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Finfree User Agreement and
Terms of Individual User

1. PARTIES

 

The FinFree User Agreement and Terms of Individual User consisting of this agreement and annexes that are considered an integral part of the agreement and the Notice (hereinafter will be referred to as “Agreement”) have been concluded by and between “LAPLACE ANALYTICS FINANSAL TEKNOLOJILER ANONIM SIRKETI” (hereinafter will be referred to as “FinFree” or “Company”) and the User, who has registered the FinFree application (hereinafter will be referred to as “Application”) or sent an e-mail over www.finfree.co (hereinafter will be referred to as “Site”), downloaded and registered the Application of his/her free will and at his/her own request, or clicked the relevant directions over the Site, accessed the and registered the Application of his/her free will and at his/her own request.

 

This User Agreement has been signed between you (hereinafter will be referred to as “you” or “your”) and FinFree. By accessing, downloading, using, or clicking ‘’I Accept’’ to accept any FinFree Service and Product provided by FinFree (as defined below), you agree to have read, understood, and approved these Terms of Use (hereinafter will be referred to as “these Terms” or “Terms”) and our Privacy Policy available at https://www.finfree.co/privacy-policy. Furthermore, you may be subject to certain additional terms and conditions when utilizing the Services or Products. This agreement will enter into force on the date you have approved/accepted/signed these Terms or on the date, we have first offered the Services and Products to you, if earlier. If you have any questions concerning these Terms, you can contact us as soon as possible and demand an explanation.

 

2. IMPORTANT DISCLOSURE

 

BY USING FINFREE SERVICES, YOU ARE DEEMED TO HAVE DECLARED THAT:

 

i.     YOU ARE AWARE OF THE RISKS RELATED TO THE SHARE TRANSACTIONS YOU WANT TO CONDUCT, AND THE SERVICES RENDERED BY FINFREE DO NOT CONSTITUTE ANY ADVICE AND GUIDANCE,

ii.    YOU ASSUME ALL RISKS WHILE USING THE PRODUCTS AND SERVICES OR CONDUCTING YOUR SHARE TRANSACTIONS,

iii.   FINFREE CAN NOT BE HELD LIABLE FOR ANY RISK RELATED TO YOUR TRANSACTIONS OR FOR ANY NEGATIVE CONSEQUENCE OF YOUR TRANSACTIONS,

iv.   BY GETTING FINFREE PRODUCTS OR SERVICES, YOU AIM TO MAKE AN INVESTMENT AND UTILIZE FINFREE SERVICES BY HAVING KNOWLEDGE ABOUT PERFORMING INVESTMENT TRANSACTIONS THAT ARE NOT QUALIFIED AS  AN END-CONSUMPTION, YOU WILL BE IN THE CAPACITY OF AN INVESTOR UNDER THE USER AGREEMENT TO WHICH YOU ARE A PARTY, AND YOU CAN NOT BE CONSIDERED AS A CONSUMER UNDER THE LAW NO. 6502 ON THE PROTECTION OF CONSUMERS,

v.   THIS USER AGREEMENT BINDS YOU AND YOU HAVE EXAMINED AND BEEN FULLY INFORMED ABOUT IT AND THUS, APPROVE AND ACCEPT IT OF YOUR OWN FREE WILL.  

 

3. DEFINITIONS

 

User: Natural person, who utilizes the services offered in the Application and the Site by reading, understanding, and approving the agreement.

 

Company: Electronic trading company with the commercial title LAPLACE ANALYTICS FINANSAL TEKNOLOJILER ANONIM SIRKETI having its registered address at Suadiye Mahallesi Bağdat Cad. Mehmet Dural Apt. No: 404/5 Kadıköy/Istanbul and exclusively authorized to use the Site and Application in its electronic trading activities,

 

Form: Registration document of the Application that the users fill out by providing his/her information to use the application,

 

Application: Mobile application that enables the User to buy and sell shares and create a portfolio by entering his/her personal information and registering it, provides information to the User about finance, enables him/her to follow up on his/her investments, the stock market and related financial news conveniently,

 

Site: Site that consists of the domain name www.finfree.co and sub-domains linked to this domain, redirects the User to the Application along with the entry of his/her e-mail address, lets him/her listen to podcasts and write and read blog posts about fintech as a service and gives information about FinFree,

 

Competition: System in which the Users are ranked according to the investment transactions made within the application on a weekly, monthly, and quarterly basis and the Company rewards the Users accordingly,

 

FinFree Academy: System that gives brief information about financial issues to users over the application,

 

Blog: System in which users register by entering their e-mail addresses and creating a password to be informed about financial issues and news, to share, read and write new developments, evaluations, and various information,

 

Podcast: Audio broadcasts on financial issues based on objective financial data submitted to provide information to users and for news purposes,

 

Cookies: Informative e-mails that provide weekly news and analyses about the world of finance by obtaining the name, surname, identity information, and e-mail if the user has accepted the Cookie Policy,

 

Premium Membership: Application services to which the User can access extra over the Application and Site for a certain fee,

 

User Approval: Approval that enables the company to process the personal data of the User in line with the purpose and scope determined by him/her, to use them limited to the services rendered, and to send commercial electronic mail to him/her and whose content can be accessed over the Application and Site and which is granted by the User himself/herself,

 

Chat: System that allows users to talk over the Application and get support from the Company and where online correspondence can be made and these correspondences are recorded by the company.

 

Similar Stocks: A tab of the Application which displays similar shares in line with the financial data of the stocks purchased by the User over the Application.

 

Quantitative Stock Analysis: Scoring the stocks objectively over the company’s algorithm.

