
    <div>
    <div>
        <h3>Cookie Policy</h3>
        <p>Certain technologies, products ("Cookies") are used by <span>Dyor Kripto Varlık Alım Satım Platformu Anonim A.Ş. (“DyoreX”)</span> to enable you to benefit effectively from the services and to improve your user experience.</p>
    </div>
    <p>If you prefer not to use cookies, you can delete or block cookies from your browser settings. If you do not change your cookie settings, we will assume that you accept the use of cookies on our site and mobile application.</p>
    <ol>
    <li>
        <h4><strong>1. What Are Cookies and Similar Technologies?</strong></h4>
        <p>A cookie is a small text file saved on your computer, tablet, mobile device, or network server by the websites you visit via your browser. Cookies allow a site to run more efficiently and to present pages tailored to your habits and usage patterns.</p>
    </li>
    <li>
        <h4><strong>2. Types of Cookies and Purposes of Use</strong></h4>
        <p>We classify cookies into three groups based on their duration, source, and purpose of use, such as Session Cookies, Persistent Cookies, First-Party Cookies, Third-Party Cookies, Strictly Necessary Cookies, Functional Cookies, Performance Cookies, and Marketing Cookies.</p>
    </li>
    <li>
        <h4><strong>3. How to Manage Your Cookie Preferences?</strong></h4>
        <p>Please note that blocking the use of Functional, Performance, and Marketing cookies on your browser may affect the customization of the website to your needs and preferences. Disabling cookies may cause access restrictions to certain features of the website.</p>
    </li>
    </ol>
    </div>
    

Cookie Policy


    <div>
      <div>
        <h3>Privacy Policy</h3>

        <p>
          <span>Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (“DyoreX”)</span>
          recognises the importance of providing clear and accessible information
          regarding the personal data we process, the manner and purposes of such
          processing, the parties with whom personal data may be shared pursuant to
          legal and regulatory obligations, and the rights of data subjects under
          Personal Data Protection Law No. 6698 (“KVKK”), published in the Official
          Gazette dated 7 April 2016 and numbered 29677.
        </p>

        <p>
          This Privacy Policy explains our principles and practices regarding the
          processing of personal data provided by our customers and users.
        </p>

        <p>
          Through its official website at dyorex.com, mobile application and other
          platforms, DyoreX provides services including the purchase, sale and transfer
          of crypto assets, conversion of crypto assets into fiat currency, digital
          wallet services for the custody of crypto assets, real-time monitoring of
          crypto asset markets, the use of crypto assets for payment purposes to the
          extent permitted by applicable legislation, and other related products,
          services and content.
        </p>

        <p>
          By visiting DyoreX platforms, including its official website and mobile
          application, downloading or using content made available through such
          platforms, or using online services provided by DyoreX, you acknowledge
          that you have reviewed this Privacy Policy. Where required under applicable
          legislation, your personal data will only be processed on the basis of your
          explicit consent or another valid legal basis.
        </p>

        <p>
          This Privacy Policy may be amended from time to time due to developments in
          technology, changes in industry practices or amendments to applicable
          legislation. We recommend reviewing this document periodically to remain
          informed of any changes. The most recent version of this Privacy Policy will
          always be published on DyoreX platforms.
        </p>

        <p>
          Please note that this Privacy Policy does not apply to third-party websites,
          applications or platforms that you may access through links provided on
          DyoreX platforms. Such third-party services are governed by their own privacy
          policies and practices.
        </p>
      </div>

      <ol>
        <li>
          <h4><strong>1. Collection of Personal Data</strong></h4>

          <p>
            When using products, services or content offered through the DyoreX
            official website, mobile application or other platforms, personal data
            voluntarily provided by you may be collected and processed in accordance
            with this Privacy Policy, the KVKK and other applicable legislation.
          </p>

          <p>
            DyoreX collects personal data only to the extent permitted by law and only
            for the specified, explicit and legitimate purposes described in this
            Privacy Policy.
          </p>
        </li>

        <li>
          <h4>
            <strong>2. Personal Data We May Collect and Purposes of Processing</strong>
          </h4>

          <p>
            DyoreX may process the categories of personal data listed under the
            “Personal Data Collected” section of the Annex in accordance with
            applicable legal and regulatory obligations and in a manner that protects
            your right to privacy.
          </p>

          <p>
            DyoreX uses personal data to provide high-quality and efficient services,
            improve its products and services, enhance the user experience and maximise
            customer satisfaction.
          </p>

          <p>
            Personal data listed in the Annex may, subject to applicable legislation,
            be transferred to, stored by, updated by, periodically reviewed by and
            classified by legally authorised public institutions and private
            organisations, business and project partners, domestic and international
            service providers, organisations providing support and consultancy
            services, independent audit firms and other relevant domestic or
            international natural or legal persons.
          </p>

          <p>
            DyoreX may also use personal data to better understand its users, improve
            its services and generate aggregated statistics, including statistics for
            marketing, service development and demographic research purposes.
          </p>
        </li>

        <li>
          <h4>
            <strong>3. Storage and Accuracy of Your Personal Data</strong>
          </h4>

          <p>
            DyoreX stores personal data securely for the periods required by applicable
            legislation or for as long as necessary to fulfil the purposes for which
            the personal data was collected.
          </p>

          <p>
            Personal data is processed in accordance with the principles of lawfulness
            and fairness, accuracy and, where necessary, being kept up to date,
            processing for specified, explicit and legitimate purposes, being relevant,
            limited and proportionate to the purposes of processing, and retention for
            the period prescribed by applicable legislation or required for the
            relevant processing purpose.
          </p>

          <p>
            Users are responsible for ensuring that the information they provide to
            DyoreX is accurate, complete and up to date. Users should notify DyoreX
            without undue delay if their personal information changes.
          </p>
        </li>

        <li>
          <h4>
            <strong>4. Parties with Whom Your Personal Data May Be Shared</strong>
          </h4>

          <p>
            Subject to applicable legislation, your personal data may be transferred
            to, stored by, updated by, periodically reviewed by and classified by
            legally authorised public institutions and private organisations, service
            providers engaged to support our business operations, project and programme
            partners, domestic and international organisations, consultancy and support
            service providers, independent audit firms and other relevant domestic or
            international natural or legal persons.
          </p>

          <p>
            Personal data may be transferred abroad in accordance with the conditions
            and safeguards stipulated under Article 9 of the KVKK and other applicable
            data protection legislation.
          </p>

          <p>
            Where explicit consent is required for an international transfer, your
            personal data will only be transferred after obtaining your valid explicit
            consent. Where another legal basis or transfer mechanism is available under
            applicable legislation, the transfer may be conducted without explicit
            consent in accordance with that legal basis or mechanism.
          </p>

          <p>
            DyoreX will not share personally identifiable information with third
            parties for their independent marketing purposes without your consent.
          </p>
        </li>

        <li>
          <h4><strong>5. Security of Your Personal Data</strong></h4>

          <p>
            DyoreX attaches great importance to protecting the integrity,
            confidentiality and security of your personal data. Accordingly, DyoreX
            takes appropriate technical and administrative measures to prevent
            unauthorised access to, alteration, disclosure, loss or misuse of personal
            data.
          </p>

          <p>
            Personal data provided by you is stored in secure and closely monitored
            systems and databases, subject to access controls and other appropriate
            information security measures.
          </p>
        </li>

        <li>
          <h4>
            <strong>
              6. Protection of Personal Data Relating to Minors
            </strong>
          </h4>

          <p>
            Persons under the age of 18 who have not reached the age of legal majority
            must not conduct transactions through our platforms or use our online
            services without the consent of their parents or legal guardians, subject
            to applicable legal and regulatory requirements.
          </p>

