Top of Rules
Bottom of Rules


NO PURCHASE NECESSARY TO ENTER OR WIN THIS CONTEST. A PURCHASE DOES NOT INCREASE OR IMPROVE YOUR CHANCE OF WINNING. The Vestly™ Weekly Investing Game Contest (“Contest”) is a promotion open to all legal residents of the 50 United States and the District of Columbia who have reached at least 18 years of age and the age of majority in their state of residence. The Contest consists of two separate promotions: the Skills Contest and the Prize Drawing (both, as defined below). All federal, state, and local laws apply. Void where prohibited.  Contest sponsored by Intelligration LLC, 1732 1st Ave #29598, New York, NY  10128 (“Sponsor”). The Contest begins at 12:01 am Eastern Standard Time (“EST”) on 6/7/2021 and ends at 11:59 pm EST on 6/13/2021 (the “Contest Period”). Employees, officers, directors of Sponsor and their immediate families are not eligible to participate in the Contest.  To be eligible to win a prize in the Contest, an individual must follow the entry steps detailed below and have a valid email address connected to their Facebook profile or Apple account.  


To Enter:  Participants must download the free Vestly™ app or access the Vestly™ game online (collectively the “Vestly™ Game”) from participating platforms and services.  For a complete list of participating platforms please visit  Participants will then register and sign into the Vestly™ Game through: (1) their Facebook account, (2) sign in with Apple, or (3) in the future (at the sole discretion of Sponsor) through e-mail or phone number registration.  Sponsor may also provide an alternate method for registration if Facebook or sign in with Apple becomes unavailable (or at the sole discretion of Sponsor, if it becomes incompatible with the Vestly™ Game in any manner).  It is free for participants to download or play the Vestly™ Game and to join Facebook or sign up for an Apple account.  Once you have successfully signed onto the Vestly™ Game, you will be able to participate in the Contest.  By entering the Contest, participants agree to waive any right to claim any ambiguity or error in these rules, or the Contest itself, and agree to be bound by these rules and by all decisions of Sponsor, which are binding and final. Failure to comply with these rules may result in disqualification from this Contest.   Vestly™ is not associated with Apple, Inc., Google Inc., or Android. Apple, Inc., Google Inc., and Android are not a sponsor of, or involved in any way with Vestly™ contests and the prizes are not Apple, Google or Android products.

For every five hundred (500) points a Participant earns in the Contest Period, the Participant will receive one (1) entry in the Prize Drawing (for example, if Participant receives 1001 points in a particular Contest Period they will get 2 entries in the Prize Drawing).  To be deemed valid, entries must be fully and accurately completed in accordance with the requirements imposed in these Official Rules and in the Vestly™ Game.  Sponsor is not responsible for lost, late, incomplete, incorrect, damaged, or misdirected entries or prize claims. Sponsor is further not responsible for problems of any kind related to the Contest or the Vestly™ Game, whether mechanical, electronic, or human.  Any attempt to make more than the stated number of entries by using multiple accounts or by any other method may void all entries from that participant.

Entry may require an existing Facebook or Apple account, or signing up for an account through Facebook or Apple, and logging into Facebook or Apple through the Vestly™ Game. As of the start of the Contest there is no charge to download the Vestly™ Game, or for an account on Facebook or Apple.  The Contest is conducted and hosted solely on Sponsor’s app, and is in no way sponsored, endorsed, or administered by, or associated with Facebook or Apple.  All information provided by participant is provided to Sponsor and not Facebook or Apple.  Participant hereby releases and holds harmless Facebook and Apple from any liability or claims arising from the Contest, use of the Vestly™ Game, and/or the receipt or misuse of any prize.

Skills Contest

How to Play: Once participants have successfully logged into the Vestly™ Game, they can begin to participate in the Skills Contest.  Participants can earn points by buying and selling stocks, and through other incentives offered by Sponsor.

Upon their first login to the Vestly™ Game, participants will be given a starting “investment capital” that can be used to buy and sell certain publicly traded stocks listed on the U.S. exchanges, which are provided by Sponsor.  All participants start with the same amount of investment capital. The amount of investment capital is not quantified, and stocks are not bought and sold in terms of “shares” or dollar values.  Participant’s portfolio is measured by the performance of the stocks they choose to trade.  Trades may be made by purchasing a stock or shorting a stock.  For stocks that trade infrequently, the trade will be executed on Vestly at the time it gets executed next on the actual stock exchange.  The order is only valid for the rest of the trading day so that if there are no trades in that stock on the actual stock exchange for the remainder of the trading day, then the order on Vestly is cancelled.  Orders entered after trading hours will be honored at the Open Price on the next trading day.

