Chapter One: Foundational Provisions and Legal Definitions
Article One: Introduction and Legal Framework
This document constitutes the comprehensive, binding, and exclusive legal contract between Fratiro (Simple Limited Partnership), a Lebanese company duly registered in the Commercial Register of the Ministry of Economy and Trade in Beirut under number 1028414, in its capacity as the exclusive owner and sole operator of the Twincoin digital platform and all related services and applications, on the one hand, and every natural or legal person—whether a user or a business partner—who uses, accesses, or interacts with the platform’s services in any manner or by any technical means whatsoever, on the other hand.
The Twincoin Platform constitutes an integrated and advanced digital ecosystem for managing commercial loyalty programs, consumer rewards, and effective marketing. It operates exclusively as a neutral technical intermediary between end-consumers and authorized business partners, through an innovative technological mechanism based on internal digital currencies that are non-redeemable for cash and not exchangeable outside the platform’s closed ecosystem. This complex technical system is operated through two specialized and technically separate applications: Twincoin, dedicated exclusively to end-users and consumers, and Twincoin Business, dedicated exclusively to approved business partners and institutions, in addition to the advanced digital infrastructure, servers, and supporting security systems.
Mere access to the platform by any technical means, browsing any of its interfaces, registering on it, downloading its applications, or using any of its services, features, or functionalities shall be deemed, by operation of law, an explicit, final, and irrevocable acceptance of all the provisions and articles of this legal document and all policies and implementing regulations associated with it, all of which constitute an integral and indivisible part of the contractual legal relationship between the parties.
Successful registration on the platform requires, as an absolute and mandatory condition, that the user or business partner place an electronic confirmation mark (✔) in the designated technical checkbox affirming agreement to these Terms and Conditions and the associated Privacy and Personal Data Policy as officially adopted by the administration. The records and data of this electronic act are automatically stored in secure databases with precise timestamps, serving as conclusive legal evidence and binding judicial proof of explicit, voluntary, informed, and final acceptance.
Furthermore, mere access, browsing, or use by unregistered visitors shall be deemed an implicit and binding legal acceptance of full and absolute compliance with all provisions of this legal document without exception.
Article Two: Binding Legal Definitions
For the purposes of interpreting and applying these Terms, the following definitions shall be adopted as the exclusive legal reference:
“Platform” or “Twincoin”: The complete digital ecosystem that includes the applications, websites, servers, databases, algorithms, and all intellectual property associated with the trademark Twinkey Twincoin, registered with the Ministry of Economy and Trade – Intellectual Property Protection Office under number 230003, and which is exclusively managed and operated by Fratiro.
“User”: Any natural person who uses the Twincoin application, whether registered with a full account or browsing as a visitor, and who is subject to all applicable general provisions, with specific obligations and responsibilities according to their level of use.
“Friends”: Registered users who have mutually exchanged and accepted friend requests through the platform, thereby becoming connected by a defined digital social relationship in accordance with the controls and restrictions set forth in these Terms.
“Business Partner”: Any legal entity or natural or juristic person registered in the Twincoin Business application, who offers products, services, advertisements, or promotional offers through the platform, and who is bound by the specific partner terms in addition to the general provisions.
“Gold Coins”: Internal digital units that are non-redeemable for cash, granted by the Business Partner to users upon purchasing approved offers, and used exclusively within the platform for the purpose of redemption with gift boxes or available rewards, without representing any real monetary value or financial obligation on Twincoin.
“Silver Coins”: Secondary digital units earned through interactive activities and the referral network, subject to dynamic storage limits linked to the user’s level, and used as a complementary currency in the rewards system in accordance with the rules determined by the administration.
“Redemption”: A transparent legal mechanism whereby the user, of their own free and conscious will, selects a specific gift box from among a unit (i.e., a displayed group of boxes), using their earned coins, in a deliberate selection process.
“Gift Box”: An encrypted digital unit containing a reward of predetermined value, whether it is the main gift of the unit or additional coin bonuses or otherwise, selected by the user and redeemed using their coins, through a transparent mechanism concealed even from the platform’s own team to ensure absolute integrity.
Chapter Two: Legal Capacity and Account Creation
Article Three: Eligibility Criteria and Age Restrictions
Any natural person who has reached eighteen (18) years of age or older, and who enjoys full legal capacity pursuant to the applicable Lebanese laws, is entitled to create an account on the platform and use all its services without restrictions, bearing full and direct responsibility for all activities, actions, and transactions related to their account.
Persons between thirteen (13) and seventeen (17) years of age are permitted to register and use the platform on a limited basis, provided they acknowledge their understanding of how the platform operates, and on the condition that any financial interaction or receipt of any physical gift is subject to the approval of a parent or legal guardian. The parent or guardian expressly and irrevocably acknowledges that the minor’s use of the platform is undertaken entirely under their responsibility, and that they alone bear all legal consequences and liabilities arising from the minor’s actions related to the account. Upon receiving any physical gift, the minor is required to present official documents proving their age, and the parent or guardian must attend in person with the required personal identification documents to sign the receipt acknowledgment, or the gift shall be delivered exclusively in the name of the parent or guardian if delivered through courier companies.
It is strictly and absolutely prohibited for children under thirteen (13) years of age to register or use the platform under any circumstances. Twincoin reserves its full and absolute right to terminate any account found to be in violation of this condition immediately and without prior notice, with confiscation of all balances, subscriptions, or currencies associated with it, without Twincoin incurring any obligation to provide compensation of any kind.
Article Four: Registration Mechanism and Identity Verification
Accounts are created through a rigorous registration process that includes identity verification via a One-Time Password (OTP) or any alternative verification method adopted by the platform. The registrant is obligated to provide correct, accurate, complete, and up-to-date information, including but not limited to: full legal name, true date of birth, gender, active phone number, and valid email address.
The user or business partner bears full legal responsibility for the accuracy of the information provided and for updating it immediately upon any change. Any damage, loss, or deprivation of rights resulting from providing incorrect or outdated information shall be borne solely by the account holder, without any liability on Twincoin. Completion of the registration process and explicit electronic acceptance of these Terms is considered an integral part of the validity of account creation.
With respect to business partners, accounts and branches are created exclusively by the specialized Twincoin team, after full verification of the submitted information and the required legal documents, which may include: a valid commercial register extract, professional licenses, the official identification of the authorized signatory, the detailed address of the main premises and branches, and any additional documents deemed necessary by the administration to verify eligibility and legality.
Chapter Three: Digital Currency and Rewards System
Article Five: Mechanism for Acquiring and Using Internal Digital Currencies
Gold Coins are primarily earned through rewards granted by the Business Partner to users upon the purchase of approved offers through the platform, whereby the partner determines the reward value in Gold Coins for each offer according to its marketing strategy, without any intervention from Twincoin in such determination. Additionally, Gold Coins may be granted through interactive tasks, level rewards, or special gift boxes launched by the platform from time to time.
Silver Coins are earned exclusively through interactive activities within the platform, which include: regular daily logins, completion of specified tasks and challenges, leveling up, inviting new users through the personal referral code, or automatically through the multi-level referral network when linked users earn Gold Coins through their purchases from partners.
Silver Coins are subject to a dynamic storage limit system linked to the user’s level, where the base capacity starts at three thousand (3,000) Silver Coins and gradually increases every ten levels according to a predefined table. Twincoin reserves its absolute right to modify these limits and earning mechanisms at any time in accordance with its operational requirements, without any obligation to provide prior notice, and continued use shall be deemed implicit acceptance of any such modifications.
Gold and Silver Coins shall not expire once they have been added to the user’s account, subject to the provisions of Articles Thirteen and Twenty-Five of these Terms.
