Privacy Policy
Effective Date: May 7, 2026 · Last Updated: May 7, 2026
This Privacy Policy describes how Samcom Technologies ("we", "our", "us") collects, uses, stores, and discloses information when you use Pingly (available at pingly.in) — our AI-powered WhatsApp CRM & customer support platform. By accessing or using Pingly, you agree to this Privacy Policy.
1. Overview & Scope
Pingly is a B2B SaaS platform that enables businesses ("Workspace Administrators" or "Customers") to manage customer communications across WhatsApp Business API, WhatsApp Direct (personal number via QR scan), and Web Chat. We act as a data processor when handling your end-users' personal data on your behalf, and as a data controller for our own operational data (account, billing, etc.).
This policy applies to:
- Visitors to pingly.in and its sub-pages (including
/pricing,/enterprise) - Registered users (Admins, Managers, Agents, Support staff) of the Pingly platform
- End-customers ("Contacts") whose data is processed through Pingly by our business customers
- Visitors who interact with a Pingly-powered Web Chat Widget embedded on a third-party site
2. Information We Collect
2.1 Account & Registration Information
When you register for or use Pingly:
- Identity: Full name, email address, password (bcrypt-hashed, never stored in plaintext), role
- Organisation: Company name, workspace name, business hours, timezone
- Integration credentials: WhatsApp Business API keys (Gupshup), AI API keys (Anthropic Claude, OpenAI GPT) — all stored AES-256 encrypted
- Billing profile: Company name, billing address, GST number, contact email (for invoice delivery)
2.2 Contact & Conversation Data (Processed on Your Behalf)
When businesses use Pingly to communicate with their customers, we process:
- Contact profiles: Name, phone number, email, tags, opt-in/opt-out status, custom attributes, WhatsApp profile picture URL (if fetched), WhatsApp Business profile data (category, website, description — if applicable)
- Conversation messages: Text content, images, documents, audio/voice notes, videos, stickers, locations, contact cards (vCards), message timestamps, delivery/read receipts
- WhatsApp status: Delivery ticks (sent/delivered/read) and message status updates from WhatsApp
- CSAT ratings: 1–5 star ratings and optional text feedback submitted by end-users
- Web Chat sessions: Visitor name, email, phone (from pre-chat form); chat messages; session identifiers; browser user-agent (for display only)
- Support tickets: Ticket subject, description, status, priority, linked conversation data
- Sales leads: Lead name, phone, email, requirement, budget, pipeline status, notes
2.3 Knowledge Base Documents
If you upload documents (PDFs, Word files, text) to the Pingly Knowledge Base for AI bot training, those documents are stored in our infrastructure and may be processed by the AI provider you select (Anthropic or OpenAI) when the AI bot generates responses. You are responsible for ensuring you have the right to upload and process any documents you provide.
2.4 Enterprise Enquiry Data
When you submit the Enterprise Plan enquiry form at /enterprise, we collect: company name, contact name, work email, phone, team size, use case description, payment preference, and net payment terms. This data is used solely to respond to your enquiry and is visible only to Samcom Technologies's sales team and Super Admin users.
2.5 Automatically Collected Technical Data
- Server logs: IP addresses, browser type, OS, pages visited, timestamps, HTTP response codes
- Session tokens: JWT authentication tokens stored in browser localStorage (see Section 12)
- Usage metrics: Feature usage patterns, API call volumes, error rates — aggregated, not individually identifiable
- WebSocket connection data: Real-time event delivery for inbox, notifications, and presence features
2.6 Third-Party Integration Data
If you connect external systems via Contact Sync or API webhooks, we may receive data from those sources. You are responsible for ensuring lawful transfer of that data into Pingly.
3. WhatsApp Data Processing
Pingly offers two WhatsApp integrations with distinct data-handling characteristics. It is important that you understand which applies to your setup.
3.1 WhatsApp Business API (via Gupshup BSP)
When you use the WhatsApp Business API integration, messages are delivered through Gupshup(an authorised Meta Business Solution Provider). In this model:
- Message content passes through Gupshup's infrastructure on its way to and from WhatsApp
- Inbound WhatsApp voice calls are detected and can be routed to your VOIP PBX or AI Voice Agent
- Template messages sent to contacts are subject to Meta's WhatsApp Business Policy
- Gupshup's Privacy Policy applies: gupshup.io/privacy-policy
3.2 WhatsApp Direct (Personal Number via QR Scan)
WhatsApp Direct connects your personal WhatsApp number to Pingly using an open-source library (Baileys). This is a non-official integration and is not affiliated with or endorsed by Meta Platforms, Inc.
In this model, Pingly processes:
- Session credentials: Encrypted WhatsApp session keys stored in our database, required to maintain the connection
- Message content: All inbound and outbound messages on the connected number, stored in your workspace's conversation inbox
- LID (Linked Device) map: A mapping of WhatsApp's internal identifiers to phone numbers, stored per workspace for privacy-mode resolution
- Historical chat sync: When you first connect via QR, WhatsApp may deliver recent message history (typically last 50–100 chats). Pingly ingests these into your inbox and stores them as conversation records
- Contact profile pictures: Fetched from WhatsApp and cached (refreshed every 7 days) as
profilePictureUrlon Contact records - Call notifications: When a customer calls your WhatsApp number, Pingly records the call event (caller JID, timestamp, duration if available) in the conversation timeline. Note: WhatsApp Direct does not route or connect voice calls — it shows notifications only.
