Principles for Electronic Notifications to be Made to the Customer

1. Purpose

The purpose of this Policy is to ensure that the documents, notifications, transaction notification forms, and data operations that must be transmitted to customers, in accordance with the regulations of the Capital Markets Board (SPK), within the scope of the services provided by Paribu Kripto Varlık Alım Satım Platformu A.Ş. (hereinafter referred to as "Paribu") as a crypto asset service provider, are transmitted in a timely, accurate, and auditable manner. The Policy defines the scope of the contents to be transmitted, the communication channels to be used, the timing of transmission, and the responsibilities of the relevant departments.

2. Scope and Basis

This Policy covers all services provided by the Company to customers. From the establishment of the business relationship with the customer, throughout the activity process, and after the termination of the business relationship, every kind of document, notification, transaction data, and information regarding personal data processing activities that must be sent to customers is within the scope of this policy. The Policy also includes the integration processes carried out with the Central Securities Depository (MKK) and the system records and log data that must be kept within this scope.

This policy has been prepared on the basis of the regulations of the Capital Markets Board to which Paribu is subject, including primarily the Capital Markets Law No. 6362, the Communiqué No. III-35/B.1 on the Establishment and Operating Principles of Crypto Asset Service Providers, the Communiqué No. III-35/B.2 on the Working Procedures and Principles of Crypto Asset Service Providers and Capital Adequacy, and the Information Systems Communiqué No. VII-128.10.

3. General Principles

3.1. Information Provided and Requested in the Establishment of a Business Relationship with the Customer

Paribu is obliged to provide certain information and documents to the customer before and at the time of establishing a business relationship with the customer, in accordance with the applicable legislation and internal policy provisions, and to keep records that these documents have been transmitted. At the stage of establishing the business relationship, both the customer and Paribu have obligations regarding the transmission of documents. The obligations to be fulfilled by both Paribu and the customer in this scope are defined below.

Framework Agreement: The framework agreement and its annexes (Risk Disclosure, KVKK texts, Electronic Notification Principles, etc.) are submitted for digital approval through the Paribu app before the business relationship is established. Approval is obtained by one or more of the following methods: wet signature, electronic signature, one-time password, or check-box marking in the electronic environment.

Requesting and Providing Documents Related to Customer Identification: Within the scope of the remote identification process, in order to fulfil the MASAK and SPK obligations, Paribu directs the customer to the "Verification" screen on the Paribu app. The customer follows the steps on the screen and uploads the required documents. The identification step is performed automatically by the system. Even if a customer account exists on the app before the identification step is completed, the customer cannot perform any transactions.

MKK Integration: In order for the transactions belonging to the customer to be recorded with MKK, Paribu is obliged, after the identification process, to share the customer's information with MKK and to perform the registry-matching operations. Through the API connection established between Paribu and MKK, customer data are transmitted to the MKK system in electronic form. The registry number obtained from the MKK system is matched with the customer records in the company system and defined to the customer profile within the platform.

3.2. Information Provided or Requested Regarding Customer Transactions

Paribu is obliged to transmit certain information and documents to customers during and after crypto asset buy-and-sell transactions. These obligations are carried out in order to ensure that the customer has timely, clear, and verifiable access to information about the transactions, to fulfil the principle of financial transparency, and to protect investor rights. The information transmitted to the customer within this scope is set out below.

Fee and Commission Information: The applied commission rates, per-transaction fees, and transfer fees are notified to customers. Commission rates are set out on the Commission rates screen in the Paribu app; the commission, transaction, and transfer fees to be charged to the customer are set out on the transaction execution screens.

Order Execution Policy: The Order Execution Policy, which contains information about the order matching system and orders, is published on the Paribu app and the Paribu website.

Transaction Result Form: It is prepared with consecutive numbering, showing the type, quantity, and price of the crypto assets bought and sold, together with the commissions and expense provisions accrued to the customer. This form is made available to the customer in electronic form by the end of the day at the latest.

Monthly Account Statement: Contains information about the names of all crypto assets bought, sold, or transferred; the dates, times, prices, and quantities of the buy, sell, or transfer operations; all movements regarding the customer's crypto assets and the cash held with banks; and any commissions, fees, and taxes accrued to the account. The Monthly Account Statement is made available to the customer in electronic form within the first 5 days of the month following the relevant period.

Notification When Customer Orders Are Met Outside the Trading Environment: While Paribu matches customer orders in the trading environment, in exceptional cases it may execute these orders directly from its own wallet as the counterparty. In this scope, when customer orders are met by the platform, such transactions may result against the investor and may also generate a gain in favour of the platform. In cases where the transactions are met directly from the Paribu wallet, customers are clearly and understandably informed that, if they incur a loss, this loss may constitute a gain for the platform.

