Donation and Affiliate Transparency Policy

1. Purpose

To explain simply and accurately how shopping through the hangel market turns into support for NGOs, and to say clearly what exists and what does not.

2. Scope

The hangel market, affiliate networks and partner brands, users' choice of NGOs and transfers to NGOs.

3. Principles — how the model works

1. The brand pays a commission; it is not a donor. hangel makes commission agreements with brands or affiliate networks. The commission the brand pays hangel is the rate shown in the market as the "donation rate".
2. No money comes out of the user's pocket. The user shops on the shop's own website at the shop's price; hangel adds no fee to the price.
3. The commission first arrives in hangel's account. Once the purchase is confirmed by the shop and the network, the commission is collected in hangel's account.
4. The remaining amount is transferred to the NGO chosen by the user, on the user's behalf. After taxes and hangel's share are deducted, the remaining amount is transferred, in line with the user's choice, in equal parts to up to two NGOs (associations, foundations or sports clubs) the user selected in advance. In the bank transaction, the sender is hangel.
5. What does not exist. hangel has no direct cash donations, no payroll giving and no employer matching. Users cannot donate money to an NGO through hangel.
6. No promise of tax relief. No tax deduction is promised to users.

4. Roles and responsibilities

• Super-admins (finance): manage rates, monitor reconciliation and record transfers.
• Board of Directors: responsible for the model and this policy.
• NGO administrators: provide correct institutional bank details and record incoming transfers in their own books.

5. How it works at hangel today

• Calculation: In the default settings, income tax (20%) and VAT (20%) are deducted from the gross commission; the remaining net amount is divided between the NGO share and hangel's share, with hangel's share equal to 10% of the NGO share. Example: on a commission of 100 TL, taxes are 40 TL, the NGO share is about 54.55 TL and hangel's share about 5.45 TL; if two NGOs were chosen, each receives about 27.27 TL. Rates can be changed by a super-admin.
• Statuses: The amount is not final until the shop confirms the purchase; for returns and cancellations the contribution is corrected. Users see their contributions and their status on the "My Donations" page.
• Reconciliation: Every day, conversions reported by the network for the last 35 days are compared with platform records.
• Transfer: At month end, amounts are transferred manually by bank transfer to the NGO's institutional bank account; a payout record is created and the NGO's administrator is notified.
• Account deletion: The donation records of users who delete their account remain as financial records, with the link to the person removed.

6. Not yet in place and our goals

• Legal review: The legal nature of making transfers on the user's behalf (including under Türkiye's Law No. 2860 on Aid Collection), in whose name receipts are issued and the tax consequences are under review by our lawyer.
• Difference from existing texts: The existing "Donation and Affiliate Policy" and the Privacy Policy describe the donation as "a donation hangel makes from its own commission income, in its own name". This policy describes the transfer as made on the user's behalf. The two descriptions need to be brought together into one after the legal review.
• Market label: The "donation rate" shown in the market is the gross commission rate; the amount reaching NGOs is about half of it (54.5% with the default rates). Our goal is to also show the approximate amount reaching NGOs on the cards.
• There is no public report showing the total amount transferred across the platform.

7. How to raise a concern

Questions about amounts, status or transfers: destek@hangel.org. Suspected misconduct: kvkk@hangel.org (subject "Whistleblowing — Confidential").

8. Review

At least once a year; whenever rates change and when the legal review is concluded.

9. Related documents

Financial Transparency Policy · Existing "Donation and Affiliate Policy", "Donation and Aid Policy" and "Supporter Rights Declaration" · Brand Membership Agreement · NGO Membership Agreement