- WhatsApp Groups (if enabled): Group JID, group name, participant list, and group messages — stored only if the "Receive group messages" setting is enabled by the workspace admin
Data for WhatsApp Direct sessions is stored only within your workspace and is not shared with Gupshup or any BSP. It is transmitted between your linked phone and our server using WhatsApp's own end-to-end encryption (E2EE).
4. Voice & Call Data
Pingly supports voice call handling for WhatsApp Business API (BSP) workspaces. WhatsApp Direct workspaces receive call notifications only (no call routing or recording).
4.1 What We Store for Voice Calls (BSP)
- Call event log: Caller phone number, timestamp, call duration, call status (answered / missed / rejected), and agent who answered
- VOIP routing records: Which SIP trunk or extension the call was routed to, and the outcome
- AI Voice Agent transcripts: If an AI Voice Agent handles the call, the transcript of the conversation is stored in the conversation timeline — linked to the caller's Contact record
- Missed-call auto-reply log: A record of the WhatsApp message automatically sent to a caller who was not answered
4.2 Call Recordings
Pingly itself does not record voice calls. Recording, if any, is performed by your VOIP PBX or SIP provider and is governed by that provider's policies. You are responsible for informing callers of any recording in accordance with applicable law (e.g., Indian Telegraph Act, TRAI regulations).
4.3 Browser SIP WebPhone
When agents use the browser-based SIP WebPhone feature, the browser establishes a WebRTC/SIP connection directly to your configured SIP server. Pingly does not proxy or record audio streams; it only manages the signalling (call state, routing instructions).
4.4 WhatsApp Direct — Call Notifications Only
For WhatsApp Direct workspaces, Pingly stores only the call notification event (caller, timestamp, missed/answered status). No audio, no routing, no AI agent is involved. The notification appears in the conversation timeline so agents are aware a call was attempted.
5. AI & Chatbot Data
5.1 What Data Is Sent to AI Providers
When the AI chatbot feature is enabled, Pingly sends the following to your chosen AI provider (Anthropic Claude or OpenAI GPT) to generate a response:
- The last 20 messages of the conversation (as context window)
- Relevant excerpts from your Knowledge Base documents (vector-matched to the query)
- The system prompt you configured
- The incoming customer message
5.2 AI Provider Privacy Policies
- Anthropic (Claude): anthropic.com/privacy
- OpenAI (GPT-4o): openai.com/policies/privacy-policy
5.3 AI Training
Pingly does not use your conversation data to train its own AI models. API calls to Anthropic and OpenAI are made under their API (enterprise-tier) terms, which by default do not use your data for model training. Your API keys are used — we never use a shared platform key that could mingle your data with other customers.
5.4 AI Reply Suggestions
The AI reply suggestion feature (agent assist) sends the current conversation context to the AI provider to generate suggested replies shown only to the agent. Suggestions are not sent to customers unless the agent chooses to send them.
6. How We Use Your Information
| Purpose | Legal Basis |
|---|---|
| Provide and operate the Pingly platform | Contractual necessity |
| Process and deliver WhatsApp and Web Chat messages | Contractual necessity |
| Authenticate users and maintain secure sessions | Contractual necessity / Legitimate interests |
| Route inbound WhatsApp voice calls to VOIP / AI Voice Agent (BSP) | Contractual necessity |
| Display WhatsApp call notifications in inbox (WA Direct) | Contractual necessity |
| Run AI chatbot on your Knowledge Base and conversation context | Contractual necessity |
| Generate analytics, CSAT summaries, and performance reports | Contractual necessity |
| Process subscription payments via Razorpay | Contractual necessity |
| Respond to Enterprise Plan enquiries | Legitimate interests / Consent |
| Send SLA breach alerts, system notifications, and billing emails | Contractual necessity |
| Improve platform features, fix bugs, and prevent abuse | Legitimate interests |
| Comply with legal obligations (DPDP Act, IT Act, court orders) | Legal obligation |
We do not sell, rent, or use your data or your end-customers' data for advertising purposes.
