This page explains how Tapylapy protects itself and its users from fraud and money laundering, how gifts and rewards work on the platform, and when and how rewards may become withdrawable.

1) Scope & Who We Are

This policy applies to all coin top-ups, gift sending and receiving, and any current or future rewards or withdrawal activity on Tapylapy. It is read together with our Terms of Service and Refund & Coins Policy.

2) Purpose of This Policy

This policy is designed primarily to protect Tapylapy, SULTAN X LTD, and its users from fraud, money laundering, financing of unlawful activity, and misuse of the gift and reward system. We apply reasonable verification and review procedures before approving any withdrawable reward request, or when we detect financial activity that raises a reasonable concern, to help ensure money on the platform is used lawfully. Sending an ordinary gift does not require upfront identity verification; verification is required only from a creator requesting to convert rewards into a withdrawal.

3) Customer Due Diligence (CDD)

Before enabling any financial feature that requires verification (such as a withdrawable reward request), we may ask you for:

• Your full legal name as shown on a valid official ID document.
• A clear photo of a valid government-issued ID (national ID, passport, or equivalent).
• A date of birth confirming you are at least 18 years old.
• An active phone number and email address linked to your account.
• Confirmation that any bank account or e-wallet linked to a reward request is registered in your own personal name.
• A live "selfie" photo taken at the time of verification, compared against your ID document photo to confirm they match.

Automated AI-based photo comparison: matching your selfie against your ID photo is performed using automated image-analysis technology, via an approved third-party AI provider (we default to OpenAI, and may occasionally use Cloudflare as a technical alternative for internal testing). Both images are sent to the provider solely for comparison and are not used for any other purpose. Our internal admin panel also offers a third technical option: self-hosted, internal processing that compares the photos without sending them to any external party at all; this option is currently used for internal testing only and is not the default in the production environment. Any borderline or inconclusive result is subject to additional manual review by our team before we accept or reject the verification. See our Privacy Policy — Who We Share Data With for more on our AI service providers.

In addition to initial verification, verified accounts undergo periodic re-verification approximately every 30 days, through an automated AI comparison between a new selfie and the last approved selfie, to confirm the account holder's identity continues to match. The selfie of each re-verification cycle is deleted as soon as that cycle's outcome is decided (approved, finally rejected, or verification withdrawn), unless an active dispute or investigation requires otherwise. The ID and selfie photos of an approved verification are kept while your account is active and for up to 5 years after it is closed (see Section 6), while the photos of a rejected or revoked verification are wiped at once. We do not store a face template or any biometric template: the comparison is done by sending the two images to the comparison service, and nothing is kept from its output. A single failed periodic re-verification attempt does not, by itself, immediately cost you the verification badge; the account may retry (up to once per day) throughout a reasonable grace period before any final action is taken, and only failing to complete verification successfully within that entire period removes the verification badge, and only the badge, without affecting Verified Creator status (see Sections 10 and 11 and the reasons for withdrawing the badge below).

"Verified Creator" status and the verification badge are two different things. "Verified Creator" is the earnings status: it is granted after you pass the financial identity (KYC) verification described in this policy and Tapylapy approves you, and it does not depend on keeping the verification badge or on the monthly re-verification; it alone is what makes your earnings withdrawable. The verification badge (blue or gold) is a public mark showing that the account belongs to a known user with real, verified information; on its own it does not make you a creator and does not allow withdrawals. The monthly re-verification belongs to the badge only: if you miss it after the grace period, or an administrator withdraws the badge, only the badge is removed, and you remain a Verified Creator with your eligible coins and any pending withdrawal request intact. Verified Creator status is removed only by a decision of Tapylapy about the creator status itself (for example an administrator rejecting or revoking it for violations, fraud or AML reasons). If you lose Verified Creator status on that basis: the coins you had earned that were eligible for cash withdrawal become non-withdrawable (they stay in your wallet and can still be spent inside the app, for example on gifts, support and in-app purchases, but can never be cashed out); any pending withdrawal request is cancelled and its coins are returned to your wallet; and if Tapylapy approves you again later, only coins you earn after the new approval are withdrawable. See Sections 10 and 11 for details.

