Pabitra Smart Banking App

This policy explains how PAVITRA LUMBINI SAVINGS AND CREDIT COOPERATIVE SOCIETY LTD. ("we," "us," "our," or "the Cooperative") handles your personal information when you use the Pabitra Smart Banking mobile app (the "App"). We are a savings and credit cooperative registered in Kathmandu, Nepal under the Co-operative Division, registration number 2176/065/66. We are the data controller for the information described here.

The App is for existing members of the Cooperative. Membership and accounts are opened in person at our Bagbazar office, not in the App.

1. Information We Collect

1.1 Information held by the Cooperative

When you became a member, we recorded your details in our core banking system. The App shows you this information and does not collect more of it:

• Name, mobile number, address and membership details
• Account numbers, balances, statements and transaction history
• Fixed deposit, loan and savings account details
• Cheque book and ATM card requests

1.2 Information you provide in the App

• Activation and login: your mobile number, account number, SMS one-time password (OTP), and the password and transaction PIN you set. Your password and PIN are stored in protected form on our servers and are never shown in plain text.
• Transactions: amounts, recipients, account or wallet numbers, and the purpose you enter for transfers, utility and bill payments, mobile top-ups, insurance premiums, traffic fines and flight tickets. Recipients you save for quick payments are stored with your account.
• Loan enquiries: the details you enter in the Loan Enquiry form, which is sent to our office. It is not a loan application and does not trigger any credit decision in the App.
• Complaints and requests you submit through the App.
• Profile image or QR images you choose to upload or save, if you use those features.

1.3 Information collected automatically

• Device model, operating system version, App version and a device identifier, used to secure your login and detect unauthorized access
• IP address and security logs
• Push notification token, so we can send you transaction alerts and news
• Crash reports and basic App usage events (which screens and features are used), collected through Firebase Crashlytics and Firebase Analytics (see Section 4)

1.4 Information we do not collect

• Your fingerprint, face or other biometric data. Biometric login is handled by iOS or Android, and the App only receives a "success" or "failure" result.
• Your precise location.
• Your contact list. If you use the contact picker for mobile top-ups, only the number you select is used.
• Advertising identifiers. We do not show ads in the App.

2. How We Use Your Information

• To verify your identity, activate the App and secure your login
• To show balances, statements and transaction history
• To process transfers, QR payments, bill payments, top-ups and other payments you request
• To process requests such as cheque books, ATM cards, fixed deposits and loan enquiries
• To send transaction alerts, security messages and notices from the Cooperative
• To detect and prevent fraud and unauthorized access
• To respond to your complaints and support requests
• To fix crashes and improve the App's performance
• To meet our legal and regulatory obligations in Nepal, including anti-money laundering and record-keeping requirements

3. Legal Basis for Processing

• To provide the service: we need your information to run your membership account and carry out the transactions you ask for.
• Legal obligation: we must keep records and report to authorities as required by Nepali law.
• Consent: for optional features such as biometric login, push notifications and device permissions. You can withdraw consent at any time in your device settings.
• Legitimate interest: to protect your account and our systems from fraud and misuse, and to keep the App working.

4. How We Share Your Information

We do not sell or rent your personal or financial information. We share it only as follows:

We may also disclose information to protect the rights, property or safety of the Cooperative, our members or the public, or with your consent for any other purpose.

5. Device Permissions

The App asks for permission only when you use the related feature. You can change these at any time in your device settings.

Declining a permission only limits the matching feature. For example, without camera access you can still pay by entering details manually.

6. Data Security

• Data sent between the App and our servers is encrypted in transit (TLS).
• Your login password and transaction PIN are separate, and every transfer and payment is confirmed with your PIN.
• Access to member data inside the Cooperative is limited to staff who need it.
• We monitor for unusual activity and unauthorized access.

No system is completely secure. Please keep your password, PIN and OTPs private, never share them with anyone (including people claiming to be from the Cooperative), and keep your device locked. Contact us immediately if you think your account has been accessed without your permission.

7. Data Retention

We keep your account and transaction records for as long as you are a member, and afterwards for the period required by Nepali law governing cooperatives, taxation and financial record-keeping. When that period ends, we delete or anonymize the data, unless it is needed for a legal claim or dispute. Crash and analytics data held by Firebase is retained for the periods set by Google.

8. Your Rights and Choices

Subject to applicable law, you can:

• Ask what personal information we hold about you and get a copy
• Ask us to correct information that is wrong or incomplete
• Withdraw consent for optional features (biometric login, notifications, device permissions) in your device settings
• Turn off push notifications in your device settings
• Complain to us, or to the relevant regulatory authority, about how we handle your data

To make a request, contact us using the details in Section 13. We may need to confirm your identity first.

9. Account and Data Deletion

The App does not create accounts, so your membership account is managed by the Cooperative. You can:

• Stop using the App by logging out (More > Logout) and uninstalling it. This removes the data stored on your device.
• Ask us to remove your App access, or to close your account, by emailing info@pabitralumbini.com from your registered details or by visiting our Bagbazar office. We will deactivate your App access promptly.

As a regulated financial institution, we must keep account and transaction records for the period required by Nepali law, so these cannot be deleted on request before that period ends. Any information we are not legally required to keep will be deleted or anonymized once your request is processed.

10. Children's Privacy

The App is for adult members of the Cooperative. We do not knowingly collect information through the App from anyone under the legal age to hold a membership. If you believe a child has used the App, contact us and we will take appropriate steps.

11. International Data Transfers

Your account data is held in Nepal. Firebase services are provided by Google, which may process crash, analytics and notification data on servers outside Nepal. We use these services only for the purposes in Section 4.

12. Changes to This Policy

We may update this policy when our practices, the App or the law change. We will update the "Last Updated" date above and, for significant changes, notify you in the App or by SMS. Please check this page from time to time.

13. Contact Us

For questions, requests or complaints about this policy or your personal information: