(last updated on October 12, 2025)

GENERAL PROVISIONS

  1. X-pay Software Limited (hereinafter referred to as the “Developer” or “we”), a company duly incorporated under the laws of the Republic of Seychelles, having company number 238654 and its registered office at 306 Victoria House, Victoria, Mahé, Seychelles, has developed this Privacy Policy (hereinafter referred to as the “Policy”) to regulate the collection, storage, use, distribution, and protection of information pertaining to persons who use its applications and services (hereinafter collectively referred to as the “Apps”), including the Telegram Mini App (“MA”) and the Progressive Web Application (“PWA”).
  2. The current version of this Policy is made available at the start of the App’s use and remains accessible within both the MA and PWA interfaces.
  3. Your continued access to and use of the Apps shall constitute your acceptance of this Policy.
  4. If you do not accept any provisions of this Policy, you shall immediately cease your use of the Apps and any associated Services.

TERMS AND DEFINITIONS

  1. Developer – X-pay Software Limited, a company duly incorporated under the laws of the Republic of Seychelles, having company number 238654 and its registered office at 306 Victoria House, Victoria, Mahé, Seychelles.
  2. Apps – all interactive software applications operated and maintained by Developer, including but not limited to the Telegram Mini App (“MA”) and the Progressive Web Application (“PWA”), which allow Users to access Developer’s services and products through various digital platforms.
  3. Telegram – Telegram Messenger Inc., a third-party platform through which Users may access the MA.
  4. User – a person accessing the Apps, whether via Telegram, a web browser, or any other supported platform (also referred to as “you”).
  5. Personal Data – any information that the User may be requested or choose to provide to Developer during the use of the Apps, including but not limited to full name, type and number of identity document (e.g. passport), gender, date of birth, place of birth, nationality, residential address, country of residence, purpose of use, sources of income, nature and details of occupation or business, contact information (such as phone number and email address), transaction and expense history, blockchain address, and other personal or financial data required for providing or maintaining the Services.
  6. Trusted Device – any device (mobile, desktop, or browser environment) used by the User to access the Apps, which the User reasonably believes to be under their exclusive control.

DISCLAIMERS

  1. Developer’s Apps, including both the MA and PWA, are operated independently by X-pay Software Limited. While the MA relies on Telegram’s infrastructure, it is neither maintained, endorsed, nor affiliated with Telegram Messenger Inc. The PWA operates independently via web browsers and is not affiliated with any browser or operating system provider.
  2. You understand and agree that this Policy may be updated from time to time at Developer’s sole discretion, and it is your responsibility to review and accept any amendments. Continued use of the Apps after such updates shall constitute your consent to the revised Policy.
  3. You acknowledge that you have read, understood, and agreed to this Privacy Policy, the Terms of Use, and any other applicable policies made available to you by Developer.
  4. You acknowledge and warrant that you possess all necessary rights and permissions to use the Apps in compliance with all applicable laws, including but not limited to age restrictions, data protection requirements, and any third-party platform terms (such as those of Telegram or your browser provider).
  5. Developer operates on the presumption that all information you provide is true, accurate, and up to date. Developer is not obliged to verify the accuracy of your statements but reserves the right to request supporting documentation when necessary for compliance or risk prevention purposes.
  6. If you choose to make any personal information public, whether directly through Telegram, via the web version, or through third-party integrations, you acknowledge that such information may become accessible to others and will no longer fall under the protection of this Policy.