1. Parties

1.1. This User Agreement and Terms of Use (hereinafter referred to as the “Agreement”) is executed between Gate Kripto Varlık Alım Satım Platformu A.Ş. (hereinafter referredtoas“Gate Türkiye”), located at Maslak Mah. Büyükdere Caddesi Meydan Sokak Beybi GizPlazaNo:1/35 Sarıyer/Istanbul, registered with the Maslak Tax Office under tax number3891735307, the owner of the website with the domain name www.gate.com.tr and related mobile applications, and the User (hereinafter referred to as the “User”) who becomes a member by accepting the terms of this Agreement through the website www.gate.com.tr orGate Türkiye’s mobile applications (collectively referred to as the “Platform”).

1.2. Gate Türkiye and the User shall individually be referred to as a “Party” and collectively as the “Parties.”

2. Subject and Purpose of the Agreement

2.1. This Agreement, along with its annexes that are considered integral parts of theGateTürkiye User Agreement and Terms of Use, is prepared to define the rights and obligations of the Parties concerning the services provided as described in the “Agreement.”

2.2. The subject of this Agreement is the mutual rights and obligations of the Parties.

2.3. By accessing, downloading, using the Platform, or clicking the “I Accept” option to accept any service provided by the Platform, the User acknowledges, understands, and agrees to all terms and conditions set forth in this Agreement, as well as any other agreements they may be required to accept. Additionally, while using certain features of the Platform, theUsermay be subject to specific additional terms and conditions applicable to those features.

3. Definitions

Gate Türkiye	Refers to Gate Kripto Varlık Alım Satım Platformu Anonim Şirketi, located at Maslak Mahallesi Meydan Sokak Beybi Giz Plaza No:1/35 Sarıyer/Istanbul, which operates the cryptocurrency trading platform described in this Agreement.
Platform	Refers to the cryptocurrency trading system managed by Gate Türkiye, including the website used for cryptocurrency trading, all web pages provided through the website, internet applications, application programming interfaces (APIs), and mobile applications owned and operated by Gate Türkiye, with all legal rights belonging to Gate Türkiye.
User/Users	Refers to real or legal persons, or their representatives, who use the Platform by becoming members and benefiting from the provided Services, and who utilize the services of Gate Türkiye.
AML	Refers to anti-money laundering which should be construed to include counter terrorist financing and preventing the financing of the proliferation of weapons of mass destruction.
Applicable Laws and Regulations	Refers to provisions of laws, statutes, ordinances, rules, regulations, permits, certificates, judgments, decisions, decrees or orders of any Competent Authority applicable to Gate Türkiye or the Users.
CDD	Refers to customer due diligence.
Competent Authority	Refers to the Capital Markets Board and any other regulatory, judicial or law enforcement authority that has jurisdiction over the activities of Gate Türkiye, the Platform, or the Users.
Cryptocurrency	Refers to virtual assets with cryptographic properties produced using blockchain technology, with a unique structure, transferable exclusively between specific wallets, carrying the same value universally at the same time, priced and traded in markets formed by buyers and sellers, and having no physical elements.
Cryptocurrency Wallet	Refers to a computer file where cryptocurrency addresses and passwords are stored. Cryptocurrencies are transferred via wallets. Cryptocurrency wallets are categorized as hot wallets, which are online virtual wallets, and cold wallets, which are offline wallets with a physical presence.
Default Event	Refers to as any one of the following: a) failure by a User to meet any of its obligations under the Agreement, other policies and procedures of Gate Türkiye, and under takings given by the User or any other agreement between the User and Gate Türkiye; b) breach of this Agreement or other policies and procedures of Gate Türkiye by a User; c) misrepresentations made by a User; d) User is declared bankrupt or seeks a voluntary arrangement in respect of its debts or it is reasonably foreseeable that the User may be subject to bankruptcy or winding-up proceedings; e) User engages in or attempts to engage in any form of market abuse; or f) an event of an enforcement proceeding, sanction, formal notification or injunction against the User by a Competent Authority.
Financial Crime	Refers to any kind of criminal conduct relating to money, financial services or markets, including any offence involving: a) fraud or dishonesty; b) misconduct in, or misuse of information relating to, a financial market; c) handling the proceeds of crime; d) the financing of terrorism and acting in violation of the United Nations Security Council's sanctions resolutions to prevent the financing of the proliferation of weapons of mass destruction; or e) other activities intended to gain or protect financial benefits through deceitful and unethical means.
Inside Information	Refers to non-public, precise information that could reasonably impact the price of a Crypto Asset or the investment judgment of a reasonable individual or User in relation to that Crypto Asset.
Insider Dealing	Refers to the situation where any User or third party possesses Inside Information and uses that information by carrying out a transaction, for its own account or for the account of a third party, directly or indirectly, in relation to a Crypto Asset to which the Inside Information relates. Insider Dealing also includes the utilization of Inside Information to cancel or modify a transaction or order related to a Crypto Asset to which the Inside Information relates where transaction or order was placed before the relevant User possessed the Inside Information.
KYC	Refers to Know-Your-Customer.
Order	Refers to an instruction from the User placed on the Platformtobuy or sell a Crypto Asset.
PEP	Refers to Politically Exposed Person.
Personal Data	Refers to personal information that can be used to identify a real person.
Personal Data Owner	Refers to the individual whose personal data is processed under this Agreement.
Unlawful Disclosure	Refer to the disclosure of Inside Information to any other User or third party except where such disclosure is made in the normal exercise of an employment, a profession or duties.
User Account	Refers to the Gate Türkiye platform account that each User can create upon registering on the Platform, which identifies the User and allows them to manage one or more linked CryptocurrencyWallets under their account.
Service	Refers to the services offered through the Platform.
Personal Data Protection Law	Refers to Law No. 6698 on the Protection of Personal Data.

4. Rights and Obligations of the Parties

4.1. The User represents and warrants that they:

• are a natural person above 18 years of age or a legal person validly organized and in good standing with full legal capacity and the ability to act under the laws of the Republic of Turkey, and authorized to perform transactions on the Gate TürkiyePlatform;
• agreed to be bound by and comply with this Agreement;
• have not previously been suspended or terminated as a User of Gate Türkiye;
• do not already hold, or have access to, an account with Gate Türkiye;
• are applying for an account exclusively for their own use and not on behalf of any other person;
• have full power and authority to enter into the Agreement and in doing so will not violate any other agreement to which they are a party;
• are not located in, or a citizen or resident of any state, country, territory, or other jurisdiction where access to the Platform or the use of Gate Türkiye’s services may be restricted or prohibited by Gate Türkiye (For example, jurisdictions which maybe subject to economic sanctions);
• have not been named on any sanctions list and not included in the list of people whose assets have been frozen by the Presidential Decision or otherwise subject to any applicable sanctions;
• are fit and proper, and of sufficient good repute;
• have sufficient technical competence to use the Platform; and
• have not been convicted of an offence involving any crime or financial impropriety.

4.2. The User will only be granted access to the Platform if they meet all the criteriaoutlined in this Agreement, and only if Gate Türkiye is satisfied that the criteria under thisAgreement have been met. Without prejudice to the AML/KYC Policy, Users whoarePolitically Exposed Persons (“PEP”) or provides services as a CASP will require additional approvals to be onboarded as a User on the Platform.

4.3. These procedures and systems are implemented to ensure that only appropriate Users are granted access, thereby enhancing the safety and reliability of the Platform for all Users. By adhering to these eligibility requirements, Gate Türkiye endeavours to provide its Users with a stable and secure environment for trading in Crypto Assets.

4.4. The User is obligated to provide all documents and information requested by Gate Türkiye. The information requested by Gate Türkiye must be documented. If the User cannot document the information shared with Gate Türkiye or is found to have providedfalseinformation, Gate Türkiye reserves the right to take any necessary measures against the User. The User agrees and undertakes to accept these measures. The User will be liable for any direct or indirect damages resulting from non-compliance with the obligations outlinedinthisarticle.