There are two tiers of the social verification badge: Blue Verification, available to any user who submits an application with a valid government-issued ID (front and back) and a live selfie automatically matched against it, granted based solely on confirming identity authenticity with no minimum follower or view count required; and Gold Verification, an upgrade normally available to an account that already holds Blue Verification, which requires selecting a category describing your public role (such as politician, political entity, artist, athlete, actor, singer, company or its management, businessperson, notable public figure, media professional, journalist, known influencer, or another category described at the time of application) and submitting an additional selfie, granted based on Tapylapy's own review and discretion. Neither tier requires a specific number of followers or views as an eligibility condition. The categories, criteria, or process for either tier may change, in line with the notice of changes described in Section 15. Revoking Gold Verification removes the badge entirely (the account does not automatically revert to Blue Verification), unless Tapylapy decides otherwise at its discretion. See our Privacy Policy regarding the ability to grant either tier directly to well-known individuals without a formal application.

An applicant for either verification tier (Blue or Gold) must be 18 years of age or older, based on the date of birth shown on the official ID document submitted with the application; any application whose submitted document shows the applicant has not reached this age is automatically rejected, regardless of the purpose of the application or the category selected for Gold Verification.

The following are the complete and sole reference for the reasons a verification badge (Blue or Gold) may be withdrawn: (a) Tapylapy discovering that the badge was granted based on false or impersonated information, or invalid documents; (b) missing the approximately every-30-day periodic re-verification described above once the grace period has ended (which removes the badge only and does not affect Verified Creator status); (c) the account holder committing a "serious violation," as defined in the Terms of Service; or (d) at Tapylapy's own discretion, for any other operational or compliance reason, with or without prior notice where practicable.

4) Enhanced Due Diligence (EDD)

For higher-value transactions or higher risk indicators, we may request additional verification, including but not limited to:

• Proof of current residential address.
• An explanation of the source of funds or the activity that generated the balance or gifts received.
• Additional supporting documents or a short call/video verification to confirm identity.

Failure to provide requested information within a reasonable time may result in the relevant transaction being delayed, declined, or cancelled.

5) Sanctions Screening & Monitoring

We apply reasonable measures designed to help identify individuals or entities subject to applicable international sanctions, watchlists, or politically-exposed-person (PEP) status, and may decline or delay a transaction where a credible match or reasonable risk indicator is identified.

We also monitor top-up, gift, and reward-request patterns to detect unusual behavior, such as an account suddenly receiving an unusually large volume of gifts, or a network of accounts artificially exchanging gifts with each other.

In addition to screening platform users, we apply reasonable internal screening procedures before transferring any rewards through the international payment providers used to pay creators directly, to help ensure compliance with applicable international sanctions lists (such as the US OFAC lists and the UK HM Treasury list); we may decline or delay any transfer that raises a reasonable concern under these lists, without obligation to explain the reason.

6) Record-Keeping

We keep verification and financial-transaction records related to coin top-ups, gifts, or reward requests for up to 5 years after your account is closed, for compliance and fraud-prevention purposes. In detail (see also our Account Deletion Policy): deleting your account is immediate and permanent and removes your profile, wallet, transactions, earnings and coin orders; what remains afterwards is only: (a) an anonymised deletion record; (b) anonymised financial ledger entries that carry no personal identifier; (c) approved identity-verification records, including their photos, for up to 5 years after the account is closed (rejected or pending verification records are deleted at once); (d) reports about the account together with the identity details saved at the time of the report, and abuse-prevention records (such as IP or device blocks); and (e) email delivery logs (recipient, subject, status).

7) Cooperation With Authorities

We cooperate with law enforcement and competent regulatory authorities upon receipt of a valid legal request, and we may report suspicious activity through lawful channels available to us, in accordance with applicable law in each relevant jurisdiction.

8) Our Regulatory Status — Plain Disclosure

Reward funds that are due but not yet withdrawn are held within the Company's ordinary operating accounts. They are not segregated in a separate escrow account and are not insured separately from SULTAN X LTD's own assets; because the Company is not a licensed e-money institution or bank, any accrued and unwithdrawn reward balance remains, in principle, exposed to the Company's general financial risk until it is successfully withdrawn.

Reward withdrawal payments are executed through Tapylapy's own commercial accounts with payment providers (such as the PayPal business account registered in SULTAN X LTD's name), as the ordinary fulfillment of a contractual obligation owed to the content creator under this policy — not as a payment or money-transmission service provided to a third party. Neither Tapylapy nor SULTAN X LTD acts as a payment institution or a licensed e-money issuer, and neither holds users' or creators' funds as a deposit, in trust, or in a custodial capacity; until successfully withdrawn, any accrued reward balance remains simply an ordinary, unsecured contractual claim against SULTAN X LTD, not a protected cash deposit or an independently owned asset.

