1. PURPOSE AND SCOPE

This Procedure governs how the Crypto Asset trading, exchange, and transfer transactions offered by CLTS Kripto Varlık Alım Satım Platformu A.Ş. (the "Company" or "Aquanow") are conducted within the framework of the applicable capital markets legislation and the Company's internal policies and procedures.
The purpose of this Procedure is to ensure that customer orders are processed transparently, securely, efficiently, and fairly and that customer rights are protected.

2. SCOPE OF SERVICES

The services offered through the Aquanow platform include:

• Purchase and sale of Crypto Assets,
• Exchange of Crypto Assets with one another,
• Transfer of Crypto Assets on behalf of customers,
• Provision of the custody services required to execute the relevant transfers.

3. TRADING AND EXCHANGE TRANSACTIONS

3.1. Execution of Purchase and Sale Orders

Customers may place purchase and sale orders through Aquanow's website or mobile application. Orders are processed in accordance with price and time priority rules.
The following factors are taken into account when executing orders:

• Order price,
• Speed of execution,
• Liquidity,
• Market conditions.

3.2. Exchange Transactions

Crypto Asset exchange transactions are carried out through the trading pairs supported on Aquanow. Customers submit the relevant request through the system to exchange one asset for another.
The following matters are taken into account in exchange transactions:

• Matching price,
• Execution process,
• Order volume in the system.

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4. TRANSFER TRANSACTIONS

4.1. Crypto Asset Transfer Request

Customers may request the transfer of Crypto Assets held on Aquanow to a wallet in their own name or to another wallet. Transfer requests must include the following information:

• Type of Crypto Asset to be transferred,
• Transfer amount,
• Recipient wallet address,
• Destination platform information, where required.

4.2. Execution of Transfers

Transfer transactions are subject to security checks in accordance with the Internal Control and Risk Management Procedure. Transfer requests considered risky may be rejected or additional information may be requested.
Transfers are processed in light of the following factors:

• Network congestion,
• Technical infrastructure,
• Security reviews.

5. RETENTION OF ORDER AND TRANSACTION RECORDS

Records relating to all orders received and processed and all transfer requests are maintained so as to include the date, time, amount, price, type of Crypto Asset, transaction type, and customer information.
For orders received electronically, the following are also retained:

• IP address,
• Information on the device used,
• Voice recordings, where applicable,
• Electronic logs, which are retained for 10 years in accordance with the relevant legislation.

6. CANCELLATION OF ORDERS AND UNEXECUTED TRANSACTIONS

Aquanow may cancel orders or reject transfer requests in the following circumstances:

• The order contains elements contrary to law,
• The account has insufficient funds,
• The transfer request poses a security risk,
• Technical failures or system-related issues,
• The customer has been blacklisted,
• Identification of orders that may disrupt the orderly operation of the market.
  Customers are also notified of unexecuted orders and transactions.
  
  

7. CONFIDENTIALITY AND DATA PROTECTION

Aquanow retains records relating to customer orders and transfer requests in accordance with the principle of confidentiality. All applicable legislation, including in particular Personal Data Protection Law No. 6698 (the "PDPL"), is complied with. Necessary technical and administrative measures are taken to prevent unauthorised access during data-processing activities.

8. FINAL PROVISIONS

This Procedure is reviewed by Aquanow at least annually or in response to changes in legislation and is updated where necessary. Customers are informed of updates made to the Procedure.

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