4.5. Gate Türkiye only accepts fiat money in Turkish Lira (TRY) sent from bank accounts located in Turkey. The User may only use bank accounts registered under their own name. Deposits can only be made from a bank account bearing the same name as the User's account on Gate Türkiye. If the User attempts to transfer fiat money from a bank account belonging to another individual, they are solely responsible for any delays or failure in completing the transaction. The User should not attempt to deposit funds using ATMs. The Userac knowledges and declares that Gate Türkiye cannot be held liable for failed transactions caused by errors made by the User or their bank.

4.6. Cryptocurrency wallets have unique structures. Due to the characteristics of cryptocurrency wallets, information must be accurate, complete, and correct during transfers. The User is solely responsible for any errors or damages caused by incorrect entries. GateTürkiye cannot intervene in or be held responsible for incorrect transfers due to the technical features of cryptocurrency wallets or the unique structure of blockchain technology. Once the cryptocurrency transfer process is approved, it begins and cannot be canceled or revoked once completed. If a fee or service charge is incurred during the transfer, it will not be refunded. The User irrevocably releases Gate Türkiye from any liability for errors arising from the transfer process.

4.7. Any damages resulting from attempts to transfer cryptocurrencies not listedonGateTürkiye’s Platform or through blockchain networks not supported by the Platformare solelythe responsibility of the User.

4.8. Gate Türkiye operates as a cryptocurrency trading platform and is an independent entity. Users cannot hold Gate Türkiye liable for damages incurred on other platforms. TheUser declares and agrees that Gate Türkiye cannot be held responsible for damages incurred by Users in any subsidiaries of the parent company to which Gate Türkiye is affiliated.

4.9. Gate Türkiye may request information such as identity photos, selfies, residency documents, and bank details from Users for security purposes or to comply with regulations, including those of the Capital Markets Board and other public institutions. Gate Türkiye will verify these documents. If it is determined that the User is not compliant with regulations, legal texts, or internal company rules, Gate Türkiye may refuse membership or deny transactions on the Platform. Gate Türkiye is not liable for damages caused by the User'sf ailure to provide accurate information, delay in sharing information, or provisionofmisleading or incorrect information.

4.10. It is accepted that the User has sufficient knowledge and expertise regarding the types of Orders available on the Gate Türkiye Platform. The User may execute spot transactions using Market and Limit Orders on the Platform. Gate Türkiye is not liable for direct or indirect damages resulting from price slippage, particularly during times of reduced liquidity, widened spreads, or increased volatility. The User acknowledges that these are results of market dynamics and technical factors.

4.11. Gate Türkiye does not guarantee the immediate execution of deposits, withdrawals, transfers, or other transactions. Transactions are processed based on the technical infrastructure of the Platform. Gate Türkiye will make reasonable efforts to execute transactions promptly but is not liable for delays caused by market congestion or unforeseen circumstances outlined under the force majeure provisions of this agreement. TheUserirrevocably releases Gate Türkiye from any claims for damages resulting from such delays.

4.12. Technical errors may occur while the User conducts transactions on the Platform. Due to system errors or malfunctions, the User’s instructions may be delayed, invalidated, or unexecuted. Gate Türkiye may cancel, reverse, or delay User transactions to correct such errors. If the User suffers any losses due to these measures, they irrevocably releaseGateTürkiye from liability. Should any assets be incorrectly credited to the User's account due to technical errors, Gate Türkiye reserves the right to reclaim such assets. The User must promptly return any incorrectly credited assets; otherwise, Gate Türkiye reserves all legal rights.

4.13. Gate Türkiye unilaterally determines daily, weekly, and monthly Turkish Lira and Cryptocurrency deposit and withdrawal limits based on Applicable Law and Regulations, economic conditions and risk assessments. These limits may be increased or decreased without prior notice to the User. The User cannot hold Gate Türkiye liable for exercising its right under this clause or for the determined limits. The User hereby irrevocably releases and waives any claims regarding such limits

4.14. Transactions conducted through the User’s account are considered to have been performed by the User. The User is primarily responsible for the security of their account, account details, and passwords. The User acknowledges and declares that all transactions carried out via their account are performed by them, assumes responsibility for these transactions, and agrees not to raise any defenses or objections claiming otherwise. TheUserfurther agrees that claiming such transactions were not conducted by them cannot serve as an excuse or defense to avoid obligations under this Agreement.

4.15. The User is solely responsible for paying all taxes, fees, duties, levies, withholding taxes, reporting, and other collection processes arising from cryptocurrency trading potential increases or decreases in value.

4.16. The User is responsible for the accuracy and confidentiality of the information provided during registration and for ensuring the security of their login details and password throughout their membership. The User must protect their account credentials and other access information. Gate Türkiye cannot be held liable for any cyberattacks, thefts, or crimes arising from the User's technical infrastructure, system, or internet service provider. The User agrees not to hold Gate Türkiye responsible for any direct or indirect damages a rising from such incidents and irrevocably releases Gate Türkiye from liability. The User undertakes not to act on behalf of others under their account. Otherwise, the User acknowledges that GateTürkiye bears no legal or criminal liability to the User or third parties for unlawful actions performed through the User’s account.

4.17. The User must not engage in activities that damage the technical operations of GateTürkiye’s Platform or impose an unreasonable load on the system. The User agrees not to conduct data mining, web crawling, spidering, algorithmic trading, or robot-assistedtradingon the Platform. The User is prohibited from uploading harmful software, using the Platform for unlawful or unethical purposes, or creating databases or records using the Platform. TheUser agrees to take all necessary precautions to avoid such activities and to refrain from entering the Platform through automated means. In the event of a violation, Gate Türkiye reserves the right to seek legal remedies and initiate necessary actions.

4.18. Users must exercise caution to avoid fraudulent sites imitating Gate Türkiyebycopying its website and logo. The User must ensure that any links or references toGateTürkiye’s affiliated group companies or global sites are legitimate and not fraudulent. TheUser should verify the domain name and web address when accessing Gate Türkiye’s site or links. The User irrevocably releases Gate Türkiye from liability for damages caused by failing to take these precautions.

4.19. Gate Türkiye’s customer support does not request passwords, provide cryptocurrency addresses, or share bank account numbers for transfers. The User acknowledges this clause and agrees that Gate Türkiye is not liable for damages caused during customer support interactions.

4.20. The User becomes a member of Gate Türkiye’s Platform by accepting the terms and conditions of this Agreement using their email address, phone number, and password. EachUser may have only one Gate Türkiye account. By approving this Agreement, theUserdeclares that their account was created solely for personal use and not on behalf of a third party. Gate Türkiye reserves the right to reject account creation or suspend, terminate, or deactivate any Gate Türkiye User Account at its sole discretion. The User agrees not to claim compensation from Gate Türkiye for any direct or indirect damages arising from such actions.

4.21. Gate Türkiye does not guarantee uninterrupted or error-free operation of its Platform services. However, Gate Türkiye aims to ensure accessibility, functionality, and usability of its Platform. Gate Türkiye cannot be held liable for direct or indirect damages arising from the Platform’s inaccessibility or unavailability for any reason.

4.22. Gate Türkiye operates as a platform facilitating cryptocurrency trading and does not participate as a party to such transactions. Cryptocurrency prices are determined by supply and demand in the market, and Gate Türkiye does not interfere with price balances. Therefore, Gate Türkiye is not responsible for any losses or damages incurred due to price fluctuations. The User acknowledges the risks associated with investing in cryptocurrencies and assumes full responsibility for such risks, losses, and damages without holding Gate Türkiye accountable.

4.23. Gate Türkiye may share the User's information and documents with administrative authorities upon request by competent public institutions and authorities in accordancewithapplicable legislation.

4.24. The User must comply with the provisions under the Intellectual PropertyRightssection of this Agreement. If the User violates the terms under the Intellectual PropertyRightssection, Gate Türkiye reserves the right to unilaterally terminate this Agreement for just cause and may initiate legal proceedings to impose civil and criminal sanctions against the User.

4.25. Gate Türkiye's failure to exercise its rights and authorities under this Agreement at the time of their emergence does not imply a waiver of such rights and authorities, even implicitly. Gate Türkiye reserves the right to exercise its rights and authorities at anytimeincompliance with applicable laws.

