User Agreement

1. Parties

This DyorEX User Agreement has been entered into between Dyor Kripto Varlık Alım Satım Platformu A.Ş. (“DyorEX”) and any person who, whether as a registered member or without registering, accesses and/or uses the content, products and services made available through the official website at www.dyorex.com, the mobile application, and any other application, content and/or platform developed, published or operated by DyorEX (the “User” or “you”). This Agreement shall become effective as of the moment you perform any of the transactions or actions referred to herein.

2. Subject Matter

This DyorEX User Agreement has been prepared to determine and regulate the mutual rights and obligations of the parties in connection with the use of the official website at www.dyorex.com, the mobile application, and any other application, content and/or platform developed, published or operated by DyorEX.

3. Definitions

3.1. DyorEX means Dyor Bilişim Teknolojileri Anonim Şirketi.

3.2. User means a natural person who approves the User Agreement applicable to the Platform or Platforms.

3.3. Cryptocurrency means a digital asset or virtual instrument that uses cryptography to secure transactions, is designed as a decentralised medium of exchange and an alternative to cash, may be used in exchange transactions, and operates through a distributed ledger database.

3.4. Crypto Asset Wallet means a computer file that stores crypto asset addresses and the relevant credentials. Crypto assets may be transferred between the relevant addresses. Each crypto asset has a unique address assigned to the User, and such address cannot technically be used for another crypto asset.

3.5. Platform means the official website at www.dyorex.com, DyorEX mobile applications operating on Android or iOS, and any other application or applications developed, published or operated by DyorEX.

3.6. User means a natural person who, whether as a registered member or without registering, accesses the Platform or Platforms and/or uses the content, products and services made available through them.

3.7. Services means the applications and services made available by DyorEX to Users as defined in this User Agreement.

3.8. KVKK means Personal Data Protection Law No. 6698 of the Republic of Türkiye.

3.9. Personal Data means information relating to the User, including identity information, electronic and physical address, IP address and telephone number.

4. Rights and Obligations of the Parties

4.1. All copyrights and other intellectual and industrial property rights relating to the applications provided by DyorEX, including algorithms, domain names, software code and interfaces; all content, including product reviews, videos, drawings and designs; all services offered through the Platform or Platforms; and all other related materials belong to Dyor Bilişim Teknolojileri Anonim Şirketi. Applications, content, Platforms and Services provided by DyorEX may not be copied, reproduced, distributed or subjected to reverse engineering.

4.2. A User who activates a DyorEX account may not assign, sell, transfer or permit any third party to use the User’s membership, rights or obligations. If such conduct is detected, DyorEX shall have the right to cancel, suspend or restrict the User’s account. The User acknowledges that the exercise of these rights by DyorEX shall not give rise to any claim against DyorEX. The User shall be responsible for all losses arising within the scope of this clause and for any applicable legal or criminal consequences.

4.3. After completing the membership form on the DyorEX registration page, the User shall electronically confirm that the User has read, understood and accepted this User Agreement and shall become a member by downloading a DyorEX application, accessing the Platform or Platforms, or accessing the website or content.

4.4. When registering through the official website, auxiliary websites, applications or any Platform made available by DyorEX, the User agrees to upload complete, accurate and up-to-date identity details, a photograph taken within the previous fifteen days and other required contact information, and to notify DyorEX without delay of any change. The User is responsible for the accuracy and confidentiality of the information submitted during registration, for protecting the username and password, and for not sharing such credentials with any other person. If the User fails to document identity and address information or fails to submit other information or documentation requested by DyorEX within the scope of applicable law and regulations, DyorEX may prevent any transaction from being conducted through the User’s account. Use of the Services is subject to approval of this Agreement.

4.5. If the User’s account information is obtained by third parties, the User shall be responsible for all transactions conducted until the User notifies DyorEX through the live support channel or by email. DyorEX shall not accept liability for such transactions to the extent permitted by applicable law.

4.6. All ownership and possession rights relating to User accounts belong to DyorEX.

4.7. DyorEX shall not be liable for delays relating to the User’s purchase or sale transactions or access to products, services or content.

