Privacy Policy

हिंदी

Last Updated: November 12, 2026

1. Introduction & Legal Framework

The Tingling mobile application and website (www.tingling.live) are developed, owned, and operated by Lightyears Games (OPC) Private Limited (hereinafter referred to as "the Company", "We", "Us", or "Our"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our voice chat and social networking application ("Platform").

This Privacy Policy is compliant with the Digital Personal Data Protection (DPDP) Act, 2023, the Information Technology Act, 2000, and the Information Technology (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 of India.

By using Tingling, you agree to the collection and use of information in accordance with this policy. Under the DPDP Act, Tingling acts as the "Data Fiduciary" and determines how your personal data is processed, while Firebase/Google Cloud acts as our Data Processor.

2. Information We Collect

2.1 Personal Information

  • Name and username
  • Email address and phone number (for Firebase Authentication)
  • Profile picture and avatar
  • Age, gender, and location information
  • Bio and personal description
  • Unique User ID (UID) generated by Firebase Authentication
  • PAN (Permanent Account Number) or Aadhaar number — collected during KYC verification for TDS (Tax Deducted at Source) compliance under Section 194-O of the Income Tax Act, 1961

2.2 Usage Information

  • Voice call duration and frequency
  • Chat messages and interactions
  • Lounge and room participation
  • Referral activity and rewards earned
  • App usage patterns and preferences

2.3 Device Information

  • Device type and operating system
  • Unique device identifiers
  • IP address and location data
  • Browser and app version information

2.4 Location Information

  • Approximate location based on IP address
  • Precise location (with your permission)
  • Location for currency conversion and regional features

2.5 Virtual Economy & Transaction Data

Tingling operates a secure, server-authoritative wallet system. We record your transaction history, coin purchases, point deductions, and “Chocolate” earnings.

Note: All financial transactions are processed via secure third-party payment gateways. We do not store your credit card or banking details on our servers.

Tax Compliance Data: As an e-commerce operator under Section 194-O of the Income Tax Act, we are legally required to track annual gross earnings per financial year and cumulative TDS deducted for each host. This data is retained for tax filing and audit purposes and includes:

  • Annual gross withdrawal amounts per financial year (April 1 – March 31)
  • Cumulative TDS deducted per financial year
  • PAN or Aadhaar verification status (for applicable TDS rate determination)
  • Entity type (Individual/HUF, Company, Partnership, LLP) for threshold applicability

This financial data is retained for 7 years as mandated by the Income Tax Act and cannot be deleted earlier, even upon account deletion, as it is required for statutory tax audits and TDS return filings (Form 26Q).

2.6 Audio & Video Privacy (Strictly Confidential)

Tingling is a real-time social discovery platform and we respect your private conversations.

  • We do not record the audio or video streams of your private 1-on-1 calls.
  • Audio and video data are transmitted strictly for the duration of the call and are not stored on our servers after the call ends.
  • We only process technical metadata (such as call length and connection quality) to accurately update your wallet and points balance.

3. How We Use Your Information (Grounds for Processing)

We process your personal data under the DPDP Act only based on your explicit consent or for legitimate uses specified under Indian law:

  • Service Delivery: To provide, maintain, and improve our voice chat and social networking services
  • Account Management: To create and manage your user account
  • Communication: To send you notifications, updates, and promotional messages
  • Safety & Content Moderation: To detect and prevent fraud, abuse, cyberbullying, harassment, and security threats, ensuring a safe environment for all users
  • Analytics: To analyze usage patterns and improve our services
  • Personalization: To personalize your experience and recommend content
  • Rewards: To manage referral programs and reward distributions
  • Legal Compliance: To comply with legal obligations and orders from Indian law enforcement or statutory authorities

4. Information Sharing & Third-Party Processors

We do not sell your personal information. We may share your information only in the following circumstances:

  • With Other Users: Your profile information is visible to other users on the platform
  • With Data Processors: With trusted third-party service providers (like Google Firebase) who process data strictly on our behalf under data protection agreements
  • For Legal Reasons: When required by Indian law, court order, or an official request from a government agency/law enforcement body
  • Business Transfers: In connection with a merger, acquisition, or sale of assets
  • With Your Consent: When you explicitly consent to the sharing

