Agreement Governing Digital Subscription Services

Distance Sales Agreement

The parties’ rights and obligations concerning the sale and performance of The Neural Ledger digital subscription services.

Effective date: 5 August 2026

Article 1 – Parties

This Distance Sales Agreement (the “Agreement”) is entered into between, on the one hand, Piyote Bilişim ve Danışmanlık Hiz. Tic. Ltd. Şti. (the “Seller”), a company registered with the Kozyatağı Vergi Dairesi under tax number 7300360278, Trade Registry No. 776383-0 and Mersis No. 0730036027800017, with its registered office at İçerenköy Mah. Üsküdar-İçerenköy Yolu Cad. Bodur İş Merkezi No: 8 İç Kapı No: 11, Ataşehir / İstanbul 34638, Türkiye, and, on the other hand, the individual or legal entity (the “Buyer” or “Member”) who places a membership/subscription order electronically through the website theneuralledger.com (the “Site”). This Agreement is deemed concluded at the moment the Buyer confirms the order electronically. The Seller may be contacted by telephone at +90 552 627 44 42 and by e-mail at [email protected].

Article 2 – Definitions

For the purposes of this Agreement, the following terms shall have the meanings set out below: “Ministry” means the Turkish Ministry of Trade; “Law” means Turkish Law No. 6502 on the Protection of Consumers; “Regulation” means the Distance Contracts Regulation; “Site” means the website located at theneuralledger.com; “Service” means the digital subscription service offered through the Site and described in Article 4; “Member” means the individual or legal entity who purchases the Service by registering on the Site.

Article 3 – Subject Matter and Scope

The subject matter of this Agreement is to determine the mutual rights and obligations of the parties, pursuant to the Law and the Regulation, in connection with the sale and performance of the digital subscription service ordered electronically by the Member through the Site, the characteristics and price of which are published on the Site. The Member acknowledges that, prior to placing an order, they were informed through the Site of the essential characteristics, sale price, payment method and terms of performance of the Service, and that the order is placed only after such information has been confirmed.

Article 4 – Description and Characteristics of the Service

The Service is a digital subscription service, performed entirely by electronic means, offered through The Neural Ledger platform, the scope of which varies depending on the plan selected and may include access to a global markets and geopolitical intelligence archive, the Ledger AI Terminal question-and-answer function, and/or an API call quota. The current scope, usage limits and prices of each plan are published at theneuralledger.com/subscribe and form an integral part of the order.

Article 5 – Fees, Payment Terms and Billing

The fee for the Service is the amount displayed to and confirmed by the Member at the time of ordering, charged on a monthly or annual basis depending on the plan selected. Payments are collected, through the virtual POS infrastructure of the authorized banking and payment institution(s) engaged by the Seller, from the credit or debit card designated by the Member. Unless the Member indicates otherwise, the Member agrees that the subscription will renew automatically at the end of each period and that the registered payment instrument will be charged again. The Member may stop automatic renewal at any time through the account/billing panel, in which case renewal will not occur for the following period only.

Article 6 – Manner and Time of Performance

As the Service does not involve any tangible goods, it is not shipped or delivered by courier. Following confirmation of payment, the Member’s account is automatically upgraded to the selected plan, and the Service becomes available through the Site and/or the API immediately or, at the latest, within a reasonable period. Further details of performance are set out in the Seller’s separately published Digital Service Delivery Information.

Article 7 – Right of Withdrawal

Pursuant to Article 15(1)(ğ) of the Distance Contracts Regulation, consumers do not have a right of withdrawal in respect of contracts for services performed immediately in electronic form and for intangible goods delivered to the consumer instantaneously. By confirming an order, the Member acknowledges and agrees that performance of the Service will begin immediately upon completion of payment, at the Member’s express request and with the Member’s consent, and that the Member will therefore not be able to exercise a right of withdrawal. Prior to upgrading to a paid plan, the Member may evaluate the free (Free) version of the Service for as long as they wish.

Article 8 – Termination and Cancellation of the Subscription

The Member may cancel their subscription at any time, without stating any reason, through the account panel. Cancellation only stops the automatic renewal charge for the following period; access already paid for continues until the end of the then-current billing period. Refund terms are set out in the Seller’s separately published Cancellation and Refund Policy. The Seller reserves the right to suspend or terminate the Member’s access to the Service, upon prior notice, where the Member acts in breach of this Agreement, the Site’s Terms of Use, or applicable law.

Article 9 – Representations and Undertakings of the Buyer

The Member represents and undertakes that the identity, contact and payment information provided at the time of ordering is accurate, current and belongs to the Member, that account access credentials will not be shared with third parties, and that the Service will be used in accordance with applicable law and the Site’s Terms of Use.

Article 10 – Force Majeure

Natural disaster, fire, epidemic, war, mobilization, act of terrorism, strike, lockout, cyberattack, infrastructure or power outage, and similar events beyond the Seller’s reasonable control and which could not have been foreseen, shall be deemed force majeure. Neither party shall be liable for any failure to perform its obligations for as long as such force majeure event continues.

Article 11 – Protection of Personal Data

Personal data belonging to the Member is processed by the Seller in accordance with Law No. 6698 on the Protection of Personal Data. The categories of data processed, the purposes and legal grounds of processing, and the Member’s rights are set out in the Seller’s separately published Personal Data Protection Notice (KVKK Clarification Text).

Article 12 – Dispute Resolution and Governing Law

This Agreement is governed by the laws of the Republic of Türkiye. Disputes arising from this Agreement shall be subject to the jurisdiction of the Provincial or District Consumer Arbitration Committees of the Member’s place of residence, within the monetary limits announced annually by the Ministry of Trade, and to the Consumer Courts for disputes exceeding such limits.

Article 13 – Effectiveness and Acceptance

By completing the order/payment step, the Member electronically declares that they have read all articles of this Agreement, understood its content, and accepted all of its terms. The Agreement becomes effective between the parties at the moment such confirmation is given, and a copy of the Agreement remains accessible to the Member at all times through the Site or by e-mail.

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