Privacy Notice

What we collect, and what your employer can never see

EECly is a workplace compliance and wellbeing application operated by Annotatory AI Projects Private Limited. It is provided to you through your employer. This notice explains what EECly collects, who can see it, what your employer can never see, how long it is kept, and the control you keep over it.

EECly is not a medical service. It does not diagnose, treat, or provide medical advice. Where it connects you to counselling or clinical support, that support is delivered by the relevant qualified provider, not by EECly.

Effective 1 August 2026 · Last updated 2026-08-08 · Reviewed by Venkat Reddy Avula

1. Who is responsible for your data

EECly handles several different kinds of information, and the responsible party is not the same for all of them. Under India’s Digital Personal Data Protection Act, the “Data Fiduciary” is the party that decides why and how data is processed, and owes you the legal duties.

For anything where your employer is the Fiduciary, we act on their documented instructions and cannot use that data for our own purposes. For your wellbeing and health data, we are directly responsible to you — and your employer does not get to decide what happens to it.

2. What EECly collects

Identity and employment information. Your name, work email, employee identifier, department, location and reporting structure. This normally reaches us from your employer’s HR or identity system — you do not usually type it in.

Sign-in information. If your employer uses single sign-on, we receive a verified sign-in assertion from their identity provider. We do not receive or store your corporate password.

Compliance and workplace records. Policy acknowledgements, training completions, and statutory register entries the law requires your employer to keep.

Content you choose to submit. Complaints, reports, grievances, survey responses, and anything you write or attach in them.

Wellbeing information you choose to record, and counselling engagement if you use those features. Plus technical information — device type, app version and operational logs — needed to run the service securely.

The EECly Android app requests only one device permission: internet access. It does not request your camera, microphone, location, contacts or files.

3. What your employer can — and cannot — see

This is enforced in software, at the point every read happens. It is not a promise about intentions; it is a property of the system.

Your employer can never see, at an individual level:

• Sexual-harassment complaint content. Only the Internal Committee can open a PoSH case. HR cannot. Compliance cannot. The Data Protection Officer cannot. You can always see your own case.
• Whistleblower reports. Only the Audit Committee and the designated Vigil Officer. HR cannot. Compliance cannot. The Internal Committee cannot.
• Data-protection grievances. Only the Data Protection Officer.
• Your counselling content. Only the assistance provider handling your engagement.
• Your individual wellbeing or health data. Never, at any time, in any role.

What your employer does see

Compliance status — whether you completed a required training or acknowledged a policy, which is evidence they are legally required to hold. The statutory registers the law obliges them to maintain. And group-level patterns only for wellbeing, counselling uptake and survey results — never you individually.

How the group-level protection actually works

A group figure is released only when the group is large enough that no individual can be identified. That threshold is higher for the most sensitive information: wellbeing and counselling figures require a materially larger group than routine workplace statistics, and statistical noise is added to those figures. We also limit how many such questions can be asked in a period, so a series of narrow queries cannot be combined to isolate a person, and a team that is permanently too small is never reported on. For harassment, whistleblower and grievance data, the system is configured so that no group figure is releasable at all.

The one narrow exception, stated plainly

Where there is a credible risk of imminent harm to someone, a designated responder may escalate. That escalation is restricted to named safety roles, limited to the minimum information necessary, and permanently logged. It exists to keep people alive, and it is the only path by which counselling information can move.

4. Why we are allowed to process it

• Your wellbeing and counselling data: your consent, which you may withdraw at any time.
• Compliance, training and statutory registers: your employer’s employment-related obligations under the DPDP Act.
• An open harassment, whistleblower or grievance case: your employer’s legal obligation. Once closed, retention continues on a legitimate-use basis for the statutory period.

If you withdraw consent while a case is open: wellbeing processing stops. The case record does not disappear — the law requires it to be retained. We consider it important to tell you this rather than let you discover it later.

5. Who else is involved

We do not sell your personal data. We do not use it for advertising. We do not use your wellbeing, case, or counselling data to train artificial-intelligence models.

EECly contains no artificial-intelligence feature. Nothing you write — no complaint, no report, no survey answer, no wellbeing entry — is sent to any AI provider, because this application does not use one. Should that ever change, we will name the provider here and ask for your consent before it applies to you.

6. Where your data is held

EECly’s production systems run in India (AWS Mumbai, ap-south-1), and this is enforced rather than merely intended: an automated check fails the build if a non-Indian region is ever configured.

7. How long it is kept, and what deletion means

Deletion works differently by data type, because the law requires different things:

• Wellbeing and counselling data — irreversibly destroyed on request, by destroying the encryption keys that make it readable.
• Survey responses — permanently detached from your identity.
• Harassment, whistleblower, grievance and training records — retained. Your employer is legally obliged to hold these, and that obligation overrides a deletion request.
• While any case involving you is open, a legal hold applies and pauses deletion until the case closes and the statutory retention period expires.

We would rather state this plainly than imply a right to erasure we cannot lawfully deliver.

8. Your rights

You may access your data, ask us to correct it, and request erasure, subject to section 7. You may withdraw consent for wellbeing features at any time without losing access to the compliance parts of EECly. You may raise a grievance and nominate someone to act for you.

Requests are handled through EECly. Where your employer is the Fiduciary for the data in question, we will route your request to them and support them in answering it.

9. Security

Data is encrypted in transit and at rest. Access is enforced per role at the database itself, so a request that should not see something cannot see it even if application code is wrong. Sensitive case material is held in a separate protected store, and every access to a case is logged. Access decisions fail closed — an unrecognised role is granted nothing rather than everything.

No system is perfectly secure, but the controls above are structural, not procedural.

10. Children

EECly is a workplace application and is not intended for anyone under 18.

11. Changes

We will update this policy as EECly changes. Material changes will be notified in-app and reflected in the “Last updated” date above.