Article Five (bis): Printed Twincoin Cards
A printed Twincoin card is a card bearing a unique Quick Response (QR) code covered by a scratch-off layer, handed by the Business Partner to the user exclusively within an approved offer on the platform, and representing a specified number of Gold Coins stated on it. The card bears the Twincoin name and its trademark duly registered with the Ministry of Economy and Trade, and is protected under Article Eighteen of these Terms. The card is neither money nor a cash voucher, and may not be sold, purchased, or exchanged for money under any circumstances.
A Business Partner receiving printed Twincoin cards must be registered on the platform with an active account and must have an approved offer linked to these cards, and the cards remain dedicated exclusively to covering that offer. The partner may under no circumstances sell, gift, distribute, exchange, or otherwise dispose of the cards outside the approved offer, nor hand them to any user except against the user’s actual fulfillment of the offer’s terms as published on the platform. The partner is likewise prohibited from changing the content or terms of the offer upon execution in a way that makes what the user receives differ from what is offered. A user who has fulfilled the terms of the offer and did not receive the card may file a report directly in accordance with Article Fifteen of these Terms. Any breach of the foregoing constitutes a serious violation subject to the provisions of Articles Twelve and Thirteen, and Twincoin retains the right to recover unused cards and cancel their codes.
A Business Partner’s request to return or exchange printed cards is subject to the same provisions applicable to the cancellation and refund of Gold Coin packages under Article Eleven of these Terms, and Twincoin may, upon approval, impose a deduction that includes printing and production costs.
Coins are added to the user’s account immediately upon scanning the code through the Twincoin application, which requires downloading and registering on the application upon first use. Twincoin determines the type of each code and the number of times it may be used; a code is valid for one use only unless otherwise stated, and the coins go to the first account that scans it. A card does not expire before it is scanned.
Twincoin bears no responsibility for lost cards, cards scanned by someone other than their holder, or cards handed to the user after their code has already been used; in the latter case, the Business Partner shall be held accountable in accordance with these Terms. A damaged card shall only be replaced upon a request submitted by the user directly to Twincoin, accompanied by a clear photo of the card. After Twincoin verifies that the code is valid and unused, the coins shall be added to the user’s account within seven (7) business days.
Forging cards, copying their codes, tampering with them, or scanning them by automated or unlawful means is strictly and absolutely prohibited. Any person committing such acts shall be subject to the penalties set forth in Articles Twelve and Thirteen of these Terms, in addition to civil and criminal prosecution under applicable Lebanese laws.
Article Six: Level System and Advanced Referral Network
All users are subject to a hierarchical system of one hundred (100) graduated levels, in which advancement occurs automatically based on the total points earned from various activities. Each level unlocks new benefits and capabilities, including increased Silver Coin storage capacity, nominal account titles, and level-specific rewards.
The referral network extends to five (5) levels in depth, whereby the host receives a percentage of the Gold Coins earned by users within their network through their purchase of offers from partners, automatically converted into Silver Coins according to the following percentages:
• Level One: 50%
• Level Two: 40%
• Level Three: 30%
• Level Four: 20%
• Level Five: 10%
These percentages are calculated from the base value of the Gold Coins earned and do not affect the original user’s reward in any way.
Chapter Four: Social Relations and Limited Exchange
Article Seven: Friendship System and Non-Commercial Exchange
The technical system enables registered users to establish defined digital friendships through sending and accepting friend requests in accordance with the pre-determined technical mechanisms and protocols. Once mutual acceptance is completed, the two users acquire the status of “Friends” as defined in these Terms, thereby becoming entitled to benefit from the specific and limited social features and services set forth in this Article.
Approved Friends are permitted to exchange internal digital currencies (Gold and Silver) and gift boxes exclusively among themselves, in accordance with the technical limits and controls determined by Twincoin, which may be amended at any time without prior notice. It is strictly and absolutely prohibited to use this feature for any commercial, investment, or profit-seeking purpose, including but not limited to: selling currencies or gift boxes for real money, trading currencies or gift boxes outside the platform, creating parallel markets, or any form of direct or indirect commercial or financial exploitation.
Friends may attach personal text messages to exchanged boxes, provided that all messages and exchanged content are subject to continuous security monitoring and both automated and manual review, in accordance with advanced artificial intelligence systems and specialized review teams. Twincoin reserves its absolute and exclusive right to monitor, inspect, and review all exchanged content and messages to ensure compliance with applicable laws and platform policies, while maintaining its legal and ethical obligation to immediately notify the competent authorities upon discovering any content that is threatening, unlawful, or poses a risk to public safety or personal security.
Twincoin commits not to interfere with deleting or modifying personal messages exchanged between Friends except in exceptional cases that legally or security-wise necessitate such intervention, while preserving the right of users to report any violating or abusive content through the designated reporting mechanisms. Upon receiving substantiated and justified reports, the platform administration shall conduct the necessary investigation and take appropriate actions, which may include issuing warnings, suspending, or terminating the offending account, without altering the content of the messages themselves except pursuant to a judicial order or an overriding legal necessity.
Chapter Five: Unit System and Gifts
Article Eight: Unit System and Silver Boost
The Unit System in Twincoin is based on the principle of conscious and voluntary selection conducted in accordance with specific and binding legal procedures, whereby the user personally and of their own free and absolute will selects a specific box from among a group of boxes displayed and available for each Unit, using their digitally earned coins lawfully and legitimately acquired through their various approved activities within the platform. This conscious, deliberate, and voluntary selection is the core distinguishing element of our system.
The boxes displayed in each Unit contain various and pre-determined types of rewards and gifts, including but not limited to: the main physical gift announced and approved for the Unit, which may be a modern electronic device, an approved vehicle, a specified cash amount, or any other announced and guaranteed valuable gift; additional Silver Coins in varying quantities ranging from a single coin to hundreds of coins depending on each Unit. The user expressly and irrevocably acknowledges full, clear, and complete understanding that not all boxes necessarily contain a high-value or exceptional physical gift, and that a considerable percentage of them—reaching up to 99%—may contain only small and limited amounts of Silver Coins. The user finally and irrevocably accepts this diversity and variation as an essential and integral part of the nature of the platform’s system, bearing full and absolute responsibility for their choice and decision.
The entire process and all of its stages are conducted through advanced and complex encryption algorithms using the latest and strongest internationally recognized cybersecurity and digital protection technologies, which ensure and confirm that the contents of the boxes and the distribution of gifts are completely, absolutely, and permanently concealed even from the administrative and technical team of Twincoin. This guarantees absolute transparency, complete integrity, and full fairness of the system, and definitively eliminates any possibility of manipulation, favoritism, or unauthorized human or technical interference.
All ordinary Units, without exception, are subject to four specific, binding, and sequential procedural stages:
Stage One – Filling and Final Selection:
Users redeem their earned digital coins for the boxes available and displayed in the Unit according to their free, conscious, and final choice. Once redemption is completed, the user expressly and definitively consents in advance, in a binding and irrevocable manner, that the selected box shall not be opened nor shall its contents be revealed except according to the specified stages.
Stage Two – Waiting and Procedural Freeze:
This stage begins automatically and immediately once all boxes designated for the Unit have been redeemed without exception. It continues mandatorily for a pre-announced period ranging between minutes, hours, or days, during which official notifications are sent through the application to all users who redeemed boxes in this Unit.
Stage Three – Final Preparation:
The advanced systems perform final preparation for result disclosure and ensure readiness of all technical and security mechanisms for the final stage.
Stage Four – Final Disclosure and Binding Results:
A simultaneous and instant disclosure of the contents of all boxes redeemed in the Unit takes place, accompanied by official and immediate notifications through the application to all redeemers, and publication of the name and photo of the recipient of the main gift available on the platform, along with the number, date, and time of the redemption of the box containing the main gift. Verifying that the main-gift box was not redeemed at the very beginning of the Unit for the purpose of guaranteeing the result—confirmed by matching date and time—serves as additional evidence reinforcing the integrity and transparency of the system.