4.26. Gate Türkiye has the authority to delete, suspend, restrict, terminate, or cancel theUser’s account without prior notification under the provisions of this Agreement. If there are no legal barriers, the User’s assets will be returned within 90 days after such actions. TheUser assumes responsibility for any direct or indirect damages arising from these actions and cannot hold Gate Türkiye liable.

4.27. Acceptance of fiat money or Cryptocurrency transfers made by the User or Orders related to transactions on the Platform is at the discretion of Gate Türkiye. TheUseracknowledges and declares that they cannot hold Gate Türkiye responsible and irrevocably release Gate Türkiye from liability in this matter

4.28. Gate Türkiye exclusively retains the right to determine the types of Cryptocurrencies it facilitates trading for on the Platform. Gate Türkiye may remove listed Cryptocurrencies from trading screens or add other Cryptocurrencies it accepts. Gate Türkiye bears no responsibility for these actions.

4.29. The User may terminate their membership with Gate Türkiye at any time. However, the termination of membership does not automatically cancel permissions granted for commercial electronic communications, notifications, or other consents given to Gate Türkiye. In such cases, the User must separately and individually revoke these permissions. GateTürkiye retains rights arising from services provided even after the User's membership termination.

4.30. Gate Türkiye may make changes at its discretion regarding fiat money or Cryptocurrency deposits and withdrawals without prior notice. The User cannot hold Gate Türkiye responsible for direct or indirect damages resulting from such changes. The User acknowledges and declares that they have read and understood the guidelines providedbyGate Türkiye for such transactions before performing any deposit, withdrawal, or transfer operations.

4.31. The User is prohibited from allowing third parties to use their account. If theUserpermits third-party use of their account, they assume full responsibility. Gate Türkiye reserves the right to seek compensation from the User and all related parties for damages incurred due to thirdparty use of the account. The User acknowledges and declares acceptance of this provision

4.32. The User is obligated to keep all information and documents shared with Gate Türkiyeup to date. In the event of changes to such documents, communication details, or personal information, the User must immediately inform Gate Türkiye. Gate Türkiye is not responsible for damages arising from the User’s failure to keep their information and documents current.

4.33. Gate Türkiye will exercise all due care and diligence to ensure the security of theUser’s data and account. Gate Türkiye shall not be held liable for any damages resulting from the User’s own actions or for damages not attributable to Gate Türkiye. TheUseracknowledges, declares, and undertakes that they irrevocably release Gate Türkiyefromliability in such cases.

4.34. Unless expressly agreed in writing with the User, Gate Türkiye does not guarantee the accuracy, completeness, or reliability of information obtained from the Platform, throughlinks to the Platform, or by other site-related methods (including but not limitedtoadvertisements). Gate Türkiye shall not be held liable for the User’s purchase of products, services, information, or materials based on such information. The risks arising from such information are solely the responsibility of the User.

4.35. Gate Türkiye may suspend, restrict, or terminate access to any portion or the entirety of the Platform that the User uses. It may also disable or cancel the User’s account or take any actions it deems necessary and reasonable, including but not limited to these measures. GateTürkiye may cancel, suspend, block, defer, or refuse to complete a transaction at its reasonable discretion to comply with legal obligations, protect its reputation, or enforce its rights. Additionally, Gate Türkiye may be required to cooperate with relevant state authorities and judicial authorities to freeze, seize, or transfer the User’s digital assets in their account toa designated account upon the request of competent legal authorities. The User acknowledges that Gate Türkiye shall not be held liable in such cases.

4.36. A User must comply with the following continuing obligations, as they apply to them:

• abstain from participating in illegal, unlawful, illegitimate or prohibitive activities such as market manipulation, market abuse, misleading acts or practices, fraudulent transactions, or actively engage in Financial Crime;
• abstain from using a web crawler or similar technique to access the Platform or to extract data;
• abstain from using Virtual Private Networks (“VPNs”) for the purposes of circumventing their regulatory restrictions;
• abstain from reverse engineering or disassembling any aspect of the Platform or GateTürkiye’s website or mobile application in an effort to access any source code and underlying ideas, concepts or algorithms;
• abstain from taking any action that imposes an unreasonable or disproportionately large load on the Platform, or detrimentally interfere with, intercept, or expropriate any system, data or information;
• abstain from depositing or sending Crypto Assets from and to wallet addresses that are suspected of Financial Crimes;
• abstain from infringing upon Gate Türkiye’s or any third party's copyright, patent, trademark, or intellectual property rights;
• create a unique password and maintain the security of their User Account by protecting their password from unauthorized access or use;
• maintain a valid email address and phone number and promptly update any information they have provided so that the information is complete and accurate at all times;
• prepare and maintain computers, software and other devices, telecommunication lines, and other communication environments which are necessary to use the Platform;
• prepare and maintain security systems suitable for their environment for use of thePlatform to avoid computer virus attacks, unauthorized access, information leakage, etc.;
• co-operate with Gate Türkiye and any Competent Authority during any investigation that is conducted in relation to the User’s conduct on the Platform;
• ensure that it makes all the notifications required under this Agreement and other policies and procedures in a timely manner;
• comply with undertakings given by the User, and any other agreement between the User and Gate Türkiye;
• comply with the procedural, operational, and technical requirements of Gate Türkiye’s systems and networks, as specified by Gate Türkiye from time to time which are necessary for the use of the Platform;
• ensure any information or documents relating to the User provided to Gate Türkiye, including but not limited to CDD information and documents, are kept up-to-date and are complete, true and accurate;
• where applicable, maintain required personnel and technical resources to ensuretheUser’s compliance, as required under this Agreement;
• pay such fees and charges as may be applicable to the User;
• indemnify Gate Türkiye in full in respect against all liabilities, costs, damages, and expenses arising from or relating from the User’s access to or use of the Platform. Such indemnity includes and extends to damages arising from direct acts or omissions (including without limitation breach of this Agreement and/or violation of anyApplicable Laws and Regulations) as well as any judgments, settlements, and expenses (including reasonable legal fees and other legal costs) arising from threatened or actual lawsuits, investigations, proceedings, or other claims between a User and Gate Türkiye or a third party relating to the use of the Platform;
• observe high ethical standards to preserve market integrity and act with honesty, integrity, fairness, due skill and care when conducting any activities on the Platform;
• refrain from any action or conduct which may impact or harm the reputation of GateTürkiye;
• continue to meet the eligibility criteria under this Agreement at all times as long as they are Users; and
• ensure to log out from the User Account at the end of each session when accessing thePlatform.

4.37. Users are responsible for all acts and omissions conducted on their User Account, whether or not any such acts and omissions are authorised.

4.38. Each User shall act as principal in respect of all of its interactions with Gate Türkiye and activities on the Platform.

4.39. In addition to the conditions provided for User’s conduct under this Agreement, User also shall abstain from engaging in any other activity which, in Gate Türkiye’s reasonable opinion, amounts to or may amount to market abuse or market manipulation, as provided under this Agreement and other policies and procedures of Gate Türkiye. Without limiting the generality of the foregoing, the User shall not:

• engage or attempt to engage in any illegal, unlawful, illegitimate or fraudulent act or engage or attempt to engage in any scheme to defraud, deceive or trick, in connection with or related to any Order or trade on or other activity related to Gate Türkiye;
• make or assist in placing any such Order with the knowledge that such Order is being placed on the Platform for the purpose of generating unnecessary volatility or creating a condition in which prices do not or will not reflect fair market values;
• engage in conduct that is in violation of any Applicable Laws and Regulations;
• access the Platform in any way which could be expected to bring disrepute upon the User or the Platform;
• place simultaneous buy and sell Orders that could potentially execute against each other, and it is a violation of this Agreement and other policies and procedures of GateTürkiye in a way that has the effect of misleading the market;
• make any misstatement of a material fact to Gate Türkiye, its board of managers, any committee thereof, or any director, officer, manager, or employee of Gate Türkiye; and/or
• place or accept buy and sell Orders at the same price, where the User knows or reasonably should know that the purpose of the Orders is to avoid taking a bonafidemarket position exposed to market risk (transactions commonly known or referred to as wash trades). Buy and sell Orders from different accounts with common beneficial ownership and/or affiliation that are placed with the intent to: (i) negate market risk or price competition, or (ii) achieve a favorable fee schedule and the resulting benefits, shall also be deemed to violate this obligation in relation to wash trades.

