Terms and Conditions DocumentTERMS AND CONDITIONS

Effective Date: 03.06.2025
Last Updated: 03.06.2025

1. INTRODUCTION AND ACCEPTANCE
Welcome to WowBat, a digital payment facilitation platform operated by WİN WİN ORGANİZASYON 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 ("Company," "we," "us," or "our").
By accessing or using the WowBat mobile application and associated services ("Platform"), you ("User," "you," or "your") agree to be bound by these Terms and Conditions ("Terms"). If you do not agree to these Terms, you must not use our Platform.
IMPORTANT REGULATORY NOTICE: WowBat operates as a closed-loop digital payment facilitation system. We do not provide crypto asset services as defined under Turkish Capital Markets Law No. 6362 and related regulations. Our WOW units are internal digital accounting mechanisms that cannot be transferred outside our Platform or exchanged for crypto assets directly.

2. PLATFORM DESCRIPTION AND SERVICES
2.1 Service Overview
WowBat provides a digital payment facilitation platform that enables users to:
  • Purchase internal digital value units ("WOW Units") using stablecoins (USDT/USDC)
  • Use WOW Units for payment facilitation at participating merchants
  • Convert unused WOW Units back to stablecoins (subject to network fees)
2.2 WOW Units - Internal Digital Accounting Mechanism
WOW Units are internal digital accounting mechanisms used exclusively within our closed-loop system. Key characteristics include:
  • Fixed Exchange Rate: WOW Units maintain a 1:1 parity with USD-pegged stablecoins
  • Non-Transferable: WOW Units cannot be transferred outside the Platform
  • Non-Tradeable: WOW Units cannot be sold to third parties or exchanged for other digital assets
  • Internal Use Only: WOW Units serve solely as accounting units for payment facilitation within our ecosystem
REGULATORY CLARIFICATION: WOW Units are not crypto assets under Turkish law as they cannot be transferred, traded, or used outside our closed system. This classification aligns with global regulatory frameworks for closed-loop digital value systems.

3. USER REGISTRATION AND VERIFICATION
3.1 Account Creation
To use WowBat services, you must:
  • Download the WowBat mobile application
  • Complete the registration process with accurate information
  • Connect a compatible crypto wallet
  • Agree to these Terms and our Privacy Policy
3.2 Identity Verification Requirements
In compliance with Turkish anti-money laundering regulations, we implement Know Your Customer (KYC) procedures:
Without KYC Verification:
  • Daily transaction limit: $1,000 USD equivalent
  • Monthly transaction limit: $25,000 USD equivalent
  • Per transaction limit: $1,000 USD equivalent
With Completed KYC Verification:
  • Daily transaction limit: $5,000 USD equivalent
  • Monthly transaction limit: $50,000 USD equivalent
  • Per transaction limit: $1,000 USD equivalent
3.3 Compliance with AML Regulations
As required under Turkish regulations effective February 25, 2025, transactions exceeding 15,000 Turkish Lira (approximately $425 USD) require enhanced verification procedures. Users may be required to provide additional documentation for compliance purposes.

4. PURCHASE AND REDEMPTION OF WOW UNITS
4.1 Purchase Process
Users may purchase WOW Units by:
  • Connecting a compatible crypto wallet to the Platform
  • Selecting the desired blockchain network
  • Transferring USDT or USDC to the designated wallet address
  • Receiving equivalent WOW Units in their Platform account at 1:1 parity
4.2 Redemption Process
Users may redeem unused WOW Units for stablecoins by:
  • Initiating a redemption request through the Platform
  • Providing a valid wallet address for stablecoin transfer
  • Paying applicable network transaction fees
  • Receiving stablecoins at 1:1 parity minus network fees
4.3 Third-Party Service Providers
For exchange operations and fund transfers to local partners, we utilize PowerPay Exchange, a licensed financial service provider. Users acknowledge that certain operations may be subject to PowerPay's terms and regulatory requirements.

