Privacy Policy

Version 1 · Effective 16 October 2026

Twinkles is published on Google Play and operated by Shipline Solutions. Shipline Solutions Private Limited is the Data Fiduciary (a private company limited by shares under the Companies Act, 2013, 35B, Chavadi Street, Pallavaram, Kanchipuram - 600043, Tamil Nadu, India, CIN U62099TN2026PTC194573; privacy contact privacy@twinkles.live; Grievance Officer Abishek Reddy, Director, Shipline Solutions Private Limited, grievance@twinkles.live, +91 93810 26704).

What we collect and why

• Name: account management and showing a profile to other users. A Wisher appears to other users as “Wisher #NNNN”; a Star's name is shown to a Wisher only after he adds her to Court.
• Phone number: account creation, OTP login, account management and fraud prevention.
• Date of birth and gender: adult eligibility, role assignment and account management. Gender fixes the Wisher or Star role; DOB cannot be edited in the app after onboarding (contact support for corrections).
• City, languages and interests: profile functionality and personalisation. City is optional typed text, not a location-sensor reading.
• Payment information: the Razorpay in-app checkout collects payment details to process a recharge; Razorpay processes that information as our service provider.
• Purchase history: recharge orders, Gem and Bean transactions and payout records for service delivery, account management, reconciliation and legal records.
• In-app messages: stored chats for conversation delivery and safety. Contact details are masked and text may be classified for safety; do not assume chats disappear when a party deletes an account.
• Voice and sound: a Star's verification voice sample is stored for account review. Call audio is relayed in real time by Agora or our own LiveKit media servers and is not recorded by Twinkles.
• Video: call video is relayed in real time, not recorded by Twinkles. Face-presence checks run on-device; they are not recordings of the call.
• Photos: no user-uploaded profile photos are collected under the launch design; avatars are bundled presets.
• Device and other identifiers: a keyed hash of the Android device ID, rather than its raw value, for device blocks and fraud prevention; FCM token for call notifications; Firebase installation identifier and app version for push delivery.
• App interactions and other actions: call history, Gifts, Court, ratings and reports to operate the app and prevent fraud or abuse. Reports can contain a note written by another user about you.
• ML Kit SDK diagnostics: Google's face-detection SDK may collect device and app information, performance metrics and per-installation identifiers for Google's diagnostics or analytics; face detection itself runs on-device.
• Agora SDK data: Agora may process call identifiers and network data to relay calls.
• OTP records: phone number, IP address and hashed device fingerprint in OTP challenges and counters for login and fraud prevention. OTP is delivered through 2Factor; Android SMS User Consent may offer to read the message after your approval.
• Analytics: Google Firebase Analytics receives a fixed set of app events (for example, screen and call-outcome events) to understand app use. We send no name, phone number or message content with them.
• Location: no device-location data is collected; a typed city is profile information. IP addresses also appear in OTP records and media-server operational logs, rather than being used for device-location tracking.

We use account and activity data to provide the service and enforce our safety rules, and retain some information where law, tax, fraud prevention or a lawful hold requires it. We do not sell personal data or show ads.

Who receives it

Users see only the information needed for the interaction, subject to the display rules above. Our service providers include Google/Firebase (FCM, ML Kit and Analytics), 2Factor for SMS OTP, Amazon Web Services and DigitalOcean (servers in India) for hosting, Vercel for this website, Agora for call relay, and Razorpay for payments. Calls may instead pass through our own LiveKit media servers. Service providers may hold their own operational logs.

When you delete an account

Request deletion from Me → Settings → Delete account in Twinkles or at Delete account. There is a 7-day cooling-off period in which you may log in and restore the account before processing begins. A legal, financial or safety hold may delay completion; the Contact & Grievance page explains how to ask about a hold.

At completion, we remove the profile, sessions, device binding and FCM token, verification voice files, ratings, and ordinary chats, blocks and Court links. A pseudonymous account tombstone remains to keep transaction references intact. Registration details (phone, name, DOB, gender and role) remain in a restricted vault for 180 days, then expire.

We retain the following exceptions:

• Wallets, ledger entries, payment orders, calls, Gifts, payout and tax records remain under the account identifier for applicable books-of-account, tax, payment and fraud obligations. PAN and its hash may be held for TDS; bank/UPI destination data is removed from the payout profile, while payout snapshots remain in their records.
• A report-linked pair's chats are held for 180 days after account-deletion completion, or longer only under a documented lawful hold. Reports, including other users' free-text notes, and safety decisions may remain for investigation; ordinary chats are deleted.
• Moderation events and warnings, account bans, verification-event admin decision notes (including free-text reasons), consent and deletion audit records remain as evidence. At completion, original contact details in moderation text spans are redacted unless report-held.
• A banned user's raw phone number is removed from the account at completion; an HMAC of the number, not the raw number, may remain in a time-limited ban list for fraud prevention. It can be lifted after grievance review. The ban-list entry expires after 180 days. Device blocks may remain under the hashed device identifier.
• OTP challenge records remain until their own expiry (30 days); related counters expire under their own limits. Server logs may retain user identifiers, and Agora/LiveKit operational logs may retain participant identifiers and IP addresses under their applicable log-retention rules. Razorpay retains records under its own regulatory obligations.
• Backups are not rewritten when an account is deleted; they roll off within 545 days.

Your choices and rights

Ask for an account-data summary, correction of inaccurate data, erasure through the in-app or web deletion path, or grievance review using Contact & Grievance. You may nominate a person to exercise applicable data rights after death or incapacity; contact the Grievance Officer for the process. Some records cannot be erased immediately for the reasons above.

Children and security

Twinkles is for adults aged 18 or older. We check DOB with a neutral server-side age check, lock a failed attempt until eligibility, and lock DOB after onboarding; Stars also undergo voice review. We remove accounts found to belong to minors. See Child Safety Standards. We use TLS in transit and access controls.

This is version 1, effective 16 October 2026; changes will be notified and acceptance requested where required.

What is deleted and kept

Your account is hidden and sessions revoked when you request deletion. You can log in to restore it during the 7-day window. After that, your profile, verification media, devices, blocks, wishlist, ratings and ordinary chats are deleted. Your phone is removed from the account.

Registration information is held separately for 180 days for legal compliance. Chats held for a report involving both people may remain for 180 days after completion, or longer under a lawful hold. OTP challenge records expire after 30 days.

Financial, payment, call and gift records remain for tax and accounting obligations. Reports, moderation and audit evidence may remain for safety and legal reasons; payout tax and fraud-prevention records may also remain. Backups and provider logs roll off on their own schedules. Contact the grievance officer for details.