Privacy Policy

Needls. was built to help you grow your business. Our ongoing evolution is a function of listening closely to what you have to say and adapting. We view you as a partner rather than a client, providing you with the tools needed to increase sales. Your success is our success!

Needls Media Inc. ("Needls"/"we"/"us"/"our") is committed to protecting your privacy. Needls provides its customers ("Customers") with advertising management and optimization services across several online advertising networks including but not limited to Facebook, Google & Instagram as well as social media indexed lead generation services ("Services"). This Privacy Policy describes how we collect, store, use and share information collected through the website http://needls.com/ (the "Website") and the Services about visitors of the Website, Customers and prospective clients of our Customers who are identified through our lead generation services ("Prospects"). Customers and website visitors are collectively referred to herein as "you". This Privacy Policy does not apply to our Customers' use of personal information; such information is governed by our Customers' privacy practices and policies. 


Information We Collect

Customer Registration: In order to register for our Services, Customers must provide certain Personal Information to us such as their name, company name and email address. We use this information to manage Customer accounts and provide the Services. 

Content: You also provide Personal Data in content you upload to the Service, or which is uploaded on your behalf (“Content”). In general, the Content you provide will be viewable and discoverable by your users. In some cases, where content has been shared with users outside your email domain extension, your information may be viewed by those additional users. We can, but have no obligation, to monitor the Content you post on the Service.

Device Identifiers: When you access the Service by or through a device, we may access, collect, monitor and/or remotely store one or more “device identifiers”. Device identifiers allow us to uniquely identify your device and are used to enhance the Service (including sending updates and information from the Service). A device identifier does not collect or share any personally identifiable information about you. A device identifier may be used in conjunction with personally identifiable information.

Statistics and Analytics: We also collect statistics about use of the Services which we use for analytics including predictive analytics. Aggregate statistics that do not personally identify an individual will be kept by us and such aggregate statistics may be made available to other members or third parties. We may also collect information (which may include using third party services) using logging and cookies which can sometimes be correlated with Personal Information. We use this information to monitor and analyze use and interest in the Service. See the section on “Service Providers” for more detail in this respect.


System Logs & Cookies: Cookies are used by us to track content usage and traffic on the Website and Services. A cookie is a feature of your web browser that consists of a text file that is placed on your hard disk by a web server. The Website uses cookies to help it compile aggregate statistics about usage of this Website, such as how many users visit the Website, how long users spend viewing the Website, and what pages are viewed most often. This information is used to improve the content of the Website. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect information about you via the Websites and Services and across other websites and online servicesYou can set your browser to notify you when you are sent a cookie. This gives you the chance to decide whether or not to accept it. If you disable cookies, you may not be able to take advantage of all the features of the Website or Services. For more details about how we use these technologies, please see the section on “Service Providers” below and our Cookie Policy.

Your IP address is reported by your web browser whenever you visit a page on the Website. This information is recorded together with your registration information on our databases. 

Advertisements: Advertisements appearing on the Website may be delivered by us or one or more third-party web advertisers. These third party web advertisers may set cookies. These cookies allow the advertisement server operated by that third party to recognize your computer each time they send you an online advertisement. Accordingly, advertisement servers may compile information about where or whether you viewed their advertisements and which advertisements you clicked on. This information allows web advertisers to deliver targeted advertisements that they believe will be of most interest to you. The Privacy Policy applies to cookies placed on your computer by us, but does not cover the use of cookies by any third-party web advertisers. For the privacy practices of such third-party web advertisers, you should consult the applicable privacy policy for the relevant third-party web advertiser(s). 

Third-Party Links: The Website may contain links to other third-party websites that are not owned or controlled by us. Such third-party websites are governed by the terms and conditions and privacy policies of such third-party providers and we are not involved in any interaction or transaction between you and such third-parties. 

How We Use Personal Information

We use personal information (which is any information relating to an identified or identifiable natural person, “Personal Data” or “Personal Information”) that we collect for the purpose of fulfilling our contractual obligations to you under our Terms of Use, in furtherance of our legitimate interests in operating our Services, Websites and business and/or where you have consented to such usage. These are the lawful basis for the usage of your Personal Data. More specifically, we use Personal Data:

  1. To provide, update, maintain and protect our Services, Websites and business. This includes use of Personal Data to support delivery of the Services under our Terms of Service, prevent or address service errors, security or technical issues, analyse and monitor usage, trends and other activities or at an your request. We may use your email address or phone number to send you Service-related notices (including any notices required by law, in lieu of communication by postal mail). If you correspond with us by email, we may retain the content of your email messages, your email address and our responses.
  2. As required by applicable law, legal process or regulation. We may in certain instances be compelled by law to process your Personal Data in order to comply with a binding order. We will only do so to the extent reasonably required by that order.
  3. To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Personal Data to respond.
  4. For billing, account management and other administrative matters. We may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
  5. To investigate and help prevent security issues and abuse.


Transactional Notifications: We provide notifications for certain activities relating to Customers' use of our Services despite Customers' indicated e-mail preferences, for example we may send notices of any updates to our Terms of Use or Privacy Policy. 

