APILEX TERMS OF USE

1. Parties, Purpose and Definitions

These Terms of Use (the "Agreement") are concluded in electronic form between Fitty Teknoloji Anonim Şirketi ("Apilex"), whose registered office is at Çifte Havuzlar Mah. Eski Londra Asfaltı Cad. Kuluçka Mrk. A1 Blok No: 151/1C İç Kapı No: B34 Esenler/İstanbul and whose tax number is 3881624490, and the natural or legal person (the "User") who uses the services offered through the digital platform (the "Apilex Platform" or the "Platform") developed and operated by Apilex and accessible via the website, mobile application, application programming interfaces and other related digital channels. By becoming a member of the Platform or commencing use of the Platform, the User represents that the User has read, understood and accepted this Agreement.

The principal definitions used in this Agreement are as follows:

• Service: the making available to the User of the AI-Supported Legal Assistant, being a software and artificial intelligence service offered through the Apilex Platform;
• Input: any data, document, command and instruction uploaded, transmitted or entered into the Service by the User;
• Output: any text, document draft, summary, analysis or other result generated by the Service on the basis of Input;
• User Content: Input and Output collectively;
• Usage Data: technical and statistical data, such as frequency of use of the Platform, session duration and feature usage, aggregated and anonymised so as not to reveal the substance of User Content or the identity of the User;
• Beta Features: features, functions or services offered by Apilex at a preview, beta or early-access stage;
• Confidential Information: any information and document (including User Content) disclosed by one party to the other under or by reason of this Agreement, which is clearly confidential or which by its nature ought to be treated as confidential;
• Sub-Processor / Third-Party Service Provider: means cloud computing, artificial intelligence model, identity authentication and similar technology infrastructure providers from which Apilex obtains services for the operation, hosting and security of the Platform.

2. Description and Legal Nature of the Service

2.1. Scope of the Service

The Platform provides an artificial intelligence-supported automation, document generation, research and analysis tool service operating on the basis of legal texts, legislation, case law and other legal data. The Platform has been developed exclusively to support the conduct of legal work and transactions and is not available for individual or consumer use; it may be used solely within the scope of, and limited to, the professional activities of legal professionals and the legal work and transactions of legal-person users. Because the User acts in a professional capacity as a natural person or within the scope of commercial activities as a legal person, the relationship between the parties shall not be assessed under the Consumer Protection Law No. 6502; in the event of disputes, the provisions of the Turkish Code of Obligations No. 6098 and of the Turkish Commercial Code No. 6102 relating to commercial transactions shall apply.

2.2. Artificial Intelligence Limitations and Legal Nature

Artificial intelligence and machine learning are rapidly developing technologies. Apilex works continuously to make the Service more accurate, reliable and useful; however, owing to the probabilistic nature of machine learning, Output may not fully and completely reflect a real person, event or legal situation.

THE GENERATED OUTPUTS MAY CONTAIN ERRORS OR OMISSIONS AS THEY ORIGINATE FROM ARTIFICIAL INTELLIGENCE.

THE USER IS OBLIGED TO VERIFY THE OUTPUTS WITHIN THE SCOPE OF THE USER'S OWN PROFESSIONAL ASSESSMENT AND DUTY OF CARE AND TO ASSUME RESPONSIBILITY FOR DECISIONS BASED THEREON.

Output generated by the Platform does not constitute legal advice, attorney services or a legal opinion; it is not intended to predict the outcome of proceedings, to diagnose or to produce a definitive result. The Platform does not exercise the exclusive powers conferred on attorneys under the Attorneys' Act No. 1136. Apilex is not a law firm, does not practise law and does not give legal advice; accordingly, except as expressly stated in this Agreement, Apilex assumes no legal liability for Output or for information derived from the Service.

2.3. Responsibility of the User

The User accepts that any Output obtained from the Platform is only a preliminary draft and reference material, and that the User must confirm its accuracy, currency, suitability to the concrete case and legal validity. The User undertakes not to use Output in legal or official proceedings (including submission to a court, initiation of enforcement proceedings, or filing with an official authority) without the review and approval of an attorney registered with a bar association. The User accepts that, within the scope of the duty under Article 34 of the Attorneys' Act and the applicable professional rules to perform assigned duties with care, accuracy and honour, the User is obliged to check all information, suggestions and drafts provided to the User within the framework of the User's own professional knowledge and duty of care, and to take the final decision personally. Consulting a competent lawyer for final decisions and transactions is solely the User's responsibility.