3.3. KAP Notifications

Within the scope of its transparency and public disclosure obligations throughout its activities, Paribu provides clear and accessible information to customers and the public, through the Public Disclosure Platform (KAP) and the website, about the services it is authorised to provide and information identifying the company. Within this scope, trade registry information, current shareholding and management structure, contact information (phone, address, email), activity reports, business name, and brand-use authorisations are published. Any operating authorisation or brand-use authorisation granted by the Board is announced on the Paribu website and on KAP within 2 business days from notification. In the event of temporary suspension of activities or cancellation of the operating authorisation by the Board, this is also immediately announced to the public. Furthermore, in the event that Paribu applies to relinquish its operating authorisation, customers will be clearly notified that the activities will end, that they may transfer their assets to any wallet of their choice, and the latest date by which such requests will be met.

3.4. Periodic and Discretionary Notifications

In the course of the business relationship established with the customer, Paribu is obliged to provide information to customers at certain periods or in special situations. These notifications are made for the purpose of compliance with legislation as well as protection of customer rights, transparency, and accountability. The types and scope of notifications carried out in this context are listed below.

MKK Notifications: Notification of the customer regarding records held with MKK is carried out via the E-Investor Portal. The transmission of such information to the E-Investor Portal is carried out through the integration established with MKK.

Notifications Regarding Customer Complaints and Requests: Written and oral responses regarding the customer's complaints, objections, and requests are shared directly with the customer. Information sharing is provided through the customer's registered email address, registered phone, or the Paribu app, in accordance with the Customer Objection, Complaint, and Support Request Management Procedure.

Notifications of Changes to Policies and Rules: Changes affecting Paribu's services or operations are announced through Paribu Communication Channels and/or the customers' registered email addresses.

Liquidation and Suspension of Activity Notifications: In the event of liquidation or suspension of activity, customers are informed via their registered phone numbers or email addresses.

Extraordinary Situation Notifications: In the event of extraordinary situations such as economic, political, technological, or systemic events that may cause sudden and unexpected fluctuations in market prices, lack of liquidity in the market, suspension of trading, technical failures, cyber attacks, or natural disasters affecting the operation of Paribu, related explanations and the precautions and measures taken in this scope will be announced through Paribu Communication Channels.

Notification Regarding Partner Institutions: Partner Institution means market makers, liquidity providers, the bank where customer cash is kept, and the custody institution where customer crypto assets are kept. Paribu may cooperate with partner third-party institutions for matters such as market making, liquidity provision, custody service, or technology infrastructure for the crypto assets it lists on the platform.

In this framework;

1. In the event that there is a direct or indirect capital, voting rights, or management relationship between the institutions and organisations undertaking the role of Market Maker and Liquidity Provider and Paribu, these matters are clearly published on the Paribu website.
2. In the event of a contract being concluded with an authorised custody institution regarding the custody of crypto assets, the title of this institution, the structure of its relationship with Paribu, and the custody model (e.g., hot/cold wallet ratio, multi-signature structure) are publicly disclosed in detail.
3. The current list of institutions that have a partnership with Paribu and the details of the relationships with these institutions are published on the relevant page of the Paribu website and updated when changes occur.

This information is regularly reviewed and announced to the public in line with the principles of transparency, prevention of conflict of interest, and informing the investor.

Listing Policy: The Listing Policy, which explains the listing criteria and the listing process, is set out on the Paribu Website. The relevant policy also explains the delisting criteria and delisting processes.

Listing Criteria and List of Listed Assets: The crypto asset listing criteria and the list of listed crypto assets are set out on the Paribu Website.

KVKK Notifications: The retention and use conditions of the personal data collected are set out on the Paribu website and the mobile app.

General Disclaimer Note: The disclosure stating that the information on the Paribu website is of a general nature and may not be sufficient for investment decisions is set out on the Paribu website and the mobile app.

Notification Regarding Conflicts of Interest: Paribu prioritises the interests of its customers in the conduct of its activities and has established a written conflict of interest policy to prevent conflicts of interest. This policy aims to ensure that the interests of the various departments, employees, or persons/institutions from whom services are received at Paribu are observed, managed, and prevented in a way that does not work against customers or create inequality between customers.

Notification Regarding Insurance of Assets: In the event that all or part of the crypto assets held by customers on the platform are insured, Paribu announces the information regarding such insurance to customers in a complete, clear, and understandable manner through the Paribu website.

