Privacy Policy

Last updated: August 2025

If you are a minor, and are not sure you understand everything in this Policy, please make sure to speak with a trusted adult before using Pinga.

Please also remember that Pinga is not meant to be used if you are under 16. If you are under 16 years old, your parent or guardian must approve your use of the app.

In this Privacy Policy, we will explain what information we collect about you, how we use it, when we share it, and the controls we provide you to manage the information you share with us.

1. Information we process about you

Pinga (the 'App') collects information that you provide directly to us, through your use of our App and your visit to our website or shared by third-parties.

1.1 Data that you provide to us

Account Creation Data: when you create an account on our App, we will ask you for the following information. Without it, we cannot provide you access to the App:

Topics you're interested in, Height.
The email address of a parent or guardian, for users under 16 years old.

During (or after) account creation there is also some additional information you can decide to share with us:

A biography, your location (as precise as you want), and a profile picture.

Content Data: when you use the App, you can decide to share the following data:

Photos and videos that you take ("Content") using the app or photos that you share from your library. You can create an account without allowing us to access and collect data from your device's camera or photo library. However, you will only be able to see your friends' Content when you have posted your own Pinga. It's a foundational part of how Pinga works.
Your reaction to your friends' Content: Real shooting, emojis, captions and comments.

Chat Data: when you use the Pinga chat function, we collect the messages, photos and videos you share with your friends within the chat.

Communications with Pinga: When you report a concern with our App, respond to a survey, request assistance, we collect the following data:

Your email address,
Content of communication with us,
Photos you may decide to share with us,
Copies of government issued identification (only when strictly required to identify you with certainty),
Identifiers (e.g., phone numbers or email address),
Any other information you may decide to share with us.

1.2 Data we collect when you use our App or visit our website

Like all internet based services, as you use our App or visit our website, we automatically receive information about you from your device and your usage of our App and your visit of our website. Most information is collected through trackers:

a. Through the use of our website:

Connection and Technical Data such as IP address, device type, operating system version, browser, language preference, and browsing data.

b. Through your use of the App:

Connection and Technical Data such as:

IP address, account creation date, last login, terminal equipment and port, operating system, system configuration data, device type, operating system version, browser, language preference, and applications.
user_id (unique identifier generated at account creation), device_id (unique identifier generated when connecting on new device) and Amplitude ID.

Mobile advertising IDs and device identifiers:

We collect technical identifiers developed by mobile operating systems for advertising purposes which remain under your control and can be reset or erased at any time in through your device settings:

Mobile advertising IDs (e.g., Apple IDFA if you use iOS or Google AAID if you use Android).
Device identifiers (e.g., IDFV for iOS devices and Android ID for Android devices).

Interaction Data:

Friend (number of friends, friend invitations, the friends with whom you interact the most).

Inferred information: We will analyse Account Creation Data and the Content Data to infer information about you:

Your time zone.
Your interests.

Usage Data: actions performed on the App or our website, time of posting Content, how many times you retook a photo before posting, number of Pinga posts, Content viewed, Content interactions, the fact that you deleted Content, or that you blocked users, when you take a screenshot in our App, application crashes, pages visited and event logs.

Geolocation Data: when you use our app, we infer your country, city, region based on your IP address.

Integrations with partners: When you decide to connect a partner application to use a specific integration on Pinga, we receive information that allows us to bring that feature to you. This will include all necessary device data, and other optional data that you may choose to share as part of the integration.

1.3 Information about you provided by third parties

We may receive information about you from other users of our app. For instance, When you use certain social features of Pinga—such as inviting a contact or sharing a post—we may send an SMS message to that person on your behalf using the phone number you've provided (e.g., from your synced contacts). These messages may include a link to the content or an invitation to join Pinga. Recipients can opt out of future messages by following the instructions included in the SMS.

We will also receive the information about where you came from to download the App (for example, if you clicked on an ad on another social media) from our partners.

