SAFEBİT FRAMEWORK AGREEMENT
1. PARTIES
This Framework Agreement (“Agreement” or “Framework Agreement”) is executed between Safebit Kripto Varlık Alım Satım Platformu A.Ş. (“Safebit”) and real or legal persons (“Customer”) who become members in order to benefit from the cryptocurrency trading platform services offered through the website www.safebit.com.tr, the Safebit Mobile Application, and other platforms managed by Safebit, in compliance with the provisions of the Capital Markets Law No. 6362, the Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers (III-35/B.1), and the Communiqué on the Working Principles and Capital Adequacy of Crypto Asset Service Providers (III-35/B.2), as well as other applicable regulations. Accordingly:
i. You acknowledge that you are aware of the risks associated with crypto asset transactions,
ii. You agree that all risks arising from the use of Safebit products, services, and tools, or from conducting crypto asset transactions, belong solely to you,
iii. You acknowledge that Safebit cannot be held liable for any risks or adverse consequences resulting from your crypto asset transactions,
iv. By accessing or using any of Safebit’s Services, Products, or Platforms, you confirm and declare that you are bound by this Framework Agreement.
Safebit and the Customer shall each be referred to individually as a “Party” and collectively as the “Parties.”
2. SUBJECT AND SCOPE
2.1. This Agreement is a Framework Agreement (“Agreement”) executed once at the outset within the scope of the Capital Markets Board regulations, which generally governs the relationship between Safebit Kripto Varlık Alım Satım Platformu A.Ş. (hereinafter referred to as “Safebit”) and the Customer, and forms the basis for individual transactions. The provisions of this Agreement shall apply as general terms to the crypto assets that the Customer buys/sells or requests Safebit to act as an intermediary for. The purpose of this Framework Agreement is to regulate the principles of the cryptocurrency trading and related services (“Services”) provided by Safebit to the Customer. Accordingly, this Agreement sets forth matters relating to the transmission, execution, and settlement of Customer orders, pre- and post-trade obligations, order types, procedures for depositing and withdrawing cash, crypto asset transfers and their limits (if any), the banks where customer funds are held and the principles of interest accrual, the custodian institution where crypto assets are stored, the security of user and password information, and the fees, commissions, and other charges, among others. The mere signing of this Agreement by the Customer does not in itself impose an obligation on Safebit to provide all Services covered by the Agreement. The Customer must meet other requirements stipulated by the legislation and detailed in the Agreement to access the Services. Safebit reserves the right to create new service channels, modify existing ones, or terminate services.
2.2. This Agreement governs the general principles of the legal relationship between Safebit and the Customer and the procedures for account opening, to ensure that the Services are provided in accordance with the Capital Markets Law No. 6362, the Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers (III-35/B.1), the Communiqué on the Working Principles and Capital Adequacy of Crypto Asset Service Providers (III-35/B.2), and the relevant regulations of the Capital Markets Board (CMB), MASAK, and MKK, as well as other Turkish laws, secondary legislation, international treaties to which the Republic of Türkiye is a party, and the regulations of foreign authorities for cross-border transactions. The Parties may carry out multiple transactions at different times under this Agreement. The details of such transactions are included in the Customer’s instruction and order forms. Any other agreements, undertakings, instructions/confirmations, suitability tests, suitability test result notifications, customer classification notices, and any forms or documents that the Customer may sign for the execution of Services by Safebit shall constitute an integral part of this Agreement.
2.3. By entering into this Agreement, the Customer may, within the scope of the Capital Markets legislation, buy and sell Crypto Assets (as defined below) listed on the Platforms through Safebit. Such Crypto Assets shall be bought, sold, and held in accordance with this Agreement and the Capital Markets legislation.
2.4. In addition to the above-mentioned CMB Communiqués III-35/B.1 and III-35/B.2, this Agreement may be executed remotely via a Durable Medium in accordance with the Communiqué (III-42.1) on Remote Identification Methods and Establishment of Contractual Relationships in Electronic Environments for Investment Firms and Portfolio Management Companies and the Communiqué on the Document and Record-Keeping Rules Regarding Investment Services, Activities, and Ancillary Services. In such cases, the parts of the Agreement referring to signature shall mean confirmations or approvals obtained via the Durable Medium. The forms annexed to the Agreement shall be completed via the Durable Medium, and notifications shall also be provided through this method.
2.5. This Agreement may also be executed remotely via a Durable Medium. In such cases, the sections referring to signature shall mean confirmations or approvals obtained via the Durable Medium. The annexed forms shall be completed via the Durable Medium, and notifications shall be delivered through this method.
2.6. A copy of this Agreement and its annexes is available on the website www.safebit.com.tr.
3. DEFINITIONS
Open Order: Orders entered into the system by the Customer that have not yet been completed, canceled, or expired.
Bank Account: An account opened in your name with a financial institution located in Türkiye through which you perform money transfer transactions.
Wallet or Digital Wallet: A computer file that stores crypto asset addresses and their passwords. Crypto assets can be transferred between addresses. These addresses are pairs of cryptographic public keys generated randomly.
E-Investor Application: The application supported by the Capital Markets Board that allows Corporate Customers to access their records held by the Central Securities Depository (“MKK”).
Order: Instructions sent to the Platform by the Customer or the Customer’s duly authorized agent or representative, in the form and manner permitted by Safebit, to buy, sell, and/or transfer Crypto Assets.
Matching Processes: The procedures involving obtaining or verifying a registry number for the Customer from MKK and matching it with the customer number assigned by Safebit.
Beneficial Owner: The individual(s) who determine the ultimate ownership structure of a legal entity, as defined under MASAK regulations.
Services: All types of products, services, and activities authorized by the Capital Markets Board, including receiving, matching, executing, and settling customer orders related to crypto assets, their initial sale or distribution, transfer, custody, and other related operations.
Applicable Legislation: The Capital Markets Law No. 6362 and all associated regulations, communiqués, and guidelines published by the Capital Markets Board, as well as principles, procedures, and decisions issued by the Board, and all national and international rules applicable to Safebit’s area of operation and binding on both Safebit and the Customer.
Transaction Result Form: The electronic confirmation form showing the time, amount, type of crypto asset, commission information, and equivalent value of the transaction executed following an order.
Durable Medium: Any tool or medium, such as SMS, email, internet, disk, CD, DVD, memory card, etc., that allows the information sent or received by the Customer to be recorded and copied without alteration for a reasonable period suitable for its purpose, and enables access to such information in its exact form.
Law: The Capital Markets Law No. 6362.
Personal Data: Any information relating to an identified or identifiable natural person.
Crypto Asset: A digital asset that uses cryptographic encryption methods, can be used in exchange transactions, is decentralized, fluctuates based on free market conditions, and is designed as an alternative means of exchange to cash.
Corporate Customer: Customers that have legal personality under the applicable legislation.
Corporate Customer Representative: Natural person(s) authorized to act on behalf of the Customer by a notarized power of attorney.
KVKK: The Law on the Protection of Personal Data No. 6698.
MASAK: The Financial Crimes Investigation Board.
MKK: The Central Securities Depository Joint Stock Company, as defined in Article 81 of the Law.
Customer: The natural or legal person who approves this Agreement.
Customer Account: The digital account created by the Customer to benefit from the services offered on the Safebit platforms, containing a personal profile and authentication information, used exclusively by the account holder, who is responsible for all transactions made through the account.
Platform or Platforms: The entire crypto asset trading system managed by Safebit, including the website www.safebit.com.tr, the Safebit Mobile Application, and other platforms managed by Safebit, where one or more of the following are conducted: crypto asset trading, initial sale or distribution, transfer, custody, and other related transactions.
Custody Service Provider: The custody service provider contracted by Safebit, where the Customers’ crypto assets are held.
Hot Wallet: Crypto asset wallets stored in an environment connected to the internet.
Cold Wallet: Crypto asset wallets stored in an environment not connected to the internet.
CMB or Board: The Capital Markets Board established by the Capital Markets Law No. 2499.
CBRT: The Central Bank of the Republic of Türkiye.
Transfer: The transfer of crypto assets between wallets through distributed ledger technology.
TSPB: The Turkish Capital Markets Association.
TÜBİTAK: The Scientific and Technological Research Council of Türkiye.
YTM: The Investor Compensation Center.
4. KNOW YOUR CUSTOMER AND IDENTIFICATION
4.1. By signing this Agreement and its annexes, the Customer delivers to Safebit the identity, information, and documents requested by Safebit for the identification of the Customer and, if any, the Customer’s representative, pursuant to the Law No. 5549 on the Prevention of Laundering Proceeds of Crime and the relevant legislation. The Customer is obliged to promptly deliver to Safebit any and all identity information and documents requested by Safebit, now or in the future, for the identification and/or verification of the Customer and, if any, the Customer’s representative, in accordance with Safebit’s request. Safebit is not obliged to open any account unless it performs the necessary identification in accordance with the provisions of this Agreement. If the additional information and documents that may be requested by Safebit for the identification or verification to be performed under this clause are not provided by the Customer in a timely manner, Safebit may unilaterally terminate this Agreement immediately. The Customer accepts and declares that all information and statements provided to Safebit are true, complete, and reflect the facts.
4.2. Safebit shall carry out customer due diligence processes in accordance with its legal obligations. In this context, different processes may be implemented depending on whether the Customer is a natural or legal person, a citizen of the Republic of Türkiye or a foreign national. By signing this Agreement, the Customer is obliged to personally and without delay comply with the instructions, requests, and invitations communicated by Safebit.
4.3. The Customer accepts, declares, and undertakes that Safebit may request a supporting document containing up-to-date address information and, in such case, the Customer will promptly submit to Safebit the supporting documents containing the address information of the Customer and, if applicable, of the Corporate Customer. If the contractual relationship is established electronically, Safebit shall perform remote identification of the Customer in accordance with the provisions of the relevant legislation, and thereafter the procedures regarding the signing of the Agreement shall be carried out. For membership applications, the mandatory information requested at the membership stage in the Know Your Customer Form required by the Platform must be provided for the application to be accepted.
4.4. The Customer accepts that the information provided to Safebit is accurate and truthful; in the event of any change in such information, the Customer is obliged to promptly notify Safebit thereof. The Customer is solely responsible for all direct and indirect damages that may arise due to failure to notify Safebit.
4.5. If the Customer is (i) a citizen of the United States of America (USA), the European Union (EU), or any other foreign country, (ii) conducts transactions in these countries, (iii) is subject to tax liability therein, or (iv) subject to other legal obligations, the Customer accepts that personal, financial, and any other information may be shared with the authorities of the relevant country, the Government of the Republic of Türkiye, the U.S. Internal Revenue Service (IRS), the U.S. Commodity Futures Trading Commission (CFTC), the U.S. Securities and Exchange Commission (SEC), the European Securities and Markets Authority (ESMA), the Common Reporting Standard (CRS) published by the Organisation for Economic Co-operation and Development (OECD), the U.S. Dodd-Frank Act, FATCA, EMIR and similar legal regulations, international agreements, and authorized persons and institutions under the applicable legislation (including the Revenue Administration, the Social Security Institution, and other official authorities of foreign countries). The Customer declares and undertakes that the Customer has given prior consent to such sharing.
4.6. In transactions to be conducted through Safebit that require identification, the Customer declares, accepts, and undertakes that the Customer is not acting on behalf of another person while acting in the Customer’s own name; and that if acting in the Customer’s own name but on behalf of another person, the Customer is obliged to notify Safebit in writing, before carrying out such transactions, on whose behalf the Customer is acting, and that failure to comply with this obligation is subject to criminal sanctions. The execution of this Agreement by the Customer shall mean that the Customer agrees and undertakes to transact only on the Customer’s own behalf or on behalf of a natural or legal person whom the Customer is authorized to represent.
4.7. The identification process for Corporate Customer Representatives shall be carried out in accordance with Article 5.2 of the Agreement.
4.8. Transactions on the Customer’s account may be carried out only by persons other than the Customer who have been authorized by a power of attorney issued by a notary public.
5. PROVISIONS ON CAPACITY AND REPRESENTATION
5.1. Natural Persons
5.1.1. As a rule, in order for natural person Customers to transact on the Platforms, they must have full legal capacity. Minors and persons under legal disability may benefit from the services through their parents or guardians. Within a marital union, either parent may represent the minor in the capacity of guardian. In such case, Safebit may carry out transactions with the consent of both spouses.
5.1.2. Safebit has the right to close Customer accounts that do not meet the age criteria without notice. The Customer is responsible for the accuracy of the information declared.
5.1.3. The Customer may appoint a representative to transact on the Customer’s own name and account. The power of attorney must be issued by a notary public, a consulate, or competent authorities abroad. The scope of representative authority shall be determined by Safebit’s interpretation of the document submitted as the basis of representation, in line with the nature of the transaction intended by the representative. In determining this scope, Safebit shall not require the use of specific information regarding Crypto Assets or Orders, direct mention of Safebit’s name, or the use of technical terms.
5.1.4. Matters regarding incapacity shall not be valid vis-à-vis Safebit unless notified to Safebit in writing.
5.1.5. If Safebit becomes aware of the Customer’s death or of a judicial decision of presumption of death, Safebit is authorized to block the account until a tax clearance certificate is submitted. In such case, Safebit will not permit transactions on the account. After submission of the tax clearance certificate, the remaining rights and receivables shall be paid to the heirs.
5.2. Legal Persons
5.2.1. Safebit shall carry out identification processes for Corporate Customers in accordance with the relevant provisions of the legislation. In this context, it shall collect various information relating to legal persons, such as trade name, trade registry number, tax identification number, field of activity, registered address, telephone number, and, if any, fax number and email address. The Corporate Customer is obliged to provide and deliver, accurately, completely, and on time, any and all information and documents requested by Safebit.
5.2.2. Corporate Customers are represented before Safebit by a Corporate Customer Representative. The Corporate Customer Representative must be a natural person. In accordance with its legal obligations, Safebit shall carry out a separate identification process for the Corporate Customer Representative. If the information and documents requested in the identification process of the Corporate Customer Representative are not provided accurately, completely, and on time, Safebit shall not proceed with opening an account for the Corporate Customer. The Corporate Customer may not bring any claim against Safebit for any damage incurred for this reason.
5.2.3. The disposal authority of the Corporate Customer Representative shall remain valid vis-à-vis Safebit until changes made to such authority are notified in writing by the Corporate Customer to Safebit. Safebit shall in no way be held liable for any direct or indirect damages incurred by the Corporate Customer due to failure to notify changes relating to authority.
5.2.4. The Corporate Customer may notify Safebit by completing the relevant section annexed to this Agreement or by way of a separate form or instruction. Transactions carried out solely by the Corporate Customer shall bind the Corporate Customer.
5.3. Agents and Representatives
5.3.1. Individual Customers may only use the accounts opened in their own names on the Platform; such accounts may not be transferred to or used by third parties. Corporate accounts may only be used by representatives authorized on behalf of the institution. Corporate Customers are obliged to notify in writing the authorized representatives who will use the platform and to submit their authorization documents. All transactions carried out from corporate accounts shall be deemed to have been performed by the authorized representative and shall be binding on the relevant institution.
5.3.2. Any notifications, statements, and announcements made by Safebit to representatives or agents authorized to act on behalf of the Customer shall be deemed to have been made to the Customer as well.
5.3.3. The Customer accepts that the authority to dispose over the accounts opened in the Customer’s name with Safebit belongs solely to the Customer or to representatives expressly authorized by a notarized power of attorney or authorization document. The Customer shall duly notify Safebit in writing of the identities, contact information, and specimen signatures of the persons authorized to represent the Customer. Unless and until this notification is made, only those persons recorded in Safebit’s own records shall be deemed authorized before Safebit.
5.3.4. In the event that the powers of the authorized representative or agent are terminated, amended, restricted, or revoked, the Customer is obliged to notify Safebit immediately and in writing. Unless such notification is made, Safebit’s transaction records and the current list of authorized persons shall prevail. Safebit shall bear no liability for transactions and dispositions carried out on the basis of such authorities. The Customer shall be solely responsible for any damages arising from failure to notify.
5.3.5. Any notification, statement, warning, or service of process made by Safebit to representatives or agents shall be deemed to have been made to the Customer. Unless a general power of attorney presented to Safebit expressly contains a restriction of authority, the persons submitting such power of attorney shall be deemed authorized to represent the Customer before Safebit in all transactions and to make binding dispositions on behalf of the Customer.
5.3.6. If the Customer appoints an agent to transact on the accounts with Safebit, give instructions, or conduct transactions with third parties, the Customer accepts, declares, and undertakes that all transactions carried out by such agent shall have consequences for and bind the Customer. The Customer acknowledges in advance that Safebit shall have no legal, criminal, or compensatory liability if the agent’s transactions are not suitable for the Customer’s investment preferences, risk appetite, or portfolio structure; if the transactions become loss-making due to changing market conditions; if the agent acts negligently or exceeds authority; or for any other reason causing loss. The Customer declares that the Customer may not seek recourse from Safebit for losses arising from the agent’s conduct.
5.3.7. In establishing, modifying, or terminating a power of attorney or representation relationship, the Customer is responsible for fulfilling the obligations under the applicable legislation regarding identification, signature verification, authorization document control, and beneficial owner notification. Safebit reserves the right to request additional information, documents, or statements to verify the authority of the representative or agent. If the Customer fails to meet these requests or provides incomplete/misleading information, Safebit reserves the right to refuse to perform the transaction or to terminate the Agreement.
5.3.8. The Customer shall be solely responsible for any and all consequences arising from the loss of legal capacity, restriction of capacity, death, presumption of death, or similar personal status changes of the Customer or the authorized representative. Unless such changes are notified to Safebit by a special written notice signed by the Customer’s authorized persons, Safebit shall bear no responsibility for any consequences arising therefrom. The publication of such changes, their registration in the trade registry, or announcement to the public shall not eliminate the obligation of special written notification.
5.3.9. Safebit is obliged to verify, with reasonable care and diligence, the identity and signatures of the Customer or of persons acting as authorized representatives, agents, parents, guardians, or trustees by comparing them with specimen signatures found in application forms, this Agreement, signature circulars, notarized powers of attorney, and similar documents, either physically or electronically. However, unless a clear fault attributable to Safebit exists, Safebit shall not be liable in the following cases:
i. Consequences arising from signature similarities, forged or imitated signatures that cannot be detected at first glance,
ii. Alteration, fraud, or deceptive acts contained in documents or correspondence submitted,
iii. Unauthorized use of electronic, mobile, or wet signature tools by third parties,
iv. Instructions transmitted via fax, email, or electronic communication channels being incomplete, incorrect, duplicate, or unconfirmed,
v. Failures, interruptions, delays, or technical malfunctions in telecommunication, internet, server, or software infrastructure,
vi. Data loss, delay, or corruption arising from errors in the Customer’s or third parties’ devices, software, or security infrastructure.
5.3.10. If accounts opened in the name of the Customer are managed by a parent, guardian, or trustee: Persons acting in the capacity of parent (guardian) may transact on behalf of the minor individually; within a marital union, either parent may act alone on behalf of the child. Safebit shall presume that each spouse acts with the consent of the other. In case of divorce, the parent vested with custody by court order; and in case of death, the surviving parent may transact on behalf of the child. Persons acting as guardian or trustee are obliged to submit to Safebit the court decision regarding their appointment and to act in accordance with the provisions of the applicable legislation. Safebit may, where necessary, request authorization from the competent court.
5.3.11. The parent, guardian, or trustee transacting on behalf of a child accepts that all obligations set forth in this Agreement are equally valid and binding for themselves and that they are personally liable for transactions conducted in excess of their authority. Safebit reserves the right not to provide products or services that are incompatible with an account opened on behalf of a child. It is accepted that the phone number, password, and access information provided by the parent for accounts opened on behalf of a child shall be used exclusively by the parent; and the parent shall be solely responsible for all consequences arising from transactions carried out by the child or third parties using this information.
5.3.12. If a guardian or trustee exceeds the limits stipulated by law or court order while conducting transactions on behalf of the Customer, they shall be personally liable to both Safebit and the Customer. Safebit shall not be held liable for any loss arising from such transactions.
5.3.13. Safebit has the authority to verify the powers of persons acting in the capacity of representative, agent, parent, guardian, or trustee; to suspend the transaction where it deems necessary; to request additional documents; or to refuse the transaction. Safebit shall incur no liability due to measures taken within this scope.
5.3.14. Unauthorized use of the Customer’s account constitutes an unlawful act, and Safebit has the right to suspend or terminate the relevant account. The Customer is obliged to keep account information and passwords confidential. Safebit shall not be held liable for transactions carried out by third parties.
5.3.15. Unless otherwise stated, each Customer may open only one account. If it is determined that more than one account is used by the same person, Safebit has the right to close the relevant accounts without notice.
5.4. Signature Review
5.4.1. Safebit verifies the identity and signatures of the Customer or of persons acting as authorized representatives, agents, parents, guardians, or trustees by comparing the specimen signatures contained in application forms, this Agreement, signature circulars, notarized powers of attorney, and similar documents, and performs such verification physically or electronically. Safebit is entitled to verify identity and signature information through public institutions, identity verification services, notaries, banks, or authorized third-party providers within the framework of the applicable legislation.
5.4.2. Safebit acts with reasonable care and diligence in signature review and verification processes; however, unless a clear fault attributable to Safebit exists, it shall not incur any legal, criminal, or compensatory liability in the following cases:
i. Consequences arising from signature similarities or forged/imitated signatures that cannot be detected at first glance,
ii. Alterations, fraud, or deceptive acts in documents or correspondence submitted,
iii. Unauthorized use of electronic, mobile, or wet signature tools by third parties,
iv. Instructions transmitted by fax, email, or electronic channels being incomplete, incorrect, duplicate, or unconfirmed,
v. Failures, interruptions, delays, or technical malfunctions in telecommunication, internet, server, or software infrastructure,
vi. Data loss, delay, or corruption arising from errors in the Customer’s or third parties’ devices, software, or security infrastructure.
5.4.3. In the presence of suspicious or verification-required instructions, Safebit is authorized to suspend the transaction, request additional confirmation or documents from the Customer, refuse the transaction, or limit the execution of the transaction for security reasons. Safebit cannot be attributed any liability for delays, cancellations, or failures to execute transactions due to measures taken within this scope.
5.4.4. The Customer accepts, declares, and undertakes that all information, documents, and specimen signatures submitted to Safebit are owned by the Customer, accurate, and up to date; and that Safebit shall not be held liable in any way if such documents are misused, altered, or forged by third parties.
5.4.5. Safebit processes the information obtained during identity and signature verification solely for the purposes of identification, prevention of money laundering and terrorist financing, prevention of fraud, and ensuring transaction security, in accordance with the applicable legislation; and shares such data and documents only with the relevant institutions and authorities in cases required by legal obligations.
5.5. Beneficial Owner
5.5.1. The Customer declares, accepts, and undertakes that, under this Agreement, the Customer acts in the Customer’s own name and on the Customer’s own account in all accounts held with Safebit; and that the Customer does not act on behalf of or for the account of any third person or entity.
5.5.2. If the beneficial owner of the account is a person other than the Customer, or if in the future transactions are conducted on behalf of or for the account of a third person, the Customer is obliged, in accordance with the provisions of the applicable legislation—particularly Law No. 5549 and MASAK regulations—to notify Safebit in writing, immediately as of the date of becoming aware of such situation, of the identity information of the natural or legal person for whom or for whose account transactions are conducted.
5.5.3. The Customer accepts that, in the event of failure to fulfill this obligation, the Customer shall be solely responsible for all legal, administrative, and criminal consequences; and that, upon detection of such situation, Safebit has the right to suspend the relevant accounts, halt transactions, notify the competent authorities, and take other measures it deems necessary.
5.5.4. Safebit may request additional information, documents, or statements from the Customer for the purpose of identifying and verifying the beneficial owner. If the Customer fails to meet this request or provides incomplete/misleading information, Safebit reserves the right to refuse to perform the transaction or to terminate the Agreement.
5.5.5. Safebit processes the beneficial owner information reported by the Customer solely for the purposes of fulfilling legal obligations, risk-based supervision, prevention of money laundering and terrorist financing, and lawful reporting, and retains such information in compliance with the applicable legislation.
6. EXECUTION OF THE AGREEMENT AND CUSTOMER ACCOUNT OPENING
6.1. Before signing this Agreement, the Customer accepts and declares that the Customer has read, understood, and signed the Safebit Risk Disclosure Form set out above and has received a copy thereof.
6.2. By signing this Agreement, the Customer accepts that Safebit is entitled to make partial or complete amendments to the provisions of the Agreement in the future and that such amendments may be made electronically. Amendments made electronically shall be presented to the Customer after the Customer accesses the Platforms using a password sent by Safebit to one of the Customer’s contact addresses registered with Safebit. The amendments shall enter into force upon receipt of the Customer’s approval that the Customer has read and understood the relevant amendments. It is also possible for the Customer to approve the amendments with a qualified electronic signature. If the amendments are not approved by the Customer, Safebit will not accept orders from the Customer or execute Orders submitted on behalf of the Customer.
6.3. Unless otherwise stated, each Customer may open only one account. If it is determined that more than one account is used by the same person, Safebit has the right to close the relevant accounts without notice.
6.4. Upon signing of the Agreement by the Parties, Safebit shall assign a Customer number to the Customer. The Customer number assigned to the Customer shall not be assigned to anyone else unless ten years have elapsed since the termination date of the Agreement. If a registry number previously obtained from MKK on behalf of the Customer exists, Safebit shall match it with the Customer number; if not, Safebit shall obtain a registry number from MKK on behalf of the Customer and match it with the Customer number. Safebit shall obtain the MKK registry and perform the Matching Processes in accordance with the electronic transaction methods to be determined by MKK. After the registry number obtained from MKK is matched with the number assigned to the Customer, a Customer Account shall be opened on the Platforms linked to the Customer number. In accordance with its legal obligations, Safebit will not accept orders from the Customer or execute Orders submitted on behalf of the Customer until the Matching Processes are completed. Safebit will not accept orders from Customers who have not obtained a registry from MKK or whose registry has not been matched. Safebit cannot be held liable for any direct or indirect damages that the Customer may incur within the scope of this clause.
6.5. The Customer shall access the Platforms with any of the contact addresses registered with Safebit and a password. To access the Platforms, the Customer may create any password of choice, provided it complies with the security requirements set by Safebit. The Customer is responsible for the protection and security of the password, and, except where attributable to Safebit, Safebit shall not be held liable for damages arising from loss or compromise of the password. Following the Customer’s written statement regarding the loss or compromise of the password, Safebit shall immediately place a block on the account. The authority to access the account and transact with the password belongs solely to the Customer. If the Customer allows third parties to conduct transactions by sharing the password, all responsibility for such transactions rests with the Customer, except where attributable to Safebit.
6.6. As part of security measures, Safebit may request the Customer to periodically change the current password or may mandate such change.
6.7. Upon completion of the application, completion of identity verification processes, fulfillment of other legal obligations, and if deemed appropriate by Safebit, the Customer’s account on the Platform shall be activated. Activation does not grant an absolute right. If Safebit determines that the Customer has acted in violation of this Agreement or the legislation, Safebit reserves the right to suspend the relevant account, temporarily halt transactions, or terminate them entirely.
6.8. The account opened in the name of the Customer on the Platforms is allocated solely for the Customer’s use, and the Customer may place Orders, including for the purchase, sale, and exchange of Crypto Assets, provided that such actions are not contrary to the legislation, including international regulations.
6.9. If Safebit becomes aware of the Customer’s death or of a judicial decision of presumption of death, Safebit is authorized to block the account until a tax clearance certificate is submitted by the relevant tax office. No transactions shall be permitted on the account during this period. After submission of the tax clearance certificate, the rights and receivables in the account shall be paid to the heirs.
6.10. In cases of universal succession such as transfer, merger, or inheritance regarding the Customer or Customers, or changes due to the inclusion of new right holders or the withdrawal of some from joint accounts, the change must be notified to Safebit by the changing right holders or the relevant institutions or organizations. Following such notification, the Agreement must be renewed in line with the request of the changing right holders. If the changing right holders do not wish to enter into the Agreement, Safebit shall proceed in accordance with the relevant legislation. In this context, if necessary, subject to the approval of the relevant authorities—primarily MASAK and/or the Board—and within the framework of the documents evidencing universal succession, Safebit shall transfer the Customer’s rights in the account to the universal successors and close the Customer’s account.
7. TRANSMISSION, EXECUTION, AND TRANSFER PROCESSES OF ORDERS
7.1. As a rule, Customer Orders are placed electronically. All Orders of the Customer may be received through the Platforms, namely Safebit’s websites, mobile applications, or via the platform’s registered telephone lines through the platform’s operations personnel.
7.2. Upon receipt of the Orders by the Safebit system, the time of receipt, order type, price, quantity, and validity period are determined with a timestamp in an electronic recording environment. The form, content, and transmission of these Orders are subject to the provisions of the applicable legislation.
7.3. During the transmission of Orders, the Customer’s identity verification, balance sufficiency, transaction limit, order-type suitability, and authorization status are checked through automatic control mechanisms. Safebit has the right, pursuant to the provisions of the legislation, to refuse orders it deems risky in terms of identification, transaction security, or system integrity, or to request additional verification before processing them.
7.4. In disputes between the Parties regarding the existence of an Order, without prejudice to Article 193/II of the Code of Civil Procedure No. 6100, any written orders and confirmations, as well as audio and video recordings—including records created via computer networks, the Internet, and similar means—together with Safebit’s records, shall be taken into consideration as evidence or as the beginning of written evidence.
7.5. After the Customer’s Order is taken into process by Safebit, the Customer may not change or revoke the Order except for changes that are possible within the framework of the legislation and technical conditions.
7.6. The Customer accepts that the processing of Orders relating to crypto asset transfers is contingent upon the fulfillment of conditions prescribed by the legislation, and that delays or technical malfunctions may occur during the transmission or execution of orders or instructions to the Bank or to different crypto asset service providers. Safebit, the relevant crypto asset service provider, or the Bank shall be liable in accordance with their fault for such delays or technical malfunctions, or for the impossibility or delayed execution of the transaction subject to the Order.
7.7. Safebit has the right to request additional information and documents from the Customer in order to execute Orders. If the Customer fails to provide the requested information and documents accurately, completely, and on time, the Order may not be executed in accordance with the legislation applicable to Safebit. The Customer may not bring any claim against Safebit for any direct or indirect damages incurred for this reason.
7.8. In cases of deficiency, inaccuracy, invalidity, or doubt in the information contained in Orders, Safebit is free to execute or not execute the Orders. In cases where the Customer’s Order is partially or wholly not accepted by Safebit, Safebit shall notify the result to the Customer or the Corporate Customer Representative without being obliged to state the reason.
7.9. The Customer may not hold Safebit liable for Orders that are not executed due to reasons not attributable to Safebit. Safebit’s liability is limited only to cases determined by a final and binding arbitral award rendered by the competent arbitration body.
7.10. Each Order that passes the suitability checks at Safebit is automatically recorded by the Safebit system with a unique order number. Orders assigned an order number are matched with pending orders within the framework of Safebit’s current Order Execution Policy and the principles set out in this Agreement. Safebit securely stores order book records in electronic form for the legally required period.
7.11. The Customer may trade on the Platforms using limit and market order types. In limit orders, the Customer requests execution at the specified price, while in market orders, execution occurs at the prevailing market price at the time of the Order. Orders placed by the Customer are processed quickly and efficiently within the trading hours and conditions determined by Safebit. Order matching priorities are determined based on criteria such as trading volume, order type, and time.
7.12. In the event Corporate Customers use high-volume transactions or algorithmic trading models, they are obliged to notify Safebit in advance and to comply with special trading protocols.
7.13. Transfer transactions are carried out based on the Customer’s explicit and clear approval given through the Platform. The Customer accepts the irreversible nature of the transactions and transacts knowing that reversal is not possible in the event of an error. The Customer is obliged to verify the accuracy of the address and other information entered in transfer transactions and shall be solely responsible for any financial losses that may arise from incorrectly entered information.
7.14. Safebit reports and retains data relating to Customer transactions in a manner consistent with the Central Securities Depository (MKK). Customer accounts and platform accounts are kept segregated.
7.15. The Customer accepts that the Customer’s transactions on the Platforms will be transmitted to the MKK system and that, in this context, the Customer’s investor identity information, transaction data, and wallet balances will be recorded with MKK. The Customer also accepts the electronic monitoring of investor sub-accounts and balances created with MKK. The Customer agrees to register with the e-Investor Information Center system operated by MKK, to keep contact information up to date, and to follow electronic notifications regarding account activities through this system. Notifications made through this system constitute legal service of process.
7.16. Orders are executed within the scope of this Framework Agreement in line with principles of transparency and protection of Customer interests. The Customer accepts that non-execution, delay, or partial execution of Orders may arise from market conditions and technical reasons and may not hold Safebit liable without a finalized court decree.
7.17. At the moment an order is placed, Safebit does not undertake to withdraw or deposit the crypto asset or fiat currency. Safebit performs the processing of the crypto assets or fiat money sent by the Customer depending on the software and hardware infrastructure belonging to its system. Except for technical failures of the Safebit system and other unforeseeable events within the scope of this Agreement, Safebit fulfills such Customer Orders within a reasonable time. In cases of force majeure listed in this Agreement or in cases where, due to congestion, crypto asset/fiat deposit and withdrawal transactions are not executed at all or are executed late, Safebit shall not be liable for any direct or indirect damages. The Customer accepts, declares, and undertakes that the Customer shall not make any claim from Safebit for damages arising from these reasons and irrevocably releases Safebit.
7.18. Safebit is obliged—taking into account the nature of the activity performed—to issue a transaction result form and an account statement and to notify the Customer of executed Orders. Notification may be made by various methods, provided it complies with the provisions of the legislation.
7.19. In line with the executed orders, Safebit shall issue a sequentially numbered transaction result form (“Transaction Result Form”) showing the type, quantity, and price of the crypto assets bought and sold; and the commissions and expense charges accrued to the Customer. Safebit may send the issued Transaction Result Form to the electronic mail address declared by the Customer at the latest by the end of the day, or may provide the Customer with electronic access to account statements.
7.20. Account statements belonging to the Customer may be sent to the Customer’s registered electronic mail address within five (5) business days following each monthly period, or the Customers may be provided electronic access to their account statements. Safebit has the right not to send an account statement if the Customer has conducted no transactions during the relevant period.
8. CASH DEPOSIT AND WITHDRAWAL PROCEDURES
8.1. The Customer may conduct cash transfers only via a bank account registered in the Customer’s own name in accordance with the legislation of the Republic of Türkiye. The identity information of the bank account holder must exactly match that of the Platform account holder. Otherwise, Safebit has the right to reject the relevant transaction, request additional verification, or suspend the transaction.
8.2. Safebit cannot be held liable for delays, misdirection, shortfalls, or third-party interference that may arise in money transfers made via electronic money institutions, digital wallets, or similar methods. Such risks lie entirely and solely with the Customer. The Customer accepts to carry out the necessary checks and confirmations to ensure that the transfer is carried out correctly and completely. Safebit’s liability is limited to circumstances that can be attributed to Safebit.
8.3. The Customer may withdraw the balance in the Platform account only to a bank account registered in the Customer’s own name. For security, identity verification, or fulfillment of legal obligations, Safebit may request additional information, documents, or confirmations regarding cash withdrawal requests. Cash withdrawals may be delayed due to Safebit’s transaction volume, the working hours of the banking system, or technical failures. In such cases, Safebit takes all necessary measures to complete the transaction within a reasonable time. Safebit cannot be held liable for delays arising from the banking infrastructure or third-party service providers.
8.4. Until the moment the withdrawal transaction is executed by Safebit, the Customer declares acceptance of deductions, commissions, or transaction fees that may arise with Safebit, and that the relevant costs shall be borne by the Customer.
8.5. Pursuant to legal obligations or at the Customer’s request, Safebit may return cash belonging to Customers to the Customers’ bank accounts. In such cases, Safebit shall share the receipts relating to the refund electronically with the Customer via the Customer’s registered contact information.
9. CRYPTO ASSET TRANSFERS
9.1. Within the framework permitted by the legislation, Safebit has the discretion to take appropriate measures to set limits on the amounts and number of transactions relating to crypto asset transfers. The Customer has no right to object to the limitations applied at Safebit’s discretion.
9.2. While processing Orders relating to crypto asset transfers, Safebit may request additional information and documents from the Customer due to its legal obligations. The Customer is obliged to exercise the necessary diligence and cooperation in line with the requests directed at the Customer to ensure Safebit’s compliance with legal obligations.
9.3. It is required to send an information message regarding crypto asset transfer transactions intermediated by Safebit, and the information message shall be created in a content and format prescribed by the legislation. Within the monetary limits regulated by the legislation, Safebit may request information and documents from the Customer regarding the sender and recipient for inclusion in the messages.
9.4. In crypto asset transfers, Safebit sends the information on the sender and recipient simultaneously with the transfer through secure communication channels. Safebit has exclusive discretion to determine the method to be used for sending transfer messages. In this context, provided it is in compliance with the legislation, Safebit may, at its discretion, use any software applications and technological tools that enable messaging, such as distributed ledger technology, an independent messaging platform belonging to itself or its contracted partners, or an application interface.
9.5. If the Customer is a party to a crypto asset transfer received from or sent to a crypto asset service provider or a financial institution authorized for crypto asset transfers that is located abroad and, under its own legislation, has no obligation to share information on the sender and the recipient, the transfer shall be executed provided that the Customer’s statement is obtained.
9.6. In crypto asset withdrawal transactions intermediated by Safebit, including transfers made to a crypto asset service provider other than Safebit, the transfer transaction shall be executed within the scope of the obligations to which Safebit is subject under the applicable legislation. In this context, Safebit shall not wait for the period prescribed in the legislation regarding the purchase, exchange, or deposit transaction of the crypto asset to be transferred, and the Customer may not make any claim against Safebit for this reason.
9.7. Due to the nature of distributed ledger technology, transfer transactions are irreversible and cannot be canceled once confirmed. Safebit cannot intervene in erroneous transfers made on the blockchain; in such cases, all responsibility lies with the Customer.
9.8. In withdrawals of Crypto Assets that aim to maintain a stable value by reference to one or more official currencies, another value, a right, or a combination thereof, including transfers made to other crypto asset service providers, Safebit is obliged to apply limits as prescribed by the legislation. As a rule, the limits in force on the signing date of this Agreement are applied as an amount equivalent to USD 3,000 per day and USD 50,000 per month.
9.9. In the event that the limits determined by the legislation are changed, increased, decreased, or new types of limits are introduced, such changes shall automatically produce legal effect from their effective date without any additional approval or amendment to the Agreement. Safebit shall immediately implement these changes and update its systemic and operational processes relating to withdrawals accordingly.
9.10. Safebit shall announce the new limits to be applied pursuant to changes prescribed in the legislation or by administrative authorities, either a reasonable time before their effective date or at the latest on the same day, by publishing them on its website or notifying the Customer at the Customer’s email address registered in the system. Such notification is for informational purposes and does not affect the validity or applicability of the new limits.
9.11. In all Crypto Asset transfer transactions to be carried out through the Platforms, the Customer is obliged to enter a transaction description of at least 20 characters relating to the nature of the transaction.
9.12. In accordance with its legal obligations, Safebit takes necessary measures regarding customer due diligence and periodically obtains relevant information and documents, including information on the source of assets and account details with banks or other platforms. In this context, the Customer is obliged to cooperate with Safebit and to provide accurate and complete information.
9.13. Safebit establishes necessary control and oversight mechanisms to prevent Customers from circumventing the time and limit measures prescribed in the legislation for Crypto Asset transfers. The Customer shall not, knowingly or unknowingly, engage in any conduct aimed at bypassing, evading, or manipulating any control or oversight mechanism established by Safebit.
9.14. If Safebit determines that a Crypto Asset transfer is carried out solely for the purposes of liquidity provision, market making, or inter-market arbitrage, Safebit may, by a Board of Directors decision to be taken separately for each Customer, decide not to apply the time and limit measures prescribed by the legislation. The authority to render such decision rests exclusively with Safebit. Safebit’s right to request additional information and documents from the Customer due to its legal obligations is reserved.
9.15. In line with its operational processes and legal obligations, Safebit is authorized to set daily, weekly, and monthly deposit or withdrawal limits for money and Crypto Assets beyond the cases stipulated in the legislation.
9.16. To learn the monetary limits referred to in this Agreement and determined pursuant to the legislation, the Customer may review the relevant Policy available on the Platforms or contact Safebit.
10. OFF-PLATFORM CRYPTO ASSETS
10.1. In transfers made over blockchain networks not supported by Safebit, Safebit is not responsible for losses arising from delays, errors, losses, or failed transactions due to the technical features, transaction confirmation mechanisms, or verification processes of these networks. The Customer accepts that the Customer may only transact with Crypto Assets listed on the Platform and expressly stated to be supported by Safebit.
10.2. The Customer accepts that, in the event Crypto Assets not listed or supported on the Platform are sent to Platform wallet addresses, the risk that such assets cannot be recovered or accessed belongs entirely to the Customer. Safebit is under no obligation to recover, refund, or track such transfers; however, entirely at its own discretion and to the extent technically feasible, it may evaluate the Customer’s request for a fee.
10.3. If Safebit determines that transactions are carried out with persons, entities, or wallet addresses included on national or international sanctions lists (for example, UN Security Council, OFAC, European Union, or the Ministry of Treasury and Finance lists) or that transfers are effected indirectly related to such addresses, Safebit is authorized to immediately suspend the relevant Customer accounts, halt transactions, and make necessary notifications to the relevant authorities.
10.4. The Customer accepts that Safebit has no control, supervision, or protection obligation over Crypto Assets held off the Platform, with third-party crypto asset service providers, or in personal wallets; and that all risks arising from the security, accessibility, transfer, or transactions carried out by third parties regarding such assets lie solely with the Customer.
10.5. Safebit is not responsible for consequences arising from hard forks, airdrops, token swaps, chain splits, staking, slashing, reorganizations (reorgs), or similar technical changes occurring in the technical structure of any Crypto Asset or in the blockchain protocol. In such cases, Safebit has the authority to determine whether the relevant asset will be supported on the Platform. Safebit’s obligation to notify the competent authorities is reserved.
11. CUSTODY AND INTERESTING OF CUSTOMER FUNDS
11.1. Customer funds held with Safebit are safeguarded entirely separately from Safebit’s own assets at banks contracted by Safebit, within the framework of the provisions of the legislation and the matters determined by the relevant regulatory authorities. Customer funds shall in no event be subject to pledge, lien, attachment, or blocking for Safebit’s operational activities, commercial debts, or third-party obligations.
11.2. Safebit works only with banks compliant with the legislation to ensure the security, accessibility, and integrity of Customer funds. The current list of contracted banks is published on the Platforms, primarily on Safebit’s website, and may be updated as needed. Safebit reserves the right to change the contracted bank or account information. The Customer accepts, declares, and undertakes that the Customer will not claim any damages, losses, or compensation due to such changes that may be made by Safebit in bank information or account structure.
11.3. In the future, provided it is in compliance with the legislation and the Board’s regulations, Safebit may enable Customer funds to accrue interest or generate returns. In such case, the applicable principles, rates, periods, deduction or commission rates, and distribution methods shall be determined by Safebit and announced to Customers via the website. The Customer accepts that, if an interest-accrual practice is initiated, deductions or commissions at rates to be determined by Safebit may be taken from the gross return generated, and the remaining amount shall be reflected to the relevant Customer accounts in proportion to their assets.
11.4. The Customer accepts, declares, and undertakes that the Customer is aware that funds not subject to interest accrual are held solely for the purpose of protection and safekeeping; that Safebit does not use such amounts in any investment, credit, or income-generating transaction; and that the Customer will not claim any interest, return, or yield from Safebit in periods where no interest accrual is applied.
11.5. Safebit cannot be held liable for temporary access restrictions or delays that may arise due to systemic malfunctions, technical failures, delays arising from banking transactions, or force majeure events that may occur at the banks where Customer funds are held.
12. CUSTODY OF CRYPTO ASSETS
12.1. Safebit stores Customers’ Crypto Assets in Cold and Hot wallets. At least 97% of Customer assets are held in Cold Wallets. Customers’ Crypto Assets are kept in accounts separate from Safebit’s assets. Safebit implements technical methods such as multi-signature, use of HSM (Hardware Security Module), and offline storage for the custody and security of Customer Assets.
12.2. The custody service is provided by Custody Service Providers, and Customers’ assets are clearly segregated from Platform accounts. The Customer is obliged to exercise necessary diligence regarding the security of Private Keys.
12.3. Customer assets are protected against cybersecurity threats, and a cybersecurity insurance policy—reviewed annually by Safebit against risks that may occur on the system—is in effect.
12.4. In addition, a price surveillance system is implemented to prevent price manipulation, and written procedures regarding the functioning of this system are periodically audited within the scope of internal audit and control processes.
13. FEES, COMMISSIONS, AND OTHER EXPENSES
13.1. Taxes and legal obligations of all transactions carried out through the Platform belong to the Customer. The Customer is obliged to fulfill legal responsibilities regarding arising profits, losses, and expenses. Safebit does not provide tax advisory services or assume legal responsibilities.
13.2. It is deemed that the Customer is aware of the type of Orders placed. Where necessary, Safebit may execute transactions through contracted third-party exchange platforms. In cases where orders are executed at levels different from the prices seen by the Customer due to market conditions, any losses that may arise from such technical necessities are not the responsibility of Safebit. The Customer accepts price differences that may arise from reasons such as slippage, increased spreads, and market volatility, and that these are a result of market conditions.
13.3. Crypto asset buy-sell transactions carried out by Customers through the Platform, as well as TL and/or crypto asset withdrawals and deposits to and from off-Platform, are subject to transaction fees and/or commissions determined by Safebit.
13.4. The fees, commissions, and expense rates to be applied by Safebit may vary according to transaction type, transaction volume, transfer direction, and similar parameters. Current information on these fees is clearly published on the website www.safebit.com.tr and made accessible through the Platform. The Customer declares that the Customer has read, understood, and accepted these pricing principles.
13.5. Safebit reserves the right to change transaction fees and commission rates unilaterally and without prior notice. Changes are announced on the Platform and enter into force as of the announcement date. Platform records are taken as the basis for assessments on this matter.
13.6. The transaction fee may (i) be collected directly from the Customer’s TL or crypto asset balance on the Platform, (ii) be deducted from the relevant transaction amount, or (iii) in case of insufficient balance, the transaction may be rejected.
13.7. The transaction fee is the consideration for the performance of the service and, even if the transaction fails to be executed or is canceled for any reason, it is not refunded since the service has commenced.
13.8. In consideration of the services provided to the Customer, Safebit collects an annual commission fee each year. This fee is charged to cover operational costs such as the maintenance of the platform’s technical infrastructure, security, customer support services, fulfillment of regulatory obligations, and similar expenses. The annual commission fee accrues separately from transaction-based commissions, as consideration for general service provision.
13.9. The amount of the annual commission fee is reviewed annually within the framework of market conditions, the scope of the service provided, and the relevant legislation, and may be updated if deemed necessary. The updated amount is announced via the platform’s website or Customer interface and becomes effective as of the following annual period.
13.10. The Customer’s not actively using the platform during the period in which the annual commission fee accrues does not require a refund of this fee. If the annual commission fee is not paid within the prescribed period, Safebit reserves the right to limit services or to terminate the Agreement. In such case, the other rights and obligations of the Parties arising from the Agreement shall remain unaffected.
13.11. The Customer accepts, declares, and undertakes not to object to the transaction fees and the pricing system collected under this clause, not to hold Safebit liable for any dispute that may arise regarding the collection of fees, and to irrevocably release Safebit in these matters.
14. PROHIBITED USES
14.1. The activities listed below are prohibited under this Agreement, and the Customer declares and accepts that the Customer will not use the account for the following activities (“Prohibited Uses”):
14.1.1. Using the Services in any way that prevents other Customers from fully benefiting from the Services, disrupts them, adversely affects them, or damages, disables, or places excessive load on the functionality of the Services;
14.1.2. Using the Services to pay for, support, or participate in any illegal gambling activity, fraud, money laundering, terrorist activities, or other unlawful activities;
14.1.3. Accessing the Services or extracting data using any robot, spider, crawler, scraper, or other automated method or interface not provided by Safebit;
14.1.4. Unauthorized use or attempted use of another Customer’s account; threatening, harassing, stalking, or violating the legal rights of another party; or encouraging speech or actions involving hate, intolerance, or violence;
14.1.5. Attempting to bypass Safebit’s controls or technology or attempting to access an unauthorized service;
14.1.6. Developing third-party applications that interact with the Services without Safebit’s prior written consent;
14.1.7. Creating or conducting misleading, false, deceptive, or manipulative transactions or activities, including manipulative or prearranged trades;
14.1.8. Encouraging or directing third parties to engage in the activities prohibited in this Section;
14.1.9. Acting directly or indirectly contrary to the regulations set forth in the legislation and international agreements, regardless of whether it is intentional.
14.2. Safebit has the right, in accordance with its legal obligations, to categorize Customer Orders as Prohibited Uses and apply necessary measures in the following cases, including but not limited to:
14.2.1. Using external or third-party programs in your trading transactions;
14.2.2. Suspicious and/or fraudulent activities;
14.2.3. Transactions conducted in bad faith to obtain benefits together with other Customers;
14.2.4. Use of multiple IP addresses to carry out a DDoS attack;
14.2.5. Causing price delays in the system via external or third-party programs;
14.2.6. Stealth attacks on the system;
14.2.7. Unusual/suspicious transactions (drugs, money laundering and financing of terrorism, immoral transactions, unauthorized games of chance, gambling, etc.);
14.2.8. Placing orders at manipulated prices;
14.2.9. Attempting money laundering and/or financing of terrorism and/or other unlawful activities;
14.2.10. Conducting scalping activity.
14.3. By accessing and using the Safebit Platforms, the Customer respectively:
14.3.1. Declares that the Customer has not opened an account using a false identity or using the identity information of a third party without authorization, and has not applied for or opened more than one account for the same person;
14.3.2. Declares that the Customer resides in a country where the Services provided by Safebit do not constitute a violation of the legislation of the country of residence or any other regulation applicable to the Customer; that the Services may only be used by persons residing in countries where crypto asset trading activities or services within this scope are not prohibited by local law; and that it is the Customer’s own responsibility to determine the provisions of the local legislation to which the Customer is subject and to act in compliance therewith;
14.3.3. Declares that the Customer currently complies with the provisions of this Agreement and will fully comply with these provisions throughout the term of the Agreement;
14.3.4. Declares that the Customer does not engage in transactions or activities deemed prohibited by Safebit;
14.3.5. Declares that the Customer does not infringe any intellectual property right belonging to Safebit or third parties;
14.3.6. Declares that the Customer is not subject to any trade embargo or economic sanctions regime; is not listed on the “Specially Designated Nationals (SDN) List” maintained by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC), or on sanctions lists published by MASAK or any other competent authority;
14.3.7. Declares that the Customer has not allowed the Customer’s account to be used on behalf of any third party or for the benefit of persons who do not have disposal authority over the account in return for commission, benefit, or other gain, and that the ultimate beneficial owner of the account is the Customer personally,
accepts and undertakes.
14.4. The Customer undertakes to use the Platform only for lawful purposes, in accordance with the rules of good faith and the legislation. The Customer personally assumes all legal liabilities that may arise in transaction processes. In the event of detection of unlawful use, Safebit may take necessary measures, including suspension of transactions, freezing of accounts, or cancellation of membership. In addition, the Customer:
i. Accepts not to share content that is immoral, threatening, illegal, or that infringes the rights of third parties,
ii. Accepts not to engage in conduct that would harm the rights of other Customers and the security of the Platform,
iii. Accepts to comply with the general rules of use of the Platform and community standards.
Foreign-resident corporate Customers are responsible for compliance with their own national legislation. The Platform may share Customer information in accordance with the requests of foreign regulatory authorities.
15. MARKET STABILITY AND SAFEBIT’S RIGHT OF INTERVENTION
15.1. Safebit is authorized to unilaterally intervene in cases where it determines any activity that does not reflect real market conditions due to systemic or technical failures, transactions that distort price formation or constitute market manipulation, transactions aimed at gaining unfair profits from price differences between crypto assets, or any activity that generally threatens service integrity or adversely affects platform operations, for the purpose of protecting Customer rights, ensuring market stability, and maintaining compliance with applicable legislation.
15.2. In this context, Safebit has the right to cancel such transactions, reverse their results, correct transaction records, temporarily suspend related Customer accounts, or take other necessary measures. Safebit shall inform the Customer through appropriate communication channels regarding such interventions but shall not assume any liability for transaction cancellations, corrections, or interventions carried out for the reasons stated.
15.3. The Customer accepts, declares, and undertakes not to make any claim, demand, compensation, or similar request due to such actions carried out by Safebit in accordance with applicable legislation or for the purpose of maintaining market stability.
15.4. Even in such circumstances, unless there is a legal restriction, sanction, or judicial decision, the Customer’s assets on the Platform shall be returned upon request within ninety (90) days at the latest. If the Customer fails to provide a valid crypto wallet address, the said assets shall be converted into Turkish Lira by Safebit in accordance with current market conditions and refunded accordingly.
15.5. Safebit shall have the following rights under this Agreement:
15.5.1. If the Customer violates any obligations declared and/or undertaken under this Agreement, or if the Customer’s account is used for Prohibited Activities or there is reasonable suspicion thereof, Safebit, at its sole discretion, shall have the right to temporarily or permanently suspend or terminate the Customer’s Account.
15.5.2. Safebit may, at any time and at its sole discretion, terminate any Service and/or Product it provides, or delist any Crypto Asset traded on its platform. In such cases, Safebit shall notify the Customer to allow necessary action on the relevant balance related to the Crypto Asset. The relevant procedures shall be carried out pursuant to the “Listing and Delisting Procedure” published on Safebit Platforms. By signing this Agreement, the Customer acknowledges that they have read and understood the said Safebit Policies and Procedures. Upon notification, the Customer is obliged to immediately cancel all open Orders related to the removed Service/Product or Crypto Asset. Otherwise, all relevant Orders not canceled by the Customer shall be acted upon by Safebit on its own initiative, provided it does not contravene the legislation.
15.5.3. If the Customer’s Account is found to have been used for prohibited transactions or activities, or if reasonable suspicion arises in this regard, Safebit reserves the right to notify MASAK and other competent public authorities and institutions as required under the Law No. 5549 on the Prevention of Laundering Proceeds of Crime and its secondary regulations.
16. OTHER RIGHTS AND OBLIGATIONS OF THE PARTIES
16.1. To ensure Customer security and regulatory compliance, Safebit implements Customer identification and verification procedures within the framework of the Capital Markets Law No. 6362, MASAK regulations, and relevant secondary legislation.
16.2. The Customer is obliged to correctly and completely complete all identification and security verifications required during the registration and pre-transaction processes to fully benefit from the Platform. In case of false, misleading, or incomplete information, Safebit reserves the right to suspend, terminate, or restrict the Customer’s account. All Customers are required to keep their information up to date. Changes must be reported within 7 (seven) days at the latest. The Customer is solely responsible for all consequences arising from this obligation.
16.3. Safebit reserves the right not to accept transaction orders or fiat/crypto asset transfers placed by the Customer in cases of technical, security, or regulatory non-compliance. In such cases, no liability shall be attributed to Safebit, and the Customer may not make any claims or demands.
16.4. The Customer declares that the transactions conducted comply with the legislation and are not related to illegal activities such as money laundering or terrorist financing. Due to the untraceable nature of crypto asset transfers, the final purpose of transactions may not be technically traceable. The Customer is solely responsible for all direct or indirect losses arising from the misuse of crypto assets.
16.5. Safebit is obliged to securely retain all transaction orders, order books, matching and reconciliation records made on the Platform for at least 10 (ten) years as required by legislation. This obligation continues even after the termination of the Customer’s account.
17. ACCOUNT CLOSURE
17.1. The Customer may request the complete closure of their account at any time and without providing justification. To submit this request, the Customer must send a signed and self-photographed petition with identification to [email protected]. The Customer’s request shall be processed, and the account shall be closed within 30 (thirty) days following the receipt of the request.
17.2. Safebit has the right to close, suspend, or impose limits on the Customer’s account in accordance with its obligations under legislation and the provisions of this Agreement. The transaction details and data of a Customer whose account has been closed shall continue to be stored by Safebit for the legally required periods.
18. CUSTOMER LIABILITY, RISK, AND LEGAL DISCLAIMER
THE CUSTOMER ACKNOWLEDGES CERTAIN RISKS ASSOCIATED WITH INVESTING IN CRYPTO ASSETS. IN THIS CONTEXT, THE CUSTOMER DECLARES THAT THEY POSSESS THE NECESSARY EXPERIENCE AND KNOWLEDGE REGARDING CRYPTO ASSET TRADING AND INVESTMENT. THE CUSTOMER ACCEPTS THAT THE PRICES OF CRYPTO ASSETS ARE HIGHLY VOLATILE AND THAT THIS REQUIRES AN ASSESSMENT OF FINANCIAL AND LEGAL RETURNS AND RISKS. THEREFORE, THE CUSTOMER MAY NOT HOLD SAFEBIT, ITS MANAGERS, EMPLOYEES, CONSULTANTS, AFFILIATES, OR SUBSIDIARIES LIABLE FOR ANY NEGATIVE SITUATION OR FOR LOSSES OR DAMAGES ARISING FROM OR RESULTING FROM SERVICES PROVIDED OR TRANSACTIONS CONDUCTED UNDER THIS AGREEMENT.
BY ACCEPTING THIS AGREEMENT, CUSTOMERS DECLARE THAT THEY UNDERSTAND AND ACCEPT THE RISKS INVOLVED IN INVESTING IN CRYPTO ASSETS. CUSTOMERS ARE SOLELY RESPONSIBLE FOR PROFITS AND LOSSES ARISING FROM PRICE FLUCTUATIONS AND HAVE NO RIGHT TO MAKE ANY CLAIM AGAINST SAFEBIT IN THIS REGARD.
IN THE EVENT THAT THE USE OF THE SERVICES AND PRODUCTS PROVIDED UNDER THIS AGREEMENT RESULTS IN TAX LIABILITIES, THE CUSTOMER SHALL BE SOLELY RESPONSIBLE FOR SUCH TAXES. CORPORATE CUSTOMERS ARE ALSO PERSONALLY RESPONSIBLE FOR ALL TAXES, DUTIES, AND OTHER FINANCIAL LIABILITIES ARISING FROM THEIR OPERATIONS. WITHIN THIS CONTEXT, THE INVESTMENT RISK, KNOWLEDGE LEVEL, AND TRANSACTION COMPETENCE ARE CONSIDERED TO HAVE BEEN SELF-ASSESSED. SAFEBIT CANNOT BE HELD LIABLE IN ANY WAY FOR SUCH TAXATION PROCESSES. SAFEBIT SHALL ONLY BE HELD LIABLE FOR CLAIMS ARISING FROM FINALIZED COURT DECISIONS IN CIRCUMSTANCES ATTRIBUTABLE TO SAFEBIT ITSELF, INCLUDING DAMAGES RESULTING FROM SUPPORT PROVIDED BY ITS EMPLOYEES.
SAFEBIT SHALL IN NO WAY BE HELD LIABLE FOR LOSSES SUFFERED BY PERSONS WHO BECOME MEMBERS OF "FAKE" WEBSITES CREATED USING THE SAFEBIT NAME AND LOGO. CUSTOMERS MUST ALWAYS ACCESS THE PLATFORMS THROUGH WWW.SAFEBIT.COM.TR OR THE SAFEBIT MOBILE APPLICATION AND VERIFY THE ADDRESS UPON EACH LOGIN. THE CUSTOMER ACCEPTS, DECLARES, AND UNDERTAKES THAT SAFEBIT IS IRREVOCABLY RELEASED FROM ANY LIABILITY FOR DAMAGES THAT MAY ARISE IN THIS REGARD.
SINCE TRANSACTIONS CONDUCTED ON THE BLOCKCHAIN NETWORK ARE IRREVERSIBLE, THE CUSTOMER MUST BE AWARE THAT ERRORS MADE IN TRANSFERS, WALLET-TO-WALLET TRANSACTIONS, OR TRANSFERS TO COLD WALLETS CANNOT BE UNDONE. THEREFORE, THE RESPONSIBILITY LIES ENTIRELY WITH THE CUSTOMER. SAFEBIT DOES NOT INTERVENE IN THE PROCESS OTHER THAN EXECUTING TRANSACTIONS IN ACCORDANCE WITH INSTRUCTIONS. DUE TO THE NATURE OF BLOCKCHAIN TECHNOLOGY, CRYPTO ASSET TRANSFERS CANNOT BE REVERSED, AND THEREFORE, REFUNDS OF AMOUNTS PAID, INCLUDING TRANSACTION FEES AND COMMISSIONS, ARE NOT POSSIBLE. THE CUSTOMER MUST ENSURE THE ACCURACY OF THE INFORMATION ENTERED AND CONFIRM THE TRANSACTION BEFORE EXECUTION. THE CUSTOMER ACCEPTS THAT TRANSACTIONS CONDUCTED ON THE BLOCKCHAIN ARE IRREVERSIBLE AND CANNOT BE CANCELED AND THAT THE CUSTOMER IS RESPONSIBLE FOR SUCH TRANSACTIONS.
SAFEBIT MAKES NO WARRANTIES WHATSOEVER, INCLUDING BUT NOT LIMITED TO MERCHANTABILITY, PERFORMANCE, MARKETABILITY, OR FITNESS FOR A PARTICULAR PURPOSE, REGARDING THE RESULTS THAT MAY BE OBTAINED BY CUSTOMERS FROM THE SERVICES PROVIDED. ALL CONTENT IS PROVIDED TO THE CUSTOMER "AS IS." CONTENT PUBLISHED BY SAFEBIT ITSELF OR ON THIRD-PARTY SOCIAL MEDIA PLATFORMS IS FOR INFORMATIONAL PURPOSES ONLY. SAFEBIT CANNOT BE HELD LIABLE FOR ANY PROFIT LOSS OR ADVERSE DAMAGE THAT MAY RESULT FROM CUSTOMERS RELYING ON SUCH CONTENT. REFERENCES MADE IN THE SERVICES OR CONTENT PROVIDED BY SAFEBIT TO ANY PERSON, INSTITUTION, COMPANY, OR BRAND DO NOT CONSTITUTE INVESTMENT ADVICE OR RECOMMENDATIONS REGARDING THEIR MARKET VALUE, BRAND VALUE, OR STOCK TRANSACTIONS.
ALL DATA, ANALYSES, REPORTS, AND STATISTICS ON THE PLATFORM ARE PROCESSED BY AUTOMATED SOFTWARE WITHOUT ANY MANUAL REGULATION OR DIRECTION AND PRESENTED OBJECTIVELY. THE NEWS AND REPORTS PROVIDED BY SAFEBIT ARE FOR INFORMATIONAL PURPOSES ONLY AND DO NOT CONSTITUTE DIRECT SOLUTIONS, CONCLUSIONS, LEGAL OPINIONS, OR POLITICAL OR SOCIOLOGICAL RESEARCH INFORMATION; THEIR ACCURACY IS NOT GUARANTEED. DATA MAY BE CONTRADICTORY OR INCONSISTENT; SAFEBIT ASSUMES NO LIABILITY IN SUCH CASES.
The Customer acknowledges that the prices of crypto assets may fluctuate suddenly and that all or part of the invested amount may be lost. The Customer declares understanding of the risks associated with these transactions and that their financial situation is sufficient to bear such risks.
The Customer, upon accepting this Agreement in writing or electronically, declares that they have read, understood, and accepted the “General Risk Disclosure Form” beforehand and have provided physical or electronic confirmation thereof via the Platform.
19. PROTECTION OF PERSONAL DATA AND PRIVACY
19.1. Safebit diligently protects Customers’ personal data within the scope of the Law on the Protection of Personal Data (KVKK). Personal data shared by Customers may be collected and processed by Safebit in accordance with the KVKK and related legislation. By signing this Agreement, the Customer acknowledges and declares that the necessary disclosure and information regarding the processing of Personal Data have been provided.
19.2. Safebit records the Customers’ IP addresses, the devices and models they use to access the Platform, operating systems, and browser information. Safebit may use the collected Personal Data within the framework of its legal obligations and operational activities to create general Customer profiles, ensure Customer and system security, and prevent fraud. The Customer’s Personal Data shall not be used or shared with third parties for any purpose other than Safebit’s legal obligations and operational activities.
19.3. Safebit may provide links to other websites or applications within the Platform. It may display advertisements from contracted third parties or offer application forms related to various services, thereby directing Customers to third-party sites or applications. Safebit assumes no responsibility for the privacy practices and policies or the content of third-party applications or websites accessed via these links.
19.4. The Customer may review Safebit’s Personal Data Protection Policy at any time via www.Safebit.com.tr and may contact Safebit at any time to obtain further information regarding personal data processing activities.
20. INTELLECTUAL PROPERTY RIGHTS
20.1. All software, design, domain name, interfaces, algorithms, drawings, models, and designs of the services provided through the Platforms—including the Safebit brand and logo—and all content created by Safebit (excluding third-party content and applications), as well as all trademarks, designs, logos, trade dress, slogans, videos, and other intellectual and industrial property rights, belong to Safebit. The software, design, and copyrights of the provided services also belong to Safebit.
20.2. The Customer may not use, share, distribute, display, reproduce, reverse-engineer, or create derivative works from the intellectual property owned by Safebit without written permission. The Customer may not use all or any part of the mobile application or Platform in another medium without Safebit’s written consent.
20.3. If the Customer infringes the intellectual property rights of Safebit or third parties, the Customer shall be liable to compensate Safebit or the relevant third party for all direct and indirect damages and costs.
21. LEGAL AND PENAL SANCTIONS
21.1. By accepting this Agreement, the Customer is deemed to have read and accepted all current and future statements and secondary regulations issued by competent authorities including SPK, MASAK, and TÜBİTAK concerning all Crypto Assets. The Customer is responsible under this Agreement for any consequences arising from the use or unauthorized use of the Platforms for unlawful purposes. The Customer accepts, declares, and undertakes not to hold Safebit liable in this regard. Safebit reserves the right to prohibit any individual whose account has been frozen, deleted, or suspended from opening a new account indefinitely.
21.2. By accepting this Agreement, the Customer undertakes to use the Platform in compliance with the Law, the legislation, and secondary regulations. Safebit reserves the right to share all information belonging to the Customer with the competent authorities in the event of detection of illegal use. This shall not be considered a violation of confidentiality, and Safebit shall not accept any liability arising therefrom.
21.3. The Customer undertakes not to make statements that tarnish Safebit’s name, damage its commercial reputation, or create unfair competition. This commitment covers all written and visual media platforms, including social media. In the event of a breach of this clause, Safebit has the right, without prior notice, to unilaterally terminate the Agreement, block, suspend, or permanently delete the Customer’s account. Furthermore, Safebit may claim compensation for any damages arising from such breach. The Customer accepts, declares, and undertakes in advance that they waive any objection or claim in the event Safebit exercises its rights under this clause.
21.4. Safebit has the right to temporarily or permanently disable the accounts of Customers who attempt suspicious transactions, suspend trading orders, freeze accounts, or temporarily close them for security and operational reasons. Furthermore, Safebit reserves the right to enforce seizure (blocking) measures on Customer assets upon judicial or administrative requests or notifications from banks. Safebit shall not be held legally or criminally liable for actions taken in good faith and in accordance with the principles of fairness.
21.5. Safebit has the right to temporarily or permanently suspend trading for Customers who use improper language in communications conducted via [email protected], Live Support, or the Contact Center. Safebit shall not be held legally or criminally liable for enforcing this clause in accordance with the principles of fairness and good faith.
21.6. If Safebit mistakenly transfers Crypto Assets to the Customer, resulting in unjust enrichment, this shall be immediately notified to the Customer by electronic mail, call, or SMS. If the Customer fails to return the assets within 1 (one) business day despite notification, Safebit reserves the right, without further notice, to close, suspend, or permanently restrict access to the Customer’s account. Additionally, Safebit may debit the Customer’s account by the amount of the mistaken transfer and pursue legal remedies. Safebit reserves the right to claim compensation for any direct or indirect losses incurred as a result.
21.7. If Safebit determines that the Customer has violated any provision(s) of this Agreement, such determination shall not mean that the Agreement has been terminated, that legal action has not been taken, or that these rights have been waived. Safebit’s rights regarding such violations remain fully reserved.
22. FORCE MAJEURE
Safebit shall not be liable for delayed or non-performance of its obligations under this Agreement due to the following circumstances, including but not limited to, and such events shall not be deemed a breach of the Agreement:
i. Uprising, embargo, government intervention, rebellion, occupation, war, mobilization, strike, lockout, labor actions, or boycotts;
ii. Cyberattacks, communication failures, infrastructure and internet outages, system upgrades or maintenance, problems arising from third-party service providers, and resulting malfunctions;
iii. Power outages, fires, explosions, storms, floods, earthquakes, landslides, epidemics, extreme weather conditions, or other natural disasters;
iv. Legal or administrative regulations, prohibitions; or
v. Other events beyond Safebit’s control, not arising from its fault, and reasonably unforeseeable.
Such events shall constitute force majeure, and the Parties’ obligations under this Agreement shall be suspended for the duration of the force majeure.
23. SUPPORT SERVICES
If the Customer wishes to receive support regarding the services, they may contact Safebit via the email address [email protected]. Additionally, Safebit provides a Live Support and Contact Center service through the Platform.
24. TERMINATION OF THE AGREEMENT
24.1. The Customer has the right to terminate this Agreement at any time by ending their membership through the Platforms. If the Customer acts contrary to the Agreement or legislation, Safebit may immediately and unilaterally terminate the Agreement. The Customer is solely responsible for any damages arising from conduct contrary to the Agreement or the legislation.
24.2. If the Customer violates this Agreement, uses the services provided by Safebit unlawfully, poses a threat, creates a security risk, attempts to exploit vulnerabilities on the Platforms for unfair gain, or conducts abnormal trading of Crypto Assets, Safebit shall have the right to unilaterally cancel, reverse, freeze, suspend, or terminate the Customer’s transactions or membership, prevent the Customer from opening new accounts, or take other necessary measures, with or without justification. Upon termination of this Agreement, subject to the provisions of the legislation, the Customer may transfer their legal assets to another Wallet or convert them to Turkish Lira and transfer them to their bank account.
25. NUMBERING AND DELIVERY OF THE AGREEMENT
25.1. This Agreement is issued by Safebit with consecutive serial numbering, and the copy delivered to the Customer bears the phrase “certified true copy” and is confirmed with signature/stamp.
25.2. In agreements approved electronically, this information is stored in a digital recording medium; changes made to the agreement are carried out with the Customer’s approval, qualified electronic signature, or secure electronic confirmation methods.
26. MISCELLANEOUS PROVISIONS
26.1. This Agreement is valid for all Customers who register on the Platform as an individual or corporate Customer and give electronic approval. In addition, the term “Customer” used throughout the agreement shall be interpreted, depending on the context, to cover both natural-person individual Customers and legal-entity Corporate Customers.
26.2. This Agreement becomes valid as of the date it is published on the site by Safebit, retroactively covering all former and new Customers.
26.3. No clause in this Agreement may be interpreted in a way that prevents the Customer from fulfilling legal obligations, complying with relevant regulations, or being audited.
26.4. The failure of either Party to exercise, or delay in exercising, any right, power, or privilege arising from this Agreement shall not be construed as a waiver thereof. A waiver of any provision, condition, or term of this Agreement shall not be construed as a continuing waiver of such provision, condition, or term.
26.5. Safebit may amend all terms and provisions set forth in this Agreement without prior notice. Unless otherwise required by the Legislation, changes shall become binding on the Customer with the Customer’s approval. However, the changes made shall be announced on Safebit’s website at www.safebit.com.tr.
26.6. This Agreement constitutes the entire agreement between the Parties with respect to the subject matter. If any provision of this Agreement is determined by any competent court, arbitral tribunal, or administrative authority to be wholly or partially invalid, unenforceable, or unreasonable, this Agreement shall be deemed severable to the extent of such invalidity, unenforceability, or unreasonableness, and the remaining provisions shall remain in full force and effect.
26.7. The Customer may not assign, in whole or in part, the rights or obligations under this Agreement without the prior written consent of Safebit. Safebit may assign and transfer any rights, obligations, debts, and/or receivables arising from this Agreement without any consent.
26.8. The Customer accepts that, in disputes arising from this Agreement, Safebit’s official books and commercial records, as well as e-archive records, electronic information, and computer records kept in Safebit’s databases and servers, shall constitute binding, conclusive, and exclusive evidence, and that this clause is an Evidence Agreement within the meaning of Article 193 of the Turkish Code of Civil Procedure No. 6100.
26.9. In disputes arising from this Agreement or the use of the Platforms, this Customer Agreement and the laws of the Republic of Türkiye shall apply, and the Istanbul Anatolian Courts and Enforcement Offices shall have exclusive jurisdiction for the resolution of such disputes.
27. GOVERNING LAW AND DISPUTE RESOLUTION
27.1. The laws of the Republic of Türkiye shall apply to this Agreement.
27.2. All disputes arising from or in connection with this Agreement shall be finally resolved by arbitration before the Istanbul Arbitration Center (ISTAC) under the Fast-Track Arbitration Rules. The language of arbitration shall be Turkish. The seat of arbitration is Istanbul/Türkiye. Turkish law shall apply to the merits of the dispute, and the number of arbitrators shall be as provided in the ISTAC rules.
28. EFFECTIVENESS AND ACCEPTANCE
28.1. This Agreement consists of 28 (twenty-eight) articles and enters into force on the date the Customer starts using the Platforms and accepts it electronically by registering.
28.2. Customers who do not accept the terms of this Safebit Framework Agreement may not use the Platforms or the Services provided through the Platforms. Responsibility for any damages incurred or to be incurred within this scope lies with the Customer, and Safebit’s liability is limited solely to cases determined by a final and binding arbitral award rendered by the competent arbitral tribunal.
This text was last updated on 14.10.2025.
1. PARTIES
This undertaking has been executed between Safebit Crypto Asset Trading Platform Inc. (“Safebit”) and the customer who receives services electronically via the Safebit platform.
2. PURPOSE
The purpose of this undertaking is to clearly and bindingly define the customer’s responsibilities regarding information security, account security, and the use of electronic services within the scope of electronic services provided by Safebit, and to ensure that customers are duly informed pursuant to Article 20 of the Capital Markets Board (CMB) Communiqué No. VII-128.10.
3. CUSTOMER’S INFORMATION SECURITY OBLIGATIONS
The Customer accepts, declares, and undertakes the following:
3.1. Account Security
· That the Customer is solely responsible for the confidentiality of the username, password, PIN, one-time password (OTP), verification codes, and similar information,
· That the Customer knows such information must not be shared with third parties (including family members, friends, and Safebit employees) under any circumstances and undertakes to comply with this rule,
· That Safebit shall not be held liable for information security breaches arising from the Customer’s own fault, negligence, or carelessness,
· That the Customer shall immediately notify Safebit if account credentials are obtained by unauthorized persons,
· That the Customer shall take all necessary measures to ensure the security of account credentials.
3.2. Use of Strong Passwords
· That the Customer shall create a strong password consisting of at least 8 characters, including uppercase and lowercase letters, numbers, and special characters,
· That the Customer shall not use easily guessable passwords (such as date of birth, name, 123456, etc.),
· That the Customer shall not use the same password across different platforms,
· That the Customer shall change the password at regular intervals.
3.3. Multi-Factor Authentication (2FA)
· That the Customer shall activate and keep activated multi-factor authentication (2FA) to enhance account security,
· That the Customer shall not share 2FA codes with third parties under any circumstances,
· That the Customer shall keep the 2FA device (phone, authenticator application) secure.
3.4. Secure Device and Software Usage
· That the Customer shall conduct transactions only from devices with up-to-date operating systems and antivirus software,
· That the Customer shall take necessary measures to ensure the security of their devices,
· That the Customer shall use security software to protect against malware, viruses, and similar threats,
· That the Customer shall not download suspicious applications and shall obtain software only from trusted sources.
3.5. Use of Official Communication Channels
· That the Customer shall conduct transactions only through Safebit’s official website, mobile application, and approved email addresses,
· That the Customer shall not rely on suspicious messages received via social media, WhatsApp, Telegram, or similar channels,
· That the Customer shall not respond to requests originating outside Safebit that ask for account credentials, passwords, or verification codes,
· That the Customer shall carefully check URL addresses and shall not access fraudulent websites.
3.6. Awareness Against Phishing and Fraud
· That the Customer shall not rely on emails or SMS messages that appear to be sent on behalf of Safebit but contain suspicious content,
· That the Customer shall not click on links contained in suspicious emails or SMS messages,
· That the Customer knows Safebit will never request passwords, 2FA codes, or confidential information via phone calls, emails, or SMS,
· That the Customer shall not comply with requests made by persons claiming to be Safebit employees without verification.
3.7. Secure Network Usage
· That the Customer shall not conduct transactions over insecure networks such as public Wi-Fi networks,
· That particularly sensitive transactions (withdrawals, transfers, etc.) shall be conducted only over secure and private networks,
· That where VPN usage is required, the Customer shall prefer reliable VPN services.
3.8. Monitoring and Notification of Account Activities
· That the Customer shall regularly monitor account activities,
· That the Customer shall immediately notify Safebit of transactions not belonging to them,
· That the Customer shall immediately take action upon detecting suspicious activities (unauthorized login attempts, unknown IP addresses, etc.),
· That the Customer shall regularly review account statements and notifications.
3.9. Session Security
· That the Customer shall securely log out after completing transactions,
· That the Customer shall not use the browser’s “remember me” feature on shared devices,
· That the Customer is aware that sessions will automatically terminate after a period of inactivity,
· That the Customer shall completely delete all information when accessing the account from another person’s device.
4. NOTIFICATION OBLIGATIONS
The Customer undertakes to immediately notify Safebit in the following cases:
· Suspicion of theft or compromise of account credentials,
· Detection of unauthorized access or transactions,
· Receipt of suspicious emails, SMS messages, or phone calls,
· Loss or theft of the device,
· Loss of access to the 2FA device,
· Changes in contact information (email, phone number).
The Customer accepts that they shall be responsible for any damages arising from failure to make such notifications.
5. LIMITATION OF LIABILITY
The Customer accepts the following:
· That Safebit shall not be held liable for damages arising from the Customer’s own fault, negligence, or actions contrary to this undertaking,
· That the Customer shall be responsible for losses arising from sharing account credentials with third parties,
· That the Customer shall be responsible for losses arising from failure to comply with security obligations,
· That the Customer shall be responsible for damages arising from failure to fulfill notification obligations,
· That the Customer shall be responsible for issues arising from the use of insecure networks or devices.
6. LEGAL BASIS
This undertaking has been prepared pursuant to the following legislation:
· Capital Markets Law No. 6362,
· CMB Communiqué No. VII-128.10 on the Procedures and Principles Regarding Information Systems Management,
· CMB Communiqués No. III-35/B.1 and III-35/B.2 on Crypto Asset Service Providers,
· Law No. 6698 on the Protection of Personal Data.
7. EFFECTIVENESS AND APPROVAL
This undertaking:
· Enters into force on the date it is approved electronically by the Customer,
· Is recorded within Safebit systems,
· Remains valid as long as the Customer’s account is active,
· May be updated in case of legislative amendments (the Customer shall be informed).
· I have read, understood, and undertake all the information stated above.
This undertaking has been prepared in accordance with CMB regulations and shall enter into force upon your electronic approval.