 

Filtering: Application options that enable the user to display and list the shares in line with his/her search requests.

 

Purchase: Payment transaction that you will make against your request of service for app stores and getting in-app services by accepting the membership fees for the areas, to which you will gain access for a fee within the FinFree application.

 

4. SUBJECT OF THE AGREEMENT

 

This Agreement stipulates the liabilities of the User, who gains the right to utilize the services offered by the Company by being directed to the Application through entering his/her e-mail on the Application and the Site and individually registering the Site for blog posts, and of the Company to each other. 

 

5. RIGHTS AND OBLIGATIONS OF THE USER

 

5.1   The User registers the Application by granting approval to this Agreement and creating a user profile over an account panel to his/her name. To utilize the services, the User shall click the relevant directions to download the App over the Site or enter his/her e-mail address on the ‘’Download’’ page of the Site, download the App, and register the Site by approving the Company agreements.

 

5.2   The User declares and accepts that all the information s/he has given, particularly the contact information, is correct and that s/he is over 18 years old and of full age and eligible to take legal action.

 

5.3   The responsibility for all damages that may arise from any incorrect, incomplete, or misleading personal information given by the User belongs to the User. The Company will not be held liable for damages that may arise for these reasons. The User knows that the relevant data of membership and usage can be anonymized and sold to the relevant institutions and organizations by the Company, and s/he accepts, declares, and undertakes not to make any claims against the Company under any name, and to irrevocably release the Company in this regard.

 

5.4   The User can only have one membership account. The Company has the right to unilaterally terminate the Agreement and to cancel, freeze or suspend the User’s account without any notice if it detects that the User has provided incorrect and/or false information. Furthermore, the Company has the right not to open an account for this person thereafter. All legal and penal liability that has arisen or will arise in the cases listed under this clause belongs to the User.

 

5.5   Any changes in the user’s identity information will be promptly notified to the Company. The Company cannot be held responsible and any claim cannot be made against it for the failure of the User to notify the Company of these changes. Due to failure to notify these changes, the Company has the right to suspend transactions, close the account temporarily or indefinitely, and take all measures. Therefore, no liability can be imposed on the Company.

 

5.6   The User declares and accepts to use the panel and conduct transactions on the Application and the Site personally and not grant a right to access and use it by any third party and that information such as password and passphrase is exclusive to the user, and s/he is obliged to protect them. If any User action contrary to this clause is detected, the Company has the right to unilaterally cancel, freeze or suspend the User’s account without any prior notification.

 

5.7   The User accepts and declares that s/he is entitled to use the name, image, and all other information on the Application and the Site and that such uses do not violate the rights of third parties.

 

5.8   The User accepts in advance not to use and let other people use the platform contrary to all legislation and general rules of law in force in the Republic of Turkey, particularly Law No. 5549 on the Prevention of Laundering Proceeds of Crime and Law No. 6415 on the Prevention of the Financing of Terrorism and sub-regulations as well as the Company’s policy, and to be personally responsible for all legal and penal liabilities that may arise from using the Application and Site or from letting other people use his/her account contrary to the law and legislation. The Company cannot be held responsible for any disposition of the User’s assets by the competent authorities due to his/her use of the account in violation of Turkish Laws.

 

5.9   The User declares, accepts, and undertakes that if s/he has not chosen Premium Membership, s/he will not be able to access Premium Membership services, the relevant services are available for an additional fee and differ from normal services and if s/he stops renewing his/her membership by making the payment of relevant fee, s/he will not be able to utilize the relevant Premium Membership services and s/he cannot hold the Company responsible in this regard. The services offered by the Company for the Premium Membership will be announced on the ‘’Premium’’ page of the Application and the Site, and the relevant services may be changed unilaterally by the Company from time to time. The User hereby accepts and declares that the Premium membership is exclusive to the user(s), who has paid the Premium membership fee, and s/he will not share the information obtained through this service and content by paying the membership fee with 3rd parties/institutions and not reproduce and release them, and if FinFree detects any contrary act, it will suspend the user’s membership without any notice and in this case, s/he will pay a penal clause at the amount of 10 times of the paid Premium Membership Fee due to his/her breach of this clause immediately upon the first request, along with any other negative and positive damages suffered by FinFree, and indemnify FinFree. 

 

5.10   The User accepts and declares to act in compliance with the law, and national and international regulations related to the profile account that s/he has opened with the Company, and in all kinds of investment transactions that s/he has performed, and not directly or indirectly engage in the areas designated as risky activities by the Company’s Compliance Policy on the Prevention of Laundering of Proceeds of Crime and Financing of Terrorism. 

 

By registering the Company platform and/or opening an account, the User declares and warrants that s/he is not listed in the commercial or economic sanctions list such as the OFAC (US Office of Foreign Assets Control) and UN Security Council Sanctions list, etc. On the other hand, the Company reserves the right to choose the markets and countries where it will operate and it may restrict its services or render service in certain countries at its sole discretion.

 

5.11   The User is personally responsible for providing the security of his/her membership information, e-mail address, password, account, and other information. The User accepts, declares, and undertakes not to make any claims against the Company for damages arising from any use of this information by unauthorized persons or any unauthorized access to this information by third parties, and to irrevocably release the Company in this regard. The Company cannot be held responsible for any cyber-attack or theft that may occur in the User’s accounts or the Company’s systems due to the systems of the internet service provider company or for any reason. The User accepts, declares, and undertakes not to make any claims under any name against the Company for damages arising from these matters, and to irrevocably release the Company in this regard.

