Privacy Policy

Version 1.0 · Effective April 13, 2026 · DPDP Act 2023 Compliant

We do not sell personal data. We do not show ads. Partners never see your PAN or UPI.
Data Protection Officer: dpo@hangon.live

1. Who We Are and Who This Covers

HangOn Interactive Private Limited is the Data Fiduciary under the DPDP Act 2023. This policy applies to all Users of any HangOn feature: tournaments, discovery, chat, feed, voice rooms, venue booking, and rewards.

2. What Data We Collect and Why

2.1 Account and Identity

Data	Why We Collect It	Legal Basis
Mobile phone number	Account login, OTP verification	Contract
Display name	Profile display across all features	Contract
Date of birth	Age verification, minor account detection	Legal obligation
Profile photo	Discovery, social feed identity	Consent
City / location	Local tournament and venue discovery	Consent
Guardian phone + PAN + UPI (minor accounts)	Financial compliance for minors	Legal obligation

2.2 Gaming Profile

Data	Why	Legal Basis
In-game names (IGNs)	Tournament registration, profile display	Contract
Game player IDs	Tournament verification	Contract
Game ranks and stats	Profile display, matchmaking	Consent
Gaming platform (Mobile/PC)	Tournament filtering	Contract
Playstyle preferences	Discovery matching	Consent

2.3 Tournament Financial Data

Data	Why	Shared With	Legal Basis
PAN number	TDS deduction + Form 16A	Income Tax Dept.	Legal obligation
UPI ID	Prize payout disbursement	Razorpay only	Contract
Entry fee payment ID	Refund processing	Razorpay only	Contract
Net winnings per FY	Annual TDS reconciliation	Income Tax Dept.	Legal obligation

2.4 Partner Financial Data (Partners Only)

Data	Why	Shared With
Business name + address	Partner profile, KYC	Not shared
PAN / GST number	Tax compliance, KYC	Tax authorities if required
Bank account + IFSC	Earnings settlement	Razorpay only
Tournament history and earnings	Settlement, analytics	Not shared

2.5 Social and Communication Data

Data	Why	Who Can See It
Social feed posts and media	Feed display	Based on your privacy settings
Chat messages	Messaging service	Only the parties in the conversation
Voice room participation	Service delivery	Other room participants (live only)
Connections / matches	Discovery feature	Only you and the connected user
Blocked users list	Safety feature	Only you
Reports submitted	Safety and moderation	HangOn safety team only

2.6 Venue Booking Data

Data	Why	Shared With
Booking date/time/venue	Booking confirmation	The booked venue (Partner)
Payment for booking	Transaction processing	Razorpay only
Booking history	Refund processing, records	Not shared

2.7 Automatically Collected Data

Data	Why	Legal Basis
Device fingerprint (hashed)	Multi-account fraud detection	Legitimate interest
IP address	Geographic restriction enforcement	Legal obligation
City-level GPS (if permitted)	Local discovery, venue proximity	Consent
App version and OS	Bug fixes, compatibility	Legitimate interest
Session and usage data	Feature improvement	Legitimate interest
Push notification token	Transactional notifications	Contract
Crash reports	Stability improvements	Legitimate interest

3. What We Do NOT Collect

•Full bank account credentials, card numbers, or net banking passwords
•Your camera, microphone, or contacts without explicit in-app permission
•Your location continuously — location is read only when you open the app
•Data from minors under 13 under any circumstances

4. Data Sharing

4.1 Third-Party Service Providers

Provider	What They Receive	Purpose	Their Policy
Razorpay	Payment IDs, UPI IDs, bank details	Payment collection + payout	razorpay.com/privacy
Cloudflare R2	Screenshots, profile photos, KYC docs	Secure file storage	cloudflare.com/privacypolicy
Expo / Firebase	Push notification tokens only	Notifications	expo.dev/privacy
MSG91 / Twilio	Phone number + OTP message	OTP verification	Provider privacy policy

4.2 Legal Disclosures

We share data with government and law enforcement authorities when: required by a valid court order or warrant, required by law (e.g. quarterly TDS filings with Income Tax Department), or in cases involving imminent threat to life or CSAM. We will attempt to notify you of legal requests unless prohibited by law.

4.3 What We Never Share

•Your PAN, UPI ID, or bank details with any Partner, other Gamer, or advertiser
•Your private chat messages with any third party except pursuant to a valid legal order
•Your personal data with advertisers — HangOn does not run ad-based monetisation
•Your contact details (phone number, email) with other users through any Platform feature

5. Data Retention

Data Category	Retention Period	Reason
Account and profile data	5 years after account deletion	Legal disputes, audit
Tournament and result records	7 years	Financial record requirement
TDS ledger and PAN data	8 years	Income Tax Act obligation
Payment transaction records	7 years	GST and financial audit
Chat messages	12 months, then permanently deleted	Service delivery
Social feed posts	Until you delete them + 30 days	Cached copies
Tournament screenshots	90 days post-tournament	Dispute resolution
Device fingerprints	2 years from last active session	Fraud prevention
Fraud signals and logs	3 years	Pattern detection
Venue booking records	3 years	Dispute and audit
Push notification tokens	Until account deletion	Service delivery
Voice room data	Not recorded — no retention	N/A

6. Your Rights under DPDP Act 2023

Right to access

Request a summary of personal data we hold about you and how it is used

Right to correction

Request correction of inaccurate or incomplete data

Right to erasure

Request deletion of your data, subject to legal retention obligations

Right to withdraw consent

Withdraw consent where processing is consent-based (may affect feature access)

Right to nominate

Nominate a person to exercise your rights in case of death or incapacity

Right to grievance

Lodge a complaint with our DPO or the Data Protection Board of India

Exercise your rights by contacting dpo@hangon.live. We respond within 30 days. We may require identity verification before processing a request.

7. Permissions the App Requests

Permission	Why Needed	When Requested	Can You Decline?
Camera	Profile photo, screenshot upload	When you choose to upload	Yes — use gallery instead
Photo Library	Screenshot upload for verification	When submitting match proof	Yes — disqualifies from payout
Microphone	Voice rooms	When you join a voice room	Yes — listen-only mode
Location (approximate)	Local tournament/venue discovery	When you open discovery	Yes — city selection manually
Notifications	Tournament updates, creds, payouts	At onboarding	Yes — use app manually
Contacts	Not requested	Never	N/A

8. Data Security

•All data in transit: TLS 1.3 encryption
•PAN, UPI IDs, bank details: AES-256 encryption at rest
•Screenshots and KYC docs: stored in Cloudflare R2 with signed URL access — not publicly accessible
•Access to financial data: restricted to named HangOn personnel on need-to-know basis
•Admin accounts: 2FA mandatory
•Data breach notification: within 72 hours of discovery to affected users and the Data Protection Board

9. Cookies and Tracking

The HangOn mobile app does not use browser cookies. The HangOn website uses essential session cookies only for authentication. No advertising, analytics, or third-party tracking cookies are used on any HangOn surface. HangOn does not use pixel tracking or fingerprinting technologies on the website beyond what is described in Section 2.7.

10. Children's Privacy

HangOn does not knowingly collect personal data from users under 13. For users aged 13–17, data processing is conducted under Guardian consent. Guardian data is processed only for the purpose of enabling the minor's account and financial transactions. For full minor data protection details see the Child Safety Policy.

11. Contact

Data Protection Officer (DPDP Act)

dpo@hangon.live

Grievance Officer

grievance@hangon.live

Privacy Queries

privacy@hangon.live

Data Protection Board of India

www.meity.gov.in

HangOn Interactive Private Limited, Delhi, India · hangon.live