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. Each verification cycle's photo is automatically deleted as soon as that cycle's outcome is decided (approved, finally rejected, or verified status withdrawn), with no further retention period afterward, unless an active dispute or investigation requires otherwise. A single failed periodic re-verification attempt does not, by itself, immediately result in withdrawal of verified status or monetization eligibility; 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 results in automatic withdrawal of both verified status and monetization eligibility together (see the complete list of reasons for withdrawing verified status below).

Having your account's social verification badge (blue or gold) is a completely separate process from the financial identity verification (KYC) required to activate reward-withdrawal eligibility, and does not automatically grant that eligibility; activating withdrawals requires independently completing the financial verification procedures described in this policy.

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. Tapylapy may change the categories, criteria, or process for either tier at any time without prior notice. Revoking Gold Verification removes verified status 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; (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 retain identity-verification and financial transaction records related to coin top-ups, gifts, or reward requests for 5 years, starting from the date your account is closed. While your account remains active, these records continue to be retained regardless of the date of your last transaction, and the 5-year period only begins once the account is actually closed. This is consistent with UK anti-money-laundering record-keeping standards, even if you fully delete your account (see our Account Deletion Policy).

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, 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, or PayPal is still pending, Tapylapy commits to resolving that purchase once service resumes, either by crediting the user with the coins owed, or by directing them to obtain a refund directly from the relevant store (Apple/Google) if crediting the coins is not possible.

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 via Apple In-App Purchase on iOS or Google Play Billing on Android, and the amount converts into Tapylapy coins.
• 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 at any time, at its sole discretion; any adjustment applies only to future gifts and has no retroactive effect on gifts already received before the adjustment takes effect.

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 at any time.
• 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.
• 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:

• Coins resulting from topping up your own balance with your own money via Apple or Google.
• 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 expired verification, an administrative review, or otherwise), 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 remains spendable inside the app only, and is not deleted. 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, and Tapylapy reserves the right to change this threshold at any time without any obligation of prior notice.
• 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.

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. 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. Tapylapy retains full discretion as to whether to return any portion of the balance unrelated to the violation, with no obligation to do so.

Freeze, cancellation, or closure decisions under this section are subject to internal review at the platform's discretion, and are not covered by the 30-day appeal mechanism described in the Refund & Coins Policy (which applies to standard eligibility decisions), given the investigatory nature of these measures.

Tapylapy aims to complete its internal review of any suspected fraud or money-laundering freeze case within 90 days of the freeze. If no explicit final decision is issued within this period, the absence of a ruling is deemed an implicit final decision maintaining the freeze, which automatically opens the user's right to 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 and becomes effective upon publication.

16) Contact

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

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

If there is any conflict between the Arabic and English versions, the Arabic version shall govern.