Privacy Policy

1. Introduction

NeeNam ("we", "us", "our") operates NGOHub (https://ngohub.in). This Privacy Policy explains how we collect, use, share, and protect personal data when you use NGOHub or visit our website. We are committed to complying with India's Digital Personal Data Protection Act 2023 (DPDP Act) and all other applicable laws.

By using NGOHub or visiting ngohub.in, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this policy, please do not use the NGOHub platform or website.

2. Who this policy applies to

This policy applies to:

• Visitors — anyone who visits the NGOHub website at ngohub.in;
• Customers — organisations that subscribe to use the NGOHub platform;
• End users — staff members of NGOHub customer organisations who access the platform on behalf of their organisation;
• Donors — individuals whose personal data is stored in NGOHub by our NGO customers. Please see Section 7 for information specific to donors.

3. What data we collect

3.1 Data you provide directly

When you create an NGOHub account, submit a contact form, or communicate with our team, we may collect:

• Your name and the name of your organisation;
• Your email address and phone number;
• Billing information (processed via Razorpay — see Section 8);
• The content of your communications with our support team.

3.2 Data collected automatically

When you visit ngohub.in or use the NGOHub platform, we automatically collect certain technical information, including:

• IP address and approximate location;
• Browser type, version, and operating system;
• Pages visited and features used within the platform;
• Session duration and navigation paths;
• Cookies and similar technologies (see Section 6).

We use this data to operate and improve the NGOHub website and platform.

3.3 Data processed on behalf of NGO customers

NGO customer organisations upload and manage donor data through NGOHub. This data includes, but may not be limited to, donor names, email addresses, phone numbers, PAN numbers, and donation records. We process this data as a data processor on behalf of the NGO, which is the data fiduciary under the DPDP Act 2023. For more information, see Section 7.

4. How we use your data

We use the personal data we collect for the following purposes:

• To provide, operate, and maintain the NGOHub platform;
• To process payments for subscriptions via Razorpay;
• To send product updates, invoices, and service notifications;
• To respond to support requests and general enquiries;
• To improve the platform based on aggregated usage analytics;
• To detect and prevent fraud and security incidents;
• To comply with our legal and regulatory obligations under applicable Indian law.

We do not sell your personal data to any third party. We do not use your personal data for advertising purposes.

5. Legal basis for processing

Under the Digital Personal Data Protection Act 2023, we process personal data on the following bases:

• Consent — where you have explicitly provided consent, including for marketing communications and newsletter subscriptions. You may withdraw your consent at any time by contacting us at don.caleb@neenam.com;
• Contractual necessity — to fulfil our obligations under the NGOHub subscription agreement, including providing access to the platform and processing payments;
• Legitimate interests — for security monitoring, fraud prevention, and improving the platform, where our interests do not override your rights and interests;
• Legal obligation — where processing is required to comply with applicable Indian law, including tax and regulatory requirements.

6. Cookies

We use cookies and similar technologies to operate the NGOHub platform and website. The types of cookies we use are:

• Essential cookies — these are strictly necessary for the NGOHub platform to function. They enable features such as authentication, session management, and security. You cannot opt out of essential cookies while using the platform.
• Analytics cookies — these help us understand how users interact with the NGOHub website and platform. We use anonymised data to improve the user experience. You may opt out of analytics cookies by adjusting your browser settings or by contacting us.

We do not use advertising cookies, tracking cookies, or cookies that share your data with third-party advertisers.

7. Donor data (data processed on behalf of NGO customers)

NGO customers upload and manage donor personal data — including names, contact details, PAN numbers, and donation records — through the NGOHub platform. For this data:

• The NGO is the data fiduciary under DPDP Act 2023. The NGO is responsible for ensuring that donor data has been collected lawfully, that appropriate consent has been obtained where required, and that donors are informed about how their data is used.
• NeeNam acts as a data processor. We process donor data only as instructed by the NGO and for the purpose of providing the NGOHub service to that NGO. We do not use donor data for any other purpose.
• Donor rights — donors have rights under DPDP Act 2023, including the right to access, correct, and request erasure of their personal data. Donors may exercise these rights through the NGOHub donor self-service portal (where provided by the NGO) or by contacting the NGO directly. If you are a donor and cannot reach the NGO, you may contact us at don.caleb@neenam.com and we will assist in directing your request appropriately.
• Data sub-processing — where we engage sub-processors to assist with providing the NGOHub service (such as cloud hosting or WhatsApp message delivery), we ensure those sub-processors are bound by data processing agreements with equivalent data protection standards.

