NEEDLES AND HAYSTACKS PRIVACY POLICY

Date of Latest Version: 19-02-2026

This Privacy Policy ("Policy") covers how Needles & Haystacks, an autonomous and intelligent skill-assessment agentic AI workflow platform of Needles And Haystacks Technology Private Limited, company incorporated under the Companies Act, 2013, having registered office at WeWork, Prestige Atlanta, Software Industry, No 10/12, 80 Feet Main Road, Koramangala 1A Block, Koramangala I Block, Bangalore, Karnataka, India, 560034 ("we" / "us" / "Needles & Haystacks/ Platform") collects, uses, discloses, processes, transfers and stores information received from users of our services and visitors and users of our website located at "needlestacks.ai", Needles & Haystacks Candidate Facing web Platform "needleinthehaystack.com" and "Dylogs" mobile application in Play Store/App Store (collectively, "Offerings"). We are committed to upholding the privacy and security of information supplied by every person accessing or using our Offerings ("you").

Please take a moment to familiarise yourself with our privacy practices, and to learn about our information gathering practices. By accessing or using our Offerings after giving consent for processing your personal data, you agree to be bound by, and acknowledge the acceptance of the terms and conditions of this Policy. You signify that you have read and understood this Policy.

This Policy is in line with Needles & Haystack's commitment to comply with all applicable data privacy and protection requirements, including those prescribed under the Information Technology Act, 2000, the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, the Digital Personal Data Protection Act, 2023 and rules made under it (collectively "Data Privacy Laws").

1. DEFINITIONS

"Non-Personal Information" means any Personal Information that is either publicly available, or any information not personally identifiable to you.

"Personal Information" means any non-public information that directly or indirectly, in combination with other information available with us, is capable of identifying you, and includes the information that you provide when you register with us or avail out services through our website.

2. MINIMUM AGE AND ANTECEDENTS

Our Offerings are not designed for use by anyone under the age of 18 (eighteen). If you are a minor, you must access or use the Offerings through your parent / legal guardian. We do not verify the age of our users and customers, nor do we have any liability for such verification or lack thereof. We may, at our sole discretion, delete information pertaining to, and cancel accounts of users suspected of being under the age of majority and using the Offerings without the verifiable consent of their parent / legal guardian.

3. INFORMATION COLLECTED

Generally, you control the amount and type of information you provide to us when using our Offerings. If you choose not to provide Personal Information, you may be able to browse our website to find out more about us and our services, but you may not be able to access certain features and functions of our website.

If you choose to use our Offerings to purchase services you will be required to provide us with additional information, based on the nature of the services and facilities availed. Based on the features of our Offerings that you access or use, we may also be required to share your information, including Personal Information with our vendors and partners including our delivery partners to facilitate the rendering of the Offerings. You hereby agree and acknowledge that such collection and sharing is based on your voluntary disclosure.

In course of your use of the Offerings, we may collect Personal Information from you. While some of your information must be mandatorily provided for registration and usage of the Offerings the provision of other information is optional and depends on the services being availed by you. We collect the information in the following manner:

(a) Registration Information. When you register with us, we collect certain mandatory information from you which is required to enable you to use the Offerings and for us to verify your identity. This includes, among other things, your name, phone number, email address and address.

(b) Payment Information. When you choose to purchase or subscribe to our Offerings, we may collect financial information necessary to process your payments. This includes your bank account details, card credentials, UPI ID or any other payment information details as disclosed by you.

(c) User Content. When you use our Offerings, we collect Personal Information that is included in the inputs, file uploads, or any other content you provide. You warrant that where such content includes another person's personal data, you have obtained all necessary consent as required under the Data Privacy Laws.

(d) Communication based Information. When you communicate or interact with us, we collect your name, contact information and the contents of messages you send us including any files.

(e) Other Information. Any additional information which we may collect from you during your subsequent use of the Offerings and its features, or as and when you avail our services.

While certain portions of the information will be held by us, some information will be shared with our vendors and partners for the purpose of delivering out Offerings.