2. How we use information we receive about you

We use the information we collect to provide, maintain, and improve our services, to communicate with you, and to protect our users and services.

3. When we share information about you

We share information about you with our employees and service providers, who will process it under our control.

Pinga Employees: To allow you to use the App to you or provide you support, authorized Pinga employees may need to get access to your information. We strictly limit who can access your data.

Service Providers: To bring you our App we work with a small group of partners who provide us services. This includes partners who help with technical and hosting support, sending notifications, publishing, and sharing content, user analytics and satisfaction surveys, management of security incidents or fraudulent activity, etc. In working with those partners, we may share your information with them to bring you our App.

Counsels: For compliance with our statutory obligations, in particular in terms of accounting, auditing and internal control, we might share your information with our counsels (legal, financial, audit).

4. Children's data

Pinga never knowingly or willingly collects any personal data concerning children under 13 years of age. Depending on where you live, if you are under the age of consent in your country, a parent or guardian may also have to provide consent for you to use our App. If you are under 13, please do not use Pinga.

5. International transfers

Some of the partners and service providers referred to in this policy are located outside of the European Union.

In such case, we ensure that:

The personal data is transferred to countries recognized as offering an equivalent level of protection or.
One of the mechanisms offering appropriate guarantees is implemented (for example, the adoption of the standard contractual clauses of the European Commission.

6. How long we keep information about you

We keep your information only for as long as it's needed to provide our services to you, in line with legal requirements and data protection authorities guidelines.

7. What controls you have over your information in the App

At Pinga we have implemented features to ensure that you remain in control of your personal data.

Notification: In the settings of the applications you can choose and control which notifications you receive about our App.

Block or Hide Users: To make sure you have a great experience when using our App, you can block or hide users who you do not want to receive Content from or who you do want to see your Content. If you block or hide a user, at any time you can go into the settings of the App and view who you have blocked or hidden. You can also unblock or unhide them at any time.

Who sees your Content: Note that when you share Content through our App, that Content is available to your Pinga friends. Each time you share Content, you can also decide to allow friends of your friends to see it or even to publish it on Pinga's discovery feed. You can control this at any time in the settings of the applications how other users use your Content is not under our control.

Time Zone: When you create an account we determine your time zone for the purpose of providing you our App. In the settings of the applications you can change your time zone at any time.

Integrations: From time to time we may offer integrations with partners to provide you certain features. If those partners require you to log into your account on their services to avail of the feature, you will be able to control those integrations in the settings of the applications at any time.

Deactivate Memories: In the settings of the App, you can choose to activate or deactivate the memories feature at any time. If you deactivate this feature, you and other users of the App won't be able to see your prior Content.

Delete Your Account: In the settings of the App, you can choose to delete your account at any time. If you choose to delete your account, your account will be scheduled for deletion. This process takes approximately 15 days. If you log back into your account during that 15 day period, it will stop the deletion request. If you do not log back in, your account and all of your information will be permanently deleted. Note, information will not be deleted where Pinga has received a valid legal request requiring us to preserve your information.

Consent: When we rely on your consent, you can withdraw your consent at any time from the "settings" page in our application.

If your account is permanently suspended by us and you choose to delete your account, we will keep Account Creation Data related to your account to prevent permanently suspended users from creating new accounts.

8. What rights do you have over your information

Privacy is a fundamental human right. That means every person that uses our App, irrespective of where they reside, can expect the same things from us. Whether you are in Europe, one of the 50 U.S. States, Latin America, the Middle East, Africa, Japan, Asia Pacific, or anywhere in between, you can:

Right to access and obtain a copy of your data: you may request access to your personal data. If you request such access, we will provide you with all the information required by law, including the purposes of the processing, the categories of data processed, the categories of recipients, the data retention periods and your rights.
Right of rectification: You may also ask us to rectify any personal data concerning you that is inaccurate and to complete any incomplete information.
Right to erasure/deletion: Under certain circumstances, you may request the erasure of your personal data. We may nevertheless need to retain certain limited data in an archived database, in particular if we have a legal obligation to retain such personal data or if it is necessary for the exercise or defense of legal claims.
Right to restrict processing: In certain circumstances, you may request the limitation of the processing of your personal data, in particular when you request the rectification of your personal data.
Right to withdraw your consent: Where the processing of your personal data is based on your consent, you may, at any time, withdraw any consent you have previously provided to us. Such withdrawal does not affect the lawfulness of processing based on consent prior to withdrawal.
Right to object: You may also object at any time to the processing of your Personal Data when it is used for commercial prospecting purposes or for reasons related to your particular situation.
Right to portability: In certain cases, you may also obtain a copy of your personal data, in a commonly used and machine-readable format, to enable you to exercise your right to data portability.
Right to set instructions for how your data is processed post-mortem: If you are a French user, you also have the right to set directives concerning the management of your personal data after your death.
If you are in the European Union, EFTA States or the United Kingdom, and wish to raise a concern about our data processing practices, you have the right to do so with your local supervisory authority or Pinga's lead supervisory authority, the Commission Nationale de l'Informatique et des Libertés (CNIL).

Some of these rights (rectification, deletion and consent withdrawal) can be exercised directly from the App, in the setting section. You can also exercise these rights and all other rights by addressing your request to our support at info@nexus-light.com. Since we don't necessarily collect your address email, we sometimes will need additional information to make sure that the request does come from you.

9. U.S. Privacy Rights

This U.S. Privacy Rights section supplements the information contained in our Privacy Policy and applies to all users, visitors and others who reside in the United States. We adopt this notice to comply with various federal and state privacy regulations...

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked...

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the business or commercial purposes described...

Data Retention

We will retain personal Information from or about you as reasonably necessary...

Sharing Personal Information

We may share your personal information with third parties for business purposes, including:

Advertising Networks: To provide tailored advertising based on your activities...
Data Analytics Providers: To understand app and website usage patterns and improve our services.

Please note that we do not sell personal information as traditionally understood...

Your Rights and Choices

As a U.S. resident, you have specific rights regarding your personal information...

1. Right to Know

You have the right to request that we disclose certain information to you...

The categories of personal information we have collected about you.
The categories of sources from which your personal information was collected.
The business or commercial purpose for collecting or selling your personal information.
The categories of third parties with whom we share your personal information.
The specific pieces of personal information we have collected about you.

2. Right to Delete

You have the right to request that we delete any of your personal information that we collected from you...

3. Right to Opt-Out of the Sale and share of Personal Information

You have the right to opt-out of the sale and share of your personal information...

You may also use a Global Privacy Control (GPC) signal...

4. Right to Non-Discrimination

You have the right not to receive discriminatory treatment...

Exercising Your Rights

To exercise the rights described above, please submit a verifiable consumer request...

Contact our Data protection office here: info@nexus-light.com

Only you, or a person registered with the California Secretary of State...

The verifiable consumer request must provide sufficient information...

We will respond to your request within 45 days...

Response Format and Delivery

We will deliver our written response by mail or electronically...

For data access requests, our response will cover only the 12-month period...

Children

Our website and our App are not intended for use by children under the age of 13...

If you are between 13 and 16 years old and wish to exercise your rights...

Do Not Track (DNT):

Some browsers offer a "Do Not Track" (DNT) setting...

10. Contact

Pinga is produced by Pinga CO., LIMITED, headquartered in Hong Kong. We created Pinga...

Our registered office is located at Room 701, Unit 108B, 7th Floor...

If you have a question about our privacy practices or Privacy Policy, you can reach us by postal mail at:

info@nexus-light.com

11. Update of our Privacy Policy

We can update our Privacy Policy if this is necessary or if the law requires it.

Pinga Services