8. Billing & Payments
Subscription payments, add-on purchases, and coupon redemptions are processed by Razorpay(Razorpay Software Private Limited, India). Pingly does not store your full card number, CVV, or bank account details. Razorpay's Privacy Policy applies to payment data: razorpay.com/privacy
We store the following billing records:
- Razorpay
order_idandpayment_id(tokenised references only) - Subscription plan, billing cycle (monthly/annual), amount, currency (INR)
- Invoice details: company name, address, GST number (for GST-compliant invoices)
- Payment status, renewal dates, and failed-payment events
- Coupon codes applied and discount amounts
- Billing audit log entries for all billing events (plan change, upgrade, downgrade, cancellation)
9. Data Retention
We retain personal data for as long as necessary for the purposes described, subject to:
| Data type | Retention period |
|---|---|
| Conversation messages & media | Subscription duration + 90 days after termination, then deleted |
| Contact profiles | While workspace is active + 90 days after termination or deletion request |
| WhatsApp Direct session keys | Until workspace disconnects the session; purged on revocation |
| WhatsApp LID map & history sync data | Tied to the workspace session; deleted with session |
| Voice call event logs | Up to 12 months, then deleted |
| AI Voice Agent transcripts | Same as conversation messages — 90 days post-termination |
| Knowledge Base documents | Until deleted by admin, or workspace termination + 90 days |
| Account / user data | Until account deleted or workspace terminated |
| Billing records & invoices | 7 years (statutory requirement under Indian tax law) |
| Audit logs | 12 months |
| CSAT ratings | Subscription duration + 90 days |
| Enterprise enquiry form data | 2 years from submission, then deleted |
| Server logs (IP, access logs) | 90 days |
You may request early deletion by contacting us at privacy@pingly.in. Backup copies are securely purged within 30 days of primary data deletion.
10. Security
We implement industry-standard technical and organisational measures:
- Encryption in transit: TLS 1.2+ for all web traffic and API calls
- Encryption at rest: AES-256 encryption for sensitive fields (API keys, WhatsApp session tokens)
- Password hashing: bcrypt with per-user salts — plaintext passwords are never stored
- Authentication: JWT-based sessions with configurable idle timeout; role-based access control (SUPER_ADMIN, ADMIN, MANAGER, AGENT, SUPPORT)
- Database access: Restricted to the application server; no public database endpoint
- Audit logging: All privileged actions (workspace override, plan change, Super Admin access) are logged with actor and timestamp
- Dependency management: Regular security patches and dependency updates
- Infrastructure: Hosted on dedicated VPS within India with firewall rules limiting external access
11. Your Rights (DPDP Act 2023 / GDPR)
Depending on your jurisdiction, you have the following rights. We honour these rights for all users regardless of location, consistent with India's DPDP Act 2023 and GDPR principles.
Access
Request a copy of the personal data we hold about you, including what data we have collected and how it is used.
Rectification
Request correction of inaccurate or incomplete personal data.
Erasure
Request deletion of your personal data ("right to be forgotten"). Subject to legal retention requirements.
Data Portability
Receive your account data in a structured, machine-readable format (JSON/CSV).
Restriction
Request that we temporarily or permanently restrict processing of your data.
Objection
Object to processing based on our legitimate interests.
Withdraw Consent
Withdraw consent at any time where processing is consent-based, without affecting prior processing.
Nominate
(DPDP Act) Nominate another individual to exercise your data rights on your behalf in case of death or incapacity.
Grievance Redressal
(DPDP Act) Lodge a complaint with our Grievance Officer (see Section 16) or with the Data Protection Board of India.
Non-discrimination
Exercise your rights without receiving inferior service or being penalised.
Workspace users (Admins / Managers / Agents): Access and update profile data in Settings → Profile. To delete your account, contact your Workspace Administrator or email us.
End-customers (Contacts): Contact the business that communicated with you via Pingly.Samcom Technologies acts as a data processor in that relationship and will assist the Customer in fulfilling your request.
To exercise any right, email privacy@pingly.in with the subject "Privacy Request". We will respond within 30 days (7 business days for DPDP Act requests where mandated).
13. Children's Privacy
Pingly is a business-to-business (B2B) platform intended for use by organisations and their employees. It is not directed at children under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child under 18 has provided us with personal data without parental consent, we will delete it promptly. If you believe a child's data has been collected, contact us at privacy@pingly.in.
14. International Data Transfers
Samcom Technologies is based in India. Your data is primarily stored on servers within India. However, some data may be processed by sub-processors in other countries (e.g., Anthropic and OpenAI in the United States) when you enable AI features. When we transfer personal data internationally, we rely on:
- Data Processing Agreements with all sub-processors
- Standard Contractual Clauses (SCCs) where required
- Adequacy decisions by relevant data protection authorities where available
By using Pingly and enabling AI features, you consent to the transfer and processing of relevant data in the United States and other countries as described above.
15. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our practices, technology, or legal requirements. When we make material changes, we will:
- Update the "Effective Date" and "Last Updated" at the top of this page
- Display a prominent in-app notice for at least 14 days
- Send an email notification to registered Workspace Administrators
Your continued use of Pingly after the effective date of any revised policy constitutes acceptance of the changes. If you do not agree to material changes, you may cancel your subscription before the effective date.
16. Contact Us & Grievance Officer
For any questions, privacy requests, or complaints about this Privacy Policy or our data practices:
Samcom Technologies
Grievance Officer / Data Protection Contact
Email: privacy@pingly.in
Address: Samcom Technologies, India
Website: pingly.in
We aim to respond to all privacy requests within 30 days(7 business days for urgent matters or requests under the DPDP Act 2023). For security vulnerabilities, mark your email "URGENT — Security".
Under the Digital Personal Data Protection Act, 2023 (India), if your concern is not resolved to your satisfaction, you may approach the Data Protection Board of India once it is constituted by the Central Government.