          <p>
            Where individuals between the ages of 13 and 17 wish to request information
            or submit comments regarding content, their parents or legal guardians
            should review our policies and contact us in accordance with the applicable
            requirements.
          </p>
        </li>

        <li>
          <h4><strong>7. Cookies</strong></h4>

          <p>
            As further described in the DyoreX Cookie Policy, DyoreX may use cookies
            based on users’ preferences, habits and use of its platforms.
          </p>

          <p>
            DyoreX may also process personal data in aggregated and anonymised form to
            analyse and generate statistical information concerning the demographic
            characteristics and usage patterns of user groups.
          </p>

          <p>
            DyoreX may share anonymised data with third parties without obtaining your
            consent, provided that such data cannot be associated with an identified
            or identifiable natural person.
          </p>
        </li>

        <li>
          <h4><strong>8. Governing Law and Jurisdiction</strong></h4>

          <p>
            This Privacy Policy is governed by the laws of the Republic of Türkiye.
            The Istanbul Anatolian Courts shall have jurisdiction over disputes arising
            from the interpretation or implementation of this Privacy Policy, subject
            to mandatory provisions of applicable law.
          </p>
        </li>

        <li>
          <h4><strong>9. Your Rights</strong></h4>

          <p>
            DyoreX enables its users and customers to obtain information regarding the
            personal data processed about them and the purposes for which such data is
            processed.
          </p>

          <p>
            Subject to applicable legislation and, where required, your consent,
            DyoreX may send promotional emails, newsletters, notifications and other
            informational or marketing communications. You may withdraw your consent
            or unsubscribe from such communications at any time through the available
            communication preference settings or by contacting DyoreX.
          </p>
        </li>

        <li>
          <h4>
            <strong>
              10. Your Rights Under Article 11 of Law No. 6698
            </strong>
          </h4>

          <p>
            Pursuant to Article 11 of the KVKK, you have the following rights in
            relation to your personal data:
          </p>

          <p>
            <strong>a)</strong> To learn whether your personal data is being processed;
          </p>

          <p>
            <strong>b)</strong> To request information where your personal data has
            been processed;
          </p>

          <p>
            <strong>c)</strong> To learn the purpose of processing your personal data
            and whether it is being used in accordance with that purpose;
          </p>

          <p>
            <strong>d)</strong> To learn the identity of third parties to whom your
            personal data has been transferred domestically or abroad;
          </p>

          <p>
            <strong>e)</strong> To request the correction of personal data that has
            been processed incompletely or inaccurately;
          </p>

          <p>
            <strong>f)</strong> To request the deletion or destruction of your
            personal data within the framework of the conditions stipulated under
            Article 7 of Law No. 6698;
          </p>

          <p>
            <strong>g)</strong> To request that correction, deletion or destruction
            procedures carried out in accordance with paragraphs (e) and (f) above
            be communicated to third parties to whom your personal data has been
            transferred;
          </p>

          <p>
            <strong>h)</strong> To object to a result arising against you as a result
            of the analysis of processed personal data exclusively through automated
            systems; and
          </p>

          <p>
            <strong>i)</strong> To request compensation for damage arising from the
            unlawful processing of your personal data.
          </p>

          <p>
            To exercise any of the rights listed above, you may submit a written and
            signed request to DyoreX. Your application should include sufficient
            information to verify your identity, a clear description of the right you
            wish to exercise and any information or documentation relevant to your
            request.
          </p>

          <p><strong>Email Address:</strong></p>
          <p><a href="mailto:kvkk@dyorex.com" style="color: #d21e2b; text-decoration: underline;">kvkk@dyorex.com</a></p>

          <p>
            DyoreX reserves the right to amend this Privacy Policy at any time through
            its platforms. We will inform users of significant or material changes
            through instant notifications, emails or announcements published on our
            platforms. Amendments will enter into force on the date they are published,
            unless otherwise stated.
          </p>
        </li>
      </ol>

      <h4><strong>ANNEX – PERSONAL DATA COLLECTED</strong></h4>

      <div>
        <h4><strong>Personal Data Collected</strong></h4>

        <ul>
          <li>- Full name</li>
          <li>- Email address</li>
          <li>- Turkish Republic Identification Number</li>
          <li>- Date of birth</li>
          <li>- Identity information</li>
          <li>- Front side of the identity document</li>
          <li>- Back side of the identity document</li>
          <li>
            - A selfie photograph showing the individual holding a white sheet of
            paper bearing “dyorex.com” and their full name
          </li>
          <li>- Contact information</li>
          <li>- Correspondence records where the individual contacts DyoreX</li>
          <li>- Information regarding the pages visited</li>
          <li>- Time spent on individual pages</li>
          <li>- Activities performed while logged into an account on our platforms</li>
          <li>- Personal information submitted for participation in prize draws</li>
          <li>- Personal information submitted for participation in competitions</li>
          <li>- Personal information submitted for participation in promotions</li>
          <li>- Operating system information</li>
          <li>- Browser information</li>
          <li>- Software application information</li>
          <li>- IP address</li>
          <li>- Geographical location information</li>
          <li>- Security status and security-related information</li>
          <li>- Device information</li>
        </ul>

        <h4><strong>Purposes of Processing</strong></h4>

        <ul>
          <li>- Providing the requested products and services</li>
          <li>
            - Enabling users to benefit from the services offered through our platforms
          </li>
          <li>- Conducting Know Your Customer and Anti-Money Laundering checks</li>
          <li>- Communicating with users regarding products and services</li>
          <li>- Improving and adapting our products and services</li>
          <li>- Informing users of changes, developments and updates</li>
          <li>- Developing and updating our business operations</li>
          <li>- Improving the usability of our platforms</li>
          <li>
            - Improving platform interfaces and enhancing the user experience
          </li>
          <li>- Evaluating information provided through surveys</li>
          <li>- Preventing fraud and managing risk</li>
          <li>- Managing account activity and devices</li>
          <li>- Ensuring platform and content compatibility</li>
        </ul>
      </div>

      <p>
        <strong>Providing the requested products and services</strong> means managing
        the relevant services, fulfilling our contractual obligations to customers and
        informing customers about changes to products or services.
      </p>

      <p>
        <strong>Informing users of changes and developments</strong> means notifying
        users of changes, updates and developments concerning the DyoreX products and
        services they have selected. Subject to applicable legislation and your
        communication preferences, information may also be used to communicate with
        you through in-app notifications, post, email, telephone, SMS or online and
        social media advertisements.
      </p>

      <p>
        <strong>Developing and updating our business operations</strong> means
        analysing customer usage patterns and preferences to understand customer
        requirements and improve our activities, products and services accordingly.
      </p>

      <p>
        <strong>
          Improving platform interfaces and enhancing the user experience
        </strong>
        means analysing user activity on our platforms and, where necessary, working
        with business partners or service providers to make the platforms easier to
        use and more user-friendly.
      </p>

      <p>
        <strong>Preventing fraud and managing risk</strong> means analysing relevant
        user activity and technical information, including operating system,
        geographical location, browser and device information, to identify and manage
        potential security threats, fraud and other adverse events. Where appropriate,
        users may be informed through in-app notifications, post, email, telephone or
        SMS.
      </p>
    </div>
  

Privacy Policy

User Agreement


    <div>
      <div>
        <h3>Privacy Notice</h3>

        <p>
          As <span>Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (“DyoreX”)</span>,
          we attach the utmost importance to ensuring the security of your personal data,
          particularly in accordance with Personal Data Protection Law No. 6698 (“KVKK”)
          and other applicable legislation. In this context, we would like to inform you,
          in our capacity as the Data Controller, regarding the processing of your personal data.
        </p>
      </div>

      <ol>
        <li>
          <h4><strong>1. Collection of Personal Data</strong></h4>