In order to be deemed an “Active Investor,” a participant must have logged onto the Vestly™ Game at least one time over the course of the current or previous Contest.  If participant has an existing Vestly™ account from a previous Contest Period and is an Active Investor, their starting portfolio for the next Contest Period will consist of the same stocks held at the conclusion of the previous Contest Period; these stocks will be automatically traded in equal proportions at the beginning of the Contest Period and the opening market price on the first trading day of the week will be used as the trade price for the purposes of the Contest Period.  However, there are some stocks which may be deemed illiquid (based on a combination of trading price, trading volume, and market cap during the most recent period).  In the event that a stock in a participant’s portfolio contains stocks deemed illiquid by the Sponsor, those stocks will not be carried forward to the participant’s next week’s portfolio.  

Participant’s investment capital is used to pay for trades of stock.  In addition to traditionally buying a stock and then selling it, participants may also “short” stocks by selling them first and then buying them back. When a participant trades a new stock, the corresponding amount of investment capital is removed from their account and the remaining investment capital becomes “unallocated capital.”  The amount of unallocated capital used to trade stocks is performed automatically and participants cannot trade more or less than this amount.  The mechanisms by which stocks are traded in the Skills Contest are described below:  

When participant holds no stocks (“holds” refers to a long or short position) and trades their first stock, 1/3 of their investment capital is used to trade the stock and the remaining 2/3 of the unallocated capital is held in reserve. If participant holds one stock, when they trade a second stock 1/2 of the unallocated capital is used to trade the second stock.  If participant holds two stocks, when they trade a third stock the entirety of the remaining unallocated capital is used to trade the third stock.  If participant holds three or more stocks they do not have any remaining unallocated capital and the overall value of the portfolio is used to determine the amount of any subsequently traded stock because equal portions of their existing holdings are traded to pay for the new trade.  When participant trades a fourth stock the amount traded is equal to 1/4 of the overall value of participant’s portfolio at the time of the trade; when participant trades a fifth stock the amount traded is equal to 1/5 of the overall value of participant’s portfolio at the time of the trade; when participant trades a sixth stock the amount traded is equal to 1/6 of the overall value of participant’s portfolio at the time of trade, etc.  To pay for the trades of stocks when participant holds three or more stocks, an equally proportionate amount is “sold or covered” from the stocks participant is holding to pay for the trade of the new stock.  For example, for the trade of a fourth stock 1/3 of the trade value of the new stock is “sold or covered” from each of participant’s three held stocks; for the trade of a fifth stock 1/4 of the trade value of the new stock is “sold or covered” from each of participant’s four held stocks.

When participant holds three or fewer stocks and trades one of those stocks, the proceeds from the trade become unallocated capital.  When participant holds four or more stocks and trades one of those stocks, the proceeds from that trade are automatically used to trade more of each of participant’s remaining holdings in an equal amount.

The amount of stock traded by participant is dependent upon their investment capital and other holdings.  When participant elects to trade a stock they must trade all of that particular stock.  Participants cannot alter the amount of stock they buy or sell.  Dollar values and amounts are not displayed to participant.  Participant’s performance is determined by the performance of a stock during the time it is held by Participant.  

Stock pricing may not exactly correspond to other updates or services due to processing, communication or other factors.  In the event of any discrepancy, the pricing on the Vestly™ Game will govern.  Stocks on the Vestly™ Game will be traded at the price at the time the trade is made by participant, but the details of the transaction will not be available immediately and will be available usually about fifteen or twenty minutes after the trade.   Stocks traded after the market closes will be traded at the opening price the next business day.

Some stocks pay dividends; in the event a participant holds a stock that provides dividends any dividend will be automatically reinvested in such stock provided that participant held that stock in their portfolio prior to the ex-dividend date.  If participant trades a stock on the day of ex-dividend they will not receive any reinvestment of the dividend.  If there is a stock split, merger, acquisition, spinoff, complex dividends or other action determined to be complex by the Sponsor affecting a stock held by participant, the value of the participant’s account will be adjusted accordingly.

Only stocks that appear on the Vestly™ Game will be available for trading and only such stocks will be used to determine participant’s score for purposes of the Skills Contest.  Not all stocks may be available for trading on the Vestly™ Game.  Sponsor is not responsible for stocks not being available on the Vestly™ Game, or lost, incomplete, incorrect or unexecuted trades.  