For the avoidance of doubt, no Output generated under the Service may be treated as a definitive, final or binding legal opinion, an official document, an expert report, a final opinion to be submitted directly to a court, enforcement office, administrative authority or arbitral body, or as the sole basis for a decision or transaction.

3. Account, Access and Rules of Use

3.1. Membership and Account Security

To become a member of the Platform, the applicant must have attained the age of 18 and must provide the information requested in the membership form completely, accurately and in up-to-date form. The User may not, under any circumstances, allow third parties to use, or transfer, lease or sell, the account, username and password allocated to the User; the User is exclusively responsible for the security of such information. Access through a corporate/company account may be used only by authorised personnel; use outside the company is prohibited. The User shall notify Apilex immediately in the event of any suspicion of unauthorised access to the account; otherwise the User shall be liable for any resulting damage. In Corporate/Enterprise Membership, the Primary Account holder is jointly and severally liable for compliance with this Agreement by all additional users attached to the Primary Account; a breach of the Agreement by any additional user may result in the suspension or termination of the entire subscription. The User is liable for transactions carried out through the account unless it is clearly proven that the unauthorised use resulted from Apilex's fault.

3.2. Restrictions on Use

While using the Platform, the User may not: (i) use it in a manner that infringes the rights of third parties; (ii) sublicense, sell or transfer the right of use; (iii) reverse-engineer the Platform or attempt to access its source code, except where permitted by applicable law; (iv) modify, adapt or create derivative works of the Platform; (v) extract data or Output by automated or programmatic methods other than those offered by the Platform (including data scraping, data mining, use of bots and similar); (vi) use access to the Platform for the purpose of developing a competing product or service; (vii) use the Platform or Output for the purpose of training, reconstructing or imitating artificial intelligence models; (viii) engage in model extraction, prompt injection or systematic collection of output aimed at revealing the Platform's performance, architecture or model behaviour; (ix) interfere with, or attempt to interfere with, the operation of the Platform; (x) upload content that constitutes a criminal offence or is contrary to law or public morals; (xi) present Output to third parties as a final legal opinion, advisory product, legal opinion or binding work without the necessary review, verification and professional assessment.

Apilex reserves the right, in order to prevent abuse of the Service, to record the User's access logs (IP address, time of access and similar) in accordance with applicable legislation and to monitor abnormal usage behaviour. In the event of a breach of the above restrictions, Apilex may suspend or terminate the User's access without prior notice; in such case the User shall be liable for all damage that has arisen or may arise.

3.3. Beta Features

Apilex may, where appropriate, make available to the User features at a preview, beta or early-access stage. Beta Features are provided "as is and at the then-current level of availability"; no warranty is given as to availability or performance in respect of such features. Obligations relating to confidentiality, protection of personal data and information security apply equally to Beta Features. Apilex may modify, restrict or withdraw Beta Features without prior notice.

3.4. Technical Support

Technical support covers only issues arising from the Service itself; issues arising from hardware, software or internet connectivity belonging to or under the control of the User, or from applications of Third-Party Service Providers, fall outside the scope of support.

3.5. Fair Use and Excessive Resource Consumption

The User is obliged to use the Service in accordance with the principles of fair use, the scope of the relevant package/plan and the ordinary purpose of use of the Platform. In order to protect service quality, platform security and other users' ability to benefit from the Service, Apilex may monitor usage data such as query volume, transaction intensity, data volume and resource consumption in a proportionate manner and limited to that purpose. Use by the User that (i) consumes platform resources beyond reasonable use limits, (ii) performs the same operations in an unnecessary, repetitive or automated manner, or (iii) benefits from the Service beyond the scope of the package/plan, shall be deemed use contrary to the principle of fair use. Upon detection of such a situation, Apilex may, after informing the User, apply usage limits, stop the relevant operations, restrict access to features temporarily or permanently, or suspend the account. If, as a result of the User's use contrary to the principle of fair use or causing excessive resource consumption, Apilex incurs reasonable and documentable additional infrastructure, processing or artificial intelligence usage costs exceeding Apilex's ordinary service costs, Apilex reserves the right to claim recovery of such additional costs from the User.

