User Agreement

1. Parties and Scope of the Agreement

Parties: This User Agreement ("Agreement") is entered into between WhiteBIT Kripto Varlık Alım Satım Platformu Anonim Şirketi (hereinafter referred to as "WhiteBIT TR" or "Platform") on the one hand, and the User (hereinafter referred to as "User") who is a member of the Platform and uses its services on the other hand. WhiteBIT TR is a company established under the laws of the Republic of Turkey, with its headquarters located at Fulya Mah. Büyükdere Cad. Torun Center A Blok No: 74A, İç Kapı No: 31, Şişli/İstanbul, and registered in the relevant commercial registry under number 811145163.

Scope: This Agreement governs the rights and obligations of the parties regarding the use of crypto asset purchase, sale, transfer, and custody services offered by WhiteBIT TR to Users residing within the borders of the Republic of Turkey. By using any of the services offered by the Platform or by creating an account, the User declares that they have read, understood, and accepted all the terms of this Agreement.

The Agreement is governed by 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 Operating Procedures and Principles of Crypto Asset Service Providers and Capital Adequacy (III-35/B.2) and the Communiqué on Procedures and Principles Regarding Information Systems Management (VII-128.10), as well as Law No. 5549 on the Prevention of Money Laundering, Law No. 6415 on the Prevention of Terrorism Financing, Law No. 7262 on the Prevention of the Financing of the Proliferation of Weapons of Mass Destruction, Law No. 5651 on the Regulation of Publications Made in the Internet Environment and Combating Crimes Committed Through These Publications, Law No. 7545 on Cyber Security, Law No. 6698 on the Protection of Personal Data, and all related secondary legislation. WhiteBIT TR and the User acknowledge that the provisions of the Agreement are legally binding on them and that they have met the necessary technical/legal requirements for compliance with the legislation.

Warning: Please read this Agreement carefully in its entirety before using the Platform. If you do not accept the terms of the Agreement, you should not use the Platform services. The Platform's website: www.whitebit-tr.com This Agreement text is a framework agreement containing the general terms and conditions for the use of WhiteBIT TR services. Together with this Agreement, WhiteBIT TR's published Personal Data Protection Policy Disclosure Text, Consent Form, Cookie Policy, Risk Disclosure Form, and all other relevant policies and rules constitute an annex and an integral part of the Agreement.

2. DEFINITIONS

Some of the terms used in this Agreement have the following meanings:

• AML (Anti Money Laundering): Refers to legal regulations related to the prevention of money laundering and the identity verification, transaction monitoring, and reporting processes implemented by the Platform in this context.
• CFT (Counter Financing Terrorism): Refers to legal regulations on the prevention of terrorist financing and the identity verification, transaction monitoring, and reporting processes carried out by the Platform in this context.
• Delist: Refers to the removal of a specific crypto asset from trading on the Platform, i.e., the situation where the relevant digital asset is delisted by WhiteBIT TR. Buy and sell orders for a delisted asset will not be accepted, existing orders will be canceled, new transactions cannot be opened, and the holding of the relevant asset in User accounts on the Platform will be terminated (Users will be able to withdraw their assets within a certain period).
• Order: Refers to instructions given by the User via the Platform for buying or selling and/or depositing, withdrawing, transferring, and other transactions.
• Fiat Currency: Refers to traditional currencies issued by governments or authorized authorities and accepted as legal tender (Turkish Lira, Dollar, Euro, etc.).
• Funds: Refers to all assets in the User's Account – all balances in Crypto Assets and Fiat Currency are referred to as Funds.
• Account: Refers to the personal account created by the User upon registration on the Platform and used to access Platform services. Each Account is created for use solely by the relevant User and is protected by login details (username, password, etc.).
• Business Day: Means days when banks are open in Turkey, excluding weekends, public holidays, and religious holidays.
• Transaction: Refers to the actual purchase or sale made as a result of the User's orders on the Platform or the transfer of crypto assets/fiat. The result of the order being matched and executed is reflected in the User's accounts as a Transaction.
• Commissions and Fees: Refers to all kinds of fees, commissions, expenses, and similar charges collected from the User in exchange for the services offered by the Platform. WhiteBIT TR publishes its current fee schedule on its website, and the User agrees to pay commissions at the rates determined for the transactions performed.
• Crypto Asset (Digital Asset): Refers to intangible assets created electronically using distributed ledger technology or similar technology and distributed over digital networks, which do not constitute fiat currency, book money, electronic money, payment instruments, securities, or other capital market instruments, but may represent a value or right (e.g., cryptocurrencies and tokens such as Bitcoin and Ethereum).
• User: Refers to a real person or legal entity who is a member of the WhiteBIT TR Platform, uses the services by creating an account, and accepts this Agreement by approving it electronically.
• KPS (Identity Sharing System): Refers to the system provided by the General Directorate of Population and Citizenship Affairs that enables the verification of identity information electronically.
• KYC (Know Your Customer): Refers to the identity verification, information, and document control processes carried out by the Platform for the purpose of verifying the user's identity.
• Liquidity: Refers to the ability to buy and sell a crypto asset at a price close to the current market price, within a reasonable time frame, and without causing a significant price change in the crypto asset market.
• MASAK: Stands for the Financial Crimes Investigation Board.
• Legislation: Capital Markets Law No. 6362, Communiqué on the Establishment and Operating Principles of Crypto Asset Service Providers (III35/B.1), Communication on the Working Procedures and Principles of Crypto Asset Service Providers and Capital Adequacy (III-35/B.2), and Communication on Procedures and Principles Regarding Information Systems Management (VII-128.10), the Law No. 5549 on the Prevention of Money Laundering, the Law No. 6415 on the Prevention of the Financing of Terrorism, the Law No. 7262 on the Prevention of the Financing of the Proliferation of Weapons of Mass Destruction, Law No. 5651 on the Regulation of Publications Made in the Internet Environment and Combating Crimes Committed Through These Publications, Law No. 7545 on Cyber Security, Law No. 6698 on the Protection of Personal Data, and, without limitation, other relevant laws, decrees, communications, regulations, policy decisions, all provisions of legislation currently in force or to be enacted in the future, and all legal regulations of official regulatory and supervisory authorities; the general provisions of the laws of the Republic of Turkey and, in the event of any change or replacement, the changed and/or replaced Legislation.
• MKK: Stands for Central Registry Agency.
• Platform (WhiteBIT TR): Refers to the online platform operated by WhiteBIT Kripto Varlık Alım Satım Platformu Anonim Şirketi., where Users can buy, sell, exchange, and transfer Crypto Assets and where custody services related to these transactions are provided.
• CMB or Board: Refers to the Capital Markets Board.
• Agreement: Refers to the WhiteBIT TR User Framework Agreement and other agreements, texts, appendices, and disclosures specified as being related to and forming an integral part thereof.

Except as defined above, other terms not specifically defined throughout the text of the Agreement shall have their general meanings according to the context and shall be interpreted in accordance with the Capital Markets Law and related legislation.

3. ACCOUNT OPENING AND IDENTITY VERIFICATION (KYC)

3.1. Membership Application: Any person wishing to use the Platform services must create a user account on WhiteBIT TR. During the account creation process, the User must provide the Platform with their current, accurate, and complete personal information (name, surname, Turkish ID number or passport number, date of birth, residential address, contact information, etc.). Only natural persons who are at least 18 years of age and fully competent, as well as legal persons through their legal representatives, may become members of the Platform.

3.2. Identity Verification (KYC): WhiteBIT TR requests various information and documents during registration and, when necessary, at a later date to verify the User's identity in accordance with its "Know Your Customer" (KYC) obligations.

The User is required to provide official identity documents such as an ID card/passport, a photograph, proof of address such as a utility bill, customer identification forms, and any other documents that may be requested by WhiteBIT TR.

Remote identity verification is performed using methods compliant with applicable legislation (e.g., verification video call, NFC identity reading, biometric verification, etc.).

WhiteBIT TR may use authorized identity verification infrastructures (e.g., Sumsub) that are certified under the TS EN ISO/IEC 27001 Information Security Management System and comply with the provisions of the MASAK General Communiqué (No. 19) during this process.

WhiteBIT TR may also conduct remote identity verification processes through customer representative companies that are affiliated with WhiteBIT TR, act on behalf of WhiteBIT TR, and have experience in this field, under confidentiality agreements.

These companies are authorized by WhiteBIT TR, have received the necessary training, and operate in compliance with MASAK regulations. Customer representatives act in accordance with WhiteBIT TR's instructions and process all information obtained solely on behalf of WhiteBIT TR and in accordance with the law.

The user completes the customer acceptance process knowing and accepting that their transactions in the remote identity verification process may be carried out by WhiteBIT TR or authorized customer representatives. In this context, the user accepts that the information, documents, images, and voice recordings obtained during identity verification will be processed in accordance with the legislation and stored by WhiteBIT TR for the legal period.

WhiteBIT TR uses verification services provided through the Identity Sharing System (KPS) of the General Directorate of Population and Citizenship Affairs (NVİ) in identity verification processes.

Verifications made through KPS are carried out to fulfill the obligations stipulated in MASAK and CMB legislation. The User accepts that identity queries performed through the KPS system are verified by comparison with official records and that this verification is performed solely for the purpose of fulfilling WhiteBIT TR's legal obligations. Verification fees or transaction fees determined by the relevant public institutions or service providers in relation to KPS services may be collected by WhiteBIT TR from the User's account and transferred to the relevant institution or service provider. The User acknowledges that they authorize WhiteBIT TR to deduct and transfer transaction fees in this context.

3.3. Accuracy and Updating of Information: The User declares that all information and documents provided to the Platform are accurate, up-to-date, and belong to them. Providing misleading, false, or third-party information or submitting false/incorrect documents is strictly prohibited. The User is obligated to keep their membership information (contact address, email, phone number, changes in identity documents, etc.) up to date and to immediately notify the Platform of any changes. Otherwise, all liability arising therefrom shall be borne by the User.

3.4. Single Account Rule: As a rule, each natural person or legal entity may open only one membership account on the Platform. WhiteBIT TR reserves the right, at its sole discretion, to suspend, merge, or close any accounts if it determines that a User has opened multiple accounts or allowed another person to use their account. The User may not transfer their account to a third party, allow others to use it, or perform transactions on behalf of others through their account.

3.5. Unauthorized/Restricted Persons: When applying for membership and using the services, the User declares that they are not on any economic sanctions lists or blacklists, are not a person/entity subject to international sanctions, and will not use the Platform for any criminal activity. WhiteBIT TR may restrict access to the services for citizens of certain countries or specific persons in accordance with national and international legislation. If the User is a citizen or resident of a country other than the Republic of Turkey, it is their responsibility to comply with the relevant regulations of that country, and WhiteBIT TR assumes no responsibility in this regard.

3.6. Acceptance of Application: WhiteBIT TR reserves the right to accept or reject a membership application at its sole discretion. Until the accuracy of the information provided by the User is verified and the terms of this User Framework Agreement are explicitly accepted, WhiteBIT TR reserves the right not to activate the relevant account, to restrict access to services, or to grant limited usage rights. WhiteBIT TR may request additional information and/or documents if deemed necessary and/or may exercise its right to reject the membership application based on the User's risk profile. Furthermore, WhiteBIT TR has the authority to strengthen identity verification and customer identification processes, set transaction limits, take restrictive measures on the account, reject the membership application, or suspend the existing membership, depending on the User's risk level.

3.7. Corporate Accounts: If the user account is to be opened on behalf of a legal entity such as a company, foundation, or association, the documents requested by WhiteBIT TR must be submitted in full. These documents may include official documents pertaining to the legal entity, authorization documents, trade registry records, signature circulars, and the identity information of the authorized representative. The identity of the person who will perform transactions on behalf of the account must be verified, and their authority to represent the entity must be documented.

WhiteBIT TR may apply additional identity verification steps for corporate users and reserves the right to refuse account opening requests.

By accepting this agreement, legal entity users agree to accurately and completely declare the authorized persons who will perform transactions on the platform and the ultimate persons benefiting from these accounts (ultimate beneficiaries) and to update this information when necessary. The information of these persons must be kept up to date and resubmitted if requested.

Furthermore, representatives of legal entities are also considered parties to this agreement, and all terms herein bind both the representative and the legal entity. WhiteBIT TR may request additional agreements and declarations for corporate users. Therefore, corporate users must carefully review the Legal Entity Acceptance Processes procedure prepared by WhiteBIT TR.

3.8. Central Registry Authority Registration Number: Each User signing the Agreement is assigned a unique User number. This number is specific to the relevant User and cannot be assigned to another person. For each User with whom an agreement is made, a sub-account is opened or ensured to be opened with the MKK before an order is accepted or transmitted on behalf of the User; the registration number obtained for this account is matched with the User number. If a previously obtained registration number exists for the User, this number is matched with the User number. User numbers are also used in the same way for the custody sub-account at the CSD. Orders are not accepted from accounts that do not have a registration number at the CSD or that are not matched with a registration number. Within the scope of the relevant legislation, users will be able to access information about their assets through the CSD E-Investor service.

WhiteBIT TR is obligated, in accordance with the regulations of the Capital Markets Board ("CMB"), to open a sub-account for each User with the Central Registry Agency ("MKK") and to execute transactions through these accounts.

The User accepts that fees, commissions, contribution shares, collateral, and system usage fees that may arise in exchange for account opening, sub-account matching, data updating, custody, or similar services at MKK may be collected by WhiteBIT TR from the User's account in accordance with the rates determined by MKK or CMB.

The collection of these fees is independent of WhiteBIT TR's own service commissions and is collected for direct payment to the CSD or the relevant institution. The User irrevocably authorizes WhiteBIT TR to collect these fees from their account, offset them, and transfer them to the CSD.

4. PLATFORM SERVICES AND TRANSACTION TYPES

4.1. Scope of Services: WhiteBIT TR provides Users with various services related to crypto assets through the Platform. These services primarily enable Users to buy and sell crypto assets, store their crypto assets on the Platform, and deposit and withdraw (transfer) crypto assets and fiat currency. WhiteBIT TR may offer the following types of transactions to the extent permitted by law:

• Cryptocurrency Trading: Users can buy or sell cryptocurrencies listed on the Platform according to market conditions. Trading transactions are executed through the matching of orders submitted by users in the trading environment provided by the Platform. The Platform shall exercise due diligence to execute customer orders in the best possible manner and promptly, in accordance with its own Order Execution Policy and the provisions of this Agreement. Orders may be executed through a counterparty matching model or by the Platform acting as the counterparty liquidity provider.
• Crypto Asset Transfer (Deposit/Withdrawal): Users may deposit their crypto assets from external wallets into their Platform account or withdraw crypto assets from their Platform account to an external wallet. Similarly, the User may deposit fiat currency from their bank account to the Platform and withdraw fiat currency from their Platform account to their bank account. These transfer services are conducted in accordance with anti-money laundering rules and within the procedures specified by WhiteBIT TR (e.g., withdrawals only to bank accounts registered in the User's name, wallet address notification procedures, etc.).
• Custody Service: WhiteBIT TR provides custody services for the crypto assets held by Users on the Platform. The digital assets in the User's account are held in secure wallets under WhiteBIT TR's supervision. WhiteBIT TR uses cold wallets (offline custody) and hot wallets (online wallets for transactions) infrastructure as deemed appropriate for the secure custody of crypto assets. (Example: The Platform enhances security by storing the majority of customer crypto assets in offline cold wallets.)
• Initial Exchange Offering (IEO) and Distribution: Where permitted by law, WhiteBIT TR may act as an intermediary for the initial sale or offering of certain crypto assets. When such a service is offered, the relevant terms and conditions will be announced separately by the Platform, and Users' separate consent will be obtained. WhiteBIT TR may organize the initial distribution or private sales of a crypto asset, but these transactions are also conducted in compliance with CMB regulations.
• Other Services: WhiteBIT TR may occasionally offer services to Users such as lending/borrowing intermediation and earning returns by locking crypto assets (staking). If such services are offered, the terms of operation and potential risks will be communicated to the User in advance, and the relevant transactions will be conducted under separate terms agreed upon on the Platform. The User shall confirm that they understand the risks before using such a product.

4.2. Non-Service Matters: Platform services are limited to the purchase, sale, and custody of crypto assets. WhiteBIT TR is not a bank or payment service provider; it does not engage in activities such as lending to Users, paying interest, or providing payment instruments. Fiat currency movements on the Platform are solely for the purpose of supporting crypto asset transactions and are carried out through the banking system. Transactions made by the User through the Platform do not constitute investment advice; WhiteBIT TR does not provide personalized financial, legal, or tax advisory services to the User.

4.3. Service Changes: WhiteBIT TR reserves the right to develop, modify, or terminate the types of services it offers within the provisions of this Agreement and the legal framework. For example, a new transaction type may be added, or a service may be removed or restricted. In such a case, WhiteBIT TR will notify Users in advance using appropriate means. By continuing to use the Platform services, the User is deemed to have accepted the changes.

4.4. Interest on Customer Assets:

4.4.1. General Principles: The User decides on their preference regarding the interest accrual of their cash balance in Turkish Lira or other currencies held in their Platform account and not subject to any transaction, either at the time of approval of this Agreement or through the options clearly presented on the Platform interface. If the User requests interest accrual, they are obligated to comply with the procedures, time frames, and limits determined by the Platform. If the User does not request interest accrual, the cash balance in their account will not earn any interest, and no claim for damages or loss of profit may be made against the Company for this reason. If the User does not request interest accrual and their balance is below the minimum interest accrual limit set by the Company, by signing this Agreement, the User accepts, declares, and undertakes that the Company will accrue interest on this amount on the platform. If the User does not request interest and has a balance higher than the minimum interest threshold determined by the Company, the Company may, separately from this framework agreement and in accordance with written or electronic consent obtained individually from customers, evaluate the interest so that it remains on the platform.

4.4.2. Interest Request and Process: If the User requests interest, WhiteBIT TR may evaluate the User's cash, along with the cash assets of other Users who have requested interest or separately, to deduct a commission at the rate determined by WhiteBIT TR in exchange for this transaction, to record and transfer the remaining amount to the User's account as a credit after deducting the commission and legal obligations, and to act on behalf of the User within the scope of these transactions. User requests for interest accrual shall be submitted electronically via the Platform between 09:00 and 16:00. Interest accrual requests submitted outside this time frame will not be processed. For the User's interest request to be valid, the amount subject to the request must remain inactive in the account from 4:00 PM on the relevant day until 9:00 AM the following day. If any movement occurs in the Customer's account regarding the amount in question during this period, no interest income can be earned.

4.4.3. Interest Calculation Principles: WhiteBIT TR reserves the right to set a minimum limit for balances eligible for interest accrual. The specified minimum limit is announced on the Platform and communicated to the User via electronic means. Amounts below the minimum limit may be evaluated by WhiteBIT TR in its favor; WhiteBIT TR is authorized to hold such balances in the account for interest accrual in its favor. The Customer acknowledges that they cannot make any claims or demands in this regard. WhiteBIT TR may evaluate amounts above the minimum threshold, in accordance with the User's explicit request for interest accrual, through investment instruments or contracted banks it deems appropriate. Yield rates may vary depending on market conditions, the investment vehicle, or the bank used. WhiteBIT TR has the discretion to determine the instruments to be used or the institutions to be worked with.

4.4.4. Returns, Commissions, and Taxation: After deducting the commission and legal deductions determined by WhiteBIT TR from the returns obtained as a result of the investment, the remaining amount is proportionally reflected in the User's accounts. WhiteBIT TR is authorized to collect, exchange, and deduct any taxes, funds, and expenses that may arise from interest accrual transactions from the User's account. WhiteBIT TR informs the User that returns are not guaranteed in advance and that interest rates may vary depending on market conditions. The User accepts that returns are not guaranteed at a specific amount or rate.

4.4.5. Disclosure, Risks, and Liability: Interest accrual transactions are carried out by WhiteBIT TR for the benefit of the User. However, WhiteBIT TR cannot be held liable for any losses that may arise due to the return on the investment instrument, market conditions, or the practices of third-party institutions. The User accepts that all information, rate, and commission changes related to the interest accrual process will be communicated to them via the Platform or electronic communication tools, and that these notifications will be valid at the time they are made. The User has the right to change or cancel their interest preference at any time. In this case, the interest-bearing cash balance will be transferred to the User's account upon request within one (1) business day at the latest.

4.4.6. Blocked Balances: If the cash in the User's account is blocked for any reason or subject to legal restrictions, WhiteBIT TR reserves the right not to perform the interest accrual process in whole or in part. In this case, the User cannot claim interest income.

5. CUSTODY OF CASH AND CRYPTO ASSETS

5.1. Tracking in Separate Accounts: Fiat currency (e.g., USD) and crypto asset balances deposited by the User into WhiteBIT TR are recorded separately from WhiteBIT TR's own company assets and on a customer-by-customer basis. The Platform is obligated to track each User's cash and crypto asset balances in a complete, accurate, and up-to-date manner in its own systems and relevant custody records. This ensures that User assets are kept separate from WhiteBIT TR's assets and belong to the User. WhiteBIT TR takes all necessary measures to ensure this segregation as required by law and to track customer assets in segregated accounts.

5.2. Fiat Currency Custody: Users' TL or other fiat balances in their Platform accounts are held in bank accounts designated by WhiteBIT TR and operating in Turkey. WhiteBIT TR holds cash assets stored on behalf of customers in reliable bank accounts, preferably in segregated accounts. The User's fiat balance on the Platform can be withdrawn to the User's own bank account upon request (in accordance with Article 6.4). Under no circumstances does the Platform use User fiat assets for its own operational expenses or other purposes; these assets exclusively represent the rights and claims of the relevant User.

5.3. Crypto Asset Custody: WhiteBIT TR uses advanced infrastructure to securely store Users' crypto assets on the Platform. The majority of User balances are held in cold wallets (offline hardware security modules or physical custody) and only the amount of assets necessary for daily transaction liquidity is kept in hot wallets. WhiteBIT TR stores assets in compliance with the CMB's regulations on custody; when necessary, it may also work with a custody institution authorized by the CMB. (If required by law, WhiteBIT TR undertakes to hold customer assets partially or entirely with a third-party custody institution licensed by the CMB.)

5.4. Custody and Collateral: Cryptocurrencies and fiat currencies deposited on the Platform belong to the User, and WhiteBIT TR has the right to dispose of them only for the purpose of performing transactions in accordance with the Agreement. Unless expressly instructed by the User or required by the Agreement, WhiteBIT TR shall not establish any liens, collateral, or attachments on User assets. However, if a precautionary measure, garnishment order, or similar legal request is received from legal authorities, WhiteBIT TR may block the relevant User assets or perform transactions in accordance with the instructions (see Article 7 – AML/Legal Obligations).

5.5. Guarantee and Insurance: Crypto assets are not covered by Deposit Insurance or the Savings Deposit Insurance Fund (SDIF) guarantee as required by law. Although WhiteBIT TR strives to minimize risks through security measures, it does not provide any insurance coverage for losses that may occur as a result of cyber attacks, technical failures, or force majeure during the custody of crypto assets, except for the obligations stipulated by law. However, WhiteBIT TR may endeavor to secure its crypto asset custody service with specific insurance policies within the framework of international industry standards; in this case, the relevant insurance coverage and conditions will be announced separately.

5.6. Asset Status and Notification: The User may view their asset balances (fiat and crypto) on their account on the Platform at any time and review the details of all transactions made. WhiteBIT TR agrees to provide the User with reports or statements regarding the asset status within a reasonable time upon the User's request. Furthermore, in accordance with applicable legislation, the Platform shall securely store records containing the accounting and reconciliation of each User's assets for at least 10 years (see also Article 14 – Record Keeping and Proof).

6. TRANSMISSION OF ORDERS AND ACCOUNT TRANSACTIONS

6.1. Placing Orders: When placing orders for purchases, sales, or other transactions via the Platform, the User must use the relevant instructions on the Platform interface. To place an order, the User must have a valid account on the Platform and sufficient balance for the relevant transaction. When entering an Order, the User accepts responsibility for the content of that order (transaction type, amount, price, conditions, if any, etc.). The risk of loss arising from incorrect order entry is borne by the User. WhiteBIT TR assumes that it has received and queued an order after it is submitted to the Platform; successfully submitted orders are displayed as "open orders" on the Platform.

6.2. Order Execution: WhiteBIT TR executes customer orders by matching them with existing counter-orders through its matching engine. Orders are processed according to the principles of time priority and price priority: For example, the highest-priced buy order and the lowest-priced sell order are the most likely orders to match; among orders at the same price, the order entered earlier will match first. The order placed by the User may be partially or fully executed. Partial execution: If the User's buy/sell order finds a match for part of the specified quantity, that part is executed as a trade, and the remaining portion remains as an open order. The remaining portion may later be matched with other orders or canceled by the User.

6.3. Order Cancellation and Modification: The User may cancel or modify orders submitted to the Platform that have not yet been executed (completed) at any time. However, partially or fully executed orders cannot be canceled; the executed portion is binding. The User cannot unilaterally reverse or modify a transaction resulting from the full execution of an order. WhiteBIT TR reserves the right to cancel or correct such transactions if obvious price errors or duplicate transactions occur due to a technical error or system failure on the Platform at the time of the transaction; in such a case, the User will be notified.

6.4. Deposit (Fiat): When the User wishes to deposit fiat currency into their account on the Platform, they must use the methods specified by WhiteBIT TR. Generally, fiat currency deposits will be possible via wire transfer/EFT from a bank account registered in the User's name to the bank account specified by WhiteBIT TR. When depositing funds, the User must comply with WhiteBIT TR's instructions (e.g., use of a reference code, correct recipient account details). As a rule, transfers to the Platform from third-party accounts (bank accounts not registered in the User's name) are not accepted; WhiteBIT TR reserves the right to return such incoming payments. Deposited amounts are credited to the User's account after they reach and are verified in WhiteBIT TR's bank account. Under normal circumstances, fiat currency deposits made during business hours are transferred to the User's account on the same business day.

6.5. Withdrawal (Fiat): When the User wishes to withdraw fiat currency from their Platform account to their own bank account, they submit a withdrawal request via the Platform. WhiteBIT TR is obligated to forward withdrawal requests submitted by the customer to the relevant bank no later than the business day the request is made. Bank transfer/EFT times may vary depending on the banking system; WhiteBIT TR's responsibility is limited to forwarding the request to the bank in a timely manner. The User acknowledges that they can only make withdrawal requests to bank accounts registered in their own name. Withdrawal requests to accounts belonging to different third parties will be rejected. WhiteBIT TR may request additional verification or written confirmation from the User if deemed necessary (e.g., for high-value withdrawals). Once a confirmed fiat currency withdrawal request has been processed, it cannot be reversed, and the transaction is considered complete when the funds reach the User's bank account.

6.6. Crypto Asset Deposit: The User may transfer (deposit) crypto assets from their personal crypto wallets in the external world to their account on the WhiteBIT TR Platform. For this purpose, the Platform provides the User with a unique wallet address for the relevant crypto asset. The User confirms that they have used this correct address and initiated the transfer when depositing their assets. The completion of a crypto asset deposit transaction depends on the transaction receiving a sufficient number of confirmations on the relevant blockchain network. Once the transaction confirmations are complete, WhiteBIT TR credits the deposited amount to the User's account. Incorrect address usage: The User is responsible for copying the wallet address correctly when depositing crypto assets. If the User sends funds to an incorrect address or an unsupported network, the assets may be lost; WhiteBIT TR shall not be liable in such cases. However, if technically feasible and reasonable, WhiteBIT TR may make a good faith effort to recover the lost assets and may charge the User for any expenses incurred.

6.7. Crypto Asset Withdrawal: When the User wishes to withdraw crypto assets from their Platform account to an external crypto wallet, they submit a withdrawal request to the relevant wallet address via the Platform. The User must verify that they have entered the correct withdrawal address and that the asset they wish to withdraw is supported by the destination wallet. For security reasons, WhiteBIT TR may require the User to perform actions such as 2FA (two-factor authentication) approval or email confirmation for crypto withdrawal requests. After the Platform receives the user's withdrawal request, eligibility checks are performed: conditions such as the user having sufficient balance, no blockages in the account, and the request passing the AML/security assessment are checked. WhiteBIT TR may delay or temporarily suspend crypto withdrawal processing in cases it deems appropriate (e.g., unusually large amounts, suspicious transactions, technical maintenance periods, etc.). When an approved crypto withdrawal request is processed, the relevant asset is deducted from the User's account and a transfer instruction is sent to the blockchain network; at this point, the transfer cannot be reversed. The User acknowledges that WhiteBIT TR is not responsible for the performance of the network that executes blockchain transfers (network congestion, technical issues, etc. are beyond WhiteBIT TR's control). The risk of loss resulting from sending to an incorrect wallet address or incorrect blockchain network is entirely the User's responsibility.

6.8. Transaction Records: All transactions in the User's account (including fiat currency deposits/withdrawals, crypto asset deposits/withdrawals, buy/sell orders, and transactions) will be visible on the relevant activity screen and account statement of the User's account. WhiteBIT TR records every transaction made by the User, including the date/time, type, amount, relevant asset, and counterparty information. If the User requests a more detailed statement of their account history, WhiteBIT TR will reasonably comply with this request.

6.9. Erroneous or Unauthorized Transactions: If the User notices a transaction on their account that they believe occurred without their knowledge, they must immediately notify WhiteBIT TR (see Security clause). Upon the User's notification, WhiteBIT TR will investigate the transaction in question and take temporary measures if deemed necessary. The User shall be liable for any damages arising from unauthorized transactions due to the User's negligence or failure to adequately secure their account. WhiteBIT TR shall be liable within the framework of the legislation for transactions resulting from an error in its own systems or unauthorized access.

7. CUSTOMER IDENTIFICATION AND ANTI-MONEY LAUNDERING OBLIGATIONS (KYC/AML/CFT)

7.1. WhiteBIT TR is subject to Law No. 5549 on the Prevention of Money Laundering, Law No. 6415 on the Prevention of Terrorism Financing, Capital Markets Law No. 6362, and all relevant regulations, circulars, and Financial Crimes Investigation Board (MASAK) regulations issued based on these laws.

The platform commits to full and complete compliance with all applicable legal regulations to prevent money laundering, terrorist financing, market disruptive actions, and other illegal activities. In this context, WhiteBIT TR exercises high attention and care in all transactions from the moment user accounts are opened, implements best compliance practices in the processes of monitoring, recording, and reporting suspicious transactions to the competent authorities.

7.2. Internal Controls and Compliance Program: WhiteBIT TR has established the Internal Control System and Compliance Program required under AML/CFT legislation. In this context, a Compliance Officer has been appointed within the Platform, and regular AML/CFT training is provided to all employees. Transactions are continuously monitored, and risky transactions are identified using automated/manual filtering systems. WhiteBIT TR's AML/CFT policies and procedures cover matters such as customer identification (KYC), ongoing customer status monitoring, reporting suspicious transactions to MASAK, information and document retention, and the appointment of a compliance officer.

WhiteBIT TR fulfills its obligations automatically and securely by connecting to the digital integration systems of MASAK, CMB, and relevant public institutions (e.g., KPS, MKK, KEP, MASAK E-Tebligat). In this context, the identity, transaction, and account information obtained can only be shared with the relevant authorities as required by law.

7.3. Suspicious Transaction Reporting: WhiteBIT TR monitors User transactions in accordance with the criteria specified in MASAK regulations. The User declares that the transactions they perform using the Platform comply with all applicable laws; however, if WhiteBIT TR deems any transaction to be a "suspicious transaction," it is obligated to report it to MASAK. This reporting is a legal requirement and does not constitute a breach of WhiteBIT TR's duty of confidentiality towards the User. Suspicious transaction reports are confidential; WhiteBIT TR cannot inform the User that such a report has been made, as required by law.

7.4. Transaction Limits and Additional Controls: WhiteBIT TR may apply certain transaction limits and restrictions as part of anti-money laundering measures. For example, daily/monthly deposit/withdrawal limits, transaction volume limits, or transfer restrictions with certain countries may be imposed. For high-value transactions, WhiteBIT TR may request additional information/documents from the User regarding the source or purpose of the transaction (e.g., documents proving the source of funds, invoices related to the transaction, etc.) before executing the transaction. The User is obligated to comply with such additional verification requests deemed reasonable by WhiteBIT TR. Where deemed necessary, WhiteBIT TR reserves the right to hold or reject the relevant transaction until the request is resolved.

7.5. Application of Enhanced Measures (MASAK Serial No. 29): WhiteBIT TR applies the enhanced measures specified in the General Circular (No. 29) published by the Financial Crimes Investigation Board ("MASAK") in accordance with Law No. 5549 on the Prevention of Money Laundering and related secondary regulations, within the framework of a risk-based approach.

In this context, one or more of the following measures may be applied in high-risk customer or transaction cases:

• a) Requesting additional information and documentation regarding the customer and the beneficial owner,
• b) More frequent updating of customer information,
• c) Requesting the submission of documents regarding the source of the funds and assets involved in the transaction,
• d) Obtaining additional explanations regarding the purpose of the transaction or business relationship,
• e) Making the establishment of certain transactions or business relationships subject to senior management approval,
• f) Increasing the frequency of transaction monitoring and control mechanisms.

WhiteBIT TR reserves the right to request documents and information from the customer, temporarily suspend, freeze, or reject the transaction while implementing the aforementioned measures. The user acknowledges that these obligations arise from national legislation and that the investigations conducted within this scope are within WhiteBIT TR's legal responsibility.

7.6. Account Restriction, Freezing, and Termination (AML): If there is suspicion that the User's activities on the Platform are in violation of applicable legislation, or if the KYC/AML information and documents requested by the User are not provided, are incomplete, or information not requested by WhiteBIT TR is provided, or false information/documents are submitted; WhiteBIT TR reserves the right to restrict certain functions of the User's account, temporarily freeze it, or unilaterally terminate this User Agreement (close the account).

If the account is restricted, the User cannot perform transactions such as withdrawing funds. This restriction will continue until the information and documents requested by WhiteBIT TR are submitted in a complete and verified manner.

If the account is frozen, the User cannot access their account or perform any transactions. During this process, WhiteBIT TR will assess the situation and conduct the necessary investigations. The account will be reactivated once the suspicious activity ceases. Otherwise, the account may be closed in accordance with legal obligations, and the User's assets may be returned or blocked according to the instructions of the competent authorities. The User hereby accepts, declares, and undertakes that WhiteBIT TR shall not be liable for any account restrictions, freezes, terminations, or notifications carried out within the scope of its legal obligations.

7.7. International Sanctions and FATF Requirements: WhiteBIT TR undertakes to act in accordance with international sanctions regimes and the principles and recommendations published by the Financial Action Task Force (FATF). In this context, the platform reserves the right not to provide services to countries, institutions, organizations, and individuals included in the sanctions lists published by the Office of Foreign Assets Control (OFAC) under the U.S. Department of the Treasury, the United Nations, the European Union, and the Republic of Turkey. WhiteBIT TR may take measures such as suspending, rejecting, investigating, or restricting/freezing accounts for transactions and users deemed to carry international sanctions risk. The User declares and undertakes that they and their transactions are not connected to sanctioned persons or organizations. Furthermore, in accordance with the Travel Rule prescribed by the FATF, in crypto asset transfers above a certain amount, it may be mandatory to collect, transmit to the other party, and share with the competent authorities the necessary data such as the identity and wallet information of the recipient and sender. In this context, the User accepts and declares that they will provide the necessary information and consent to the monitoring of transactions in accordance with international regulations.

High-risk countries are those announced by the Ministry as countries that do not have sufficient regulations to prevent money laundering and terrorist financing, do not cooperate sufficiently in combating these crimes, or are considered risky by competent international organizations. Country risk is involved in business relationships and transactions with the citizens, companies, and financial institutions of the countries listed in the definition.

The following regions are considered high-risk in all circumstances.

• European Union (EU), countries subject to sanctions or embargoes by the UN.
• Countries that have not implemented the necessary legal regulations to combat crime proceeds.
• Countries listed on the Non-Cooperative Countries List announced by the Financial Action Task Force (FATF) to its member countries. (Available at http://www.fatf-gafi.org.) (Natural persons who are citizens of or reside in countries on the blacklist, such as North Korea, Myanmar, and Iran, or legal entities established in such countries, cannot be Users on the platform.
• Countries identified by reliable sources as providing resources for terrorism.
• Offshore and free zones, tax havens, or countries known worldwide as tax havens (Anguilla, Andorra, Antigua, Aruba, Bahamas, Bahrain, Barbados, Belize, British Virgin Islands, Cook Islands, Dominica, Gibraltar, Grenada, Guernsey/Sark/Alderney, Isle of Man, Jersey, Liberia, Liechtenstein, Maldives, Marshall Islands, Monaco, Montserrat, Nauru, Netherlands Antilles, Niue, Panama, St. Kitts and Nevis, St. Lucia, St. Vincent, Seychelles, Tonga, Turks and Caicos Islands, U.S. Virgin Islands, Vanuatu, and Western Samoa).

Individuals who are citizens of or reside in the United States, Canada, or the United Kingdom, or legal entities established in those countries, cannot be Users on the platform.

7.8. Legal Cooperation: WhiteBIT TR is responsible for fulfilling its obligation to cooperate with authorized public institutions and organizations within the scope of Law No. 5549 on the Prevention of Money Laundering, Law No. 6362 on the Capital Markets, and other relevant legislation. In this regard, requests for information and documents duly submitted by the Financial Crimes Investigation Board (MASAK), the Capital Markets Board (CMB), courts, prosecutors, law enforcement agencies, and other competent authorities shall be fulfilled within legal limits and as soon as possible. In this context, account information, identity data, transaction records, and similar information belonging to the User may be communicated to the relevant authorities.

By continuing to use the Platform, the User acknowledges that they have given their prior and explicit consent to such data sharing in the context of these legal requests. Furthermore, WhiteBIT TR undertakes to fully comply with all information, document, and reporting requests made within the scope of the CMB's supervisory and oversight authority.

The User acknowledges in advance that WhiteBIT TR exercises its rights to report suspicious transactions, apply transaction restrictions, and freeze accounts as a legal obligation in accordance with the laws of the Republic of Turkey and international regulations, and that these actions are not a discretionary choice of WhiteBIT TR but a mandatory responsibility. In this context, the User agrees, declares, and undertakes to cooperate with WhiteBIT TR in the relevant processes.

8. RISK NOTICE AND USER OBLIGATIONS

8.1. General Risks: The User acknowledges that trading and investing in crypto assets involves high risk. Crypto markets are volatile, and the value of a crypto asset may increase or decrease significantly in a short period. The User understands that they may incur significant financial losses as a result of transactions on the Platform, and even lose their entire investment, and accepts these risks. WhiteBIT TR does not make any return commitments regarding the value of crypto assets and does not control market movements. The User should carefully assess their own financial situation and risk appetite before trading. If necessary, they should seek financial advice to decide whether crypto assets are suitable for them.

8.2. Risk Disclosure Forms: In accordance with applicable legislation (Law No. 6362 and CMB regulations), WhiteBIT TR is obligated to inform Users about the general risks of cryptocurrency transactions. In this context, the Platform may provide Risk Disclosure Texts during the membership process and update them as necessary. The User declares that they have carefully read and understood the General Risk Disclosure and, if applicable, the Special Risk Disclosure Forms that will be sent to them electronically when opening an account and that they accept them. The risks summarized in these documents are an integral part of this Agreement. The User acknowledges that they understand the risks and accept all damages that may arise as a result of these risks.

8.3. User's Representations and Warranties: When registering on the Platform and using the services, the User represents and warrants the following:

• The User has the ability to read and understand all the terms of this Agreement; is an adult and a natural person competent to perform legal transactions on their own behalf or a legal entity duly represented.
• The User will use the account created on the Platform only on their own behalf; they will not perform transactions for a third party as an agent, intermediary, or representative. They assume responsibility for all transactions made under their account.
• The User shall comply with all applicable laws and regulations when using the Platform. The User agrees not to use the Platform for illegal activities such as illegal betting, gambling, money laundering, terrorist financing, smuggling, fraud, or unauthorized sale of securities.
• All information provided when registering on the Platform and during its use is accurate and up-to-date; the User guarantees that the documents submitted to WhiteBIT TR are genuine and have not been forged or altered.
• The User shall keep their account login details (username, password, 2FA devices, etc.) confidential and shall not share them with third parties. The User is responsible for the security of their account information; they shall use a strong password and enable additional security measures such as two-factor authentication as recommended by WhiteBIT TR.
• If the user suspects that their account information or password has been compromised by third parties, they will immediately notify WhiteBIT TR. WhiteBIT TR is not liable for any damages arising from transactions made on the account during the period prior to this notification. The user acknowledges that they will be liable for the consequences of any unauthorized use of their account in the event of negligence on their part.
• While using the Platform, the User shall behave respectfully and lawfully towards other users, WhiteBIT TR personnel, or third parties. The User shall not send any criminal, threatening, harassing, insulting, obscene, or similar inappropriate content in any communication (chat, comments, etc.) made through the Platform. Otherwise, WhiteBIT TR may delete the relevant content and restrict the User's access (see Article 9.5).
• The user acknowledges, declares, and undertakes that any and all tax, duty, fee, and similar financial obligations that may arise under the applicable tax legislation, including profits earned from transactions carried out through the Platform, are solely their responsibility.
• The User undertakes to fulfill any obligations arising in this regard using their own resources and may not request any services or advice from WhiteBIT TR in this regard. WhiteBIT TR will not make any tax assessments, declarations, or deductions on behalf of the User unless there is a clear legal obligation to do so.
• The User acknowledges that any tax obligations that may arise in relation to the earnings obtained through the Platform, even retroactively, are solely his/her responsibility and that WhiteBIT TR has no liability in this regard.

8.4. Consequences of Non-Compliance: Any breach by the User of the above commitments shall constitute a violation of this Agreement. In such a case, WhiteBIT TR reserves the right to take appropriate measures regarding the action in question (such as account suspension, closure, notification to the competent authorities, or legal action). Furthermore, the User shall be liable to compensate WhiteBIT TR for all damages incurred as a result of such breaches. For example, if WhiteBIT TR is fined due to incorrect information provided by the User, or if a third party files a lawsuit against WhiteBIT TR, the User shall cover all expenses, damages, and losses incurred by WhiteBIT TR as a result.

8.5. Investment Decisions: The User acknowledges that any buy/sell decisions made on the Platform are entirely their own. No information provided on WhiteBIT TR (market data, analyses, research reports, news, employee comments, etc.) constitutes investment advice or guidance. WhiteBIT TR may provide general information about market conditions but does not recommend investing in a specific crypto asset and is not responsible for the User's profit/loss. The User hereby declares that they will bear the consequences of their own investment decisions and cannot claim any liability from WhiteBIT TR in this regard.

9. RIGHTS AND RESPONSIBILITIES OF THE PLATFORM

9.1. Platform Obligations – General: WhiteBIT TR undertakes to provide Platform services in accordance with the principles of honesty, diligence, and compliance with the law. WhiteBIT TR's fundamental obligations include maintaining the technical infrastructure of the Platform in a secure and operational state, executing customer orders in accordance with the Agreement, protecting customer assets, and maintaining proper records. WhiteBIT TR conducts its activities in a manner open to CMB supervision and submits all relevant information and documents to the CMB. In addition, the Platform is obligated to store records related to user transactions for specified periods and to present them to the authorities when necessary (see Article 14).

9.2. Uninterrupted Service and Maintenance: WhiteBIT TR will make every effort to ensure the Platform provides uninterrupted service 24/7. However, service interruptions may occur due to maintenance, updates, or unforeseen technical issues. WhiteBIT TR will notify Users in advance whenever possible in cases of planned maintenance. In emergencies or unexpected failures, the Platform may be temporarily disabled. WhiteBIT TR will work to restore service as soon as reasonably possible. The User understands that during such interruptions, they may not be able to trade or may experience delays in accessing their assets. WhiteBIT TR shall not be liable for any damages incurred by the User due to interruptions beyond its control or force majeure (Article 15).

9.3. Order and Transaction Management: WhiteBIT TR manages user orders fairly in accordance with the Agreement and its own Order Execution Policy. The platform ensures equal market access for all users; for example, the rules established for market maker and market taker transactions apply equally to all users. WhiteBIT TR may take temporary measures to protect the market in extraordinary market conditions (e.g., sudden and extreme price movements, liquidity crises): For example, implementing a trading halt for a specific crypto asset, temporarily freezing order acceptance, or setting a price margin. Such measures are taken in compliance with CMB regulations and in a manner that protects users. If WhiteBIT TR takes such an emergency measure, it will notify Users as soon as possible via the announcement board, email, or similar means.

9.4. Liquidity Provision and Market Making: Liquidity may vary depending on the trading volume of the relevant cryptocurrency, market depth, the intensity of buy and sell orders, and the activity of market participants. While the Platform does not directly guarantee liquidity, it provides the necessary technical infrastructure to enhance liquidity through its order matching system and market-making mechanisms. The Platform may engage in market-making activities or provide liquidity to other exchanges/platforms to the extent permitted by the Capital Markets Board (CMB) in order to increase liquidity and establish a healthy market structure. For example, WhiteBIT TR may narrow the bid-ask spread between buyers and sellers by continuously quoting buy and sell prices for certain trading pairs using its own algorithms. These activities are conducted in accordance with WhiteBIT TR's principle of transparency and do not aim to manipulate the market. WhiteBIT TR matches User orders in accordance with the principles specified in the Agreement, even in transactions where it acts as a market maker on its own platform, and protects the interests of the User. The User accepts that the Platform may perform such transactions for the purpose of providing liquidity.

9.5. Content and Behavior Monitoring: WhiteBIT TR has the right to monitor the content created by Users while using the Platform (e.g., what they write in forums, chats, comment sections, etc.) and their behavior. The User is responsible for any content they share on the Platform and undertakes that such content will comply with the law and general moral rules. WhiteBIT TR may, at its sole discretion, delete or block access to any user content that it determines to be in violation of the law or the terms of the Agreement. For example, a message insulting another user, a post promoting an illegal product, or unauthorized content intended for advertising/promotional purposes may be removed from the Platform. Such intervention does not impose an obligation on WhiteBIT TR to notify the user in advance. Furthermore, WhiteBIT TR reserves the right to suspend or terminate the accounts of users who threaten the security of the Platform, engage in fraudulent activities, or misuse the system.

9.6. Data Provision and Copyright: WhiteBIT TR owns or holds the relevant rights to all price data, graphics, statistics, and other content displayed on the Platform. Users may only view the data and content provided by WhiteBIT TR for personal use. Copying this data in bulk, providing it to third-party applications, or using it for commercial purposes without WhiteBIT TR's written permission is prohibited. WhiteBIT TR may share data via API (Application Programming Interface) at its sole discretion; in this case, the terms of API use are determined separately. All intellectual property rights to the software, interface, and designs provided by WhiteBIT TR belong to WhiteBIT TR. The User agrees not to decrypt the Platform in any way, including through reverse engineering or source code analysis, and not to make unauthorized copies or reproductions.

9.7. Limitation of Liability: Platform services are provided "as is" and "to the extent possible." WhiteBIT TR makes no express or implied warranty that the services will be uninterrupted, error-free, or fit for a particular purpose. WhiteBIT TR acknowledges that it has taken reasonable precautions to ensure that the Platform is properly presented and that it has fully fulfilled its obligations under this Agreement. In this context, WhiteBIT TR shall not be liable under any circumstances for any damages arising from the use or inability to use the Platform, including but not limited to direct or indirect losses, lost profits, business interruption, data loss, or loss of reputation. Specifically:

• WhiteBIT TR is not responsible for damages resulting from fluctuations in crypto asset prices or market conditions. The User conducts trading at their own risk and cannot claim damages resulting from market changes.
• WhiteBIT TR is not responsible for the performance and reliability of blockchain networks. Since transaction confirmation times, network congestion, miner issues, or smart contract vulnerabilities are beyond WhiteBIT TR's control, WhiteBIT TR cannot be held liable for any damages arising from such circumstances.
• WhiteBIT TR is not responsible for losses resulting from the failure or error of third-party services (bank transfers, payment processors, external wallet services, API integrations, etc.). For example, if funds arrive late due to delays in the banking system or if assets are lost due to a security vulnerability in the external wallet service used by the User, this loss is the responsibility of the User.
• WhiteBIT TR shall not be liable for any transactions that cannot be completed or any erroneous transactions resulting from possible technical failures, software errors, or system interruptions on the platform, unless there is intent or gross negligence on the part of WhiteBIT TR. WhiteBIT TR will make good faith efforts to remedy any systemic problems it discovers and will attempt to cancel or compensate for affected transactions; however, the User agrees not to make any claims for indirect damages or loss of opportunity.
• WhiteBIT TR is not a party to disputes between users or between a user and a third party and therefore assumes no responsibility or liability.

9.8. Indemnification (WhiteBIT TR's Rights): The User agrees to indemnify and hold harmless WhiteBIT TR, its affiliates, employees, and representatives from any and all claims, demands, damages, and expenses that WhiteBIT TR may incur if the User uses the Platform in violation of this Agreement or the law. This means that if a third party sues WhiteBIT TR due to the User's actions or if administrative authorities impose penalties on WhiteBIT TR, any expenses incurred by WhiteBIT TR, including defense costs, attorney's fees, and penalties paid, may be recovered from the User. WhiteBIT TR reserves the right to deduct the relevant amounts from the User's account or to pursue legal remedies in such a case.

9.9. Right to Make Changes to the Platform: WhiteBIT TR reserves the right to make unilateral changes to the Platform's interface, design, terms of use, and features offered. Such changes generally apply to all Users, and WhiteBIT TR will endeavor to communicate significant changes in advance via website announcements, email, or mobile app notifications. If Users do not comply with the new changes, they have the option to stop using the Platform (see the Contract Termination clause). By continuing to use the Platform, the User is deemed to have accepted the changes made.

9.10. Customer Service and Complaint Management: WhiteBIT TR offers a customer support service to answer Users' questions and resolve any issues they may encounter (email and support form channels are available, with 24/7 service targeted). Users may submit their questions or complaints regarding the Platform through the support channels. WhiteBIT TR undertakes to evaluate incoming complaints and requests within the time limits stipulated by law and to make efforts to resolve them. If the User's complaint cannot be resolved, the right to resort to legal remedies is reserved. WhiteBIT TR also declares that it will comply with the regulations imposed by the CMB and other relevant authorities regarding customer complaints.

10. CRYPTO ASSET LISTING AND DELISTING POLICY

10.1. Listing Authority: WhiteBIT TR has the authority to decide which crypto assets will be listed (traded) on the Platform. The decision to open a crypto asset for trading on the Platform is made based on WhiteBIT TR's internal evaluations, market conditions, project reliability, legal compliance, and technical suitability analyses. Users may request WhiteBIT TR to list any specific cryptocurrency, but WhiteBIT TR evaluates these requests at its sole discretion and is the final authority on listing. The listing of any cryptocurrency is not guaranteed, and WhiteBIT TR reserves the right to update its listing criteria and processes at any time.

10.2. Delisting Rules

10.2.1. WhiteBIT TR reserves the right to remove any coin/token from the Platform for any reason specified in the coin/token listing agreement. After making such a decision, WhiteBIT TR will send a delisting notice to the coin/token issuer (or the team/legal entity managing the relevant project, or the owner(s) of the relevant project, or the Person who initiated the listing) fourteen (14) calendar days prior to the commencement of the delisting procedure.

10.2.2. WhiteBIT TR makes the decision to delist the coin/token by following the criteria/conditions below:

• if the coin/token is no longer supported by the team, issuer, community, etc.;
• if the blockchain or related technology is compromised or becomes defective, or if there are serious technical or security issues/problems (including those known from public sources);
• Due to the implementation of new regulatory standards and other compliance issues;
• The coin/token faces significant legal issues related to compliance with applicable laws and regulations;
• Violation of the WhiteBIT TR User Agreement or the relevant listing agreement;
• in circumstances specified by the relevant listing agreement;
• receiving multiple complaints (or reports of suspicious activity) from users regarding the coin/token;
• If necessary to prevent and/or stop fraud, manipulation, security breaches, or other illegal actions, or cyberattacks.

10.2.3. The start of the Delisting procedure is marked by disabling coin/token deposits and trading, setting a period for the withdrawal of coins/tokens, and sending a Delisting notification to Users who hold these coins/tokens in their Accounts.

10.2.4. WhiteBIT TR will send notifications regarding the delisting of coins/tokens to Users holding such coins/tokens in their Accounts via email notification and/or social media posts. Users are responsible for regularly checking for updates regarding the delisting of the coin/token.

10.2.5. WhiteBIT TR will give Users a specific period of time, specified in the delisting notification, to withdraw coins/tokens from their WhiteBIT TR Accounts to external wallets. The period specified in the delisting notification to Users will be 30 calendar days from the date of publication.

10.2.6. At the end of the specified announcement period, acceptance of buy/sell orders for the relevant crypto asset will be suspended, and any open orders placed up to that point will be canceled. WhiteBIT TR reserves the right to remove the coin/token from the Platform after the expiration of the Withdrawal period specified in the Delisting notification and is free to do so. In this case, technical support for the coin/token (and the technical ability to hold the coin/token in the platform's wallet) will be terminated. The User acknowledges that it is their responsibility to withdraw or convert the assets subject to delisting from the Platform within the specified timeframes.

10.2.7. If WhiteBIT TR cannot guarantee the withdrawal of the relevant Digital Assets (related to the blockchain in question) within 30 calendar days due to technical or other changes or technical issues arising in the relevant blockchains (major technical issues or updates), WhiteBIT TR reserves the right to shorten this period. In this case, WhiteBIT TR will send at least 3 (three) warnings to Users via email and/or official social media channels.

10.2.8. Liquidation of Remaining Assets: If, at the end of the announced withdrawal period for delisted crypto assets, there is still a balance on WhiteBIT TR and the User has not withdrawn these assets, WhiteBIT TR may liquidate or convert these assets in a manner beneficial to the User. For example, WhiteBIT TR may credit the value obtained by selling the asset in question on the external market to the User's TL balance or, if possible, automatically convert the asset into a stable coin (such as USDT/USDC). Such transactions are carried out in mandatory cases due to the asset no longer being technically supported, and the most reasonable solution for the User is targeted. WhiteBIT TR will strive to keep Users informed throughout this process.

10.2.9. User Responsibility: The User should be aware that any asset listed on the Platform may be delisted in the future. WhiteBIT TR cannot be held liable to the User for delisting decisions made in good faith and for the purpose of protecting users. The User will be responsible for any damages incurred if they miss the withdrawal period after delisting.

10.2.10. Platform Responsibility: WhiteBIT TR strives to make listing and delisting decisions transparently and in the best interests of users. WhiteBIT TR provides users with all possible technical support for withdrawal transactions of delisted assets; for example, if the network is operational after delisting, the infrastructure necessary for users to withdraw their assets is maintained. However, in circumstances beyond WhiteBIT TR's control, such as the complete collapse of the project, the blockchain stopping, or legal obstacles, WhiteBIT TR will make reasonable efforts to recover User assets but does not make any additional commitments regarding compensation for damages.

11. FEES AND COMMISSIONS

11.1. Fee Schedule: The type, rates, and collection method of commissions and fees charged by WhiteBIT TR for the services it provides are published on the Fees/Commissions page of the Platform's website. This schedule includes market maker and buyer commission rates for trading transactions, network fees/commissions for crypto asset withdrawal transactions, fiat currency deposit/withdrawal fees, and any other service fees, if applicable. By starting to trade on the Platform, the User is deemed to have accepted the applicable schedule and agrees that the relevant fee will be charged for each transaction they execute.

Additionally, transaction fees that must be paid directly to public institutions or authorized service providers due to integration with MKK, KPS, MERSIS, MASAK E-Tebligat, or other public systems within the scope of WhiteBIT TR's legal obligations may be passed on to the user. Such fees are collected from the user based on the relevant institution's rates and are not included in WhiteBIT TR's revenue.

11.2. Commission Collection: WhiteBIT TR collects commissions arising from purchase and sale transactions by deducting them directly from the transaction amount at the time of the transaction. For example, when a User executes a 1 BTC purchase order, a certain percentage of commission is deducted and the remaining amount is transferred to the user, or the commission is deducted from the TL balance as a result of the transaction. For crypto asset withdrawal transactions, the relevant blockchain transfer fee (miner fee) and the withdrawal commission applied by WhiteBIT TR are automatically deducted from the withdrawn amount. Similarly, for fiat currency withdrawal transactions, bank transfer/EFT fees and any applicable commission may be deducted from the amount payable to the User. The User acknowledges that they have granted WhiteBIT TR an irrevocable authorization to collect commissions and that the Platform has the right to collect these commissions from the account balance.

11.3. Fee Changes: WhiteBIT TR reserves the right to change its fee schedule. Any increases in fee rates or changes in fee types will be announced by WhiteBIT TR on its website and/or via email prior to their entry into force. For example, if a general update to commission rates is to be made, WhiteBIT TR will endeavor to announce this at least 7 days in advance. By continuing to use the Platform after the announced change date, the User is deemed to have accepted the new fee schedule. If the User does not accept the new schedule, they have the right to close their account and refrain from using the Platform services (in which case they will need to withdraw any assets they may have).

11.4. Non-Transaction Fees: WhiteBIT TR may apply additional fees under certain conditions, apart from basic transaction fees. For example:

• Inactive Account Fee: If the User's account has not been used for 6 months or longer and still holds a balance, WhiteBIT TR may consider the account inactive. If the account remains inactive, WhiteBIT TR may apply a nominal maintenance fee to cover operational costs. Even if this practice and amount are not specified in the agreement, WhiteBIT TR will announce it in advance if it is in effect.
• Incorrect/Extra Transaction Fees: If the User's incorrect transaction requests (e.g., sending to the wrong wallet address and requesting recovery from WhiteBIT TR) require extra effort, WhiteBIT TR may charge a reasonable transaction fee. This fee will be determined based on the cost of the relevant recovery operation and will be notified to the User in advance.
• Other Service Fees: New services that may be offered by the Platform (e.g., premium membership, instant notification service, API premium access) may be offered with an additional subscription fee or usage fee. In this case, the User's consent will be obtained before using such a service.

11.5. Taxation: In accordance with the tax legislation in force in Turkey, WhiteBIT TR will issue invoices and tax the commissions received for the services provided when deemed necessary. Transaction commissions and fees are, as a rule, stated inclusive of Value Added Tax (VAT) (unless otherwise specified). WhiteBIT TR reserves the right to collect from Users any additional legal deductions it may be required to apply to commissions in the event of changes in tax laws or the introduction of new legal obligations. The User agrees to comply with the applicable tax legislation while using the Platform and to fulfill their own tax obligations (such as declaring their earnings).

11.6. Fee Disputes: If the User wishes to dispute a fee or commission item deducted from their account, they must notify customer service in writing. WhiteBIT TR will review the dispute and correct any possible error; otherwise, it will notify the User that the fee deduction complies with the Agreement and the published tariff. Transactions within a reasonable period (e.g., 30 days) prior to the date of the dispute will be considered; for disputes regarding older transactions, WhiteBIT TR's transaction records will be used as the basis, and statutory limitation periods will apply.

12. SECURITY AND INFORMATION SYSTEMS

12.1. Information Systems Security: WhiteBIT TR operates the Platform's information systems and technological infrastructure in accordance with the relevant regulations of the CMB (e.g., Information Systems Communiqué No. VII-128.10) and international standards. In this context, WhiteBIT TR has taken all necessary technical and administrative measures regarding network security, system access controls, data encryption, penetration testing, log records, and business continuity. The Platform's servers are hosted in secure data centers, critical data is backed up, and disaster recovery plans are implemented. User data and transaction records are protected in accordance with the KVKK and relevant legislation. WhiteBIT TR monitors 24/7 against illegal access attempts or cyber attacks and uses firewalls, intrusion detection/prevention systems, and other up-to-date security tools to prevent potential threats.

12.2. Two-Factor Authentication (2FA): WhiteBIT TR supports two-factor authentication to enhance user account security. Users are encouraged to enable a second verification method, such as SMS verification, one-time password (OTP) via the mobile app, or hardware authenticator, when logging into their accounts and performing critical transactions (e.g., withdrawing funds/crypto). WhiteBIT TR reserves the right to require the use of 2FA for higher security (especially for users conducting high-value transactions or for corporate accounts). The user acknowledges that disabling 2FA or similar security features increases their own risk. A User with 2FA set up on their account may request a 2FA reset by contacting WhiteBIT TR and completing identity verification steps if they lose their verification device or access to it; in this case, WhiteBIT TR may request additional security questions and documents.

12.3. User Account Security: The User is also responsible for security at the level of their own devices and account information. Accordingly:

• They must use up-to-date and reliable antivirus software and protect their devices from malware.
• They should set a complex and difficult-to-guess account password and change it regularly. They should avoid using the same password on other platforms.
• They should be cautious about emails or messages that they are not sure came from WhiteBIT TR (they should be aware of phishing attacks and not click on suspicious links). WhiteBIT TR never requests user passwords via email or phone; users should not trust such requests.
• Users should avoid accessing their accounts from shared or public computers; if they must access them, they should not save their login information and should log out after use.

The user accepts that they will be responsible for any unauthorized transactions that may occur on their account if they fail to take these basic security measures (as specified in Article 8.3). WhiteBIT TR may publish brochures, guides, or warnings regarding user account security, and the User should take these into consideration.

12.4. Internal Security and Controls: WhiteBIT TR also implements strict controls regarding personnel and system security within its own organization. Employee access to customer assets is restricted as a matter of principle; only personnel with specific access permissions required for their duties may access critical systems, and even then in a controlled and recorded manner. WhiteBIT TR has established a comprehensive internal security and monitoring system that records and monitors all employee activities. This ensures that precautions are taken against threats that may arise from within. In addition, WhiteBIT TR pays attention to employee reliability during the hiring process and provides regular cybersecurity training to its employees.

12.5. Notification in Case of Breach: If WhiteBIT TR detects a security breach (such as a data leak or system hack) affecting user information or assets despite all security measures, it will make the necessary notifications in accordance with relevant legislation and inform Users about the scope of the breach. In particular, if a "personal data breach" is involved under the KVKK, notification will be made to the Personal Data Protection Authority and affected Users within the legal timeframes. WhiteBIT TR will also implement emergency action plans to minimize damage and prevent recurrence in such cases, temporarily suspending Platform activities if necessary. The User acknowledges that WhiteBIT TR cannot be held liable for the criminal actions of malicious third parties as long as WhiteBIT TR has taken all reasonable precautions against possible attacks and breaches.

12.6. Transaction Security and Approval: WhiteBIT TR may request additional security verifications for critical transactions on the Platform (e.g., large-value transfers, account information changes, etc.). For example, steps such as sending a confirmation link to the User's registered email address, sending an SMS code to the registered phone number, or answering identity verification questions may be applied. These procedures are intended to enhance User and Platform security. The User understands that the relevant transactions will not be executed without completing these additional security steps.

12.7. Device and Browser Security: The User must ensure that the devices (computers, smartphones, etc.) used to access the Platform are up-to-date and secure. It is the User's responsibility to use an up-to-date operating system and browser and not to install untrusted applications. WhiteBIT TR may offer mobile applications in addition to its web application; the User should only download mobile applications from official sources (such as the App Store or Google Play). Applications downloaded from unofficial sources pose a security risk, and WhiteBIT TR accepts no responsibility in such cases.

12.8. Information Systems Audit: WhiteBIT TR conducts regular independent audits or obtains security testing services from authorized institutions in accordance with the criteria determined by the CMB within the scope of information systems audits. Compliance with standards set by authorities such as TÜBİTAK Infrastructure Criteria is ensured. Any deficiencies identified in the audit reports are promptly addressed. In addition, WhiteBIT TR uses monitoring systems to detect unusual activity in user accounts (such as suspicious login attempts from different IP addresses or hundreds of orders placed in a very short time) and may temporarily block accounts in abnormal situations. This is for account security purposes, and verification is performed by contacting the User if necessary.

13. PRIVACY AND PROTECTION OF PERSONAL DATA

13.1. Disclosure under the KVKK: WhiteBIT TR processes and protects Users' personal data in accordance with the Personal Data Protection Law No. 6698 (KVKK) and related legislation. Personal data shared when registering on the Platform and using the services (identity information, contact information, financial data, transaction records, IP address, device information, etc.) is collected and processed for the purposes of fulfilling the Agreement, complying with legal obligations, and within the scope of WhiteBIT TR's legitimate interests. WhiteBIT TR has published its Personal Data Protection and Processing Policy, Disclosure Statement, and related documents on its website. By becoming a member of the Platform, the user acknowledges that they have been informed about the processing of their personal data as described in these documents and that their consent has been obtained to the extent necessary.

13.2. Data Processing Purposes: WhiteBIT TR may process personal data for the following purposes:

• Provision of Services: To perform services covered by the Agreement, such as account creation, identity verification, customer classification, transaction execution, record keeping, fee collection, and customer support services.
• Legal Obligations: To fulfill obligations such as identity verification, reporting suspicious transactions, information custody, and responding to requests from official authorities, as required by MASAK regulations, the Capital Markets Law, the Tax Procedure Law, and other regulations.
• Security and Fraud Prevention: To ensure account and transaction security, detect unauthorized or suspicious transactions, prevent misuse, and ensure system security.
• Communication: To provide necessary communications such as notifications to the User regarding the Agreement, transaction confirmations, security alerts, and maintenance announcements. In addition, marketing communications and campaign notifications may be sent if the User has given their consent (the User may withdraw this consent at any time).
• Improvement and Analysis: To perform anonymous or aggregate data analysis for the purpose of improving platform services, designing new features, and enhancing the user experience.

13.3. Data Sharing: WhiteBIT TR may share Users' personal data with third parties in accordance with the law and the principle of fairness. These shares are as follows:

• Authorized Official Authorities: Necessary user information may be transferred to legally authorized judicial and administrative authorities (courts, prosecutors, CMB, MASAK, Revenue Administration, etc.) upon their request or in cases of legal obligation (as explained in Article 7.7).
• Business Partners and Service Providers: WhiteBIT TR may work with certain domestic/foreign third parties while providing its services (e.g., infrastructure companies providing cloud computing services, customer support software providers, technology companies providing identity verification services, banks and payment institutions, law/consulting firms). Data necessary for the service is transferred to these parties on a limited basis. WhiteBIT TR ensures that the service providers to whom it transfers data comply with the KVKK and privacy obligations and enters into the necessary data processing agreements.
• Group Companies: Data may be transferred to domestic or foreign group companies directly or indirectly affiliated with WhiteBIT TR for internal reporting, risk management, and consolidated customer management purposes. In this case, the necessary measures will be taken in accordance with the legislation (e.g., if transfer abroad is required, the conditions specified in Article 9 of the KVKK will be met).
• Sharing at the User's Request: If the user voluntarily requests the transfer of data from the Platform to another financial institution or digital wallet (e.g., transfer of account balance to another institution), WhiteBIT TR may share the necessary data in accordance with the user's instructions to fulfill this request.

WhiteBIT TR does not sell, rent, or share user data with unauthorized third parties in any way for commercial gain.

13.4. Data Retention Periods: WhiteBIT TR is obligated to retain users' identity, account, and transaction information for the period specified by applicable legislation. For example, customer identification and transaction records are retained for at least 8 years in accordance with the MASAK Measures Regulation; records related to investment services are retained for at least 10 years in accordance with CMB regulations. WhiteBIT TR keeps such data secure and confidential during these periods and destroys it at the end of the period unless legally required otherwise. The User acknowledges that WhiteBIT TR may continue to retain their data after the termination of the Agreement due to legal retention requirements. During this period, the data may only be used for purposes permitted by law (requests from authorized institutions, legal proceedings, etc.).

13.5. User Rights: Pursuant to Article 11 of the KVKK, the User may apply to WhiteBIT TR to learn whether their personal data has been processed;

• Whether their personal data has been processed,
• Request information if processed,
• To learn the purpose of processing and whether it is being used in accordance with that purpose,
• To know the third parties to whom the data has been transferred within or outside the country,
• Request the correction of data if it has been processed incompletely or incorrectly,
• Requesting the deletion or destruction of the data in accordance with the law,
• Requesting that these actions be communicated to third parties to whom the data has been transferred,
• Objecting to a result that is detrimental to the individual due to analysis exclusively by automated systems,
• To request compensation for damages incurred due to unlawful processing,

The user has these rights. To exercise these rights, the user may apply to WhiteBIT TR in writing or using the methods specified in the KVKK (e.g., via a registered email address). WhiteBIT TR will evaluate the request within 30 days at the latest and respond in accordance with the law. In some cases, particularly due to legal obligations, WhiteBIT TR may not be able to fully comply with every request (e.g., deletion may not be possible if there is a requirement to retain certain data); however, in such cases, the User will be informed with the relevant justification.

13.6. Cookie Policy: The Platform website and mobile application may use cookies to improve the user experience and perform statistical analysis. WhiteBIT TR publishes its Cookie Policy on its website, and users agree to this policy when using the site. Users are free to restrict the use of cookies through their browser settings; however, in this case, they understand that some features of the Platform may not function properly.

13.7. Privacy Commitment: WhiteBIT TR strictly adheres to internal privacy principles to protect users' personal data and account privacy. Employees and business partners are obligated to ensure the confidentiality of user data obtained in the course of their duties and are contractually bound by commitments in this regard. WhiteBIT TR does not disclose confidential information belonging to users (account balances, trade secrets, etc.) to third parties without the user's explicit consent or legal obligation.

13.8. Communication and Commercial Electronic Messages: By providing their contact information when registering on the Platform, the User agrees that WhiteBIT TR may send them notifications regarding the Agreement and account usage. Additionally, if the User has provided separate consent, they are deemed to have agreed to receive commercial electronic messages from WhiteBIT TR and its business partners containing campaign, promotional, and new product announcements. The User may notify WhiteBIT TR at any time to stop receiving these commercial communications or use the opt-out mechanisms in the communications. In this case, WhiteBIT TR will stop sending commercial communications within the legal timeframe.

14. RECORD RETENTION AND EVIDENCE AGREEMENT

14.1. Record Retention Obligation: WhiteBIT TR is obligated to retain all transaction and communication records related to the services provided under this Agreement for the period required by law. In this context, data such as the User's identity information, account movements, purchase and sale orders and transactions, balance changes, deposit/withdrawal records, correspondence with WhiteBIT TR, and contract approvals are securely stored in electronic form. In accordance with Capital Markets Board regulations and MASAK legislation, such records shall be retained for a minimum period of 10 years. WhiteBIT TR uses cryptographic signatures, time stamps, and backup methods to ensure the integrity and confidentiality of the records it retains.

14.2. Sharing with Official Authorities: WhiteBIT TR will share the stored records with authorized authorities such as the CMB, MASAK, and courts upon their request (in accordance with Articles 7.7 and 13.3). These records are reliable electronic records taken from WhiteBIT TR systems and can be accepted as valid evidence in official proceedings. WhiteBIT TR also relies on these records in its internal audit and dispute resolution mechanisms.

14.3. Evidence Agreement: The User acknowledges and agrees that in any disputes arising from this Agreement, WhiteBIT TR's books and records, electronic data stored in WhiteBIT TR systems, email correspondence, transaction logs, computer records, and printouts generated by WhiteBIT TR shall constitute binding and conclusive evidence within the meaning of Article 193 of the Code of Civil Procedure. The Parties agree that this clause constitutes an evidence agreement and that the specified WhiteBIT TR records shall be binding unless proven otherwise by valid and credible evidence. Calculations and determinations made by WhiteBIT TR based on its own records shall be considered valid by the User as long as they are based on data extracted in good faith.

14.4. Priority of Official Records: If there is a discrepancy between the records kept in WhiteBIT TR's systems regarding the User's transactions on the Platform and the records of transactions on the blockchain or the records of banks, all data will be evaluated together as far as possible. However, ultimately, WhiteBIT TR's own system records and, where necessary, the relevant blockchain records shall be accepted as evidence together. The User shall act on the assumption that WhiteBIT TR's records have not been manipulated; if the User has such a claim, the burden of proof shall be on the User.

14.5. Protection of Records: WhiteBIT TR performs periodic backups to ensure the security of the records it stores and keeps these backups in different physical locations. Accesses and changes made to electronic records are also logged. The user must also store their own records (e.g., account statements from WhiteBIT TR, notification emails) appropriately. WhiteBIT TR will assist the user to a reasonable extent upon request regarding the details of a specific transaction, but will not be responsible for resending notifications lost on the user's end (for example, if the user has deleted their email, WhiteBIT TR will provide reasonable support from its archives but does not guarantee this).

15. FORCE MAJEURE

15.1. Definition of Force Majeure: Events that develop beyond the control of the parties and are unforeseeable, and which, when they occur, partially or completely, temporarily or permanently prevent the fulfillment of the obligations under this Agreement, are considered force majeure. Force majeure events are evaluated within the framework of relevant legal regulations and Supreme Court precedents. The following situations, for example, may be considered force majeure: War, terrorist acts, natural disasters (earthquakes, floods, fires, hurricanes, etc.), epidemics, general mobilization, power and internet outages, communication infrastructure failures, cyber attacks (despite WhiteBIT TR taking the necessary precautions), decisions or actions of state institutions (prohibitions, new regulations, court decisions), general strikes or lockouts, global interruptions in third-party services, blockchain network crashes or prolonged downtime.

15.2. Obligations of the Parties: In the event of force majeure, the affected party shall notify the other party of this situation and its effects as soon as possible. The obligations of the parties shall be suspended for the duration of the force majeure event. From WhiteBIT TR's perspective, obligations related to the provision of services may not be fulfilled during the force majeure period; in this case, WhiteBIT TR cannot be held liable. However, WhiteBIT TR shall make all reasonable efforts to minimize the effects of the force majeure event and to maintain services as much as possible.

15.3. Impact on Services: In cases of force majeure, the entire Platform or part of it may become unavailable, and transactions may be suspended or restricted. For example, if there is a nationwide internet outage, WhiteBIT TR will be unable to provide services; or if certain transactions are prohibited by an unexpected regulatory decision, WhiteBIT TR will immediately suspend them. In such cases, the User may not claim service interruption or compensation for damages from WhiteBIT TR.

15.4. Termination of Force Majeure: When the force majeure event ceases, the parties shall resume their suspended obligations from where they left off. WhiteBIT TR will do its utmost to restore its services to normal and will inform Users that the situation has been resolved. If the force majeure event continues uninterrupted for more than 30 days, either party may have the right to terminate the Agreement (in the event of termination, the return of User assets and account closure procedures shall be carried out in good faith, to the extent possible – see Article 17).

15.5. Special Circumstances – Cyber Attacks: A large-scale cyber attack targeting WhiteBIT TR's infrastructure may be considered a force majeure event. In such a case, WhiteBIT TR will first take urgent measures to ensure system security and protect assets; it may temporarily suspend services. The User acknowledges that WhiteBIT TR may take urgent decisions such as delaying or canceling transactions or restricting access to assets due to cyber attacks, and that this shall not constitute a breach of contract. WhiteBIT TR will resume normal operations once the effects of the attack have been eliminated and will remove any measures taken, if applicable.

16. CONTRACT AMENDMENTS

16.1. Right to Amend: WhiteBIT TR reserves the right to unilaterally amend the terms of this User Agreement. Amendments may arise for reasons including, but not limited to, updates to service conditions due to changes in legislation, the addition of new features, security requirements, or adaptation to market conditions. WhiteBIT TR undertakes to notify the User of any significant changes to the Agreement before they take effect. Notification may be made via an announcement on the Platform website, notification via email, or obtaining consent upon first login.

16.2. Notification Period: Changes to the Agreement will be announced at least 15 days in advance, unless a provision must take effect immediately. However, this period may not be observed for changes that must be implemented immediately due to legislation or authority decisions; in such cases, WhiteBIT TR will notify users as soon as possible.

16.3. User Acceptance: The amended Terms of Service become binding on the User upon use of the Platform after the specified effective date. If the User does not accept the updated Terms of Service, they have the right to close their account and terminate the Agreement by notifying WhiteBIT TR in writing before the effective date (the account closure procedure will be carried out in accordance with Article 17). Users who do not raise any objections during this period and continue to use the Platform are deemed to have accepted the new terms.

16.4. Scope of Changes: Changes to the Agreement may include additional terms and conditions as well as amendments to existing provisions. WhiteBIT TR will endeavor to clearly indicate which provisions have been amended or added in the text of the amendment (e.g., by providing the version number and date). Except for partial amendments, WhiteBIT TR will publish the current full text of the Agreement on its website in an easily accessible manner.

16.5. Fee and Policy Changes: Similar notification processes shall be followed in the event of changes to documents such as the Fee Policy, Personal Data Protection and Processing Policy, Disclosure Statement, Express Consent Statement, Risk Disclosure Form, and AML Policy, which WhiteBIT TR announces separately outside of this Agreement. These policy changes are generally considered to be of the same importance as changes to the Agreement. The User accepts the responsibility to review the current versions on the website when WhiteBIT TR updates its policies.

