1. STATEMENT
This Privacy Policy ("Policy") applies to the Shuklagandaki iSmart mobile application ("App", "Services"), available on the Google Play Store and Apple App Store under the developer/publisher account "Shuklagandaki iSmart". The App is the official mobile banking application of Shuklagandaki Saving And Credit Cooperative Ltd. ("Shuklagandaki", "Company", "we", "us", or "our"), and is technically developed and maintained on Sanjeewani's behalf by DevanaSoft Pvt. Ltd. ("Service Provider").
The following statement explains our Policy with respect to information including personally identifiable data ("Personal Data") and other information that is collected by us when you access and/or use the Shuklagandaki iSmart App. As you use our Services, we want you to be clear how we are using such Personal Data and the ways in which you can protect your privacy. By voluntarily providing us with Personal Data, you are consenting to our use of it in accordance with this Policy. If you provide Personal Data, you acknowledge and agree that such Personal Data may be transferred from your current location to the offices and servers of the Company and/or its Service Provider. All words and phrases used in this Policy shall have the same meaning given to them in our Terms of Use. Specifically, the word "Authorized Third Party" shall mean contractors, agents and/or third party supplier engaged by us from time to time for the purposes of providing certain Services.
2. CHANGES
Our Policy may change from time to time. As a result, at times it may be necessary for us to make changes to this Policy. We reserve the right to update, revise or modify this Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide us any of your Personal Data. This Policy was last updated on the date indicated above. Your continued use of the Services after any changes, revisions or modifications to this Policy shall indicate your agreement with the terms of such revised Policy.
ONE OR MORE OF OUR SERVICES ARE NOT CATERED TO USERS UNDER THE AGE OF 18. IF YOU ARE UNDER 18, PLEASE OBTAIN YOUR PARENT/GUARDIAN'S PERMISSION BEFORE USING AND/OR ACCESSING THE SHUKLSGANDAKI ISMART APP. PLEASE DO NOT PROVIDE US WITH YOUR PERSONAL DATA UNLESS YOU HAVE OBTAINED PERMISSION FROM YOUR PARENT/GUARDIAN. PARENTAL DISCRETION IS ADVISED FOR ALL USERS BELOW 18. WE ENCOURAGE PARENTS/GUARDIANS TO MONITOR THEIR CHILDREN'S INTERNET USAGE AND TO HELP ENFORCE OUR POLICY BY INSTRUCTING THEIR CHILDREN NEVER TO PROVIDE PERSONAL DATA THROUGH THE APP WITHOUT PERMISSION. IF YOU HAVE REASON TO BELIEVE THAT A CHILD UNDER THE AGE OF 18 HAS PROVIDED PERSONAL DATA TO US, PLEASE CONTACT US AND WE WILL ENDEAVOUR TO DELETE THAT INFORMATION FROM OUR DATABASE. OTHERWISE, ALL PERSONAL DATA PROVIDED BY A USER SHALL BE DEEMED TO HAVE BEEN SUBMITTED BY A USER ABOVE 18 OR ONE WHO HAS OBTAINED THE RELEVANT PERMISSION FROM THEIR PARENT/GUARDIAN.
3. PARENTAL ADVISORY
As Shuklagandaki iSmart is a financial services application intended for co-operative members and account holders, use of the App by minors requires prior parental or guardian consent, and account-holding eligibility is further subject to Shuklagandaki Saving And Credit Cooperative Ltd.'s own membership and account-opening rules. Parents/guardians are encouraged to supervise use of the App by minors under their care.
4. THE INFORMATION WE COLLECT
Personal Data that you provide to us.
We collect Personal Data (such as name, gender, postal address, date of birth, telephone number, email address, account and card information, photographs, KYC and identification documents, etc.) when you voluntarily provide such information to us, or when it is required in order to open or operate your Sanjeewani account and use the App's banking features.
Information we get from your use of the App.
When you interact with us through the App, we may collect or receive and store certain information automatically. This includes:
Device-specific information such as hardware model, operating system version, unique device identifiers, mobile network information, memory, and IP address.
Cookies and similar technologies that may uniquely identify your browser or device (see Section 8).
Details of how you use the App, such as transaction activity and search queries.
Aggregate statistics such as the total number of visitors/users and usage of each feature of the App.
5. USE OF YOUR PERSONAL DATA AND INFORMATION
We use the Personal Data you provide in a manner that is consistent with this Policy. Where you provide Personal Data for a specific purpose, we will use it in connection with that purpose. Sanjeewani, its Authorized Third Parties, and/or its Service Provider may use your Personal Data and Information for the following reasons:
For the purposes of technical administration of the App.
For research and development.
Statistical analysis.
Customer administration.
Profiling of service preferences.
Finance and marketing operations, including credit control services, where relevant.
