Effective date of this policy: December 15, 2020
needl is committed to protecting the privacy of your data. This Privacy
Policy explains what information needl and its associates (together, “needl,” “we” or “us”) collect, use,
and disclose about you when you access or use our websites and applications, which we refer to collectively
as “the Services”.
All users/ subscribers of Needl who are using ‘paid services’ are the Account Holder and End User of the
Needl Service.
You should note that this policy may be amended with the introduction of new features, technology, or
legal requirements. You need to keep yourself abreast with the applicable policy. Needl will notify its
users if we make a significant change(s) and, where required, seek your consent.
a. Privacy policy provides you information on how Needl deals with your
Personal Data and Sensitive Personal Data;
b. Data collected by the Needl for the purpose of providing this service is available to view by the
provider of the information;
c. Before any information or Sensitive Personal Data is collected by Needl for providing the Service,
Needl will obtain consent from the User/ Subscriber/ Registered User and Needl will inform the User/
Subscriber/ Registered User the purpose behind collection of information or Sensitive Personal Data;
d. Needl shall collect information or Sensitive Personal Data only for the purpose of (i) information is
collected only for the purpose of providing Service to the User/ Subscriber/ Registered User (ii) and
collection of information or Sensitive Personal Data is only limited and considered necessary to provide
Service to the User/ Subscriber/ Registered User;
e. Information collected from User/ Subscriber/ Registered User is collected by Needl.ai LLP;
f. Information collected from User/ Subscriber/ Registered User is used only for the purpose of
providing Service to the User/ Subscriber/ Registered User;
g. User/ Subscriber/ Registered User has right to review the Information/ Sensitive Personal Data
provided to Needl and if required edit or correct it;
h. User/ Subscriber/ Registered User should note that providing Information/ Sensitive Personal Data is
completely voluntary on the part of the User/ Subscriber/ Registered;
i. User/ Subscriber/ Registered User can anytime withdraw consent given to Needl for Information/
Sensitive Personal Data;
j. User/ Subscriber/ Registered User should note that not providing basic information/ Sensitive
Personal Data will hinder Needl from providing its Services or subsequent withdrawal of consent by User/
Subscriber/ Registered User shall result in Services of Needl being not available to User/ Subscriber/
Registered User;
k. Information/ Sensitive Personal Data provided by User/ Subscriber/ Registered User is stored securely
with the help of reasonable security measures;
l. Needl has appointed Grievance Officer, whom User/ Subscriber/ Registered User can reach out to if
User/ Subscriber/ Registered User has any grievance against the Needl or Needl’s Service;
m. Needl is committed to resolve any grievance of User/ Subscriber/ Registered User within a period of
thirty (30) days from the receipt of the same by the Needl in its designated email;
Needl is being created with the objective of (a) providing you with a
secured data repository (b) personalized search engine for ‘Your Data/ Your Content’ and (c) task
automation tools developed by Needl to amplify the information and eliminate the noisy data.
Only way the Needl makes money is by providing you these Services for subscription fees. Needl is not
interested in your data. We are only concerned with providing you the Services for a subscription fee.
That means you can store, input, upload, or store with Needl any text, images, and other data that you
choose and for which you are the rightful owner, we refer to that information as ‘Your Data/ Your
Content’.
Information collected from you is for the purpose of providing Needl Services and not for any other
purposes. Information collected from you is limited to the purposes of providing our Services to you. We
do not collect information which is not related to providing Needl Services to you.
We collect and receive the following types of information:
Basic information of the subscriber/ user: To open your account and process payments, we collect and
receive identifiers like your name, email address, telephone and, depending on how you purchase a subscription of
Needl, your billing address and other payment information. If you decide to link your WhatsApp,
Telegram account(s) with needl, you will have to provide your telephone number for accessing these services.
Usage data: We collect and log Internet or other electronic network information on how you and others
access and use Needl, for example, filters applied for locating specific file/ data or file format
preferred by you. Usage data may be collected through cookies, and similar technologies. For more
information, including how to opt-out, please go through Cookie Policy;
Location information: We collect the IP address you use to connect to the Service and if you choose to
share it your location information from your device.
