Gate Kripto Varlık Alım Satım Platformu Anonim Şirketi (hereinafter referred to as "GateTürkiye") is committed to safeguarding the privacy and personal data of its Users with utmost care in compliance with the applicable personal data protection legislation. Ensuring the security of Users' personal data is of paramount importance and sensitivity for GateTürkiye and is processed and protected in accordance with the Constitution and relevant laws.

This Privacy Policy has been prepared in accordance with Article 10 of the Personal DataProtection Law No. 6698 ("KVKK") and the Communiqué on the Procedures and Principles for Fulfilling the Obligation to Inform. It aims to inform Users accessing and using services and products offered via the website and mobile applications of Gate Türkiye about methods of obtaining personal data, as well as data processing, transfer, retention periods, and users' rights. Under the Turkish Constitution and KVKK, it is a fundamental right of Turkish citizens to be informed about their personal data.

Since this document is a part of Gate Türkiye's User Agreement and Privacy Policy, we recommend reading it carefully before proceeding further. By opening an account with GateTürkiye and connecting to this form, you accept the terms of this document while using our websites, pages, features, mobile applications, APIs, and other online products and services ("Platform").

Data Controller

Under Article 3 of the KVKK, a data controller is defined as the real or legal person who determines the purposes and means of processing personal data and manages the place where data is systematically kept (data recording system). Gate Kripto Varlık Alım SatımPlatformuAnonim Şirketi is the data controller for personal data.

• Data Controller: Gate Kripto Varlık Alım Satım Platformu Anonim Şirketi
• Address: Maslak Mah. Maslak Meydan Sokak No:1/35 Kat:10, Beybi Giz Plaza, 34396 Sarıyer/ İstanbul
• Tax Office: Maslak Tax Office
• Tax Number: 3891735307

Processed Personal Data

The personal data listed below may be processed depending on the legal relationship or transactions between the User and Gate Türkiye. Users' data and login information will be matched according to their username and activities. Data collected through cookies will beprocessed anonymously in accordance with the Cookie Policy.

• Data collected through cookies
• Data collected for authentication steps
• Data obtained from companies and service providers with servers located abroad
• Demographic data
• Data obtained for social media tools
• Data collected for payment processes
• Data collected for membership processes
• Data collected for domestic service providers
• Data required by legislation
• Data collected by customer service specialists and call centers
• Data collected for international partners and affiliates
• Special categories of personal data
• Name and surname
• Parents’ names
• Date and place of birth
• Mobile phone number and email address
• Transaction history, access dates, and times
• IP address and WLAN (Wireless Local Area Network) information
• Device type and ID
• Usage tracking information
• Browser type and version
• Location information
• Occupation information
• Bank account numbers
• Address
• Photograph
• Visual and audio recordings (image/sound/video)
• Visual and audio recordings obtained during live (video) calls
• Identification details

Purpose of Processing Personal Data

Users' personal data will be processed by Gate Türkiye, as the data controller, in compliance with Article 20 of the Turkish Constitution and Article 4 of the KVKK, for the following purposes:

• Verifying the information provided by the User
• Within the scope of Article 25 of the Communiqué No. III-35/B.1, conducting identity verification through video calls during the remote customer identification process and recording these procedures
• Ensuring the security of User accounts and archives
• Enabling deposit and withdrawal transactions for the User
• Facilitating easy access to products and services provided by Gate Türkiye
• Allowing the User to start and continue transactions
• Keeping records of Platform logins and exits
• Enabling membership processes for Gate Türkiye’s websites and platforms
• Approving the User's account opened on Gate Türkiye
• Informing the User of new developments via SMS, email, etc
• Preparing documents that serve as the basis for Gate Türkiye’s business operations
• Resolving current or potential legal disputes
• Enabling the User to submit inquiries, opinions, and requests related to Gate Türkiye
• Conducting market research related to the Platform
• Performing data analytics to improve products and services offered on the Platform
• Verifying and executing financial transactions conducted on the Platform
• Fulfilling legal obligations under KVKK and other regulations
• Identifying visitors to Gate Türkiye’s websites
• Complying with anti-money laundering regulations
• Protecting Gate Türkiye's legitimate interests, such as preventing fraud and crimes
• Performing reasonable and necessary activities deemed appropriate by Gate Türkiyeunder KVKK

Transfer of Personal Data

Gate Türkiye transfers Users’ personal data to the following entities. These entities mayinclude domestic, foreign, or international individuals or institutions:

• Public institutions and organizations to which information must legally be disclosed
• Third parties providing services for Gate Türkiye's operations
• Individuals and organizations in cooperation with Gate Türkiye
• Entities providing cybersecurity or physical security services
• Entities providing support or consultancy services
• Third parties providing legal support and consultancy services
• Independent audit service providers
• Third parties providing storage, hosting, server, or cloud computing services in Turkey, EU countries, the USA, and the UK, subject to security measures and legal requirements
• Subcontractors involved in Gate Türkiye's products and services
• Third parties providing commercial or financial support and consultancy services
• Third parties supporting communication areas such as call centers, advertising, andpromotion for Gate Türkiye
• Employees and affiliates of Gate Türkiye

The primary purpose of Gate Türkiye in transferring User’s personal data is to maintain the highest quality of products and services offered to Users, fulfill legal obligations, and conduct activities in which it is involved.

Gate Türkiye takes all necessary administrative and technical measures to ensure the security of users' personal data when transferring them to foreign countries. Data transfer to foreign countries is carried out with the "explicit consent" of the User. Gate Türkiye conducts datatransfer activities in accordance with Article 8 of the Personal Data Protection Law(KVKK).

Methods and Legal Grounds for Collecting Personal Data

User’s personal data is collected via the Sites and, if necessary, from social media accounts and third-party platforms. Personal data may also be collected through SMS, verbal, written, video, voice recordings, or any other electronic medium.

Users’ personal data may be collected through the following methods:

• Completion of all forms, contracts, and other documents created electronically with the User’s consent or signature.
• Applications submitted by the User through communication channels.
• Interactions between the User and Gate Türkiye via social media or other publicly available platforms.
• Written or digital applications submitted by the User to Gate Türkiye and the reviewof legal records.
• Personal data may also be collected through video and audio recordings obtained via video calls conducted during the remote identification process.
• Provision of requested information by Users in physical environments.
• Use of electronic tools and acceptance of cookies while using products and services.
• Allowing tools to be created on the Sites.
• Other methods reasonably deemed appropriate by Gate Türkiye, provided they comply with the Personal Data Protection Law.

Personal data collected through the above legitimate methods can be processed or transferred under the basic principles outlined in the Personal Data Protection Law and the conditions and purposes specified in Articles 5 and 6 of the KVKK. The legal grounds for collecting personal data include, but are not limited to:

• Explicit provisions in laws.
• Explicit permission granted by laws.
• Situations explicitly regulated in laws.
• Consent explicitly provided by laws.
• Situations explicitly mentioned in laws.
• Negotiation, establishment, or execution of a membership agreement (KVKKArticle5/2-c).
• The necessity of data processing for the legitimate interests of Gate Türkiye, providedit does not harm the fundamental rights and freedoms of the data subject (KVKKArticle 5/2-f).
• Obtaining the explicit consent of the relevant individual.

Legal Basis

The legal grounds for Gate Türkiye to process, transfer, collect, and store personal datainclude, but are not limited to:

• Obtaining the explicit consent of the User.
• Users making their personal data public themselves.
• The necessity of processing personal data for the establishment or execution of acontract.
• Explicit provisions in applicable laws.
• The necessity of processing personal data for Gate Türkiye to fulfill its legal obligations.

Duration

In cases where the User is unable to provide consent due to physical impossibilities or where their consent lacks legal validity, processing personal data is deemed necessary for the protection of the life or physical integrity of the User or another individual. Similarly, dataprocessing may be necessary for the establishment, exercise, or protection of a legal right.

Gate Türkiye may process Users' personal data when necessary for its legitimate interests, provided that this does not harm the personal rights and freedoms of the User.

Personal data collected under the Personal Data Protection Law and other relevant legislation will be retained within the periods specified by competent authorities and laws, after which they will be subject to necessary procedures such as destruction or anonymization. The following table outlines the retention periods for specific types of personal data under applicable legislation:

Rights of Users Under the Personal Data Protection Law

Under Article 11 of the Personal Data Protection Law (KVKK), Users, as data subjects, have the following rights:

• To learn whether their personal data is being processed,
• To request information if their personal data has been processed,
• To learn the purpose of processing their personal data and whether it is being used in accordance with that purpose,
• To know the third parties to whom their personal data is transferred domestically or abroad,
• To request the correction of incomplete or incorrect personal data,
• To request the deletion or destruction of personal data,
• To request that third parties to whom personal data has been transferred be informed about the correction, deletion, or destruction of personal data,
• To object to the processing of personal data exclusively through automated systems if such processing results in a consequence unfavorable to the User,
• To demand compensation for damages incurred due to the unlawful processing of personal data.

To make a request regarding your personal data, you must submit a written applicationinaccordance with Article 13 of the Personal Data Protection Law and Article 5 of theCommuniqué on the Principles and Procedures for the Request to Data Controller, published in the Official Gazette dated March 10, 2018, and numbered 30356.

Gate Türkiye will conclude requests submitted in accordance with the relevant legislation within 30 days, in accordance with Article 13 of the KVKK, depending on the nature of the request. Your request will be accepted or rejected, and the response will be delivered to you in written or electronic form with reasoning. If the requested action incurs additional costs, the tariff determined by the Personal Data Protection Board will apply.

Users wishing to submit a request in accordance with the relevant legislation may choose one of the following methods:

• For identity verification-related requests, please deliver your application in person via notary public to Maslak Mah. Meydan Sokak No:1/35 Kat:10, Beybi Giz Plaza, 34396 Sarıyer/Istanbul.
• For other requests, please send your application via secure electronic signature, registered email (KEP), mobile signature, or the email address you used to open your Gate Türkiye account to kvkk@gate.com.tr.

This Privacy Policy may be reviewed periodically to reflect changes in Gate Türkiye’s operations or practices, as well as any amendments to the Personal Data Protection Law, toensure compliance with legal requirements, technology, and the business environment. Such changes (among others) may result in updates or revisions to this document. These updates will be available for review on the Sites and platforms. All personal information held will be subject to the most recent version of this document.