CHATINGO PRIVACY POLICY

Last Updated: April 23, 2025

1. ABOUT THIS POLICY

This Privacy Policy applies to information we collect when you use our website, mobile application, and other online products and services (collectively, the "Service") or otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Service to stay informed about our information practices and the choices available to you.

This Privacy Policy is governed by and construed in accordance with the laws of India, particularly the Information Technology Act, 2000, and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 ("Privacy Rules").

2. INFORMATION WE COLLECT

2.1 Information You Provide to Us

We collect information you provide directly to us. This includes:

• Account Information: When you create an account, we collect your name, email address, username, password, and any other information you choose to provide.
• Instagram Authentication: To use our automation services, you provide us with access to your Instagram account through Instagram's authentication process.
• Payment Information: If you make a purchase, we collect payment information, including credit card numbers, billing addresses, and other payment details. This information is processed by our payment processors, and we do not store complete credit card information on our servers.
• Communications: We collect information when you contact us directly, fill out a form, respond to surveys, or otherwise communicate with us.
• Profile Information: We collect any additional information you add to your profile, such as profile pictures, biographical information, or preferences.
• Marketing Preferences: Information about your marketing preferences and subscription to our newsletters.

2.2 Sensitive Personal Data or Information

Under Indian law, certain information is classified as "Sensitive Personal Data or Information" (SPDI). We may collect the following categories of SPDI:

• Passwords
• Financial information such as bank account or credit card or debit card or other payment instrument details
• Any detail relating to the above clauses as provided to us for providing service

We collect this information only when it is necessary for a lawful purpose connected with a function or activity of our service.

2.3 Information We Collect Automatically

When you access or use our Service, we automatically collect certain information, including:

• Log Information: We collect log information about your use of the Service, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Service.
• Device Information: We collect information about the device you use to access our Service, including hardware model, operating system and version, unique device identifiers, and mobile network information.
• Location Information: We may collect information about the precise location of your device with your consent, or we may derive your approximate location from your IP address.
• Usage Information: We collect information about your usage of the Service, such as the actions you take (like the Instagram accounts you interact with, the type of interactions, and the frequency of your use of our features).
• Cookies and Similar Technologies: We use cookies, web beacons, and other tracking technologies to collect information about you when you interact with our Service or emails, including information about your browsing behavior on our Service.

2.4 Information We Collect From Other Sources

We may obtain information from other sources and combine that with information we collect through our Service. For example:

• We may collect information about you from third parties, including marketing partners, analytics providers, and publicly available sources.
• If you create or log into your account through a social media service (like Instagram), we will receive information from that service, such as your name, account information, and friend lists, in accordance with the authorization procedures determined by such social media service.

3. HOW WE USE YOUR INFORMATION

We use the information we collect to:

• Provide, maintain, and improve our Service: Including to process transactions, develop new products and services, and manage the performance of our Service.
• Personalize your experience: We use your information to deliver content and product offerings relevant to your interests, including targeted offers and ads through our Service, third-party sites, and via email or text message (with your consent).
• Manage your Instagram automation: We use your information to automate your Instagram activities according to your preferences and settings within our Service.
• Send you technical notices, updates, security alerts, and support and administrative messages.
• Respond to your comments, questions, and requests: And provide customer service.
• Communicate with you about products, services, offers, promotions, and events: And provide other news or information about us and our select partners.
• Monitor and analyze trends, usage, and activities: In connection with our Service to improve our Service and for marketing purposes.
• Detect, prevent, and address technical issues: Including fraud, security breaches, and other illegal activities.
• Comply with legal obligations: Including responding to lawful requests from public authorities.

4. LEGAL BASIS FOR PROCESSING

We collect and process your personal information based on the following legal grounds:

• Consent: We process your personal information based on your consent, which you provide when you sign up for our Service or specifically opt in to certain processing activities.
• Contract Performance: We need to process your personal information to perform our contract with you, such as providing the Service you've subscribed to.
• Legitimate Interests: We may process your information for our legitimate business interests, such as improving our Service, preventing fraud, and ensuring the security of our platform.
• Legal Compliance: We may process your personal information to comply with applicable laws and regulations in India.

As per Indian Privacy Rules, we obtain your consent before collecting and using your Sensitive Personal Data or Information. By using our Service, you consent to the collection, use, and disclosure of your SPDI in accordance with this Privacy Policy.

5. HOW WE SHARE YOUR INFORMATION

We may share information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants, and other service providers: Who need access to such information to carry out work on our behalf.
• With third-party applications: When you use third-party apps, websites or other features integrated with our Service, they may collect information about your use of the feature. Any information collected by these third parties is subject to their own terms and policies.
• In response to legal process: Including to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• To protect our rights and interests: Or the rights, property, and safety of our users, the public, or others.
• In connection with a merger, sale of company assets, financing, or acquisition: Of all or a portion of our business to another company.
• With your consent: Or at your direction, including if we notify you through our Service that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.

We only share your Sensitive Personal Data or Information with third parties after obtaining your prior permission through an opt-in mechanism, except in limited circumstances as permitted by Indian law, such as when sharing is required by governmental agencies by law or for lawful purposes.

6. INSTAGRAM PLATFORM RULES

In addition to our own Privacy Policy, your use of our Service is subject to Instagram's Platform Policy and terms of service. Our Service uses Instagram's APIs to access your Instagram account data with your permission. We are committed to complying with all of Instagram's Platform Rules, which govern our use of their APIs and your data.

We will never:

• Store your Instagram login credentials;
• Access private media without the owner's consent;
• Post content on your behalf without your explicit permission;
• Use your data for any purpose not explicitly disclosed in this Privacy Policy;
• Transfer your Instagram data to any advertising network, data broker, or other advertising or monetization-related service.

7. DATA RETENTION

We store the information we collect about you for as long as is necessary for the purpose(s) for which we originally collected it or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations. The retention periods we apply take into account:

• The duration of our relationship with you, including any active subscriptions;
• Legal obligations to retain data for certain periods;
• Statutes of limitations under applicable Indian law;
• Potential disputes;
• Guidelines issued by relevant data protection authorities.

When we no longer need to use your personal information, we will remove it from our systems and records and/or take steps to anonymize it so that you can no longer be identified from it.

8. DATA TRANSFERS

We are based in India, and the information we collect is governed by Indian law. We may transfer your personal information to countries outside India for processing. When we transfer your personal information outside India, we ensure that an adequate level of protection is afforded to it by ensuring that:

• The country to which we transfer data has been deemed to provide an adequate level of protection for personal information;
• We have entered into specific contracts or use other safeguards to ensure your information is protected;
• We obtain your specific consent for such transfer where required.

By using our Service, you consent to the transfer of your information to countries outside India, which may have different data protection rules than those of India.

9. YOUR CHOICES

9.1 Account Information

You may update, correct, or delete your account information at any time by logging into your account or emailing us at [email protected]. If you wish to delete or deactivate your account, please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of your information for a certain period of time.

9.2 Instagram Access

You can revoke our access to your Instagram account at any time by changing your Instagram password or revoking access through Instagram's application settings.

9.3 Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Service.

9.4 Promotional Communications

You may opt out of receiving promotional emails from us by following the instructions in those emails. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

9.5 Push Notifications

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

10. DATA SECURITY

We implement reasonable security practices and procedures as mandated under the Information Technology Act, 2000 and its rules to protect your personal information from unauthorized access, use, alteration, and disclosure. These security measures include:

• Encryption of your sensitive information in transit using SSL/TLS protocols;
• Regular security assessments and penetration testing;
• Access controls and authentication procedures;
• Regular security updates and patching;
• Employee training on security and privacy practices;
• 24/7 monitoring of our systems for potential security breaches;
• Implementation of a comprehensive information security program that is documented, reviewed, and updated regularly.

However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

11. CHILDREN'S PRIVACY

Our Service is not directed to children under 18, and we do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [email protected].

12. YOUR DATA PROTECTION RIGHTS

Under Indian Privacy Rules, you have certain rights regarding your personal information, including:

• Right to Access: You have the right to request a copy of the personal information we hold about you.
• Right to Correction: You have the right to request that we correct any inaccurate personal information we hold about you.
• Right to Opt-Out: You have the right to withdraw your consent for the collection and use of your personal information at any time.
• Right to Grievance Redressal: You have the right to address any grievances related to processing of your information.

To exercise these rights, please contact our Grievance Officer using the details provided in the "Grievance Officer" section below.

13. DATA PROCESSING INFORMATION

Category of Personal Information	Source	Purpose of Processing	Categories of Recipients
Contact Information (e.g., name, email, phone)	Directly from you	Account creation, customer service, communications	Service providers, payment processors
Instagram Account Information	Instagram API with your authorization	Providing automation services	Service providers
Payment Information	Directly from you	Processing payments, subscription management	Payment processors
Device and Usage Information	Automatically when you use our Service	Service improvement, analytics, security	Analytics providers, security vendors
Communication Records	Interactions with our team	Customer support, service improvement	Customer support tools, CRM systems

14. DO NOT TRACK

Some browsers offer a "Do Not Track" ("DNT") signal whereby you may indicate your preference regarding tracking and cross-site tracking. Although we do not currently employ technology that recognizes DNT signals, we will only process your personal information in accordance with this Privacy Policy. Some third parties, however, may keep track of your browsing activities when they provide you content, which enables them to tailor what they present to you.

15. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email (using the email address specified in your account) or by means of a notice on this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

16. GRIEVANCE OFFICER

In accordance with the Information Technology Act, 2000 and rules made thereunder, the contact details of the Grievance Officer are provided below:

Name: [Name of Grievance Officer]
Designation: Grievance Officer
Email: [email protected]
Phone: [Phone Number]
Address: [Your Company Address in India]

The Grievance Officer shall redress the grievances of users expeditiously but within one month from the date of receipt of grievance.

17. CONTACT US

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Chatingo
[Your Company Address in India]
Email: [email protected]
Phone: [Your Company Phone Number]

18. DISPUTE RESOLUTION

Any dispute, controversy or claim arising out of or relating to this Privacy Policy shall be resolved through negotiation in good faith. If the dispute cannot be resolved through negotiation, it shall be subject to the exclusive jurisdiction of the courts in [Your City], India.