Device information: We collect information about the number and type of devices you use to connect to
the Service, as well as information about the operating systems on those devices (e.g., iOS, Android,
Windows, Linux).
We also may link your subscriber information with data we receive from our service providers and other
third parties to help understand your needs and provide you with a better experience. For example, if
you create or log into Needl account using your Google Apps credentials via single sign-on, we will have
access to certain information such as your name and email address as authorized in your Google Apps
profile settings.
We have provided herein below the types of information we collect and receive in the table below.
Generally, we collect this information to enable you to make your usage of Needl a seamless experience.
| Information collected by Needl | Purpose of Information Collection |
|---|---|
| Your username, email address, and contact preferences | a. To create and support your Needl account.
b. To communicate with you. c. To verify your email address to help prevent spam, fraud, and abuse. d. To enable other users to share with you through data sharing features e. In accordance with your communication preferences, to send you information about Needl features and services. |
| Your name, image, and other personal information, if you choose to share it | a.To display in your user profile, which may be visible to those with whom you share Content |
| Your telephone number, if you choose to share it | a. To integrate chat accounts (namely; WhatsApp, Telegram) linked to your phone number |
| Your payment information, if you purchase a subscription | a. To process your payment. |
| Your location | a. This information is sought to determine applicable tax on your purchase of Services. |
| The geographic area from which your computing devices interact with the Needl Service, your preferred language, and, if you select the option to share it, your mobile device location information | a. To assist us in complying with legal restrictions that may limit the permissible use of
the Services.
b. To help you monitor use of your account: We make recent IP address history available to you through your account settings. |
| Your device information | a. To show you (on your account’s Access History page) which of your devices you have
authorized to access your Needl service account and when you last accessed the Service from
each device.
b. To provide account support. |
| Your actions while using the Service (e.g., search criteria, tagging, sharing) | a. To administer the Services and to improve the features and usability of the Service.
b. To provide account support. |
| Information collected by Needl | Purpose of Information Collection |
|---|---|
| Your email address (if you provide it) | a. To help you create Needl account. b. To communicate with you. |
| Tracking information | a.Please refer to Cookie Information |
| Information received from Google API | Purpose of Information Collection |
|---|---|
| Emails from Gmail account | a. To integrate gmail with Needl and enable you to have all data in one place, and search for data across multiple platforms including gmail. |
| Attachments from your emails | a. To have a seamless view of documents and media from different sources including gmail. To do automatic tagging and enable semantic search across your documents. |
| Files from GDrive | a. To have a seamless view of documents and media from different sources including gmail. To do automatic tagging and enable semantic search across your documents. |
Needl's use and transfer to any other app of information received from Google APIs will adhere to
Google API Services User Data Policy, including the Limited Use requirements.
Information collected
while providing Services to users/ subscribers are limited for the purposes as explained above.
Needl uses the data received through Google API for providing services to the users/ subscribers as
explained above. Needl does not make money from selling the users data/ content and hence your data is
not shared with anyone for the purpose of advertisement.
Needl may derive information about you based on the information Needl or our partners/ services providers collect. For example, we may make a determination about your location based on your IP address.
needl is committed to protecting the privacy of your information. As explained earlier, needl earns money by providing you with needl service and not in any other manner. You are encouraged to read carefully the information provided in following paragraphs the manner in which we use the information we collect and receive to provide, maintain, and improve the needl Services, to provide troubleshooting and customer support, to protect the Service for all our users, to contact you, and to administer needl Business accounts.
Needl Services enables you to save your data securely and helps you with task
automation tools. Our systems automatically analyze your data to enable needl continually improve the
Services for you in a way that does not require anyone to look at your Data/ Content.
a. Help you save your data securely;
b. Help you find data most relevant to you at any given moment;
c. Suggesting actions for you to take based on information you have stored.
To provide troubleshooting and customer support, our Customer Support team may need to access your information, such as your account email address and information about the Needl application you are using, subject to the protections described below. Please note that in case of data/ information belonging to end users of needl, needl follows privacy by design rule. needl does not allow its employees to read through the end user’s data. There are four limited exception to this rule (a) needl obtains a end-user's consent to read specific messages (for example, for tech support), (b) it's necessary for security purposes (for example, investigating abuse), (c) to comply with applicable laws, and (d) the developer aggregates and anonymizes the data and only uses it for internal operations (for example, reporting aggregate statistics in an internal dashboard).