4. Fees and Payment

4.1. The price of paid plans or packages is stated on the relevant plan/package page or in a separate order form/agreement concluded with the User. Unless otherwise stated, fees are exclusive of Value Added Tax (VAT); taxes, duties and similar charges are borne by the User.

4.2. If payment is not made when due, the User shall be in default without any further notice and default interest applicable to commercial transactions under the Turkish Commercial Code No. 6102 shall accrue. Apilex reserves the right to suspend/stop the Service until payment is made and to terminate for just cause.

4.3. Apilex reserves the right to change its pricing policy; fee changes are subject to the notice and objection mechanism set out in clause 11.10. Where the User does not exercise the right of termination under clause 11.10, no refund may be claimed in respect of fees already paid; where the User exercises the right of termination by reason of a material breach by Apilex without any fault of the User, a refund may be claimed for the unused portion between the date of termination and the end of the paid period.

5. Term and Termination

5.1. This Agreement enters into force upon the User becoming a member of the Platform or commencing use of the Platform and remains in force until the User terminates the membership.

5.2. If Apilex determines that the User has acted in breach of this Agreement, its annexes or the Platform rules of use, Apilex may, by giving reasonable prior notice, require the breach to be remedied; if the breach is not remedied or is by its nature irremediable or poses an urgent risk to Apilex, Apilex may, without prior notice, temporarily suspend or permanently terminate the User's membership.

5.3. Upon termination of the Agreement for any reason, the User's access to the Service shall be cut off. Data in the system shall, without prejudice to statutory retention obligations, be deleted in accordance with Apilex's retention and destruction policy and the provisions of KVKK (Turkish Personal Data Protection Law No. 6698); restoration of a deleted account is not possible. Upon the User's written request, Apilex shall provide the User with a written statement concerning the destruction process. The User accepts that the User alone is responsible for separately backing up the User's own information and documents.

5.4. Provisions which by their nature are intended to survive termination of the Agreement (including confidentiality, intellectual property, limitation of liability, governing law and competent courts) shall remain in force. Confidentiality obligations shall remain in force indefinitely where the relevant Confidential Information constitutes a trade secret; in other cases, for a period of at least 5 (five) years from the date of termination.

6. Intellectual and Industrial Property Rights

6.1. Rights in the Platform

The source code, software, database, design, interface, algorithms, data models, artificial intelligence infrastructure of the Platform, the "Apilex" trademark, logo and all content belonging to Apilex on the Platform are protected under the Law on Intellectual and Artistic Works and the Industrial Property Law, and all moral and economic rights therein belong exclusively to Apilex. No provision of this Agreement shall constitute an assignment or licence of such rights except as expressly stated.

6.2. Rights in User Content

All rights in User Content belong to the User. The User accepts that, in respect of content uploaded to the Platform, the User grants Apilex a limited, worldwide, royalty-free and non-transferable licence of use (sublicensing being limited to Apilex's Third-Party Service Providers) solely for the purpose of providing the Service. This licence terminates upon termination of the Agreement. The User is granted, for the term of the Agreement only and solely for the User's own needs, a simple (non-exclusive), non-transferable and non-sublicensable right of use (licence).

The User knows and accepts that Input entered into the Platform may be the same as or similar to content entered by other users, and that, owing to the nature of machine learning, Output may not be unique as between users.

6.3. Feedback and Usage Data

Any feedback, suggestion or request for improvement transmitted by the User to Apilex ("Feedback") may be used by Apilex without any obligation to pay consideration; the intellectual and industrial property rights arising from such use belong exclusively to Apilex. For the avoidance of doubt, the use of Feedback does not confer on Apilex any right in User Content, and Apilex shall not use Feedback in a manner that identifies the User.

Apilex may collect Usage Data for the purpose of developing, supporting and operating the Service. Usage Data does not in any way include User Content, and Apilex shall not share it with third parties except where it has been aggregated and anonymised.

6.4. Undertaking Regarding the Training of Artificial Intelligence Models

Apilex undertakes that it will not use the User's User Content and Confidential Information for the purpose of training, fine-tuning or developing artificial intelligence models.

