Privacy Policy

Sub Telecom E-Commerce Platform

Last Updated: January 24, 2026

1. Introduction

Welcome to Sub Telecom. We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, store, protect, and share your personal data when you use our mobile application and e-commerce platform (collectively, the "Platform").

Important: By accessing or using our Platform, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree with our policies and practices, please do not use our Platform.

This Privacy Policy is designed to comply with:

1. Nepal's Data Protection and Privacy Laws
2. Electronic Transaction Act, 2063
3. International data protection standards
4. Google Play Store privacy requirements
5. Apple App Store privacy guidelines

2. Information We Collect

We collect information to provide you with better services, improve user experience, and fulfill our business operations. The information we collect falls into the following categories:

2.1 Information You Provide to Us

Account Registration Information: When you create an account on our Platform, we collect:

1. Full Name
2. Email Address
3. Physical Address (shipping and billing)
4. Phone Number
5. Password (encrypted and securely stored)

Order and Transaction Information: When you make a purchase, we collect:

1. Shipping and billing addresses
2. Payment method information (processed securely through third-party payment gateways)
3. Purchase history and transaction details
4. Order preferences and special instructions

Customer Support Information: When you contact our customer support, we may collect:

1. Communication records (emails, chat transcripts, phone call logs)
2. Feedback and survey responses
3. Product review and rating information
4. Complaint and dispute details

Profile Information: You may optionally provide:

1. Profile picture
2. Date of birth
3. Gender
4. Preferred communication settings

2.2 Information Collected Automatically

Device Information:

1. Device type, model, and manufacturer
2. Operating system and version
3. Unique device identifiers
4. Mobile network information
5. Screen resolution and device settings

Usage Information:

1. Pages and features accessed
2. Time spent on different sections
3. Search queries and browsing history
4. Product views and shopping cart activity
5. Click patterns and navigation paths

Location Information:

1. IP address
2. Approximate geographic location (city/region level)
3. Precise location (only if you grant permission for delivery optimization)

Technical Information:

1. Browser type and version
2. Internet connection type
3. App version and installation details
4. Crash reports and error logs
5. Performance metrics

2.3 Information from Third-Party Sources

Payment Processors:

1. Transaction confirmation and payment status
2. Limited payment method information (last 4 digits of card, payment type)

Delivery Partners:

1. Delivery status updates
2. Proof of delivery information

Social Media (if you choose to connect):

1. Public profile information
2. Email address associated with social account

Note: We do NOT collect sensitive personal information such as religious beliefs, political opinions, health information, or biometric data.

3. How We Use Your Information

We use your personal information for the following purposes:

3.1 Service Delivery and Order Fulfillment

1. Process and fulfill your orders
2. Arrange shipping and delivery
3. Send order confirmations and updates
4. Provide order tracking information
5. Handle returns, exchanges, and refunds
6. Verify payment and prevent fraud

3.2 Account Management

1. Create and manage your account
2. Authenticate your identity
3. Enable account features and preferences
4. Process account deletion requests
5. Maintain account security

3.3 Customer Service and Support

1. Respond to your inquiries and requests
2. Provide technical support
3. Resolve complaints and disputes
4. Conduct satisfaction surveys
5. Improve customer service quality

3.4 Platform Improvement and Analytics

1. Analyze user behavior and preferences
2. Improve Platform functionality and features
3. Develop new products and services
4. Conduct research and analytics
5. Test new features and updates
6. Optimize user experience

3.5 Communication and Marketing

1. Send transactional emails (order confirmations, shipping notifications)
2. Provide important Platform updates
3. Send promotional offers and deals (only if you opt-in)
4. Share product recommendations based on browsing history
5. Notify you about new products or features

Note: You can opt-out of marketing communications at any time through your account settings or by clicking "unsubscribe" in our emails.

3.6 Security and Fraud Prevention

1. Detect and prevent fraudulent activities
2. Protect against security threats
3. Verify user authenticity
4. Monitor for suspicious behavior
5. Enforce our Terms and Conditions

3.7 Legal Compliance

1. Comply with applicable laws and regulations
2. Respond to legal requests and court orders
3. Protect our legal rights and interests
4. Resolve disputes and enforce agreements
5. Meet regulatory requirements

4. How We Share Your Information

We do NOT sell, rent, or trade your personal information to third parties for their marketing purposes.