          <p>
            By sharing your personal data with DyoreX to use any products, services or
            other content provided through mobile applications, websites or other
            platforms owned or operated by DyoreX, you consent to the processing,
            recording, storage and retention of your personal data in accordance with
            Law No. 6698, applicable laws and the principles of good faith.
          </p>

          <p>
            Your personal data will be processed for specified, explicit and legitimate
            purposes, in a manner that is relevant, limited and proportionate to the
            purposes for which it is processed, and will be kept accurate and up to date.
          </p>

          <p>
            Persons under the age of 18 who have not reached the age of legal majority
            must not conduct any transactions through our platforms or use our platforms
            online without the consent of their parents or legal guardians, subject to
            the requirements imposed by legal or regulatory authorities.
          </p>

          <p>
            Where individuals between the ages of 13 and 17 wish to obtain information
            or submit comments regarding any content, their parents or legal guardians
            must review our policies and contact us in accordance with the applicable
            requirements.
          </p>
        </li>

        <li>
          <h4>
            <strong>2. Personal Data We May Collect and the Purposes of Collection</strong>
          </h4>

          <p>
            DyoreX may collect all personal information listed under the
            “Personal Data Collected” section of the Annex in accordance with the
            obligations imposed by legal or regulatory authorities.
          </p>

          <p>
            Your personal data may be stored and processed for the purposes specified
            in the Personal Data Processing and Protection Policy, including completing
            membership and account registration procedures, resolving your problems and
            complaints, understanding and promptly responding to user requirements,
            informing users about our products and services, obtaining and responding
            to user feedback, and improving and diversifying our products and services.
          </p>

          <p>
            Where you have provided your consent to receive commercial electronic
            communications, your personal data may also be processed to send you news,
            information, updates, offers, details of special events and other marketing
            communications that may be of interest to you.
          </p>

          <p>
            Your personal data may also be processed to conduct the necessary quality
            and standards audits in accordance with applicable legislation and to fulfil
            reporting and other statutory or regulatory obligations. Services relating
            to these activities may be obtained from third-party service providers.
          </p>

          <p>
            Subject to your consent and applicable legislation, DyoreX may send you
            marketing and promotional emails and/or SMS messages, contact you by
            telephone or communicate with you through other communication channels
            approved by you. These services may also be provided through third-party
            service providers acting on behalf of DyoreX.
          </p>
        </li>

        <li>
          <h4>
            <strong>3. Storage and Accuracy of Your Personal Data</strong>
          </h4>

          <p>
            DyoreX securely stores the personal data provided by you to the extent
            required under applicable legislation and takes all necessary technical
            and administrative measures to prevent unauthorised access to, alteration,
            disclosure or collection of such information.
          </p>

          <p>
            Where you provide personal or other data either directly to us or to a
            relevant service provider for the purpose of paying for goods or services
            purchased by DyoreX or relating to your transactions, you acknowledge that
            you are solely responsible for the accuracy and completeness of the data
            provided and for any tangible or intangible loss, damage or consequence
            arising from the provision of such data or the completion of the relevant
            transaction. DyoreX shall not be held liable in this regard.
          </p>
        </li>

        <li>
          <h4>
            <strong>4. Parties with Whom Your Personal Data May Be Shared</strong>
          </h4>

          <p>
            Your personal data may be transferred to, stored by, updated by,
            periodically reviewed by and classified by legally authorised public
            institutions, private persons and organisations, project and programme
            partners with whom we cooperate, domestic and international organisations,
            service providers engaged for the conduct of our business activities,
            organisations providing support and consultancy services, independent
            audit firms, and other relevant domestic or international natural or
            legal persons, subject to applicable legislation.
          </p>

          <p>
            DyoreX will not share personally identifiable information with third parties
            for marketing purposes without your consent.
          </p>
        </li>

        <li>
          <h4>
            <strong>5. Security of Your Personal Data</strong>
          </h4>

          <p>
            DyoreX attaches great importance to maintaining the integrity and security
            of your personal data. Accordingly, your personal data is securely stored
            in highly protected and closely monitored databases in order to prevent
            unauthorised access to or alteration of the information provided by you.
          </p>
        </li>

        <li>
          <h4><strong>6. Cookies</strong></h4>

          <p>
            As further described in the Cookie Policy, DyoreX may use cookies based on
            your preferences and use of our platforms. DyoreX may also process your
            personal data in aggregated and anonymised form in order to analyse and
            generate statistics regarding the demographic characteristics and usage
            patterns of user groups, either collectively or individually.
          </p>

          <p>
            DyoreX may share such anonymised data with third parties without obtaining
            your consent, provided that the data can no longer be associated with an
            identified or identifiable individual.
          </p>

          <p>
            You have the right to learn whether your personal data is being processed,
            request information regarding such processing, learn the purpose for which
            your personal data is processed and whether it is being used in accordance
            with that purpose, and exercise your other rights under applicable personal
            data protection legislation.
          </p>

          <p>
            Further information regarding your rights is available on the official
            website of the Turkish Personal Data Protection Authority at
            https://www.kvkk.gov.tr/.
          </p>

          <p>
            You may submit all requests for information and applications within the
            scope of Article 11 of Law No. 6698 and other applicable legislation to
            <a href="mailto:kvkk@dyorex.com" style="color: #d21e2b; text-decoration: underline;">kvkk@dyorex.com</a>.
          </p>

          <p>
            DyoreX reserves the right to amend this Privacy Notice at any time through
            its platforms. We will notify our users of any significant or material
            changes to this Privacy Notice through instant notifications, emails or
            announcements published on our platforms. All amendments will be published
            on the relevant platforms and will enter into force on the date of publication.
          </p>
        </li>
      </ol>

      <h4><strong>ANNEX – PERSONAL DATA COLLECTED</strong></h4>

      <div>
        <h4><strong>Personal Data Collected</strong></h4>

        <ul>
          <li>- Full name</li>
          <li>- Email address</li>
          <li>- Turkish Republic Identification Number</li>
          <li>- Date of birth</li>
          <li>- Identity information</li>
          <li>- Front side of the identity document</li>
          <li>- Back side of the identity document</li>
          <li>- A selfie photograph showing the individual holding a white sheet of paper bearing the words “dyorex.com” and their full name</li>
          <li>- Contact information</li>
          <li>- Correspondence records where the individual contacts DyoreX</li>
          <li>- Information regarding the pages visited</li>
          <li>- Time spent on individual pages</li>
          <li>- Activities performed while logged into an account on our platforms</li>
          <li>- Personal information submitted for participation in prize draws</li>
          <li>- Personal information submitted for participation in competitions</li>
          <li>- Personal information submitted for participation in promotions</li>
          <li>- Operating system information</li>
          <li>- Browser information</li>
          <li>- Software application information</li>
          <li>- IP address</li>
          <li>- Geographical location</li>
          <li>- Security status</li>
          <li>- Device information</li>
        </ul>

        <h4><strong>Purposes of Processing</strong></h4>

        <ul>
          <li>- Providing the requested products and services</li>
          <li>- Enabling users to benefit from the services provided through the platforms</li>
          <li>- Conducting Know Your Customer and Anti-Money Laundering checks</li>
          <li>- Communicating regarding products and services</li>
          <li>- Improving our products and services</li>
          <li>- Notifying users of changes and updates</li>
          <li>- Developing and customising our products and services</li>
          <li>- Developing and updating our business operations</li>
          <li>- Improving the usability of our platforms</li>
          <li>- Improving platform interfaces and enhancing user experience</li>
          <li>- Evaluating information provided through surveys</li>
          <li>- Preventing fraud and managing risk</li>
          <li>- Managing account activity and devices</li>
          <li>- Ensuring platform content compatibility</li>
        </ul>
      </div>
    </div>
  

Clarification Text

 <div> <div> <h3>Anti-Money Laundering and Counter-Terrorist Financing Policy (AML Policy)</h3> </div>

