Know Your Customer Process

ARTICLE 1- PARTIES

These Know Your Customer Process have been arranged between Allpay Transfer Bilişim ve Yazılım A.Ş. and the real person(s) who become a member of this Site in order to use the services offered on the website www.allpaytr.com and mobile application and is an annex and integral part of the User Agreement currently in force. These Know Your Customer Process are subject to the User Agreement and are valid together with this Agreement. Nothing in this text shall be interpreted separately or differently from the User Agreement, and in case of any conflict between this text and the User Agreement, the User Agreement shall prevail.
Within the scope of these Know Your Customer Process, Allpay Transfer Bilişim ve Yazılım A.Ş. and the real person(s) who become a member of this Site in order to use the services offered from www.allpaytr.com Internet address and mobile application will be referred to as the Parties together.

ARTICLE 2- SUBJECT

Allpay Transfer Bilişim ve Yazılım A.Ş. has adopted the principle of "Know Your Customer" as an effective method of struggle within the framework of compliance with the "Law on Prevention of Laundering Proceeds of Crime" numbered 5549 and the "Law on Prevention of Financing of Terrorism" numbered 6415. The real person(s) who become a member of this Site in order to use the services offered from the www.ALLPAY.com Internet address and mobile application are deemed to have read and understood the customer acceptance conditions and customer recognition regulations in this text in order to maintain the service relationship between the Parties in accordance with the specified legislation, based on mutual trust and openness, and to accept all obligations attributed to him in advance.

ARTICLE 3- DEFINITIONS and ABBREVIATIONS

KYC Terms and Conditions and their contents.
ALLPAY: Allpay Transfer Bilişim ve Yazılım A.Ş., the operator of the Website, is an independent private law legal entity established under Turkish Law. ALLPAY carries out commercial activities on its own behalf and is not an agent, branch or representative of any domestic or foreign legal entity.
User(s): Refers to natural person(s) who become a member of the Website by accepting this Agreement.

ARTICLE 4- MEASURES TAKEN BY ALLPAY UNDER the KYC and OPERATION

ALLPAY takes the necessary measures and actions within the scope of the policies and procedures established in accordance with the legislation in the following matters.
The name/surname and contact information of the membership holder is determined,
The target of user transactions (the private or legal person who benefits as a result of the transaction) is identified when necessary,
It monitors the User's use of the service and the actions taken by the User,
It takes measures for the User or transactions that are seen as suspicious. In cases where identification cannot be made, the transaction is not authorized. In suspicious cases that occur after User registration, the actions specified in Article 4.2 shall be taken immediately.
ALLPAY takes all measures that it is legally obliged to take in order to protect the operability of the Website, to ensure the proper functioning of the system, to fulfill legal requirements and to prevent transactions that may constitute a crime. In this regard, all employees of ALLPAY have received the necessary training. The User is aware of this and acknowledges that he/she is aware that he/she must refrain from engaging in transactions that are prohibited by law and that constitute criminal offenses.
4.1. Verification of Identity
The following information must be provided by the User prior to the establishment of the service relationship between ALLPAY and the User:
Name and surname of the User
User's e-mail address and telephone number
Also ALLPAY
a) Identifying user transactions when necessary due to their purpose (private or legal person who benefits as a result of the transaction) and collecting detailed information about the user's transaction,
b) Tracking user transactions and evaluating them together with the customer's personal profile,
c) ALLPAY may at any time decide to monitor and record Users with high transaction volumes or who carry out risky/suspicious transactions (Users who carry out risky/suspicious transactions, Users whose credentials are in doubt as to the health or adequacy of their credentials, and to stop such transactions if necessary or to cancel the transactions that have already taken place (ALLPAY may decide to activate the monitoring activity for all Users when deemed necessary).

4.2. Circumstances where Membership will not be accepted/terminated
Natural persons with the following characteristics cannot be accepted as a member of the Site and in the event of such situation/situations, the membership established in any way whatsoever shall be immediately canceled.
Accordingly
- In case of an attempt to open a User account with a fake name or identity document, the persons applying for membership
- During the control carried out, persons who were reported by local and international official organizations to have engaged in illegal activities, especially the Laws No. 5549 and 6415 and related legislation,
- Persons who are not listed above but whose ALLPAY records indicate that they have been involved in any financial crime, including money laundering or terrorist financing,
- User accounts found to be used in connection with betting and gambling and/or membership transactions of users found to be related to these accounts are not accepted/terminated.
4.3. Restricted Users
Even if persons with the following characteristics are accepted as members of the Website, ALLPAY's management has the discretion to approve or disapprove User accounts and will only approve or restrict access to such accounts after conducting the necessary investigations.
These persons are;
Non-governmental organizations, all associations, foundations, political parties and sports clubs,
MPs, political party representatives, BRSA, CMB and bank employees,
Users whose accounts are under review or temporarily or permanently suspended due to any of the criteria in any of the above items may, at any time, be interchanged and their status may be changed by ALLPAY at its discretion.
4.4. Risk Analysis and Monitoring
Within the scope of customer identification measures, ALLPAY protects, monitors and controls its platform against risks through Risk Analysis, Monitoring and Control activities.
ALLPAY adopts a risk-based approach in monitoring the financial activities of its Clients, and in order to prevent laundering proceeds of crime and financing of terrorism, ALLPAY conducts risk analysis using the following methods and may monitor the relevant Clients based on the information obtained as a result of this analysis. 4.5. Detections and Measures Taken|
The determinations that must be made by ALLPAY as a minimum within the scope of standard customer identification measures are listed below:
Identification and confirmation of customer identity, real beneficiary and authorized representatives within the scope of legal regulations and ALLPAY Teknoloji A.Ş. internal policies,
Screening clients for risks of being included on international sanctions lists (including country risk assessment),

Determining whether the client and parties related to the client are politically influential or connected to politically influential parties,
Investigating whether the client and its related parties are associated with very high risk countries recognized under international sanctions and ALLPAY Internal Policies,
Determining whether someone else is acting on behalf of and/or on account of another person,
Monitoring customer transactions to detect unusual transactions,
Increased customer measures are also applied for customers deemed risky by ALLPAY during customer acceptance or as a result of a risk assessment to be made later. Regardless of the outcome of the risk assessment, it may be possible to take enhanced measures and/or update monitoring activities within the framework of risky customer/transaction/sector assessments within the scope of national and international legislation and current company practices.

Within the scope of enhanced customer measures, ALLPAY filters customers, real beneficiaries, authorized representatives against the risks of identification and inclusion in international sanctions lists.
ALLPAY is authorized to take all necessary actions in accordance with the "Prevention of Laundering Proceeds of Crime and Financing of Terrorism Policy".

ARTICLE 5- FINAL PROVISIONS

ALLPAY may change the content of the KYC whenever it deems necessary.
The updated content of the KYC shall take effect on the date of its publication on the Site. In the event of any dispute, ALLPAY's records alone shall prevail and bind the parties.