Silver Boost System
In Units that support the Silver Boost option, a specialized system differing from ordinary Units applies. Some Units may include a “Silver Boost” option, an advanced system allowing Unit boxes to be redeemed using a mixture of currencies (a primary currency + an additional currency such as Gold + Silver) according to a special and pre-determined mathematical formula set by the platform for each Unit individually and independently.
It is strictly required that the user redeem at least one box using the primary currency designated for the Unit as a mandatory condition. In return, the platform grants a specified and announced number of additional boxes that may be redeemed using the secondary currency in accordance with the declared and fixed conditions and formulas. A user may redeem again using the additional currencies according to the same original announced formula after completing the first round.
Reduction Mechanism for Silver Boost
Twincoin determines in advance, with full clarity, the numerical threshold at which, once the total number of boxes redeemed with the primary currency is reached, the “specialized reduction” stage begins. During this stage, all non-redeemed Silver Boost boxes that do not contain the main gift are automatically and permanently cancelled, while exclusively retaining the number of remaining non-redeemed boxes, which may be redeemed using the primary currency only. After completing the reduction stage, the Unit proceeds in accordance with the four ordinary stages mentioned above until all remaining boxes have been redeemed.
Twincoin retains its absolute, final, and unchallengeable legal right to suspend or cancel any ordinary Unit or Silver Boost Unit at any time before the start of Stage Four (Final Disclosure) for any justified reason it deems appropriate and reasonable. In such exceptional cases, all redeemed coins shall be fully returned to the balances of the users who redeemed within the Unit, without any deduction or reduction, and without Twincoin incurring any obligation to pay any additional compensation, interest, damages, or remedial rewards. This is considered an inherent, fixed, and legitimate right of the platform that may not be contested or challenged under any legal or factual pretext.
Prohibited Conduct
It is strictly and absolutely prohibited for all users and business partners, whether directly or indirectly, to engage in any of the following actions:
• Issuing, publishing, or promoting any statements, predictions, or possibilities regarding Unit results or box contents prior to the final disclosure.
• Using social media, media outlets, or any other digital means to imply possession of internal or confidential information regarding the results.
• Influencing the public or redeemers through insinuations, promotional campaigns, or advertisements suggesting that any party can predict or control the contents of boxes.
Twincoin reserves its absolute right to:
• Conduct immediate investigations into any breach of this clause.
• Suspend or terminate the offending account without prior notice.
• Confiscate all digital currency balances associated with the account.
• Refer the offender to the competent authorities in cases involving fraud, public deception, or harm to the platform’s reputation.
This clause constitutes an essential part of the principle of absolute transparency and complete fairness upon which the Unit System is founded. Any violation thereof shall be classified as a serious offense warranting the maximum penalties stipulated in these Terms.
Article Eight (bis): Gift Shop
The Gift Shop is an independent section within the platform where the user directly redeems their coins for a gift, voucher, or balance of their own choosing, at a price announced in advance in coins, without any random or chance-based element. The Shop’s items include, without limitation: physical gifts, vouchers with Business Partners, monetary balances transferred through money-transfer companies, and any other items announced by the platform from time to time.
Each item is priced either in Gold Coins or in Silver Coins, and the same item may be offered at two separate prices, one in Gold Coins and the other in Silver Coins. Twincoin reserves its absolute right to set and modify prices and quantities at its discretion and without prior notice. Certain specifications of a gift, such as color or model, may differ from the item displayed depending on availability, provided that the gift is equivalent to it in category and value.
Twincoin alone lists partner vouchers in the Shop after purchasing them from the partners, and the Business Partner has no authority to list or modify them. The partner is obligated to honor the voucher according to its terms and remains solely responsible for the quality, safety, and validity of the product or service and for everything resulting from its use, in accordance with Article Ten of these Terms. Twincoin bears no responsibility if a voucher is not used within its validity period.
Redemption is final and irrevocable once confirmed. Redeemed coins are refunded only if the item is unavailable, if an error occurs on Twincoin’s part, or if the voucher cannot be honored for a reason attributable to the Business Partner once this is established by Twincoin.
Items are delivered according to the nature of each item and as stated in its description: via a delivery service at the user’s expense or at Twincoin’s expense, by collection from Twincoin’s office, or at the relevant Business Partner. Delivery usually takes between seven (7) and fifteen (15) business days from the date of redemption, and the provisions of Article Twenty-One of these Terms apply to delivery.
Monetary balances are transferred to the account designated by the user with the relevant money-transfer company, and the user alone is responsible for the accuracy of the account or phone number and all other details they provide. Twincoin bears no responsibility for transfers made to incorrect details provided by the user, or for any delay or malfunction at the transfer company, in accordance with Article Twenty-One of these Terms. The user bears any fees charged by the transfer company, including withdrawal fees.
A gift redeemed from the Gift Shop shall be held for the user for ninety (90) days from the date of redemption, or any shorter period stated in the description of the item or voucher according to its nature. During this period, the user is obligated to respond to communications from Twincoin or the relevant partner, to set a collection appointment or provide correct and complete delivery details, or to contact Twincoin directly to complete delivery. Where delivery is made by courier, Twincoin shall make one (1) delivery attempt only; if that attempt fails for a reason attributable to the user, including without limitation: not responding to calls or messages, not attending at the specified time or place, not being present at the delivery address, or providing incorrect or incomplete information, the user must collect the gift in person from the location designated by Twincoin within the remaining period, or request redelivery at their own expense where Twincoin agrees to it. Upon the lapse of the specified period without delivery being completed for a reason attributable to the user, the user’s right to claim the gift or the redeemed coins shall permanently expire, and Twincoin may dispose of the gift as it deems appropriate, without any obligation to compensate.
Article Nine: Gift Delivery Mechanism, Warranties, and Media Publication
Following the announcement of the final result of the Unit and the simultaneous disclosure of the contents of all boxes at the same time, and the announcement of the identity of the redeemer of the main physical gift, the redeemer is obligated to re-confirm their complete and accurate personal information, including: full legal name as stated on the official identification document, identification number or passport number, date of birth, full and detailed address, active phone number, active email address, and to provide any additional documents that Twincoin may request to verify their identity and legal eligibility to receive the gift. Providing this information and documentation is considered an essential part of the entitlement to the gift, and Twincoin has the right to withhold or suspend its delivery if this obligation is not fulfilled.
Twincoin shall retain the main physical gift in its secure storage facilities or with the sponsoring entity for a full period of three (3) months (ninety days) calculated from the date of the official announcement of the result. During this period, the redeemer has the right to claim and receive their gift in accordance with the mechanism determined by the administration, including specifying the conditions such as the date and time of delivery, and the delivery location, whether direct delivery at the company’s headquarters, the sponsor’s store, an official event, in the presence of or through guest dignitaries, or via an approved courier company. If the redeemer does not present themselves to receive their gift within the specified period, the gift shall automatically and irrevocably be converted into a monetary value equivalent to forty percent (40%) of the original purchase price as stated on the official invoice, and this value shall remain available for an additional three (3) months. After six (6) months (180 days) have elapsed, the redeemer’s right to claim the gift or its value shall permanently and conclusively expire, and Twincoin shall have full freedom to dispose of the gift or its value as it deems appropriate, including donating it, re-listing it in later Units, or retaining it without any further obligation.
Twincoin reserves its full and absolute right, at its sole discretion, to accept or reject any request submitted by the redeemer to receive the main gift through a third party, including but not limited to: delivery or shipping companies, a family member, a relative, or any other entity proposed by the redeemer. If the administration explicitly and in writing approves such a request, the delivery process shall automatically be subject to all the provisions and conditions stipulated in the article concerning third parties and external services, and the redeemer shall be deemed to understand that full responsibility transfers to the third party once delivery occurs. The redeemer also acknowledges their final and binding agreement to bear all costs, fees, and expenses related to delivery, shipping, or any additional services associated with the delivery.
