Originally Posted by
KATERGOO
You can call Miles & Smiles and ask them. The only problem is that their answers are not really reliable. One agent might tell you yes, and the other one no … but if you call 3 times, and they all say yes, or no, then you get your answer

Yeah, I always trust systematic way over (underpaid, undertrained) agents.
The fare rules I found on TK's website (a few posts back) looks different than the one you posted from ITA. But I wonder if the absence of language about "promotional tickets not eligible" is any indication.