  <p>
    <strong>Money laundering</strong>, in general terms, refers to transactions and activities intended to conceal the unlawful origin of assets obtained from criminal and/or illegal sources by presenting such assets as though they had been derived from legitimate sources.
  </p>

  <p>
    As <strong>Dyor Kripto Varlık Alım Satım Platformu A.Ş.</strong> (“<strong>DyorEX</strong>”), we are committed to working diligently and responsibly to safeguard the accounts of all Users who benefit from the DyorEX Platform or Platforms and accept the User Agreement, to provide our Services to the highest possible standard and to maintain the highest level of customer satisfaction. In connection with the Services we provide, DyorEX represents and undertakes that it will strictly implement this Anti-Money Laundering and Counter-Terrorist Financing Policy (hereinafter referred to as the “<strong>AML Policy</strong>”) in order to prevent, under any circumstances, the laundering of assets derived from criminal and/or unlawful sources. This AML Policy summarises the procedures and mechanisms established by DyorEX under applicable legislation for the prevention of money laundering and terrorist financing.
  </p>

  <h4><strong>1. Purpose</strong></h4>

  <p>
    The purpose of this AML Policy is to raise awareness among customers who have accepted the User Agreement regarding the prevention of money laundering and terrorist financing, to ensure that they are appropriately informed, and to notify them of DyorEX’s rights and obligations in this regard, particularly under Law No. 5549 on the Prevention of Laundering Proceeds of Crime, Law No. 6415 on the Prevention of the Financing of Terrorism and other applicable legislation.
  </p>

  <h4><strong>2. Scope</strong></h4>

  <p>
    This AML Policy applies to natural persons who register with the Platform or Platforms, accept the User Agreement forming an integral part of this Policy, benefit from the Services offered through the Platform, and accept the provisions of this AML Policy. The Policy is intended to support the lawful and uninterrupted conduct of DyorEX’s activities.
  </p>

  <h4><strong>3. Duties, Powers and Responsibilities</strong></h4>

  <p>
    DyorEX has prepared this AML Policy in accordance with international legal principles and standards and applicable national legislation. Within this framework, DyorEX has adopted the necessary measures to verify the identity of Users to a reasonable and legally required standard, monitor User transactions, report suspicious transactions carried out by Users to the competent authorities in accordance with applicable legislation, retain transaction records within the scope of the User Agreement, and coordinate the effective implementation of this AML Policy.
  </p>

  <p>
    Under this AML Policy, DyorEX represents and undertakes that it will not enter into business relationships with criminals and/or terrorists, process transactions arising from criminal and/or terrorist activities, or facilitate any transaction connected with criminal and/or terrorist activities.
  </p>

  <h4><strong>4. Risk Assessment</strong></h4>

  <p>
    DyorEX adopts a risk-based approach to the prevention of money laundering and terrorist financing in accordance with applicable national and international legislation. Measures implemented under this AML Policy shall be proportionate to the risks identified, with the greatest attention being given to the areas presenting the highest level of risk.
  </p>

  <p>
    As part of its risk-based approach, DyorEX conducts risk analyses using the methods set out below to prevent money laundering and terrorist financing and may place the relevant User or Users under enhanced monitoring in light of the information obtained from such analyses.
  </p>

  <h4><strong>4.1. High-Risk Users and Transactions</strong></h4>

  <ol>
    <li>
      The total value of a single crypto asset purchase or sale transaction, or multiple linked crypto asset purchase or sale transactions, being equal to or greater than TRY 100,000.00;
    </li>
    <li>
      The total value of a single crypto asset exchange transaction, or multiple linked crypto asset exchange transactions, being equal to or greater than TRY 100,000.00;
    </li>
    <li>
      Circumstances requiring the submission of a suspicious transaction report under applicable legislation;
    </li>
    <li>
      Doubts concerning the accuracy, authenticity or adequacy of identity information;
    </li>
    <li>
      Complex transactions that may have the potential to conceal the involvement of third parties;
    </li>
    <li>
      Circumstances in which the source of funds cannot be readily verified;
    </li>
    <li>
      Transactions connected with jurisdictions classified as high risk, requiring additional monitoring and control; and
    </li>
    <li>
      Adverse media coverage concerning the User in relation to money laundering, proceeds of crime or terrorist financing.
    </li>
  </ol>

  <p>
    Where DyorEX concludes, following its assessment, that a transaction is suspicious, it shall follow the guidance and instructions of the Financial Crimes Investigation Board (“MASAK”) and submit the information and findings obtained to MASAK or, where legally requested or subpoenaed, to the competent courts or authorities.
  </p>

  <h4><strong>5. Transaction Monitoring and Suspicious Transaction Reporting</strong></h4>

  <p>
    DyorEX shall have the right and, where applicable, the legal obligation to monitor transactions involving high-risk Users or transactions, or circumstances giving rise to suspicion of money laundering or terrorist financing. Transaction monitoring is an important instrument for risk assessment and the detection of suspicious activity. In this context, DyorEX may take the following measures:
  </p>

  <ol>
    <li>
      Reporting suspicious transactions to MASAK and/or other competent law-enforcement, judicial or administrative authorities;
    </li>
    <li>
      Requesting additional information and documentation from the customer; and
    </li>
    <li>
      Suspending, restricting or closing the customer’s account in accordance with applicable legislation.
    </li>
  </ol>

  <p>
    The measures listed above are not exhaustive. In order to fulfil the obligations prescribed by applicable legislation, User transactions may be monitored on a daily basis by the AML Compliance Officer, relevant Users and transactions may be reported internally, and an assessment may be conducted to determine whether the activity should be classified as suspicious.
  </p>

  <h4><strong>6. Know Your Customer Policy</strong></h4>

  <p>
    DyorEX shall establish and maintain internal procedures to determine the standards applicable to the prevention of the laundering of assets obtained from criminal and/or unlawful sources and to ensure compliance with its Know Your Customer (“KYC”) Policy.
  </p>

  <p>
    Before commencing transactions, DyorEX Users must complete an identity verification procedure and provide an official identity document approved or issued by a competent authority, such as a passport, national identity card and/or driving licence. DyorEX reserves the right to collect User identity information for the purposes of this AML Policy. Such information shall be processed and securely retained in accordance with applicable legislation and the DyorEX Privacy Policy.
  </p>

  <p>
    <strong>6.1.</strong> Under this AML Policy, DyorEX may request a secondary identity or address verification document issued or recognised by an official authority, such as a bank statement or electricity or water utility bill dated within the previous three months and displaying the customer’s full name and residential address.
  </p>

  <p>
    <strong>6.2.</strong> After verifying the accuracy of the documents and information submitted by customers, DyorEX reserves the right to request additional information and documentation from Users who are classified as high risk, potentially dangerous or suspicious.
  </p>

  <p>
    <strong>6.3.</strong> If a customer’s identity information has changed or the customer’s activities are considered suspicious, DyorEX may request updated documentation even where the customer’s identity was previously verified.
  </p>

  <h4><strong>7. Reporting</strong></h4>

  <p>
    In connection with the Services provided by DyorEX through the Platform or Platforms, transactions identified as suspicious following the necessary review due to indications of money laundering, proceeds of crime or terrorist financing shall be reported to MASAK in accordance with applicable legislation, regardless of the transaction amount.
  </p>

  <p>
    Natural persons carrying out suspicious transactions, their legal representatives, and managers or employees who fail to comply with applicable suspicious transaction reporting obligations may be subject to civil, administrative and criminal sanctions under applicable legislation.
  </p>

  <h4><strong>8. Anti-Money Laundering Compliance Officer</strong></h4>

  <p>
    The Anti-Money Laundering Compliance Officer is a DyorEX employee appointed to support and oversee compliance with this AML Policy. The Compliance Officer’s duties include the following:
  </p>