4.40. The User shall not:

• coordinate prices (including quotations), trades, or trade reports with any other User or any other person;
• direct or request another User to alter a price (including a quotation); or
• engage, directly or indirectly, in any conduct that threatens, harasses, coerces, intimidates, or otherwise attempts improperly to influence another User or another person.

4.41. Users are responsible for ensuring that they have:

• sufficient authority to transact business on the User Account;
• sufficient knowledge and understanding of their responsibilities under this Agreement and the Applicable Laws and Regulations at all times;
• sufficient knowledge, understanding and experience with respect to financial markets, Crypto Assets, and trading.

5. Powers, Enforcement, and Investigation

5.1. Gate Türkiye is empowered under this Agreement to supervise its market. Without limitation, Gate Türkiye is entitled, pursuant to various provisions in this Agreement, to:

• notify terms, conditions, rules, restrictions and procedures for registration of Users;
• notify terms, conditions, rules, restrictions and procedures to be complied with for admission and continued inclusion, of Crypto Asset(s), for trading;
• stipulate the time, mode and manner for execution of trades between Users and the trading and settlement procedures for Gate Türkiye’s market;
• determine fees and other charges payable to Gate Türkiye;
• supervise the market;
• initiate disciplinary proceedings against Users and impose disciplinary actions under this Agreement;
• impose suspension of trading under this Agreement;
• amend this Agreement and other policies and procedures of Gate Türkiye from time to time,
• undertake any measures or steps as may be prescribed or mandated by the Capital Markets Board, or any other competent authority in relation to Gate Türkiye, the listed Crypto Assets, the User Accounts or the Users;
• exercise one or more of the following powers:
  
  1. warnings;
  2. reprimands;
  3. training;
  4. qualification minimums;
  5. remediation plans;
  6. compliance audits;
  7. restitution;
  8. contractually agreed penalties;
  9. conditions on trading;
  10. trading prohibitions;
  11. suspensions and restrictions to trading;
  12. expulsions;
  13. cancellation of a User’s Orders and any outstanding instructions fromthat client;
  14. report any breaches to the Capital Markets Board; and
  15. criminal referrals;
• any other powers which Gate Türkiye may have under its constitutional documents, any other agreements which it has entered into with the Users; and
• any powers which it may have under Applicable Laws and Regulations.

5.2. Gate Türkiye is empowered by this Agreement to exercise supervision over Users and their activities. To ensure that the User complies with their obligations under the Agreement, other policies and procedures of Gate Türkiye and any Applicable Laws and Regulations or to maintain market integrity, Gate Türkiye may exercise a wide range of powers including but not be limited to surveillance, monitoring, review, examination, and investigation.

5.3. In exercise of these powers, Gate Türkiye, at its absolute discretion may, request the User to produce any accounts, documents, books, contracts, or any other records.

5.4. Gate Türkiye may, through its officers, employees or agents including auditors, investigate into the conduct and affairs of a User including, inter-alia:

• any suspected breach of this Agreement by a User regardless of how a suspected breach comes to its attention;
• any complaint against a User for any acts or omissions; or
• any matter which may affect fair and orderly trading.

5.5. Gate Türkiye has no obligation to notify a User that an investigation is underway.

5.6. In furtherance to the investigation rights under this Agreement, Gate Türkiye reserves the right to disclose information and documents provided by or relating to a User for the following purposes:

• for the purpose of enabling, it to institute, carry on or defend any proceedings including any court proceedings;
• as instructed, requested, demanded or ordered by any competent authority, or undercompulsion of law in any jurisdiction;
• for the purpose of enabling Gate Türkiye to discharge its functions having regard, in particular to the maintenance of high standards of integrity and fair dealing; or
• for any other purpose, with the consent of the person from whomthe informationwasobtained and, if different, the person to whom it relates in accordance with the Applicable Laws and Regulations.

5.7. Following an investigation pursuant to this Agreement, if Gate Türkiye determines, inits absolute discretion, that a breach of this Agreement has occurred and was committed by a User, Gate Türkiye may take a disciplinary action against such a User under this Agreement.

5.8. Gate Türkiye shall record any investigations and disciplinary action taken against aUser on a User’s compliance record.

5.9. Any breach of this Agreement and other policies and procedures of Gate Türkiye, the Agreement, or any Applicable Laws and Regulations by Users shall lead to investigation proceedings which may include referrals to the competent authorities.

5.10. The User shall be bound by any decision, finding or penalty resulting fromthe aboveproceedings.

5.11. Users must provide all reasonable assistance requested by Gate Türkiye and its delegates in relation to an investigation to Gate Türkiye’s satisfaction. The Users must provide assistance within the timeframes specified by Gate Türkiye.

6. Legal and Criminal Sanctions

6.1. In the event of a transaction mistakenly resulting in unjust enrichment for the User by means of the transfer of Cryptocurrency, this matter will be immediately communicatedtotheUser by Gate Türkiye through any communication method deemed reasonable (email, call, SMS, etc.). If the transfer is not returned by the User within 1 business day followingthenotification, Gate Türkiye may, without further notice, close, suspend, or indefinitely block access to the User’s account. Additionally, Gate Türkiye may adjust the User's account to reflect a negative balance equal to the mistakenly transferred amount of unjust enrichment. Gate Türkiye reserves the right to initiate the necessary legal and enforcement procedures if deemed necessary. Should Gate Türkiye incur any direct or indirect losses during this process, it reserves the right to claim compensation for such damages. The User acknowledges, declares, and undertakes to release Gate Türkiye from liability in this regard.

6.2. Even if Gate Türkiye identifies a violation of any article(s) in this Agreement by the User, the failure of Gate Türkiye to terminate the Agreement or take legal action against the User cannot be interpreted as a waiver of these rights by Gate Türkiye. All rights of GateTürkiye regarding identified violations are reserved.

6.3. The User declares and undertakes that they have read all statements issued by competent and regulatory authorities, as well as other public institutions, regardingCryptocurrencies and will follow any future statements.

6.4. The User undertakes to use the Platform in compliance with the laws and regulations of the Republic of Turkey. The User assumes all legal and criminal liabilities arising from any actions or transactions performed through their account on the Platform. Once Gate Türkiye identifies any illegal use, it has the right and authority to share all information related to the User with competent authorities. This does not constitute a violation of confidentiality, and Gate Türkiye cannot be held liable. Gate Türkiye cannot be held criminally liable for any illegal use of the Platform by the User.

6.5. The User is responsible for any tax obligations arising from the use of Cryptocurrencies, the Platform, or the services provided by Gate Türkiye. Gate Türkiye is not liable for any tax obligations resulting from the User’s gains or losses.

6.6. If Gate Türkiye identifies that the User is using or has enabled the use of the Platform for unlawful purposes, it reserves the right to pursue all legal remedies and take necessary administrative and security measures, such as freezing the account, permanently or temporarily deleting the account, or terminating the Agreement. Additionally, Gate Türkiye reserves the right to prohibit the User from opening another account indefinitely.

6.7. The User shall not engage in behavior or make statements, whether verbal, written, or visual, in any communication channel with Gate Türkiye employees, that violate public morals, honesty, or respect, or that abuse the goodwill of Gate Türkiye employees. Insuchcases, Gate Türkiye reserves the right to temporarily or permanently disable the User’s account for trading, suspend, freeze, or completely close the account, and pursue all legal remedies. Gate Türkiye cannot be held criminally or legally liable for enforcing this clause.

6.8. The User undertakes not to make any statements, using Gate Türkiye’s name and/or logo, that tarnish Gate Türkiye’s reputation, harm its commercial standing, or create unfair competition. This commitment applies to all forms of written and visual media, including social media platforms. If a violation of this article is detected, Gate Türkiye reserves the right to unilaterally terminate the Agreement, block, suspend, or permanently deletetheUser’s account without prior notice. Additionally, Gate Türkiye will seek all forms of compensation from the User for violating this clause. The User acknowledges, declares, and undertakes to waive all objections and claims related to the enforcement of this article in advance.

