FLIPTOE PRIVACY POLICY

For the Fliptoe Mobile Application, Website and Related Services

Last Updated: 24 August 2026

Effective Date: [24 August 2026]

1. INTRODUCTION

Fliptoe Private Limited ("Fliptoe", "Company", "we", "us" or "our") is committed to protecting the privacy and security of individuals who use the Fliptoe mobile application, website and related services (collectively, the "Services"). This Privacy Policy explains how we collect, receive, use, process, disclose, retain and protect information relating to users of Fliptoe ("User", "you" or "your").

Fliptoe is a social live-streaming and communication platform in which a person may participate as a viewer/user, become a streamer/host, interact with other users, send or receive virtual gifts, use paid or virtual features, participate in one-to-one calls, and use the random/roulette calling feature to connect with other users. Fliptoe uses a single application and does not require separate applications for viewers and streamers.

This Privacy Policy applies to information processed through the Fliptoe application, the Fliptoe website, customer-support channels, and other services that expressly link to this Privacy Policy.

2. SCOPE AND ACCEPTANCE

By downloading, installing, registering for, accessing or using Fliptoe, you acknowledge that you have read and understood this Privacy Policy. Where consent is required by applicable law, we will request consent through an appropriate notice or consent mechanism before processing the relevant personal data.

If you do not agree with this Privacy Policy, you should not access or use the Services. If you use a particular feature that requires additional information or permissions, we may provide an additional feature-specific notice.

This Privacy Policy should be read together with Fliptoe's Terms of Use, Community Guidelines and other policies made available through the Services.

3. ABOUT THE FLIPTOE SERVICE

Fliptoe allows the same account holder to use multiple roles and features. Depending on how you use the Services, you may:

• create and maintain a Fliptoe account and profile;
• browse profiles, streams and other user-generated content;
• start or participate in live streams;
• use camera and microphone features for live streaming and calls;
• send or receive virtual gifts and participate in the Fliptoe virtual-currency/coin economy;
• make or receive one-to-one voice or video calls where available;
• use the random/roulette calling feature to be matched with other eligible users;
• communicate through chat or other in-app communication features;
• report, block or otherwise interact with other users; and
• use other features that Fliptoe may introduce from time to time.

4. INFORMATION WE COLLECT

The information we collect depends on how you use Fliptoe, the permissions you grant, and the features you use.

4.1 Information You Provide Directly

• Account and registration information, such as your name, mobile number, email address, date of birth, gender or other profile information, where requested.
• Authentication information, including OTPs or verification information used to verify access to an account.
• Profile information, including profile photograph, biography, interests, preferences and other information you choose to display.
• User-generated content, including text, photographs, videos, live-stream content, comments, messages or other content you voluntarily submit or transmit through the Services.
• Customer-support and grievance information, including information you provide when contacting Fliptoe.
• Information you provide when participating in promotions, surveys, campaigns, contests or other optional activities.

4.2 Camera, Microphone and Communication Data

When you use live streaming, voice calling, video calling, or related communication features, Fliptoe may request access to your device camera and microphone. These permissions are used to enable the feature you choose to use. Audio and video may be processed and transmitted between your device and other participants or Fliptoe's service infrastructure as necessary to provide the relevant feature.

Fliptoe does not represent that every audio or video interaction is recorded or permanently stored. If a specific feature records, stores, moderates or otherwise retains an interaction, Fliptoe will provide the applicable disclosure or notice where required.

4.3 Device and Technical Information

• IP address and approximate network information;
• device type, operating system, app version, language and configuration;
• unique or resettable identifiers permitted by applicable platform rules;
• network and connectivity information;
• crash reports, diagnostics, performance information and log data;
• security and fraud-prevention information; and
• information about how you interact with the Services, such as feature usage, session information and timestamps.

4.4 Location Information

Where a Fliptoe feature requires location information and you grant the relevant permission, we may process device location or approximate location for purposes such as service availability, security, fraud prevention, feature functionality, localisation or improving the Services. You can control device location permissions through your device settings, subject to the effect that disabling permission may make certain features unavailable.

4.5 Payment and Transaction Information

When you purchase virtual coins, gifts, subscriptions or other paid features, payment transactions may be processed by third-party payment processors, app stores or other authorised payment providers. Fliptoe may receive transaction-related information such as transaction identifiers, amount, currency, payment status, product purchased and limited payment metadata necessary to reconcile and provide the transaction.