 

5.12   The User accepts, declares, and undertakes that the financial ratios and company financials determined according to the Quantitative Stock Analysis on every page listing the shares are for financial information purposes only, the Company does not have any responsibility since these financial data and ratios may be incorrect or incomplete due to their source, they do not constitute any advice and not guarantee any gains, the gains and losses that may be obtained in all transactions and investments entirely depend on the User’s own decisions, and therefore, the Company and its relevant officials, proxies, managers, business associates, employees and/or representatives cannot be held responsible for investments and/or losses and/or damages, and the risks in the relevant transactions are assumed by him/her.

 

5.13   The User knows that this Site or Application is not a licensed business to provide real investment advice. Any information on the Site or any part of the Application does not constitute investment advice and cannot be used by the User as a basis for making an investment decision. The User is severally responsible for the results of the investment decisions that s/he will take by utilizing the information contained in any part of this site and/or application. To the full extent permitted by applicable legislation, FinFree specifically disclaims any implied warranties for title, merchantability, and fitness for a particular purpose and/or non-infringement. Finfree shall not be held liable for any loss, damage, or claim arising from the use of the services by the User.

 

5.14   The User accepts, declares, and undertakes that s/he is obliged to register with an e-mail address to make comments and release articles on the blog, and the relevant e-mail address belongs to him/her. Furthermore, the User accepts, declares, and undertakes to notify any citation in his/her articles s/he will write on the Blog, s/he has not made any plagiarism in the relevant articles in any way, s/he will be held responsible for these articles in case any legal responsibility arises from the relevant articles, and in this direction, s/he has irrevocably released the Company and the company’s members of the board, managers, and employees.

 

5.15   The User accepts and undertakes to give information such as his/her name, surname, identity information, and e-mail as contact information to access the Cookies and that the relevant information belongs to him/her. The User declares, accepts, and undertakes that the relevant e-mails are for informational purposes only, do not constitute any investment advice or transaction, and therefore, s/he will not hold the Company responsible for the results of the relevant transaction if s/he performs any transaction based on them.

 

5.16   The Company has the right to take all kinds of measures, including closing the User’s account to ensure that the User utilizes the Application and the Site within the framework of this Agreement and the legislation, and to prevent any use contrary to these.

 

5.17   The User accepts in advance not to use the Application and the Site for unlawful and illegal purposes and be responsible for all legal and penal liabilities that may arise in the case of any use for unlawful and illegal purposes. The User is severally responsible for all claims and demands that may arise from his/her breach of this Agreement and the legislation and s/he is obliged to immediately indemnify any damages suffered by the Company due to such claims and demands.

 

5.18   After registering the Application and the Site, the User cannot transfer, sell and donate his/her account and rights and make them available to third parties regardless of the name under which. In case any User act contrary to this clause is detected, the Company has the right to cancel, stop or suspend the User’s account without any prior notice. The User accepts, declares, and undertakes to irrevocably release the Company from all damages that may arise due to the exercise of these rights by the Company. The User is responsible for all damages and all penal sanctions that may arise within the scope of this clause.

 

5.19   By accepting this Agreement and using the Application, the User irrevocably accepts, declares, and undertakes that s/he has been informed and warned by the Company concerning that the share and market values may vary, they are not guaranteed by official and non-official institutions, and his/her use may be subject to different regulations due to legislative changes; s/he conducts the transactions on the Application and the Site by understanding this information and warning and declaring and accepting that all kinds of legal, financial and criminal responsibility belong to him/her and in case of a change in the legislation, s/he will act in compliance with the new regulations. In this regard, the User is deemed to have read and accepted all the explanations made by the official authorities concerning the shares and to be made thereafter.

 

5.20   The User declares, accepts, and undertakes that the information provided by the Company under FinFree Academy and the articles on the Blog are only for financial information purposes, the podcasts listened to on the Site do not constitute any advice, and the analyses and news in the Cookies are for informational purposes only, no priority will be given in the competitions, they do not guarantee any gains, the gains and losses in the investment entirely depend on the User’s own decisions, and therefore s/he will not hold the Company and any of its employees responsible for investments and/or losses and/or damages.

 

5.21   The User declares, accepts, and undertakes that the competition rules can only be changed by the Company and that the responsibility to follow up these changes belongs to him/her since the relevant changes are released on the Site and Application. The User declares, accepts, and undertakes not to hold the Company responsible for the problems that may arise due to his/her creating a new list. The User declares, accepts, and undertakes that the rewards to be awarded in the competition may also change.

 

5.22   The user declares and accepts that the Company is not responsible for the correspondence made in the Chat section and that the support offered by the Company in the Chat section does not constitute any real investment advice. The user is responsible for his own correspondences in the Chat section. The Company has the right to cancel, stop or suspend the User’s account without any prior notice if it determines that the User has committed an inappropriate, offensive, or insulting statement in these correspondences.

 

5.23   The User can stop using the Application and the Site at any time by closing his/her account.

 

5.24   All services offered by the Company on the Application and the Site within the framework of these Terms may be terminated without any reason and without the obligation to give any prior termination notice.

 

5.25   The User is responsible for all tax liabilities that will or may arise due to the User’s use of the Application and the Site. No invoice will be issued against the purchase of a share by the User.

 

5.26   The responsibility for all kinds of damages and losses that have arisen or will arise from the use of the Application and the Site by the User belongs to the User. If the Company fulfills its obligations under this Agreement, the Company and its members of the board, managers, employees, and third-party service providers cannot be held liable for any legal or criminal sanction. The User accepts, declares, and undertakes to irrevocably release the Company and the aforesaid persons in these matters.