5. Data Storage & Localization

Your data is stored securely on Google Cloud Platform through Firebase. In strict compliance with Indian data sovereignty and advisory directives:

  • Primary data, including user profiles, logs, and authentication details, are stored and hosted primarily within Google Cloud's secure data centers located in India (Mumbai/Delhi regions)
  • Firebase Authentication: Phone numbers, email addresses, and UIDs are stored in Firebase Authentication system
  • Cloud Firestore: User profiles, chat messages, call logs, and app data are stored in Firestore (Google's NoSQL database)
  • Firebase Storage: Profile pictures, avatars, and media files are stored in Firebase Storage (Google Cloud Storage)

Google Cloud complies with industry-standard security certifications including ISO 27001, SOC 2, and rigorous data protection frameworks.

6. Data Security

We implement industry-standard security measures to protect your information:

  • Encryption of data in transit and at rest
  • Secure authentication and access controls
  • Regular security audits and testing
  • Limited access to personal information
  • Secure data storage and processing

However, no method of transmission over the Internet is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Your Privacy Rights Under DPDP Act, 2023

As a "Data Principal" in India, you enjoy the following statutory rights:

  • Right to Summary: Request a summary of personal data being processed and the processing activities
  • Right to Correction & Erasure: Request correction of inaccurate data, completion of incomplete data, or erasure of data no longer required for the purpose it was collected
  • Right to Grievance Redressal: Register a grievance with our Grievance Officer regarding any act or omission by us regarding your data rights
  • Right to Withdraw Consent: You have the right to withdraw your consent for data processing at any time. Withdrawal of consent will make it impossible for us to continue providing certain services to you

How to Request Deletion / Withdraw Consent: To request deletion of your account and all associated data, please:

  • Send an email to support@tingling.live with the subject "Data Deletion Request"
  • Include your registered phone number or email address for verification
  • We will acknowledge your request within 24 hours and permanently delete your data across Firebase Authentication, Firestore, and Firebase Storage within 30 days, except where retention is mandated by Indian law for tax, legal, or compliance purposes

8. Data Retention

We retain your personal information only for as long as necessary to provide our services or as mandated by law:

  • Account information: Retained while your account is active
  • Usage data & Call logs: Retained for up to 180 days to fulfill regulatory log retention mandates under Indian cyber security directives (CERT-In)
  • Tax & Financial Records: PAN/Aadhaar, annual gross earnings, and cumulative TDS deducted are retained for 7 years as required under the Income Tax Act, 1961 (Section 194-O compliance). This data survives account deletion.
  • Deleted accounts: Permanently purged or anonymized within 30 days of deletion request, except tax records which are retained for 7 years as mandated by Indian tax law

9. Children's Privacy

Tingling is not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected information from a child under 18, we will take steps to delete such information immediately.

10. Regional Language Notice

In compliance with Section 5(3) of the DPDP Act, 2023, this privacy notice is available in English. If you require this notice or consent form in Hindi, Telugu, Kannada, or any other official regional language specified under the Constitution of India, please contact our Grievance Officer listed below, or toggle the language settings within the App interface.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. Contact Us

If you have any questions about this Privacy Policy, please contact us:

13. Grievance Redressal & Content Moderation

In accordance with the Information Technology Act 2000, the IT Intermediary Rules 2021, and the DPDP Act 2023, the details of the Grievance Officer are listed below. For privacy breaches, safety concerns, abuse reports, or cyber-harassment, please reach out to:

  • Grievance Officer: Subhransu Sekhar Mallick
  • Company: Lightyears Games (OPC) Private Limited
  • Contact Email: support@tingling.live
  • Physical Address: Tingling App Platform, [Address subject to change - final location being finalized], HSR Layout, Bengaluru, Karnataka, India

Timeline for Grievance Redressal:

  • Content/Privacy violations involving explicit content or impersonation: Acknowledged and acted upon/removed within 24 hours
  • General grievances/data access requests: Acknowledged within 24 hours and fully resolved within 15 days