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Varlık — Terms of Service and User Agreement

Version: v1 · Last updated: June 4, 2026

These Terms of Service and User Agreement (the "Agreement") govern the rights and obligations of the parties regarding the use of the Varlık mobile application (the "Application" or "Varlık"). By downloading, creating an account, or using the Application in any manner, you represent that you have read, understood, and agreed to be bound by this entire Agreement. If you do not accept these terms, you must not use the Application.

IMPORTANT NOTICE: Varlık is solely a personal finance TRACKING and VISUALIZATION tool. Varlık is NOT investment advisory, portfolio management, or brokerage service; it does NOT provide investment advice, does not hold money, does not open accounts, does not execute trades, and does not act as an intermediary. All prices, values, and calculations displayed in the Application are for informational purposes only and may be delayed, incomplete, or inaccurate. Your investment decisions are entirely your own responsibility.

This Agreement is provided in Turkish and English. For users resident in Türkiye, in case of any conflict between the texts, the Turkish version prevails.

Last Updated: 03.06.2026 — Effective Date: 03.06.2026

1. Parties and Subject Matter

1.1. This Agreement is concluded electronically between Halilhan İnan, the individual developer and operator of the Application (a sole individual; hereinafter the "Developer", "Varlık", or "we"; contact: halilhaninan@gmail.com), on the one part, and the natural person who downloads, registers for, or uses the Application (the "User", "you"), on the other part.

1.2. The subject matter of this Agreement is to define the terms of use, and the mutual rights and obligations of the parties, for the personal net-worth and portfolio tracking, visualization, calculation, AI-assisted informational (AI Coach), and optional social features provided to the User through the Varlık Application.

1.3. The Application is distributed through the Apple App Store. Apple Inc.'s own terms (including the Apple Media Services Terms and the Apple Standard End User License Agreement) apply separately to the use of the App Store (see Section 19). Apple is not a party to this Agreement.

1.4. The User represents that, before beginning to use the Application, they have completed the age of 18 and have the legal capacity to act. Persons under the age of 18 may not use the Application.

2. Definitions

The principal terms used in this Agreement have the following meanings:

3. Scope and Nature of the Service

3.1. Varlık is a PERSONAL FINANCE TRACKING and VISUALIZATION tool that enables the User to consolidate in one place the asset information they enter MANUALLY, calculate their total net worth, view the current market value of their assets, and perform scenario calculations such as charts/projections and dividend/retirement estimates.

3.2. Varlık DOES NOT, under any circumstances, provide or perform the following:

3.3. All values, charts, and calculations displayed in the Application are informational VISUALIZATIONS based solely on the data the User has entered and on third-party market data. Their accuracy, currency, or correctness is not guaranteed.

3.4. The Developer reserves the right, at any time and without obligation of prior notice, to change the scope of the Service, add or remove features, and suspend it temporarily or permanently. Access to the Service may be temporarily interrupted due to technical maintenance, updates, or interruptions originating from Third-Party Providers.

3.5. The Service is provided "AS IS" and "AS AVAILABLE". The Developer does not warrant that the Service will be uninterrupted, error-free, or fit for a particular purpose.

4. Not Investment Advice (Important Legal Notice)

4.1. No information, data, chart, projection, calculation, leaderboard, AI Coach output, or content within Varlık constitutes INVESTMENT ADVISORY, investment advice, a buy/sell recommendation, or any inducement within the meaning of the Capital Markets Law No. 6362 (CML) and the relevant Capital Markets Board (CMB) regulations, and none may be construed as such.

4.2. Under the CML, investment advisory activity may only be carried out by institutions licensed by the CMB, on a personalized basis, and under a written agreement with the client. Varlık and the Developer are NOT an institution authorized to provide investment advice and do not engage in any such activity. The content provided in the Application consists of GENERAL information and tracking tools that are not personalized to any individual.

4.3. Standard CMB Notice (Communiqué No. III-37.1, Annex-3): The investment information, comments and recommendations herein do not constitute investment advisory services. Investment advisory services are provided by authorized institutions on a personalized basis, taking into account each individual's risk and return preferences. The comments and recommendations herein are general in nature. They may not be suitable for your financial situation and your risk and return preferences. Therefore, making an investment decision based solely on the information herein may not yield results consistent with your expectations.

4.4. No amount, return, projection, or scenario (including dividend, retirement, or future-value calculations) displayed or calculated in the Application constitutes a GUARANTEE OF RETURN, a profit guarantee, or any assurance regarding future performance. Past performance or assumption-based projections are not indicators of future results.