4.8. All deposits and withdrawals conducted by the User through the DyorEX Platform or Platforms must be made through a bank account registered in the same full name as the identity information used during registration. Transactions made through bank accounts registered to third parties shall not be accepted by DyorEX.

4.9. DyorEX reserves the unilateral right to amend the rules governing purchases, sales, use of products and access to Services. The User may access the applicable rules and updates through the Platforms.

4.10. Neither DyorEX nor its directors, employees or the persons who prepare the information made available on the Platform shall bear civil or criminal liability for any loss, damage or liability arising from the User’s fault, to the extent permitted by applicable law.

4.11. Users may conduct transactions through the Platform or Platforms only for lawful purposes and in compliance with applicable legislation. If a User conducts an unlawful transaction, the User acknowledges that the User shall be solely responsible for all resulting civil, criminal and administrative liabilities and sanctions.

4.12. DyorEX may share the User’s identity, address, information and documentation with natural or legal persons in accordance with the DyorEX Privacy Policy and applicable legislation.

4.13. DyorEX reserves the right to suspend or terminate the membership of a User who has been granted access to purchase, sale, use, products and/or Services at any time for any lawful reason. DyorEX may notify the User of such action through the Platform or Platforms.

4.14. If any risk is identified or arises in connection with a transaction conducted through DyorEX, DyorEX may cancel the relevant transaction, with any applicable costs being borne by the User to the extent permitted by law.

4.15. DyorEX shall not be liable for delays caused by the User, a bank or any other third party. DyorEX reserves the right to request identification or additional information and documentation from the relevant User in relation to transactions that it has rejected, deemed risky or declined to process.

4.16. DyorEX does not request passwords in support communications and does not provide Users with a crypto asset address for the purpose of asking them to transfer crypto assets. This clause constitutes an express security notice. DyorEX shall not be liable for actual or potential losses arising from communications sent from addresses other than official DyorEX email addresses. Users are responsible for maintaining the security of their own accounts.

4.17. Prices formed on DyorEX Platforms are not determined by DyorEX. Accordingly, DyorEX shall not be liable for losses suffered by Users as a result of price fluctuations, volatility or sudden market movements.

4.18. DyorEX does not provide investment advice, trading recommendations or investment consultancy services through the Platform or Platforms. DyorEX shall not be liable for transactions conducted by the User through any other trading platform or for losses arising from such transactions.

4.19. The User acknowledges that the prices of products traded on crypto asset markets may be highly volatile and subject to significant fluctuations, and that the User possesses the knowledge, capability and experience necessary to trade or invest in crypto assets through DyorEX and to assess the legal and financial risks and potential returns involved. Users are solely responsible for profits and losses resulting from price movements. The User shall be responsible for losses or damages arising from adverse circumstances, Services provided under this Agreement or transactions conducted through the Platform and may not assert a claim against DyorEX, except where otherwise required by mandatory law.

4.20. By accepting and approving this Agreement, Users represent and undertake that they understand the risks associated with investing in cryptocurrencies and crypto assets.

4.21. DyorEX shall not be liable for losses suffered by the User or third parties arising from the misuse of crypto asset trading or investment activities by the User. Users are solely responsible for all legal obligations, costs and tax liabilities arising from the use of products, Services and Platforms, and DyorEX shall not be held responsible for such obligations.

4.22. To protect against cyberattacks on DyorEX systems, User assets may be stored in cold wallets that are not connected to the internet. Notwithstanding the implementation of this measure, DyorEX shall not be liable for account compromise, theft, fraud or any other event arising from circumstances not attributable to DyorEX.

4.23. Users must be over the age of 18 to receive Services through DyorEX Platforms. This criterion may be verified through the Central Civil Registration System of the Republic of Türkiye. If DyorEX determines or reasonably suspects that a User is under 18 or that an account is being used by a person under 18, DyorEX may terminate or suspend the relevant account without prior notice. The User represents and warrants that the User is over the age of 18 and is solely responsible for the accuracy of all information provided.