6.9. Gate Türkiye reserves the right to temporarily or permanently disable trading accounts identified as engaging in suspicious activities related to the Platform's workflowandtechnical security. It may suspend, freeze, or temporarily disable accounts associatedwithsuspicious transactions. Gate Türkiye may also implement asset freezes (blocks) on the User's account due to confiscation requests from judicial and/or administrative authorities or notifications from banks in response to such requests. Gate Türkiye cannot be held liable for damages incurred by the User as a result of this provision and shall not bear any legal or criminal liability.

7. Compliance

7.1. A User’s conduct on the Platform is subject to this Agreement and other policies and procedures of Gate Türkiye, and any Applicable Laws and Regulations.

7.2. By agreeing to the Agreement and opening a User Account, the User agrees that they will at all times comply with their obligations under the Agreement and other policies and procedures of Gate Türkiye and any Applicable Laws and Regulations.

7.3. Gate Türkiye maintains a stance of cooperation with competent authorities. GateTürkiye reserves the right to seize, freeze, and terminate Users’ Accounts and funds which are flagged or investigated by a competent authority or perform any acts as instructed, requested, demanded or ordered by a competent authority.

7.4. Gate Türkiye shall immediately report to the relevant competent authority, as pertinent, any User conduct which may comprise market abuse or manipulation, Financial Crime, or a breach of Applicable Laws and Regulations, and share the required details relating totheUserincluding but not limited to the Know-Your-Customer (“KYC”) information of the User and the User’s positions in the order book, in particular, details of any large positions held and changes to the position limits.

7.5. A User must comply or procure compliance with any request made by Gate Türkiye with respect to information provided by the User to Gate Türkiye, including providinganyexplanations or documents for verification.

7.6. Gate Türkiye may, by written notice, require information from a User about any matter which it considers may relate to this Agreement or to the integrity of the Platform, or which Gate Türkiye may require for the purpose of compliance with Applicable Law and Regulations.

7.7. A User must not knowingly, recklessly or carelessly provide Gate Türkiye with information (including information for the purpose of becoming a User) which is false, misleading or inaccurate.

7.8. Gate Türkiye reserves the right to disclose any information or documents in its possession or which it has obtained from a User to any person (including a competent authority) for the purpose of complying with any legal obligation of Gate Türkiye, other than an obligation imposed by contract, or for complying with Applicable Laws and Regulations.

8. Prohibited Conduct

8.1. Users are strictly prohibited from participating in, aiding, abetting, allowing, financing, supporting, or otherwise endorsing any behaviour involving market abuse, fraud or any conduct contrary to Gate Türkiye’s AML procedures or Applicable Rules and Regulations including but not limited to:

• engaging in any conduct that is calculated to, or that creates a significant risk of misleading the market including sharing, publishing, broadcasting or otherwise disseminating false or misleading information on Crypto Assets;
• engaging in any conduct amounting to market manipulation, including the placing of any Order for:
  
  • creating or executing fictitious transactions or place any Order for a fictitious transaction with knowledge of its nature;
  • place any Order on the Platform which has been pre-arranged (or discussed with another market participant prior to being placed on the Platform) for the purpose of creating an artificial price, fictitious trade, or another disruptive, fraudulent, non-competitive, or unfair impact on the Platform;
  • to give or potentially give a false or misleading interpretation of the supply and/or demand for a Crypto Asset; and/or
  • creating an abnormal or artificial price.
• engaging in any conduct that is calculated to create, or creates, a significant risk of, overloading or otherwise impairing the operation of the Platform.

8.2. Each User acknowledges and agrees that if any such techniques or activities are detected (or are reasonably suspected) through Gate Türkiye’s market surveillance systemorby any other means then any User found or reasonably suspected by Gate Türkiye to have participated, aided, abetted, allowed, financed, supported or otherwise endorsedanybehaviour will be subject to disciplinary action in accordance with this Agreement.

8.3. Each User agrees and acknowledges that User will not involve in any Unlawful Disclosure of Inside Information. “Unlawful Disclosure” shall refer to the disclosure of InsideInformation to any other User or third party except where such disclosure is made in the normal exercise of an employment, a profession or duties.

8.4. Each User acknowledges that User will not be involved in any situationofrecommending, counselling, procuring or otherwise facilitating or inducing another User or any third party to engage in Insider Dealing where the User possesses Inside Informationandon the basis of that Inside Information, recommends or induces another User or any third party to:

• carry out a transaction in relation to the Crypto Asset to which that Inside Information relates; or
• cancel or amend a transaction or order concerning a Crypto Asset to which that InsideInformation relates or induces that User or third party to make such a cancellationoramendment.

8.5. The User shall not engage in any trading, practice, or conduct on the Platform that:

• demonstrates an intentional or reckless disregard for the orderly executionoftransactions; or
• is, of the character of, or is commonly known as “spoofing” (bidding or offering with the intent to cancel the bid or offer before execution).

8.6. Users agree and acknowledge that Users shall not:

• engage or attempt to engage in Insider Dealing;
• recommend that another User or any third party engage in Insider Dealing or induce or otherwise facilitate another User or any third party to engage in Insider Dealing; or
• engage or attempt to engage in Unlawful Disclosure.

9. Default Rules and Disciplinary Actions

9.1. Gate Türkiye defines a Default Event as any one of the following:

• failure by a User to meet any of its obligations under the Agreement and other policies and procedures of Gate Türkiye, undertakings given by the User or any other agreement between the User and Gate Türkiye;
• breach of this Agreement or other policies and procedures of Gate Türkiye by a User;
• misrepresentations made by a User;
• User is declared bankrupt or seeks a voluntary arrangement in respect of its debts or it is reasonably foreseeable that the User may be subject to bankruptcy or winding-up proceedings;
• User engages in or attempts to engage in any form of market abuse; or
• an event of an enforcement proceeding, sanction, formal notification or injunction against the User by a Competent Authority.

9.2. Gate Türkiye may, at its absolute discretion, declare the relevant User as a defaulter on the occurrence of a Default Event. Declaration of a User as a defaulter shall be made by email to the defaulter.

9.3. Upon declaring a User as a defaulter, Gate Türkiye may initiate, taking into account the severity of the Default Event, inter-alia, any of the following disciplinary actions:

• Issuing a written warning to the defaulter;
• requiring the defaulter, via a notice, to provide any information or document within a specified time to assist Gate Türkiye in its investigation of the Default Event;
• requiring the defaulter, via a censure or a written notice, to remedy the Default Event, where possible or desirable by Gate.TR in its sole discretion, within the time it specifies;
• cancelling some or all Orders or transactions of the defaulter;
• selling some or all of defaulter’s Crypto Assets to the credit of the defaulter's UserAccount;
• suspending or terminating the defaulter’s access to the Platform;
• blocking the defaulter’s access to their User Accounts;

9.4. Gate Türkiye reserves the right to report any Default Event and any disciplinary action by Gate Türkiye in respect of any such Default Event to the relevant Competent Authorities. Gate Türkiye will not, and has no obligation to, notify a User before reporting any Default Event to any of the Competent Authorities.

10. Suspension or Termination of User Access

10.1. Gate Türkiye may at its absolute discretion, and without liability, suspend or terminate access to, and the use of, the Platform to any User, for any reason, including but not limited to where:

• the User becomes a defaulter;
• Gate Türkiye is required to do so under any Applicable Laws and Regulations or by the order of any other Competent Authority;
• Gate Türkiye has concerns about the security of a User Account, or Gate Türkiye suspects that the User Account is being used in a fraudulent or un authorized manner (including when the User notifies Gate Türkiye of the same);
• the User ceases to meet the eligibility criteria mentioned under this Agreement;
• the User’s conduct on the Platform is determined by Gate Türkiye to be inconsistent with, or detrimental to, the operation and maintenance of a fair and orderly market on the Platform;
• the use of a User Account is subject to any pending litigation, investigation, or government proceeding and / or Gate Türkiye perceives a heightened risk of legal or regulatory noncompliance associated with a User's conduct on the Platform;
• the User takes any action that may circumvent or attempts to circumvent our controls, such as opening multiple User Accounts, abusing promotions which we may offer from time to time, or circumventing suspensions and terminations through any other method;
• the User has actually or potentially infringed the rights of any other Users of thePlatform; or
• the User’s act or omission, in Gate Türkiye’s opinion impairs or prejudices the good will or reputation of Gate Türkiye;

10.2. In the event of suspension or termination of a User access to, and use of, the Platform:

• all Open Orders in respect of that Users may be cancelled;
• all transactions shall continue to be binding on such User, and the terms of such transactions shall be unaffected by such suspension or termination; and
• any access credentials attributed to the User may be disabled and access to Platform removed.