Twincoin further reserves its full right to document and publicize the gift delivery process by photographing redeemers during collection or requesting photos or videos from them as proof of receipt when delivery is carried out through courier companies or any third party. Twincoin also reserves the right to publish this material through the platform or any official media or advertising channel, or through the platform’s social media accounts or official website. The redeemer acknowledges, from the moment they redeem from the Unit (i.e., redeem a box), their final and binding consent that Twincoin has the right to publish their full or abbreviated name, their profile photo appearing on the application, the redeemed box number, and the date and time of the redemption of the redeemed box, as this is considered an essential part of the transparency and announcement system upon which the platform is based. Under no circumstances shall the redeemer have the right to object to such publication, request its cessation, or demand any financial consideration or compensation as a result thereof. This acknowledgment is considered a fundamental condition for participating in the redemption process and accepting its outcomes.
Digital Rewards and Coins
Silver Coins appearing in boxes that do not contain the main gift are automatically and immediately added to the user’s account, without the need for any additional procedures or confirmations. These rewards are not subject to the time or procedural restrictions applicable to physical gifts, and may not be redeemed for any monetary or material value under any circumstances.
Warranties, Guarantees, and Scope of Liability
Twincoin undertakes to purchase the main physical gifts from official and reliable sources with valid legal invoices, and guarantees that the gift conforms to the specifications announced for the Unit. In the event a defect or malfunction is proven prior to delivery and is caused by negligence on the part of Twincoin, the platform is obligated to address the issue within a maximum period of one (1) month, whether through repair, replacement, or providing appropriate financial compensation not exceeding the official value documented on the invoice. In the event a defect or malfunction appears after delivery, responsibility lies exclusively with the original seller in accordance with the warranty or legal guarantee attached thereto, if any.
Disclaimer of Personal Safety and Damages
Twincoin bears no responsibility whatsoever for the safety or security of the redeemer or their companions before, during, or after the process of receiving the gift, regardless of the delivery location. Twincoin bears no liability for any physical, psychological, or material damages that the redeemer or their companions may incur during their travel or throughout the delivery process.
Chapter Six: Provisions Applicable to Business Partners
Article Ten: Acceptance Criteria and Prohibited Activities
Twincoin has the absolute and sole discretion to accept or reject the registration of various types and sizes of commercial activities—from multinational corporations to small sole-proprietorship businesses—including but not limited to: private and public companies, sole proprietorships, commercial markets, malls, community activities, governmental and semi-governmental entities, and non-profit organizations, provided that the core activity is not included in the prohibited list, which strictly and exclusively includes: tobacco products, tumbak, flavored tobacco (mu’assel), cigarettes, cigars, and all their derivatives; alcoholic beverages of all types and concentrations; pornographic or adults-only content; gambling, betting, or lottery activities; and any materials or services prohibited under Lebanese law or international conventions to which Lebanon is a party.
The Business Partner may create sub-accounts linked to its main account to enable its branches or internal units to use the platform’s services and manage offers independently. All such sub-accounts are considered an administrative extension of the main account and do not establish any direct contractual relationship between the branches and Twincoin. The main account remains the sole legally and financially responsible party before Twincoin for all activities, transactions, and advertisements issued by any sub-account belonging to it, including any violations or breaches of the Terms and Conditions. These internal accounts are merely an organizational tool for the partner, and Twincoin bears no responsibility for internal mismanagement, disputes, or conflicts between branches or their employees. Twincoin reserves its right to monitor, suspend, or cancel sub-accounts if any breach of the Terms is proven, and such action shall have the same binding legal effect as if taken against the main account.
The Business Partner is strictly and definitively obligated to provide offers that are clear, accurate, truthful, and complete, including all essential details without any deception or concealment, such as: the true initial or final price of the product or service, a detailed and precise description of the product or service offered, any special terms and conditions applicable to the offer if present, real and authentic images of the product, and the value of Gold Coins granted as a reward upon purchase. The partner is also obligated to ensure that the offers presented, in all their details without exception, do not contain any item from the strictly prohibited list.
Once an offer is published and approved by Twincoin’s administration, the partner may not modify, change, or delete it directly through their account. Instead, they must submit a formal and detailed request to the Account Management team or the Sales team specifying the required modifications and the reasons behind them. The team shall, upon approval, execute the necessary changes themselves, ensuring full transparency and protecting users from any manipulation or sudden change to the offer's terms.
The Business Partner is the sole, exclusive, and full party responsible for: determining the reward value in Gold Coins for each offer according to its marketing strategy; the accuracy, correctness, and timeliness of all information related to its products and services; the quality of the products or services offered to users; all delivery, shipping, and transportation operations for its products and services to users; and all contractual or legal obligations arising between it and the users.
The Verified Badge is a distinctive mark granted exclusively by Twincoin to Business Partners with a paid subscription. It signals that the account is verified and linked to an active subscription. This badge does not, under any circumstances, constitute a recommendation or guarantee from Twincoin regarding the quality of the partner’s products or services, nor does it represent any legal obligation of the platform toward users. Twincoin reserves the full and absolute right to suspend, withdraw, or cancel the Verified Badge at any time, without the need for prior notice, if negative performance, repeated violations, misuse of the platform, or any breach of the Terms is detected. Twincoin’s decision in this regard is final, binding, and non-appealable. Removal of the badge does not create any financial or compensatory obligation on Twincoin toward the Business Partner or users, and the partner acknowledges that its continued use of the remaining paid subscription services remains valid and independent of the badge.
Twincoin bears no responsibility whatsoever for: the quality, safety, or suitability of the partner’s products or services; the timing, costs, or mechanisms of delivery, shipping, or transportation; any contractual or financial obligations between the partner and the user; any disputes, conflicts, or claims related to sold products or services; any direct or indirect damages arising from dealings between the partner and the user; or any delay or failure in delivering products or providing services. Twincoin’s role is exclusively and conclusively limited to providing the technical platform as a neutral electronic intermediary, ensuring delivery of the due Gold Coins to the user according to the published offer and after completion of the sending process by the partner, and providing partner contact information through the contact details available on the platform.
To keep offers, branches, and the partner’s commercial account active, the branch presenting the offer must maintain a sufficient balance of Gold Coins covering at least the value of one unit of the highest offer presented. If the balance falls below this minimum threshold, the platform shall suspend the appearance of the offers and the associated account within no more than twenty-four (24) hours, and the account shall not be reactivated until the balance is replenished to the required level.
Article Eleven: Financial System and Subscriptions
Subscription prices, packages, advertising spaces, sponsored offers, and additional services are determined according to the pricing policy adopted by Twincoin’s administration and announced through the application or by the sales team. All announced prices do not include value-added tax (VAT) or any other governmental fees unless explicitly stated otherwise, and such taxes are added at invoicing according to the applicable legal rates.
Twincoin reserves the right to modify prices, provided that partners affected by the changes are notified at least thirty (30) days prior to the implementation of the new prices via the registered email address or application notifications. Exempt from the notice period are changes resulting from governmental tax alterations or force majeure conditions, which apply immediately upon issuance. The partner has the right to terminate their subscription before the new prices take effect without any additional penalties.
Subscription fees—including periodic subscriptions, advertising space services, and sponsored offers—are collected in advance and in full for the agreed-upon period (whether weekly, monthly, or yearly), and payment is considered a required and binding condition for benefiting from the service during that period. These fees are non-refundable under any circumstances, even if the service is not used or if the account is suspended or terminated as a result of the Business Partner’s violation of any applicable Terms.
As for Gold Coin packages, they shall not be activated until the payment process is confirmed and the invoice is approved by the sales team. These packages may not be cancelled or refunded after activation, except through an explicit and written approval from Twincoin’s administration, or in the event of a human or technical error officially proven by the platform team. If the administration grants an exceptional approval for cancellation or refund, it may—at its absolute discretion—impose a financial deduction from the value of the unused coins, with the percentage of this deduction to be determined through negotiation and mutual agreement between the parties. The resulting agreement is final, binding, and non-modifiable or subject to appeal by any means.