4.24. Each User may associate identity information with only one User account and may maintain only one account. If DyorEX identifies multiple User accounts used by the same person, DyorEX may terminate or suspend the relevant accounts without prior notice.

4.25. DyorEX may reverse and/or cancel User transactions where required by law or regulation, for security reasons, due to system updates or development work, or as a result of system disruptions. User accounts may be frozen while such reversals or cancellations are being conducted. DyorEX shall not be liable for such actions where they are taken lawfully and in good faith.

4.26. When conducting a money transfer through a bank lawfully operating within the Republic of Türkiye, the User acknowledges that the User account name and bank account holder name must be identical. If the User makes a transfer under a different name, through an ATM or by another deposit method, the User shall be responsible for any delay or failure in processing by the bank. The refund process applicable to transfers made contrary to the relevant rules is described in the “Help Centre” section available through the Platforms, which forms an integral part of this Agreement. A breach of this clause may constitute grounds for unilateral termination for cause, and the User shall bear the resulting legal and criminal liability.

4.27. The User must provide documentary evidence of identity and/or any other information requested by DyorEX. If the User fails to provide the requested documents, DyorEX may freeze the User’s account and/or prevent transactions from being conducted.

4.28. The username and password required to conduct transactions through DyorEX Platforms and/or access the “Account Information” page are created by the User. The security and confidentiality of such credentials are solely the User’s responsibility.

4.29. The User is responsible for providing all information required for registration, for the accuracy of such information and for maintaining its confidentiality. The User acknowledges, represents and undertakes that all transactions conducted through the User’s account using the relevant username and password shall be deemed to have been performed by the User, that responsibility for such transactions belongs to the User, and that the User may not avoid contractual obligations by objecting to or disputing transactions conducted through the account, except in cases of unauthorised activity for which mandatory law provides otherwise.

4.30. DyorEX shall not be liable for crypto asset transfers that fail to reach the intended destination because the User entered an incorrect address and/or network. Since incorrect crypto asset transfers may be irreversible, service fees and transaction fees charged by DyorEX in connection with such transfers shall not be refunded. The User acknowledges and accepts this clause in advance.

4.31. DyorEX shall not be liable for losses affecting the User’s transactions as a result of content shared through DyorEX Platforms being used, disclosed or published by third parties without authorisation.

4.32. The User represents and undertakes that the User will not use photographs, usernames or content, or submit messages or comments, that are contrary to the laws of the Republic of Türkiye, applicable legislation or international agreements; contain political messages; are racist, immoral or offensive; or infringe intellectual or industrial property rights. Photographs, correspondence, subject headings and usernames uploaded to the Platform or Platforms must comply with generally accepted standards of morality, etiquette and law and must not contain political messages.

4.33. The User agrees not to publish, reproduce or distribute materials or information that are defamatory, degrading, immoral, inappropriate or unlawful; not to advertise, sell or offer to sell goods or services; not to conduct surveys, competitions or chain-letter activities; and not to send information or programs that may damage other Users’ computers, software or the Platforms. The User further acknowledges that any records or materials obtained through the Services are acquired at the User’s own discretion and risk and that the User shall be responsible for any malfunction, loss of information or other damage caused to the User’s own computer or systems.

4.34. DyorEX reserves the right to decline money transfers and/or orders submitted by Users without being required to provide a reason, subject to applicable law. Where DyorEX exercises this right, funds deposited by the User in connection with the declined transaction shall be returned without undue delay.

4.35. DyorEX reserves the right to make changes to deposit and withdrawal processes and to banking and other Services offered through the Platform or Platforms. To the extent permitted by law, DyorEX shall not be liable for losses arising from such changes. DyorEX shall announce material changes through notices, notifications and/or relevant pages on its Platforms.

4.36. DyorEX is a company independent from other crypto asset exchanges and trading platforms offering similar services. It is not the representative of, and does not operate in partnership with, any other company, exchange, platform or institution. DyorEX shall not be liable for losses or grievances experienced by Users through other platforms.