Tapylapy reserves the right to temporarily suspend coin top-up channels (including purchases via Apple, Google, PayPal, card payment, or any other method), in whole or in part, for any operational reason (such as technical maintenance, a compliance review, or an outage at a payment provider), with no obligation of prior notice. If a top-up channel is suspended while a purchase the user has already completed with Apple, Google, PayPal, or by card is still pending, Tapylapy commits to resolving that purchase once service resumes; if a completed purchase cannot be delivered, we will deliver the coins owed or refund the amount ourselves. We may also point the user to the store's own refund process where that is the faster route, but that does not remove our obligation to deliver the coins or refund the amount.

9) Gifts — How They Work Today

Gifts are currently available on Tapylapy as a way for users to show appreciation to creators during live streams or on posts:

• You top up your Tapylapy balance, and the amount converts into Tapylapy coins. Coins can be bought through Apple In-App Purchase (iOS), Google Play Billing (Android) and, where we offer them, PayPal or card payment through our payment providers.
• You choose a digital gift and send it to a creator in one tap, as a voluntary expression of appreciation.
• A gift is not payment for a service or good, is not an investment, and is not a payment method for any purpose outside the platform.
• Platform commission on gifts: the full value of a gift does not convert into the receiving creator's reward balance — Tapylapy retains a portion as a service commission (covering live-streaming operation, payment processing, and platform maintenance), and only the remaining portion is added to the creator's reward balance, which may later be converted to USD. Tapylapy may adjust the gift-commission percentage; any adjustment applies only to future gifts and has no retroactive effect on gifts already received before the adjustment takes effect. The current percentage is shown in the app, and any change to the commission, thresholds, or criteria is communicated in the app or by email before it applies to new earnings, under the notice terms in Section 15.
• Which coins become withdrawable: the recipient is credited the gift's coin value minus the platform commission, and it makes no difference whether the sender paid with purchased coins or free coins (from tasks or the lucky wheel). Those coins are withdrawable only if the recipient is an approved Verified Creator at the moment the gift arrives; otherwise they are spendable inside the app but never withdrawable. Free or reward coins that a user owns themselves are never withdrawable.
• Live ended by force: if a live stream is ended by force (by an admin, by moderation, by an account ban, or by the system), gifts already received stay with the recipient and are not reversed, and senders are not refunded. Only unopened treasure-box coins are refunded, where applicable.

10) Rewards

Verified creators may receive rewards from Tapylapy based on their activity on the platform — most notably their live-streaming hours, views on their content, and gifts/support received from their followers — under the platform's own criteria (unrelated to any advertising or third-party sponsored content). These rewards:

• Represent a discretionary reward granted by the platform under its own policy — not wages, a salary, or income from a direct business activity with Tapylapy.
• Do not create any employment, agency, or partnership relationship between the user and Tapylapy or SULTAN X LTD.
• Do not guarantee a fixed or ongoing value, and Tapylapy may change the criteria for calculating rewards; such changes are communicated in the app or by email before they apply to new earnings, under the notice terms in Section 15, and the current rates and thresholds are shown in the app.
• Are the user's own responsibility for any tax obligations arising in their country.

Creator Independence — A Free Creator, Not an Employment Relationship

The rewards program is built on full creator independence and does not resemble an employment relationship in any respect. You retain complete control over your content, your time, and your activity:

• No mutual obligation: Tapylapy is not obligated to guarantee any minimum views, gifts, or rewards, and the creator is not obligated to post, stream, or maintain any schedule or activity level.
• No exclusivity: Creators may use any other platform or earn income from any other source in parallel with Tapylapy, without restriction.
• No supervision of how the work is done: Tapylapy does not set working hours, location, or method for producing content; creators use their own equipment and devices and decide freely when and how to post.
• Eligibility criteria are for compliance purposes only: the identity-verification and minimum follower/view requirements (next section) are anti-fraud and compliance measures only, not performance management or employee evaluation.

The controls, conditions, and protective measures (such as freezes or eligibility review) described in this policy are anti-fraud and financial-system-integrity measures only, and do not in any way constitute supervision or control over how a creator does their work, and do not create an employment or agency relationship; Tapylapy has no obligation to provide any work, a minimum level of opportunities, continuity, or exclusivity to any creator.

Which Coins Are Actually Eligible for Withdrawal?

