Terms of Service

Effective Date: October 15, 2026 · Last Updated: October 15, 2026

Introduction

This Terms of Use Agreement (the "Agreement") is entered into between WIN WIN ORGANIZASYON VE DANIŞMANLIK LİMİTED ŞİRKETİ, a Turkish limited liability company registered under Company Registration No. 414233-5, with registered address at Aksaray Mah. Koçibey Sk. Özel İşhanı No: 2 İç Kapı No: 11, Fatih, Istanbul, Turkey, operating under the brand name "WoWbat" ("we," "us," or "our"), and you as a current or prospective user of the wallet services ("Service") provided through the WoWbat mobile application ("WoWbat App") and website.

By accessing or using the WoWbat App, you agree to be bound by this Agreement. Please review this Agreement carefully, including provisions that limit our liability.

1. Use of the Services

1.1 Eligibility

To access the Service, you must be at least eighteen (18) years old and have the legal capacity to enter into this Agreement. You may only open and use a User Account on your own behalf.

1.2 Mobile App and User Account Required

To access the Service, you must download and maintain a current version of the WoWbat App and create a user account ("User Account"). You are responsible for maintaining accurate, current, and complete information.

1.2.1 Sign-In with a Third-Party Account

You may create and access your User Account using a Google or Apple account. If you do:

  • (a) you represent that you own and control that account and are entitled to use it;
  • (b) your use of that account is governed by the provider's own terms and privacy policy;
  • (c) WoWbat does not control the provider and is not responsible for its availability, for suspension or closure of your account with it, or for changes to its service;
  • (d) if you lose access to the Google or Apple account you signed in with, you may lose the ability to sign in to your User Account;
  • (e) signing in with Google or Apple does not back up, store, or recover your wallet. Your recovery phrase remains the only way to restore the wallet, and losing both the provider account and the recovery phrase means the wallet cannot be recovered.

Revoking WoWbat's access in your Google or Apple account settings stops you from signing in, but does not delete your User Account or your data. Account deletion is performed in the WoWbat App, in Settings.

1.3 Wallet Services (Non-Custodial)

WoWbat provides technology that enables users to create and manage cryptocurrency wallets through the WoWbat App.

You acknowledge and agree that:

  • (a) your wallet is non-custodial and controlled solely by you;
  • (b) WoWbat does not hold, store, or control private keys or digital assets;
  • (c) WoWbat provides only technical infrastructure and user interface functionality;
  • (d) you are solely responsible for securing your wallet credentials and private keys;
  • (e) WoWbat cannot access, transfer, freeze, seize, or reverse blockchain-based assets.

Any suspension, restriction, or termination applied by WoWbat affects only access to the platform and does not affect ownership or on-chain control of digital assets.

1.4 KYC / AML Verification

To access certain features of the Service, including on-ramp services and QR-based merchant payments, you may be required to complete Know Your Customer (KYC) and Anti-Money Laundering (AML) verification.

Such verification is conducted by certified third-party service providers acting on behalf of licensed financial partners, in accordance with applicable laws and regulations.

By proceeding, you authorize:

  • (a) the collection and processing of identification and verification data by such providers;
  • (b) screening against compliance databases as required by licensed partners;
  • (c) ongoing compliance-related checks performed by licensed partners.

Following successful completion of mandatory KYC procedures, as required by licensed partners and to ensure the security of QR-based payments, users may be granted access to transaction functionality subject to a default monthly transaction limit of up to USD 5,000 (or equivalent) per user.

Transaction limits may be adjusted, increased, reduced, or restricted based on partner requirements, regulatory obligations, or additional risk assessment.

WoWbat does not independently perform regulated source of funds or source of wealth assessments. Where required, WoWbat relies on the controls and determinations of licensed partners and may apply platform-level restrictions or request additional information to support compliance.

WoWbat does not independently submit suspicious transaction or activity reports (STR/SAR). Regulatory reporting obligations are fulfilled by licensed partners in accordance with applicable law.