You hereby consent to such collection, use, display, processing and handling of your information by us as described in this Policy, and as may be reasonably necessary to render the Offerings to you. You also acknowledge and agree that all such information provided by you is accurate, true and up to date. You agree to make required corrections and updates from time to time. You agree that we are not, in any manner, responsible for the correctness of information held by us in relation to you.

You acknowledge that your consent as provided to us is free, informed, unconditional, specific and has been provided willingly without any coercion.

Our Offerings may use "Cookies" to identify the areas of the website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser. We may use Cookies to personalise the content that you see on our website and the services that we offer to you. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access some functionalities of our website correctly or at all. We never place Personal Information in Cookies.

We may use Cookies for a number of purposes, including to provide general analytics; study traffic patterns in order to customise your experience, match your interests and preferences and improve Offerings performance; keep track of preferences that you specify while you access and use the Offerings; support security measures; assist in identifying possible fraudulent activities; and to improve the services we provide.

Third-Party Tracking Tools

We may also use third-party tracking tools to improve the performance and features of our website and Offerings that are designed to collect only Non-Personal Information about your use of the Offerings. However, you understand that such tools are created and managed by parties outside our control, and we are not responsible for what information is captured or used by such third parties.

Automatic Information

We automatically receive information from your web browser or mobile device including the name of the website from which you entered our website, the name of the website to which you are headed when you leave our website, if any, and other information such as your device usage information, features of the device and your location. We also receive the IP address of your computer, or the device or proxy server you use to access the internet, your internet provider's name, your web browser type and your computer operating system. We use such information to analyse trends and to help improve our Offerings.

4. USE OF INFORMATION

We use information received from you to provide and maintain the website and our Offerings. Among other things, your information may be used:

(a) To generate and maintain your account on the website;

(b) To allow you to purchase services on the website;

(d) To communicate information pertaining to your inquiries;

(e) To provide customer support;

(f) To issue invoices, administer accounts, collect and process payments;

(g) To provide you with tips or guidance on how to use the Offerings, the services and facilities that we offer, to inform you of new features and Offerings, or provide other information that may be of interest to you;

(h) To personalise the services we provide to you, tailor your experience to your requirements and make more appropriate recommendations;

(i) To modify the Offerings to cater to your interests;

(j) To allow you to participate in interactive features on the website;

(k) To call you, send you emails, e-newsletters, messages personalised offers via direct messaging or other communications about our services;

(l) To collect feedback;

(m) To process and track your transactions;

(n) To prevent fraudulent transactions on the website;

(o) To analyse software usage patterns for improving product design and utility; and

(p) For such other purposes as we deem fit, in accordance with applicable law.

To this end, we may contact our users and customers via email, SMS, call or push notifications on our website as we deem appropriate. Further, our vendors and partners may also do so, to the extent required to render the Offerings.

Your information, including Personal Information may be transferred to, and maintained on systems located outside your state, country or jurisdiction, and the applicable Data Privacy Laws may vary from those of your jurisdiction. You consent to such transfer and the application of the Data Privacy Laws to the exclusion of law applicable in your jurisdiction.

You understand that the information we collect may be collated, aggregated, analysed and used to generate statistics and may also be used for our internal research and development. We may, to the extent permitted by law, use, licence, reproduce, distribute, disclose, sell and aggregate all Non-Personal Information that is derived from your use of the Offerings, and you hereby consent to the same.

We may, to the extent permitted by law, use, licence, reproduce, distribute, disclose, sell and aggregate all Non-Personal Information that is derived from your use of the Offerings, and you hereby consent to the same.

5. SHARING OF INFORMATION

We do not sell, rent or otherwise provide your Personal Information to third parties for commercial gain. We may, however, use your Personal Information for the purposes of rendering the Offerings and for marketing. We may also provide your Personal Information to sub-contractors, vendors, third-party service providers, partners or affiliate or group entities that provide services to us in furtherance of our Offerings. Such parties will only receive the information necessary to provide the respective services to us/ you.

While we will endeavour to ensure that such parties have in place a privacy policy similar to ours or that they are bound by confidentiality obligations of similar nature before sharing your information with them, we will not, in any manner whatsoever, be liable for a breach of privacy or confidentiality by them to the extent that such breach is outside our scope of control.

We may disclose or transfer your Personal Information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganisation of all or substantially all the equity, business or assets of Needles & Haystack's to which your Personal Information relates.