4.5. Capital market instruments, crypto assets, and other investments carry significant risks, including loss of price and value. The User is SOLELY AND EXCLUSIVELY responsible for all investment, trading, and financial decisions they make. Before making any investment decision, the User should obtain professional support from authorized institutions and expert advisors (certified accountants, licensed investment advisors, tax advisors, etc.).

4.6. The Developer cannot be held liable for any damage, loss of profit, or loss arising from decisions made or transactions carried out by the User in reliance on the information in the Application.

5. Artificial Intelligence (AI Coach) Feature

5.1. The AI Coach provides general and educational information generated by artificial intelligence (Anthropic, PBC — USA); it is NOT personalized investment advice, a buy/sell recommendation, or a portfolio recommendation prepared by taking into account your financial situation, risk preferences, or investment objectives.

5.2. AI outputs may, by their nature, be inaccurate, incomplete, misleading, or outdated, and may contain statements that do not reflect reality ("hallucinations"). Do not base any investment, financial, legal, or tax decision solely on AI Coach outputs; consult CMB-licensed authorized institutions and expert advisors where necessary.

5.3. When you use the AI Coach, your questions and any portfolio context you choose to share are transmitted to Anthropic (USA) so that a response can be generated. Detailed information and the legal basis regarding this transfer are set out in the PDPL Privacy Notice and Privacy Policy; the related explicit-consent/notification processes are conducted separately.

5.4. You are advised not to enter sensitive, confidential, or third-party personal data into the AI Coach. The User is solely and exclusively responsible for any decisions made or transactions carried out in reliance on AI Coach outputs.

6. Third-Party Data Provider Terms (Twelve Data + CoinGecko)

6.1. The Market Data displayed in the Application is sourced from third-party providers (Twelve Data and CoinGecko) and remains the property of those providers. The Developer does not produce this data.

6.2. When using such data, the User agrees to comply with the applicable terms of these providers and not to redistribute, commercially reproduce, or offer the data to third parties as an independent data source.

6.3. The providers furnish the data "AS IS" and without warranty of accuracy, and are not liable for any decisions made in reliance on it. The Developer likewise cannot be held liable for any errors, delays, or interruptions originating from Third-Party Providers.

6.4. The Application displays the attributions required by the relevant providers (for example, "Powered by CoinGecko").

6.5. The data, trademarks, and content belonging to Third-Party Providers are the property of their respective owners and are subject to the terms of the relevant provider.

7. Data Accuracy and the Possibility of Delayed/Misleading Prices

7.1. The Market Data displayed in the Application (stock prices, crypto rates, exchange rates, gold prices, etc.) is not produced by the Developer; it is obtained from THIRD-PARTY PROVIDERS such as Twelve Data, CoinGecko, and similar. Some of these providers are located abroad (for example, in the USA).

7.2. Market Data may be DELAYED; it is not guaranteed to be real-time (instantaneous). The data depends on the refresh frequency, technical infrastructure, and any interruptions of the source provider. Displayed prices may differ from actual market prices, exchange closing values, or the prices at which transactions might be executed at a brokerage.

7.3. The Developer gives NO WARRANTY as to the accuracy, currency, completeness, or continuity of the Market Data. The data may be incomplete, inaccurate, outdated, or misleading. The Developer is not liable for errors, delays, or interruptions originating from Third-Party Providers.

7.4. The net-worth total and other calculations depend both on the accuracy of the data entered MANUALLY by the User and on the Market Data received from Third-Party Providers. Incorrect or incomplete data entry leads to incorrect results; this responsibility rests with the User.

7.5. The User should base important financial decisions not on the data in the Application, but on the official and current data of the relevant exchange, brokerage, or authorized source. Under no circumstances may the Application be regarded as an official or primary data source.

8. User Obligations

8.1. The User agrees to use the Application solely in accordance with Applicable Law, morality, and this Agreement, for personal and non-commercial purposes.

8.2. The User undertakes not to engage in the following acts:

8.3. The User is personally responsible for the accuracy and currency of all data they enter into the Application. The Developer is not obliged to verify the data entered by the User.

8.4. Indemnification (Expanded): The User agrees to indemnify and hold the Developer harmless from any third-party claims, actions, administrative or judicial penalties, damages, and reasonable legal fees that the Developer incurs DUE TO THE USER'S OWN FAULT arising from: (a) the User's breach of this Agreement, Applicable Law, or the terms of third-party service/data providers (Twelve Data, CoinGecko, Apple, Anthropic); (b) the User's misuse of the Service; (c) Content the User shares or acts the User performs; or (d) the User's infringement of intellectual property rights. This obligation is limited to damages caused by the User's own fault or breach.