We may share your information only in the following limited circumstances:

4.1 Service Providers and Business Partners

We share necessary information with trusted third-party service providers who assist us in operating our Platform:

Payment Processors:

1. To process payments securely
2. Only payment-related information is shared
3. All processors are PCI-DSS compliant

Delivery and Logistics Partners:

1. To ship and deliver your orders
2. Only delivery-related information (name, address, phone number, order details)
3. Shared only for order fulfillment purposes

Technology Service Providers:

1. Cloud hosting and storage services
2. Email and notification services
3. Analytics and monitoring tools
4. Customer support platforms

Important: All service providers are contractually obligated to:

1. Use your information only for specified purposes
2. Maintain strict confidentiality
3. Implement appropriate security measures
4. Comply with data protection laws

4.2 Legal Requirements

We may disclose your information when required by law:

1. In response to court orders, subpoenas, or legal processes
2. To comply with legal obligations and regulations
3. To protect the rights, property, or safety of Sub Telecom, our users, or the public
4. To prevent or investigate fraud, security issues, or illegal activities
5. In connection with legal proceedings or regulatory investigations

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets:

1. Your information may be transferred to the acquiring entity
2. You will be notified of any such transfer
3. The new entity will be bound by this Privacy Policy

4.4 With Your Consent

We may share your information with third parties when:

1. You explicitly provide consent
2. You authorize specific sharing for particular purposes
3. You participate in promotional campaigns or contests

4.5 Aggregate and De-identified Information

We may share aggregated, anonymized, or de-identified information that cannot be used to identify you:

1. For business analytics and reporting
2. Market research and trend analysis
3. Platform improvement purposes

5. Data Security

We take the security of your personal information seriously and implement comprehensive measures to protect it:

5.1 Technical Security Measures

Encryption:

1. SSL/TLS encryption for all data transmission
2. End-to-end encryption for sensitive information
3. Encrypted storage of passwords using industry-standard hashing
4. Database encryption at rest

Access Controls:

1. Multi-factor authentication for internal systems
2. Role-based access control for employees
3. Regular access audits and reviews
4. Principle of least privilege access

Network Security:

1. Firewall protection
2. Intrusion detection and prevention systems
3. Regular security monitoring
4. DDoS protection measures

Application Security:

1. Regular security testing and vulnerability assessments
2. Code reviews and security audits
3. Secure development practices
4. Timely security patches and updates

5.2 Organizational Security Measures

Employee Training:

1. Regular security awareness training
2. Data protection and privacy education
3. Strict confidentiality agreements
4. Background checks for personnel with data access

Data Handling Policies:

1. Clear data handling procedures
2. Incident response protocols
3. Data breach notification procedures
4. Regular policy reviews and updates

Third-Party Security:

1. Vendor security assessments
2. Contractual security requirements
3. Regular compliance audits
4. Security certification verification

5.3 Security Limitations

While we implement robust security measures, please note:

1. No system is completely secure
2. Internet transmission carries inherent risks
3. You are responsible for maintaining account credential security
4. Notify us immediately of any suspected security breach

6. Data Retention

6.1 Retention Periods

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy:

Active Accounts:

1. Information retained while your account is active
2. Updated as you modify your profile or preferences

Inactive Accounts:

1. Accounts inactive for 3+ years may be archived
2. You will receive notification before archival
3. You can reactivate your account at any time

Order and Transaction Data:

1. Retained for 7 years for accounting and tax purposes
2. Required by Nepal's financial regulations
3. Necessary for warranty and customer service

Communication Records:

1. Customer support interactions retained for 3 years
2. Marketing communication preferences retained until you opt-out

Legal Requirements:

1. Data retained longer when required by law
2. Retained during ongoing legal proceedings or disputes

6.2 Data Deletion

We delete or anonymize personal information when:

1. Retention period expires
2. You request account deletion
3. Information is no longer needed for legitimate purposes
4. Legal retention requirements are satisfied

7. Your Rights and Choices

We respect your rights regarding your personal information. You have the following rights:

7.1 Right to Access

You have the right to:

1. Access your personal information
2. Request a copy of data we hold about you
3. Review your account information at any time through the Platform
4. Request information about how we process your data

How to Exercise: Log into your account or contact us at privacy@subtelecom.com.np

7.2 Right to Correction

You have the right to:

1. Correct inaccurate personal information
2. Update your profile details
3. Modify shipping and billing addresses
4. Change communication preferences

How to Exercise: Update information directly in your account settings or contact customer support.