Marketing Communications: If you provide your email address to us or, if you are a resident of the EEA, you opt-in to receive marketing communications from us, we will keep you up to date on our products and services. You may withdraw your consent to receiving marketing communications from us at any time by following the opt-out instructions in each communication. 

Legal Basis For Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), We legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

We may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it’s not overridden by your rights
  • To comply with the law

We set out a more detailed breakdown of the legal basis for our use in the “how we use information” section above.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

  • Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Behavioural Remarketing

Predictable Revenue uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.

  • Google AdWords is a remarketing service provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

  • Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

  • Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt-out from Facebook’s interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

  • AdRoll remarketing service is provided by Semantic Sugar, Inc.

You can opt-out of AdRoll remarketing by visiting this AdRoll Advertising Preferences web page: http://info.evidon.com/pub_info/573?v=1&nt=1&nw=false

For more information on the privacy practices of AdRoll, please visit the AdRoll Privacy Policy web page: http://www.adroll.com/about/privacy

Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us using the contact information set out below.

In certain circumstances, where we act as Data Controller, you have the following data protection rights:

  • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you where we are the data controller and to check that we are lawfully processing it.
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal information. This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the information's accuracy; (b) where our use of the information is unlawful but you do not want us to erase it; (c) where you need us to hold the information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your information but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

If you wish to exercise any of the rights set out above, please contact us using the contact details below.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

We may also contact you to ask you for further information in relation to your request to speed up our response.

Identifying The Data Controller And Processor

Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. In general, We are the controller of information which we request or collect for the purposes of maintaining the Service. Our customers are the controller of Personal Data which they enter into the Service which is not requested by us, or which we may enter into the Service on their behalf. Our Data Processing Addendum applies to the processing of any Customer Data to which the General Data Protection Regulation (2016/679) applies.


General Terms

Disclosures & Transfers: We have put in place contractual and other organizational safeguards with our agents (see further below) to ensure a proper level of protection of your Personal Information (see further Security below). In addition to those measures, we will not disclose or transfer your Personal Information to third parties without your permission, except as specified in this Privacy Policy (see further Important Exceptions below). If we plan to use your Personal Information in future for any other purposes not identified above, we will only do so after informing you by updating this Privacy Policy. See further the section of this Privacy Policy entitled ‘Amendment of this Policy'. 

As at the date of this Privacy Policy, we share Personal Information about you in respect of the Website or Services only with our service providers and partners that provide cloud hosting, analytics, email marketing, data feeds, helpdesk software, conversion tracking, social network APIs and payment processing. Our service providers are located in Canada and the United States and accordingly your Personal Information may be available to Canadian and United States governments under a lawful order, irrespective of the safeguards we have put in place for the protection of your Personal Information. 

From time to time we may employ third parties to help us improve the Website and/or the Services. These third parties may have limited access to databases of user information solely for the purpose of helping us to improve the Website and/or the Services and they will be subject to contractual restrictions prohibiting them from using the information about our members for any other purpose. 

Important Exceptions: We may disclose Personal Information to third parties without obtaining consent if we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other Website members, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities. We may disclose Personal Information when we believe in good faith that such disclosure is required by and in accordance with the law. 

We may also disclose your Personal Information in connection with a corporate re-organization, a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same, provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information. 

Security: The security of Personal Information is important to us. We use commercially reasonable efforts to store and maintain Personal Information collected by us in a secure environment. We take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you. 

In certain areas, such as when you provide credit card or other payment information to us, the Website works to help protect the security of your credit card and other payment information during transmission by using industry standard Secure Sockets Layer (SSL) encryption technology. 

You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your email account information or your password for the Services to third parties. 

Retention: We will retain Personal Information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained Personal Information will remain subject to the terms of this Privacy Policy. If you request that your Personal Information be removed from our databases, it may not be possible to completely delete all your Personal Information due to technological and legal constraints. 

Amendment of this Policy: We reserve the right to change this Privacy Policy at any time. If we decide to change this Privacy Policy in the future, we will post an appropriate notice on the home page. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective 30 days from their posting on the Website. Unless stated otherwise, our current Privacy Policy applies to all Personal Information that we have about you. The date on which the latest update was made is indicated at the bottom of this document. We recommend that you print a copy of this Privacy Policy for your reference and revisit this policy from time to time to ensure you are aware of any changes. Your continued use of the Website and Services signifies your acceptance of any changes. 

Access and Accuracy: You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected in respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we will provide you with a copy of your Personal Information although in certain limited circumstances, we may not be able to make all relevant information available to you such as where that information also pertains to another user. In such circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all requests for access and modifications in a timely manner. 

We will make every reasonable effort to keep your Personal Information accurate and up-to-date, and we will provide you with mechanisms to update, correct, delete or add to your Personal Information as appropriate. As appropriate, this amended Personal Information will be transmitted to those parties to which we are permitted to disclose your information. Having accurate Personal Information about you enables us to give you the best possible service. 

Contact Us: You can help by keeping us informed of any changes such as a change of address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions of if you find any errors in our information about you, please contact us or write to us at:

Needls Media Inc.

1655 Dupont Street, Unit 337

Toronto, Ontario, Canada

M6P3T1. 

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