 

5.27   It may not always be technically possible to monitor how the shares purchased over the application are used, where and for what purpose they are transferred, and whether they are used in a crime or not. The Company cannot be held responsible for the sufferings, losses, or negative or positive damages of the User or third parties that have arisen or will arise from the abuse of the shares purchased. In this regard, if the Company has a legal responsibility in any way, the User who has given rise to this damage is obliged to compensate all the losses. The User agrees and undertakes to pay 0.1% daily default interest for each day that the said loss is not compensated by him/her.

 

5.28   The User accepts, declares, and undertakes that the Company communicates with him/her via electronic communication tools and provides information such as campaigns and promotions.

 

5.29   The User knows and accepts that the financial analysis reports reviewed by him/her during the use of the application and on social media, the analyses, reports, messages, and opinions shared in digital channels by the analysts within the scope of the application and transmitted to him/her over communication channels and/or followed by him/her are not within the scope of investment consultancy and they do not constitute investment advice, the releases will not bear any promise of interest and commitment of profit and the necessary legal warnings regarding these are included in them, s/he cannot engage in unauthorized portfolio management activities in communication with users, followers, analysts or potential users, the owners of the channels and analysts are fully and individually responsible from the released content and the Application is used only as a channel for review.

 

5.30   The User accepts, declares, and undertakes not to infringe the reports and analyzes that s/he has released, within the scope of plagiarism and intellectual property rights, not to share them with 3rd parties, and not to attack or insult the company or 3rd parties via the Application and digital channels and not to use them in any channel by combining the releases with a promotion, advertisement or sponsorship broadcast.

 

6. RIGHTS AND OBLIGATIONS OF THE COMPANY

 

6.1   The Company undertakes to provide the security of the User, who registers the Application and the Site, during the transactions conducted on the Application and the Site to the maximum extent. In this regard, the Company will be able to demand identity, address and bank information, and related documents while creating a membership for the security of the User as well as making an SMS verification. The Company cannot be held responsible for any damages that may arise due to the failure of the User to share or late or misstate this information and documents requested by the Company. The company will be able to sell the relevant information to third-party institutions and organizations by anonymizing it. As a prudent merchant, the Company will take all necessary care to protect the User’s identity and bank information against a possible cyber-attack. The provisions of clause 4.11 of this Agreement shall apply in case the account is seized by unauthorized persons and the Company services are used despite the fulfilment of this commitment by the Company.

 

6.2   The identity, address, and bank information requested by the company are requested for the system to comply with the laws and regulations of the Republic of Turkey and they will be shared with the competent authorities if requested by competent authorities. The Company undertakes not to share the identity, address, and bank information of the User with any natural person and/or legal entity, except for these cases. However, the Company may use statistical anonymous information apart from the User’s identity, address, and bank information and collected as a result of using the Site and the Application, by keeping the identity, address, and bank information of the User confidential, and may share it with third parties in line with the approval that the user has granted within the scope of the express consent form. Under its Policy on Prevention of Laundering Proceeds of Crime and Financing of Terrorism, the Company can perform identification procedures again in the case of User’s transactions exceeding a certain amount. However, the Company may apply tightened measures for Users that it deems risky within the scope of risk-based assessment, and request additional information and documents from such Users. The User accepts that the business relationship can be terminated if s/he does not submit the requested information and documents.

 

6.3   The Company will not share any contact data such as telephone and/or e-mail obtained from the User with any third party, except for the cases specified in 5.1 and 5.2, and not sell this information for any purpose. The Company cannot be held responsible if the User shares this information with a third party on his/her initiative.

 

6.4   The Company will be able to use the order and portfolio data for its benefit and the benefit of the User, by making the information about the transactions conducted by the User and the shares followed in the section Similar Stocks independent from the User’s name and surname utilizing encryption, starring, and other methods.

 

6.5   The Company will announce the service to be provided to Users with Premium Membership on the ‘’Premium’’ page on the Application and Site. The Company will not give access to Premium Membership services unless the User chooses Premium Membership. The Company will pay attention that the services offered to the Users with Premium Membership differ from normal services. The Company has the right to unilaterally terminate the relevant Premium Memberships of Users, who stop paying the relevant fee and renewing his/her membership. The services offered by the Company to Premium Memberships will be announced on the ‘’Premium’’ page of the Application and the Site, and the related services may be changed unilaterally by the Company in due course.

 

6.6   The User accepts that the Company is authorized to take all necessary measures for business relations and transactions that it will deem risky under both national and international legislations and rules concerning the fight against ‘’Laundering of Proceeds of Crime’’, ‘’Financing of Terrorism’’ and ‘’Corruption’’, and it may carry out the necessary development/adaptation work by following the recommendations, principles, standards, and guidelines of the national legislation and international organizations regarding the issues within its scope of risk, and in this regard, it will not be a party to any business and/or transaction that it deems risky and not conduct the transactions related to any stock purchase deemed to be risky for this reason, including but not limited to those listed here.

 

6.7   The Company, its relevant officials, proxies, managers, business associates, employees, and/or representatives cannot be held responsible under the provisions specified in clauses 4.12 and 4.13 and it is not obliged to indemnify the losses and damages that may arise due to the misinterpretation of the financial ratios and company financials by the User according to the Financial Stock Analysis on the relevant stock pages.

 

6.8   If the Company sends money to the User in consequence of and/or apart from the Competition in such a way that gives rise to his/her unjust enrichment, this is immediately notified to the User (e-mail, call, SMS, etc.). If it is not returned by the User within 1 business day despite this notice, the User’s account may be closed, suspended, or blocked to access by the Company indefinitely without any further warning or notification. In this case, the User’s account may be reduced to a deficit account by the Company at the amount of the transfer made by mistake and legal actions may be taken against him/her. The User accepts and undertakes in advance that s/he has irrevocably released the Company in this regard. The Company reserves the right to indemnify its direct or indirect damages incurred due to this transaction.

