- Legal name
- Clearpoint Data LLC
- Trading name
- FlyThePay
- Legal form
- Wyoming limited liability company
- State filing ID
- 2026-002036826
- Date of organization
- 22 July 2026
- Federal tax ID (EIN)
- 30-1502345
- Principal office
- 1021 E Lincolnway #10515, Cheyenne, WY 82001, United States
- Registered agent
- FBRA LLC, 1023 E Lincolnway, Cheyenne, WY 82001, United States
- Manager and sole member
- Hugo Gil Gisbert
- Contact
- sales@flythepay.com
1. The basic rule
Your products and services must be legal in the country where your business is established, in every country where you sell, and under the rules of the card networks and payment methods we use. Where a product is legal in some markets and not in others, you must restrict sales to the markets where it is legal, and we may require geo-blocking, age verification or licensing evidence before enabling it.
If you are not sure whether your business fits, ask us before applying. We would rather say no early than terminate an account later.
2. Prohibited businesses and content
We will not onboard, and will immediately terminate, any merchant selling or promoting:
- child sexual abuse material or any sexual content involving minors; non-consensual sexual content, revenge pornography or content depicting sexual violence;
- gambling, betting, lottery, skill games for money or fantasy sports operated without a valid licence for each market in which players are accepted;
- firearms, ammunition, explosives, weapon parts, 3D-printed weapons and instructions for making them;
- illegal drugs, controlled substances, new psychoactive substances and paraphernalia; prescription medicines sold without a valid licence and prescription process;
- counterfeit goods, replicas, unauthorised copies of software, media or brands, and any product that infringes intellectual property rights;
- pyramid and Ponzi schemes, matrix programmes, cash-gifting and multi-level marketing without a genuine product;
- unregistered securities, token offerings that constitute securities, binary options, and investment services that promise guaranteed returns;
- unlicensed financial services, including money transmission, currency exchange, lending, payday loans, debt collection and credit repair without the licences required in the relevant markets;
- sale or resale of personal data, hacked accounts, stolen card data, malware, phishing kits, DDoS-for-hire, account-takeover tools or services that facilitate unauthorised access to systems;
- human trafficking, prostitution, escort services and any service facilitating sexual exploitation;
- hate speech, incitement to violence, terrorist content and organisations, and content that promotes or glorifies harm to people or animals;
- sales of human organs, endangered species, ivory and protected wildlife products;
- fake documents, diplomas, IDs, licences, reviews, followers or engagement;
- psychic, fortune-telling and miracle-cure services sold with claims of guaranteed results; products marketed with false health, income or efficacy claims;
- tobacco and nicotine products sold to minors or into markets where their sale or online sale is prohibited;
- any business or person subject to sanctions of the United States, the European Union, the United Kingdom or the United Nations, or located in a comprehensively sanctioned country or territory;
- any activity prohibited by Visa, Mastercard or other card network rules, including the Visa Integrity Risk Program and the Mastercard Business Risk Assessment and Mitigation (BRAM) programme, or by the terms of any alternative payment method we offer.
3. Restricted businesses (allowed under conditions)
The following industries are welcome, subject to enhanced due diligence and the conditions listed. We may add conditions to your Merchant Agreement.
- Adult content, dating and creator platforms: verified 18+ age gating on every entry point, records that comply with 18 U.S.C. §2257 or equivalent where applicable, consent and identity verification of all performers, content moderation, and no content listed in section 2.
- iGaming affiliates and tipsters: you may only promote operators licensed in the markets you target, must display responsible-gambling messaging, and may not accept player deposits yourself.
- Forex, trading and crypto education, signals and prop-firm challenges: clear risk warnings, no promises or implied guarantees of returns, no handling of client funds for trading, and licensing evidence where the activity is regulated in the buyer's market.
- Nutraceuticals and supplements: ingredients legal in each destination market, no medical or disease claims that are not permitted by the relevant regulator, and clear disclosure of any subscription or continuity terms.
- CBD and hemp products: THC content within the legal limit of each destination market, third-party lab certificates, and no sales into markets where the product is prohibited.
- Vaping and e-cigarettes: age verification at checkout and delivery, compliance with flavour, nicotine-strength and labelling rules in each market, and no sales into markets that prohibit them.
- Telehealth and online pharmacies: licensed practitioners, legitimate prescription workflows, pharmacy registration in each market served, and no controlled substances.
- Travel, events and ticketing: clear cancellation and refund terms, evidence of supplier arrangements, and financial protection where required by law.
- Subscriptions, memberships, coaching and infoproducts: price, billing frequency and renewal terms shown before purchase, express consent to recurring billing, easy online cancellation, and refund terms that match what the customer was shown.
- Marketplaces, agencies and platforms paying third parties: full onboarding of the platform, disclosure of sub-merchant categories, and our prior approval of any payout to third parties.
4. Merchant obligations
Every merchant must:
- sell only the products, from only the websites, that we approved, and tell us before adding new products, brands, websites or markets;
- display accurate product descriptions, pricing, currency, taxes, delivery times, refund policy and customer support contact details on every checkout;
- deliver what was sold within the promised time and handle refunds and customer service promptly;
- use only the billing descriptor we assign and never disguise the nature of a transaction;
- keep chargeback and fraud ratios below the thresholds set by the card networks and in the Merchant Agreement, and cooperate with our dispute-prevention tools;
- never process transactions for another business, split transactions to avoid limits, process cash advances, or run transactions on your own cards;
- never store, log or transmit full card numbers, CVV or authentication data outside our tokenized checkout;
- comply with data protection, consumer protection, tax and sanctions law in every market you sell into;
- notify us within 24 hours of any data breach, regulatory enquiry, licence change or event that could materially affect your risk profile.
5. Monitoring and enforcement
We monitor merchant websites, transactions, ratios and customer complaints on an ongoing basis, and we may ask for information or documents at any time. If we believe this policy has been breached, or that continuing to process would expose us, our partners or customers to legal, financial or reputational risk, we may take any of the following steps without prior notice: request corrective action, block specific products, markets or payment methods, hold or delay payouts, increase reserves, suspend processing, or terminate the account.
Card network rules may require us to report terminated merchants to network databases such as the Mastercard MATCH list, and to report suspected illegal activity to law enforcement. We will do so when required.
6. Reporting a violation
If you believe a business using FlyThePay is breaching this policy, email sales@flythepay.com with "Abuse" in the subject line and as much detail as you can. We investigate every report.
7. Changes
We may update this policy at any time, for example when card network rules or the law change. The effective date at the top of the page shows when the current version took effect. Merchants will be notified of material changes by email and are expected to comply from the date stated in the notice.
