Clipay Factory
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Privacy Policy

Version dated July 29, 2026

The English version is the governing version. The Russian translation is provided for convenience. Mandatory rights under Russian law apply regardless of the document language.

1. Operator and service

Clipay Factory (also referred to as “Clipay”) is operated by Individual Entrepreneur Dmitry Nikolaevich Podzorov, Russian Taxpayer ID (INN) 771978998706, Primary State Registration Number (OGRNIP) 326774600187601 (“Operator”, “we”). Clipay is a technology marketplace and intermediary where clients publish clip-creation tasks and clippers submit results and may earn rewards.

2. Data we process

  • Telegram Mini App data: Telegram ID, name, username, language, and profile image;
  • role, settings, account history, tasks, submissions, clips, moderation decisions, and support requests;
  • links to published content, public profile data, and view metrics;
  • TON wallet address and public blockchain transaction data;
  • technical data: request time and result, device and browser type, language, errors, usage events, and security signals;
  • information voluntarily provided to support.

Clipay does not routinely perform passport-based KYC. Telegram ID is used for access, but we may request additional information where required by law or reasonably necessary to protect an account, verify rights, prevent fraud, or resolve a dispute.

3. Purposes and legal grounds

We process data to:

  • authenticate users and maintain accounts;
  • publish tasks, accept clips, moderate content, and calculate results;
  • prepare blockchain transactions, verify payouts, and maintain financial history;
  • verify authorship, public metrics, and rule compliance;
  • prevent abuse, secure the service, and handle claims;
  • analyze service operation, fix errors, and meet legal obligations.

Processing is based on performance of the Terms, consent, legal obligations, and the Operator’s legitimate interests in service security, rights protection, and improvement. Consent may be withdrawn for future processing unless another lawful ground applies.

4. Providers and transfers

To the extent necessary to operate Clipay, data may be processed by Telegram, Vercel, Railway, Supabase, TON/TON Center, TikTok, and providers of technical support and public metric verification. We may also disclose data in response to a lawful authority request or to protect users, rights, and safety.

Some infrastructure and providers are located outside Russia, so data may be processed in other countries. Public wallet addresses and blockchain records are visible to network participants and cannot be erased from the blockchain by the Operator.

5. Retention

  • product analytics events: up to 180 days;
  • client and server error logs: generally up to 30 days;
  • rejected-submission history needed for abuse prevention: up to 90 days;
  • temporary codes and checks: for their validity period and up to 7 days afterwards;
  • account, task, moderation, payout, and dispute data: while the account exists and afterwards for as long as needed for settlement, security, claims, and legal duties.

After account deletion, public access is removed, but a restricted operational history may be archived for financial records, security, proof of performance, and dispute resolution. Public blockchain records remain indefinitely independently of Clipay.

6. Local storage and cookies

Clipay uses localStorage and sessionStorage for the session, language, role, theme, interface cache, and technical flags. We do not use first-party advertising cookies. Third-party services opened by a user apply their own policies.

7. Minors

Users under 18 may use Clipay only within their legal capacity and with prior consent of a parent or legal representative where the law requires it. Financial actions for a user under 14 must be performed by their legal representative. If Telegram or another relevant service requires a higher age, that service’s requirement applies.

8. Your rights

You may request information, access, correction, blocking, or deletion, withdraw consent, and challenge processing before a competent authority or court. To protect the account, we verify requests using Telegram ID and, where needed, additional information. Account deletion is requested through support and does not erase legally retained data or public blockchain records.

9. Security and changes

We use organizational and technical measures intended to limit unauthorized access, alteration, and disclosure. No transmission or storage method is absolutely secure. An updated version will be published on this page with a new date; material changes may also be announced inside the service.

10. Contact

Personal-data and account-deletion requests may be sent through the official Clipay Telegram bot. Include your Telegram ID and request details; never send a wallet seed phrase or private key.