As part of our efforts to protect your account and the functionality of the Needl Services, our systems may analyze the data flow to detect potential security concerns.
In accordance with your communication preferences, Needl may occasionally contact you to inform you about new features which you may like to use while using Needl Services and provide information about how Needl works with products and services from our business partners.
Needl also uses information to satisfy applicable laws or regulations, and discloses information in response to legal process or enforceable government requests, including to law enforcement. For more information, please visit the section “How does Needl respond to legal requests for my information?” of this Privacy Policy.
The only business of needl is to provide you with secured data repository,
personalized search engine and task automation tools. We do not have any other business than this. Hence
by default no one other than you have access to Your Data/ Your Content. Your data, during transmission
and while it stored with needl is end-to-end encrypted.
To enable us to help you with meaningful task automation tools customized to your needs and data behavior,
employees from needl shall access data only under circumstances as explained above. But it is to be noted
that, your data is anonymised and hence no one other than you can identify Your Data/ Your Content.
In the following situations Needl shall access your data:
a. When you specifically and expressly permit us to access your data to comply with any Statutory
Obligations;
b. Needl gets request from law and enforcement authority to share your data with them;
c. If you contact our Customer Support team for help with specific pieces of Content in your account
(for example, if you can’t find data you believe should be in your account), we may ask for your
temporary permission to look at your Content. This permission terminates when the issue is resolved;
d. If we become aware of a potential violation of our Terms of Service or User Guidelines, we may suspend
or close your account until the problematic material is removed. Under such a circumstance, we would only
look at the Content in your account if you give us consent or if necessary, to comply with our legal
obligations, including to protect the safety of you or any other person.
Needl is not in the business of selling or renting your information. Here are instances when we may
disclose your information and then only the minimum information necessary to help you enjoy full
services of Needl.
We share your information with service providers who process data on our behalf, such as credit card
processors and customer management systems. For example, these service providers help us:
a. Complete your payment transactions
b. Fulfill your sales and support requests
Data shared with the credit card payment processors or payment aggregator is restricted only for the
purpose of completing the transaction.
It is to be noted that Your Data/Your Content is private and unless you decide you want to share it,
Your Data/ Your Content will not be shared.
You need to understand that Needl Services enable you to connect different third-party subscriptions,
applications to the Needl Service. At the same time you can share Your Data/ Your Content with your
contacts and you may choose to share using Needl features that allow you to share. If you choose to
share, we may need to take certain steps to facilitate your data/ your content sharing.
In the event of a merger, sale, or reorganization of all or part of our business, information covered by
this policy may be transferred in connection with that deal.
We also may share information about you with third parties whenever you consent to or direct such
sharing. This includes, for example, if you connect your Needl account with a third-party app in the App
Center.
We protect the privacy of your account. We will disclose your information
to law enforcement or other governmental authorities if we believe it is required to comply with
warrants, court orders, or other lawful government requests. This may include responding to legal
requests from jurisdictions outside of India where we have a good faith belief that the response is
required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with
internationally recognized standards of due process.
As a policy we only disclose Content in your account that is specifically responsive to a government
warrant or where you have provided your explicit consent. In accordance with our User Notice Policy , we
will notify you if we believe we are compelled to comply with a third party’s legal demand for your
information.
In addition, in rare cases, we may share your information as necessary to investigate or take action
regarding illegal activities, suspected fraud, or potential threats against persons, property or the
systems on which we operate the Service, or as otherwise necessary to comply with our legal obligations.
Consistent with our policy of data protection, your data is yours, in most
cases; you can manage your information simply by logging into your account and editing your information
directly within the Needl account.