9. Account and Security

9.1. To benefit from the Service, the User may need to create an Account. The User is obliged to provide accurate, current, and complete information during registration.

9.2. Account security (including password, access credentials, and device security) is the User's responsibility. The User is obliged to keep their login credentials confidential and not to share them with third parties. The User is responsible for all activities carried out through the Account.

9.3. The User is obliged to notify the Developer immediately (halilhaninan@gmail.com) upon becoming aware of any unauthorized use of, or breach of security relating to, their Account.

9.4. The processing of personal data is carried out within the framework of the PDPL and the applicable Privacy Notice / Privacy Policy. Within the Application, certain Third-Party Providers (hosting, market data, artificial intelligence, etc.) may be located abroad; data transfers are made in compliance with the relevant provisions of the PDPL. The User may exercise their rights regarding personal data through the means specified in the Privacy Policy.

9.5. While the Developer takes reasonable technical and administrative security measures, the User acknowledges that the absolute security of data transmission over the internet cannot be guaranteed.

9.6. The User may request closure of their Account at any time. When the Account is closed, personal data other than that whose retention is mandated by Applicable Law will be deleted or anonymized within the framework of the relevant policies.

10. Intellectual Property

10.1. All intellectual and industrial property rights relating to the Application (including software code, design, interface, logo, trademark, text, graphics, database structure, and overall look and feel) belong exclusively to the Developer or its licensors and are protected by applicable intellectual property legislation (including the Law on Intellectual and Artistic Works No. 5846).

10.2. The Developer grants the User only a personal, non-exclusive, non-transferable, non-sublicensable, and revocable license to use the Application, valid for the term of this Agreement. This license covers only the use of the Application for its intended purpose.

10.3. Without the Developer's written permission, the User may not copy, reproduce, distribute, sell, rent, communicate to the public, or use the Application or any of its components for commercial purposes.

10.4. While the User retains their rights in the Content they share, by sharing such Content in the Application, the User grants the Developer a worldwide, royalty-free, transferable, and sublicensable license to use it, limited to the purposes of providing, operating, and promoting the Service. This license is necessary for the Content to be displayed within the Service.

10.5. The data, trademarks, and content belonging to Third-Party Providers are the property of their respective owners.

11. Social Features and Content Moderation

11.1. Varlık may, at the User's option, offer Social Features such as creating a public profile, following/being followed, the leaderboard, and content sharing. These features are OPTIONAL; the User may benefit from the Application's core tracking functions without using them.

11.2. When the User enables public profile or leaderboard features, they accept that the information they choose to share (username, profile image, shared leaderboard/performance information, etc.) may be visible to other users. The User should not share information they wish to keep sensitive or confidential in public areas.

11.3. A significant portion of the members appearing in the leaderboard and similar lists may be ILLUSTRATIVE (sample/mock) and may not be real user data. The leaderboard is for display purposes only and may not be construed as a genuine performance comparison, ranking, or indicator of success.

11.4. All responsibility for User-generated Content rests with the relevant User. The Developer is not obliged to pre-screen or verify User Content.

11.5. The Developer holds the position of a "hosting provider" within the framework of the Law on the Regulation of Electronic Commerce No. 6563 and related legislation. The Developer has the right to review and remove Content reported as unlawful, and to warn, suspend, or terminate the relevant Account; however, it has no obligation to proactively monitor all Content.

11.6. The User may report inappropriate Content or users to the Developer via the "report" function, may remove other users from interaction via the "block" function, and may contact the Developer at halilhaninan@gmail.com. The Developer evaluates reports within a reasonable time and reserves the right to remove users who produce unacceptable Content.

11.7. The Developer reserves the right to remove Content that violates this Agreement, Applicable Law, or community rules without prior notice, and to take necessary action regarding the relevant User.

12. Limitation and Disclaimer of Liability

12.1. The Service is provided "AS IS" and "AS AVAILABLE". To the maximum extent permitted by Applicable Law, the Developer gives no warranty, express or implied (including merchantability, fitness for a particular purpose, uninterrupted operation, error-free operation, or data accuracy), regarding the Service.

12.2. The Developer cannot be held liable for the following:

12.3. Under no circumstances shall the Developer be liable for indirect, incidental, special, punitive, or consequential damages (including loss of profit, loss of data, loss of business, or loss of reputation).

12.4. The Developer's total liability under this Agreement is in any event limited, to the maximum extent permitted by Applicable Law, to the total fees actually paid by the User for the Service in the twelve (12) months preceding the date the claim arose; for free use, this liability is zero.

