Stock Shark – an investment game with virtual money

The Game

1. The game “Stock Shark 2026” (hereinafter “the game”) allows players to virtually invest in US stocks and crypto assets, thereby gaining practical knowledge and experience of investing.
2. The game runs from February 17, 2026, to April 17, 2026 (at 11:00 PM). Registration is open from February 6 until the end of the game. All individuals who are at least 13 years old at the time of registration can participate.
3. At the beginning of the game, the virtual portfolio (hereinafter “portfolio”) contains 25,000 United States (US) dollars of virtual money. A player may only register one game account.
4. The winner is the player whose portfolio has the highest market value as of 11:00 PM (Estonian time) on April 17, 2026. Only the portfolio associated with a player’s single registered account will be considered. If a player has multiple accounts and/or portfolios, AS LHV Pank (hereinafter LHV) and/or Stock-Trak Inc (hereinafter the Platform Organizer) may delete such accounts and/or portfolios at their discretion without prior notice.
5. The game is organized by LHV in cooperation with the Platform Organizer. Registration information is available on the LHV website at www.lhv.ee/en/shark, and the game takes place on the Platform Organizer’s environment at www.stocktrak.com/.
6. By joining the game, the player confirms that they:
   • will provide correct and factual data upon registration;
   • have reviewed and agree to the terms and conditions of LHV and the Platform Organizer (available on the LHV website www.lhv.ee/en/shark);
   • agree that the Platform Organizer may make its terms and applications (including customer support) available in English. The player confirms that they have a sufficient understanding of the English language.
   • agree that LHV and the Platform Organizer will display advertisements and marketing messages in the game, including offers and notifications about products and services.

Participation and Registration

1. The game is open to anyone who is at least 13 years old at the time of registration and who agrees to the terms of LHV and the Platform Organizer.
2. Employees of AS LHV Group and their family members may participate in the game but are not eligible for prizes. LHV-related employees are marked accordingly on the leaderboard.
3. To participate, you must register for the Börsihai game, agree to the terms, and create a game portfolio with USD 25,000 of virtual money. A player can make a total of up to 10,000 transactions during the game.

Leaderboard

1. The game’s standings can be monitored in real-time in the Platform Organizer’s game environment.

Making Transactions

1. Virtual transaction orders can be placed in the game environment on the Platform Organizer’s website, www.stocktrak.com/.
2. The game environment is available in Estonian and English.
3. Players can place limit and market price orders. It is also possible to use a stop order, which becomes a market order upon activation.
   1. A limit order can be modified and canceled. If a limit order is not filled during the market day, it will be automatically canceled on the next market day.
4. Transaction orders can be entered 24/7.
5. When placing an order, a sum of money is reserved in the player’s virtual account using the last available stock price in the system at that moment.
   1. The weight of a single position may not exceed 20% of the total portfolio value.
   2. In the case of short selling, a sum of money equal to 50% of the market value of the position being opened is similarly reserved in the player’s virtual account.
6. The virtual transaction fee in the game is 0.1% of the transaction amount.
7. Market orders for the US market are executed immediately, and the exact purchase price of the stock is displayed on the account approximately 15 minutes after the order is filled. Stocks can be sold immediately after purchase if desired. There is no price delay for crypto assets.
8. Limit orders for the US market are filled when the limit price matches the price of the last transaction.
9. A limit order may be placed on hold if it cannot be filled due to market conditions.
10. If the last price of a stock is missing, the order will remain pending until the end of the day and will be canceled if a last price does not become available.
11. On US markets, both buy and sell transactions are executed at the last available price.

Schedule of Operations

1. Stocks can be traded on business days during official US stock market hours, from 4:30 PM to 11:00 PM (Estonian time). Crypto transactions can be made 24/7, including on weekends.
2. Orders entered after the daily deadline will be deferred to the next trading day.
3. Stocks in the portfolio will be revalued the following morning based on the closing prices of the previous trading day.
4. The portfolio’s market value is calculated based on the market value of the assets and the net balance of available cash in the game account at that time.