Chapter Seven: Obligations and Prohibitions
Article Twelve: General Prohibitions and Penalties
It is strictly and absolutely prohibited for all platform users—whether end users or Business Partners—to engage in any act or practice constituting a material breach of these Terms, and such conduct shall be deemed a serious violation warranting immediate penalties. These violations include, but are not limited to: creating more than one account for the same person or entity; using forged or impersonated identities; attempting to circumvent the platform’s technical systems through automated software, virtual private networks (VPN), or similar technologies; selling, purchasing, or trading internal digital currencies outside the official and approved channels; exploiting the friend-to-friend currency exchange system for commercial or profit-driven purposes; creating fake accounts to bypass restrictions; using social relationships for manipulation or fraud; issuing predictions or promoting assumptions about box or Unit results; attempting to hack or tamper with technical systems or exploit software vulnerabilities; publishing offensive or illegal content or content inciting hatred or violence; abusing, threatening, or defaming any other user or any Twincoin employee; or cooperating in any manner in fraudulent or unlawful activities.
It is also strictly prohibited for any Business Partner, whether directly or indirectly, to engage in any cooperation, collusion, or agreement with a user or external party to sell, purchase, or exchange internal digital currencies of the platform outside the official channels approved by Twincoin, whether through cash transactions, unauthorized transfers, or any other unlawful means. Such conduct constitutes a grave breach that undermines the core of the platform’s financial system and exposes it to severe risks, including suspicions of money laundering, legal circumvention, or undermining public trust in the platform. In the event this violation is proven, Twincoin reserves its absolute and final right to impose deterrent measures, which may include: the immediate suspension of the violating partner’s account or branch; confiscation of all associated balances without any right to reimbursement; cancellation or removal of all published offers; and referral of the case to the competent judicial authorities for legal prosecution when required. Continued use of the platform by the Business Partner after this statement shall constitute an explicit and binding acknowledgment of full compliance with this prohibition and full legal responsibility for its breach.
Twincoin, in all cases, reserves its absolute right to take the appropriate disciplinary measures upon establishing any violation, in accordance with a graduated escalation policy that considers the severity of the misconduct, starting from issuing initial warnings, to temporary account suspension, and up to permanent suspension with confiscation of all associated balances in serious cases. In grave violations such as fraud, hacking, or unlawful cooperation, immediate suspension and full confiscation shall apply without prior notice, as such violations threaten the integrity and stability of the platform as a whole.
Article Thirteen: Balanced Freezing and Confiscation Policy
Upon suspicion of a violation, or upon receiving credible reports from users or partners, or upon detecting suspicious activity through automated monitoring systems, Twincoin has the right, at its absolute discretion, to apply immediate precautionary freezing of the concerned account for a period not exceeding thirty (30) days, during which a thorough and detailed investigation shall be conducted to verify the validity of the claims or suspicions.
For Business Partners: In cases of final termination of a Business Partner’s account resulting from an amicable settlement or a proven violation—including but not limited to operational breaches, non-compliance with platform standards, delays in sending coins, or publishing inappropriate content—the partner may, optionally and within a period not exceeding one (1) week from the date of suspension, request to recover fifty percent (50%) of the unused balance of Gold Coins, calculated according to the last officially approved invoice issued by Twincoin, after deducting any dues owed to Twincoin or any compensation owed to affected third parties. Reimbursement shall be completed within sixty (60) days from the date of final approval of the refund request.
In cases of proven fraud, attempted hacking, or deliberate manipulation, full confiscation (100%) of all balances, coins, and subscriptions shall apply without any right to refund or compensation, and this shall be deemed partial compensation for the damages incurred by the platform.
For regular users: All established violations by regular users—whether minor or major, fraudulent or non-fraudulent—shall result in full confiscation (100%) of all balances of Gold and Silver Coins, without any right to refund, compensation, or claims, as these coins were granted for free and the user did not pay any monetary value for them. The only exception for users applies in cases of a proven and documented technical error on the part of Twincoin that led to the unjustified loss of coins, in which case the user shall be compensated only for the lost amount.
Full and final confiscation (100%) shall apply to both users and Business Partners, without exception or right to refund, in the following cases:
• Proven fraud supported by conclusive evidence or attempted deception against the platform or its users
• Attempted hacking of the systems, exploitation of software vulnerabilities, or deliberate harm to the infrastructure
• Manipulation of currencies, attempting to sell them for cash outside the platform, or collusion in currency-laundering operations
• Identity theft, use of forged identities, or falsified documents
• Repetition of serious violations after receiving a final documented warning
• Cooperation in criminal, terrorist, or money-laundering activities
Chapter Eight: Grievance and Legal Review Mechanism
Article Fourteen: Internal Grievance System
Any user or Business Partner whose account has been frozen, suspended, had its balances confiscated, or been subjected to any disciplinary action, has the right to submit a formal grievance within fifteen (15) days from the date of receiving the disciplinary notice, via the designated email address: appeals@twincoin.app.
The grievance must include: a detailed and logical explanation of the incident from the complainant’s perspective; supporting evidence and documentation, if any; an acknowledgment of the accuracy of the information provided; and clearly defined demands.
Twincoin is obligated to form an independent review committee comprising at least three members of senior management, or the Chief Executive Officer, General Manager, or their authorized delegate may independently issue the review decision, provided that the decision is reasoned, written, and documented. The review body (whether the committee or the authorized manager) shall issue its final, reasoned, and written decision within thirty (30) days from the date of receiving the complete grievance with all its attachments. This decision shall be final and binding at the platform level and may not be appealed again internally.
During the grievance review period, the account shall remain under precautionary freezing, with the possibility—in cases of extreme necessity—of granting exceptional permission for partial withdrawal of non-disputed balances, based on a justified, documented request and written approval from the administration.
Article Fifteen: Reporting System for Business Partners
Twincoin establishes a dedicated legal and procedural system for receiving and processing reports submitted by users or affected parties against approved Business Partners on the platform, in cases where unlawful practices or material operational violations are proven or suspected, such as offering fraudulent deals, withholding delivery of Gold Coins, or publishing misleading or unlawful content. This system forms an integral part of the guarantees provided by Twincoin to protect user rights, uphold the integrity of the platform, and ensure that all Business Partners comply with required contractual and legal standards.
Reports are processed through an official mechanism that begins with the user or affected party submitting a documented report through the designated channels within the application or via the official email, including details of the incident and any available supporting evidence. Upon registration of the report, the responsible administration opens an independent review file that includes technical and legal investigation, collection of data related to the offer, service, or branch subject to the report, and granting the Business Partner the opportunity to defend themselves by submitting a written response within a specified deadline. Review reports issued by the administration are adopted as binding internal evidence for making the appropriate decision.
Twincoin retains full legal authority to take necessary measures if the report is proven valid, including but not limited to: suspending or disabling the violating offer, disabling the relevant branch or the entire business account, freezing balances related to the offer subject to the report, or permanently confiscating them in cases of proven deception or fraud. In severe cases that may constitute criminal or civil offenses, the platform shall refer the file directly to the competent authorities, providing them with all documents and evidence collected during the investigation.
Continued use of the platform by the Business Partner after issuance of a final decision regarding the report shall constitute prior and explicit acceptance of full compliance with all consequences of this system, as well as a waiver of any subsequent claim of lack of knowledge of its existence or any right to challenge it outside the internal legal framework of Twincoin. The platform further acknowledges that its decisions issued in this context aim to preserve the paramount interest of users and the ecosystem, and that such decisions are final and binding and may only be reviewed in accordance with the provisions of the previous article governing the internal grievance system.
Chapter Nine: Data Protection and Privacy
Article Sixteen: Collection and Use of Personal Data
Twincoin collects the essential and necessary data required to operate its services and continuously improve the user experience, including but not limited to:
• Basic Data: Full name, email address, mobile phone number, date of birth, gender, nationality.