7. Confidentiality and Information Security

7.1. The parties are obliged to keep confidential the Confidential Information learned within the framework of the Agreement, to use it solely for the purpose of the Agreement and to protect it with at least the same degree of care as they protect their own confidential information. Confidential Information does not include information that is in the public domain, was previously known to the recipient, was lawfully obtained from a third party, or was independently developed.

7.2. The parties may disclose Confidential Information only to their employees, consultants and subcontractors who have a need to know and who are subject to confidentiality obligations at least as strict as those in this Agreement; where disclosure is required by legislation or by a decision of a competent authority, the other party shall, to the extent possible, be informed in advance.

7.3. Apilex shall take all reasonable and proportionate technical and administrative measures to protect all processed data, including User Content, including as a minimum encryption, secure communication via SSL/TLS, regular penetration tests, an access authorisation matrix and compliance with the ISO 27001 Information Security Management System standard, and shall not reduce this level of security during the term of the Agreement.

7.4. Confidentiality obligations shall remain in force after termination of the Agreement for the periods specified in Article 5.

8. Protection of Personal Data

8.1. The User's personal data and personal data uploaded to the Platform are processed in accordance with KVKK and applicable legislation. Detailed information is available in the Privacy Notice and the Privacy Policy on the Platform.

8.2. In respect of personal data transferred to the Platform by the User in the User's capacity as Data Controller, Apilex acts as Data Processor; it processes such data solely for the purpose of providing the Service and in accordance with the User's instructions. The User is directly responsible for the obligations arising from the capacity of Data Controller (including the lawful collection of data and the informing of data subjects).

8.3. Apilex may transfer personal data to Sub-Processors from which it obtains services for the operation of the Platform. The User may at all times access the current list of Sub-Processors via the "Sub-Processor" table published on the website. Cross-border data transfers are carried out within the framework of Article 9 of KVKK and the regulations of the Board (standard contract, explicit consent or other appropriate transfer mechanisms).

8.4. In the event of a personal data breach, Apilex shall notify the Personal Data Protection Authority and/or the affected User no later than 72 (seventy-two) hours from the moment it becomes aware of the breach.

9. Warranties, Indemnity and Limitation of Liability

9.1. Nature of the Information

All information and Output presented on the Platform are provided "as is" and "as available". Apilex gives no express or implied warranty as to their accuracy, completeness, currency or fitness for a particular purpose. As legal legislation and case law may change continuously, the obligation to check the currency of the information rests with the User.

9.2. Service Warranty and Exclusion of Liability for User Error

Apilex aims for the Service to be available at a rate of 99% on a calendar-month basis. This rate does not constitute a warranty or a firm commitment and expresses Apilex's obligation of commercially reasonable efforts; it does not give rise to any financial compensation mechanism (service credits, invoice discounts or similar). Planned maintenance work and updates (provided they are notified in advance), force majeure and interruptions originating from Third-Party Service Providers are not included in the calculation of this target. Apilex does not undertake that the Service will be uninterrupted, error-free, secure or free from viruses. Apilex cannot be held liable for any direct or indirect damage arising from the User's incorrect use of the Platform, entry of incorrect/incomplete data, or use of Output without checking it or without consulting a lawyer; use of Output without review by an attorney shall be deemed gross negligence of the User.

9.3. Mutual Indemnity Obligations

The User warrants that Input uploaded, entered or processed on the Platform is lawful and does not infringe the intellectual property, privacy or other rights of third parties; otherwise the User is directly liable to Apilex for any compensation, administrative fine and litigation costs that may arise, and shall, upon first demand, reimburse Apilex by way of recourse for amounts that Apilex is obliged to pay to third parties for this reason.

If it is established by a final court decision that use of the Platform in accordance with this Agreement infringes a third party's intellectual property right, Apilex shall cover the compensation and litigation costs that the User is obliged to pay pursuant to that decision; however, this obligation shall not apply where the infringement arises from the User's Input, from use contrary to the Agreement, or from a source other than Apilex.

If a party becomes aware of a third-party claim, official authority notification, lawsuit or administrative process that may give rise to an indemnity claim under this Article, it shall inform the other party in writing within a reasonable time and shall provide the claiming party with a reasonable level of information, documents and cooperation in the defence process. Delay in notification shall affect the indemnity obligation only to the extent that the ability to defend has in fact been materially impaired by reason of that delay.