Unless specifically stated otherwise, Fliptoe does not require you to provide your full card number or banking credentials directly to Fliptoe. Such information may be collected and processed by the applicable payment provider under its own privacy policy.

4.6 Information From Other Users and Third Parties

We may receive information about you from other users, service providers, identity/verification providers, payment providers, analytics providers, security vendors, app stores and other third parties where permitted by law. For example, another user may report your account or submit information in connection with a safety or abuse report.

5. HOW WE USE INFORMATION

We may use personal information for the following purposes, as applicable:

• creating, authenticating and managing your account;
• providing live streaming, calling, chat, profile, discovery and other Fliptoe features;
• enabling a user to act as a streamer/host without requiring a separate host application;
• facilitating random/roulette matching and other user-to-user connection features;
• processing virtual coins, gifts, purchases, withdrawals or other transactions where applicable;
• providing customer support and responding to requests or complaints;
• sending service messages, security alerts, verification messages, push notifications and other operational communications;
• personalising and improving the Services;
• monitoring performance, diagnosing technical problems and maintaining reliability;
• detecting, investigating and preventing fraud, abuse, spam, manipulation, unauthorised access and other harmful activity;
• protecting users, the Company and the public, including responding to safety incidents and lawful requests;
• enforcing the Terms of Use, Community Guidelines and other policies;
• conducting analytics using aggregated, de-identified or otherwise non-identifying information where appropriate;
• complying with applicable laws, regulations, legal processes and governmental requests; and
• carrying out other purposes that are disclosed to you at the time of collection or otherwise permitted by law.

6. USER CONTENT, LIVE STREAMING AND USER-TO-USER COMMUNICATION

Fliptoe is an interactive platform. Content that you voluntarily make available through a public profile, live stream, chat, comment, call-related feature or other user-facing feature may be visible or accessible to other users according to the functionality and privacy controls of that feature.

You should therefore avoid sharing sensitive personal information, financial credentials, passwords, private identification numbers or other information with another user unless you are comfortable doing so. Fliptoe cannot control what another user independently records, screenshots, copies, retransmits or otherwise shares outside the Services.

Where necessary for safety, moderation, fraud prevention, legal compliance or enforcement of our policies, Fliptoe may process reports, metadata and other information associated with user interactions. Any recording or retention of audio/video content, if implemented for a specific feature, will be subject to the applicable feature disclosure and legal requirements.

6.1 Random / Roulette Calling

The random/roulette calling feature is designed to connect eligible users with other users on a random basis. Using this feature may cause your profile, display name and other information that is ordinarily visible to other users to be shown to a matched participant. Camera and microphone data may be processed if you enable video or voice communication.

Because random matching involves interaction with people you may not know, you should use appropriate caution and should not disclose sensitive information to strangers. You can use available block, report or safety controls where provided.

7. COOKIES, LOGS AND ANALYTICS

The Fliptoe website may use cookies, pixels, local storage or similar technologies to maintain sessions, remember preferences, improve security, understand website usage and measure performance. The mobile application may use comparable technologies and analytics mechanisms permitted by the mobile platform.

Third-party analytics, crash reporting, advertising or performance services, if integrated, may process certain technical and usage information. The exact providers used by Fliptoe may change as the Services evolve. Fliptoe will maintain its disclosures and Play Store Data Safety information to reflect applicable data practices.

8. SHARING AND DISCLOSURE OF INFORMATION

Fliptoe does not sell or rent personal information as a standalone commercial product. We may disclose or share information in the following circumstances:

• Service providers: with vendors that provide hosting, cloud infrastructure, analytics, communications, customer support, security, payment processing, verification or other services on our behalf.
• Other users: information that you choose to make public or available through profiles, streams, calls, chats or other interactive features may be accessible to other users as part of the Services.
• Legal and regulatory requirements: where required by law, regulation, court order, governmental request or lawful process.
• Safety and security: where reasonably necessary to prevent, investigate or respond to fraud, abuse, illegal activity, threats, security incidents or harm.
• Protection of rights: to protect the rights, property, safety and legitimate interests of Fliptoe, its users, service providers or the public.
• Corporate transactions: in connection with a merger, acquisition, financing, restructuring, sale of assets, change of control or similar transaction, subject to applicable safeguards.
• With your direction or consent: where you ask us to share information or otherwise consent to the disclosure.
• Aggregated or de-identified information: information that cannot reasonably identify you may be used or shared for analytics, research, reporting and business purposes, subject to applicable law.