7.3 Right to Deletion (Right to be Forgotten)

You have the right to:

1. Request deletion of your account
2. Request removal of your personal information
3. Have your data permanently erased from our active systems

Important Information:

1. Account deletion is permanent and irreversible
2. Some information may be retained for legal compliance
3. Deletion requests processed within 7-14 business days
4. You will receive confirmation upon completion

How to Exercise:

1. Use the "Delete Account" feature in your account settings
2. Contact privacy@subtelecom.com.np
3. Call customer support at +977 985-1013509

7.4 Right to Data Portability

You have the right to:

1. Receive your personal data in a structured, commonly used format
2. Transfer your data to another service provider
3. Request export of your information

How to Exercise: Contact privacy@subtelecom.com.np with your request.

7.5 Right to Opt-Out

You have the right to:

1. Opt-out of marketing communications
2. Unsubscribe from promotional emails
3. Disable push notifications
4. Withdraw consent for optional data processing

How to Exercise:

1. Click "Unsubscribe" in any marketing email
2. Adjust notification settings in the app
3. Contact us at info@subtelecom.com.np

Note: You cannot opt-out of transactional communications (order confirmations, shipping updates, account notifications).

7.6 Right to Object

You have the right to:

1. Object to certain data processing activities
2. Withdraw consent previously given
3. Request restriction of processing in specific circumstances

7.7 Right to Lodge a Complaint

If you believe we have violated your privacy rights:

1. Contact our Privacy Officer at privacy@subtelecom.com.np
2. File a complaint with relevant data protection authorities in Nepal
3. Seek legal remedies as provided by law

8. Children's Privacy

8.1 Age Restrictions

Our Platform is not intended for use by individuals under the age of 18. We do not knowingly:

1. Collect personal information from children under 18
2. Market our services to minors
3. Allow account creation by underage users

8.2 Parental Notice

If we become aware that we have collected information from a child under 18:

1. We will delete the information immediately
2. We will terminate the associated account
3. We will notify parents/guardians if contact information is available

8.3 Parental Rights

If you believe your child has provided us with personal information:

1. Contact us immediately at privacy@subtelecom.com.np
2. We will promptly investigate and take appropriate action
3. We will delete any information collected from minors

9. Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files stored on your device that help us improve your experience and understand how you use our Platform.

9.2 Types of Cookies We Use

Essential Cookies:

1. Required for Platform functionality
2. Enable account login and authentication
3. Maintain shopping cart contents
4. Remember your preferences
5. Cannot be disabled without affecting functionality

Analytics Cookies:

1. Collect information about Platform usage
2. Help us understand user behavior
3. Measure Platform performance
4. Improve user experience

Marketing Cookies:

1. Track your browsing across websites
2. Deliver personalized advertisements
3. Measure marketing campaign effectiveness
4. Only used with your consent

Functional Cookies:

1. Remember your preferences and settings
2. Provide enhanced features
3. Customize your experience

9.3 Managing Cookies

You can control cookies through:

1. Browser settings (block or delete cookies)
2. Platform settings for app-specific tracking
3. Cookie consent banner on first visit

Note: Disabling essential cookies may limit Platform functionality.

9.4 Other Tracking Technologies

We may also use:

1. Web beacons (tracking pixels)
2. Mobile device identifiers
3. Local storage technologies
4. Analytics tools (Google Analytics, etc.)

10. Third-Party Links and Services

10.1 External Links

Our Platform may contain links to third-party websites or services:

1. We are not responsible for their privacy practices
2. This Privacy Policy does not apply to third-party sites
3. Review their privacy policies before providing information
4. We do not endorse or control third-party content

10.2 Social Media Integration

If you connect social media accounts:

1. You authorize information sharing according to social platform policies
2. We collect only publicly available information
3. You can disconnect at any time
4. Refer to social media privacy policies for their practices

10.3 Payment Processors

Payment information is processed by secure third-party gateways:

1. We do not store complete credit card information
2. Payment processors have their own privacy policies
3. They are PCI-DSS compliant
4. Transaction data is encrypted

11. International Data Transfers

11.1 Data Storage Location

Your information is primarily stored on servers located in:

1. Nepal
2. Secure cloud storage facilities with international certifications

11.2 Cross-Border Transfers

In some cases, your information may be transferred to:

1. Service providers in other countries
2. Cloud hosting facilities outside Nepal
3. Payment processors with international operations

11.3 Transfer Protections

When transferring data internationally, we ensure:

1. Adequate level of data protection
2. Compliance with applicable data protection laws
3. Contractual safeguards with service providers
4. Use of standard contractual clauses where appropriate

12. Data Breach Notification

12.1 Our Commitment

In the event of a data breach that compromises your personal information:

1. We will investigate immediately
2. We will take steps to contain and remediate the breach
3. We will notify affected users without undue delay
4. We will report to relevant authorities as required by law