 

6.9   The Company reserves the right to cancel, stop or suspend all transactions conducted by the Users using his/her memberships, the Application, and the Site, and to report suspicious transactions to the competent authorities.

 

6.10   The Company may cancel the transactions conducted by the Users to rectify the system due to technical errors and ensure its correct operation. During cancellation, the User may suspend his/her accounts. The Company cannot be held responsible for any damages arising from such transactions and no rights can be claimed against the Company.

 

6.11   The Company cannot be held responsible for technical failures that may arise in the Application and the Site. The Company cannot be held responsible for any direct or indirect damages that may arise due to short-term or long-term technical failures.

 

6.12   The Company has the right to make all kinds of changes in the stock investments offered over the Application and accordingly the rules of the Competition. The Company will not be responsible for any damages arising from these changes. However, the Company undertakes to notify the User of the changes in the Agreement by announcing them on the User Agreement page, which is available at the Site and Application and an integral part of this Agreement, and/or sending a notification e-mail or SMS to the User. The notification obligation of the Company ends with the use of one of the notification methods listed in this clause. The Company cannot be held responsible for the losses suffered by the User due to his/her failure to follow the notification of the change, and the User accepts, declares, and undertakes that s/he irrevocably releases the Company for any damages incurred in this way.

 

6.13   The Company is an independent venture from all other enterprises, banks, and financial institutions that conduct stock buying and selling and investment transactions, and it is not the representative or successor of any company, website, or institution. It does not conduct any collaborative work with any natural person or legal entity. Therefore, the Company cannot be held responsible for the unjust sufferings of the Users on other platforms, even if they refer to the Company, Site, Application, and values ​​owned by the Company.

 

6.14   The Company may communicate with the User through electronic or traditional methods, including commercial ones for itself, and/or on behalf of 3rd party companies for which consent of the User has been obtained digitally.

 

6.15   The Company has taken all necessary quality measures following industry standards for the system, software, and other technical conditions of the Application and the Site. However, the Company cannot be held responsible for any consequences arising from the deliberate exploitation of or a cyber-attack on the Application and the Site by any User or third party.

 

6.16   The Company shows maximum effort to ensure that the Application and the Site operate uninterruptedly or free from any errors. However, the Company does not guarantee that the services rendered over the Application and the Site will meet the subjective expectations of the User, and it cannot be held responsible for such matters.

 

6.17   The Company may provide links to third-party websites or make reference to third-party products or services on the Application and Site. The services or products linked or referenced in this way are not examined by the Company, and the Company does not assume responsibility for these services or products. Utilizing third-party services or products is entirely the User’s own preference, and no claim or demand can be directed to the Company in this regard. The Company has no responsibility for the privacy practices and policies of other sites accessed through this link, or any content they contain.

 

6.18   FinFree has the capacity of hosting provider under Law No. 5651 on Regulation of Internet Broadcasts and Prevention of Crimes Committed through Such Broadcasts; it is obliged to collect some data such as the name and Internet Protocol (IP) address of the Internet service provider used by the User to access the Application and the Site as well as the date and time the Application and the Site were accessed.

 

6.19   The Company will provide support services only through the Application, the Site, and the e-mail address help@finfree.co. Apart from this address, support services are not provided through social media devices such as Facebook, Twitter, Instagram, and forums. In the support services to be rendered over this address, the Users are not asked for a password, and no address is given to them for sending money. No support service is provided to Users by any method other than this e-mail address. By accepting the provisions of this clause, the user accepts to get support from the Company. The Company is not responsible for any damages arising from this reason. The Company cannot be held responsible for the unjust sufferings of the members of the Site due to the ‘’pirate’’ sites created using the company name or making such an impression. The user accepts, declares, and undertakes to irrevocably release the Company from these matters.

 

6.20   The Company does not have the capacity of an intermediary firm under the Capital Markets legislation, does not operate as an intermediary firm, and does not carry out any license-based work in the capital markets. In this context, the fact that the Company works with other intermediary firms will not mean that the Company carries on such a business.

 

7. INTELLECTUAL PROPERTY

 

The design of the Application and the Site, and all content including all images published in the Application and on the Site, are under the copyright protection of the Company and cannot be copied, reproduced, distributed in any format, released, or used otherwise without the written consent of the Company. Legal action will be taken against Users who have committed contrary actions.

 

8. THIRD-PARTY LINKS

 

8.1   The Application and the Site may contain links to other sites (‘’External Sites’’) owned or operated by third parties.

 

8.2   FinFree has no control over these External Sites, even if that third party has a business relationship with FinFree. All these sites are entirely independent of FinFree and they have their own policies, data collection practices, and terms of use.

 

8.3   FinFree cannot be held responsible for such independent policies or practices and is not responsible for the privacy practices, contents, and/or terms of use of these websites. These linked sites are for your convenience only and you assume all responsibility related to accessing them.

 

8.4   Any trademark, trade name, service mark, design, logo, symbol, or any other copyrighted material displayed on or accessed through such External Sites does not mean that they are sponsored, certified by, affiliated to, or associated with FinFree or that FinFree is legally authorized to use them.

 

8.5   If you want to share information about FinFree services on any social media platform, including the ones linked by FinFree on the Site, you can share this information through your profile on that social networking platform without leaving the Site. Some social networking platforms allow the Users to send and receive data to that social networking platform using middleware or other technologies. Although it seems that the data are collected by FinFree, they are actually collected directly by that social networking platform or a third service provider. Your use of a social networking platform to share any information is subject to terms of use and restrictions of the relevant social networking platform, and you are obliged to comply with them.

