Privacy Policy

1. Who we are and how to contact us

The controller of your personal data is Pingle Software LTD, a private company limited by shares, registered in England and Wales. Our company number and registered office are on our company details page.

You can contact us through our contact page, or by post to our registered office (please mark the envelope "Privacy").

In this policy, "Pingle", "we" and "us" mean Pingle Software LTD.

2. About this policy

This policy explains how we use personal data when you:

• visit our website and its language versions;
• send us a message or join a waitlist through a form on our website;
• use the Pingle VPN apps on your devices;
• buy or sell on the Pingle Marketplace (website and Telegram Mini App);
• use the Pingle control panel as an operator;
• contact our support, including the support chat.

We wrote it to meet Articles 13 and 14 of the UK General Data Protection Regulation ("UK GDPR"), as amended by the Data (Use and Access) Act 2025.

Some of the services described here are not available yet. Our apps are not yet released, and "Create your service" (our white-label offering), the SDK and the developer documentation are in development. The parts of this policy about a service apply from when that service is available to you.

When we act for a business customer. If you use a VPN service run by one of our business customers (an "operator") on the control panel or white-label platform, that operator decides how your data is used. The operator is the controller and we are its processor. Read the operator's own privacy notice. Section 9 explains this.

3. What our privacy promises mean

Our website makes three promises. Here is exactly what each one means.

"We don't track traffic"

We do not record the websites you visit, the content of your traffic, your DNS queries, or which of our IP addresses you used at a given time together with your original IP address.

To run the service we still need a small amount of technical data:

• Data volume per account. Lite, Standard and Pro have monthly traffic allowances. An account without a plan has a free daily allowance of 200 MB, and its traffic beyond that is charged at US$0.20 per GB from its prepaid balance, as Extra Usage is. So we count how many bytes each account uses. We keep a running total: for a plan, per billing month; without a plan, per UTC day, reset at 00:00 UTC. We do not record where the traffic went. Family has unlimited traffic and no Extra Usage; its volume counter helps check compliance with the resale prohibition in the Terms of Service.
• Live connection state. While you are connected, our servers must hold your current connection (for example, your device's public IP address and the session keys) so they can route your packets. We use it only to carry your connection and do not keep it after the session ends.
• Security filtering. Our threat-blocking layer (built on eBPF in the Linux kernel) checks traffic against block rules as it passes. It does not store what it checks.
• Network protection. To protect our network, we may look at aggregate signals that do not include the content or destinations of anyone's traffic, for example an unusual flood of connections to one port from our servers, or one of our IP addresses being put on a block list.

"No email or phone number required"

You can create a VPN account without giving us an email address or phone number. Your account is identified by an account identifier, not by your name, email or phone number. You may choose to give us contact details, for example to get support replies or join a waitlist. In that case we use them only as this policy describes.

Using the service still involves some personal data (for example, your IP address while you are connected, and payment records). "Anonymous" means we do not ask who you are. It does not mean that no data exists.

"We don't track money transactions"

We do not build a profile of your payments or link your payments to your VPN activity. We do keep the records the law requires, such as the amount, date, plan and payment reference of each purchase or top-up (see section 10). The referral programme links a friend's payments to the referrer's rewards, only to work the rewards out (section 4.11).

• Card payments are handled by our payment providers. We do not see or store your full card number.
• Cryptocurrency payments are recorded on a public blockchain. Anyone can see those records and nobody can delete them, including us.

4. The personal data we collect

4.1 Website visitors

We do not use analytics tools, advertising pixels, social media plugins, or fonts and scripts loaded from other companies. Everything the page needs comes from our own servers.

4.2 The "What the site sees" connection check

Some of our pages, including the home page, show what any website can learn about a visitor. To do this, the page runs a live check automatically when it opens:

1. Your browser sends a request to our checker at ip.pingle-family.com. Like any web request, it shows the checker your IP address. The checker replies with your IP address, country, city, network operator and its AS number, and an approximate longitude. It works these out from your IP address using a geolocation database. We use the checker only to answer the request. We do not use it to identify you or to build a record of visitors.
2. Your browser reads some of its own settings: your time zone, clock offset and preferred languages, and your browser's own list of time zones for your country. It compares them with the checker's answer to estimate how likely you are to be using a VPN or proxy. This happens only in your browser. These settings and the result are not sent to us and are not stored.

4.3 Contact and waitlist forms

Our website has forms you can use to contact us and to join a waitlist (for example, for "Create your service"). When you send a form, we receive:

• your Telegram handle or your email address (whichever you give us);
• your message, if you write one (it is optional);
• the page you sent the form from and the language of that page.

How it reaches us. The form sends these details to us as a message through Telegram, using the Telegram Bot API. Telegram delivers the message to a Telegram chat our team uses and stores it on its servers as the provider of the messaging service. Telegram's own privacy policy describes how it handles data.

Why we use it. To reply to your message, and, if you joined a waitlist, to tell you when that product launches and to talk to you about taking part. Joining a waitlist does not add you to general marketing.

Our lawful basis. Where you ask about buying or using our services, taking steps at your request before entering into a contract (Article 6(1)(b) UK GDPR). Otherwise, our legitimate interests in answering the people who contact us and in running our waitlists (Article 6(1)(f)).

How long we keep it. For a message: as long as we need to deal with it and any follow-up, then we delete it. For a waitlist: until we have told you the product has launched, or until you ask us to remove you, whichever comes first. You can ask us to remove you at any time (section 12).

Transfer outside the UK. Telegram stores messages on servers that may be outside the UK. Section 8 explains how we protect such transfers.

4.4 VPN app users

We do not collect: browsing history, traffic destinations, DNS queries, traffic content, or timestamps that link your original IP address to a VPN IP address.

4.5 Payments

Payment providers are independent controllers for the checks they must carry out, including anti-money-laundering and fraud checks.

4.6 Marketplace (website and Telegram Mini App)

The Marketplace lets buyers and sellers trade VPN services and digital goods and services. Payment is held in escrow by a smart contract on the TON blockchain.

Blockchain records are public and permanent. Deal payments go through a smart contract on a public blockchain. Wallet addresses, amounts and times can be seen by anyone and cannot be changed or deleted, by us or anyone else. Your erasure rights cannot apply to on-chain data. Think about this before linking a wallet to your identity.

Identity checks. Most Marketplace users are never asked for identity information. Section 4.10 sets out the cases where we may ask, for example where the law requires us to collect information about sellers or to check against sanctions lists.

Telegram is an independent controller of the data it holds about you. Its privacy policy applies to your use of Telegram.

4.7 Control panel (operators and business customers)

If you use the control panel to run VPN nodes and manage users, we collect about you and your staff:

• name or username, business name, role, and login credentials (including two-factor authentication secrets);
• contact details you give us (email, Telegram handle or phone);
• billing and invoicing details, and VAT number;
• audit logs of actions taken in the panel (who did what and when);
• details of the nodes you connect (server IP addresses, hostnames, software versions, health metrics).

We are the controller of this data. The data about your own end users that you manage in the panel is covered by the data processing agreement we provide to business customers with their contract. For that data, you are the controller and we are your processor.

4.8 Support and the support chat

Our support chat has two parts: an AI assistant answers first, and a human specialist joins if needed.

The AI assistant is provided by a service provider that processes your messages on our behalf under a contract. The AI does not make decisions with legal or similarly significant effects on you. It cannot close your account, refuse a refund or settle a dispute. A person makes those decisions.

4.9 Legal, security and compliance

We may process any of the data above to prevent fraud and abuse, to protect our network, to handle legal claims, and to respond to lawful requests from authorities (see section 7).

4.10 Identity and sanctions checks

You can use the VPN without proving who you are, and most Marketplace buyers are never asked for identity information. We may ask for it only:

• from Marketplace sellers, before their first payout or once their sales reach the level at which the law requires us to collect seller information and report it to HM Revenue & Customs;
• from business customers, before they use the control panel or other business services;
• from anyone, where a name, wallet address or payment looks like a match with the UK Sanctions List, a payment or wallet is linked to fraud, theft or other crime, we receive a lawful request from an authority, a refund is asked for to a different person, card or wallet from the one that paid, or we see signs of fraud, account takeover or money laundering.