5. PAYMENT FACILITATION SERVICES
5.1 QR Code Payment System
When using WowBat for merchant payments in Vietnam:
  • Users scan merchant QR codes to view payment amounts in local currency (VND)
  • Exchange rates are calculated in real-time based on USDT/VND rates
  • Service fees of 3-5% (or 0.5% for premium subscribers) are clearly displayed
  • Upon confirmation, WOW Units are debited and fiat payments are processed through our licensed partners
5.2 Local Partner Network
Payments to Vietnamese merchants are processed through our verified and licensed partners who operate within the VietQR and NAPAS payment systems. These partners maintain all necessary local licenses and regulatory approvals.
5.3 Service Fees and Pricing
We offer two pricing tiers:
  • Standard Service: 3-5% transaction fee per payment
  • Premium Subscription: $20/month with a reduced 0.5% transaction fee

6. REGULATORY COMPLIANCE AND LIMITATIONS
6.1 Turkish Regulatory Compliance
Our operations comply with Turkish regulations by:
  • Operating as a closed-loop system exempt from CASP licensing requirements
  • Not facilitating crypto asset trading, custody services, or initial offerings
  • Utilizing licensed third-party providers for crypto exchange operations
  • Implementing required AML and KYC procedures
6.2 Prohibited Activities
Users may not:
  • Attempt to transfer WOW Units outside the Platform
  • Use the service for money laundering, terrorist financing, or other illegal activities
  • Circumvent transaction limits or verification requirements
  • Access the service from jurisdictions where such activities are prohibited
6.3 Geographic Restrictions
While our Turkish entity operates the Platform, payment facilitation services are currently available only in Vietnam through our licensed local partners. Expansion to other jurisdictions will be subject to local regulatory approval.

7. RISK DISCLOSURES
7.1 Technology Risks
Users acknowledge risks associated with:
  • Blockchain network congestion and transaction delays
  • Smart contract vulnerabilities in underlying stablecoin protocols
  • Mobile application technical issues or service interruptions
7.2 Regulatory Risks
Cryptocurrency and digital payment regulations continue to evolve globally. Changes in applicable laws may affect service availability or terms of use. We will provide notice of material changes as required by law.
7.3 Exchange Rate Risks
While WOW Units maintain 1:1 parity with USD stablecoins, fluctuations in local currency exchange rates may affect the purchasing power of WOW Units when used for merchant payments.

8. DATA PROTECTION AND PRIVACY
In compliance with Turkish data protection laws and international standards, we collect and process personal information as detailed in our Privacy Policy. Users have rights regarding their personal data including access, correction, and deletion subject to regulatory requirements.

9. LIMITATION OF LIABILITY
TO THE MAXIMUM EXTENT PERMITTED BY LAW, OUR LIABILITY IS LIMITED TO THE DIRECT DAMAGES CAUSED BY OUR NEGLIGENCE. WE ARE NOT LIABLE FOR INDIRECT, CONSEQUENTIAL, OR SPECIAL DAMAGES ARISING FROM USE OF THE PLATFORM.

10. DISPUTE RESOLUTION
Disputes arising from these Terms shall be resolved through binding arbitration in Istanbul, Turkey, under Turkish law, except where consumer protection laws require court jurisdiction.

11. MODIFICATIONS AND TERMINATION
We reserve the right to modify these Terms with 30 days' notice to users. Continued use of the Platform constitutes acceptance of modified Terms. We may suspend or terminate accounts for violation of these Terms or applicable laws.

12. CONTACT INFORMATION
For questions regarding these Terms or our services, please contact:
WİN WİN ORGANİZASYON VE DANIŞMANLIK LİMİTED ŞİRKETİ
Aksaray Mah. Koçibey Sk. Özel İşhanı No: 2 İç Kapı No: 11
Fatih, Istanbul, Turkey
Email: legal@wowbat.asia

Conclusion
These Terms and Conditions are specifically crafted to position WowBat's operations outside the scope of Turkish crypto asset service provider licensing requirements while maintaining full regulatory compliance. The closed-loop nature of the WOW Units, combined with the use of licensed third-party providers for crypto exchange operations, creates a regulatory framework that enables immediate operation while preparations for future jurisdictional changes proceed. The document incorporates all necessary AML/KYC provisions required under current Turkish law and provides flexibility for expansion into other markets through appropriate local partnerships and licensing arrangements.