Terms of use | Notion

(last updated on October 20, 2025)

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 compiled these Terms of Use (hereinafter referred to as the “Terms”) to govern the use of its applications and interfaces (collectively, the “Apps”), including the Telegram Mini App (“MA”) and the Progressive Web Application (“PWA”), which allow users (hereinafter referred to as the “Users” or “you”) to access its services and products (hereinafter referred to as the “Services” and “Products”) through various digital platforms, including but not limited to Telegram Messenger Inc. (hereinafter referred to as “Telegram”) and compatible web browsers.

ACCEPTANCE OF TERMS By using MA/PWA and our Services and Products through it, you agree that you have read in full, understood and accepted to be legally bound by the terms contained herein. We may, at our sole and absolute discretion and without liability, at any time and without notice, introduce changes to MA/PWA and modify Terms in any way we deem necessary. We hold no liability for how these changes may affect access to MA/PWA, as well as Services and Products offered in it. Your continued access to and use of MA/PWA shall constitute your acceptance of these Terms, including any updates or modifications to them.

TELEGRAM When you connect to MA, you may be further subject to Telegram’s terms of use, which are to be considered in addition to this document and are subject to periodical revisions on the part of Telegram. Although MA operates independently of Telegram, it relies on the platform’s proper functioning. Therefore, Developer shall not be held responsible for interruptions in Telegram’s operations, security breaches in resulting from vulnerabilities in Telegram’s code, changes in Telegram’s policies and any of their adverse consequences. Since your account on Telegram (hereinafter referred to as “TGA”) serves as the identification we use to grant you access to our MA, you fully acknowledge and explicitly assume any and all risks related to the security of your TGA. Developer may offer security guidelines; however, they are not to be viewed as formal advice. Should you discover that someone else has gained control to a device with access to your TGA (hereinafter referred to as “Trusted Device”), you shall bear the sole responsibility for taking all appropriate measures to prevent unauthorized access of that person to our MA, including, but not limited to resetting the password and logging out of devices over which you do not exercise the sole control. You agree to exempt Developer from any liability for any losses resulting from such incidents.

PROGRESSIVE WEB APPLICATION When you access our Services via the PWA, you do so through your web browser and internet connection. The PWA operates independently of Telegram and relies on the proper functioning of your browser, operating system, and network connection. The Developer applies reasonable technical and organizational measures to ensure the security and continuous operation of the PWA, including appropriate encryption, access control, and system monitoring. These measures are designed to protect data integrity and prevent unauthorized access within the scope of our control. However, you acknowledge that the use of the PWA involves certain risks inherent to internet-based services, such as connection interruptions, browser vulnerabilities, or unauthorized access to your device. The Developer cannot be held responsible for failures, errors, or security breaches caused by factors beyond its reasonable control - including issues related to third-party browsers, devices, internet providers, or malicious software present on your device. You are solely responsible for maintaining the confidentiality of your credentials and securing the device used to access the PWA. Should you discover that your browser session, password, or device has been compromised, you shall take immediate measures to prevent unauthorized access, such as changing passwords, logging out of active sessions, and ensuring the physical and digital security of your device. To the extent permitted by applicable law, the Developer’s liability is limited to ensuring the proper functioning and reasonable security of the PWA itself, and it shall not be liable for any indirect losses arising from external factors or your failure to take reasonable precautions.

SERVICES AND PRODUCTS MA/PWA encompasses a range of services and products, including but not limited to:

custodial wallet (hereinafter referred to as “Wallet”) and tools for its management;
payment cards and their management through a dedicated dashboard (hereinafter referred to as “Card Account”);
referral program. Wallets and Card Accounts are established and maintained by us for the sole purpose of providing Services and Products. Under no circumstances should the provision of Wallets and Card Accounts be interpreted as offering a banking service, or a stored value facility of any kind. Nor shall any of the information in MA/PWA construed as financial advice. Developer reserves the right to update, modify, discontinue, suspend, disable, or restrict access to any of those Services and Products, as well as separate features, components or content thereof at any time, for any reason, without notice or liability to the user.

THIRD-PARTY SERVICE AND PRODUCT PROVIDERS When providing some of Services and Products to Users Developer relies on third-party providers (hereinafter referred to as “TPPs”). Those include, without limitation, processing providers, banks, exchanges, data storage facilities, as well as software development companies. TPPs have their own terms of use and policies, whose change may lead to change in these Terms. Developer shall not be held accountable for any consequences of TPPs’ changes in their terms and policies, which result in respective changes in these Terms. Nor shall Developer be liable for any interruptions, limitations or deficiencies in Services or Products caused by interruptions, limitations or deficiencies in TPPs’ services and products it relies upon.

ACCESS TO SERVICES AND PRODUCTS To be able to use Services and Products, User shall run MA/PWA on a Trusted Device. By accessing MA/PWA, you warrant that:

You understand that the Services are not available in certain jurisdictions due to applicable regulatory limitations. Without limitation, the Services are not intended for, and shall not be accessed or used by, any person who is located in, resident in, or subject to the laws of the United States, the European Union, the United Kingdom, or the United Arab Emirates, or any other jurisdiction where the access to or use of the Services is prohibited or restricted by applicable law.
You are accessing MA/PWA on your own initiative without active promotion and/or solicitation from us, any of its companies, employees and/or any of its affiliated, associated or connected persons.
You have read, understood and agreed to our Privacy Policy as well as these Terms.