Privacy Policy

This privacy policy (“Policy”) was last changed on August 11th, 2020. We may occasionally make changes to the Policy.
We sincerely believe that you should always know what data we collect from you, the purposes for which such data is used, and that you should have the ability to make informed decisions about what you want to share with us.
Therefore, we want to be transparent about: (i) how and why we collect, store and use your personal data in the various capacities in which you interact with us; and (ii) the rights that you have to determine the contours of this interaction.
While we would strongly advise you to read the Policy in full, the following summary will give you a snapshot of the salient points covered herein:
1. This Policy details the critical aspects governing your personal data relationship with Needly which is owned and operated by Abhinav It Solutions Private Limited, a company incorporated under the laws of India, and having its registered office at 25-31, B-wing, Bandal Dhankude Plaza, Paud road, Kothrud, Pune, Maharashtra, India - 411038;
2. Your personal data relationship with Needly varies based on the capacity in which you interact with us/avail of our products and solutions (“Services”). You could be: (i) a visitor to www.Needly.app (“Website”) or any pages thereof (“Visitor”); (ii) a person/entity availing of one of our Services (“Customer”); or (iii) an employee/agent/representative/appointee of a Customer who uses the said Service (“User”);
3. Based on whether you are a Visitor, Customer or User, the type of data we collect and the purpose for which we use it will differ and this Policy details such variations
4. This Policy is a part of and should be read in conjunction with our Terms of Service; and
5. This Policy will clarify the rights available to you vis-à-vis the personal data you share with us. If you have any queries or concerns with this Policy, please contact us via contact@aidify.io. If you do not agree with the Policy, we would advise you to not visit/use the Website or the Needly mobile application(s)/platform(s) (collectively “App”).

1.Information We Collect

1.1 Contact Lists:

We may collect and store information from your device's contact list with your explicit consent. This information may include names, phone numbers, email addresses, and other contact details. We use this information to facilitate social features within the App, such as connecting you with friends who are also using the App. Additionally, users' contact lists may be uploaded without posting a privacy policy in Play Distributed App.

1.2 Images:

The App may allow you to upload various types of images, including but not limited to profile images, template images for sending messages, and images for the App's website. These images may be stored on our servers. We understand that you may have concerns about the privacy of your images, and we take this seriously. We will take reasonable steps to protect your images from unauthorized access or disclosure. We will not use your images for any commercial purposes without your express consent.

1.3 Call Log:

Purpose of Call Log Collection: Your call log data is collected solely for the purpose of providing customer support, tracking referrals, and creating groups within the app. This disclaimer informs users that their call logs may be accessed for these functionalities.

1.4 Usage Data:

In addition to images, contact lists, and call logs, we may also collect usage data such as device information, IP addresses, browser type, pages visited, and other statistical data to improve the functionality and performance of the App.

2.How We Use Your Information

2.1 Contact Lists:

We may use the contact information collected from your device's contact list to display your contacts who are using the App, suggest friends for you to connect with, send messages, create groups, and for referral purposes. We will not share this information with third parties without your explicit consent, except as described in this Privacy Policy.

2.2 Images:

Images uploaded by users, including profile images and template images, will be used within the App for the purposes intended by the user, such as personalizing user profiles, creating message templates, and enhancing the user experience. These images may also be displayed on the App's website, if applicable.

2.3 Call Log:

Call log data is used exclusively for providing customer support, tracking referrals, and creating groups within the app. We do not use this data for any other purpose.

2.4 Usage Data:

Usage data is used to analyze trends, administer the App, track users' movements within the App, gather demographic information, and optimize our services. This data may also be utilized for referral tracking purposes.