 

9. CHARGING 

 

9.1   The Company will announce the fees related to services utilized by Users on the Application in the ‘’Commissions’’ section of the Application and the Site, and the fees for Users with a Premium Membership on the ‘’Premium’’ page. The Company has the right to collect the fees related to the services of the Site, which is an integral part of this Agreement, from the Users at the announced rates.

 

9.2   The Company has the right to make changes to the commission rates, service fees, and Premium Membership fee it will collect from Users at any time. The changes made will be announced by the Company on the Application’s ‘’Commissions’’ and ‘’Premium’’ pages of the Site. The Company has no obligation to notify the User through any other communication channel other than announcing the changes in commission rates, service fees, and Premium Membership fees on the ‘’Commissions’’ and ‘’Premium’’ pages.

 

9.3   The changes in commission rates, service fees, and Premium Membership fees announced in the Application and on the Site become valid from the moment they are announced. Following the announcement of the commission rates, service fees, and Premium Membership fees in the Application and on the Site, the User’s first transaction on the Application and the Site means that the changes are also approved by the User.

 

9.4   The awards, which are won from the Competition and sent to the User by the Company, can be taken back by the Company by assessing the relevant situation. The User cannot hold the Company responsible for any action that s/he thinks s/he has made faulty, and irrevocably releases the Company.

 

9.5   The User declares and undertakes that s/he accepts the provisions of this Agreement under the title of ‘CHARGING’ in advance by registering the Application or the Site.

 

10. IN-APP PURCHASE

 

THE USER WILL MAKE PURCHASES FROM APP STORES WITH AN IN-APP PURCHASE OPTION AND THE SUBSCRIPTION FEES ARE SUBMITTED FOR THE USER’S REVIEW ON THE APPLICATION PAGES. WHEN THE USER ACCEPTS AND APPROVES THE SUBSCRIPTION FEE, THEY CAN UTILIZE THE SERVICES AND PRODUCTS. THE USER ACKNOWLEDGES AND REPRESENTS THAT THE SUBSCRIPTION WILL BE REGULARLY RENEWED EVERY MONTH UNTIL IT IS CANCELED.

 

IT MAY BE REQUIRED TO ACCEPT THE USER AGREEMENT OF THE RELEVANT APP STORE DURING THE PURCHASE PROCESS. THE COMPANY IS NOT RESPONSIBLE FOR SUCH APP STORE AGREEMENTS OR PROCEDURES, AND THE USER MUST DIRECTLY CONTACT WITH THE RELEVANT APP STORE IN CASE OF ANY DISPUTES.

 

The User can conduct the subscription cancellation procedures over the app store with the ID and password used for the application stores. The Company has no obligation at this stage and the User shall contact the app store directly. Within the framework of the cancellation process, the Company is not the addressee of the claims and complaints for the fee collection, the cancellation of the subscription, the charging-based wishes and complaints (fee collection, subscription cancellation, purchase complaints, fraud, etc.) that may be made related to the subscription, and these claims are directly managed by the relevant app store. Even if the user has conducted the subscription procedures over his/her Appstore and Googleplay accounts, they can use the relevant subscription with the mobile phone number they have entered while purchasing the application. The subscription/cancellation details can be managed by Users from the application store’s settings.

 

The User accepts and declares that s/he is not entitled to withdraw from the contract when s/he has accepted the charges in this Agreement and purchased the Application, and s/he can cancel the subscription and withdraw the use of the paid application in the following periods and the refund can be made based on the principle of the per diem deduction for the period s/he has withdrawn.

 

11.OUR LEGAL NOTICE ON OUR COMMITMENTS

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FINFREE SERVICES AND PRODUCTS OR OTHER SERVICES PROVIDED ON BEHALF OF OR BY FINFREE ARE PROVIDED ‘’AS IS’’ AND ‘’AS THEY APPLY’’. FINFREE DOES NOT MAKE A COMMITMENT THAT FINFREE SITES AND SERVICES ARE ACCURATE, COMPLETE, RELIABLE, CONTINUOUS, FAULTLESS, AND FREE OF VIRUSES OR OTHER HARMFUL ASPECTS. FINFREE ACKNOWLEDGES AND REPRESENTS THAT IT IS NOT RESPONSIBLE FOR ANY DEFECTS OR DAMAGES ARISING FROM INCLUDING BUT NOT LIMITED TO: (A) ANY WRONG OR INCORRECT INFORMATION IN THE DATA ON SHARE PRICES (B) ANY FAULT OR DELAY IN TRANSMISSION OF THIS DATA (C) ANY INTERRUPTION IN ALL KINDS OF DATA, (D) ANY REGULAR AND PROGRAMMED MAINTENANCE BY FINFREE AND ANY SERVICE INTERRUPTION AND DATA-RESULT CHANGE ARISING FROM THIS MAINTENANCE, (E) ANY DAMAGE ARISING FROM ACTS OF OTHER USERS AND NEGLECT OR BREACH OF THESE CONDITIONS, (F) UNLAWFUL ACTS OF THIRD PARTIES NOT AUTHORIZED BY FINFREE; AND (G) OTHER EXEMPTIONS SPECIFIED IN THE LEGAL WARNINGS AND RULES PRACTICES GIVEN BY FINFREE.