Participants can hold as many as ten (10) different stocks at one time.  There is no limit on the number of trades participant can make; however, high-frequency trading or similar strategies are not permitted.  Use of scripts, computer programs, macros, robotic or any other automated means are also not permitted. Modification, decompilation or tampering with the Vestly™ Game is prohibited. Communication with Intelligration servers and systems is only permitted via the Vestly™ Game. Sponsor reserves the right to disqualify any participant, or modify or otherwise edit any portfolio in Sponsor’s sole discretion if such participant is deemed to have engaged in any action not permitted by these Official Rules or the Vestly™ Game, or is found by Sponsor to be circumventing the nature of the Skills Contest.  All decisions by Sponsor shall be final.

Points will be allocated by percentage gain of stocks owned or shorted by participant. In the event a participant shorts a stock, the points will flow in the opposite direction.  Participants will receive (or lose) 100 points for each one percent (1%) increase (or decrease) in their portfolio.  Participants can receive points for fractional stock movement (i.e., 2 points for a 0.02% increase).  

Participant is not required to sell or cover their stocks prior to or at the conclusion of the Contest Period.  Participant will receive points for stocks still held in their portfolio at the conclusion of the Skills Contest.  

All decisions regarding points awards and allocation, stock trade and sales, and participant’s accounts will be made by Sponsor in its sole discretion, and all decisions will be made final.  For purposes of Contest Periods the values assigned to stocks in the Vestly™ Game shall govern; stock values based on other trading indices or marketplaces may differ from the Vestly™ Game.  Sponsor reserves the right to adjust the value of any stock or otherwise account for various modifications.  

How To Win: At the end of the Contest Period, participants who are Active Investors will be ranked based on the number of points earned (the “Skills Contest”)The total points awarded each Contest Period will be your score for that Contest Period. Points will only be awarded for actions performed during that Contest Period. There is no limit to the number of points you can receive during the Contest Period. At the beginning of the Contest Period all users will start with zero points, any points accrued in any prior Contest Period will not count towards your point total for the current Contest Period.  The participant with the highest point total during the Contest Period will be the First Place Winner, the second highest total will be the Second Place Winner, and so on.  The prize breakdown is below:

Place Prize
1st $500 
2nd $250 
3rd $100
4th  $50
5th $20
6th-10th $15

Total ARV of all prizes for the Skills Contest for each Contest Period: $1000.

In the event of ties, the prizes for all of the places occupied by the tied players will be evenly distributed amongst the tied players.  Odds of winning depend on the relative skill of participants, relative trading performance, and the number and performance of eligible entries received.  

Random Prize Drawing:

How To Win: At the end of each Contest Period, participants who have logged onto the Vestly™ Game at least once during the Contest Period will earn one (1) entry into the prize drawing (“Prize Drawing”) for completing each of the following items: 

  • For every five hundred (500) points a Participant earned.
  • Completion of your demographic profile during the Contest Period. 
  • Trading your third stock during the week.
  • Opening the Vestly™ Game on three separate days in any one Contest Period.
  • Opting to allow the Vestly™ Game to provide you with push notifications.
  • Answering trivia questions that may be presented by Sponsor.
  • Watching a Vestly video if presented by Sponsor. 
  • Participating and winning a Group Challenge as detailed below.
  • Watching an advertisement if presented by the Sponsor to receive one (1) entry into the Contest Period per ad viewed.
  • Inviting a friend through the mobile application’s “earn tickets” screen if presented by the Sponsor to receive one (1) entry into the Contest Period for each invitee who then installs and registers using the direct invite link supplied by the mobile application.
  • Spinning a wheel within the mobile application that may be presented by the Sponsor to receive entries into the Contest Period based on a fixed and equal probability to land on a winning result for all players.
  • Answering poll questions, surveys or questionnaires when offered by the Sponsor to receive entries into the Contest Period such that all players have an equal opportunity to be awarded the same number of entries.
  • Visiting the Vestly™ Game on multiple consecutive days (e.g. streaks) as announced and if presented by Sponsor, such that all players have an equal opportunity to be awarded the same number of entries for such streaks.

