Terms of Use and Membership Agreement

2026-10-06

These Terms of Use and Membership Agreement (the “Terms”) govern use of the online fund-data and historical-data analysis platform offered under the Fonigeo brand (the “Platform”). By registering, creating a membership by email, or signing up or signing in with your Google account, you declare that you have read, understood and bindingly accept (i) these Terms, (ii) the Fund Analysis and Data-Use Acknowledgement accepted separately at registration, (iii) the No Investment Advice and Advisory-Boundary Acknowledgement, and that you have viewed (iv) the KVKK Privacy Notice. Together these documents form an integral part of the membership relationship.

1. Definitions

“User / you”: the natural person who becomes a member. “Service”: the software functions Fonigeo provides (fund list and cards, price and return views, comparison, market/FX conversion tools, watchlist, notifications, historical-data analysis and saved analyses). “Content”: any data, metric, label or text shown on screen or in a notification. “Official source”: the fund’s prospectus, investor information form, internal regulations, KAP disclosures, TEFAS and publications of competent authorities.

2. Parties, legal nature and licensing status

The Platform is a software service for compiling, visualising and mathematically summarising public market and fund data from historical records. Fonigeo is not a brokerage, portfolio management company, investment firm, exchange, clearing/custody institution or payment institution. Under Capital Markets Law No. 6362 and CMB regulations it does not carry out investment advisory, portfolio management, brokerage, general investment recommendation, order transmission, custody or similar capital-markets activity, and it does not claim to hold an authorisation for such activities. No purchase, sale, transfer, fund order, payment or other financial transaction is or can be carried out through the Platform. Fonigeo is also not a fund founder, manager or distributor and receives no commission, premium or referral fee from funds.

3. Scope of the Service

To support the user’s own research, the Service may include: fund list and detail; historical price and return summaries; fund comparison; KAP disclosure summaries (where available); public market indicators such as CBRT data and informational FX/gold conversion; a watchlist; in-account notifications; and mathematical summaries computed from historical prices, with saved analyses. Features, data coverage and presentation may change for operational reasons; no feature is promised to be offered continuously.

4. Limits of the Service — what Content is not

Content is for information and to support your own research only. Content is not (i) investment advice, (ii) personal or general investment recommendation, (iii) a buy/sell/hold signal or trading instruction, (iv) a promise of return, principal, liquidity, tax or legal outcome, (v) a forecast of future prices or returns, (vi) an official document, prospectus or substitute for KAP, or (vii) a suitability or appropriateness assessment, KYC, or risk-profile determination. The official fund risk value (e.g. 1–7) is shown only as far as it is published at the source; other labels or summaries on screen are not official classifications.

5. User declarations and capacity

You accept that you are a natural person aged 18 or over with capacity to act; that you open the account in your own name and at your own responsibility; that you will not use the account on behalf of a legal entity, investment firm or third party; and that the Platform does not remove your duty to research independently and, where needed, seek the view of a licensed investment firm or expert before making an investment decision. You understand that capital-markets instruments carry risk including loss of principal; that fund unit values can fall as well as rise; that past performance does not indicate future returns; and that participation/interest-free labels are not a religious or legal-compliance opinion. If you are outside Türkiye, complying with the rules of your country is your responsibility.

6. Account, authentication and Google

You may register with email and password or with Google authentication. If you use Google, Google’s own terms and notices also apply. You are responsible for the accuracy of your account information, the confidentiality of your password and all activity under your account. You may not share or transfer the account. On suspected unauthorised access, change your password and notify destek@fonigeo.com. Email verification and security notices are sent to perform the membership relationship and are separate from commercial-message consent.

7. Prohibited uses

Automated scraping, excessive load, unauthorised access, reverse engineering, exploiting vulnerabilities, unauthorised commercial reproduction of Content, framing, data mining, resale, or presenting Content to third parties as “advice / signals / model portfolios” is prohibited. The Platform may not be used for market fraud, manipulation or misleading public disclosure. Accounts that breach the Terms, the law or security may be suspended or closed without prior notice.