1.5 On-Ramp Services

Fiat-to-cryptocurrency conversion services are provided exclusively by licensed third-party partners. When initiating an on-ramp transaction, you acknowledge that:

  • (a) WoWbat does not provide regulated financial services;
  • (b) conversion, settlement, compliance checks, and reporting are performed by licensed partners;
  • (c) applicable fees and exchange rates are determined by such partners.

1.6 Service Provided

WoWbat provides a technology platform that enables users to:

  • (a) create and manage non-custodial wallets;
  • (b) initiate cryptocurrency transactions;
  • (c) access payment and conversion services offered by licensed partners.

You acknowledge that regulated financial services are not provided by WoWbat.

1.7 Funding Your Wallet

Funding, conversion, and settlement of transactions are facilitated by licensed partners. WoWbat does not accept, store, or control fiat currency or user funds.

1.8 Exchange Rates and Currency Conversion

Exchange rates, spreads, and fees are determined by licensed partners. WoWbat does not control, set, or guarantee such rates.

1.9 Fees

Applicable fees are disclosed prior to transaction confirmation. WoWbat may receive transaction-based fees for providing access to the platform. Such fees relate solely to access to the technology platform and do not constitute payment processing or financial services.

1.10 Account Statements

Transaction records displayed in the WoWbat App are informational only. Blockchain transactions are permanent and immutable.

1.11 Accuracy of Information and Duty to Update

You agree to provide accurate and up-to-date information and authorize verification where required by law or licensed partners. If you use a masked or relay email address, such as Apple's "Hide My Email", you are responsible for keeping forwarding enabled or providing a contact address we can reach.

1.12 Our Right to Refuse or Restrict Service

WoWbat may refuse, restrict, suspend, or terminate access to the Service where reasonably required for:

  • (a) compliance with legal or regulatory obligations;
  • (b) security or risk management;
  • (c) partner requirements;
  • (d) suspected misuse, fraud, or unlawful activity;
  • (e) any actual or suspected breach of Section 2.6 (Merchant Payments: Permitted Use and User Responsibility).

Restrictions may include temporary or permanent limitations on specific features, transaction functionality, or usage thresholds.

Such actions apply only to platform access and do not affect user-controlled digital assets.

1.13 Responsibility and Risk Acknowledgment

You acknowledge and accept the risks associated with cryptocurrency usage, including volatility, irreversibility of transactions, technical failures, and regulatory changes.

2. Acceptable Use

2.1 Compliance

You agree to use the Service in compliance with all applicable laws and regulations in the jurisdictions relevant to the use of the Service.

2.2 Prohibited Activities

You agree not to engage in activities including fraud, money laundering, terrorist financing, sanctions evasion, system interference, or misuse of the Service. Prohibited activities also include any use of the Service in breach of Section 2.6, including paying for unlawful goods or services, transferring funds to yourself, or transferring funds to individuals who are not merchants.

2.3 Electronic Communications

You consent to receive communications electronically from WoWbat.

2.4 Security and Responsibility for Credentials

You are solely responsible for safeguarding account credentials, private keys, and devices. This includes the credentials and security settings, such as two-factor authentication, of any Google or Apple account you use to sign in. Activity carried out through a signed-in provider account is treated as your own.

2.5 Submissions and User-Generated Content

You agree not to submit unlawful, harmful, or infringing content.

2.6 Merchant Payments: Permitted Use and User Responsibility

(a) Permitted use only. You agree to use the Service and the merchant payment functionality of the WoWbat App solely to pay for goods and services sold by merchants, meaning businesses that accept payments through the national QR payment system of the relevant country (including VietQR in Vietnam) and are served by licensed partners ("Merchant Payments"). You will not use the Service for any other purpose.

(b) Not a money transfer service. The Service is not a remittance or money transfer service. You shall not use the Service:

  • (i) to pay for any goods, works or services that are illegal, prohibited or restricted under the laws of Vietnam, the laws of any other country where the payment is made, the laws applicable to you, or applicable sanctions, or for any other unlawful purpose, including money laundering, terrorist financing, fraud or unlawful gambling;
  • (ii) to transfer funds to yourself, that is, to any bank account, card, e-wallet or other account that you own or control, in any country, including by presenting the destination account as a QR code;
  • (iii) to transfer funds to accounts of other individuals who are not merchants (including relatives, friends and intermediaries), or for cash-out, currency exchange or any other transaction that is not a payment for goods or services sold by a merchant;
  • (iv) to pay using QR codes generated by you or by anyone acting on your behalf, or to simulate a purchase where no real sale of goods or provision of services takes place.

