KNOW YOUR CUSTOMER (KYC) POLICY
ARTICLE 1- PARTIES
These Customer Recognition Principles are drawn up between GOCADA TEKNOLOJİ VE TİCARET LTD. ŞTİ. and the natural person(s) who become a member of this Site to use the services offered on the app.gocada.co Internet address and are an annex and integral part of the User Agreement currently in force. This Policy is subject to the User Agreement and is valid together with this Agreement. No provision 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 this Policy, GOCADA TEKNOLOJİ VE TİCARET LTD. ŞTİ. and the natural person(s) who become a member of this Site in order to use the services offered from the app.gocada.co Internet address will be collectively referred to as the Parties.
ARTICLE 2- SUBJECT
GOCADA TEKNOLOJİ VE TİCARET LTD. ŞTİ. has adopted the principle of “Know Your Customer” as an effective combat method within the framework of compliance with the “Law on the Prevention of Laundering Proceeds of Crime” no. 5549 and the “Law on the Prevention of Financing of Terrorism” no. 6415. The natural person(s) who become a member of this Site in order to use the services offered from the app.gocada.co Internet address are deemed to have read and understood the customer acceptance terms and regulations for customer recognition 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
CRT: Means these Customer Recognition Terms and Conditions and its content.
Gocada: The company titled GOCADA TEKNOLOJİ VE TİCARET LTD. ŞTİ., the operator of the website, refers to the independent private law legal entity established in accordance with Turkish Law. Gocada carries out commercial activities on its own behalf and is not an agency, branch or representative of any domestic or foreign legal entity.
User(s): Refers to the natural person(s) who become a member of the SITE by accepting this agreement. Legal entity membership is currently not accepted.
** Site/website: ** Refers to the cryptocurrency trading system managed by Gocada, including all web pages, web applications, application programming interfaces (APIs) and mobile applications offered through the app.gocada.co
Cryptocurrency: Virtual currencies that are encrypted using special software algorithms and traded based on changing hands in the virtual environment. Cryptocurrencies do not have physical equivalents, as in the case of official currencies in circulation under the supervision of central registry institutions (e.g. TL and the Central Bank of the Republic of Turkey), and these cryptocurrencies are not under the supervision of any central registrar. Cryptocurrencies are traded on digital databases called “Blockchain”. Gocada assumes that Users know and understand the characteristics of cryptocurrencies.
Cryptocurrency Wallets: These are the unique and non-repeatable virtual wallet addresses that Users can identify to their accounts. A different wallet is used, with a separate address algorithm and encryption for each type of cryptocurrency.
ARTICLE 4- MEASURES AND PROCESSING BY Gocada WITHIN the SCOPE OF CRT
Gocada takes the necessary measures and actions within the scope of the policies and procedures established in accordance with the legislation in the following matters.
Detects the identity of the membership holder,
Identifies the target of user transactions (the private or legal person who benefits as a result of the transaction) when necessary- Get information about the purpose and nature of the transaction that the user wants to perform,
-Obtains information about the purpose and nature of the transaction that the User wishes to perform
Monitors the status of the User’s use of the service and transactions performed,
Takes measures for users or transactions that are seen as suspicious.
Gocada takes all the measures that it is legally obliged to take in order to protect the operability of the Site, ensure the proper functioning of the system, fulfill legal requirements, and prevent transactions that may constitute a crime. In this regard, all employees of Gocada have undergone the necessary training, the User is aware of this issue and acknowledges that he/she knows that he/she must refrain from performing transactions prohibited by law and constituting a crime
4.1. Verification of Identity
The following information must be provided by the User prior to the establishment of the service relationship between Gocada and the User:
User’s name and surname,
User’s e-mail address.
Within the framework of CRT, the user information form on the Site shall be filled in completely by the user during registration and establishment of the User Agreement. In addition, the User shall upload a clearly legible photograph of his/her official and valid identity document (identity card, ID card for Turkish Citizens) to the Site via the system and submit it to Gocada’s approval. The official identity document of the User (for Turkish Citizens) must be verified in an integrated manner with Mernis and with visual support. In addition, the User must provide a document showing the current residence address of the User and the User must go through address verification. Even if the user does not make any monetary transactions; It is required to complete this identity verification step, which is equivalent to the acceptance of the User Agreement.
a) may decide to identify the User’s transactions when necessary for the purpose of the User’s transactions (natural or legal person who benefits as a result of the transaction) and to collect detailed information about the user’s transaction,
b) May decide to monitor the user transactions and evaluate them together with the customer’s personal profile,
c) May decide at any time to monitor and record such transactions about Users with high trading volume (the amount of a single or multiple swaps or transaction 100. 000.00 TL and above) or risky/suspicious transactions (even if the transaction volume is low, there is a suspicion of violation of the legislation) and to monitor and record of Users who carry out transactions, there is a suspicion about the security or adequacy of their credentials, to stop such transactions if necessary or cancel the realized transaction (Gocada may decide to activate the monitoring activity for all Users when deemed necessary).