  <ol>
    <li>
      Overseeing the collection and verification of customer identity information;
    </li>
    <li>
      Establishing, reviewing and updating internal policies and procedures for the preparation, review and retention of all reports required under applicable legislation;
    </li>
    <li>
      Monitoring and analysing material deviations and unusual patterns arising from customer activity;
    </li>
    <li>
      Implementing a records management system for recording and retrieving documents, files, forms and daily session login and logout records; and
    </li>
    <li>
      Reviewing and updating risk assessments on a regular basis.
    </li>
  </ol>

  <p>
    By carrying out the duties listed above, DyorEX aims to ensure continuous compliance with this AML Policy and applicable legislation.
  </p>

  <h4><strong>9. Training, Updates and Internal Audit</strong></h4>

  <p>
    DyorEX fulfils its training-related obligations through personnel policies and procedures established to ensure effective internal governance and compliance with applicable legislation. In this context, DyorEX provides its personnel with regular training, including training on anti-money laundering procedures, and takes appropriate measures to ensure that relevant knowledge remains accurate and up to date.
  </p>

  <p>
    DyorEX conducts periodic internal reviews and audits to assess whether its activities comply with applicable legislation, internal policies and procedures, particularly Law No. 5549 on the Prevention of Laundering Proceeds of Crime, Law No. 6415 on the Prevention of the Financing of Terrorism, and the relevant regulations and communiqués.
  </p>
</div>


Policy on Combating Money Laundering and the Financing of Terrorism (AML Policy)

 <div> <div> <h3>Personal Data Processing and Protection Policy</h3> </div>

  <p>
    As <strong>Dyor Kripto Varlık Alım Satım Platformu A.Ş.</strong> (“DyorEX”), we would like to inform any person who accesses the DyorEX Platform or Platforms, whether as a registered member or without registration, and/or uses the content, products and services made available through them (the “User” or “you”) about the processing and protection of personal data through this Personal Data Processing and Protection Policy.
  </p>

  <h4><strong>1. Subject Matter</strong></h4>

  <p>
    Pursuant to Personal Data Protection Law No. 6698 (“KVKK”), all personal data relating to Users shall be processed by DyorEX in its capacity as Data Controller. The processing, protection and transfer of personal data shall be carried out with due care and safeguarded in accordance with the KVKK, the Constitution of the Republic of Türkiye, applicable international conventions and other relevant legislation.
  </p>

  <h4><strong>2. Definitions</strong></h4>

  <ol>
    <li>
      <strong>2.1. Processing of Personal Data:</strong> Any operation performed on personal data, whether wholly or partly by automated means or by non-automated means provided that such processing forms part of a data filing system, including the collection, recording, storage, retention, alteration, reorganisation, disclosure, transfer, acquisition, making available, classification or restriction of use of personal data.
    </li>
    <li>
      <strong>2.2. Law:</strong> Personal Data Protection Law No. 6698.
    </li>
    <li>
      <strong>2.3. Explicit Consent:</strong> Consent relating to a specific matter, based on adequate information and freely given.
    </li>
    <li>
      <strong>2.4. Data Subject:</strong> The identified or identifiable natural person whose personal data is processed.
    </li>
    <li>
      <strong>2.5. Personal Data:</strong> Any information relating to an identified or identifiable natural person.
    </li>
    <li>
      <strong>2.6. Special Categories of Personal Data:</strong> Personal data relating to race, ethnic origin, political opinions, philosophical beliefs, religion, religious denomination or other beliefs, appearance and clothing, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.
    </li>
    <li>
      <strong>2.7. Data Controller:</strong> The natural or legal person who determines the purposes and means of processing personal data and is responsible for establishing and managing the data filing system in which such data is systematically retained.
    </li>
    <li>
      <strong>2.8. Data Processor:</strong> The natural or legal person who processes personal data on behalf of and under the authority of the Data Controller.
    </li>
    <li>
      <strong>2.9. Data Filing System:</strong> A filing system in which personal data is processed according to specific criteria.
    </li>
    <li>
      <strong>2.10. Anonymisation:</strong> Rendering personal data incapable of being associated with an identified or identifiable natural person under any circumstances, even when matched with other data.
    </li>
    <li>
      <strong>2.11. Platform:</strong> The official website at <a href="https://www.dyorex.com" target="_blank" style="color: #d21e2b; text-decoration: underline;">www.dyorex.com</a>, DyorEX mobile applications operating on Android or iOS, and any other application or applications developed, published or operated by DyorEX.
    </li>
  </ol>

  <h4><strong>3. Purposes and Legal Grounds for Processing Personal Data</strong></h4>

  <p>
    DyorEX processes and protects Users’ personal data for specified, explicit and legitimate purposes and only to the extent necessary, in accordance with the KVKK and other applicable legislation. DyorEX acts in compliance with the principles of lawfulness, fairness and good faith when processing personal data.
  </p>

  <p>
    The purposes of personal data processing are clearly and specifically described in this Policy, the User Agreement forming an integral part of this Policy, and other relevant DyorEX policies and agreements, provided that such purposes are legitimate and lawful. DyorEX avoids processing personal data that is unnecessary or unrelated to the matters specified in this Policy and other agreements prepared by DyorEX.
  </p>

  <p>
    Personal data is retained only for the period required for the purposes for which it is processed and for the retention periods prescribed under the KVKK and other applicable legislation.
  </p>

  <h4><strong>4. Conditions for Processing Personal Data</strong></h4>

  <ol>
    <li>
      <strong>4.1.</strong> DyorEX processes personal data only where permitted under applicable legislation, where the Data Subject has provided valid explicit consent when required, and within the scope of the provisions set out in this Policy and the other agreements forming an integral part of it.
    </li>
    <li>
      <strong>4.2.</strong> Users who access and/or register with the DyorEX Platform or Platforms acknowledge that they have read and understood the User Agreement, Privacy Policy, Privacy Notice, AML Policy, Cookie Policy and this Policy. Acceptance of these documents shall not constitute a waiver of any mandatory rights granted to the User under the KVKK or other applicable legislation.
    </li>
    <li>
      <strong>4.3.</strong> Personal data may be processed without the Data Subject’s explicit consent where such processing is expressly permitted or required by law.
    </li>
    <li>
      <strong>4.4.</strong> Personal data may be processed where it has been made public by the Data Subject, provided that the processing is consistent with the purpose for which the data was made public.
    </li>
    <li>
      <strong>4.5.</strong> When processing special categories of personal data specified under Article 6 of Law No. 6698, DyorEX acts in accordance with the requirements of the applicable legislation. Special categories of personal data include data relating to race, ethnic origin, political opinions, philosophical beliefs, religion, religious denomination or other beliefs, appearance and clothing, membership of associations, foundations or trade unions, health, sexual life, criminal convictions and security measures, as well as biometric and genetic data.
    </li>
    <li>
      <strong>4.6.</strong> Pursuant to Law No. 6698, special categories of personal data may be processed in the circumstances specified below, provided that adequate measures determined by the Turkish Personal Data Protection Board are implemented.
    </li>
    <li>
      <strong>4.6.1.</strong> Special categories of personal data other than data concerning health and sexual life may be processed without explicit consent where expressly permitted by law. Personal data concerning health and sexual life may be processed without explicit consent only by persons subject to a confidentiality obligation or by authorised public institutions and organisations for the purposes of protecting public health, preventive medicine, medical diagnosis, treatment and care services, and the planning and management of healthcare services and their financing.
    </li>
  </ol>

