Privacy Policy for Smingle

Last updated: April 25, 2025

This Privacy Policy describes Our policies and procedures on how Your information is collected, used, and disclosed when You use the Service and informs You about Your privacy rights and legal protections.

We use Your Personal data to provide and improve the Service. By using the Service, You consent to the collection and use of information according to this Privacy Policy.

Interpretation and Definitions

Interpretation

Words with a capitalized initial letter have meanings defined below. These definitions apply whether the words are singular or plural.

Definitions

For the purposes of this Privacy Policy:

Account means a unique account created for Your access to our Service or parts of our Service.
Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of voting shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
Application refers to Smingle, the software program provided by the Company.
Company (referred to as "the Company", "We", "Us" or "Our" in this Agreement) refers to Smingle Labs Private Limited, G8, Block 11, SJR Bluewaters, Bangalore, Karnataka, 560068.
Country refers to: Karnataka, India.
Device means any device that can access the Service like a computer, a cellphone, or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual. The types of data collected and identifiable information are explained further below.
Service refers to the Application.
Service Provider means any natural or legal person who processes the data for the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to help the Company in analyzing Service usage.
Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
Usage Data refers to information automatically collected when you interact with the Service. This may include data generated through your use of the application, your activity within the app, technical information sent by your device, or diagnostic and performance data gathered by the Service infrastructure. It helps us understand how the Service is being used, improve functionality, and enhance user experience.
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of whom such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

Email address
First name and last name
Phone number
Address, State, Province, ZIP/Postal code, City
Location
Pictures

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol address (e.g., IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers, and other diagnostic data.

When You access the Service by or through a mobile device, We may automatically collect certain information, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers, and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

Google
Facebook
Instagram
Twitter
LinkedIn

If You decide to register through or otherwise give us access to a Third-Party Social Media Service, We may collect Personal data already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities, or Your contact list linked to that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a way consistent with this Privacy Policy.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

Information regarding your location
Information from your Device's phone book (contacts list)
Pictures and other information from your Device's camera and photo library

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server, or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

To provide and maintain our Service, including to monitor its usage.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service available to You as a registered user.
For the performance of a contract: the development, compliance, and undertaking of the purchase contract for the products, items, or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products, or contracted services, including security updates, when necessary or reasonable for their implementation.
To provide You with news, special offers, and general information about other goods, services, and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
To manage Your requests: To attend to and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and to evaluate and improve our Service, products, services, marketing, and your experience.

We may share Your personal information in the following situations:

With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners, or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services, or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures, and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You, and view Your profile.
With Your consent: We may disclose Your personal information for any other purpose with Your consent.

We are committed to protecting your personal data and will not share it with third parties except as outlined in this Privacy Policy. Your information is securely stored and accessed only by authorized personnel. However, in certain circumstances, we may be legally required to disclose your data for compliance with applicable laws and regulations, including but not limited to the Digital Personal Data Protection (DPDP) Act, 2023 and the Information Technology Act, 2000. Such disclosures will only be made in response to valid legal requests from government authorities, law enforcement agencies, or regulatory bodies.

Retention of Your Personal Data

The Company will keep Your Personal Data only as long as is needed for the purposes set out in this Privacy Policy. We will keep and use Your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

The Company will also keep Usage Data for internal analysis. Usage Data is generally kept for a shorter time, except when this data is used to strengthen security or to improve Service functionality, or We are legally obligated to keep this data longer.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and kept on — computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and according to this Privacy Policy and no transfer of Your Personal Data will occur to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or ask Us to help in deleting the Personal Data that We have collected about You.

Our Service may give You the ability to delete certain information about You from within the Service.

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so. After you delete your account, all associated personal information will be permanently deleted within 6 months, unless we are legally required to retain it under applicable laws or regulatory obligations, including those specified under relevant statutes.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children's Privacy

Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.

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.

User-Generated Content and Conduct

Acceptance of Terms and Prohibited Content: By using our Service and engaging in activities that involve User-Generated Content, You agree to adhere to our End User License Agreement (EULA). This EULA will explicitly state that there is zero tolerance for objectionable content or abusive users. Objectionable content includes, but is not limited to, content that is unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, libelous, invasive of another's privacy, hateful, or racially, ethnically, or otherwise objectionable. Any user engaging in such conduct or posting such content will be subject to appropriate action, including but not limited to content removal and account termination.
Mechanism for Blocking Abusive Users: We provide a mechanism within the Application that allows users to block other users. This feature can be utilized to prevent further interaction or contact from users who exhibit abusive behavior. You can access this feature through the profile screen of the user or while chatting with the user.
Reporting and Content Moderation: We provide a reporting mechanism within the Application for users to report objectionable content or abusive behavior. Upon receiving a report, we will review the reported content and/or conduct. If the reported content or conduct is found to be in violation of our EULA, we will take action to remove the content within 24 hours and may eject the user who provided the offending content. We will make reasonable efforts to notify the user of the action taken.
Definition of User-Generated Content: For the purposes of this section, "User-Generated Content" refers to any content that users contribute to the Service, including but not limited to text, images, videos, and other media shared or posted by users on the Application.

Contact Us

If you have any questions about this Privacy Policy, You can contact us: By email: support@smingle.in

Child Safety Standards

Smingle is committed to maintaining a safe environment for all users, with special emphasis on the safety of children.

Child Sexual Abuse and Exploitation Prevention

Smingle has zero tolerance for child sexual abuse or exploitation. We:

Proactively moderate content
Offer in-app reporting tools
Cooperate with law enforcement
Immediately act on CSAM-related reports

Designated Contact for child safety concerns: support@smingle.in

Reporting Mechanisms

Smingle provides in-app tools for users to report any safety concerns, including inappropriate content, abusive behavior, or exploitation. If you encounter any content or conduct that feels unsafe—whether it's directed at you or someone else—we encourage you to report it immediately using the in-app reporting feature. This includes behavior that may involve harassment, discrimination, or exploitation of individuals of any age. We have zero tolerance for child abuse or exploitation, and any such reports are handled with the utmost urgency in accordance with applicable laws. Your reports help us maintain a respectful, inclusive, and safe environment for all.

Compliance with Laws

We comply with all relevant child safety laws and regulations. All reports regarding potential child exploitation are promptly reported to the appropriate regional and national authorities as required by law.

Designated Contact

For matters specifically related to child sexual abuse material (CSAM) prevention and compliance, please contact our designated representative at: support@smingle.in