8. Data sharing

We share personal data only with the following categories of third parties, and only to the extent necessary:

• Razorpay — for processing subscription payments. Razorpay is a licensed payment aggregator under RBI guidelines. Razorpay's Privacy Policy governs their use of payment data.
• Cloud infrastructure providers — for hosting the NGOHub platform and storing data. All data is stored in India or in cloud regions approved under applicable Indian law.
• WhatsApp Business API providers — for delivering WhatsApp messages on behalf of NGO customers. Message content is transmitted to Meta's infrastructure for delivery in accordance with Meta's WhatsApp Business policies.
• Analytics providers — for anonymised usage analytics to help us improve the platform.
• Law enforcement or regulatory authorities — where we are required by applicable Indian law, a court order, or a lawful government request to disclose information. We will notify you of such requests where permitted by law.

All third-party processors with whom we share personal data are bound by written data processing agreements.

9. Data retention

We retain customer account data for as long as your account is active. Following cancellation or termination of your account, we retain your data for 30 days to allow you to export your data. After this period, account data is permanently deleted from our systems, except where we are required by law to retain it for longer (for example, for tax, audit, or regulatory compliance purposes).

Donor data uploaded by NGO customers is retained as directed by the NGO. NGOs may export and delete their donor data from within the NGOHub platform at any time.

Server logs and security records are retained for a period of up to 12 months for security monitoring and incident investigation purposes.

10. Data security

We take the security of your personal data seriously and implement industry-standard measures, including:

• Encryption of data in transit using TLS (Transport Layer Security);
• Encryption of data at rest;
• Role-based access controls limiting access to personal data to authorised personnel only;
• Regular security reviews and vulnerability assessments;
• Audit logging of access to sensitive data;
• Secure data centres with physical access controls.

All data is stored in India or in cloud regions approved under applicable Indian law. While we implement strong security measures, no system is completely secure. In the event of a personal data breach that is likely to result in harm to you, we will notify you as required under applicable law.

11. Your rights under DPDP Act 2023

Under the Digital Personal Data Protection Act 2023, you have the following rights in relation to personal data we hold about you:

• Right to access — you have the right to obtain a summary of the personal data we hold about you and information about how it is being processed;
• Right to correction — you have the right to request correction of inaccurate or incomplete personal data;
• Right to erasure — you have the right to request erasure of your personal data, subject to our legal retention obligations;
• Right to withdraw consent — where we process your data based on consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing before the withdrawal;
• Right to nominate — you have the right to nominate another individual to exercise these rights on your behalf in the event of your death or incapacity.

To exercise any of these rights, please contact us at don.caleb@neenam.com. We will respond to your request within the timeframes required under applicable law.

12. Children's data

NGOHub is not directed at children under the age of 18. We do not knowingly collect or process personal data from children. If you believe we have inadvertently collected personal data from a child, please contact us immediately at don.caleb@neenam.com and we will take steps to delete that data.

13. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the NGOHub platform, or applicable law. We will notify customers of material changes by email and/or by an in-app notification within NGOHub, with reasonable advance notice before the changes take effect. The date of the most recent revision is shown at the top of this page.

We encourage you to review this Privacy Policy periodically. Continued use of NGOHub after the effective date of any changes constitutes your acceptance of the updated policy.

14. Contact

If you have any questions about this Privacy Policy, would like to exercise your data protection rights, or wish to report a privacy concern, please contact us:

• Email: don.caleb@neenam.com
• Phone: +91 97516 33626
• Organisation: NeeNam, India
• Website: neenam.com

We are committed to resolving privacy complaints promptly and fairly. If you are not satisfied with our response, you may have the right to lodge a complaint with the Data Protection Board of India once established under the DPDP Act 2023.