10.3. The suspension or termination imposed by Gate Türkiye may be immediate or from a date specified and for such period as may be decided in the sole discretion of Gate Türkiye.

10.4. Gate Türkiye shall endeavour to notify the Users by email of a decision to suspend or terminate their access to, and use of, the Platform.

10.5. Gate Türkiye may revoke a suspension if it is satisfied that the reason for suspension has been remedied. Where the violation has not been remedied, Gate Türkiye may further extend the period of suspension.

10.6. The User who has been subject to suspension or termination shall remain subject to this Agreement and other policies and procedures of Gate Türkiye in respect of acts and omissions while they were registered as a User and in respect of any investigation or disciplinary proceedings relating thereto. This includes the obligation to pay for outstanding fees or other sums due by the User to Gate Türkiye or another User which are yet to be settled.

10.7. Gate Türkiye shall terminate a User’s access to the Platformpermanentlyandimmediately upon the termination of the Agreement.

11. Penalties

11.1. In the event of a violation of any of this Agreement or other policies and procedures of Gate Türkiye, the User shall be subject to penalties as determined by Gate Türkiye.

11.2. The penalties for the violation of this Agreement and other policies and proceduresofGate Türkiye may include but are not limited to, suspension or termination of the User'sAccount, or any other action deemed appropriate by Gate Türkiye.

11.3. The User acknowledges and agrees that Gate Türkiye may, at its sole discretion, modify the penalties for the violation of this Agreement and other policies and procedures of Gate Türkiye from time to time.

11.4. The User shall be notified of any changes to the penalties for the violations of this Agreement and other policies and procedures, as and when they occur.

12. Services Provided by Gate Türkiye

12.1. The cash belonging to the User is held in partner banks which are Türkiye Cumhuriyeti Ziraat Bankası Anonim Şirketi, Türkiye Vakıflar Bankası T.A.O., Fibabanka Anonim Şirketi, and Şekerbank T.A.Ş.

12.2. The cash and Cryptocurrencies belonging to the User are kept separately from Gate Türkiye’s assets and are designated in bank accounts opened explicitly in the name of theUser, clearly indicating ownership by the User, and are not used for purposes other than intended use.

12.3. Gate Türkiye conducts the User's cash transfers through partner banks. Gate Türkiye does not accept cash from the User in person and does not deliver cash to the User in person. These cash and fiat currency services are provided by a third-party service provider underservice agreements and policies, and the User acknowledges and declares that Gate Türkiye has no responsibility for these services.

12.4. All Orders from the User are received through Gate Türkiye’s website and mobile applications, as reported to the Capital Markets Board by Gate Türkiye. Orders are not received through other channels or via different social media platforms.

12.5. All Orders from the User are logged and recorded electronically by Gate Türkiye, with the necessary electronic log records and electronically stored data showing the date, time, and source of the order. These records cannot be altered or falsified.

12.6. Gate Türkiye does not provide any absolute return guarantees or commitments to protect against losses to its Users at any time.

12.7. Gate Türkiye does not organize promotional campaigns that promise specific returns or direct investments in one or more Cryptocurrencies. Additionally, Gate Türkiye does not run promotional campaigns that provide benefits or advantages to individuals who bring customers to the Platform or to the users they bring, by any method.

12.8. In transactions where Gate Türkiye is the counterparty to the User, sales are made only up to the amount of Cryptocurrency available in Gate Türkiye's Cryptocurrency Wallet. For transactions matched between Users, Gate Türkiye is responsible for ensuring that the Cryptocurrencies involved in the transaction are available in the relevant accounts and transferred to the respective parties

12.9. Gate Türkiye does not exercise any right of disposition over the Cryptocurrenciesorcash belonging to the User for its own benefit or for the benefit of third parties.

12.10. Gate Türkiye does not provide services involving borrowing of Cryptocurrencies, transactions that result in lending to the User, or leveraged transactions.

13. Protection of Personal Data and Privacy

13.1. Gate Türkiye undertakes to strictly maintain the confidentiality of the information provided to it, to treat this information as a trade secret, and to take all necessary measures and exercise all due diligence to ensure and maintain confidentiality and prevent any part or entirety of the confidential information from falling into unauthorized hands.

13.2. Gate Türkiye pledges to collect and protect Users' personal data in compliance with the Personal Data Protection Law and not to use the personal data obtained from the User for any purpose other than the fulfillment of the purpose of the relationship between the Parties, either directly or indirectly. Gate Türkiye further undertakes not to share, process, or transfer the User's personal data to any institution or individual without the explicit consent of theUser and to ensure that only the necessary personnel access personal data to the extent required. Gate Türkiye may engage third-party service providers, in accordancewithApplicable Law and Regulations, in order to maintain its operations. In this context, depending on the nature of the service provided, personal data and/or transaction data of the User may be shared with such service providers, limited to what is necessary for the performance of the relevant service. By accepting this Agreement, the User acknowledges, declares, and undertakes that such data transfers may be carried out solely to the extent required by the service and in compliance with the Applicable Law and Regulations.

13.3. Gate Türkiye's Personal Data Protection Policy, Privacy Policy, Cookie Policy, Clarification Text, and Explicit Consent Statement accessible via the Platform constitute integral parts of this Agreement. Users may review these documents on the Platformorcontact Gate Türkiye’s customer support team to obtain more comprehensive information regarding personal data. Reviewing these documents and obtaining more detailed information is strongly recommended by Gate Türkiye. Despite all measures and legal precautions, GateTürkiye cannot be held responsible for the use, theft, or processing of personal data for any reason beyond its knowledge and control. The User acknowledges and declares that they irrevocably waive any claims against Gate Türkiye in this regard.

13.4. Gate Türkiye undertakes to keep all information and data belonging to the User confidential and to take all necessary measures to ensure confidentiality. However, information and documents requested by competent authorities of the Republic of Turkey can be disclosed to these authorities under laws, decrees, and other relevant legislation. Additionally, information about Users may be disclosed to third parties under the following circumstances, outside the scope of confidentiality obligations:

• In cases required by legislation,
• In cases related to the fulfillment and implementation of the Agreements between the Parties,
• In cases where information is requested about Users during an investigation or inquiry conducted by competent administrative and/or judicial authorities in compliancewithprocedural rules,
• In cases where providing information is necessary to protect the rights or security of Users

The situations listed above do not constitute a violation of confidentiality, and Gate Türkiye cannot be held liable for any direct or indirect damages that may arise.

13.5. The Parties mutually acknowledge the rights and obligations arising from the Personal Data Protection Law No. 6698 and agree to act in compliance with this law through this Agreement.

13.6. Within the scope of its collaboration with third parties, Gate Türkiye may provide links to other websites or applications within the Platform, redirect Users to third-party websites or applications, or publish their forms. It may also, under its agreements, publish its advertisements on different platforms belonging to third parties and include links and forms. In such cases, Gate Türkiye cannot be held responsible for the privacy and cookie policies or any other content on the sites and applications accessed by Users belonging to third parties. Establishing partnerships with other companies or organizations does not imply that GateTürkiye has a relationship with those companies or organizations.