We may be legally required to disclose your Personal Information, if such disclosure is (a) required under any law or other legal process; (b) necessary to assist law enforcement officials or government enforcement agencies; (c) necessary to investigate violations of or otherwise enforce our legal terms; (d) necessary to protect us from legal action or claims from third parties; (e) necessary to protect the legal rights, personal property or personal safety of Needles & Haystack's, our users, employees and affiliates; or (f) necessary for any other reasonable purpose that Needles & Haystack's may, in its sole discretion, deem fit.

6. LINKS TO OTHER SITES

Our website may contain links to third-party sites that are not operated by us. If you click on a third-party link, you may be redirected to such third-party's site. We have no control over, and assume no responsibility for the content, privacy policy or practices of a third-party site. We advise you to separately review the privacy policy of every site you visit.

7. INFORMATION SECURITY

The information provided by you is stored in access-controlled facilities with restricted access. Your information that is transmitted over the internet is protected through the use of encryption using secure protocols.

If a password is used to help protect your account and account information, it is your responsibility to keep the password confidential. You have to ensure that you always log out of your account, before sharing your device with a third-party.

We will use generally accepted industry standards to protect information that you have submitted to us against loss, theft, unauthorised access, disclosure, copying, use or alteration as required under the Data Privacy Laws. Your Personal Information is kept secure behind secure networks and is only available to a limited number of people including our employees, information technology service providers and the persons to whom your Personal Information is being shared through your consent, who are bound by confidentiality obligations. To the extent possible, all data is encrypted and stored. All payment transactions are handled by a third-party gateway provider and are neither stored nor processed on our servers.

However, please be advised that, no method of transmission over the internet, or method of electronic storage, is 100% (one-hundred percent) secure. Therefore, although we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security and your use of the Offerings is at your sole risk and discretion. We do not warrant that such information may not be misused in the event our safeguards and protocols are breached by a malicious third-party. We will, however, promptly notify you and take all actions necessary under the Data Privacy Laws if we discover that any of your information is compromised as a result of a security breach.

8. RIGHTS OF THE USER

Right to know. You have the right to obtain from us summary of your Personal Information being processed by us, and identities of vendors and partners with whom your Personal Information has been shared.

Right to opt-out. You have the right to opt-out of providing any of your information, including your Personal Information. However, in such an event, we reserve the right to refuse or limit your access and use of the website, our Offerings, and their features.

Right to withdraw and deletion of Personal Information. You have the right to withdraw your consent to the use, disclosure or transfer of your information, including your Personal Information, and request for its deletion by contacting us. However, in such event, we reserve the right to refuse or limit your access and use of the website, our Offerings, and their features. Further, withdrawal of consent shall not affect the legality of processing of data based on consent made before your withdrawal.

Right to correct. You have the right to update or correct any of your information, including your Personal Information.

Right to nominate. You have the right to nominate another person to exercise your rights under applicable data protection laws on your behalf in the event of your death or incapacitation.

Right to grievance redressal. You have the right to redress any grievances with regards to collection or processing of your Personal Information in the manner prescribed in Para 10 of this Policy.

To exercise any of your rights, you may contact us at: support@needlestacks.ai.

We fully comply with national laws regarding spam. You can always opt-out of receiving further promotional correspondence from us.

9. DATA RETENTION AND ERASURE

Unless required to be retained to comply with Data Privacy Laws or any other applicable law in force, we will erase or permanently delete all your Personal Information provided to us, upon termination of our services, withdrawal of your consent or once the purpose for which the Personal Information was collected is no longer being served.

10. GRIEVANCE REDRESSAL

In case of any grievance, you may address such grievance to our grievance officer. The contact details of the officer are:

Email ID: support@needlestacks.ai

11. CHANGES TO THIS POLICY

We reserve the right to update or modify this Policy at any time and all such changes will be effective immediately upon our posting the updated or modified Policy on our website. You are encouraged to review this Policy each time you access or use the Offerings.

12. QUESTIONS ABOUT OUR PRIVACY PRACTICES

If you have any questions about our privacy practices or this Policy, you may write to us at support@needlestacks.ai.