Trading Restrictions

1. Trading is available for stocks listed on US exchanges and the 100 most-traded crypto assets, with the following exceptions:
   • stocks with a price below 5 US dollars at the time of the transaction in the game;
   • ETFs or any other exchange-traded funds listed on US exchanges to which access is restricted in the EU.
2. LHV and/or the Platform Organizer reserve the right to modify the list of securities later.
3. Transactions that would not be possible in real life (e.g., buying or selling a suspended stock) are prohibited, and LHV and/or the Platform Organizer have the right to cancel them. Transactions related to abnormal market prices will also be canceled.
4. Market manipulation to gain a better position is prohibited.

1. The game’s monetary prizes are exclusively for players in the following age groups and are distributed as follows:
   1. Grand Prize – EUR 5,000 for the player whose portfolio has the highest market value as of 11:00 PM on April 17 2026.
   2. Youth Prize – EUR 2,000 for the player aged 13 to 25 (inclusive) whose portfolio has the highest market value among players in that age group as of 11:00 PM on April 17 2026.
   3. Additional prizes from partners will be listed on the Stock Shark homepage lhv.ee/en/shark.
2. If a young player (13 to 25 years old) achieves the best overall result and wins the grand prize, the youth prize will be awarded to the next-best performing young player. The winner will be announced no later than one week after the game ends. LHV will contact the prize winners within one week after the game ends. Prize money will be paid out within 14 days after the game ends.
3. The player’s age is fixed at the time of registration. If the player ages during the game, no adjustments will be made to their prize category eligibility.
4. Best of the Week Prizes
   1. EUR 250 to the player who increases their portfolio’s market value the most during each calendar week. This prize is awarded for the first seven weeks of the game.
   2. EUR 75 to the young player (13 to 25 years old, inclusive) who increases their portfolio’s value the most during each calendar week. This prize is also awarded for the first seven weeks of the game; no weekly prize will be given for the final, eighth week.
   3. All adult players will receive a EUR 10 credit on their Growth Account when opening it for the first time using a promo code.
5. If a young player wins the weekly prize mentioned in point 7.4.1, the prize mentioned in point 7.4.2 will be awarded to the next-best performing young player. The player’s age is fixed at the time of registration.
6. The player who increases their portfolio’s market value the most each week will receive a copy of the book “Minu Wall Street - USA börsist eesti aktsendiga” with the author’s dedication.
7. To receive prize money, a personal LHV current account is required. For minors, the account must be opened in the minor player’s name. The Growth Account promo code can only be used by adults. The market values of crypto assets in the portfolio are fixed on Mondays between 5:00 AM and 7:00 AM (Estonian time). If a player makes a crypto transaction during this period, the Platform Organizer and/or LHV may not consider these transactions when determining the portfolio’s market value.

Player Rights and Obligations

1. In case of misunderstandings or problems, players have the right to contact LHV at info@lhv.ee and/or through the Börsihai Facebook page. For technical questions regarding the platform’s functionality or transactions, players can also contact the Platform Organizer’s customer support via the chat window in the game environment. The Platform Organizer’s customer support communicates in English.
2. Players must act in accordance with the game rules and the principles of fair play.
3. Disputes over possible violations of the game rules will be resolved by LHV at its discretion.
4. Players must register for the game with their real first and last names.
5. If a player registers with a false name or other incomplete information, LHV or the Platform Organizer has the right to immediately remove the player from the game and cancel and/or delete the player’s rights (including in relation to their user account, results, and prizes).
6. The player’s username and team name can be freely chosen but must not violate good morals and customs. LHV will make a decision on any potential violations at its own discretion, and LHV and/or the Platform Organizer have the right, among other things, to immediately remove such a player from the game and cancel and/or delete the player’s rights (including in relation to their user account, results, and prizes).
7. By registering, the player gives LHV the right to publish their first and last name, username, and portfolio name, along with the portfolio’s contents and transactions. The player is aware that their personal data will be processed in accordance with LHV’s Customer Data Processing Principles. The portfolio data of the top 50 participants might be published on the LHV website until the following year’s game.
8. The game winner is obligated to participate in an interview organized by LHV. If the winner refuses the interview, LHV has the right to withhold the prize money until the interview takes place.