9. THIRD-PARTY SERVICE PROVIDERS

Fliptoe may rely on third-party providers for infrastructure and functionality. These providers may process information on Fliptoe's behalf or independently under their own terms and privacy policies. Examples may include cloud hosting, database infrastructure, payment processing, app-store services, SMS/OTP delivery, push notifications, analytics, crash reporting, content safety, communications and security services.

Before publishing this policy, Fliptoe should maintain an internal inventory of every third-party SDK, API, processor and service that receives data from the application and ensure that the public Privacy Policy and Google Play Data Safety declaration accurately reflect those data flows.

10. DATA SECURITY

Fliptoe uses reasonable technical and organisational measures designed to protect personal information from unauthorised access, alteration, disclosure, misuse or destruction. Depending on the nature of the information and risk, safeguards may include access controls, authentication, encryption in transit, secure infrastructure, logging, monitoring, backups, restricted administrative access and other security measures.

No internet-based service can guarantee absolute security. You are responsible for maintaining the security of your account credentials and for notifying Fliptoe promptly if you believe your account has been compromised.

11. DATA RETENTION

Fliptoe retains personal information for as long as reasonably necessary to provide the Services, maintain security, prevent fraud and abuse, resolve disputes, enforce agreements, complete transactions, satisfy legal or regulatory obligations, or otherwise fulfil the purposes described in this Privacy Policy.

When information is no longer required for these purposes, Fliptoe will take reasonable steps to delete, anonymise or otherwise dispose of it in accordance with applicable law and our retention practices.

Certain records may need to be retained after account deletion where required for legal compliance, fraud prevention, security, accounting, dispute resolution or other legitimate purposes. Where possible, retained information will be restricted, anonymised or isolated from ordinary product use.

12. ACCOUNT DELETION AND DATA DELETION

Fliptoe will provide an accessible mechanism for users to request deletion of their account and associated personal information, subject to applicable legal and operational requirements.

Users may request account deletion through the in-app account settings or the external account-deletion web resource made available by Fliptoe. The external deletion page should be accessible without requiring the user to reinstall the application.

Upon a valid deletion request, Fliptoe will delete or anonymise associated personal information within the period required by applicable law and our deletion procedures, except where specific information must be retained for legal, security, fraud-prevention, accounting, dispute-resolution or other lawful purposes.

Uninstalling the Fliptoe application alone does not necessarily delete your account or personal information. You must use the account-deletion mechanism provided by Fliptoe.

13. YOUR RIGHTS AND CHOICES

Subject to applicable law, you may have rights relating to your personal information, including rights to access, correction, updating, deletion, withdrawal of consent, grievance redressal and other rights provided under applicable data-protection law.

• You may update certain profile information through your account settings.
• You may control camera, microphone, location and notification permissions through your device settings.
• You may use available block, report and safety features to control interactions with other users.
• You may request deletion of your account and associated data through the designated deletion mechanism.
• Where processing is based on consent, you may withdraw consent where permitted; withdrawal may affect availability of certain features.
• You may contact Fliptoe using the contact details below for privacy-related requests or grievances.

14. CHILDREN AND AGE REQUIREMENTS

Fliptoe is intended for adults and is not directed to persons under 18 years of age. We do not knowingly permit minors to use the Services where prohibited by applicable law.

If we learn that an account belongs to a person below the permitted age, we may restrict or terminate the account and take reasonable steps to delete associated personal information, subject to applicable law.

If applicable law requires a different approach to age assurance or verifiable parental/guardian consent, Fliptoe will implement the required process.

15. INTERNATIONAL DATA TRANSFERS

Fliptoe may use service providers or infrastructure located in India or other countries. Where personal information is transferred across jurisdictions, Fliptoe will take reasonable steps to ensure that the transfer and processing are conducted in accordance with applicable data-protection and privacy laws.

The laws of the country receiving information may differ from those of your country. Information may also be disclosed to authorities in the recipient jurisdiction where legally required.

16. FRAUD, SAFETY, MODERATION AND LAW ENFORCEMENT

Because Fliptoe facilitates live and real-time interaction between users, we may process information to protect the platform and its users. This may include account identifiers, device and network information, transaction information, reports, moderation signals, interaction metadata and other information reasonably necessary to detect or investigate misuse.

We may cooperate with law-enforcement, regulators, courts and other competent authorities where required by law or where necessary to protect users, the public, Fliptoe or others from serious harm.