  <h4><strong>5. Transfer of Personal Data</strong></h4>

  <p>
    DyorEX may transfer your personal data, in accordance with the purposes for which it is processed and subject to applicable legislation, to persons and organisations to whom disclosure is permitted or required by law, including competent public authorities, legally authorised private persons and organisations, project and programme partners from whom we receive services or with whom we cooperate in conducting our activities, domestic and international organisations, support and consultancy service providers, and independent audit firms.
  </p>

  <p>
    Your personal data may also be transferred to overseas service providers with whom DyorEX cooperates in connection with the operation of the infrastructure and information technology systems used by DyorEX, subject to the conditions, safeguards and transfer mechanisms required under applicable legislation and, where necessary, your explicit consent.
  </p>

  <p>
    All transfers of personal data shall be conducted through secure environments and subject to appropriate technical and administrative safeguards.
  </p>

  <h4><strong>6. Deletion, Destruction and Anonymisation of Personal Data</strong></h4>

  <p>
    Where the reasons requiring the processing of personal data cease to exist, personal data that has been lawfully processed shall be deleted, destroyed or anonymised by DyorEX, either ex officio or upon the request of the Data Subject, in accordance with applicable legislation.
  </p>

  <p>
    Upon expiry of the applicable retention periods prescribed under Law No. 6698 and other relevant legislation, DyorEX shall delete, destroy or anonymise personal data within the relevant periodic destruction period by using one or more of the methods specified under applicable regulations and secondary legislation.
  </p>

  <p>
    DyorEX reserves the right to decline a deletion, destruction or anonymisation request where it has a legal right or obligation to retain the relevant personal data under applicable legislation.
  </p>

  <h4><strong>7. Processing of Users’ Personal Data</strong></h4>

  <ol>
    <li>
      <strong>7.1.</strong> Your personal data may be processed for the purposes of establishing and performing agreements entered into with DyorEX; communicating with you regarding products and services obtained from DyorEX; providing effective customer and User support; conducting processing activities expressly permitted by law and fulfilling related legal obligations; responding to User requests and enquiries; carrying out marketing activities where the User has provided the required consent; verifying and improving financial transactions; retaining website and application login and logout records; providing Services to customers registered with the crypto asset and digital asset trading Platform; requesting information and documentation to protect account security; and notifying Users of changes to applicable legislation or to the rules and policies adopted by DyorEX.
    </li>
    <li>
      <strong>7.2.</strong> Personal data shall not be shared for independent commercial or marketing purposes with another person and/or organisation established in Türkiye or abroad without the User’s explicit consent, unless another valid legal basis applies under applicable legislation.
    </li>
    <li>
      <strong>7.3.</strong> DyorEX may request personal data again where necessary to provide Services relating to crypto asset purchase and sale transactions conducted through the Platform or Platforms, prevent unlawful financial flows, verify the User’s identity accurately and in accordance with applicable legislation, and fulfil KYC and AML obligations.
    </li>
    <li>
      <strong>7.4.</strong> Personal data collected verbally, in writing or electronically through DyorEX offices and operational areas, the official website, call centre, telephone calls, SMS records, email addresses, social media channels, mobile applications and similar means may continue to be processed and updated for as long as you use the relevant products and Services and/or for the applicable statutory retention periods.
    </li>
  </ol>

  <h4><strong>8. User’s Right to Obtain Information</strong></h4>

  <p>
    Pursuant to Article 11 of Law No. 6698, Data Subjects have the following rights in relation to their personal data:
  </p>

  <ul>
    <li>To learn whether their personal data is being processed;</li>
    <li>To request information where their personal data has been processed;</li>
    <li>To learn the purpose for which their personal data is processed and whether it is being used in accordance with that purpose;</li>
    <li>To learn the identity of third parties to whom their personal data has been transferred domestically or abroad;</li>
    <li>To request the correction of personal data that has been processed incompletely or inaccurately and to request that such correction be communicated to third parties to whom the personal data has been transferred;</li>
    <li>To request the deletion or destruction of personal data where the reasons requiring its processing cease to exist, notwithstanding that the data was originally processed in accordance with the KVKK and other applicable legislation, and to request that such action be communicated to third parties to whom the personal data has been transferred;</li>
    <li>To object to a result arising against the Data Subject as a result of the analysis of processed personal data exclusively through automated systems; and</li>
    <li>To request compensation for damage arising from the unlawful processing of personal data.</li>
  </ul>

  <p>
    By using the DyorEX Platform or Platforms, the User acknowledges that the User has been informed of the provisions set out above and has read and understood Articles 5 and 6 of Law No. 6698. Where explicit consent is required under applicable legislation, DyorEX shall obtain such consent separately, specifically and on an informed basis.
  </p>

  <p>
    You may submit applications concerning your personal data through one of the channels specified below, following verification of your identity: in person, through a notary public, by registered electronic mail, secure electronic signature or mobile signature, or by using an email address previously provided to DyorEX by the Data Subject and registered in DyorEX systems. Applications may be submitted to <strong><a href="mailto:kvkk@dyorex.com" style="color: #d21e2b; text-decoration: underline;">kvkk@dyorex.com</a></strong>.
  </p>

  <p>
    Applications shall be reviewed and answered by the DyorEX KVKK team within the statutory period prescribed under applicable legislation and, where possible, no later than thirty days from receipt.
  </p>

  <h4><strong>9. Final Provisions</strong></h4>

  <p>
    In the event of any inconsistency between this Policy and Law No. 6698 or other applicable legislation, the provisions of the KVKK and the relevant legislation shall prevail.
  </p>

  <p>
    DyorEX may amend this Policy at any time where necessary. Amendments shall become effective upon publication through the relevant DyorEX channels, unless otherwise stated.
  </p>

  <p>
    In the event of a dispute between the parties, DyorEX records may be relied upon as evidence to the extent permitted by applicable law. This provision shall not restrict any mandatory evidentiary or procedural rights available to the User.
  </p>
</div>



Personal Data Processing and Protection Policy

 <div> <div> <h3>KYC Policy</h3> </div>

  <p>
    <strong>Dyor Kripto Varlık Alım Satım Platformu A.Ş.</strong> requires access to and the collection of certain User data to ensure the proper operation, security and continuous improvement of its Services. In accordance with Google Play’s User Data Policy, we provide the following disclosure regarding the collection and use of such data:
  </p>

  <h4><strong>Data Collection and Use Disclosure</strong></h4>

  <ul>
    <li>
      <strong>Data Types:</strong> Images and files
    </li>
    <li>
      <strong>Purpose:</strong> To enable identity verification and the secure and efficient processing and retention of transaction records.
    </li>
    <li>
      <strong>Collection Scenarios:</strong> Such data may be collected when you upload documents for identity verification, retain transaction-related records or use features that require image or document processing.
    </li>
  </ul>

  <h4><strong>User Consent</strong></h4>

  <ul>
    <li>
      This application collects and transmits your images and files for the purposes of secure identity verification and transaction processing.
    </li>
    <li>
      You must provide your explicit consent before the collection of such data begins.
    </li>
    <li>
      To provide your consent, please read this disclosure and tap the “I Agree” button.
    </li>
    <li>
      If you do not wish to provide your consent, you may tap the “Decline” button. However, declining consent may restrict your ability to access or use certain features of DyoreX Exchange.
    </li>
  </ul>

  <h4><strong>Important Information</strong></h4>

  <ul>
    <li>
      Your consent requires a clear and affirmative action and will not be inferred from silence, inactivity or ambiguous conduct.
    </li>
    <li>
      Exiting this disclosure or closing the message will not constitute consent.
    </li>
    <li>
      DyoreX Exchange must obtain your consent before collecting or accessing your personal or sensitive User data, except where such processing is otherwise permitted or required under applicable legislation.
    </li>
  </ul>
</div>


