TERMS AND CONDITIONS FOR PARTICIPATION IN THE DRAW

FRESHLY HAIRCARE GIVEAWAY

• Organizer Identification

FRESHLY COSMETICS, S.L., with registered office at Calle Nicaragua 36, Reus (Postal Code 43204), and VAT number B-55666143, organizes this giveaway called FRESHLY HAIRCARE GIVEAWAY (hereinafter referred to as the “GIVEAWAY”), which will be governed by the following Terms and Conditions (hereinafter, the “Terms”).

• Territorial and Time Scope of the Promotion

The giveaway wil begin at 9 a.m. on September 14, 2025, and will end at 9 a.m. on September 19, 2025, both dates inclusive (hereinafter, the “Validity Period”), on the website : https://www.freshlycosmetics.com/en/giveaway-haircare-freshly-cosmetics

• Eligibility Requirements

All individuals of legal age who reside in Spain or Portugal are eligible to participate.

Employees of FRESHLY COSMETICS, S.L., and, where applicable, any companies involved in organizing the giveaway, as well as their direct relatives up to the second degree of kinship or affinity, are not eligible to participate.

If a winner is found to be ineligible or has provided invalid data, their participation will be null and void, and they will be automatically disqualified.

• Free Participation

Participation in this Promotion is completely free of charge.

• Validity of Participation

o validate participation, individuals must follow the steps indicated on the giveaway landing page created by FRESHLY COSMETICS: https://www.freshlycosmetics.com/en/giveaway-haircare-freshly-cosmetics

and accept the corresponding Data Protection notice.

Any fraudulent participation will be directly excluded from the draw.

Participation implies that the participant has read and expressly accepts these Terms and Conditions without reservation.

All non-winning participants accept to receive a thank-you email from Freshly, which may include, at Freshly’s discretion, a temporary discount or coupon for having participated.

• Prize

The prize consists of a bundle of Freshly products, including Freshly items from the haircare range. Below is the list of products, subject to stock availability.

The total value of the prize is estimated at €335. Shipping of the products is subject to Freshly’s Shipping Conditions.

• Winner Selection

There will be one (1) winner. The winner will be selected through a draw using the ViralSweep platform among all participants who have participated validly.

• Winner Notification

On September 19, FRESHLY COSMETICS will announce the winner and communicate the result via email and social media through its profiles: instagram.com/freshlycosmetics_es and instagram.com/freshlycosmetics_pt.
The winner will have a period of FIVE (5) calendar days from the date of notification to accept the prize by replying to the communication.
If the winner does not respond within the given time, fails to comply with these Terms, or rejects the prize, they will be disqualified, and the prize will be awarded to the next selected participant as described in these Terms.

9. Intellectual Property and Assignment of Image Rights

The acceptance of these Legal Basis by the participants in the draw implies their express consent to the use and dissemination of their first and last names on the FRESHLY COSMETICS website and social networks, to reproduce and use them in relation to any promotional activity related to the draw, for ONE (1) year from the start of the draw, in any medium (including, by way of example, not limitation, exploitation through the internet and social networks) without such use conferring them any right to remuneration or benefit, except for the prize won in accordance with these Legal Basis.

10. Data Protection

The personal data that may be required from the participants of the draw, and, if applicable, from the winners, are necessary to manage their participation in the draw and, if necessary, for the delivery of the prize.

The personal data of the participants or winners that, if applicable, FRESHLY may require, will be incorporated into a file owned by FRESHLY COSMETICS, S.L., solely for the purpose of managing this Promotion, communicating and assigning the prize, and thanking them for their participation.

Once the Promotion is finished, FRESHLY COSMETICS will only keep the data of those participants who, at the time of participation, have given their express consent, by checking a box enabled for this purpose, so that FRESHLY COSMETICS can incorporate their data into a file for the purpose of sending them newsletters and communications with commercial information, highlighted content, relevant advice on system operation, and promotions. The data of the other participants will be deleted from the processing systems of FRESHLY COSMETICS once the Promotion is finished, without prejudice to the possibility of keeping them, limiting their processing to the exercise and defense of claims, in accordance with the provisions of applicable law.

Participants who have consented to receive such newsletters and communications will have the possibility to request the cessation of such dispatches in the terms provided in Law 34/2002, of July 11, on Information Society Services, and to unilaterally revoke their consent at any time, also by sending an email to the following address: [email protected] or unsubscribing directly from the newsletters sent in the unsubscribe section.

The processing of personal data of the participants will be carried out in accordance with the provisions of the General Data Protection Regulation (EU Regulation 2016/679 of the European Parliament and of the Council, regarding the protection of individuals with regard to the processing of personal data), and the Privacy Policy of FRESHLY COSMETICS.

Participants in the Promotion may exercise their rights of access, rectification, cancellation, erasure, portability, opposition, and/or not systematic treatment for profile obtaining, by sending an email to the following address: [email protected]. Please refer to our Privacy and Data Protection Policy here: www.freshlycosmetics.com/es/politica-privacidad

11. Tax Matters

The prize of this draw constitutes a capital gain subject to the applicable regulations of the Personal Income Tax, Non-Resident Income, and other legal texts in tax matters at the time of obtaining the prize. The winner of the prize will be subject to compliance with all tax obligations established by the applicable current legislation of their country, if applicable, being solely responsible for their payment.

12. Reservations and Limitations

FRESHLY COSMETICS is exempt from all liability in the event of malfunctioning of the electronic communication networks that prevent the normal development of the Promotion due to causes beyond the Company's control and, especially, due to external acts of bad faith.

Any abusive or fraudulent use of participation forms by a participant will result in their disqualification from the draw. It will be understood, by way of example but not limited to, that there is an abusive or fraudulent use when a participant identifies themselves using a false identity or third-party identities without their consent.

FRESHLY COSMETICS is not responsible for the participant's use of the prize obtained from the promotion.

FRESHLY COSMETICS is not responsible for possible losses, damages, delays, or any other circumstance attributable to third parties that may affect participation in the Promotion.

FRESHLY COSMETICS reserves the right to change the elements of the prize of the Promotion for others of equal value when there is just cause.

FRESHLY COSMETICS reserves the right to modify or extend these promotional rules, provided that it does not harm or impair the rights of the participants.

This draw may be extended or suspended in cases of force majeure.

13. Applicable Law and Jurisdiction

These Legal Terms are governed by Spanish law.
To resolve any dispute, discrepancy, question, or claim arising from the execution or interpretation of these Legal Terms, the Parties expressly submit to the jurisdiction of the Courts and Tribunals of Reus, expressly waiving any other jurisdiction that may correspond to them.