12.5. The disclaimers and limitations in this Section apply only to damages arising from the Developer's SLIGHT (light) FAULT. Pursuant to Article 115 of the Turkish Code of Obligations No. 6098, any provision that purports in advance to exclude or limit the Developer's liability for damages arising from its INTENT or GROSS NEGLIGENCE is absolutely void and shall not apply. Mandatory provisions in favor of consumers under the Law on the Protection of Consumers No. 6502 and other Applicable Law are reserved; the consumer's statutory rights arising from Applicable Law may not be limited or eliminated by this Agreement.

13. Pricing and Subscription

13.1. Some of the Application's core features may be offered free of charge. Access to certain advanced features may require a recurring Subscription (e.g., monthly/annual) or a one-time purchase.

13.2. All purchases and Subscription transactions are carried out through the Apple App Store infrastructure, within the framework of the payment methods and conditions determined by Apple. Pricing, billing, and refund processes are subject to the Apple Media Services Terms. The Developer does not access or store the User's payment information.

13.3. Unless the User turns off auto-renewal at least 24 hours before the end of the subscription period, Subscriptions RENEW AUTOMATICALLY for the same term and at the prevailing price. The renewal fee is charged within the 24 hours before the end of the period. Auto-renewal is managed and may be turned off from the device's App Store / Apple ID account settings.

13.4. Current prices are displayed within the Application and on the App Store at the time of purchase. The Developer reserves the right to change prices for future periods; price changes are notified to the User before their effective date, and the User may cancel their Subscription if they wish.

13.5. Refund requests are, as a rule, made directly to Apple under Apple's refund policy. The consumer's statutory rights arising from Applicable Law are reserved (see Section 17).

14. Term and Termination of the Agreement

14.1. This Agreement enters into force when the User begins using the Application and remains valid for as long as the Account remains active.

14.2. The User may terminate the Agreement at any time by ceasing to use the Application, deleting their Account, or removing the Application from their device. If there is an active Subscription, cancellation of the Subscription must be carried out separately through the App Store pursuant to Section 13.

14.3. The Developer has the right to temporarily suspend or permanently terminate the Account without prior notice if the User acts in breach of this Agreement, Applicable Law, or community rules, misuses the Service, or poses a risk to other users or third parties.

14.4. If the Developer decides to discontinue the Service in whole or in part, it will endeavor to inform Users in advance where reasonably possible.

14.5. Upon termination of the Agreement, provisions that by their nature should remain in force (intellectual property, limitation of liability, indemnification, applicable law, etc.) retain their validity.

14.6. In the event of termination, the refund of prepaid and unused Subscription fees will be assessed within the framework of Apple's policies and the mandatory provisions of Applicable Law.

15. Force Majeure

15.1. Events beyond the parties' control that cannot be prevented by reasonable measures (natural disasters, earthquakes, floods, fires, epidemics, war, terrorism, civil unrest, strikes, cyberattacks, internet/infrastructure/electricity outages, interruptions originating from Third-Party Providers, decisions of official authorities, legislative changes, etc.) are deemed force majeure.

15.2. In events of force majeure, the affected party cannot be held liable for failing to perform, or for delaying performance of, its obligations. The parties' obligations are suspended during this period.

15.3. If the force majeure exceeds a reasonable period (for example, thirty days), the parties have the right to terminate the Agreement without compensation.

16. Governing Law and Competent Authority

16.1. This Agreement is governed by and construed in accordance with the laws of the Republic of Türkiye.

16.2. Where the User is a "consumer" within the meaning of the Law on the Protection of Consumers No. 6502, the Consumer Arbitration Committees and Consumer Courts at the User's own place of residence or at the place where the transaction was carried out, in accordance with the relevant monetary thresholds, have authority and jurisdiction to resolve disputes. This statutory right of the consumer may in no way be restricted or eliminated by this Agreement; any provision to the contrary is absolutely void as against the consumer.

16.3. For Users who are not consumers, the Courts and Enforcement Offices of İstanbul, at the Developer's place of residence, have jurisdiction to resolve disputes arising from this Agreement.

16.4. This Agreement is provided in Turkish and English; for users resident in Türkiye, in case of conflict between the texts, the Turkish version prevails.

17. Distance Contract and Right of Withdrawal (Digital Content Exception)

17.1. The purchase of paid features or a Subscription may constitute a distance contract within the framework of the Law on the Protection of Consumers No. 6502 and the Regulation on Distance Contracts.

