I don't think that there is a promotion, but instead the company and it's plan to grow, as well as it's deal with the newly formed cashless entity CANX has in fact been turned into a promotion.
CANX sells some shares of PHOT to pay PHOT as needed, basically a promotion to get investors to use their money to fund CANX's loan to PHOT.
So I would think this is why you're seeing it being called a promo, because it is one, it's just more crafty than most.