4.37. DyorEX does not warrant that the Services will be uninterrupted or error-free, including where availability depends on systems supporting the operation of the Platforms. DyorEX shall use commercially reasonable efforts to make its Platforms accessible and available to Users on a continuous basis.

4.38. To the extent permitted by applicable law, DyorEX shall not be liable for technical failures that may occur on the official website or other Platforms or for direct or indirect losses arising from short-term or long-term technical disruptions.

4.39. Failure by DyorEX to exercise any right or authority under this Agreement immediately upon such right or authority becoming available shall not constitute an express or implied waiver. DyorEX may exercise such rights and authorities at any time in accordance with applicable legislation.

4.40. In any dispute arising from this Agreement, the User agrees that electronic archive records, electronic data and computer records maintained in DyorEX databases and servers, together with DyorEX’s statutory books and commercial records, shall constitute binding, conclusive and exclusive evidence to the extent permitted by law, and that this clause constitutes an evidentiary agreement within the meaning of Article 193 of the Turkish Code of Civil Procedure No. 6100.

4.41. DyorEX may communicate with the User by telephone call, email and/or SMS using the telephone number or email address provided during registration. The User is responsible for keeping such contact information up to date. Any change to information provided when entering into this Agreement must be updated without delay. DyorEX shall not be responsible for consequences arising from incomplete, inaccurate or outdated contact information.

4.42. DyorEX may assign or transfer its rights, obligations, debts and/or receivables arising from this Agreement without requiring the User’s consent, subject to applicable law. The User may not assign, transfer or permit another person to exercise any right or obligation under this Agreement, in whole or in part, without DyorEX’s prior written consent.

4.43. DyorEX may amend the terms and provisions of this Agreement without prior notice, subject to applicable legislation. Amendments shall be notified to Users through the official website, the Platform or Platforms and/or relevant pages. By accepting this Agreement, the User agrees to receive notices through these methods. Any amendment shall take effect on the date specified in the relevant notice and shall not apply retroactively unless permitted by mandatory law.

4.44. This Agreement shall become effective upon publication by DyorEX on the website and shall apply to all Users, whether existing or new, subject to applicable law.

4.45. DyorEX does not make any representation, warranty or undertaking regarding the legality of content provided through the Platforms or crypto assets made available for trading. DyorEX shall not be a party to disputes arising between buyers and sellers. The User acknowledges that DyorEX shall not bear civil or criminal liability in relation to disputes between buyers and sellers, except where liability cannot lawfully be excluded.

4.46. This Agreement constitutes the entire agreement between the User and DyorEX in relation to its subject matter. If any provision is held by a competent court, arbitral tribunal and/or administrative authority to be invalid, unenforceable or unreasonable in whole or in part, that provision shall be severed to the extent necessary and the remaining provisions shall remain in full force and effect.

5. Fees and Charges

DyorEX publishes the fees and/or commissions applicable to Services provided through the Platform or Platforms. DyorEX reserves the right to amend such fees and rates at any time, subject to applicable notification requirements. Current fees, commissions and limits form an integral part of this Agreement, and amendments shall become effective once announced through the official website, the Platforms and/or relevant pages. Unless otherwise required by mandatory law, use or purchase of DyorEX products, Services or content and completed trading transactions cannot be cancelled or refunded. Accordingly, service charges and transaction fees collected from the User by DyorEX shall not be refundable. By approving this Agreement, the User acknowledges and accepts this clause and agrees not to hold DyorEX responsible for transactions that the User believes were conducted in error, except where the error is attributable to DyorEX or mandatory law provides otherwise.

6. Privacy Policy and Protection of Personal Data

6.1. Upon the User’s acceptance and approval of this Agreement, DyorEX may process User information in accordance with the Privacy Policy, which has been prepared pursuant to Personal Data Protection Law No. 6698 and forms an integral part of this Agreement. In accordance with applicable legislation and the relevant provisions of the Privacy Policy, DyorEX may identify and record Users’ IP addresses, device information and models, operating systems and browser information. Where explicit consent is required, such information shall be processed only after valid consent has been obtained. The purposes and details of processing are set out in the Privacy Policy. Information provided by Users shall not be used or shared outside the rules, purposes and legal bases specified in the User Agreement, Privacy Policy and applicable legislation.