Not every coin sitting in your wallet is a "withdrawable reward." Tapylapy internally separates coins that genuinely result from your activity and your community's support, from other coins that are spendable inside the app only. Coins that can later be converted to USD (once you meet the verification and minimum-threshold requirements in the next section) are limited strictly to these four sources:

• Live-hour earnings: the reward calculated on your actual qualifying live-streaming hours.
• Post-view earnings: the reward calculated on views of your qualifying posts.
• Gifts received during a live stream: your share of the value of gifts sent to you by viewers during your broadcast, net of the platform commission described in Section 9, provided you are an approved Verified Creator at the moment the gift arrives; it makes no difference whether the sender paid with purchased or free coins.
• Support/tips received on your posts: your share of support your followers send on your posts, net of the platform commission.

By contrast, the following coins are spendable inside the app only and can never be withdrawn or converted to USD, no matter how large your balance of them grows — because they don't represent income earned from your activity and your community's support, but rather a balance you paid for yourself or that was granted to you as an incentive or a matter of chance:

• All coins you purchased with your own money, whatever the payment method (Apple, Google, PayPal, card, or any other method).
• Administrative grants or adjustments made by the Tapylapy team for any operational or compensatory reason.
• Lucky-wheel prizes.
• Task-completion rewards — daily, weekly, or seasonal.
• Referral-program rewards.
• Weekly live league and creator-level rewards.
• Birthday gifts automatically granted by the platform.
• Treasure-box winnings during a live stream.

When Is Eligibility Determined? — At the Moment You Earn the Coin, Not Your Current Status

Whether any given coin is withdrawal-eligible is decided permanently at the exact moment you receive it, based on your status at that moment — it is never re-evaluated later based on your current status. Specifically:

• Support/gifts received while you are not yet a verified creator: if you receive support or a gift on a post or during a stream before you are a verified creator, those coins are immediately recorded as not eligible for withdrawal — they remain spendable inside the app like any other coin, but they never become withdrawal-eligible, even if you later become a verified creator. Your status at the moment of receipt is the only thing that determines that specific coin's fate, and no later change to your status applies retroactively to it.
• Live-hour earnings and post-view earnings are limited exclusively to verified creators: these two rewards are never granted at all to a user who is not a verified creator — meaning you earn zero coins from your streaming hours or your post views before you become a creator, not merely non-withdrawable coins. Once you become a verified creator, these two types of earnings start being counted from that moment forward only, with no retroactive credit or compensation for streaming hours or views that occurred before the platform approved your creator status.
• Losing your creator status permanently ends the eligibility of your then-eligible balance: if your verified-creator status is revoked for any reason (a violation, an administrative review, or otherwise, by a decision of Tapylapy about the status itself; missing the badge's monthly re-verification is not such a reason), any coin balance that was still eligible for withdrawal and that you had not yet withdrawn from that period as a creator permanently loses its withdrawal eligibility the moment your status is revoked — that balance stays in your wallet and remains spendable inside the app only (gifts, support, and in-app purchases); it is not deleted, but it can never be cashed out. Any pending withdrawal request of yours is also cancelled and its coins are returned to your wallet. And even if you later re-apply and Tapylapy approves you as a creator again, that specific balance never regains withdrawal eligibility — eligibility after re-approval applies only to coins you earn newly afterward, and does not revive any previously-eligible balance you lost when your status was revoked.

Together with the Refund & Coins Policy and the Terms of Service, this policy constitutes the entire agreement governing your relationship with Tapylapy as a creator with respect to rewards and withdrawal; Tapylapy may, at its sole discretion, offer select high-performing creators a separate, customized partnership agreement with additional terms, with no obligation to offer such an agreement to all creators.

11) Reward Withdrawal

Withdrawal of eligible rewards is currently live for verified creators (who have passed identity verification with an official document as part of account verification) who meet the platform's minimum follower/view thresholds. This is subject to:

• Passing the standard and enhanced due diligence described in Sections 3 and 4 above, including account verification with an official ID document.
• The user being 18 or older, with the receiving payment method held exclusively in their own personal name.
• Activating withdrawal eligibility requires meeting a minimum number of followers and/or views, set by Tapylapy and reviewed periodically based on platform growth and quality standards; you can view the current threshold required for your specific account inside Creator Studio (current thresholds and rates are shown in the app). Tapylapy reserves the right to change this threshold, and any change is communicated in the app or by email before it applies to new earnings, under the notice terms in Section 15.
• Payouts are made directly via PayPal (a business account registered in SULTAN X LTD's name) or a direct bank/international transfer to the creator's own receiving method, depending on what is available for the creator's country. Tapylapy does not use any local agent or intermediary to pay out rewards. No other method (including cryptocurrency) is currently supported.
• Minimum and maximum withdrawal limits, internal review periods, and service fees as described in our Refund & Coins Policy.
• Tapylapy's right to delay, deny, or cancel any withdrawal request that raises a reasonable suspicion of fraud, money laundering, or a violation of this policy.
• Withdrawal depends on Verified Creator status alone, not on the verification badge. If that status is lost (only by a decision of Tapylapy about the creator status itself; missing the monthly re-verification affects the badge only), the coins that were eligible for withdrawal become non-withdrawable while remaining spendable inside the app, any pending withdrawal request is cancelled and its coins are returned to your wallet, and if you are approved again only coins you earn after the new approval can be withdrawn (see Section 10).