• Geolocation Data: User’s current location (with consent), detailed address, city, and region, for the purpose of providing nearby local offers, calculating distances between users and stores, customizing content based on geographic regions, and improving delivery services.
• Device and Usage Data: IP address, device type, operating system, browser used, in-app activity logs, login and logout times, visited pages.
• Transaction and Interaction Data: Purchased offers, earned and spent coins, transaction dates, participated Units, referrals, friend requests, exchanged gift boxes.
Twincoin reserves the right to collect any additional data that may be necessary or beneficial for improving existing services or developing new features and services in the future, such as: personal preferences, interests, purchasing behavior, biometric data (with explicit consent), linked social media data, and any other data that serves the platform’s development.
Collected data is used for the following legitimate purposes: operating core services and managing accounts; processing transactions and tracking coins; analytics, statistics, and behavioral insights; targeted marketing and personalized offers; performance enhancement and feature development; ensuring security and fraud prevention; and compliance with legal and regulatory requirements.
Twincoin may share specific and limited data with Business Partners not only to complete individual transactions but also for broader purposes, including: comprehensive customer behavior analysis, understanding market trends, developing their products and services, improving marketing offers, targeting specific customer segments, measuring campaign effectiveness, and any other legitimate commercial purposes that ultimately serve the users’ interests by improving offer and service quality. Partners are contractually obligated to protect this data, refrain from sharing it with third parties, and use it solely for the specified purposes.
The provisions of this Article are complementary to and interconnected with the Privacy Policy adopted by Twincoin; however, they do not replace or substitute it. The Privacy Policy remains an independent document containing broader details regarding mechanisms of collecting, using, storing, sharing, and processing personal data in accordance with Lebanese law and international standards. Acceptance of these Terms by the user or partner also constitutes explicit and final acceptance of the Privacy Policy and any subsequent amendments thereto.
Article Seventeen: Rights of Data Subjects
All users and Business Partners enjoy clear and defined rights regarding their personal data, with a distinction in how these rights are exercised:
For Regular Users (Twincoin Users):
They have the right to modify their basic personal data directly through the application without submitting a formal request or waiting for approval. This includes: name, date of birth, gender, phone number, email address, personal address, profile photo, and others.
Changes apply immediately upon saving, with no restrictions on the number of edits or the types of data that may be modified (except for the unique account number).
For Business Partners (Twincoin Business Users):
Modifications to sensitive commercial data that may affect platform credibility or user safety require a formal request and approval from the Account Management team. Such data includes: store or brand name, main business address, branch geographic locations, and other similar data.
Regular operational data (e.g., secondary phone numbers, operating hours, business descriptions, images, logos) may be modified directly.
Both users and partners have the right to access all stored data; the right to deletion (subject to legal exceptions regarding accounting and tax data); the right to restrict processing in certain situations; and the right to object to specific processing activities such as direct marketing.
To exercise rights other than direct in-app modifications, a formal request must be submitted via privacy@twincoin.app along with proof of identity. Requests are processed within thirty (30) days. Twincoin also commits to using the latest encryption technologies and security protocols to protect data from unauthorized access, loss, or tampering. Despite these measures, absolute security in the digital environment cannot be guaranteed, and users acknowledge acceptance of these inherent risks.
Excluded from these rights are data relating to cases of platform closure by administrative decision, company liquidation, or bankruptcy, where Lebanese applicable laws shall govern without any additional obligation on Twincoin to fulfill requests for access, correction, deletion, or objection.
Acceptance of these Terms constitutes explicit and prior consent from all users and partners regarding the potential use of photos, videos, or any visual content associated with their activities within the platform, including but not limited to: participation, interactions, or gift collection. Redeemers of gifts remain subject to the provisions of the Article governing media documentation and publication of gift-receipt information as part of the transparency and announcement system. Under no circumstances may users or partners object to such use, request its removal, or demand payment or financial compensation for it.
Article Seventeen (bis): Communication with Users
Upon registering on the platform with their phone number, the user agrees that Twincoin may contact them via WhatsApp or any other communication channel it adopts, to send welcome, introductory, news, or promotional messages relating to the platform, its services, and its partners, as Twincoin deems appropriate in terms of content, timing, and frequency.
The user may at any time request to stop general messages, whether news or promotional, by informing Twincoin in any wording they deem appropriate, through the same channel or through the approved support channels, and Twincoin shall endeavor to act on the request within a reasonable period. The user may also request their reactivation in the same manner. A stop request does not affect the user’s account, balances, or rights within the platform.
Stopping does not cover private messages relating to the user’s account or activities, including without limitation: notifications of obtaining a gift or reward, gift delivery, account freezing or restriction, information verification, and any matter affecting the account, its balances, or its results. The provisions of this Article apply to Business Partners to the extent compatible with the nature of their relationship with the platform.
Chapter Ten: Intellectual Property and Lawful Use
Article Eighteen: Ownership Rights and Content
All intellectual property elements associated with the Twincoin Platform—including, without limitation: registered and unregistered trademarks, trade names, logos, visual and graphic designs, software code and source code, algorithms, databases, textual, visual, and audio content, interfaces and user experience, the distinctive mark No. 230003, trade secrets, and any future innovations or developments—are the exclusive and absolute property of Fratiro (Simple Limited Partnership), and are protected under Lebanese laws and relevant international conventions. Any content recorded or filmed during the gift-delivery process is also considered part of these rights and grants Twincoin the perpetual right to use, publish, or redistribute such content by any means it deems appropriate.
Any content uploaded, published, or displayed by the Business Partner through the platform—including without limitation: photographs, advertising texts, videos, logos, trademarks, advertisements, commercial descriptions, price lists, or any other materials—constitutes a perpetual, worldwide, royalty-free, non-exclusive, irrevocable, and sublicensable legal license granted to Twincoin. This license authorizes Twincoin to use such content for any operational, commercial, marketing, or promotional purpose, including copying, modifying, merging, publishing, distributing, publicly displaying, and reusing it through any existing or future medium, without any obligation to notify the partner, obtain further consent, or pay compensation.
Users and Business Partners are granted a limited, non-exclusive, non-transferable, non-assignable license to use the platform and its services solely for lawful purposes and in accordance with these Terms and Conditions. This license does not include any right to: resell, copy, distribute, modify, create derivative works, attempt reverse engineering, decompiling, analyzing the code, or attempting unauthorized access to Twincoin’s data or systems. Any violation of this shall constitute a serious breach warranting termination of the contractual relationship, confiscation of balances, and referral of the violator to the competent authorities when necessary.
By accepting these Terms and Conditions for using the Twincoin Platform, every user and every Business Partner hereby makes a final, conclusive, irrevocable, and unconditional acknowledgment that this obligation becomes effective immediately upon registration or use, and remains valid indefinitely—even after termination of the relationship with the platform—to refrain from using the name “Twincoin”, “Twinkey”, “Fratiro”, or any of their translations, forms, variations, distortions, or phonetic or written similarities in any language (Arabic, English, French, or otherwise), in any commercial, civil, or digital use, whether existing or potentially future. This includes, without limitation:
• Naming any commercial activity of any size (company, establishment, store, kiosk, etc.)
• Registering a company, association, or organization under any legal form
• Registering a trademark, trade name, or logo in any country or organization
• Launching a product, service, application, software, or website
• Registering any electronic domain (Domain) under any extension (.com, .net, .org, .app, etc.)
• Creating an account or page on any social media platform or digital service
This commitment remains legally binding even if Twincoin is not registered in the category, field, or country subject to the dispute.
Any violation of this clause constitutes a material breach that results in direct legal liability for the violator and grants Twincoin the right to claim an initial and immediate compensation of not less than one hundred thousand U.S. dollars (USD 100,000) for each violation, in addition to requiring the violator to cease the unlawful use immediately, change the name or mark, and bear all legal and judicial costs, including attorneys’ fees, experts, and consultants. Any illegally registered rights or records shall be transferred to Twincoin immediately and unconditionally.