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12. EXEMPTION FROM DAMAGES AND LIMITATION OF LIABILITY

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FINFREE DISCLAIMS ANY RESPONSIBILITY FOR ANY INCIDENTAL, INDIRECT, SPECIAL, CONSEQUENTIAL, OR SIMILAR DAMAGES OR LIABILITY ARISING FROM FINFREE SERVICES OFFERED BY OR ON BEHALF OF FINFREE OR ITS BUSINESS ASSOCIATES, PERFORMANCE OR NON-PERFORMANCE OF FINFREE SERVICES OR OTHER PRODUCTS OR SERVICES WHETHER OR NOT THEY ARE WITHIN THE SCOPE OF AGREEMENT, LAW OR LIMITED LIABILITY EXCEPT FOR THE CASES WHERE IT HAS BEEN DETERMINED BY A DEFINITE JUDGMENT THAT THEY ARISE FROM ITS GROSS NEGLIGENCE, DELUSION, WILFUL MISCONDUCT OR WILFUL BREACH OF THE LAW.  

 

IN ANY CASE NOT SPECIFIED ABOVE, THE LIABILITY OF FINFREE AND ITS PARTNERS, SHAREHOLDERS, MEMBERS, MANAGERS, EMPLOYEES, WORKERS, ATTORNEYS, AGENTS, REPRESENTATIVES, SUPPLIERS, OR CONTRACTORS ARISING FROM FINFREE SERVICES OFFERED BY FINFREE OR ITS BUSINESS ASSOCIATES ACTING ON ITS BEHALF, PERFORMANCE OR NON-PERFORMANCE OF FINFREE SERVICES OR ANY OTHER SERVICE, PRODUCT OR ARTICLE WHETHER OR NOT THEY ARE WITHIN THE SCOPE OF AGREEMENT, LAW OR LIMITED LIABILITY CAN NOT EXCEED THE FEES THAT HAVE BEEN PAID TO FINFREE BY YOU IN THE TWELVE MONTHS BEFORE THE CLAIM OR LIABILITY UNDER THESE TERMS.  

 

13. COMPENSATION

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You accept to indemnify the Company against any claim, act, action, investigation, demand, lawsuit, duties, expenses, and damages (including the attorney's fees and fines imposed by any regulatory authority) arising from or related to (i)  your use of FinFree Services or your actions related to these, (ii) your breach of these Terms and Conditions or our enforcement of these Terms and Conditions, or (iii) any breach of applicable law, regulation or right by any third party during your use of the FinFree Services and to release FinFree partners, contractors, and his/her directors, employees, workers, and agents from these.

 

14. TERMINATION OF THE AGREEMENT

 

Within the framework of this Agreement, the Company may terminate all services rendered by the Company in the Application and on the Site without any reason and without the obligation to give any prior termination notice. The User cannot claim any rights in the case the Agreement is terminated in this way.

 

i. Suspension of FinFree Accounts

You accept that FinFree has the right to immediately suspend and freeze your FinFree Account (any accounts held by related entities or affiliates) and to suspend your access to FinFree for any reason if FinFree is suspected of violation of these Terms and Conditions, our Privacy Policy or applicable laws and regulations partially or wholly. You agree that FinFree will not be responsible for any permanent or temporary change of your FinFree Account or the suspension or termination of your access to the entire or any part of the FinFree Services. FinFree reserves the right to store and use transaction data or other information related to these accounts. The aforesaid account controls may also apply in the following cases:

  • If FinFree Account is subject to a government investigation or a criminal investigation or a pending lawsuit is filed against it;

  • If unusual activities are detected in the FinFree Account;

  • If unauthorized access to FinFree Account is detected;

  • If we are obliged to do this with a summons or order from a regulatory/government authority.

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ii. Closing FinFree Accounts

If you breach the terms of this Agreement wholly or partially, FinFree has the right to terminate the Agreement directly by cancelling your FinFree Account. FinFree has no obligation to permanently suspend (cancel) your FinFree Account’s entitlements to FinFree and to revoke the corresponding FinFree Account:

  • If FinFree has terminated rendering its services to you;

  • If it is alleged that you have registered or if you have registered directly or indirectly as a FinFree User on behalf of someone else;

  • If the information you provide is groundless, inaccurate, non-current, or incomplete;

  • If you state that you do not want to accept the amended Terms and apply for cancellation of your FinFree Account or by any other means when these Terms are changed;

  • If you breach any of the provisions of these Terms partially and/or wholly;

  • If you request the termination of FinFree Services;

 

15. LEGAL and PENAL SANCTIONS

 

15.1   The user is deemed to have read and accepted all the explanations made by the Capital Markets Board (CMB), Banking Regulation and Supervision Agency (BRSA), and other regulatory authorities on financial issues and to be made thereafter.

 

15.2   If the Application and the Site are used by the User for any purpose violating all legislation and general rules of law in force in the Republic of Turkey, including the legal regulations concerning the prevention of laundering of crime revenues and financing of terrorism, the User becomes liable from all legal and penal sanctions under Articles 4.8 and 4.11 of this Agreement. In this regard, the User accepts, declares, and undertakes that she/has irrevocably released the Company. The Company has the right to freeze, delete or suspend the User’s account for a definite or indefinite period and to ban the concerned person from opening an account indefinitely for these reasons.

 

15.3   The User undertakes to use the Application and the Site within the scope of the laws of the Republic of Turkey and all legislation. In the case of any illegal use, the Company has the right and is entitled to share all the information of the User with the competent authorities. This cannot be considered a breach of the privacy policy and no liability can be attributed to the Company.

 

15.4   Notwithstanding that the Company has determined that any article(s) in this Agreement has been breached by the User, the Company’s failure to terminate the Agreement or to take legal action against the User cannot be deemed as a waiver of these rights by the Company. All rights of the Company are reserved against these violations.