10. Force Majeure

Events that substantially affect the performance of obligations arising from the Agreement, that develop beyond the control of the parties, and that are unforeseeable and unavoidable, such as disaster, fire, flood, earthquake, epidemic (pandemic), war, acts of terrorism, cyber-attacks, general strike and lock-out, shall be deemed force majeure. The party affected by force majeure shall notify the other party within a reasonable time and shall make the necessary efforts to minimise its effects. During the period of force majeure the parties' obligations may be suspended; if force majeure continues for more than 30 (thirty) days, each party shall have the right to terminate the Agreement without compensation.

11. Miscellaneous Provisions

11.1. Relationship between the Parties: The parties act independently of each other; this Agreement does not in any way create a partnership, representation or agency relationship.

11.2. Assignment: Apilex may assign its rights and obligations to an affiliate or successor company, provided that it notifies the User.

11.3. Use of Subcontractors: Apilex may use Third-Party Service Providers/subcontractors for the provision of the Service. Such use does not remove Apilex's status as the sole counterpart of the User under the Agreement; the User shall address requests and notices relating to the Service directly to Apilex and not to the subcontractor. However, Apilex's liability in respect of performance issues, interruptions or breaches originating from Third-Party Service Providers is subject to the exceptions, exemptions and caps set out in Article 9 of this Agreement; this clause does not give rise to any liability broader or unlimited compared with that provided in Article 9.

11.4. Use as a Reference: The User permits the use of the User's trade name and logo in marketing materials for reference purposes, limited to the wording "Apilex customer/user"; this permission shall be withdrawn within a reasonable time upon the User's written request.

11.5. Waiver: Failure by a party to exercise, or delay in exercising, a right arising from the Agreement shall not constitute a waiver of that right.

11.6. Severability: If any provision of the Agreement becomes invalid or unenforceable, the validity of the remaining provisions shall not be affected; the parties shall make good-faith efforts to agree on a new provision that best serves the purpose in place of the invalid provision.

11.7. Admission of Evidence: Written, printed and electronic records made between the parties through official communication channels, e-mail and instant message records, and Platform records, access logs, transaction records, payment records and electronic approval records, are accepted as conclusive and binding evidence in the context of procedural law pursuant to Article 193 of the Code of Civil Procedure (HMK).

11.8. Notices: The e-mail address notified by the User at the time of membership is accepted as the legal address for notices; general notices sent to that address shall be deemed valid. Notices of termination between the parties shall be made by notary, registered letter with return receipt, or KEP (Registered Electronic Mail). Following a notice of termination, the Service Fee accrued as of the date of termination shall be paid in full to Apilex, and no refund of fees paid up to the date of termination may be claimed.

11.9. Entire Agreement: This Agreement, together with the policies referred to in its annexes and on the Platform (Privacy Policy, Privacy Notice, Cookie Policy and similar), constitutes a whole and forms the entire agreement between the parties. If a separately signed Service Sales Agreement or other written agreement exists between the User and Apilex, the provisions of that special agreement shall prevail to the extent they conflict with these Terms of Use and solely within the scope of that special agreement; on matters that do not conflict, these Terms of Use shall remain in force as complementary provisions.

11.10. Amendments and Right of Objection: Apilex reserves the right to amend the provisions of this Agreement and its pricing policy unilaterally at any time. Amendments enter into force as of the date they are published on the Platform or notified to the User by e-mail. If the User finds an amendment substantially adverse, the User may terminate the membership within 15 (fifteen) days from the date of notice; a User who does not exercise the right of termination within that period and continues to use the Platform shall be deemed to have accepted the amendments.

12. Governing Law and Competent Courts

The laws of the Republic of Türkiye shall apply to the interpretation and performance of this Agreement. The Courts and Enforcement Offices of Istanbul (Çağlayan) shall have exclusive jurisdiction for the resolution of any dispute that may arise between the parties.

13. Entry into Force

This Agreement, consisting of 13 articles, enters into force upon the User becoming a member of the Platform or commencing use of the Platform and is deemed accepted by the User in all its provisions. This agreement is drawn up in electronic form and is valid under the Turkish Code of Obligations No. 6098.

Last updated: 21 July 2026

This agreement is drawn up in electronic form and is valid under the Turkish Code of Obligations No. 6098.