8. Data sources, timeliness and official documents

Data come mainly from TEFAS, KAP, CBRT and similar public or third-party sources. Delays, gaps, corrections, outages, rounding, classification differences, holiday/business-day shifts or errors may occur. The “as of” date, observation count and data-status badges describe coverage; they are not a certificate of accuracy or sufficiency. The official and binding sources are the fund’s prospectus, investor information form, KAP and publications of competent authorities. Verifying any figure against official sources before a decision is your responsibility. Fonigeo does not undertake that third-party data are current, complete or accurate, and does not invent missing values.

9. Analysis, notifications and live updates

The nature of analyses is detailed in the Fund Analysis and Data-Use Acknowledgement and the No Investment Advice and Advisory-Boundary Acknowledgement you accept at registration. In short: analysis outputs are mathematical summaries computed from loaded historical price data; they are not forecasts, target prices or trade dates. Notifications are movement summaries for your watchlist, not buy/sell alerts. The live-update connection may drop; the first view on screen is the saved state loaded from the server.

10. Intellectual property

Software, design, brand, interface and original content belong to Fonigeo. Rights in TEFAS, KAP, CBRT and other sources belong to the relevant institutions and providers. Unauthorised copying, framing or commercial resale is prohibited. Your saved analyses and watchlist are processed to provide the Service and meet legal obligations.

11. Fees, changes and interruptions

A service offered free of charge is not a commitment to continuity or any service level. The Service may stop for maintenance, failure, third-party outage or force majeure. Features may change with or without notice for operational reasons. The current version of the Terms is published on the Platform; use after registration may, subject to mandatory provisions, count as acceptance of the current version.

12. Personal data

Processing of personal data is subject to the Privacy Notice provided under Law No. 6698 (KVKK). The notice is not a separate “consent to processing”. Processing necessary to set up the account and perform the Service rests on the legal ground of contract. Optional commercial electronic messages are subject to separate explicit consent.

13. Limitation of liability

The Service is provided “as is” and “as available”; there is no commitment to uninterrupted or error-free operation or fitness for a particular outcome. Subject to mandatory law, Fonigeo is not liable for (a) your investment decisions and their results, tax and legal consequences, (b) loss of profit, loss of opportunity, loss of data or reputational harm, (c) errors in third-party sources, or (d) indirect, incidental or consequential damage arising from internet, browser, device, email or outages. Limitations expressly prohibited by Consumer Protection Law No. 6502 and other mandatory provisions are reserved.

14. Indemnity

To the extent the law permits, you bear claims, costs and legal fees arising from your unlawful use of the Platform or breach of these Terms, misuse of your account, presenting Content to third parties as advice, or harm you cause to third parties.

15. Termination and account deletion

You may close your account at any time. Fonigeo may suspend or delete an account that breaches the Terms, the law or security. Account deletion is consistent with the periods in the Privacy Notice, subject to legal retention obligations.

16. Force majeure

Natural disaster, epidemic, war, cyber-attack, power/communications outage, legal prohibition or third-party infrastructure failure beyond reasonable control are valid grounds for delay or impossibility of performance.

17. Notices and contact

The email address registered to your account may be treated as the notice address. Contact: destek@fonigeo.com

18. Governing law, jurisdiction and language

The law of the Republic of Türkiye applies. For consumer transactions, the mandatory jurisdiction rules of Law No. 6502 and related legislation are reserved; otherwise the Istanbul (Çağlayan) courts and enforcement offices have jurisdiction. Texts may be published in Turkish and English; the Turkish text prevails in case of difference.

19. Severability, waiver, assignment

Invalidity of one provision does not affect the others. Fonigeo’s failure to exercise a right is not a waiver. The user may not assign the account or rights under these Terms without permission.

20. Effect

This version is the text you accept at registration.

Version: 2026-10-06