(c) Your representations. Each time you confirm a Merchant Payment, you represent and warrant that the payment is made to a genuine merchant for goods or services actually provided to you, and that the payment is lawful in every jurisdiction concerned.

(d) Full responsibility. You are fully and solely responsible for the legality, purpose and consequences of every payment initiated from your User Account, including any use of the Service in breach of this Section 2.6. This covers liability to governmental authorities, banks, payment processors, merchants and other third parties. You agree to indemnify and hold harmless WoWbat and its partners against all losses, fines, fees, penalties and expenses arising from your breach of this Section.

(e) No control by WoWbat. WoWbat cannot verify the purpose of a payment, the nature of the recipient, the identity of the person who ultimately receives the funds, or whether goods or services were actually provided. Processing a payment does not mean that WoWbat has reviewed or approved it. WoWbat has no responsibility for any use of the Service in breach of this Section 2.6, in particular for transfers to yourself, transfers to individuals who are not merchants, or payments for unlawful goods or services.

(f) Blocked or rejected payments. If a payment is rejected, blocked, frozen, held or returned by a licensed partner, a local payment provider, a bank, a national payment system operator or any other competent party, including as a result of its own AML or compliance checks, WoWbat is not obliged to refund, compensate or replace the affected funds or any related fees. WoWbat is not obliged to seek the release of such funds and is not liable for decisions of third parties. If any such funds are actually returned to WoWbat, WoWbat may, but is not obliged to, return them to you after deducting all costs, fees and penalties incurred.

(g) Enforcement. If we believe or suspect that you have breached this Section 2.6, we may refuse or cancel a transaction, suspend or terminate your User Account, request additional information and documents, and disclose information about the relevant transactions to our partners, banks and competent authorities as permitted or required by law.

3. Data and Privacy

3.1 Data Handling

Your use of the Service involves the processing of personal data as described in the WoWbat Privacy Policy, which forms an integral part of this Agreement.

You acknowledge and agree that, where required for the provision of the Service, compliance with applicable laws, or partner requirements, relevant information may be shared with licensed partners and their designated service providers.

3.2 Confidentiality and Data Protection

WoWbat applies reasonable and industry-standard measures to protect personal data.

3.3 Cookies and Tracking Technologies

Cookies and similar technologies are used as described in the Privacy Policy.

4. Intellectual Property

All intellectual property rights in the Service belong to WoWbat or its licensors. No rights are granted except as expressly set out in this Agreement.

5. Disputes

5.1 User Account Disputes

You agree to cooperate in investigations of disputed activity.

5.2 Blockchain Transaction Disputes

Blockchain transactions are irreversible. WoWbat has no ability to reverse, cancel, or modify confirmed transactions.

5.3 Merchant and Third-Party Disputes

WoWbat provides a technology platform that enables users to initiate payment transactions via QR codes. WoWbat does not sell goods or services and does not act as the merchant of record in respect of any transaction.

Where a transaction is successfully initiated through the WoWbat App, the provision of goods or services remains the sole responsibility of the relevant merchant. Payment processing, settlement, and related regulated services are performed by licensed partners.

In the event of a dispute relating to the quality, delivery, or fulfillment of goods or services, WoWbat may assist by facilitating communication or providing available transaction information, but does not assume responsibility for the underlying merchant obligations.

Upon successful completion of a QR-based payment, WoWbat may display or transmit a transaction confirmation or receipt generated or provided by the relevant licensed partner or payment processor.

Such receipt or confirmation is provided for informational purposes and reflects transaction data received from third parties. Such receipt or confirmation does not constitute a fiscal, tax, or merchant-issued document and does not evidence fulfillment of the merchant's obligations.

WoWbat does not guarantee refunds for completed blockchain or QR-based transactions. Any refund requests, where applicable, are subject to the policies and processes of the relevant merchant or licensed partner.