However, if you prefer, you can contact us at compliance@needl.ai to ask us to provide access to,
correct, update, or delete your personal information. Please note that we may ask you for proof of
account ownership and/or identity before fulfilling your request.
needl’s objective is to provide you with secure data repository, your
personalized search engine and machine learning tools to identify data which is most relevant to you
at any given moment. In order to do that, we make the Data/Content, you store in needl readily accessible
to you, until you make the decision to delete it. Once you decide to close/ delete your needl account,
all your data will be deleted from needl. This includes all your data association with your needl account,
including your email address, password, and two step verification phone number. Please keep in mind that
this action is not reversible. After such reasonable period as determined by needl, your account will not
be accessible even by Customer Support Team.
If you delete your Data/Content and then sync, it will no longer be accessible to you or others who may
access the Service. The Needl service’s back-up systems may retain residual copies of your deleted
Content for such reasonable time period depending upon the nature of those systems’ operations and to
comply with applicable rules and regulations.
Needl provides you with features that allow you to communicate and share with other users. Please note
that deleting your copy of these communications (such as messages) won't delete copies existing in the
accounts of people you were interacting with.
For users who are inactive for extended periods of time, we may close your account to satisfy our
obligations under applicable law, and in accordance with our data retention policy. If that happens, we
will try to notify you before taking any action.
As described above, you can delete your Data/Content at any time, and you can stop using the needl services at any time. Your data is portable. You can export your data at any time as desired by you and terms of the process prescribed by needl. Once you decide to close/ delete your needl account, all your data will be deleted from needl. This includes all your data association with your needl account, including your email address, password, and two step verification phone number. Please keep in mind that this action is not reversible. After such reasonable period as determined by needl, your account will not be accessible even by Customer Support Team.
If Needl deactivates your account due to violation of Terms of Service, then you may contact us to request deletion of your Content, and we will evaluate such requests on a case by case basis, pursuant to our legal obligations.
When you integrate your cloud-based app(s) with the Needl Services, that data will be replicated on
cloud systems of AWS (Amazon Web Services) maintained in the United States of America. This means that
if you store information with Needl through Needl services, you acknowledge your personal information
will be transmitted to, hosted, and accessed in the United States of America.
Needl will collect, store, and use your personal information in accordance with this Privacy Policy and
applicable laws of India.
Needl.ai LLP is your data controller.
a. Account Holder (also referred to as “User” or “Subscriber”, “registered user”) means the person or
entity who has contracted with Needl as a Customer for paid service of Needl.
b. End User (also referred to as “User” or “Subscriber”, “registered user”) means the individual who
uses an account of the Needl Service.
c. Needl (or sometimes “we” or “us”) means Needl.ai LLP a Limited Liability Partnership registered in
India with the Registrar of Companies that also act as data controllers.
d. Your Data/ Your Content includes any text, images, sound, any data in any format which is legally in
your possession and for which you are the rightful owner, which you by your voluntary action decides to
store with Needl.
e. Sharing Features means any of the Service’s features that allow you to share Your Data/ Content.
f. Needl Services (or sometimes “Services”) includes the Needl Software (as defined below) and other
products, services and websites hosted or made available by Needl, User Forum, and Help & Learning pages.
g. Needl Software includes the software hosted on Needl’s servers to enable storing of Your Data/ Your Content on Needl servers,
capturing of Data/Content originating outside the Service that enable access and use of the Service
through such device.
h. Needl account includes facilities through which Users/ Subscribers/ Account Holders can access and/
or use Needl Service.
i. Needl’s servers means server space which Needl contracted with Amazon Web Service (AWS) for hosting
Your Data/ Your Content and also for hosting Needl software.
j. Needl’s property includes Needl’s website, its software, its web application, its computer codes,
computer programme, its copyright, logo, trademark and all such intellectual property rights and all
such assets which rightfully belongs to Needl.
k. Basic Subscriber Information includes your email, telephone number, name, location and payment
details which are voluntarily provided by the Users / Subscribers / Account Holders for creating needl
account and for which needl has complied with applicable laws prevailing in India.
l. Paid Service means any Needl offering for which a User/ Subscriber is required to pay subscription
fee.
m. Partner(s) (also referred to as “Service Providers”) includes, service providers which are appointed
and / or contracted by Needl to enable Needl to provide its Service to the Users/ Subscribers/ Account
Holders.