The addressee (other User/buying User) of any sale or exchange transaction of the Users within the Site must also have completed this authentication procedure. Otherwise, Gocada is authorized not to approve such transactions.
4.2. Circumstances Where Membership Will Not Be Accepted/Terminated
Natural persons with the following features cannot be accepted as members of the Site, and in the case of such situation/s, the established membership in any way whatsoever shall be immediately canceled.
-In case of attempting to open a User account with a fake name or identity document, if the documents requested in the identity verification step are not uploaded to the Site by the User on time or at all, the transactions of the persons applying for membership are not accepted/terminated.
-Memberships of persons who are reported by local and international official organizations to be engaged in illegal activities, especially laws numbered 5549 and 6415 and related legislation, are not accepted/terminated.
Although there is no identity information in the list above, the membership transactions of persons who have information in Gocada records that they are associated with any financial crime, especially money laundering or terrorism financing, are not accepted/terminated.
-User accounts that are found to be used in connection with betting and gambling and/or membership transactions of Users who are found to be related to these accounts are not accepted/terminated.
4.3. Restricted Users
Even if persons with the following features are accepted as members of the Site, the approval or disapproval of User accounts is at the discretion of Gocada management, and only after the necessary examinations have been made, these accounts will be approved or restricted access may be provided.
These persons are;
-Non-governmental organizations, all associations, foundations, political parties, and sports clubs,
-MPs, political party representatives, BDDK, SPK, and bank employees,
-Citizens of, or legal entities based in, countries that restrict or completely ban the trading of cryptocurrencies.
The status of Users whose account is under review or temporarily or permanently suspended due to the criteria under clause 4 above may be changed by Gocada at any time as deemed necessary by Gocada. Users whose account is under review or temporarily or permanently suspended due to any of the criteria in any of the above items may be subject to interchange and status change by Gocada at any time, as deemed necessary by Gocada.
4.4. Risk Analysis and Monitoring
Within the scope of customer identification measures, Gocada protects, monitors and controls the cryptocurrency trading platform against risks through Risk Analysis, Monitoring and Control activities. Gocada 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, Gocada may perform risk analysis with the following methods and monitor the relevant Clients within the framework of the information obtained as a result of these analysis.
4.5. Findings and Measures Taken
The determinations that must be made by Gocada as a minimum within the scope of standard customer identification measures are listed below:
-Detection and confirmation of customer identity, address confirmation, real beneficiary, authorized representatives within the scope of legal legislation and Gocada Teknoloji A.Ş. internal policies,
-Screening clients for risks of being on international sanctions lists (including country risk assessment),
-Determining whether the customer and related parties are politically influential or connected to politically influential parties,
-Investigating whether the client and client-related parties are associated with high-risk countries recognized under international sanctions and Gocada Internal Policies,
-Determining whether someone is acting on behalf and/or account of another person,
-Monitoring customer transactions to detect unusual transactions,
-Identification and confirmation of source of income,
-Receiving information about the reason for working with our company.
Increased customer measures are also applied for customers deemed to be risky by Gocada at the time of customer acceptance or as a result of a subsequent risk assessment. Regardless of the result of the risk assessment, it may come to the agenda to take increased 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.
The determinations that should be made by Gocada as a minimum within the scope of enhanced customer measures are also included below:
-Filtering of the customer, beneficial owner, authorized representative (including Gocada’s structure) against the risks of identification and inclusion on international sanctions lists,
-Approval of the customer relationship by the relevant business line management/senior management,
-Identification and, where necessary, documentary confirmation of the client, the real beneficiary and his/her wealth,
-Determining whether the client’s sources of funds and/or capital are easily and satisfactorily verified and, where necessary, documentary confirmation,
-Examination of information and documents related to the justification for working with the company.
ARTICLE 5- FINAL PROVISIONS
Gocada may change the content of the CRT at any time it deems necessary.
The updated content of the CRT shall enter into force on the date of its publication on the Site. In the event of any dispute, Gocada’s records alone shall prevail and bind the parties.