17.2. As a rule, in distance contracts the consumer has the right to WITHDRAW from the contract within fourteen (14) days from the date the contract is concluded, without giving any reason and without paying any penalty.

17.3. IMPORTANT EXCEPTION: Pursuant to the Regulation on Distance Contracts, in contracts relating to intangible digital content that is PERFORMED INSTANTLY IN THE ELECTRONIC ENVIRONMENT (software, digital subscription features, etc.), the RIGHT OF WITHDRAWAL CANNOT BE EXERCISED where performance has begun with the consumer's approval and the consumer has accepted that they will lose the right of withdrawal. By purchasing paid digital content/a Subscription and approving that the service is to commence immediately, the User declares that they accept that the right of withdrawal will lapse in this respect.

17.4. In cases outside the above exception, and where the right of withdrawal may be exercised, the notice of withdrawal may be communicated to the Developer in writing (halilhaninan@gmail.com); refund processes are carried out within the framework of the Apple App Store infrastructure and Applicable Law.

17.5. No provision in this Section may be construed in a manner that eliminates or restricts the consumer's mandatory rights arising from Applicable Law.

18. Amendments to the Agreement

18.1. The Developer reserves the right to unilaterally update and amend this Agreement in line with changes to the scope of the Service, requirements of Applicable Law, or operational needs.

18.2. The updated Agreement enters into force from the moment it is published within the Application or through relevant channels. For material changes, the Developer will endeavor, where reasonably possible, to inform the User by in-app notification, email, or similar means, and will request renewed consent where necessary.

18.3. The User's continued use of the Application after a change takes effect means that they accept the updated Agreement. If the User does not accept the changes, they must stop using the Application and close their Account.

18.4. The current text of the Agreement is kept accessible from within the Application at all times, and the applicable "Last Updated" date and version information are stated at the beginning of the text.

19. Apple Licensed Application Terms

19.1. Use of this application is governed by Apple's Standard End User License Agreement (Apple Standard EULA) together with this Terms of Service, which constitutes additional terms supplementing the Apple Standard EULA. In case of conflict, the minimum terms of the Apple Standard EULA prevail on matters specific to the licensed application.

19.2. This Agreement is concluded between the User and the Developer only; Apple Inc. is not a party, and the Developer alone is responsible for the Application and its content.

19.3. Apple has no obligation whatsoever to furnish any maintenance or support services with respect to the Application.

19.4. In the event of any failure of the Application to conform to any applicable warranty, the User may notify Apple, and Apple will refund the purchase price, if any, paid for the Application. Beyond that, all other warranty claims, and any and all claims, losses, costs, and obligations — including product liability, failure to conform to legal/regulatory requirements, and claims arising under consumer protection or privacy legislation — are the sole responsibility of the Developer.

19.5. The Developer is solely responsible for the investigation, defense, settlement, and discharge of any claim that the Application, or the User's possession or use of the Application, infringes a third party's intellectual property rights.

19.6. Apple and its subsidiaries are third-party beneficiaries of this Agreement; upon the User's acceptance of the Agreement, Apple acquires the right to enforce this Agreement directly against the User as a third-party beneficiary.

20. Contact and Miscellaneous Provisions

20.1. Contact: The following contact channel may be used for any requests and notifications relating to this Agreement, the Service, personal data, or complaints:

20.2. Severability: If any provision of this Agreement is held to be invalid, unlawful, or unenforceable, this does not affect the validity of the remaining provisions; the invalid provision shall be deemed replaced by the valid provision closest to its purpose.

20.3. No Waiver: The Developer's failure to exercise, or delay in exercising, any right under the Agreement does not mean that it waives that right.

20.4. Assignment: The User may not transfer their rights and obligations arising from this Agreement to third parties without the Developer's written consent. The Developer may transfer the Service in whole or in part to a third party.

20.5. Evidential Agreement: The parties agree that, in disputes that may arise from this Agreement, the Developer's books, records, electronic and system records (including server logs) shall constitute conclusive evidence pursuant to the Code of Civil Procedure No. 6100. This provision applies subject to mandatory provisions in favor of the consumer.

20.6. Entirety: This Agreement, together with the Privacy Policy / PDPL Privacy Notice (if any), the Risk Disclosure, and community rules, constitutes the entire agreement between the parties.

20.7. Declaration of Acceptance: The User declares that they have read and understood this Agreement and agree to be bound by all of its provisions, and that this acceptance occurs upon beginning to use the Application.

Version: 1 — Effective: 03.06.2026

Questions: halilhaninan@gmail.com
Data Controller: Halilhan İnan (individual developer)