Compliance with any regulatory, statutory or legal obligation imposed on us by any relevant authority (including Nepal Rastra Bank and applicable co-operative regulations).
To operate and provide the App and banking services to you.
To support your questions about the use of the App.
To detect and prevent fraudulent activity.
To verify and process payments and transactions when you use the App.
To verify and record your personal particulars, including comparing them with information from other sources, and to communicate with you.
To conduct market research on users of the App, including number of users, frequency of use, and user profile, and to use such analysis for business planning and enhancement of our services.
To send you information, promotions and updates in relation to Sanjeewani's goods and services.
If we intend to use any Personal Data in a manner that is not consistent with this Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected.
6. DISCLOSURE OF YOUR PERSONAL INFORMATION
We are not in the business of selling your information. We consider this information to be a vital part of our relationship with you. As such, we will not sell or rent your Personal Data except as provided herein. There are, however, certain circumstances in which we may share your Personal Data with third parties without further notice to you, as set out below:
Service Provider – We share Personal Data with DevanaSoft Pvt. Ltd. as our technology partner, solely for the purpose of developing, hosting, and maintaining the Shuklagandaki iSmart App on our behalf, and strictly in accordance with this Policy.
Business Transfer – As we develop our business, we might sell or transfer businesses or assets. In the event of a merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Legal Requirements – To comply with any order of court or directive from authorities investigating any alleged offence, misdeed and/or abuse, or to enforce any of the terms of the Terms of Use or this Policy, or where necessary to protect and defend the rights or property of Sanjeewani.
7. THIRD PARTY SERVICES
The App may provide a link or a platform to third-party applications, websites and/or services ("Third Party Services"). We are not responsible for the privacy practices or the content of such Third Party Services. You should review the privacy policies of any Third Party Services you access. This Policy applies solely to information collected by the Shuklagandaki iSmart App.
8. COOKIES
When you use the App, your device may automatically be issued with a cookie or similar identifier. These are used to identify your device to our server and to record which areas of the App have been used, and for how long.
We use cookies and related technologies to:
Help save and retrieve login information, so you do not have to re-enter it on every visit.
Track frequency and duration of use, and help us understand how you reached the App.
Analyze the profile of users to help us improve the App.
Personalize content and promotions shown within the App.
You may configure your device to accept, reject, or notify you of cookies; declining cookies may limit certain features of the App. We may also use third-party service providers who place or read cookies in the course of providing analytics or support services to us. We have no access to or control over any cookies placed directly by unrelated third parties, and such cookies are not subject to this Policy.
9. OPTING OUT, CHANGE, UPDATE AND ACCESS TO YOUR INFORMATION
You may be able to access certain parts of the App without providing Personal Data; however, core banking features of Shuklagandaki iSmart require Personal Data in order to identify and serve you as an account holder.
Where you provide Personal Data, we may use it to contact you about services we believe may interest you. Each such communication will contain instructions permitting you to opt out of future marketing communications. You may also contact us at any time to opt out, or to have your details removed from our marketing communications.
You can write to us at info@devanasoft.com.np, or to Shuklagandaki Saving And Credit Cooperative Ltd. directly, to obtain details of the Personal Data we hold about you. Please provide your name and address, and brief details of the information requested. We may charge a reasonable administration fee as permitted by applicable law, and we reserve the right to refuse a request, with reasons given.
10. SECURITY
The Internet is not a completely secure medium, and communications over the Internet may be subject to third-party interception. Sanjeewani and DevanaSoft Pvt. Ltd. cannot accept responsibility for unauthorized access to, or loss of, personal information, except as set out in the Terms of Use.
We have implemented security policies, rules and technical measures to protect your Personal Data from unauthorized access, improper use or disclosure, unauthorized modification, unlawful destruction or accidental loss. All employees and data processors with access to Personal Data are obliged to respect its confidentiality. While we cannot guarantee that loss, misuse or alteration of data will never occur, we take reasonable steps to prevent this.
Personal Data collected from you is stored and backed up securely in an environmentally controlled location. Only authorized personnel with a valid user ID and password have access to this information.
11. TRANSFERRING YOUR INFORMATION OUTSIDE OF NEPAL
It may be necessary to transfer your Personal Data to group companies or service providers located outside Nepal, including our Service Provider's technical infrastructure where applicable. This may occur where an Authorized Third Party is based outside Nepal, or where you use the App from outside Nepal. By continuing to use the App, you consent to such transfer.
12. CONTACTING US
If you have any questions about this Policy or your dealings with the Shuklagandaki iSmart App, please write to us at: info@devanasoft.com.np, or contact Shuklagandaki Saving And Credit Cooperative Ltd. directly through your nearest branch.
13. LANGUAGE
In the event of a conflict regarding the use of words and/or meanings of this Privacy Policy between the English and Nepali versions, the meaning given to it in the English language shall prevail.