Pabitra Lumbini Saving and Credit Cooperative Ltd. ("we," "us," "our," or "the Cooperative") operates a mobile application (the "App") that allows our members to manage their savings and credit accounts, transfer funds, pay utility bills, and access other financial services.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App. Please read this policy carefully. By downloading, accessing, or using the App, you agree to the collection and use of your information as described here. If you do not agree with the terms of this policy, please do not use the App.

1. Information We Collect

1.1 Personal Information You Provide

When you register for and use the App, we may collect:

• Full name, date of birth, and citizenship/identification details
• Contact information (phone number, email address, home address)
• Member/account number(s) and cooperative membership details
• Photograph or profile image (if provided)
• Signature (for verification purposes)
• Know Your Customer (KYC) documentation required by regulatory authorities

1.2 Financial and Account Information

• Account balances and statements
• Transaction history, status, and details (amount, date, recipient/sender, purpose)
• Transaction limits
• Fixed deposit account details and terms
• Cheque book and ATM/debit card details, including requests, issuance, and block/hotlist status
• Fund transfer details (inter-account, inter-cooperative, and external bank transfers)
• Digital wallet loading transactions
• Utility bill payment details (mobile top-up, internet, electricity/NEA, TV, catering, and similar household bills, and flight booking transactions)

1.3 Authentication and Security Information

• Login credentials (username, password/PIN — stored in encrypted/hashed form)
• Biometric authentication data (fingerprint or facial recognition), where enabled by your device, used only for local device authentication
• One-Time Passwords (OTPs) and multi-factor authentication codes
• Device identifiers, IP address, and security logs used to detect fraud

1.4 Automatically Collected Information

• Device information (model, operating system, unique device identifiers)
• App usage data and diagnostic/crash logs
• Approximate location data, where required to verify transactions or comply with regulatory/anti-fraud requirements (only with your permission)
• Log data such as access times, pages viewed, and app interactions

1.5 Information from Third Parties

• Verification data from partner banks, payment gateways, or the national payment switch when you make external bank transfers or wallet loading
• Data from utility providers (e.g., NEA) needed to process and confirm your bill payments

2. How We Use Your Information

We use the information we collect to:

1. Create, verify, and manage your Cooperative membership and account
2. Display account balances, statements, and transaction history and status
3. Enforce and display applicable transaction limits
4. Process requests for cheque books and ATM/debit cards, including blocking lost or stolen cards/cheques
5. Open and manage fixed deposit accounts
6. Process fund transfers between your own accounts, to other Cooperative members, and to external bank accounts
7. Process digital wallet loading
8. Process utility bill payments, mobile top-ups, internet bills, flight bookings, and household bill payments (NEA, catering, TV, etc.)
9. Authenticate your identity and secure your account (including OTP and biometric verification)
10. Detect, investigate, and prevent fraud, unauthorized transactions, and security incidents
11. Comply with applicable laws, including anti-money laundering (AML), KYC, and cooperative/financial regulatory requirements in Nepal
12. Send transaction notifications, service alerts, and important updates about your account
13. Respond to your customer service inquiries and support requests
14. Improve the App's functionality, performance, and user experience

3. Legal Basis for Processing

We process your personal and financial information based on:

• Contractual necessity — to provide the services you request as a member
• Legal obligation — to comply with financial regulations, KYC/AML laws, and cooperative sector requirements in Nepal
• Consent — for optional features such as biometric login, location access, and marketing communications
• Legitimate interest — to prevent fraud and secure our systems

4. How We Share Your Information

We do not sell your personal or financial information. We may share your information only in the following circumstances:

• With banking and payment partners — to complete external bank transfers, inter-cooperative transfers, and digital wallet loading
• With utility and service providers — to process bill payments (e.g., NEA, internet providers, telecom operators, airlines)
• With regulatory and government authorities — including Nepal Rastra Bank, the Department of Cooperatives, and other authorities, as required by law
• With service providers — such as cloud hosting, SMS/OTP gateways, and IT infrastructure vendors, who process data on our behalf under confidentiality obligations
• For legal reasons — to comply with a legal obligation, court order, or to protect the rights, property, or safety of the Cooperative, our members, or the public
• With your consent — for any other purpose not listed above

5. Data Security

We implement industry-standard technical and organizational measures to protect your information, including:

• Encryption of data in transit (TLS/SSL) and, where applicable, at rest
• Secure authentication, including OTP and biometric options
• Access controls limiting employee access to personal and financial data on a need-to-know basis
• Regular security monitoring and audits
• Secure storage of KYC and identification documents

While we take reasonable steps to protect your information, no method of electronic transmission or storage is 100% secure. We encourage you to protect your login credentials, PIN, and device from unauthorized access.

6. Data Retention

We retain your personal and financial information for as long as your membership and account remain active, and thereafter for the period required by Nepal Rastra Bank regulations, cooperative laws, tax laws, and other applicable regulatory requirements (typically a minimum retention period as prescribed by law). After this period, your data is securely deleted or anonymized, unless a longer retention period is required for legal or dispute-resolution purposes.

7. Your Rights and Choices

Depending on applicable law, you may have the right to:

• Access the personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion of your information, subject to our legal and regulatory retention obligations
• Withdraw consent for optional features (e.g., biometric login, location access, marketing notifications)
• Request a copy of your transaction history and statements
• Lodge a complaint with the Cooperative or the relevant regulatory authority

To exercise any of these rights, please contact us using the details in Section 13.

8. Permissions Used by the App

Depending on the features you use, the App may request the following device permissions:

Permission	Purpose
Camera	Capturing photos/documents for KYC, cheque scanning, or profile pictures
Biometric (Fingerprint/Face ID)	Secure login and transaction authorization
Location	Fraud prevention and verifying transaction authenticity (optional)
Contacts	Optional — for facilitating fund transfers to other members (only with permission)
SMS	Reading OTPs automatically for faster authentication
Storage	Saving statements, receipts, or downloaded documents
Notifications	Sending transaction alerts and account updates

You may disable any of these permissions through your device settings; however, doing so may limit certain App features.

9. Children's Privacy

The App is intended for use by individuals who are of legal age to hold a savings/credit cooperative membership under Nepali law. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected data from a minor without appropriate consent, we will take steps to delete such information.

10. Third-Party Links and Services

The App may contain integrations or links to third-party services (e.g., payment gateways, airlines for flight booking, utility providers). This Privacy Policy does not cover the practices of third parties, and we encourage you to review their respective privacy policies.

11. International Data Transfers

Your information is primarily stored and processed within Nepal. If any data is transferred to or processed by service providers outside Nepal (e.g., cloud infrastructure), we take reasonable steps to ensure it receives an adequate level of protection consistent with this Privacy Policy and applicable law.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes through the App or via email/SMS, and will update the "Last Updated" date above. Continued use of the App after changes take effect constitutes your acceptance of the revised policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us: