Privacy Policy

Last Updated on 6th November, 2025

This Pingal Mobile Application (“Platform”) is operated by Dyumn Tech Pvt Ltd (hereinafter referred to as “Company”, “We”, “Us”, “Our”). We offer access to certain AI-enabled interactive features, including but not limited to AI-based horoscope prediction and other intuitive or guidance-based conversational experiences (“Services”).

This Policy provides for the practices for the collection, possession, storage, handling and dealing of personal identifiable information/data and sensitive personal data (hereinafter collectively referred to as “Personal Information”) of the User. This Policy is an electronic record in terms of the Information Technology Act, 2000 and rules thereunder.

The Company urges the User to read and understand this Policy and the Terms of Service (“ToS”) carefully. By accessing Our Platform or availing Our Services, You consent to the collection and processing of Your Personal Information by the Company in accordance with this Policy and for the purposes stipulated herein.

1. Who does this Policy apply to?

This Policy applies to all persons accessing Our Platform and using any of Our Services (hereinafter referred to as “User”, “You”, “Your”).

2. What data do We collect?

2.1 In the course of providing the Services to the Users through the Platform, We may collect (i) User’s mobile device’s Unique ID, (ii) IP address of User’s mobile device, (iii) User’s mobile operating system, (iv) the type of mobile internet browser User use, and (v) unique device identifiers (vi) usage patterns, browsing history and other diagnostic data (“Personal Information”).

2.2 We do not collect any other personally identifiable information of the Users other than that specified under Paragraph 2.1. However, You may share the personal information through the prompts and other content you input (“Inputs”) on the Platform (“Personal Information”). We do not control what information You provide as Inputs

2.3 If you include any personal information in Inputs You provide to the Platform, such information may be reproduced in the outputs generated by the Platform (“Outputs”). The personally identifiable information contained in Inputs and Outputs are collectively referred to as “User PI”.

We do not store or transmit any User PI. All User PI in the Inputs You provide into the Platform and Outputs generated by the Platform, while availing the Services is stored exclusively on Your local device. We have no access to this User PI. (edited)

3. How do We collect Your data?

We collect data and process Personal Information when:

(a) You use Our Services.

(b) You share User PI through the chat/ messaging function on Platform. You are responsible for any User PI You share on chat and messaging features.

4. How We use Your Personal Information?

4.1 We use the Personal Information that we collect as per Paragraph 2.1 for the following purposes:

Improving the Services: To analyze User’s choices, browsing patterns including the frequency of visits and duration for which a User is logged on, to diagnose problems with Our servers, for improving Our systems and Platform and Services.
Legitimate Interests: To fulfil Our legitimate interests, and Our relationship with You as described in this Policy.
Market research, data solutions and report creation: We may use your Personal Information for market research and data solution purposes. This is done via functionality reporting on the data collected from You.
Anonymization: Personal Information which We collect and which We may convert into the anonymized format is Our property. We may use it, in Our sole discretion and without any compensation to the User, for any legitimate purpose including without limitation the transfer of the anonymized format to the third parties.

4.2 In the event You share any User PI as Input on the Platform, We may process it to provide Outputs. Since We do not store Your User PI, We do not use it for any other purpose.

5. Where is Your Personal Information stored?

The Personal Information that We collect in respect of the User is hosted within India and We have cross continental data back-up for business continuity purposes.

All Your User PI is stored in a local database on Your mobile device. We do not use any external servers or cloud storage. The security of Your User PI is therefore dependent on the security of your device. We recommend You use a strong passcode and other security features available on Your device to protect Your User PI.

6. Why and when do We transfer/disclose Your Personal Information?

6.1 The Company uses the services of certain AI providers, such as Anthropic and Grok (“AI Providers”), for providing certain features of the Services. In this regard, the User PI provided by the Users through Inputs on the Platform is transferred by the Company to such AI Providers and is processed by them for the purposes of Services. Such AI Provider is an independent data fiduciary under the applicable laws and the collection, processing, storage, and retention of the User PI by such AI Provider shall be subject to such AI Provider’s privacy policy.

6.2 Google AdMob and other third parties may collect certain Personal Information after taking Your consent for the delivery and functionality of their services to display advertisements and support functionality. Any collection, processing, storage, and retention of Your Personal Information by Google AdMob shall be subject to and governed by their privacy policy.

6.3 We can transfer the Personal Information if required by law, legal process, litigation, and/or requests from governmental or regulatory authorities, or for the purpose of national security, law enforcement, or other issues of public importance, including cyber incidents, prosecution and punishment of offences, to disclose the User’s Personal Information

7. How do We protect Your Personal Information?

7.1 We value the security of the User’s Personal Information and hence We have implemented technical and organizational security measures that are designed to help protect the User’s Personal Information from unauthorized access, disclosure, use and modification. These measures include the following:

use of secure HTTPS connections for all API requests and transmissions;
ensuring no logging or transmission of to-do data to external services except for transient processing by AI APIs;
if AI responses or any data is cached locally, it is stored securely and encrypted where feasible;
providing you with built-in options to clear all stored data or reset the Platform to factory settings for full transparency and control.

7.2 From time-to-time, We review Our security procedures to consider appropriate new technologies and methods.

7.3 Please be aware, however, that no data security measures can guarantee 100% security.

7.4 If We learn of a security breach, We may (a) attempt to notify the User electronically so that the User can take appropriate protective steps; or (b) post a notice on the Platform, or (c) take suo-motto steps to rectify the breach without any notice to the User. If the User have any questions about the security of the User’s Personal Information, please contact the Grievance Officer.

8. How long do We keep Personal Information?

8.1 We shall retain the User’s Personal Information only for as long as is necessary, and after such reasonable time, it is destroyed appropriately and securely or anonymized in accordance with the law.

8.2 We do not retain Your User PI on Our servers. All User PI is stored locally on Your device. You control the retention period i.e., local data remains only as long as the Platform is installed or until You use the in-app “Delete All Data” option. The User PI is automatically and permanently deleted from Your device when You uninstall the Platform.

9. What are Your Rights and Obligations?

9.1 Save and except the rights provided herein in this Policy since the User PI shall be stored on Users’ local device, all rights to the User PI shall belong to the User. The Users shall to regularly review this Policy.

9.2 You have the following rights pertaining to Your Personal Information collected by Us as per Clause 2.1:

Right to know what Personal Information We hold and to have the information communicated to You;
Right to access the copies of Your Personal Information. We may charge You a small fee for this service;
Right to request that the Personal Information held by Us be corrected, rectified or deleted;
Right to object to the processing of the Personal Information or to request restriction thereof;
Right to withdraw Your consent to submit or process any or all Personal Information or decline to provide any permissions on its Platform as covered above at any time.

9.3 Any such request to update, delete or correct the Personal Information, or to withdraw consent regarding sharing and use of Personal Information should be shared with the Grievance Officer as per Paragraph 14 below.

9.4 In case, You choose to object processing of the Personal Information, withdraw consent in regard to the Personal Information or delete the Personal Information shared, then Your access to the Platform and Services may be limited, or We might not be able to provide the Services to You.

9.5 We will evaluate any request for deletion of Personal Information on a case-to-case basis and take the requisite action as per applicable law. In this regard, please note that information sought to be deleted may remain with Us in archival records for the purpose of compliance of statutory enactments, or for any other lawful purpose. Therefore, You are requested to carefully evaluate what types of information they would like to provide to Us

9.6

9.2 In case, You do not want us to process Your User PI, please not includeUser PI in your Inputs into Our Platform. However, please note that in such case Your access to the Platform and Services may be hindered, or We might not be able to provide certain features of Our Services to You appropriately.

10. Links to third-party websites/apps

We may through Our Platform, provide advertisements and links to third-party platforms. We do not make any representations or warranties with respect to such third-party platforms. Further, We are not responsible for the practices employed by such platforms, applications, or services linked to or from the Services or Platform, including the information or content contained there. Such third-party websites and services are subject to that third party’s own rules, policies, and practices, and not this Policy.

11. Should children access this Platform?

We do not knowingly collect or process personal data of children below the age of eighteen years without parental consent. If You are under the age of 18 (eighteen) years, You must have Your parent or legal guardian’s permission to use avail the Services. Please have Your parent or legal guardian read these Terms with You. You represent that Your legal guardian has reviewed and agreed to these Terms. If You are a parent or legal guardian, and You allow Your child to avail the Services, then these Terms apply to You and You are responsible for your child’s activity in relation to the Services.

12. How do We update this Policy?

12.1 This Policy is current as of the last updated date set forth above.

12.2 We may periodically change this Policy to keep pace with new technologies, industry practices, and regulatory requirements, among other reasons. While, We expect most such changes to be minor, We request the Users periodically to review the changes.

13. Governing Law

13.1 This Policy shall be governed by and construed in accordance with the laws of India and the Parties agree that they are bound by the laws of India for the purposes of this Policy.

13.2 Parties shall try to resolve any dispute arising out of or in relation to this Policy by mutual discussions, failing which the same shall be submitted to arbitration under the provisions of the Arbitration and Conciliation Act, 1996 by a sole arbitrator appointed by the Company. The place of arbitration shall be Mumbai, Maharashtra, India and the language of arbitration, English. Subject to the foregoing, the courts at Mumbai, Maharashtra, India shall have exclusive jurisdiction.

14. How to contact Us?

Any complaints with regards to collection and processing of Personal Information provided by the User or breach of the terms of this Policy may be taken up with the Grievance Officer. The details of the Grievance Officer are as follows:

Grievance Officer: Mr. Kamal Upadhyay
Email: grievance@virbhumi.com
Address: 101, D Definity Premises Co-operative Society Limited, Survey No-95, Hissa No-CTS No-364, Jayprakash Road No-01, Goregaon East, Goregaon East, Mumbai, Goregaon East, Maharashtra, India, 400063.

The Grievance Officer shall acknowledge and dispose of the complaint within such time period as prescribed under the applicable laws.