Organizer’s Rights, Obligations, and Liability

1. LHV and/or the Platform Organizer have the right to make changes and additions to these rules and conditions, with notification provided in the game environment.
2. LHV and/or the Platform Organizer may change and supplement the price basis for making transaction orders, the price basis for portfolio revaluation, and the list of tradable stocks in the game.
3. LHV and/or the Platform Organizer have the right to remove a player who has violated the rules from the game and to cancel and/or delete all of the player’s rights (including in relation to their user account, results, and prizes).
4. LHV and/or the Platform Organizer are not responsible for incorrect or inaccurate information, whether caused by the actions of a game participant, information provision, or technical or human errors in programming that interfere with the game’s execution.
5. LHV and/or the Platform Organizer are not liable for the consequences of errors, failures, interruptions, deletions, operational or communication delays, communication failures, or unauthorized access within the game. If an order is not transmitted and/or filled due to these factors, LHV and/or the Platform Organizer may not make subsequent corrections to that order.
6. LHV and/or the Platform Organizer are not liable for the non-functioning of telephone networks or lines, computer networks, or other systems, nor for consequences arising from the non-functioning of computers, software, email, or internet connections.
7. LHV undertakes to respond to any obstacles that arise and to do its best to resolve them.
8. If the game is interrupted due to technical problems, LHV and/or the Platform Organizer will not allow additional or delayed execution of transaction orders.

Controller and Processor

1. The controller of personal data for the game “Börsihai 2026” is AS LHV Pank (registry code 10539549, Tartu mnt 2, Tallinn).
2. The technical platform of the game is administered by Stock-Trak Inc. (Platform Organizer), who acts as a processor on behalf of AS LHV Pank and processes personal data solely in accordance with LHV’s instructions and to the extent necessary for the functioning of the game.
3. The Platform Organizer is an independent controller with regard to the processing of users’ personal data for the purposes of platform administration, including ensuring security and fulfilling legal obligations related to the Platform.
4. Cookies are used in the Platform Organizer’s web environments https://sims.stocktrak.com/borsihai/ and https://app.stocktrak.com. Information about the cookies used is available in the Platform Organizer’s Privacy Policy. The Player may withdraw consent to cookies at any time by changing cookie settings or by deleting stored cookies in the web browser settings. Please note that deleting cookies may affect the functioning of the website.

Purpose of Processing Personal Data

1. AS LHV Pank processes players’ personal data for the purpose of conducting the game, including:
   • registering and identifying players;
   • calculating game results and compiling the leaderboard;
   • determining winners and paying out prizes;
   • ensuring fairness of the game and compliance with the rules.

Personal Data Processed

1. Within the framework of the game, the following personal data of the player are processed:
   • first and last name;
   • email address;
   • username;
   • age group (13–17, 18–25 or 26+);
   • data related to the player’s account and portfolio.

Special categories of personal data are not processed.

Legal Basis for Processing Personal Data

1. The legal basis for processing personal data is the performance of a contract, under which the processing of data is necessary for conducting the game in accordance with the game rules.

Retention of Personal Data

1. AS LHV Pank retains players’ personal data during the game and after the end of the game for as long as necessary to fulfil rights and obligations related to the game, resolve disputes, and comply with legal obligations.
2. The first and last name of the winner of the game will be published on LHV’s website and retained as part of the historical information of the game. In addition, in accordance with the game rules, LHV may publish the first and last names and portfolio data of up to 50 best players on LHV’s website until the next game takes place.