6.2. DyorEX may provide links through its Platforms to third-party websites and/or applications with which it cooperates and may publish advertisements or application forms relating to various services. When the User accesses third-party applications or websites through DyorEX, DyorEX shall not be responsible for their privacy practices, policies or content.

6.3. DyorEX may disclose User information to third parties outside the ordinary scope of this privacy notice in the following circumstances:

(i) Where disclosure is required or permitted under applicable legislation;

(ii) Where information concerning Users is requested in connection with an investigation or inquiry conducted by competent administrative and/or judicial authorities; or

(iii) Where disclosure is necessary to protect the rights or security of Users, DyorEX or third parties.

6.4. In accordance with the Privacy and Personal Data Protection section of this User Agreement, DyorEX undertakes to collect and protect personal data in accordance with the KVKK; not to use personal data, directly or indirectly, for purposes other than those for which it was collected unless another lawful basis applies; not to disclose confidential information to third parties or institutions without the User’s consent, except where required by law; and not to permit unauthorised use or copying of such information.

7. Intellectual Property Rights

All intellectual property rights in the DyorEX name and brand, logo, mobile applications, Platform software, designs, domain names and all related content created by DyorEX belong to DyorEX. The User may not use, reproduce, distribute, share or create derivative works from any DyorEX content without prior written authorisation.

If the User infringes DyorEX’s intellectual property rights, the User shall be liable to compensate DyorEX for direct and/or indirect losses and costs arising from such infringement, subject to applicable law.

8. Disclaimer

Data, analyses, reports and statistics made available through the Services are processed automatically by software and presented on an objective basis without manual editing or direction, except where expressly stated otherwise.

DyorEX does not guarantee the accuracy, completeness or reliability of content made available through the Platforms, including prices and statistics. News, reports and other materials provided to Users are for informational purposes only. Data may be inconsistent or contradictory. To the extent permitted by law, DyorEX shall not be liable for losses, damages or loss of profit resulting from reliance on or use of DyorEX content.

Through the Platforms, DyorEX provides the technological infrastructure necessary to access and use Services, products and content and, depending on their nature, to conduct purchase and sale transactions. DyorEX does not independently determine crypto asset prices; prices are formed according to market supply and demand. DyorEX shall not be liable for losses arising from price movements or the failure of a transaction to be completed, except where such loss results from DyorEX’s breach of a mandatory legal obligation.

9. Governing Law and Jurisdiction

This User Agreement and the laws of the Republic of Türkiye shall apply to disputes arising from this Agreement or use of the Platform or Platforms. The Gebze Courts and Enforcement Offices shall have exclusive jurisdiction, subject to mandatory jurisdiction rules under applicable law. The parties agree that electronic and system records maintained in DyorEX’s databases, commercial records, statutory books, email correspondence and computer records shall constitute valid, binding, conclusive and exclusive evidence to the extent permitted by law, and that this clause constitutes an evidentiary agreement within the meaning of Article 193 of the Turkish Code of Civil Procedure No. 6100.

10. Entry into Force and Acceptance

By using or beginning to use the official DyorEX website, mobile application and/or Platform or Platforms, you represent and undertake that you have read the entire User Agreement, fully understood its content and accepted all of its provisions. By accepting this Agreement, the User shall be deemed to have reviewed and acknowledged announcements made by competent authorities concerning cryptocurrencies and crypto assets.

11. Legal and Criminal Consequences

11.1. If the User uses or permits the website to be used for unlawful purposes, the User shall be responsible for the resulting consequences under this Agreement and agrees not to hold DyorEX responsible, except where liability cannot lawfully be excluded.