KYC Policy

Use and Custody Agreement


    <div>
      <div>
        <h3>RISK DISCLOSURE FORM</h3>
      </div>

      <p><strong>RISK DISCLOSURE FORM</strong> This "Risk Disclosure Form" constitutes an integral part of the Customer Framework Agreement for Custody Services and the Pre-Contractual Information Form and has been prepared to inform the Customer of the risks associated with the custody services to be provided by Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (the "Company"). This Form was delivered to the Customer before the Customer signed the Customer Framework Agreement for Custody Services and was also sent to the Customer's registered electronic mail account.</p>

      <h4><strong>1. IMPORTANT NOTICE</strong></h4>
      <p>Digital Asset markets are decentralised and may not always be subject to legal regulation. Consequently, when using the services, Customers may not benefit from the protections afforded to customers receiving legally regulated financial services. Customers are responsible for knowing and understanding how Digital Assets are treated, regulated and taxed under the applicable laws and regulations. Transactions conducted in Digital Asset markets may generate profits; however, they also involve the risk of loss, including the risk of losing your entire deposited balance, including the principal amount. Therefore, before deciding to enter into any transaction, you must understand the risks that may arise in the market and make your decision by taking into account your financial circumstances and your level of knowledge of the relevant market. The Digital Asset Custody Services Framework Agreement may contain standard terms and conditions that could be considered contrary to your interests. Before accepting the Agreement, we recommend that you review these provisions and, where necessary, seek assistance from a legal and/or financial adviser regarding their legal and financial consequences. Please be advised that, upon approving the Agreement, you will be deemed to have accepted such provisions.</p>

      <h4><strong>2. RISK DISCLOSURE</strong></h4>
      <p>In addition to the matters set out in the "Customer Framework Agreement for Custody Services" to be executed with our Company, it is essential that you understand the matters stated below.</p>
      <p><strong>a.</strong> Digital Assets do not have a specific regulatory framework in Türkiye. However, pursuant to the Regulation on the Disuse of Crypto Assets in Payments issued by the Central Bank of the Republic of Türkiye, Crypto Assets may not be used directly or indirectly for payments.</p>
      <p><strong>b.</strong> The Customer acknowledges that Digital Assets are created, traded and transferred electronically and therefore constitute a digital representation of value, and that such Assets are not local currency, foreign currency, a payment instrument, a capital market instrument or a security.</p>
      <p><strong>c.</strong> Digital Assets are not covered by any guarantee, insurance or compensation fund. No guarantee, insurance or compensation coverage is provided in respect of these products by Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (the "Company") or by any regulatory or public authority. Any and all applicable legislation and similar administrative regulations issued or to be issued by the competent authorities shall apply to the account you open with our Company and to all transactions carried out through such account, and your account shall be brought into compliance accordingly.</p>
      <p><strong>d.</strong> Digital Asset transactions are subject to varying degrees of risk. Digital Asset markets and/or prices are volatile and may change instantaneously. Accordingly, as a result of price movements and fluctuations in the market, you may lose all or a substantial portion of the funds deposited with our Company. Customers must be aware that they may be adversely affected by such fluctuations and by any other changes in market activity.</p>
      <p><strong>e.</strong> Digital Asset products involve a high degree of risk and may not be suitable for every user. This Form is intended solely to provide general information; it neither provides information specific to each Customer's individual risk profile nor covers all risks arising from Digital Asset transactions.</p>
      <p><strong>f.</strong> Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (the "Company") makes no representation or warranty regarding the existence and/or availability of Digital Assets. The Company shall not be held liable if access to a Digital Asset that is the subject of a transaction or order is partially or entirely restricted at any time or if the relevant Digital Asset becomes unavailable. The Company reserves the right to suspend and/or terminate all or any part of its services.</p>
      <p><strong>g.</strong> Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (the "Company") makes no representation or undertaking that listed Digital Assets will continue to be traded on the market at all times. Any listed Digital Asset may, at the Company's sole discretion and without prior notice, be delisted or suspended from trading by the Company.</p>
      <p><strong>h.</strong> Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (the "Company") may cooperate with third parties providing digital asset, fiat currency and/or crypto-asset services in connection with the custody services it offers. The Company does not guarantee compensation for any losses that may arise where such a third party is exposed to cybersecurity risks in any manner, fails to perform wallet management properly, loses Digital Assets, crypto assets or funds, becomes insolvent or bankrupt, has its assets or asset values seized, made subject to an injunction or attachment, or ceases its operations.</p>
      <p><strong>i.</strong> The Customer must securely retain the password and/or other information used to access the Customer's digital wallet, the Customer's private key, and the 12- or 24-word seed phrase or recovery phrase. The Customer shall also assume full responsibility and liability for the creation, storage and maintenance of all backup keys associated with accounts created through wallet services.</p>
      <p><strong>j.</strong> The Customer is responsible for ensuring that the information provided in relation to transaction orders, the recipient wallet address and the amount of the relevant Digital Asset are complete and accurate. If a Digital Asset is transferred to a wallet address other than the intended address, Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (the "Company") cannot be held liable for the transaction, and all responsibility shall rest with the Customer who initiated the transfer. The Customer is also responsible for any incorrect or erroneous transfers resulting from information required during the transfer being entered incorrectly, incompletely or inaccurately, or not being entered at all, depending on the technical characteristics of the relevant Digital Asset. Once a transaction order submitted by the Customer has been executed by the Company, it cannot be invalidated, reversed or cancelled.</p>
      <p><strong>k.</strong> The Customer acknowledges the risk that an instruction may be delayed or invalidated due to transaction errors occurring on the Platform or system-related failures. The Customer acknowledges and accepts the existing and/or potential risks associated with using an internet-based platform, including, but not limited to, software or hardware problems, unauthorised access, spyware, computer viruses, errors, corruption, malicious software, phishing and other cyberattacks.</p>
      <p><strong>l.</strong> The Customer shall bear all tax liabilities arising under the applicable legislation in connection with any increase or decrease in the value of Digital Asset products and the custody of such products and shall be solely responsible for making any tax payments required by the competent authorities. In addition, the Customer shall be responsible for taxes, including value-added tax, that may arise from the services provided and the fees or commissions charged, and the Company may collect such taxes directly from the Customer's account.</p>
      <p><strong>m.</strong> Any opinions, price analyses or other information provided by Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (the "Company") through its digital channels or on the Platform do not constitute investment advice. The Company shall not be liable for any losses arising from transaction orders placed by the Customer in reliance on such opinions, forecasts or information. The Company has no obligation to provide advice regarding transactions you may conduct in the markets. You should take into consideration that any information communicated to you by the Company is not advisory in nature and may be incomplete or require independent verification. This Digital Asset Transactions Risk Disclosure Form is intended solely to inform the Customer of the general risks associated with custody services and may not cover all risks arising from Digital Asset custody services and their implementation. You should therefore conduct careful research before allocating your savings to investments of this nature.</p>
      <p>All fees and commissions applicable under the Customer Framework Agreement for Custody Services are specified on the Company's website and shall remain valid only for the periods stated therein. It is your responsibility to obtain information regarding such commissions, fees and expenses. Before commencing any transaction, you must obtain information about and agree to all commissions, other fees and expenses payable by you.</p>
      <p>I hereby acknowledge and declare that I have read and understood all of the matters set out above; that, without prejudice to my rights to claim compensation and initiate legal proceedings in respect of any losses arising from the fault or negligence of the Intermediary Institution and/or Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (the "Company") in the implementation of these principles, I have signed this "GENERAL RISK DISCLOSURE FORM FOR DIGITAL ASSET SERVICES AND ACTIVITIES" of my own free will; and that, upon subsequently signing the Agreement, I have received a copy of this Form.</p>
    </div>
    