INFORMATION WE COLLECT AND HOW WE USE IT

TYPE OF USER	VISITOR	CUSTOMER	USER
WHAT DATA WE MAY COLLECT	1. Your IP Address; 2. Your location; 3. How you behave on the Website, (what pages you land on, how much time you spend, etc.); 4. What Device you use to access the Website and its details (model, operating system, etc.); 5. Cookies and Web Beacon data; and 6. Data from third parties who have your explicit consent to lawfully share that data.If you submit an inquiry through the Website, we will ask for you’re: 7.Name; and 8. e-mail.	1. The name and e-mail of your representative who signs up for a Service on your behalf; and 2. Credit Card/Debit Card/Other Payment Mode information to check your financial qualifications, detect fraud and facilitate payments for our Services.	Your name, e-mail; Your IP Address; How you behave in the relevant product environment and use the features; What device you use to access the Website/App and its details (model, operating system, etc.); Cookies and Web Beacon data; Data from third parties who have your explicit consent to lawfully share that data; SMSs that you send or receive on your Device from your existing and prospective customers (“Group Members”) if you have opted for thesame in the relevant section of the App; Phone call logs to record your call activities with Group Members (i.e. call time, duration, phone number of relevant Group Members) if you have opted for the same in the relevant section of the App; and E-mails that you send and receive for the purpose of reading them to sync with your Group Members, if you have opted to sync your e-mail with your Needly account using our E-mail Sync App. If you do choose to activate SMS and Call Log parsing or E-mail Sync to improve your experience, you can be sure that we will never collect or store any information that does not pertain to Group Members.
HOW AND WHY WE USE IT	We use this information to analyses and identify your behavior and enhance the interactions you have with the Website. If you submit your details and give us your consent, we may use your data to send you e-mails /newsletters, re-target Needly advertisements or re-market our Services using services from third-parties like Facebook and Google.	We collect this data in order to help you register for and facilitate provision of our Services. We also use this data to enable you to make payments for our Services.  We use a third-party service provider to manage payment processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of payment processing on our behalf. If you give us your consent, we may send you newsletters and e-mails to market other products and services we may provide.	We collect this data in order to facilitate provision of our Services. We will occasionally send you e-mails regarding changes or updates to the Service that you are using. In the event you report an issue with a Service, we may also screen/video record your Device only when you use the App for a limited time period to help us better understand how to address the issue. If you give us your consent, we may send you newsletters and e-mails to market other products and services we may provide. We may also conduct anonymized usage behavior analysis at the aggregate level to determine how the features of a particular Service are being used.

WHAT ARE THE COOKIES AND WEB BEACONS REFERRED TO ABOVE?

TYPE OF FILE	COOKIES	WEB BEACON
WHAT THEY DO	Cookies are text files which are sent from our server and downloaded to your Device when you visit our Website. They are useful because they allow us to recognize your Device when you return. You can disable them through your browser should you so wish. You can find more information about cookies at: www.allaboutcookies.org	Web Beacon (also known as Clear GIF, Web Bugs or Pixel Tag) is a tiny picture file embedded on the Website/App that tracks your behavior and navigation. It is similar to a cookie in what it does, but it doesn’t get downloaded on to your Device. You can find more information about Web Beacons at: http://www.allaboutcookies.org/faqs/beacons.html
WHAT THEY WON’T DO	1. Harvest any personally identifiable information; or 2. Contain any executable software, malicious code or virus.	FOR THE AVOIDANCE OF ANY DOUBT, WE SHOULD CLARIFY THAT IN THE EVENT WE ANONYMIZE AND AGGREGATE INFORMATION COLLECTED FROM YOU, WE WILL BE ENTITLED TO USE SUCH ANONYMIZED DATA FREELY, WITHOUT ANY RESTRICTIONS OTHER THAN THOSE SET OUT UNDER APPLICABLE LAW. Where such data is not being used by us to render Services to you, we shall explicitly seek your consent for using the same. You can choose to withdraw this consent at any time, here.

Data Retention

We will retain your personal information for as long as necessary to provide you with the services you have requested or as required by law. After this, we will delete or anonymize your personal information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our practices or to comply with legal requirements. If we make any material changes, we will provide you with notice through the App or by other means. Your continued use of the App after any changes to this Privacy Policy means you agree to the revised policy.

YOUR RIGHTS & PREFERENCES AS A DATA SUBJECT IN THE EU

It might have come to your attention that a new law was passed in the European Union (EU) called the General Data Protection Regulation (GDPR). The GDPR gives certain rights to individuals who are EU data subjects, in relation to their personal data. Subject to the GDPR and applicable law’s limitations, the rights afforded to you if you are an EU data subject are:

RIGHT TO BE INFORMED	RIGHT OF ACCESS
You have a right to be informed about the manner in which any of your personal data is collected or used which we have endeavored to do by way of this Policy.	You have a right to access the personal data you have You have a right to access the personal data you have

RIGHT TO RECTIFICATION	RIGHT TO ERASURE
You have a right to request us to amend or update your personal data if it is inaccurate or incomplete.	You have a right to request us to delete your personal data.

RIGHT TO RESTRICT	RIGHT TO OBJECT
You have a right to request us to temporarily or permanently stop processing all or some of your personal data.	You have a right, at any time, to object to our processing of your personal data under certain circumstances. You have an absolute right to object to us processing your personal data for the purposes of direct marketing.