In addition, creating a group that maintains at least 5 active members at the end of the week will result in the award of ten (10) entries into the prize drawing. There is no cap on the number of entries a Participant may receive in the Prize Drawing.  At the end of the Contest Period ten (10) winners will be randomly selected from all the eligible entries in the Contest Period drawing by an authorized representative of Sponsor from all entrants eligible for the Contest Period.  Odds of winning are dependent upon the number of Participants and the number of optional activities each Participant engages in to earn entries.  Winner need not be present at the drawing to win.  

Each winner will receive a $50 gift card or cash equivalent [ARV: $50].  

Total ARV of all prizes for each Contest Period: $1,500.

Group Challenges: In addition to the gameplay described above, Participants may enter up to five (5) additional competitions to compete against groups of other qualified participants (“Group Challenges”) during the course of a Contest Period.  Participants enter a Group Challenge by accepting an invitation from a current participant or creating a new Group Challenge by as described in the Vestly™ Game.  Once a participant has been added to a Group Challenge or created a Group Challenge they may invite others to be a part of the competition by using the designated communication platforms as detailed in the Vestly™ Game.  The Group Challenges must have at least five (5) Participants to receive entries.  Participants will earn points in the Group Challenge the same way that points are earned in the Contest Period.  The participant(s) with the highest number of points in a particular Group Challenge will receive entries into the Prize Drawing as detailed below. 

Group Challenge names are specified by the Participant who creates the Group Challenge.  Group Challenge names will be removed or changed if deemed inappropriate by the Sponsor at Sponsor’s sole discretion.  Participants may invite the same individuals to participate in multiple Group Challenges.   Sponsor reserves the right to remove participants from any Group Challenge if members are not substantially different from other Group Challenges, if a participant is deemed to have engaged in any action not permitted by these Official Rules or the Vestly™ Game, is found by Sponsor to be circumventing the nature of the Contest, or for any other reason at Sponsor’s sole discretion. For a Group Challenge to be deemed substantially different from another, the two groups may share no more than 50% of the same participants.  

To be eligible to be a participant in a Group Challenge and to count toward the total number of players in the Group Challenge, a participant must be an Active Investor.  In the event that a participant in a Group Challenge ceases to be an Active Investor they may be dropped from that Group Challenge at the sole discretion of Sponsor.

Group Challenges participants will receive entries into the Prize Drawing in accordance with the schedule below depending on their placement in relation to the other participants in their particular Group Challenge. In the event of ties, the player(s) awarded the higher number of tickets are those that have been in that Group Challenge the longest since the last time they joined or re-joined.  The number of entries to the Prize Drawing awarded to each Group Challenge will be dependent on the number of Participants in each Group Challenge, as follows:


Group Challenges are limited to 100 Participants.

At the end of the Contest Period, Participants will automatically be enrolled in their current Group Challenges unless during the next Contest Period they choose to leave the Group Challenge group.  Group Challenges restart at the beginning of each Contest Period.  Participants may leave the Group Challenge as described in the Vestly™ Game. 


All prizes for the Contest will be awarded.  No substitution or transfer of prize except at the sole discretion of Sponsor if advertised prize becomes unavailable.  Prizes shall be awarded to the respective winners through a payment method of Sponsor’s choice: Venmo, Zelle, PayPal, gift card or check.  Please note that any payment method other than a check may be subject to additional restrictions or limitations from the relevant gift card or platform, and Sponsor is not responsible for any such restrictions or limitations.  All federal, state, and/or local taxes are the sole responsibility of Winner.  Any and all applicable federal, state, and local taxes and all fees and expenses related to acceptance and use of prize not specifically stated herein are the responsibility solely of Winner.  

Each winner may be required to complete a declaration of eligibility, waiver of liability and publicity release, which must be returned within the time specified or prize award will be void and an alternate winner may be selected from remaining eligible entrants.  

All winners must complete the payout form from Sponsor prior to receiving any prize.  If any form is not filled out in a reasonable amount of time, Sponsor may void such prize award and select an alternate winner.  Prize winners are responsible for all taxes and other expenses in connection with the prizes not specified in the Official Rules. 

Second Chance Drawing:

In the event that any of the prizes in the Contest Period have not been claimed (“Unclaimed Prizes”) within thirty (30) days of the end of the Contest Period, Sponsor will conduct a random drawing of all eligible entrants to give away the Unclaimed Prizes (“Second Chance Drawing”).  To be eligible for a Second Chance Drawing, entrants must have been logged onto the Vestly™ Game in the week the Unclaimed Prizes were awarded.  Each of the Unclaimed Prizes will be awarded.  Winners of Second Chance Drawings will be required to claim their prize within five (5) days of receiving notification that they have won a Second Chance Drawing or they will forfeit their prize and Sponsor will conduct another drawing to give away the Unclaimed Prize.  In the event that the prizes remain unclaimed due to insufficient or non-responsive participants, the remaining prizes will be awarded to a charity of the Sponsor’s choice. 