16.6. Extraordinary Circumstances: If WhiteBIT TR is forced to make immediate changes to the Agreement due to unforeseen circumstances (e.g., the sudden entry into force of a new legal regulation), it will inform users as soon as possible and obtain their consent. In cases where user consent is not required (e.g., legal requirements), WhiteBIT TR will explain the reason for the change in the notice.

16.7. Continuing Rights: Changes to the Agreement shall not affect the rights and obligations of Users relating to the period prior to the change. For example, transactions that took place before the date of the change shall remain subject to the terms of the old Agreement. Transactions made after the change shall be governed by the new terms.

17. TERM AND TERMINATION OF THE AGREEMENT

17.1. Term: This Agreement shall enter into force upon the User's electronic approval and shall remain in force between the Parties for an indefinite period. The Agreement shall remain valid until terminated by either Party or until the User's Platform membership expires.

17.2. Termination by the User: The User may terminate the Agreement at any time by providing written notice to WhiteBIT TR (e.g., by submitting a request through customer support channels) and may request the closure of their account. In order for the User to request termination, they must have paid all debts to the Platform, closed all open transactions, and withdrawn all assets from their account. After receiving the termination request, WhiteBIT TR will review the User's account to verify that there are no disputes, legal obstacles, or pending transactions, and will close the account within a reasonable time. When the account is closed, the User's access to the Platform will be terminated. If the User wishes to rejoin the Platform in the future, they will need to submit a new membership application.

17.3. Termination by WhiteBIT TR: WhiteBIT TR may terminate the Agreement unilaterally and close the User's account with or without notice to the User in the following circumstances:

• If the User violates the provisions of this Agreement (e.g., illegal transactions, providing false information, harassing other users, etc.), and WhiteBIT TR may also terminate this Agreement unilaterally and close the User's account without further notice or with reasonable notice in the following cases:
• The User seriously violates the terms of the Agreement or applicable laws (e.g., engaging in illegal activities, failing to comply with AML/KYC obligations, threatening the security of the Platform, violating the rights of other users).
• Reasonable suspicion of crimes such as money laundering, terrorist financing, or fraud involving the User, or receipt of a negative report about the User from official authorities.
• The need to close the User's account by court order or instruction from a competent public authority (e.g., the User's activities being prohibited by law).
• WhiteBIT TR's decision to terminate its services or its inability to continue providing services to the User due to relevant country/regulatory conditions (e.g., revocation of WhiteBIT TR's operating license in Turkey or the imposition of a regulatory ban).

In such cases, WhiteBIT TR may, if possible, notify the User in writing prior to termination and allow time for the situation to be rectified; however, in cases of serious breach or legal obligation, WhiteBIT TR may terminate immediately. WhiteBIT TR is not obligated to disclose the reasons for termination to the User but generally acts in consideration of the User's interests and legal obligations.

17.4. Termination by WhiteBIT TR (Without Notice or Cause): WhiteBIT TR may terminate this Agreement and close the User's account without cause, provided that it gives at least 10 days' prior notice, in addition to the above valid reasons. In this case, WhiteBIT TR will notify the User of the termination date and the time the account will be closed; it will allow a reasonable period for the User to withdraw any assets they may have on the Platform.

17.5. Status of Account and Assets Upon Termination: Upon termination of the Agreement by the User or WhiteBIT TR, the User's account on the Platform will be closed and access to the services will be terminated. Prior to termination, the User must close all open positions in their account, withdraw any remaining crypto assets, and transfer their fiat currency to their own bank account.

• In the Event of User Termination: After the User submits a termination request, WhiteBIT TR will review the User's account balance and transactions; if there are no disputes or obstacles, it will refund the entire balance belonging to the User to the accounts specified by the User (withdrawal options are provided for crypto assets, fiat balances are sent to the registered bank account). The account is closed after the User has successfully withdrawn all assets.
• In the Event of WhiteBIT TR Termination: WhiteBIT TR will endeavor to return the assets in the User's account on the termination date to the User. If the User has been notified in advance, they will be asked to withdraw their assets by the termination date. If there is still a User balance at the time of termination, WhiteBIT TR will contact the User to transfer this balance to the User's registered bank account (for fiat) or send it to the User's wallet (for crypto). If the User cannot be reached or the User cannot provide instructions within a reasonable time, WhiteBIT TR may, if applicable, convert the relevant assets into TL and transfer them to the User's bank account or hold them in custody in accordance with applicable law. In cases of legal impediments (e.g., seizure of criminal proceeds, etc.), these assets may be surrendered to the relevant authorities.

17.6. Consequences of Termination: Termination of the Agreement does not eliminate the rights and obligations of the parties that arose prior to termination. The parties are subject to general provisions regarding receivables, debts, compensation claims, and liabilities related to the period prior to termination. In particular, payment obligations arising from transactions carried out by the User during the term of the Agreement (commission debt, etc.) shall continue to be fulfilled after termination. WhiteBIT TR shall continue to store user data for the legal period in accordance with its relevant record-keeping obligations (Article 14) after termination. Upon termination, the User's right to use the services covered by the Agreement shall cease, but Articles 7, 8, 9, 13, 14, 18, and 19 of this Agreement shall continue to be effective after termination (provisions that continue to apply by their nature).

17.7. Post-Account Closure Procedures: After the account is closed, the User cannot log in to the Platform and cannot perform new transactions. If the User has other agreements signed with WhiteBIT TR or has given standing instructions (e.g., API keys, automatic purchase instructions), these will also be terminated. The User acknowledges that if they wish to use WhiteBIT TR services again in the future, they will need to submit a new application; data related to their previous account (except for data subject to legal retention) will be deleted or anonymized.

18. APPLICABLE LAW AND JURISDICTION

18.1. Choice of Law: This Agreement and all disputes arising from its implementation, including interpretations and rulings, shall be governed by the laws of the Republic of Turkey. The parties agree that Turkish law shall apply to this Agreement and that conflict of laws rules shall not apply.

18.2. Competent Court: The Courts and Enforcement Offices of Istanbul (Çağlayan) shall have exclusive jurisdiction over the resolution of any disputes arising from or related to the Agreement. Subject to the rights of Users who are consumers, the parties undertake not to apply to the jurisdiction of any other court. (If the User is considered a "consumer" under the Consumer Protection Law No. 6502 and the transaction falls within the scope of this law, the right to apply to the Consumer Courts in their place of residence may exist by law; in this case, the relevant legal regulations shall apply.)

18.3. Optional Resolution Methods: The parties shall endeavor to resolve the issue through conciliation and negotiation before resorting to court proceedings. If the dispute communicated to WhiteBIT TR's customer support unit cannot be resolved, the user may exercise their legal rights. (As WhiteBIT TR is currently a platform under the supervision of the Capital Markets Board (CMB), the User also has the right to file a complaint with the CMB or other competent authorities.)

19. OTHER PROVISIONS

19.1. Prohibition on Assignment: The User may not assign or transfer any rights or obligations arising from this Agreement, in whole or in part, to a third party without WhiteBIT TR's prior written consent. The User account is personal and may not be used by anyone other than the User. WhiteBIT TR, however, has the right to assign this Agreement and/or the operation of the Platform to another company; in such a case, WhiteBIT TR will notify Users within a reasonable period of time, and Users' rights will not be affected after the assignment. In the event of an assignment, the Agreement shall continue in full force and effect with the new assignee company.

19.2. Integrity of the Agreement: This Agreement, together with its attachments and referenced policies, constitutes the entire agreement between the parties and supersedes all prior written or oral statements and agreements between the parties. If WhiteBIT TR has entered into special protocols or additional agreements with the User (e.g., corporate membership agreement), then those agreements shall also be valid to the extent they do not conflict with this Agreement. In case of conflict, the provisions of the special agreement between the parties shall prevail.

19.3. Partial Invalidity (Severability): If any provision of this Agreement is declared invalid, void, or unenforceable by a competent court or authority for any reason, such provision shall be deemed severable from the Agreement and shall not affect the validity or enforceability of the remaining provisions. The Parties shall endeavor to reach an agreement in good faith on a new provision that is as close as possible to the purpose of the invalid provision and is legally valid.

19.4. No Waiver: The failure or delay by either Party in exercising any right or remedy arising under the Agreement shall not constitute a waiver of such right or remedy. WhiteBIT TR's failure to intervene in any breach of the Agreement shall not be construed as inaction in the face of similar breaches in the future. A delay in exercising a right or a single waiver does not preclude the future exercise of that right or other provisions of the Agreement.

19.5. Contract Language: This Contract is prepared in Turkish. If the Contract is translated into different languages by WhiteBIT TR, the Turkish text shall prevail in case of any interpretation differences or inconsistencies between the texts. Although the services offered by WhiteBIT TR are international in nature, the language of this Agreement prepared for users residing in Turkey is Turkish, and the Turkish text is valid and binding under the laws of the Republic of Turkey. (Even if WhiteBIT TR offers a global English agreement, this Turkish text takes precedence for Turkish users.)

19.6. Notifications and Communication: WhiteBIT TR may send notifications to the User by sending them to the email address provided by the User during registration or by making a general announcement on the Platform website. Notifications made electronically shall be deemed to have been delivered to the User on the date they are sent. The User is obligated to immediately notify WhiteBIT TR of any changes to their contact information; otherwise, they accept that notifications sent to their old addresses will be valid. When the User wishes to contact WhiteBIT TR, they must use the support email address or help desk portal specified in the "Contact Us" section of the Platform. WhiteBIT TR's current official contact address is specified at the beginning of the Agreement (also: email:support@whitebit-tr.com , KEP:whitebit.tr@hs01.kep.tr ). The Parties agree that written electronic communication has the nature of official notification and may be used as evidence when necessary.

19.7. Acceptance and Entry into Force of the Agreement: During the membership creation process, the User confirms that they have read and understood this entire Agreement online and unconditionally accept all its provisions. Clicking a button such as "I Accept" or checking a confirmation box constitutes an electronic signature and establishes the Agreement. This Agreement is deemed to have been concluded and entered into force in the digital environment at the moment of the User's electronic approval. The User's commencement of use of WhiteBIT TR services also constitutes proof of their consent to the Agreement.

19.8. Appendices and Supplementary Documents: All rules and policies published by WhiteBIT TR on the Platform, including the Personal Data Protection and Processing Policy, Clarification Text, Explicit Consent Statement, Risk Disclosure Form, AML&CFT Policy, and Fee Schedule, are appendices and integral parts of this Agreement. The obligations and rules specified in these documents shall apply in the same manner as the provisions of the Agreement. The User acknowledges that they have read and approved these policy texts.

This WhiteBIT TR User Agreement, which includes the above articles, shall become effective between the parties upon the User's electronic approval of all its provisions after reading and understanding them. The User acknowledges that they may download or request a copy of the Agreement from the WhiteBIT TR website at any time. The parties mutually undertake to comply with the terms of this Agreement.

ADDITIONAL DOCUMENTS AND POLICIES

• Personal Data Protection Disclosure Statement
• Personal Data Protection Explicit Consent Statement
• Electronic Communication Consent
• Cookie Policy
• Risk Disclosure Form