Twincoin reserves the right to monitor any content posted on the platform by users or partners, and to remove it immediately if it is unlawful, infringes intellectual property rights, harms the platform’s reputation or its audience, or violates the Terms—without prior notice or any obligation to compensate the violating party. This right constitutes a preventive measure to protect the integrity and continuity of the platform.
Chapter Eleven: Liability and Disclaimer
Article Nineteen: General Limitations of Liability
Twincoin’s services are provided “As Is” and “As Available,” without any express or implied warranties of any kind. Twincoin does not guarantee that the services will be uninterrupted, error-free, absolutely secure, or that they will achieve the desired results from their use. Any reliance on the platform or its content is entirely at the user’s own risk.
Under no circumstances shall Twincoin be liable for any direct, indirect, incidental, consequential, special, or punitive damages, including but not limited to: loss of profits, loss of data, business interruption, reputational harm, or any other economic losses, even if Twincoin has been advised of the possibility of such damages.
In all cases, and regardless of the legal basis of the claim, the maximum liability of Twincoin toward any user or partner shall not exceed the total amount actually paid by that party directly to Twincoin during the twelve (12) months preceding the event giving rise to the claim.
Article Twenty: Indemnification and Hold Harmless
Each user and each Business Partner agrees and undertakes, individually and separately, to indemnify, defend, hold harmless, and release Fratiro (Simple Limited Partnership) (the exclusive owner and sole operator of the Twincoin Platform), along with its directors, shareholders, employees, agents, advisors, partners, and contractors, from and against any and all claims, actions, liabilities, damages, losses, costs, expenses, and fees (including but not limited to attorneys’ fees, experts’ fees, and consultants’ fees) arising from or related to:
• Their use or misuse of the platform or its services
• Their breach or violation of any provision of these Terms and Conditions
• Their violation of any third-party rights, including intellectual property or privacy rights
• Any content, information, or data they submit or upload through the platform
• Impersonation of Twincoin or any of its employees or representatives
• Use of Twincoin’s name, logo, or identity to deceive or defraud others
• Defrauding individuals locally or globally using the platform’s name
• Falsely claiming official representation or partnership with Twincoin without authorization
• Any false statements, defamation, or reputational harm to the platform
• Publishing misleading or false information about Twincoin or its services
• Attempting to extort the company or its employees in any manner
• Causing confusion or public disruption through media or social platforms
Indemnification covers all legal costs, material and moral damages, reputation-repair expenses, and any direct or indirect losses. Twincoin retains the absolute right to claim additional compensation for any harm caused to its reputation or commercial standing as a result of the actions of the user or partner, and reserves the right to pursue criminal proceedings if such actions constitute an offense.
This indemnification obligation remains in effect even after termination of the relationship with the platform and includes the costs of legal defense even if the allegations are ultimately unproven, so long as the claim arose from the actions of the indemnifying party.
Chapter Twelve: Third Parties and External Services
Article Twenty-One: Relationship with External Service Providers
Twincoin may, from time to time, rely on fully independent third parties to provide supporting or complementary services, including but not limited to: electronic payment processing, delivery and shipping services, cloud hosting, analytics and statistics tools, or any other auxiliary services deemed necessary for the operation and continuity of the platform. These parties are independent entities, not bound to Twincoin by any agency, partnership, or legal affiliation, and Twincoin assumes no direct or indirect responsibility for their actions, negligence, errors, or service-related failures. Any dispute related to their services must be resolved directly with those parties according to their own terms and conditions.
Once any gift, shipment, or official document is handed over to the delivery company or any approved third party, full responsibility for the condition of the gift or service transfers to that party, and Twincoin shall be deemed to have fully fulfilled all of its obligations toward the user or Business Partner with respect to that service.
The platform or its website may also contain links or references to websites, services, or applications belonging to external parties. These links do not constitute, in any way, an endorsement, recommendation, or assumption of responsibility by Twincoin. Users and partners acknowledge that accessing or interacting with such links or parties is entirely at their own risk, and that the protection and confidentiality of data are governed exclusively by the privacy policy of those external links. Twincoin disclaims all responsibility for any damages, liabilities, or claims arising from the use of or reliance on those websites or services.
Users and partners further acknowledge that certain essential platform services may require the sharing of limited and strictly necessary data with third parties—such as name, identification number, payment information, or delivery details—solely to the extent required to complete the requested service. Use of the platform constitutes prior and binding acceptance of such data sharing as required under Lebanese law and international data-protection standards.
Chapter Thirteen: Financial and Tax Provisions
Article Twenty-Two: Financial Transactions and Invoicing
All financial transactions conducted through the platform shall be executed exclusively in Lebanese Pounds (LBP) or United States Dollars (USD), in accordance with the exchange rate or pricing mechanism adopted and determined by Twincoin at the relevant time. Invoices shall be issued exclusively in the name of Fratiro (Simple Limited Partnership), the owner and operator of the platform, and shall include all legal and tax information and details required under applicable Lebanese laws. Prices announced through the platform are subject to change as the platform grows, must always be confirmed with the Sales Team, and are deemed free of any additional taxes or fees unless explicitly stated otherwise in the invoice or offer.
Business Partners are fully and irrevocably obligated to pay all taxes, fees, and penalties imposed by Lebanese laws or competent authorities in connection with their activities, sales, and transactions conducted through the platform, and they acknowledge that Twincoin bears no direct or indirect responsibility for such obligations. Should Twincoin incur any tax or financial obligations as a result of an error, negligence, or failure by the Business Partner, the latter shall be obligated to compensate Twincoin fully and immediately for all amounts paid, including any associated fines, interest, or additional charges.
All executed payments are considered final, binding, non-cancellable, and non-refundable in any form or under any circumstances, except in cases where a technical error or material malfunction originating solely from Twincoin’s systems is proven, or where these Terms and Conditions explicitly allow for refunds. Such cases shall be handled at Twincoin’s sole discretion and as it deems appropriate, and its decision in this regard shall be final and non-appealable.
The paying party alone shall bear all banking fees, transfer commissions, or any additional financial charges imposed by payment service providers, banks, or transfer companies, and Twincoin assumes no obligation to cover or refund these charges under any circumstances.
Chapter Fourteen: Future Development and Innovation
Article Twenty-Three: Technical Updates and Growth Prospects
Twincoin reserves its full and absolute right to develop, launch, and test innovative technologies, services, and products that enhance the user experience and expand the scope of available services. Potential future developments may include, by way of general reference and not limitation: advanced technological solutions that leverage the latest global innovations in financial technology and e-commerce; intelligent systems based on modern technologies for content customization; emerging technologies aligned with future legal and regulatory developments; in addition to other unspecified innovations that may arise with the evolution of technology and the market.
Continued use of the platform shall be deemed implicit and prior consent to benefit from any future developments, updates, or changes, regardless of their nature, without the need for further approval or the right to object. Users and partners retain the right to terminate their relationship with the platform if they do not agree with such new developments.
Users and partners also commit to regularly updating the applications and systems associated with the platform and acknowledge that any malfunctions, issues, losses, or security breaches arising from failure to install these updates shall fall solely under their own responsibility, without Twincoin incurring any legal or financial liability for such consequences.
Chapter Fifteen: Termination, Bankruptcy, or Liquidation
Article Twenty-Four: Voluntary Termination of the Platform
Twincoin reserves its full and absolute right, at its sole and non-reviewable discretion, to suspend or shut down the platform, in whole or in part, at any time it wishes and for any reason it deems appropriate to achieve its strategic or operational interests, including but not limited to: major strategic adjustments, urgent technical circumstances, or requirements of service restructuring or development.