Notification Regarding the Custody of Crypto and Cash Assets: Customers are clearly and understandably informed via the Paribu website about where and by which method the crypto assets and cash balances belonging to customers are kept. In the event that crypto assets are held in wallets within Paribu or with an authorised custody institution, information about the authorised custody institution is disclosed to customers in writing or in electronic form. Information regarding the banks where cash assets are kept is announced on the Paribu website. If Paribu starts working under contract with a custody institution or bank, this is announced to customers, and this notification is updated as changes occur.

Notification Regarding Market Making Activities: The necessary disclosures regarding transactions in which Paribu acts as the counterparty to customer orders — transactions in which it is directly a party in the capacity of market maker or liquidity provider — are shared via the Paribu website or the mobile app.

Notifications Regarding Special Situations That May Arise in the Market: In situations where customers may be affected by structural changes that crypto assets based on distributed ledger technology may undergo, or by crypto asset losses originating from the platform, Paribu is obliged to inform customers in writing or via electronic communication channels. The notifications carried out in this context will be provided through the customers' registered communication addresses. The information provided in this scope will include the necessary disclosures regarding the changes occurring in the distributed ledger network that are known to Paribu or that Paribu is reasonably expected to know, and the possible effects of these changes on the crypto asset market. Similarly, in the event that crypto asset losses originating from Paribu occur, the implementation steps regarding how these losses will be compensated will also be notified to customers through the same communication channels. Time-stamped records, log data, and access evidence regarding these notifications will be archived and kept to be presented in audits.

3.5. General Advice and Provision of Financial Information

When providing customers with information about crypto assets and market trends, Paribu observes the distinction between general advice and impartial financial information. Research that is not specific to a particular person or to a similar group of customers, that is prepared in a directional content and that may include explicit or implicit investment strategies regarding the price or value of crypto assets, is provided only within the scope of general advice. Such sharings are made only via the website, the mobile app, or bulk email notifications; they are not transmitted on a one-to-one basis through private communication channels.

Paribu considers the provision of non-directional written or oral information as financial information and shares such information in any case on the basis of being impartial and honest. The Company clearly states, in content of a general-advice nature, the date of sharing, the time period in which the content was prepared, the date/time information of the prices included, and any strategy changes and their reasons. The transmission of all content prepared within the framework of these obligations is kept together with access records and documented in a manner open to audit.

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1. Purpose

The purpose of this Policy is to ensure that the documents, notifications, transaction notification forms, and data operations that must be transmitted to customers, in accordance with the regulations of the Capital Markets Board (SPK), within the scope of the services provided by Paribu Kripto Varlık Alım Satım Platformu A.Ş. (hereinafter referred to as "Paribu") as a crypto asset service provider, are transmitted in a timely, accurate, and auditable manner. The Policy defines the scope of the contents to be transmitted, the communication channels to be used, the timing of transmission, and the responsibilities of the relevant departments.

2. Scope and Basis

This Policy covers all services provided by the Company to customers. From the establishment of the business relationship with the customer, throughout the activity process, and after the termination of the business relationship, every kind of document, notification, transaction data, and information regarding personal data processing activities that must be sent to customers is within the scope of this policy. The Policy also includes the integration processes carried out with the Central Securities Depository (MKK) and the system records and log data that must be kept within this scope.

This policy has been prepared on the basis of the regulations of the Capital Markets Board to which Paribu is subject, including primarily the Capital Markets Law No. 6362, the Communiqué No. III-35/B.1 on the Establishment and Operating Principles of Crypto Asset Service Providers, the Communiqué No. III-35/B.2 on the Working Procedures and Principles of Crypto Asset Service Providers and Capital Adequacy, and the Information Systems Communiqué No. VII-128.10.

3. General Principles

3.1. Information Provided and Requested in the Establishment of a Business Relationship with the Customer

Paribu is obliged to provide certain information and documents to the customer before and at the time of establishing a business relationship with the customer, in accordance with the applicable legislation and internal policy provisions, and to keep records that these documents have been transmitted. At the stage of establishing the business relationship, both the customer and Paribu have obligations regarding the transmission of documents. The obligations to be fulfilled by both Paribu and the customer in this scope are defined below.

Framework Agreement: The framework agreement and its annexes (Risk Disclosure, KVKK texts, Electronic Notification Principles, etc.) are submitted for digital approval through the Paribu app before the business relationship is established. Approval is obtained by one or more of the following methods: wet signature, electronic signature, one-time password, or check-box marking in the electronic environment.

Requesting and Providing Documents Related to Customer Identification: Within the scope of the remote identification process, in order to fulfil the MASAK and SPK obligations, Paribu directs the customer to the "Verification" screen on the Paribu app. The customer follows the steps on the screen and uploads the required documents. The identification step is performed automatically by the system. Even if a customer account exists on the app before the identification step is completed, the customer cannot perform any transactions.

MKK Integration: In order for the transactions belonging to the customer to be recorded with MKK, Paribu is obliged, after the identification process, to share the customer's information with MKK and to perform the registry-matching operations. Through the API connection established between Paribu and MKK, customer data are transmitted to the MKK system in electronic form. The registry number obtained from the MKK system is matched with the customer records in the company system and defined to the customer profile within the platform.

3.2. Information Provided or Requested Regarding Customer Transactions

Paribu is obliged to transmit certain information and documents to customers during and after crypto asset buy-and-sell transactions. These obligations are carried out in order to ensure that the customer has timely, clear, and verifiable access to information about the transactions, to fulfil the principle of financial transparency, and to protect investor rights. The information transmitted to the customer within this scope is set out below.

Fee and Commission Information: The applied commission rates, per-transaction fees, and transfer fees are notified to customers. Commission rates are set out on the Commission rates screen in the Paribu app; the commission, transaction, and transfer fees to be charged to the customer are set out on the transaction execution screens.

Order Execution Policy: The Order Execution Policy, which contains information about the order matching system and orders, is published on the Paribu app and the Paribu website.

Transaction Result Form: It is prepared with consecutive numbering, showing the type, quantity, and price of the crypto assets bought and sold, together with the commissions and expense provisions accrued to the customer. This form is made available to the customer in electronic form by the end of the day at the latest.

Monthly Account Statement: Contains information about the names of all crypto assets bought, sold, or transferred; the dates, times, prices, and quantities of the buy, sell, or transfer operations; all movements regarding the customer's crypto assets and the cash held with banks; and any commissions, fees, and taxes accrued to the account. The Monthly Account Statement is made available to the customer in electronic form within the first 5 days of the month following the relevant period.

Notification When Customer Orders Are Met Outside the Trading Environment: While Paribu matches customer orders in the trading environment, in exceptional cases it may execute these orders directly from its own wallet as the counterparty. In this scope, when customer orders are met by the platform, such transactions may result against the investor and may also generate a gain in favour of the platform. In cases where the transactions are met directly from the Paribu wallet, customers are clearly and understandably informed that, if they incur a loss, this loss may constitute a gain for the platform.

3.3. KAP Notifications

Within the scope of its transparency and public disclosure obligations throughout its activities, Paribu provides clear and accessible information to customers and the public, through the Public Disclosure Platform (KAP) and the website, about the services it is authorised to provide and information identifying the company. Within this scope, trade registry information, current shareholding and management structure, contact information (phone, address, email), activity reports, business name, and brand-use authorisations are published. Any operating authorisation or brand-use authorisation granted by the Board is announced on the Paribu website and on KAP within 2 business days from notification. In the event of temporary suspension of activities or cancellation of the operating authorisation by the Board, this is also immediately announced to the public. Furthermore, in the event that Paribu applies to relinquish its operating authorisation, customers will be clearly notified that the activities will end, that they may transfer their assets to any wallet of their choice, and the latest date by which such requests will be met.

3.4. Periodic and Discretionary Notifications

In the course of the business relationship established with the customer, Paribu is obliged to provide information to customers at certain periods or in special situations. These notifications are made for the purpose of compliance with legislation as well as protection of customer rights, transparency, and accountability. The types and scope of notifications carried out in this context are listed below.

MKK Notifications: Notification of the customer regarding records held with MKK is carried out via the E-Investor Portal. The transmission of such information to the E-Investor Portal is carried out through the integration established with MKK.

Notifications Regarding Customer Complaints and Requests: Written and oral responses regarding the customer's complaints, objections, and requests are shared directly with the customer. Information sharing is provided through the customer's registered email address, registered phone, or the Paribu app, in accordance with the Customer Objection, Complaint, and Support Request Management Procedure.

Notifications of Changes to Policies and Rules: Changes affecting Paribu's services or operations are announced through Paribu Communication Channels and/or the customers' registered email addresses.

Liquidation and Suspension of Activity Notifications: In the event of liquidation or suspension of activity, customers are informed via their registered phone numbers or email addresses.

Extraordinary Situation Notifications: In the event of extraordinary situations such as economic, political, technological, or systemic events that may cause sudden and unexpected fluctuations in market prices, lack of liquidity in the market, suspension of trading, technical failures, cyber attacks, or natural disasters affecting the operation of Paribu, related explanations and the precautions and measures taken in this scope will be announced through Paribu Communication Channels.

Notification Regarding Partner Institutions: Partner Institution means market makers, liquidity providers, the bank where customer cash is kept, and the custody institution where customer crypto assets are kept. Paribu may cooperate with partner third-party institutions for matters such as market making, liquidity provision, custody service, or technology infrastructure for the crypto assets it lists on the platform.

In this framework;

1. In the event that there is a direct or indirect capital, voting rights, or management relationship between the institutions and organisations undertaking the role of Market Maker and Liquidity Provider and Paribu, these matters are clearly published on the Paribu website.
2. In the event of a contract being concluded with an authorised custody institution regarding the custody of crypto assets, the title of this institution, the structure of its relationship with Paribu, and the custody model (e.g., hot/cold wallet ratio, multi-signature structure) are publicly disclosed in detail.
3. The current list of institutions that have a partnership with Paribu and the details of the relationships with these institutions are published on the relevant page of the Paribu website and updated when changes occur.

This information is regularly reviewed and announced to the public in line with the principles of transparency, prevention of conflict of interest, and informing the investor.

Listing Policy: The Listing Policy, which explains the listing criteria and the listing process, is set out on the Paribu Website. The relevant policy also explains the delisting criteria and delisting processes.

Listing Criteria and List of Listed Assets: The crypto asset listing criteria and the list of listed crypto assets are set out on the Paribu Website.

KVKK Notifications: The retention and use conditions of the personal data collected are set out on the Paribu website and the mobile app.

General Disclaimer Note: The disclosure stating that the information on the Paribu website is of a general nature and may not be sufficient for investment decisions is set out on the Paribu website and the mobile app.

Notification Regarding Conflicts of Interest: Paribu prioritises the interests of its customers in the conduct of its activities and has established a written conflict of interest policy to prevent conflicts of interest. This policy aims to ensure that the interests of the various departments, employees, or persons/institutions from whom services are received at Paribu are observed, managed, and prevented in a way that does not work against customers or create inequality between customers.

Notification Regarding Insurance of Assets: In the event that all or part of the crypto assets held by customers on the platform are insured, Paribu announces the information regarding such insurance to customers in a complete, clear, and understandable manner through the Paribu website.

Notification Regarding the Custody of Crypto and Cash Assets: Customers are clearly and understandably informed via the Paribu website about where and by which method the crypto assets and cash balances belonging to customers are kept. In the event that crypto assets are held in wallets within Paribu or with an authorised custody institution, information about the authorised custody institution is disclosed to customers in writing or in electronic form. Information regarding the banks where cash assets are kept is announced on the Paribu website. If Paribu starts working under contract with a custody institution or bank, this is announced to customers, and this notification is updated as changes occur.

Notification Regarding Market Making Activities: The necessary disclosures regarding transactions in which Paribu acts as the counterparty to customer orders — transactions in which it is directly a party in the capacity of market maker or liquidity provider — are shared via the Paribu website or the mobile app.

Notifications Regarding Special Situations That May Arise in the Market: In situations where customers may be affected by structural changes that crypto assets based on distributed ledger technology may undergo, or by crypto asset losses originating from the platform, Paribu is obliged to inform customers in writing or via electronic communication channels. The notifications carried out in this context will be provided through the customers' registered communication addresses. The information provided in this scope will include the necessary disclosures regarding the changes occurring in the distributed ledger network that are known to Paribu or that Paribu is reasonably expected to know, and the possible effects of these changes on the crypto asset market. Similarly, in the event that crypto asset losses originating from Paribu occur, the implementation steps regarding how these losses will be compensated will also be notified to customers through the same communication channels. Time-stamped records, log data, and access evidence regarding these notifications will be archived and kept to be presented in audits.

3.5. General Advice and Provision of Financial Information

When providing customers with information about crypto assets and market trends, Paribu observes the distinction between general advice and impartial financial information. Research that is not specific to a particular person or to a similar group of customers, that is prepared in a directional content and that may include explicit or implicit investment strategies regarding the price or value of crypto assets, is provided only within the scope of general advice. Such sharings are made only via the website, the mobile app, or bulk email notifications; they are not transmitted on a one-to-one basis through private communication channels.

Paribu considers the provision of non-directional written or oral information as financial information and shares such information in any case on the basis of being impartial and honest. The Company clearly states, in content of a general-advice nature, the date of sharing, the time period in which the content was prepared, the date/time information of the prices included, and any strategy changes and their reasons. The transmission of all content prepared within the framework of these obligations is kept together with access records and documented in a manner open to audit.