12.2 Notification Process

You will be notified via:

1. Email to your registered address
2. In-app notification
3. SMS for critical breaches
4. Public notice on our website if necessary

12.3 Information Provided

Our notification will include:

1. Nature of the breach
2. Types of information affected
3. Steps we are taking to address the breach
4. Recommended actions you should take
5. Contact information for questions

13. Changes to Privacy Policy

13.1 Right to Modify

We reserve the right to update or modify this Privacy Policy at any time to:

1. Reflect changes in our practices
2. Comply with legal requirements
3. Improve clarity and transparency
4. Address new technologies or services

13.2 Notification of Changes

We will notify you of material changes through:

1. Email notification to registered users
2. In-app notification or banner
3. Prominent notice on the Platform
4. Updated "Last Updated" date at the top of this policy

13.3 Your Acceptance

Material Changes:

1. You will be asked to review and accept significant changes
2. Continued use after notification constitutes acceptance
3. You may choose to delete your account if you disagree

Minor Changes:

1. Take effect immediately upon posting
2. Review this policy periodically for updates

14. Compliance with App Store Policies

14.1 Google Play Store Compliance

Our Platform complies with Google Play's privacy requirements:

1. Transparent data collection and use practices
2. Secure data handling and storage
3. User consent for data collection
4. Limited data sharing with third parties
5. Clear privacy policy disclosure

14.2 Apple App Store Compliance

Our Platform complies with Apple's App Store privacy guidelines:

1. Privacy nutrition labels accuracy
2. User privacy protection
3. Secure data transmission
4. Consent-based data collection
5. Transparent privacy practices

14.3 Privacy Labels

App store privacy labels accurately reflect:

1. Data collected by our Platform
2. How data is used
3. Whether data is linked to user identity
4. Whether data is used for tracking

15. California Privacy Rights (CCPA)

For users in California, USA (if applicable):

1. Right to know what personal information is collected
2. Right to know whether information is sold or disclosed
3. Right to opt-out of sale of personal information
4. Right to deletion of personal information
5. Right to non-discrimination for exercising privacy rights

Note: We do NOT sell personal information to third parties.

16. European Users (GDPR)

For users in the European Economic Area (if applicable):

1. Lawful basis for processing (consent, contract, legitimate interest)
2. Right to data portability
3. Right to restriction of processing
4. Right to object to processing
5. Right to lodge complaint with supervisory authority

17. Contact Information

17.1 Privacy Questions and Requests

For any privacy-related questions, concerns, or requests:

Privacy Officer

Sub Telecom

Email: privacy@subtelecom.com.np

Phone: +977 985-1013509

Address: Kathmandu, Nepal

Response Time: We will respond to privacy requests within 30 days.

17.2 General Customer Support

Email: info@subtelecom.com.np

Phone: +977 985-1013509

Business Hours: Monday - Saturday, 9:00 AM - 8:00 PM NST

17.3 Legal Inquiries

Email: legal@subtelecom.com.np

17.4 Data Protection Officer

For formal data protection inquiries:

Email: privacy@subtelecom.com.np

18. Definitions

Personal Information: Any information that can identify you directly or indirectly.

Processing: Any operation performed on personal data, including collection, storage, use, disclosure, or deletion.

Platform: The Sub Telecom mobile application and e-commerce website.

Third Party: Any individual or entity that is not Sub Telecom or you.

Consent: Your freely given, specific, informed agreement to the processing of your personal information.

19. Your Responsibilities

To protect your privacy and security:

1. Keep your account credentials confidential
2. Use strong, unique passwords
3. Log out after using shared devices
4. Review your account activity regularly
5. Update your information when it changes
6. Report suspicious activity immediately
7. Be cautious about phishing attempts
8. Verify official communications from us

20. Acknowledgment and Consent

By using the Sub Telecom Platform, you acknowledge that:

1. You have read and understood this Privacy Policy
2. You consent to the collection and use of your information as described
3. You understand your rights regarding your personal data
4. You agree to our data practices and security measures
5. You can withdraw consent and delete your account at any time
6. You will receive important updates about privacy changes

Thank you for trusting Sub Telecom with your personal information. We are committed to protecting your privacy and ensuring the security of your data.

This Privacy Policy is effective as of January 24, 2026

Sub Telecom

Connecting You to Tomorrow's Technology, Today

Contact Us:

Email: info@subtelecom.com.np

Phone: +977 985-1013509

Privacy: privacy@subtelecom.com.np

Legal: legal@subtelecom.com.np