14. Force Majeure

14.1. Force Majeure refers to events beyond the control of the Parties, which are unforeseen/unforeseeable by the Parties, or even if foreseen, the severity of their consequences could not be known, and which cannot be eliminated by the Parties. Therefore, events that may occur in Turkey or the country/countries where the User conducts their transactions, which may significantly impact activities, including but not limited to:

14.2. Economic, social, or political disturbances such as riots, uprisings, mobilizations, invasions, embargoes, government interventions, regional or global wars, strikes, lockouts, labor actions, or boycotts,

14.3. Cyberattacks, communication issues, infrastructure and internet failures, system-related improvement or renewal works and disruptions caused by them, power outages, and other unforeseen technical or human factors,

14.4. Natural disasters such as fires, explosions, storms, floods, earthquakes, migrations, epidemics, or other natural calamities,

14.5. National, regional, or global economic crises and fluctuations, extraordinary market conditions, restrictions that may be imposed by Turkey or other countries on cryptocurrency or foreign exchange regimes, commodity and precious metal markets, as well as legal regulations in Turkey and other countries, actions of public authorities, or other unforeseeable events that cannot be overcome even with prior anticipation and due diligence.

14.6. These events are defined as Force Majeure.

14.7. The User acknowledges, declares, and undertakes that due to the Force Majeure events mentioned above, but not limited to them, the User cannot hold Gate Türkiye liable for failure to fulfill its obligations under this Agreement, and consequently, the User will not claim any direct or indirect compensation under the name of damages/losses fromGate Türkiye. GateTürkiye reserves the right to take certain measures regarding cryptocurrency transactions in the event of a Force Majeure situation. The User, who suffers direct or indirect damages or incurs any expenses due to such measures, cannot hold Gate Türkiye liable for such damages and expenses. The User's obligations may be suspended during the Force Majeure period.

15. Intellectual Property Rights

15.1. The brand and logo of Gate Türkiye, along with all text, designs, domain names, trade dress, slogans, software codes, interface content, drawings, algorithms, videos, and all other materials, business models, methods, and any other content that may give rise to intellectual property rights on the Platform, are the exclusive intellectual property of Gate Türkiye.

15.2. The User may not share, distribute, reverse engineer, copy, display, reproduce, or create derivative works from Gate Türkiye's intellectual property rights or the Platform with out prior written permission from Gate Türkiye.

15.3. The intellectual property rights stated in this clause are unlimited in nature, andGateTürkiye has not waived any of its intellectual property rights. The User agrees, declares, and undertakes not to act contrary to this provision. Gate Türkiye reserves the right to take all legal actions, including but not limited to measures concerning User Accounts, against Users or related persons found to have violated these rights. The User is obligated to compensate Gate Türkiye and/or the relevant third party for all direct and indirect damages and expenses incurred.

16. Fees

16.1. Within the framework of the services provided by Gate Türkiye, the company has the right to charge Users commissions and fees at rates determined from time to time at its sole discretion which are available for review on Gate Türkiye’s official website at: https://www.gate.tr/tr/fee.

16.2. The fees and commissions to be paid by Users are listed on the relevant pages of thePlatform.

16.3. Gate Türkiye reserves the right to change the types, amounts, and rates of these fees and commissions at any time without prior notice. Such changes will take effect once announced on the Platform.

16.4. Before starting transactions on the Platform, the User must review the fees, commissions, and expenses payable, as stated on the relevant pages, and obtain information about them. The Parties must agree on these fees, commissions, and expenses. If these fees, commissions, or expenses are not expressed in monetary terms, the User must request the necessary information from Gate Türkiye.

17. User Feedback and User Inquiries

17.1. When the User contacts Gate Türkiye, they must provide their name, email address, Gate Türkiye account information, and any other details Gate Türkiye employees may require to identify the relevant notification, question, or complaint.

17.2. After contacting Gate Türkiye, the User may be offered a solution proposal. If theUser accepts the solution proposal, it will be binding on both Parties. Providing a solution proposal or offer by Gate Türkiye does not imply that Gate Türkiye accepts responsibilityforthe issue. The User undertakes to act with this understanding.

17.3. If the User encounters a problem, they must first contact Gate Türkiye’s CustomerSupport Unit to resolve the issue. If the User believes the issue remains unresolved, they should send an email explaining the nature of the issue, how they expect Gate Türkiyetoresolve it, and any other relevant details. The User will receive a response via email within a reasonable time, depending on the workload.

17.4. Response times from the Customer Support Unit to Users may be significantly delayed, especially during periods of high market fluctuations and volume changes. Under no circumstances will Gate Türkiye be held liable for damages allegedly caused byserviceinterruptions, transaction delays, or the inability of the Customer Support Unit to respond promptly. The User acknowledges and declares that they irrevocably release Gate Türkiye from liability in accordance with this clause.

17.5. Users can make a complaint through the Gate Türkiye’s website by submitting a ticket form here https://www.gate.tr/myaccount/tickets, in writing by letter to MaslakMah. Maslak Meydan Sokak No:1/35 Kat:10, Beybi Giz Plaza, 34396 Sarıyer/İstanbul, or via email at destek@gate.com.tr, or live chat on the Gate Türkiye’s website. Gate Türkiye shall not impose any fees or charges for the submission or handling of any complaints.

17.6. Any person may lodge a complaint with Gate Türkiye in accordance with Gate. Türkiye’s Complaints Handling Policy, in relation to any aspect of Gate Türkiye’s operation of the Platform. Gate Türkiye will address such complaint in accordance with the ComplaintsHandling Policy or procedures, which is published on the Platform.

18. Consultancy and Advice

18.1. Gate Türkiye does not provide Users with any investment, portfolio management, legal, accounting, tax, or other consultancy services, nor does it offer consultancy on trading techniques, models, algorithms, or business plans, even upon request.

18.2. Gate Türkiye does not accredit, supervise, audit, or evaluate any third party that may provide or claims to provide any of the aforementioned services.

18.3. Any information, charts, images, content, or documents displayed on the Platform provided by Gate Türkiye do not constitute investment advice, professional advice, consultancy, guarantees, or commitments of any kind.

19. Evidence Agreement

19.1. Any verbal or written communication between the User and Gate Türkiye’s customer support unit or any Gate Türkiye employee will be recorded and may be used as evidence in the event of a dispute.

19.2. In disputes arising from this Agreement between the Parties, data maintainedbyGateTürkiye, e-archive records, all electronic information, ledgers, documents, electronic records of customer transactions, microfilms, microfiches, correspondences, and any other data, without limitation, will be considered valid, binding, conclusive, and exclusive evidence.

19.3. The User acknowledges, declares, and undertakes that this clause constitutes an evidence agreement under Article 193 of the Turkish Code of Civil Procedure No. 6100.

20. Disclaimer of Liability and Risk Disclosure

20.1. Gate Türkiye is not responsible for any content, including pricing and statistics provided on its Platform. All content on the Platform is derived from third parties and publicly available sources. This data, reports, and analyses are processed directly by software that operates without regulation or guidance and presented objectively to Users and visitors. Gate Türkiye makes no guarantees about the absolute accuracy of the content published on the Platform. All content is provided for informational purposes only and does not constitute investment advice. The User acknowledges that they cannot claim any direct or indirect compensation from Gate Türkiye for damages incurred due to such content or data.

20.2. The Platform is accessible solely for the products and services offered byGateTürkiye. Gate Türkiye provides the infrastructure to facilitate the trading of cryptocurrencies on its Platform but does not guarantee the completion of transactions or the executionofOrders placed on the Platform. Prices are determined entirely by the supply and demand dynamics for the respective cryptocurrency among transacting parties. Gate Türkiye does not set the prices that appear on the Platform. Gate Türkiye is not responsible for any direct or indirect damages, including but not limited to financial losses, loss of profit, income loss, consequential damages, positive damages, material damages, or business losses incurred by the User due to the use or inability to use the Platform. Similarly, the User cannot holdGateTürkiye liable for any reason.

20.3. Due to the significant risks associated with cryptocurrency trading and the influenceoftechnology and international markets, Gate Türkiye does not guarantee the availability of any specific type of cryptocurrency on its Platform. Gate Türkiye reserves the right to discontinue providing services related to a specific type of cryptocurrency on the Platform. If GateTürkiye ceases to support or provide services for a specific cryptocurrency, it will make reasonable efforts to inform Users. In such cases, Users may not be able to convert the respective cryptocurrency into another currency but will be offered the option to transfer the cryptocurrency to another User, Platform, or third-party site. If the User decides to transfer the cryptocurrency to another User, Platform, or third-party site, Gate Türkiye will not be liable for any expenses incurred by the User.

