HOT BLINDERS✦PRE-LAUNCH / NO PAYMENT COLLECTION
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LEGAL CENTER / PAYMENTS / DRAFT

PayPal & China Rules

How payment approval, China laws and consumer protection fit together.

BEFORE GOING LIVE / 正式上线前： This is a draft for company and qualified Chinese legal review, NOT a binding legal opinion. Replace all highlighted company/contact placeholders. Do not enable payments until the company approves this wording and its payment provider approves the business. / 本页面为待审核草案，须补全公司信息并由中国专业律师及支付机构审核后方可用于正式交易。

1. PayPal is not connected

HOT BLINDERS currently has no PayPal buttons, merchant agreement, order processing, or card payment collection. The demo prices do not create a sale. The Chinese operating company must receive payment-provider approval for its actual livestream performer support / digital fan-gifting business model before any payment option is activated. Approval of a business account alone is not confirmation that every business activity is approved.

2. Who should own the account?

The registered operating company in mainland China should apply through appropriate PayPal China cross-border merchant services (or a vetted alternative). It should disclose the precise business model and verify its registration, business identity, beneficial owners, settlement method and other information requested by the provider. A volunteer U.S. developer should not receive these gifts into personal PayPal, act as a nominee merchant, or hold the company's payout credentials. PayPal China eligibility, supported payment methods, rates, account restrictions, reserves and payout routes depend on approval and active terms.

3. Digital gifts and seller protection

Business descriptions must be truthful. If an offering represents an intangible digital service, clearly describe the actual promised benefit and provide verifiable proof of fulfillment (for example, order identifier, timestamp and the promised digital acknowledgment). PayPal's Seller Protection for intangible services can depend on strict eligibility and evidence; donations/crowdfunding are commonly excluded, and none of these protections eliminates all chargeback exposure. The operator may owe the refunded amount, dispute fees, negative balances or reserves where applicable.

4. Chinese law and livestream safeguards

Relevant frameworks include China's Consumer Rights Protection Law, E-Commerce Law, Personal Information Protection Law (PIPL), minor-protection rules, and the April 13, 2026 CAC notice on livestream tipping management. The operating company must assess whether the specific site and its cross-platform referral model are permitted, review required registrations/licences, show legally required corporate disclosures, avoid deceptive or manipulative tipping prompts and establish meaningful minor safeguards. Compliance depends on the final products and method of operation, not simply the website text.

5. Under-18 safeguards

The planned gift service is for adults 18+ only. The preview checkbox is not real age verification. Before launch, the operator must implement adequate safeguards and a procedure for investigating suspected payments by minors, including legally required reimbursement. Avoid encouraging competition, spending streaks, coercive calls for money or special treatment in exchange for gifts.

6. Privacy, refunds and consumer rights

Digital-service exceptions to no-reason returns are not automatic and must be assessed with counsel. Consumer and PayPal/card dispute rights cannot be waived through a "no chargebacks" or "no refunds" banner. An overseas hosting/payment stack can raise cross-border data issues under PIPL. If hosting in mainland China or providing regulated internet services, ICP filing/licensing and other requirements may apply—seek operator-specific advice. Final legal text, merchant name, privacy contacts and a functioning complaint process must be publicly available before launch.

Official documents and references