Conditions: In some instances, entrants may be required to obtain permission of their employer to participate in the Contest; by entering they represent and warrant that they are permitted by their employer and any relevant regulatory body to enter the Contest and have received such permission, if necessary. By participating, winners consent to use of their name, images, likeness, submission for advertising, promotional and publicity purposes in any and all media now or hereafter devised throughout the world in perpetuity, without additional compensation, notification or permission, except where prohibited by law.  

By participating in the Contest, participants understand and consent to Sponsor’s use of the information provided by participant, including their stock trades.  Sponsor may use participant’s information and trading activity to develop algorithms or other automated procedures, build stock portfolios and other financial products and services, among other uses.  By participating, participant agrees and understands and grants Sponsor permission to use its information and activity during the Contest.  For further details of how participant’s information may be used please see the Vestly™ Privacy Policy at, which is incorporated into these rules by reference.

The virtual investment dollars allocated, earned and spent by participant have no cash value and may not be sold assigned or transferred by the participant.  All virtual investment dollars, stock ownership and trades take place solely in the Vestly™ Game for purposes of the Contest, and participant receives no monetary value or stock ownership through their participation in the Contest.  All determinations regarding investment dollars, stock value, trade value, stock ownership, and participant’s accounts shall be made in Sponsor’s sole discretion, and all decisions of Sponsor are final and binding on all matters relating to the Contest.  Sponsor reserves the right to prevent access to the Contest to any participant, or to drop any user from any Group, at any time and at its sole discretion, who acts irresponsibly or inappropriately in any manner in connection with the Contest, communication with or behavior towards other participants in the Contest, or in communication with Sponsor or its agents. Although all trading is fictional, participants are expected to engage in trading activity that fully complies with all federal and state securities laws (including without limitation laws pertaining to insider trading), as if they were trading actual securities.  

By entering, participants agree to be bound by the Official Rules, and release and hold harmless Sponsor and its agents and their respective parent companies, subsidiaries and affiliates, and each of their respective officers, directors, employees and agents from any and all liability, loss, or damage arising out of their participation in the Contest, use of the Vestly™ Game and/or with respect to the awarding, receipt, possession, use and/or misuse of any prize.  Entrants agree and acknowledge that Sponsor and its agents are not responsible for lost, late, misdirected, damaged, stolen, altered, garbled, incorrect, incomplete, delayed or undelivered entries or trades; all of which will be void. Sponsor is also not responsible for problems uploading or downloading the Vestly™ Game or any Contest information or materials or for any other technical malfunctions of electronic equipment, computer online systems, servers, or providers, computer hardware or software failures, phone lines, failure of any trade request to be received by Sponsor on account of technical problems, traffic, congestion on the internet or the Vestly™ Game, or for any other technical problems including telecommunication, miscommunication or failure, and failed, lost, delayed, incomplete, garbled or misdirected communications which may limit entrant’s ability to participate in this Contest. Sponsor is not responsible for any other errors or malfunctions of any kind, whether network, printing, typographical, human or otherwise relating to or in connection with the Contest, including, without limitation, errors or malfunctions which may occur in connection with the administration of the Contest, the processing of trades, the tabulating of points, the announcement of prizes or in any Contest-related materials. Sponsor reserves the right to modify, suspend or terminate the Contest or participation in the Contest for any reason, including without limitation in the event it becomes infected by a computer virus or is otherwise technically impaired, and to cancel or suspend the Contest in part or in its entirety should tampering, unauthorized intervention, fraud, technical failures or other causes corrupt the administration, security, fairness, integrity of, or proper participation in the Contest and, if terminated, at Sponsor’s discretion to determine the winners based on the scoring up to the time of cancellation.  


Sponsor reserves the right, in its sole discretion, to cancel the Contest, suspend the Contest or change any element thereof, including these Official Rules, with or without notice, at any time.  


List of Winners: For a list of winners, please send a self-addressed stamped envelope containing the name of the promotion and identifying the exact Contest Period to: Intelligration, LLC, Attn: Vestly winners list, 1732 1st Ave #29598, New York, NY  10128.  A list of winners will be available for at least 60 days after the end of each Contest Period.