COPIA

User Agreement

Version 1.4 · Last updated: 15 November 2026

This is an English translation provided for convenience. The Turkish version is the legally binding text.

1. Parties and Formation of the Agreement

This User Agreement (the "Agreement") is made between Ahsen Altun (the "Service Provider"), who develops and operates the Copia mobile application (the "App"), and the person who creates an account in the App (the "User"). The Agreement takes effect electronically when the User reads the full text and gives approval by ticking the "I have read, understood and accept" box. The date and time of approval and the approved version are recorded. Service Provider contact details: [email protected] · Address: Başak Mah. Yunus Emre Cad. No:6b, Başakşehir/İstanbul.

2. Definitions

Service: Tracking of assets, debts, goals and cash flow offered through the App, together with the related calculation, notification and summary features. Account: The personal user account the User creates with an email address or a Google account. User Data: All information the User enters in the App, such as assets, debts, goals, salary, income and expenses. Premium: Parts of the App that may be offered through a paid subscription in the future. Investment Assistant: The feature that shows short notes generated from User Data with the help of artificial intelligence.

3. Nature of the Service

The App is a personal record-keeping and calculation tool that helps the User keep track of their own financial situation. The Service Provider is not a bank, payment institution, brokerage firm, portfolio management company or investment adviser. The App does not connect to the User’s bank or brokerage accounts and does not carry out money transfers, payments, trades or any other financial transactions. The amounts shown in the App are based on the information the User enters and on third-party price sources.

4. Not Investment Advice

No content in the App, including Investment Assistant notes, the Financial Health Score, profit/loss calculations, charts and suggestions, constitutes investment advice or investment consultancy under Capital Markets Law No. 6362 and related legislation. This content is for general information and is not prepared with the User’s personal risk and return preferences in mind. Notes generated by artificial intelligence may contain inaccurate, incomplete or outdated information. The User makes investment, borrowing, spending and saving decisions based on their own judgement and is responsible for the consequences of those decisions. The User is advised to get professional support from authorised institutions before making investment decisions.

5. Price and Exchange Rate Information

Currency, gold, silver, cryptocurrency and stock prices are obtained from third-party sources and updated at certain intervals. These prices may be delayed, incomplete or inaccurate, and may not be updated for a while because of outages at the sources. The prices shown are for information only; they may differ from the transaction prices of banks, jewellers, exchanges or brokerage firms and should not be relied on for buying or selling. The Service Provider does not guarantee that price information will be accurate, up to date or available without interruption.

6. Calculations, Reminders and Notifications

All calculations, such as total debt, monthly payment, remaining instalments, profit/loss, goal progress, automatic salary entry and the monthly summary, are estimates based on the information the User enters. The official records of the bank, lender, public body or creditor (statements, contracts, payment plans, debt statements) always prevail. The User is responsible for confirming payment amounts and due dates with the relevant institution. The App sends a notification for debts on the reminder day the User chooses; this day is not the debt’s due date, and the App does not track due dates. If the User turns on the Monthly Summary in the notification settings in Profile, an email with a PDF attachment containing a summary of the previous month’s cash flow, spending, assets and net worth is sent to the registered email address on the 1st of each month; this feature is off by default and can be turned off at any time from the same place. Notifications and the monthly summary are for reminder and information purposes only; they may be delayed or not arrive at all because of device settings, connection problems or technical reasons. The Service Provider cannot be held responsible for late payment interest, penalties, credit score drops and similar consequences arising from calculation differences or notifications not arriving.

7. User Obligations

The User declares that they are at least 18 years old and have the capacity to accept the Agreement. The User is responsible for the security of their account details, password, app PIN and device; actions taken with their account are deemed to have been taken by the User. If the User notices that their account is being used without permission, they will notify the Service Provider immediately. The User enters personal data belonging to third parties (e.g. details of people they borrowed from or lent to) only lawfully and as far as necessary, and is responsible for that data. Using the App for unlawful purposes, copying the software, reverse engineering, attempting unauthorised access to systems, scraping data with automated tools or behaving in ways that disrupt the Service is prohibited.

8. Protection of Personal Data

The User’s personal data is processed in accordance with Law No. 6698 on the Protection of Personal Data ("KVKK"), for the purpose of providing the Service and limited to that purpose. Data is stored on the cloud infrastructure used by the Service Provider. When Investment Assistant notes are generated, only anonymous figures and category information are sent to the AI service provider; identifying information such as name, email or phone is not sent. Because the infrastructure and service providers are located abroad, data is transferred abroad. The purposes for which data is processed, to whom it is transferred and the User’s rights under the KVKK are explained separately in the KVKK Privacy Notice in the App (Profile > Help & Support). The Service Provider takes reasonable technical and administrative measures to keep data secure; however, no transmission or storage over the internet can be guaranteed to be completely secure.

