. Miscellaneous The Participant(s) undertakes that he/she has been given ample opportunity to read, and he/she has carefully read these Terms and Conditions. In addition, the Participant(s) has been given the opportunity to, and hereby advised to, have these Terms and Conditions reviewed by legal counsel of his/her/their choice. 
   2. The Participant(s) certify that he/she has made an investigation of the facts relevant to these Terms and Conditions and of all the matters pertaining thereto as deemed necessary, that he/she fully understands the contents of these Terms and Conditions, that he/she is of sound mind and intends and agrees to be legally bound by these Terms and Conditions. 
   3. All terms used in the singular form shall be interpreted to include the plural form, and vice versa, as dictated by the context and for the purposes of interpretation. 
   4. The foregoing shall constitute a binding and enforceable agreement between Participants and SPENN.