We are committed to neither offering nor accepting any bribe or unlawful advantage in our dealings with any payment partners or providers (such as PayPal, banks, or international transfer services) used to pay out creator rewards.

12) Gift Rules — Allowed and Not Allowed

• Allowed: Sending a gift to any creator whose content you enjoy, as a voluntary expression of appreciation, using your own card or wallet only.
• Not allowed: Using the gifting mechanism to circumvent payment for off-platform deals or services, or as an alternative money-transfer tool.
• Not allowed: Organizing a network of accounts to exchange fake gifts to inflate gifts or future rewards.
• Not allowed: Topping up using someone else's funds, a stolen card, or an account that is not yours.

13) Financial Risk Controls

This section describes measures to protect the financial system from fraud and money laundering — it is not a disciplinary or performance-management process for any individual. Creators are fully independent (see "Creator Independence" in Section 10), and these measures are applied based on the nature of the financial risk detected, not "employee conduct," and not necessarily in escalating order:

• Explanatory notice: For minor unusual activity, we explain the reason and may request clarification.
• Temporary pause of top-up or gifting: Pending review of suspected activity.
• Freeze of the specific balance linked to the suspected activity: Pending review — not necessarily your entire balance.
• Cancellation of rewards proven to result from manipulation or fake gifts: Only the unlawfully obtained rewards specifically.
• For serious or confirmed fraud/money laundering: Account closure, forfeiture of the violating balance, and referral to competent authorities where appropriate.

This temporary freeze during review is limited strictly to the balance or activity under suspicion. Full, immediate forfeiture of the entire unwithdrawn coin and reward balance applies only where the account is actually terminated for a "serious violation," as defined in the Terms of Service — not for any violation, however minor or immaterial — in which case the forfeiture described in our Terms of Service applies immediately, and by accepting the Terms of Service the user agrees to this. As an exception to this, confirmed cases of financial fraud or confirmed money laundering justify an immediate freeze of the related balance regardless of whether they formally meet the "serious violation" classification, given the exceptional nature of such cases. If, after review, the decision is found to have been wrongful, the next paragraph applies and the account is restored with the full balance returned.

You can ask for a review of any freeze, cancellation or closure decision under this section through our support team (using the in-app tools, or at [email protected]). A review request is decided by an authorised administrator on the facts of the case, and we aim to reply within 30 business days. A request does not by itself suspend or undo the action. If, after review, a ban, termination or financial freeze is found to have been wrongful, the account is restored and the full balance is returned.

Tapylapy aims to complete its internal review of any suspected fraud or money-laundering freeze case within 90 days of the freeze, and a freeze can be reviewed on request through support as described above. If no decision is issued within this period, silence is not a decision against the user: the user may escalate (by writing to support again) or pursue the amicable-settlement path and then the litigation process set out in our Terms of Service.

14) Age & Eligibility

All financial features covered by this policy (top-ups, gifts, rewards, withdrawal) are subject to the 18+ minimum age requirement in our Terms of Service, with no exceptions.

15) Changes to This Policy

We may update this policy from time to time, especially when enabling or changing the withdrawal feature or verification procedures. The latest version will be posted on this page. For material changes we will give reasonable advance notice (at least 14 days, except where a change is required by law or needed urgently to protect safety) through the app or by email. If you continue to use the service after the effective date, the updated version applies to you where the law allows; if you do not agree, you may stop using the service and close your account. Material changes include any change to the gift commission, withdrawal thresholds, or reward-calculation criteria, which are communicated before they apply to new earnings; the current rates and thresholds are shown in the app.

16) Contact

For questions about gifts, rewards, or verification procedures: [email protected].

For formal legal correspondence related to compliance: [email protected].

Registered address of SULTAN X LTD (company number 17198402, England and Wales): Flat 15, Aneurin Bevan Court, 55 Coles Green Road, London NW2 6EE, United Kingdom.

The Arabic and English versions are meant to say the same thing and both apply. If they differ, the version in the language you use the service in (the language selected in the app or on the page) applies to you.