9. Data Loss and Backup

The Service Provider takes reasonable care to protect User Data. However, data may be lost in cases such as technical failures, third-party infrastructure problems, the User permanently deleting records, the device being lost or account details falling into someone else’s hands. Permanently deleted records and deleted accounts cannot be recovered. The User is advised to keep a separate copy of financial records that matter to them.

10. Free Use, First-User Right and Premium Subscription

All parts of the App are currently free. A limited number of ads are shown in the App during free use. In the future, the Service Provider may move some sections, such as Debts and Goals, into a paid Premium subscription. The date has not been set yet; the User will be informed in the App or by email before Premium becomes available. The Assets section and the Financial Health Score will always remain free. First-user right: The account that installs the App on a device and signs in for the first time on that installation before Premium becomes available (the "First-User Account") will continue to use the sections moved into Premium at no extra cost. This right is tied both to that account and to the App’s installation on that device. Updating the App does not affect this right; signing out and signing back in with the same account on the same device does not end it either. If another account signs in on the same device, that account does not benefit from this right. If the App is deleted from the device and reinstalled, the device is reset or the App is installed on another device, this right ends; in that case a subscription is needed to use the Premium sections. No fee is ever charged without an explicit purchase by the User. When Premium becomes available, its price, subscription period and any free trial will be clearly shown in the App before purchase. Payments are taken only through the Apple App Store or Google Play and are also subject to the relevant store’s terms of use and payment. The subscription renews automatically unless cancelled before the end of the period. The User can cancel the subscription at any time from the subscription settings of their store account; cancellation takes effect at the end of the paid period and Premium features stay on until then. Deleting the account does not automatically cancel a subscription started through a store; the User must also cancel the subscription through the store. Price changes are notified to the User before they take effect and apply from the next renewal period.

11. Right of Withdrawal

The Premium subscription is a service performed instantly in electronic form. Under the Turkish Distance Contracts Regulation, the right of withdrawal cannot be used for such services once performance has started with the User’s approval. By confirming the purchase, the User declares that they accept that the service starts immediately and know that the right of withdrawal therefore ends. The app stores’ own refund policies and the User’s other rights under consumer legislation are reserved.

12. Intellectual Property Rights

All intellectual and industrial property rights in the App, including its software, design, logo, name, texts and calculation methods, belong to the Service Provider. The User is granted only a limited, non-transferable and non-exclusive right to use the App for personal, non-commercial purposes. User Data belongs to the User; the Service Provider uses this data only to provide the Service.

13. Changes and Interruptions to the Service

The Service Provider reserves the right to develop, change or remove features of the App. The Service may be temporarily interrupted because of maintenance, updates, third-party infrastructure problems or reasons beyond the Service Provider’s control. It is not guaranteed that the Service will be uninterrupted and error-free. If a paid feature is permanently removed, the User will be informed in advance.

14. Limitation of Liability

The Service is provided "as is" and "as available". The Service Provider cannot be held responsible for indirect damages, loss of profit and investment losses arising from investment, borrowing, spending and similar decisions the User makes based on information in the App, from price and calculation errors, data loss, Service interruptions or third-party services. These limitations do not apply in cases of intent or gross negligence by the Service Provider, damage to people’s life and health, and cases that cannot be limited under Consumer Protection Law No. 6502 and other mandatory legislation; the User’s statutory rights are reserved.

15. Account Deletion, Suspension and Termination

The User can end the Agreement at any time by deleting their account from the Profile page. When the account is deleted, User Data is permanently deleted and cannot be recovered. All records belonging to the User, including the agreement approval record, are deleted from the servers; subscription payment records are kept by the relevant app store (Apple App Store, Google Play). If the User breaches the Agreement or the law, the Service Provider may suspend or close the account after informing the User.

16. Changes to the Agreement

The Service Provider may update the Agreement because of changes in legislation or in the Service. The updated agreement is published in the App (Profile > Help & Support > User Agreement), and the User is asked to read and approve the current agreement again the first time they open the App after updating it. The App cannot be used until the current agreement is approved; the new approval is also recorded with its date, time and agreement version. A User who does not accept the current agreement can end the Agreement by deleting their account.

17. Notices and Evidence

Notices between the parties are made through the email address registered in the User’s account and through in-app notifications. The User is responsible for keeping their email address up to date. In case of dispute, the Service Provider’s server records, electronic approval records and email correspondence constitute evidence under Article 193 of Turkish Code of Civil Procedure No. 6100. The User’s right to prove otherwise by any means of evidence is reserved.

18. Governing Law and Dispute Resolution

The Agreement is governed by the laws of the Republic of Türkiye. For disputes arising from consumer transactions, the Consumer Arbitration Committees at the User’s place of residence or where the transaction took place have jurisdiction within the monetary limits set each year by the Ministry of Trade, and Consumer Courts have jurisdiction for disputes above these limits. For disputes that are not consumer transactions, the Courts and Enforcement Offices of Istanbul have jurisdiction.

19. Entry into Force

This Agreement consists of 19 articles and takes effect with the User’s electronic approval. The User declares that they have read and understood the entire Agreement and accept all of its terms.

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