In case you want to exercise the rights set out above you can contact our Grievance Officer whose details are set out in Section 12 below. The data provided by you as a Visitor, or when you sign up as a Customer / User or register for our Services will be processed by us for the purpose of rendering Services to you or in order to take steps prior to rendering such Services, at your request. Where such data is not being used by us to render Services to you, we shall explicitly seek your consent for using the same. You can choose to withdraw this consent at any time, here. Additionally, we may process your data to serve legitimate interests. Accordingly, the grounds on which we can engage in processing are as follows:

RETENTION OF PERSONAL INFORMATION

We will store any personal data we collect from you as long as it is necessary in order to facilitate your use of the Services and for ancillary legitimate and essential business purposes – these include, without limitation, for improving our Services, attending to technical issues, and dealing with disputes.
We may need to retain your personal data even if you seek deletion thereof, if it is needed to comply with our legal obligations, resolve disputes and enforce our agreements.
If you are a Customer, please be advised that: (i) you will need to inform your Group Members about how you store and deal with any data you collect from them using one of our Services, in compliance with applicable laws including the GDPR; and (ii) after you terminate your usage of a Service, we may, unless legally prohibited, delete all data provided or collected by you (including Group Members information) from our servers

TRACKING BY OUR ADVERTISEMENT PARTNERS

Upon receiving your specific consent, we may share the data we collect from Cookies or Web Beacons with our advertisement partners to track your visits, establish your non-personal identity and present you with targeted advertisements about our Services.

TOOLS USED BY OUR CUSTOMERS

If you are a Customer, you are empowered to use proprietary or other third party technologies (for example Flash Cookies) on your website and host them in our App. If you do, you agree and acknowledge that it is your sole obligation to inform your Group Members about any data you collect by using such technologies and the policies by which such collection is bound.

COMPLIANCE WITH CHILDREN’S ONLINE PRIVACY PROTECTION ACT

As a business service, we neither target our Services toward nor knowingly collect any personal information from any individuals under the age of 13.

TRANSFER OF INFORMATION

In order for us to facilitate our global operations, we may transfer and access the data we collect and process in accordance with this Policy, to our group companies around the world. Your rights and protections will, under no circumstances, be diluted by this transfer.
Further, in the ordinary course of business, we may employ other companies and people to assist us in providing certain components of our Services in compliance with the provisions of this Policy. To do so, we may need to share your data with them.
Where applicable – if the entities to which these transfers are effected are not situated in countries deemed ‘adequate’ by the European Commission or are not registered under the EU-US Privacy Shield framework, we shall enter into appropriate Data Protection Addendums with the transferee parties that comprehensively protect your data. We shall also put in place industry-standard technical and organizational measures (including robust data handling policies) to ensure that such transfers are completed in accordance with applicable laws.
Some of the examples of where we may sub-contract processing activities to third parties include—data analysis, marketing assistance, processing credit card payments, and providing customer service.

THIRD PARTY LINKS

We may display links to third-party websites or applications on our Website or App for advertising or providing you with relevant content. We will not be responsible for such third-party websites or applications if you choose to access them. If you provide any data to such website/application, please ensure you read their policies given that you will no longer by bound by this Policy in doing so.

COMPELLED DISCLOSURE

In addition to the purposes set out in the Policy, we may disclose any data we collected or processed from you if it is required:
1. Under applicable law or to respond to a legal process, such as a search warrant, court order, or subpoena; 2. To protect our safety, your safety or the safety of others or in the legitimate interest of any party in the context of national security, law enforcement, litigation, criminal investigation or to prevent death or imminent bodily harm; 3. To investigate fraud or violation of our Acceptable Use Policy; 4. If required in connection with legal proceedings brought against Needly, its officers, employees, affiliates, customers or vendors; or 5. To establish, exercise, protect, defend and enforce our legal rights.

SECURITY OF YOUR PERSONAL INFORMATION

We implement industry-standard technical and organizational measures by using a variety of security technologies and procedures to help protect your data from unauthorized access, use, loss, destruction or disclosure. When we collect particularly sensitive data (such as a credit card number or your geo-location), it is encrypted using industry-standard cryptographic techniques including but not limited to SSL, TLS, RSA, and AES.

GRIEVANCE OFFICER

The name and contact details of our Grievance Officer, who you may contact if you have any concerns, complaints or feedback pertaining to this Policy, are as follows:
NAME: Asha Bhutada
EMAIL: privacy@aidify.io