11.2. For the reasons set out in this Agreement, DyorEX may freeze, permanently or temporarily delete, suspend or restrict the User’s account and may prevent the User from opening another account for an indefinite period, subject to applicable law.

11.3. By accepting this Agreement, the User undertakes to use the official DyorEX website, mobile application and all Platforms in compliance with applicable law and regulations. If DyorEX detects unlawful use, it may share User information with competent authorities where required or permitted by law. Such disclosure shall not constitute a breach of confidentiality and shall not create liability for DyorEX.

11.4. By accepting this Agreement, the User undertakes not to use the DyorEX name and/or logo in any written, visual or social media content that defames DyorEX, damages its commercial reputation or constitutes unfair competition. If a breach is identified, DyorEX may terminate this Agreement unilaterally without prior notice, block, suspend or permanently delete the User’s account and pursue any available claim for compensation. The User’s rights under mandatory law remain unaffected.

11.5. DyorEX may impose a restriction or seizure-related block on the User’s account and/or assets held in the account in response to requests or orders issued by judicial and/or administrative authorities. DyorEX shall not bear civil or criminal liability for implementing such measures lawfully and in good faith.

11.6. DyorEX may temporarily or permanently suspend, freeze or close the accounts of Users who use expressions contrary to generally accepted standards of morality or conduct during communications through live support, email at [email protected] and/or customer service channels. Where DyorEX applies this clause lawfully, the User may not assert civil or criminal liability against DyorEX.

11.7. If DyorEX mistakenly transfers crypto assets to a User in a manner that results in unjust enrichment, DyorEX shall notify the User without delay by email, telephone and/or SMS. If the User fails to return the crypto assets within one hour after notification, DyorEX may close, suspend or indefinitely restrict access to the User’s account without further notice. DyorEX may debit the User’s account by the amount of the erroneous transfer and may pursue available legal remedies. DyorEX reserves the right to seek compensation for direct or indirect losses arising from the erroneous transfer.

12. Account Access and Assets

If the User breaches any provision of this Agreement or any other agreement forming an integral part of it, DyorEX may cancel, suspend, delete and/or restrict the User’s account without prior notice, subject to applicable law. The exercise of these rights shall not, by itself, affect ownership of the User’s assets. Provided that no statutory, judicial or administrative restriction applies, assets held by DyorEX on behalf of the User shall be returned upon a valid request. The User may transfer digital currency associated with the User’s Digital Wallet for fifteen days following deactivation, cancellation or termination of the account, unless a legal or security restriction prevents such transfer.

13. Force Majeure

13.1. If DyorEX is unable to perform its obligations under this Agreement due to a force majeure event, DyorEX shall not be liable for delayed or prevented performance, and such failure shall not constitute a breach of this Agreement. Force majeure events may include:

13.1.1. Civil unrest, embargo, government intervention, insurrection, invasion, war, mobilisation, strike, lockout, industrial action or boycott;

13.1.2. Cyberattacks, communication failures, infrastructure or internet outages, system improvement or renewal work and failures arising from such work; and

13.1.3. Power outages, fire, explosion, storm, flood, earthquake, mass migration, epidemic or other natural disaster, or any other event beyond DyorEX’s reasonable control that is not caused by its fault and could not reasonably have been foreseen.

14. Account Closure

The User may request the permanent closure of the User’s account at any time and without stating a reason by sending an application to [email protected] together with the required identity documentation, a signed petition and a selfie prepared in accordance with DyorEX’s verification requirements. The account shall be closed within thirty days after receipt of a complete and valid request, subject to applicable legislation. Transaction records and other data relating to a closed account may continue to be retained by DyorEX for the periods required under applicable law and for the protection of DyorEX’s legitimate interests.

15. Approval of the Agreement

This User Agreement shall enter into force when electronically approved by the User after the User has read and fully understood all of its provisions. Users who do not accept the terms of this User Agreement must not use the applications, Services and/or other services provided through the Platform or Platforms. DyorEX shall not be liable for losses arising from use in breach of this clause, except where liability cannot lawfully be excluded.