In the event an administrative decision is made to shut down the platform, all users and partners acknowledge in advance that Twincoin bears no legal or financial obligation to compensate them for unused balances of Gold or Silver Coins, or for subscriptions or services not yet rendered. Continued use of the platform prior to the shutdown date shall constitute final and binding acceptance of this condition, without any right to objection or appeal.
However, Twincoin may, at its absolute and sole discretion, grant a transitional period with prior notice to users and partners, enabling them, to the extent possible, to settle ongoing commitments or benefit from available services before the final shutdown date. Such notice, if issued, is a purely discretionary gesture and does not create any additional obligation upon Twincoin.
Article Twenty-Five: Bankruptcy or Liquidation
In the event that Fratiro (Simple Limited Partnership)—the owner and operator of the Twincoin platform—is subjected to any bankruptcy proceedings, liquidation, or full cessation of business for any reason whatsoever, whether by judicial or administrative decision or due to force majeure, all user and Business Partner accounts, as well as all subscriptions, services, and balances of Gold Coins, Silver Coins, or any other units registered under their accounts within the platform, shall be deemed automatically null and void with immediate effect, and shall not, under any circumstances, be subject to claim, refund, or compensation.
All users and partners acknowledge, by accepting these Terms and Conditions, that Gold Coins, Silver Coins, and all other units are internal digital loyalty units, non-monetary in nature, do not represent real currency, financial assets, or financial obligations on Twincoin or its owning company, and may not under any circumstances be considered deposits, debts, or financial instruments collectible from third parties.
Bankruptcy or liquidation of the company shall not result in any legal, financial, or compensatory obligation upon Twincoin, its management, representatives, or shareholders toward users or partners for any balances, subscriptions, or unrendered services. This condition is considered an essential and fundamental part of the contractual relationship governing the parties.
Chapter Sixteen: Final Provisions and Governing Law
Article Twenty-Six: Governing Law and Judicial Jurisdiction
The ordinary courts of Beirut shall have exclusive and final jurisdiction to hear and adjudicate all disputes, claims, and demands arising from or relating to these Terms. All parties expressly and irrevocably waive any right to file a lawsuit or claim before any other court or judicial authority inside or outside Lebanon.
All parties further undertake to exert good-faith efforts in attempting to resolve any dispute or disagreement amicably within thirty (30) days from the date of notifying the other party of the dispute, through the officially designated channels, including communication via legal@twincoin.app.
It is strictly and indivisibly prohibited to initiate any collective or representative lawsuits or claims against Twincoin or its owning company. All claims and lawsuits shall be strictly individual in nature and shall be filed and pursued independently by each affected user or partner.
If any provision of these Terms and Conditions is deemed invalid or unenforceable, in whole or in part, for any reason whatsoever, such invalidity shall not affect the validity or enforceability of the remaining provisions, which shall remain fully effective and binding upon all parties.
Article Twenty-Seven: Amendments and Notifications
Twincoin reserves its absolute and final right to amend or update these Terms and Conditions or the Privacy Policy at any time it deems appropriate. Users and partners shall be notified of any amendments through the officially designated channels, including application notifications, the email address associated with the account, social media pages, or messaging and communication groups. Amendments shall take effect automatically upon publication or on a later date specified by Twincoin. Continued use of the platform after any amendment constitutes explicit and binding acceptance of all new Terms. Claims of lack of knowledge or awareness are invalid so long as notification was issued through the channels specified in this Article.
All legal notifications and communications shall be considered valid and binding if sent to the officially registered email address on the account, through internal application notifications, or through social media and communication channels, applications, and groups. Users and partners are responsible for regularly updating their contact information and ensuring its accuracy. Any notification sent to the registered information in the system shall be considered valid and legally effective even if it was not opened or responded to. If contact information is changed without informing Twincoin in writing and having it formally approved, all notifications sent to the previous information shall remain valid and produce full legal effect.
The official announcement of Unit box results or the names of redeemers or their box numbers—whether through the platform, official media channels, or approved social media and communication platforms and groups—shall constitute a valid and binding legal notification with full effect, without the need for any additional individual notice. No redeemer or user may claim lack of awareness or challenge the validity of the result so long as the announcement was made through the methods specified above.
All parties are obligated to respond to notifications requiring action or correction within no more than five (5) business days from the date of sending, unless Twincoin specifies a different deadline in the notice itself. Failure to respond or remedy within the required timeframe grants Twincoin the right to take any appropriate legal or technical measure, including suspending or permanently terminating the account.
This Article constitutes a procedural and legal safeguard preventing any claim of lack of awareness or delay in communication. All parties acknowledge that notifications issued pursuant to this Article carry full legal force and produce their effects upon the expiry of the specified deadlines, without the need for any additional action.
Article Twenty-Eight: General and Final Provisions
These Terms and Conditions, in their entirety, constitute the final and binding legal framework governing the relationship between Twincoin on one side and users and partners on the other. Any ambiguity or uncertainty shall be interpreted in light of its core purpose of ensuring transparency, protecting integrity, and maintaining the legal stability of the platform. Twincoin’s failure or delay in exercising any of its rights, or its leniency in enforcing them, shall not be construed as a waiver or relinquishment of those rights, nor shall it relieve the other party of its essential obligations.
If any clause of these Terms is deemed invalid or unenforceable for any legal reason, such invalidity shall not affect the remainder of the provisions, which shall remain fully valid and binding. The invalid clause shall be treated as if it never existed, without affecting the core nature of the contractual relationship or the parties’ obligations.
Users and Business Partners are strictly prohibited from assigning or transferring any of their rights or obligations, in whole or in part, to any third party without prior explicit written approval from Twincoin’s Legal Department. Any assignment in violation of this prohibition shall be deemed null and void. Conversely, Twincoin reserves its absolute right to assign or transfer, in whole or in part, any of its rights or obligations to any subsidiary, strategic partner, or legal or administrative successor—whether through merger, acquisition, restructuring, or any other legal process—without requiring additional consent from users or partners, provided that essential contractual obligations continue to be fulfilled.
With regard to force majeure, all obligations of Twincoin are temporarily or permanently suspended upon the occurrence of extraordinary events or circumstances entirely beyond its control, including but not limited to: natural disasters such as earthquakes, floods, and hurricanes; large-scale fires; wars, armed conflicts, or security unrest; sudden governmental decisions or binding judicial orders; widespread outages of essential services such as electricity or internet; global or local pandemics or epidemics; large-scale cyberattacks; or any similar circumstances that render contractual performance impossible or impracticable. Suspension of obligations under such conditions is legally justified and shall not entail any liability, penalty, or compensation of any kind toward users or partners. The end of the force majeure event does not automatically create any right to claim compensation for services not performed during its duration; rather, the contractual relationship resumes from the point at which it was suspended, as Twincoin deems technically and administratively feasible. If force majeure persists or becomes a permanent impediment to the continuation of operations, Twincoin may then terminate the contractual relationship or shut down the platform, in whole or in part, pursuant to the provisions on termination, bankruptcy, or liquidation, without any additional liability. This clause is considered an essential and fundamental part of the contract, and all parties expressly agree that force majeure events are unpredictable and uncontrollable, and that their effects exempt Twincoin from any liability or compensation as long as they remain beyond the company’s reasonable control.
Final Acknowledgment
By accepting these Terms and Conditions, the user or Business Partner hereby makes a final, conclusive, irrevocable acknowledgment that:
• They have reviewed this document in its entirety, read all its provisions carefully, and fully understood its contents and implications.
• They possess full legal capacity to contract and undertake obligations.
• They have voluntarily and of their own free will—without any coercion or misrepresentation—agreed to all provisions, obligations, and conditions contained herein.
• They fully understand that these Terms and Conditions constitute a binding and enforceable contract before the Lebanese courts, and that any breach thereof entails direct legal liability.
Copyright Notice
© 2026 Fratiro (Simple Limited Partnership). All Rights Reserved.
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Version: 1.1
Release Date: 01/11/2025
Last Update: 01/10/2026
Official Language: Arabic