20.4. Gate Türkiye is not responsible for any cryptocurrency transferred from its Platformtoanother site, device, platform, wallet, or user. It is also not liable for any cryptocurrency sent to its wallets on the Platform that is not listed for trading. Gate Türkiye is not liable for any cryptocurrency sent to incorrect or incompatible wallet addresses. Examples of incompatible wallet addresses include, but are not limited to, the type of cryptocurrency being transferred.

20.5. As Gate Türkiye cannot identify the counterparty to any transaction performedbyUsers, it strongly advises Users not to send cryptocurrencies to individuals they don't personally know or trust entirely, as transactions cannot be reversed once executed. Users must take precautions when transferring and storing their cryptocurrencies and/or digital assets on the Gate Türkiye Platform or via other sites, wallets, or devices. Gate Türkiye accepts no responsibility for the misuse or theft of cryptocurrencies and digital assets. Users should educate themselves on using personal wallet services or other devices to store digital assets, including cryptocurrencies, and take additional security measures. Users should also exercise caution and take necessary precautions to ensure the security of their passwords while operating in a digital environment.

20.6. Cryptocurrency trading is highly risky and, therefore, not suitable for most individuals. Users acknowledge and accept that investing in cryptocurrencies may result in partial or total loss of their investment. It is strongly recommended that Users determine their investment amounts based on their economic capacity and risk appetite. If Users have any concerns about investing in cryptocurrencies, they are strongly encouraged to seek professional advice. In addition to the risks listed above, unforeseen risks may also arise. Therefore, before making any decisions related to cryptocurrencies, Users should carefully evaluate their financial situation and the aforementioned risks to make rational decisions. Users are solely responsible for any damages arising from these risks and irrevocably release Gate Türkiye from any direct or indirect liability.

20.7. All opinions, information, discussions, analyses, prices, recommendations, and other content on the Gate Türkiye Platform constitute general market reviews and do not provide any form of investment, financial, tax, or professional advice. Gate Türkiye shall not beheld responsible for any losses, including but not limited to loss of profit, directly or indirectly caused by or connected to the information provided above.

20.8. By accessing the Platform and utilizing its services, the User acknowledges and accepts the following:

1. Trading or holding cryptocurrencies or similar digital assets entails significant risks, potential losses can be substantial, and any loss or liability incurred by the User is uninsured. Users understand the risks associated with the transactions of the aforementioned digital assets and their derivatives.
2. The User assumes all risks related to the use of the services and transactions involving the aforementioned digital assets and their derivatives.
3. Gate Türkiye cannot be held liable for any such risks or their adverse outcomes.

21. Account Closure

21.1. The User may request the complete closure of their account from Gate Türkiye at anytime and for any reason without justification. This request must be made in writingtoGateTürkiye. Gate Türkiye may require certain information and data from the User to verify the identity of the person making the request.

21.2. Upon receiving the account closure request from the User, the User's account will be closed within 30 days from the date the request is received.

21.3. Account transaction details and data for a closed account will continue to be retained by Gate Türkiye for the periods stipulated by law.

22. Amendment of the Agreement

22.1. Gate Türkiye reserves the unilateral right to modify and update all terms and conditions contained in the legal texts on the Platform without prior notice, simply publishing them on the Platform. The changes take effect and are binding from the moment they are published on the site.

23. Notification Obligations and Communications with Users

23.1. A User must notify Gate Türkiye as soon as practicable:

• if they have or may have committed a breach of this Agreement and other policies and procedures of Gate Türkiye, or any relevant Applicable Laws and Regulations;
• if a Competent Authority is investigating or instituting any investigation, disciplinary or enforcement proceedings against the User;
• the receipt of an injunction, or the imposition of a sanction against the User by any of the Competent Authority relating to the User’s activities on the Platform or which may otherwise be material in the context of the User’s obligations under this Policy;
• the occurrence of any Default Event;
• if they discover or suspect any unauthorized access or use of their User Account or any security breaches related to their User Account;
• any material change in the User’s ability to comply with this Agreement or any relevant Applicable Laws and Regulations;
• any changes or prospective changes affecting its ability to meet the criteria set out any matter which results in the User being unable to comply with the eligibility criteria or its continuing obligations under this Agreement; and
• if there is a need to report a material incident in relation to their User Account, including any material operational problems or security concerns related to their UserAccount.

23.2. The aforementioned notifications must be made using the appropriate means notified by Gate Türkiye to the User from time to time, including through the user interface.

23.3. All communications, agreements, documents, notices and disclosures that GateTürkiye provides under this Agreement and other policies and procedures and in connection to a User Account, in the absence of any express agreement to the contrary, shall be deemed to be to be duly notified to the User if:

• posted on Gate Türkiye’s website; or
• sent to the User’s last known registered email address.

23.4. All communications between a User and Gate Türkiye shall be in Turkish. This includes every document or information provided or required to be provided by a User toGate Türkiye.

24. Severability of the Agreement Provisions

24.1. If any part, provision, clause, or condition of this Agreement is declared invalid or unenforceable in whole or in part at any time by competent authorities, the remainder of the Agreement shall not be affected. If such a situation arises, the invalidated portion shall be interpreted as if it had been removed from the Agreement, and the remaining clauses will retain their validity and enforceability. The Parties agree to work on amendments that are legally acceptable and bring provisions as close as possible to the invalidated terms to ensure the continuity of the Agreement.

25. Termination of the Agreement

25.1. Gate Türkiye is authorized to close the User Account and immediately terminate the Agreement without compensation and without notice if it deems necessary based one valuations conducted in accordance with legal regulations (including MASAKandotherregulations) and its policies. If the Agreement is terminated or ended at the User's request, any balances of cryptocurrency remaining in the User Account will be converted toTurkishLira at Gate Türkiye’s prevailing exchange rate and transferred to one of the User’s registered bank accounts, along with any other TL balances.

25.2. Either Party may terminate this Agreement without providing justification by giving written notice to the other Party three days in advance.

25.3. Gate Türkiye reserves the right to terminate this Agreement without any warning, prior notification, or obligation to issue such notification if the User violates any provisions or clauses of this Agreement and its annexes or acts contrary to the information and documents provided to Gate Türkiye.

25.4. Upon termination of this Agreement, the User's right to access the Platform is revoked. If the termination does not arise from any violation of this Agreement or its annexes, or theUser’s account has not been used for any illegal purposes or is not under legal investigation, any assets in the User’s account, if applicable, will be returned to the User within 30 days.

26. Governing Law

26.1. This Agreement shall be governed by and interpreted under the laws and regulations of the Republic of Turkey. For any disputes arising from this Agreement, the İstanbul Çağlayan Courthouse and the İstanbul Çağlayan Enforcement Offices shall have jurisdiction.

27. Acceptance and Effective Date 

27.1. This User Agreement consists of 19 main articles and takes effect when the User electronically approves it after having read and fully understood each provision.

27.2. The rules and conditions contained in this Agreement presented to the User byGateTürkiye are annexes and integral parts of the Agreement. Together, the rights and obligations in this Agreement and its annexes constitute the entirety of the Parties' rights and obligations.

27.3. The KYC & AML Policy, Privacy Policy, Personal Data ProtectionPolicy, Clarification Text, Explicit Consent Statement, Cookie Policy, and Risk Disclosure Statement are annexes to this Agreement and integral parts of it.

27.4. Gate Türkiye reserves the right to amend or modify this Agreement, its annexes, terms of service, and operational conditions from time to time without prior notification to theUser. Once Users electronically approve and accept the changes, changes take effect immediately upon being published. The User's continued use of the site and services is considered acceptance of such changes or modifications. If the User does not accept any amended terms, they must cease using or accessing the Gate Türkiye Platform. By using and accessing the Platform, the User is deemed to have accepted and fully understood this Agreement and itsannexes, including the conditions amended from time to time by Gate Türkiye.