We then ask only for what that reason requires. For an individual, this can be: full name, date of birth and home address; tax identification number and country of residence (sellers only); a photo ID document; the bank account or wallet address used for payouts; and, for the largest deals only, an explanation of the source of funds. For a business, it can be: registered name, company number, registered address and country; tax or VAT number; the names and dates of birth of its directors and of anyone who owns or controls more than 25% of it; and photo ID of the person opening the account. We may also check the wallet addresses you pay from, or ask us to pay to, against sanctions lists and blockchain analytics. This needs nothing from you beyond the address.

Where we can, specialist providers carry out these checks on our behalf, so that we do not store copies of your documents ourselves. We do not use this information for marketing, and we do not link it to your VPN activity, which we do not record.

4.11 Referral programme

If you invite friends or sign up through a friend's link, we keep:

• which account referred which, your referral link, and when the friend signed up;
• for each reward: the payment it comes from (amount and date), the reward and its status (waiting, credited or cancelled);
• for each withdrawal: the TON address and comment (memo) you give us, the amount, the date and the transaction hash.

What the other person sees. Your friend is told at sign-up that they joined through a referral link, but is not shown your account identifier. A referrer sees how many people signed up and paid through their link, and each reward's date, amount and status. They never see the friend's account identifier, contact details, plan, traffic or location. Because a reward is 20% of a payment, its amount can show roughly what that friend paid.

Checking for self-referral. To check that a referrer and a friend are not the same person, we compare payment records we already hold (section 4.5), such as the sending wallet address or the card details our payment provider sends us. We collect nothing extra for this. A person reviews a flag before any reward is cancelled (section 13).

Withdrawals are sent on the public TON blockchain, where anyone can see them (section 3). We may check the address against sanctions lists (section 4.10).

5. Why we use your data and our lawful basis

UK GDPR requires us to have a lawful basis for each use (Article 6). Where we rely on legitimate interests, we have weighed our interests against yours. You can ask us for that assessment.

Special category data. We do not ask for data about health, ethnicity, political opinions, religion, sex life or sexual orientation, trade union membership, or genetic or biometric data. Using a VPN may say something about you. We do not record your activity, so we cannot infer any of this.

If you don't provide data. Some data is needed to deliver a service (for example, an account identifier and payment). Without it we cannot provide that service. You are never required to give an email address or phone number to use the VPN.

6. Where we get data from

Most data comes from you. We also receive data from:

7. Who we share data with

We never sell personal data. We never share it for advertising.

7.1 Service providers who act for us

Our service providers may use the data only to provide their service to us and must keep it secure. You can ask us for the names of the providers we use.

7.2 Independent controllers

• Payment providers and banks process payments and carry out their own legal checks.
• Telegram for the Marketplace Mini App and any chats with us on Telegram.
• App stores if you download or pay through them. Their own policies apply.
• Blockchain networks. Transactions are published to the public TON network.
• Professional advisers (lawyers, insurers) where needed.

7.3 Authorities and legal requests

We disclose data to police, courts or regulators only if the law requires it and after checking that the request is valid. Because we do not keep activity logs, we cannot give anyone information that we do not have, such as a user's browsing history.

7.4 Business changes

If Pingle is sold, merged or restructured, personal data may pass to the new owner. This policy will continue to protect it.

8. International transfers

We are based in the UK. Some of our service providers and servers are outside the UK, including in the countries where our VPN locations are (the current list is on our website), and Telegram may store form messages outside the UK.

When we send personal data outside the UK, we use one of the protections in Chapter 5 of the UK GDPR:

• UK adequacy regulations, which cover, for example, the EEA countries.
• Standard data protection clauses issued under section 119A of the Data Protection Act 2018: the International Data Transfer Agreement (IDTA) or the International Data Transfer Addendum to the EU Standard Contractual Clauses. Before relying on them, we carry out the "data protection test": we check that your data will not be protected to a materially lower standard than in the UK (Article 46 UK GDPR).
• Exceptions under Article 49 UK GDPR, used only where they apply. For example, a transfer may be necessary to perform your contract with us, such as when you choose to connect to a VPN server in another country, or to take steps you asked for before a contract, such as answering the form you sent us.

VPN servers you choose. When you connect to a server in a country, your traffic passes through that country. That is how a VPN works. We do not store your activity on any server.

You can ask us for a copy of the safeguards we use (commercial terms may be removed) through our contact page.

9. When we act for business customers

When an operator uses our control panel or white-label platform to run its own VPN service:

• the operator is the controller of its end users' data, and decides what it collects and how long it keeps it;
• Pingle is the processor. We act only on the operator's documented instructions under the data processing agreement we provide to business customers with their contract (Article 28 UK GDPR);
• if you are one of the operator's users, send your privacy requests to the operator. If you send them to us, we will pass them on.

Our no-logs design applies to the infrastructure Pingle runs. Nodes that an operator runs itself are under the operator's control, including any logging it sets up.

10. How long we keep data

We keep data only as long as we need it for the purposes above. Then we delete it or make it anonymous.

We may keep data longer if the law requires it, or while a legal claim or investigation is ongoing.

11. How we protect your data

We use technical and organisational measures that fit the risk. They include:

• encryption in transit (TLS) on the website and panel, and encrypted VPN tunnels;
• a no-logs design that avoids collecting activity data in the first place;
• plugins isolated in WebAssembly sandboxes;
• kernel-level (eBPF) threat blocking;
• access controls, least privilege and two-factor authentication for staff;
• staff confidentiality obligations;
• a documented process for handling personal data breaches.

No system is perfectly secure. If a breach is likely to put your rights at high risk, we will tell you without undue delay, as Article 34 UK GDPR requires.

12. Your rights

You have the following rights under UK GDPR. Some of them apply only in certain situations.

How to make a request

Send your request through our contact page, from inside the App where it offers this, or by post to our registered office, whose address is on our company details page. It's free.

Proving it's you without an email address. Many of our users have not given us an email. We may therefore ask you to show that you control the account, for example by sending the request from inside the App or your Account. We ask for no more than we need. We will never ask for identity documents just to handle a request about an anonymous account.

Timing. We reply within one month of the "relevant time": when we receive your request, or later if we need to confirm your identity or clarify the request. We can extend this by up to two more months for complex or numerous requests, and we will tell you why within the first month (Article 12A UK GDPR). We carry out reasonable and proportionate searches.

We may not have your data. Because we do not log activity, we often hold very little about you. We cannot give you data we never collected.

13. Automated decision-making

We do not make decisions based solely on automated processing that have legal or similarly significant effects on you.

• The AI support assistant answers questions. It does not decide on refunds, account closure or disputes. A person does.
• Fraud and abuse rules may flag an account or a Marketplace deal. A person reviews the flag before any significant action is taken.
• The VPN likelihood figure in the website's connection check is worked out in your browser and is not stored or used for any decision.
• Escrow release in the Marketplace follows the deal's rules, which both parties accept when they start a deal. If either party disputes a deal, a person decides the outcome.

14. Children

Our services are not aimed at children. You must be at least 18 to create an account, buy a plan or use the Marketplace.

Family plan. The account holder may let family members, including children, use the service on their devices. The account holder is responsible for doing so and for supervising them. We do not knowingly collect children's personal data beyond what the service needs to work.

In the UK, a child aged 13 or over can consent to online services themselves (Article 8 UK GDPR). We do not rely on a child's consent. If you believe we hold a child's data by mistake, contact us and we will delete it.

15. Marketing

We do not send marketing messages, by email or through messengers such as Telegram, unless you have agreed to receive them. Joining a waitlist is not agreeing to general marketing. We do not use advertising or tracking cookies (see the Cookie Policy).

16. Complaints

Complain to us first. If you are unhappy with how we have used your personal data, tell us through the form on our contact page, which you can complete electronically, or by post to our registered office, whose address is on our company details page. We will acknowledge your complaint within 30 days, look into it, and tell you the outcome without undue delay (section 164A, Data Protection Act 2018).

Complain to the regulator. You can also complain to the UK data protection regulator. From 30 September 2026 this is the Information Commission, which replaces the Information Commissioner and is still known as the ICO. It usually asks people to raise a complaint with the organisation first.

• Website: ico.org.uk/make-a-complaint
• Helpline: 0303 123 1113
• Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

If you live in the EEA, you can also complain to your local data protection authority.

17. Changes to this policy

We will update this policy when our services or the law change. The date at the top shows when it was last reviewed. We will tell you about significant changes in the App, on the website or by message before they take effect.