Risk Disclosure Form


    <div>
      <div>
        <h3>DECLARATION OF PURPOSE AND INTENT FOR THE USE OF DIGITAL ASSETS</h3>
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      <p><strong>DECLARATION OF PURPOSE AND INTENT FOR THE USE OF DIGITAL ASSETS</strong></p>
      <p>I hereby declare that I do not and will not use my digital assets held with Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi in any transactions associated with money laundering or terrorist financing.</p>
      <p>I further declare that I will conduct all transactions carried out through Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi in my own name and for my own account, that I will be the ultimate beneficial owner of such transactions, and that I will not act on behalf or for the account of any other person.</p>
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Declaration of Purpose and Intent for the Use of Digital Assets


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      <div>
        <h3>DECLARATION OF EXPLICIT CONSENT</h3>
      </div>

      <p><strong>DECLARATION OF EXPLICIT CONSENT</strong></p>
      <p>You may access the Privacy Notice regarding the protection of personal data through our website. Please review the following consent statement together with the Privacy Notice available via the relevant link.</p>

      <p>Your personal data may be shared with and/or processed by the relevant public institutions and organisations and judicial authorities pursuant to the Law on the Protection of Personal Data, all regulations issued by the Financial Crimes Investigation Board of the Republic of Türkiye Ministry of Treasury and Finance, particularly those concerning customer identification and suspicious transaction reporting, and other applicable legislation. Your personal data may also be shared with and/or processed by our Company's direct or indirect parent company and/or controlling shareholder, direct or indirect affiliates and subsidiaries, domestic and/or international business partners, service providers, organisations from which services are obtained, and relevant third parties, where necessary for the performance of the agreement or under other circumstances that do not require explicit consent. Except for the circumstances specified above, we request your explicit consent in relation to the following matters:</p>

      <ul>
        <li>Conducting analyses through various channels, including the mobile application, website, call centre, meetings and social media, in order to anticipate the potential needs and requests of customers who benefit from our services; identifying customers' behavioural tendencies in accordance with relevant models; carrying out strategic planning and efficiency studies; conducting and announcing forecasting, marketing, promotional, prize draw, gift distribution, campaign and advertising activities through various channels; and providing personalised services to customers, with the aim of enabling our Company to provide its customers with the highest standard of service,</li>

        <li>Conducting surveys and market research in order to evaluate customer satisfaction regarding employees and to improve and develop our Company's activities,</li>

        <li>Carrying out the necessary activities and communicating offers for the cross-selling of existing or new products and services offered by our direct or indirect parent company and/or controlling shareholder, direct or indirect affiliates and subsidiaries,</li>

        <li>Performing controls relating to fraud prevention and cybersecurity and fulfilling the control obligations prescribed by the legislation applicable to our direct or indirect parent company and/or controlling shareholder, direct or indirect affiliates and subsidiaries, particularly obligations relating to internal systems,</li>

        <li>Ensuring compliance with foreign and international legislation, internal and external legal requirements and policies applicable to our Company's parent company, the direct and indirect affiliates and subsidiaries of such parent company, business partners where necessary, and foreign-resident entities included in the risk group of our Company's principal shareholder and its affiliates; implementing group-level risk management and audit practices; and ensuring effective corporate operations,</li>

        <li>Transferring personal data to domestic and/or international business partners, service providers, organisations from which services are obtained, and relevant third parties that provide services, particularly information systems and infrastructure support, to our Company's principal shareholder, its affiliates and foreign-resident entities included in the same risk group, for the purpose of ensuring that the products and services offered by our Company are provided efficiently and to the highest standards of quality and benefit,</li>

        <li>I hereby confirm that I have read the Privacy Notice and this explicit consent statement and consent to the processing and transfer, within the scope of the matters specified above, of my personal data—particularly my registered full name, contact details and information regarding the products and services I have obtained from our Company—to our direct or indirect parent company and/or controlling shareholder, direct or indirect affiliates and subsidiaries established or resident in Türkiye and/or abroad, as well as to our Company's domestic and/or international business partners, service providers, organisations from which services are obtained, and relevant third parties.</li>
      </ul>

      <p>You may change your preferences regarding the monitoring and processing of your personal data at any time.</p>
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Declaration of Explicit Consent

 <div> <div> <h3>PRE-CONTRACTUAL INFORMATION FORM REGARDING DIGITAL ASSET SERVICES</h3> </div>


  <p><strong>PRE-CONTRACTUAL INFORMATION FORM REGARDING DIGITAL ASSET SERVICES</strong></p>
  <p>This Pre-Contractual Information Form has been prepared by Dyor Kripto Varlık Alım Satım Platformu Anonim Şirketi (the "Company") for the purpose of providing you with information pursuant to Article 21 of Turkish Code of Obligations No. 6098, the Regulation on Distance Contracts for Financial Services and other applicable legislation.</p>
  <p>Capitalised terms not defined in this document shall have the meanings assigned to them in the Agreement.</p>
  <p>Following your signature or approval of this Pre-Contractual Information Form, you are advised to carefully review the provisions of the Agreement that will be provided to you and, where you consider it necessary, seek assistance from a legal and/or financial adviser regarding their legal and financial consequences.</p>
  <p>To benefit from the products and services relating to blockchain-based Digital Assets that will be provided by the Company under the Agreement, you will be required to sign or approve the agreements and relevant forms prepared in relation to such products and services.</p>
  <p>Once you declare that you have read, understood and accepted the information contained in this Pre-Contractual Information Form, the Agreement Regarding Digital Asset Services will be provided to you. The Agreement consists of 28 articles, and all provisions contained therein shall apply to you irrespective of the products or services from which you benefit under the relevant Agreement.</p>
  <p>In accordance with the relevant provisions of the Agreement, the Company shall have rights of pledge, lien, retention, set-off and deduction, limited to the receivables arising from the Agreement that you will sign or approve, over all present and future receivables held with the Company; all securities and negotiable instruments, including Digital Assets; all rights and receivables against the Company; and all ancillary rights and proceeds relating thereto, including periodic returns and, where such assets are sold, their sale proceeds.</p>
  <p>Upon receipt of a court order or a decision issued by a competent authority concerning your blockchain-based Digital Assets, the Company may, in accordance with the relevant decision, block or restrict the use of your Digital Assets and/or your custody account and/or digital wallet held with the Company.</p>
  <p>We hereby inform you that our Company will provide services only in relation to the Digital Assets announced on its website (<a href="http://www.dyorex.com/">www.dyorex.com</a>). If a Digital Asset other than those specified on our website is sent or transferred to your digital wallet held with our Company, a return procedure will be initiated in respect of the relevant Digital Asset. You shall be responsible for any losses that may arise from circumstances including, but not limited to, delays in the return process or the inability to return the relevant Digital Asset, and our Company shall have no liability in such cases. The Digital Assets in respect of which services will be provided by our Company may be determined freely by the Company.</p>
  <p>Upon the signature or approval of the Agreement, the fees applicable to the blockchain-based Digital Asset products and services from which you will begin to benefit under the Agreement may be unilaterally updated by the Company. You will be informed of any fee updates and detailed fee information through your registered email address and telephone number.</p>
  <p>Prior to the Agreement being provided to you following your signature or approval of this Form, all terms contained in the Form shall be deemed to have been negotiated between the parties and signed or approved by mutual agreement, and a copy of the Form shall have been delivered to you. This Form constitutes an annex to and an integral part of the Agreement. All detailed information other than the provisions and disclosures set out above is contained in the Agreement, which will be provided to you after you sign or approve this Form.</p>
  <p>If the Agreement is approved through a means of distance communication, you will not be required to execute a separate written agreement with our Company. A copy of this Form has been delivered to you and/or made available to you through a durable medium.</p>
  <p>I have read and understood the explanations set out above.</p>
  <p>The period granted to me to review this Pre-Contractual Information Form is sufficient.</p>
  <p>I hereby acknowledge and declare that I have signed this Pre-Contractual Information Form and received a copy thereof.</p>
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