 

16. APPLICABLE LAW AND AUTHORITY

 

16.1   This Agreement shall be governed by the law of the Republic of Turkey, and Istanbul (Çağlayan) Courts and Enforcement Offices are exclusively authorized in the settlement of disputes arising from the use of the Application and the Site and/or the terms and provisions of the legal notice, and/or in connection with this Application and the Site and/or this Agreement.

 

17. PRIVACY

 

17.1   The Company undertakes to keep the data of the User confidential and to take all kinds of measures for this purpose. However, in case data and documents are requested by the competent authorities within the scope of the laws, legislative decrees, and all legislations of the Republic of Turkey, and the requirements of the agreements between the Company and its Users are fulfilled and put into practice, this data and documents will be submitted to the competent authorities. Although this does not constitute a violation of confidentiality, the Company cannot be held responsible for any damages that may arise from this.

 

17.2   In the cases listed below, the Company will be able to disclose the data of the Users to third parties by going beyond the provisions of this privacy notice. These cases are as follows:

 

a) In cases where it is necessary to comply with the obligations imposed by the written rules of law issued and enforced by the competent legal authorities such as Laws, Decrees, Regulations, etc.,

b) In cases where the requirements of the agreements between the Company and the Users are fulfilled and put into practice,

c) In cases where information about Users is requested in line with research or investigation conducted by the authorized administrative and/or judicial authorities following the procedural method,

d) In cases where it is necessary to provide information to protect the rights or security of users.

 

17.3   Under this notice, FinFree hereby undertakes that it accepts to keep any confidential information strictly private and confidential, keep them secret and take all measures and show the ultimate attention to prevent all or any part of the confidential information from entering the public domain or from their disclosure to an unauthorized User or a third party.

 

18. FORCE MAJEURE

 

In the case of force majeure such as natural disasters, wars, mobilizations, fires, strikes, lockouts, internet interruptions, etc. that occur in a way and to an extent that will partially or completely, temporarily or permanently stop the working facilities of both the User or the Company or any of them, as well as the cases such as decrees taken by the government, legal regulations, etc. that arise beyond the control of the parties, the User or Company cannot be held responsible. The unaccountability of the User and Company is limited to the continuation of these cases. In this case, the User or the Company will not have the right to claim the damage that they may have suffered due to the non-enforcement or delay of the Agreement.

 

19. DISCLAIMER OF LIABILITY

 

19.1   All kinds of data, including contents, graphics, indicators, comments made by other users, categorizations, and collections offered on the Site and Application, consist of data collected from third parties and publicly available sources. All data, analyses, reports, and statistics are processed by software that automatically processes information without any edit or direction and/or submitted objectively without subjecting them to any action by the Company. All kinds of news and reports that are presented on the Site and Application are only intended for information and advice, and they are not a direct solution, conclusion, legal opinion, or political and sociological research information, and their exact accuracy is not guaranteed. The data may be conflicting or inconsistent with each other. The Company cannot be held responsible for the accuracy of the data and information specified in this clause, and it will be the User’s responsibility to check and verify his/her accuracy.

 

19.2   The Company does not give any express or implied warranty including all kinds of merchantability, performance, marketability, or fitness for a particular purpose concerning the results that may be obtained by any person or establishment through the User from the contents offered by it. All content is provided to the User ‘’as is’’. The company cannot be held responsible for any loss of profits or damages that may arise from the use of the contents. Any reference to any person/institution/company/brand in the content offered by the company is not a recommendation that will affect the market values ​​of these people/institutions/companies/brands, their rankings by various criteria and brand values, and is not an advice to buy, sell or hold any stock.

 

20. MISCELLANEOUS AND FINAL PROVISIONS

 

20.1   All notices, approvals, requests, and other types of correspondence and notifications to be given to the User by the Company or received from the User will be made via the e-mail s/he has provided during registration or over the Application or Site. Any communication made via e-mail takes the place of written communication. It is the User’s responsibility to keep the e-mail address up-to-date, to designate the e-mail address of the Company, over which the Company sends e-mail, as a secure e-mail address to receive its e-mails, and to regularly check the Company for notifications. The notifications made to the e-mail address registered in the system of the User are official notifications under the Notification Law and other laws, and the User declares and undertakes that his/her address is always accurate and accessible.

 

20.2   The provisions of this Agreement are severable and the invalidity of a provision never affects the validity of other provisions. If any of the provisions of this Agreement becomes unenforceable or invalid due to a new law or regulation, the remaining of the Agreement will not be affected by this.

 

21. ENFORCEMENT AND ACCEPTANCE

 

20.1   The User accepts, declares, and undertakes that by registering the Application and the blog on the Site, s/he is deemed to have read and understood all the articles, sub-paragraphs, and clauses of this Agreement consisting of sixteen articles, and to have approved all the content and all provisions of the Agreement. This Agreement enters into force on the date when the User approves the Agreement and it is abolished when the Agreement is terminated by the Company or the User terminates his/her membership.

 

20.2   The User, who does not accept the Agreement, shall not be a member of the Application and the Site and not utilize the services of the Application and the Site. Otherwise, the Company cannot be held responsible for any damages that have arisen and/or may arise.

 

20.3   FinFree may change this Agreement and Terms of Use from time to time. The Company has the right to unilaterally amend and update this legal notice and all the terms and provisions of this Agreement without any prior notice. The User declares and undertakes that by accepting this Agreement, s/he accepts these changes done by the Company in advance. It comes into force on the date when it is announced by the Company on the Application and/or the Site.

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