17. USER RESPONSIBILITY AND THIRD-PARTY INTERACTIONS

Fliptoe provides tools that allow users to interact directly with one another. Fliptoe is not responsible for information that a user voluntarily discloses to another user, or for how another user may use information obtained through the Services.

You should exercise caution when communicating with strangers, including through random/roulette calling, live streams and direct calls. Do not share passwords, OTPs, payment credentials, financial account details or other sensitive information with other users.

18. THIRD-PARTY LINKS AND SERVICES

The Services may contain links to or integrations with third-party services. Fliptoe is not responsible for the privacy, security or practices of third parties that operate independently from Fliptoe. You should review the applicable third party's privacy policy before providing information to it.

19. CHANGES TO THIS PRIVACY POLICY

Fliptoe may update this Privacy Policy from time to time to reflect changes to the Services, technology, business practices or applicable law. The updated version will be made available through the website or app and will state the updated date.

Where required by law, Fliptoe will provide additional notice or obtain consent for material changes. Your continued use of the Services after an updated policy becomes effective will be handled in accordance with applicable law.

20. GOVERNING LAW

This Privacy Policy shall be interpreted in accordance with the laws applicable to Fliptoe and its users. Subject to mandatory rights and protections available to you under applicable law, disputes relating to this Privacy Policy shall be subject to the jurisdiction of the competent courts in India.

21. GRIEVANCE OFFICER / PRIVACY CONTACT

For privacy questions, requests, complaints or grievances relating to the Fliptoe Services, please contact Fliptoe using the details below:

We will endeavour to acknowledge and resolve privacy-related grievances within the timelines prescribed by applicable law.

22. IMPORTANT PLATFORM AND DATA-SAFETY DISCLOSURE

The Fliptoe Privacy Policy is intended to be consistent with the data practices disclosed in the Google Play Console Data Safety section and with the disclosures presented to users inside the application. If Fliptoe introduces a new data collection practice, SDK, permission, payment method, communication feature or other material processing activity, the relevant disclosures should be reviewed and updated before or when the change is deployed.

In particular, Fliptoe should ensure that the following are accurately reflected wherever applicable: account information; profile photographs; user-generated content; camera and microphone access; location; device and network information; messages and communication data; payment/transaction data; virtual coins and gifts; analytics and diagnostics; advertising data, if any; and information shared with third-party service providers.

23. CONTACT

If you have questions about this Privacy Policy or how Fliptoe handles personal information, contact us at support@fliptoe.com.

Fliptoe Private Limited
K.No.3216/79 Rajendra Park, Gurgaon, 122001
www.fliptoe.com

APPENDIX A — PRE-PUBLICATION IMPLEMENTATION CHECKLIST

The following items should be completed by Fliptoe before publishing this Privacy Policy or submitting the application for Google Play review.

• Confirm the exact legal company name and registered office address.
• Insert the final privacy/grievance officer name and email address.
• Insert the public privacy-policy URL.
• Create and test the external account-deletion webpage.
• Implement and test an in-app account-deletion path.
• Confirm what personal information is actually collected during registration and profile creation.
• Confirm whether date of birth and gender are mandatory or optional.
• Confirm whether device location is collected and for which exact features.
• Inventory every camera and microphone use and ensure permission disclosures precede permission requests where required.
• Confirm whether live streams, calls, chat messages, thumbnails, screenshots, recordings or moderation copies are stored.
• Confirm whether call metadata (duration, participants, timestamps, call cost) is stored.
• Confirm exact virtual-currency/coin, gift, purchase, withdrawal and transaction data flows.
• Inventory all payment processors and app-store billing systems.
• Inventory all analytics, crash-reporting, advertising, attribution, notification, security and moderation SDKs.
• Confirm each SDK's data collection and sharing behavior and reflect it in Google Play Data Safety.
• Confirm cloud/hosting providers, database locations and cross-border transfers.
• Define actual retention periods for account, transaction, security, moderation and support data.
• Define what data is deleted immediately, what is anonymised, and what must be retained for legal/security purposes.
• Confirm the process for responding to privacy rights and grievances.
• Confirm the minimum age and age-verification flow.
• Confirm whether any advertising or personalised advertising is used.
• Confirm whether contacts/address book, SMS, call logs or other device data are accessed. If not, do not disclose them.
• Confirm whether any biometric, facial-analysis or face-mapping data is collected or transmitted. If the beauty/filter SDK processes camera frames only on-device and does not transmit them, document that accurately in the technical/privacy assessment.
• Review the final policy with qualified Indian privacy/legal counsel before publication.