Funds that have been rejected, blocked, frozen or held by a licensed partner, local payment provider, bank or other third party in connection with a breach or suspected breach of Section 2.6 are not refundable by WoWbat, as set out in Section 2.6(f).

6. No Warranty and Limitation of Liability

6.1 Service Provided "As Is"

The Service is provided on an "as is" and "as available" basis.

6.2 Security Disclaimer

WoWbat does not guarantee uninterrupted, error-free, or completely secure operation.

WoWbat shall not be liable for service interruptions or failures resulting from events beyond its reasonable control, including network outages, blockchain congestion, partner downtime, or regulatory actions.

6.3 Limitation of Liability

To the maximum extent permitted by law, WoWbat shall not be liable for indirect, incidental, or consequential damages.

6.4 Assumption of Risk

You assume all risks associated with using the Service and holding digital assets.

Payments may be blocked, frozen or held by licensed partners, local payment providers, banks or authorities, and in the cases described in Section 2.6(f) WoWbat has no obligation to refund such funds.

Nothing in the Service constitutes financial, investment, or legal advice. WoWbat does not act as a fiduciary, agent, or advisor on behalf of users.

7. Termination

7.1 Termination Rights

WoWbat may terminate or suspend access to the Service as described in this Agreement.

7.2 Effect of Termination

Termination affects only platform access. Digital assets remain under the user's control. Where you deleted your User Account and had signed in with Google or Apple, WoWbat revokes its authorization with that provider as part of the deletion.

8. Miscellaneous

8.1 Entire Agreement

This Agreement, together with any other documents referenced herein, including the Privacy Policy, constitutes the entire agreement between you and WoWbat regarding your use of the Service and supersedes all prior or contemporaneous agreements, communications, and understandings, whether written or oral.

8.2 No Waiver

The failure or delay by WoWbat to exercise any right, power, or remedy under this Agreement shall not operate as a waiver of such right, power, or remedy, nor shall any single or partial exercise preclude any other or further exercise of any right, power, or remedy.

8.3 Severability

If any provision of this Agreement is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be enforced to the maximum extent permissible, and the remaining provisions of this Agreement shall remain in full force and effect.

8.4 Governing Law and Venue

This Agreement shall be governed by and construed in accordance with the laws of the Republic of Turkey, without regard to its conflict of law principles. You agree that the courts of Istanbul, Turkey shall have exclusive jurisdiction to resolve any dispute arising out of or relating to this Agreement or the Service.

8.5 Amendment and Modification

WoWbat may amend or modify this Agreement at any time by providing notice through the WoWbat App, by email, or by other reasonable means. Continued use of the Service after the effective date of any changes constitutes acceptance of the amended Agreement.

8.6 Third-Party Links and Services

The Service may contain links to third-party websites or services that are not owned or controlled by WoWbat. WoWbat has no control over, and assumes no responsibility for, the content, policies, or practices of any third-party websites or services. You acknowledge and agree that WoWbat shall not be responsible or liable for any loss or damage arising from your use of any third-party services.

8.7 Survival

All provisions of this Agreement which by their nature should survive termination, including but not limited to disclaimers, limitations of liability, indemnification obligations, governing law, and dispute resolution provisions, shall survive any termination or expiration of this Agreement.

8.8 Assignment

WoWbat may assign or transfer its rights and obligations under this Agreement, in whole or in part, without restriction. You may not assign or transfer your rights or obligations under this Agreement without the prior written consent of WoWbat.

8.9 Contact Information

If you have any questions, concerns, or complaints regarding this Agreement or the Service, you may contact WoWbat at:

Email:support@wowbat.asia

Registered Address:
WIN WIN ORGANIZASYON VE DANIŞMANLIK LİMİTED ŞİRKETİ
Aksaray Mah. Koçibey Sk. Özel İşhanı No: 2 İç Kapı No: 11
Fatih, Istanbul, Turkey
Company Registration No. 414233-5

8.10 Acknowledgment

By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Agreement.

Effective Date: October 15, 2026 · Last Updated: October 15, 2026