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KNOW YOUR CUSTOMER POLICY

Blockchain Lab Yazılım Anonim Şirketi (“Blockchain Lab or the “Company”) takes very seriously the issue of providing its services to its Customers in the best way possible within the scope of “Contract for Sale of Cryptocurrency and Other Software” and “Contract for the Purchase of Cryptocurrency and Other Software” (Together, they will be referred to as the “Cryptocurrency Transactions Agreement”).

This Know Your Customer Policy (“KYC Policy”) is an integral part of the Policy on the Prevention of Laundering Proceeds of Crime and Financing of Terrorism (“Policy”) and the Cryptocurrency Transactions Agreement, and should be considered and regarded together with the Policy and the Cryptocurrency Transactions Agreement. The abbreviations in this KYC Policy have the same meaning as the definitions in the Policy.

The purpose of the KYC Policy is to reduce risk by evaluating transactions and services with a risk-based approach, to raise awareness of employees and to obtain information about the prevention of money laundering and financing of terrorism, and in this is context, it is to inform the Customers that the Company carries out its activities in accordance with the current legislation, especially the Law No. 5549 on the Prevention of Laundering Proceeds of Crime and the Law No. 6415 on the Prevention of the Financing of Terrorism.

This KYC Policy is implemented in terms of all the services our Company provides to its Customers for cryptocurrency buying/selling transactions.

Blockchain Lab takes the following measures in accordance with the applicable legislation and other internal policies in accordance with the KYC Policy.

1. Authentication

In accordance with this KYC Policy, the Company takes appropriate authentication measures for each service it offers. These verification measures are as follows:

• Verifying customer identity,

• Taking reasonable measures to identify the beneficiary as a result of the customer’s transactions,

• Requesting reasonable information about the purpose and nature of the transaction the Customer wishes to make,

• Monitoring the Customer and the transactions performed by the Customer and comparing it with the Customer profile,

• Monitoring high-risk Client transactions and other Clients that require particular attention.

Within the framework of this KYC Policy, Customer identity verification is completed prior to any transaction between the Customer and the Company. Information is requested about the cryptocurrency purchase/sale transactions that the Customer wishes to carry out through the Company and the purpose of these transactions. In this context;

• For transactions to be carried out through our Company’s branch (“Branch”) located at the address (Beyazıt, Grand Bazaar Molla Fenari Mah, Çuhacı Han Sk. No: 12, 34120 Fatih/Ä°stanbul), a TR ID card or passport photocopy is requested from the Customer,

• For transactions to be made online via the https://cointral.com/ platform, TR ID card or passport image is requested before starting the transaction.

The identity verification procedure is carried out by the Company.

In cases where the Customer, who requests a transaction through the Platform and our Company’s branches, performs the transaction for the benefit of a third party, the identity verification of both the Customer and the third party for which the transaction is made is performed.

2) Information and documents requested from customers before the transaction is performed

• Copy of identity card or passport containing the TR Identity Number and photo, and valid date information,

• Residence address/country information,

• User Authentication,

• Working Status (Optional),

• Income Sources for Investment (Optional).

3) Information and documents requested from the customers before the transaction is carried out at the Branch

• Copy of identity card or passport containing the TR Identity Number and photo, and valid date information,

• Residence address/country information,

• Working Status (Optional),

• Income Sources for Investment (Optional).

4) Information and documents requested from Corporate Entity Customers before any action is taken

• Tax registration certificate

• Trade registry gazette

• Circular of signature

• A copy of the identity card containing the TR Identity Number and photograph of the authorized person in the circular of signature

• Residence address information

• Phone number

• E-mail address

• Printed form signed with company stamp.

5) Situations in which the authentication procedure will be executed

Our Company implements an identity verification procedure for the Customer, regardless of any amount, before any cryptocurrency purchase/sale transaction to be performed by the Customer. The company reserves the right to repeat the verification process if there is any doubt about the accuracy and adequacy of the previously obtained credentials.

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