Version 01/23
Updated: Monday, Feb 14, 2023
Sentinel Lab Pvt. Ltd. (Nepal)
[Operator of Locomo Mobile App & Tracking Device]
At Sentinel we are aware of the trust you place in us when you buy our products and of our responsibility to protect your information. This Policy describes who we are, why we need to collect your information and how we will use it. We will tell you who we share your information with and how we use it to improve the service we provide to our customers.
Who we are
You are giving your information to Sentinel Lab Pvt. Ltd. (Nepal) (“we”, “us” or “our”). We have our registered office at Mahabir Marg South, Kupondole, Lalitpur 44700, Nepal. We are registered for license with the Ministry of Information under number #______, registered as a limited company with Company Registrar under number # …. , registered for import business and commerce with Ministry of Industry & Commerce under number # ……..
Where we refer to ‘you’ in this Privacy Policy we mean the User/Subscriber who receive the Services in accordance with your subscription agreement with Sentinel. If you have any questions or suggestions, please feel free to contact us by writing to our registered office or e-mailing us at info@sentinellab.io
PERSONAL DATA WE COLLECT AND WHY
“Personal data” refers to any data or information from which an individual may be directly or indirectly identified (“Personal Data”). When we provide our mobile app, website, products or services, we have a need to process Personal Data. When you:
ACCESS AND USE OF OUR MOBILE APP
We collect your following Personal Data to provide our services to you:
- your Internet Protocol (IP) address,
- your location information (such as may be determined from your Internet Protocol (IP) address),
- your mobile app activity information (such as usage information),
- location data of your vehicle/motorbike in which you have installed our device and linked that device to our mobile app.
- Your request for Police Services to track your stolen vehicles/motorbikes.
- Scanned copies of your documents that you provide our authorized resellers when availing a GSM SIM card from telecommunications provider as required by law.
HOW WE SHARE YOUR PERSONAL DATA
We do not share the Personal Data above with anyone or any entity except those mentioned in Terms of Reference. These entities include Nepal Police (only applicable when you seek police services), our authorized resellers where you install the device in your vehicle/motorbike, and finance companies, and insurance companies where you have financed and insured your vehicle/two wheelers from.
We do not share your personal data or any identifiers with any third parties other than listed above, but we may share your personal data with any companies or subsidiaries of the company.
HOW TO MAKE REQUESTS
If you would like to access, correct, and delete any Personal Data we hold about you, or exercise any other data subject rights available to you under applicable laws or regulations with the purpose of protecting Personal Data(“Applicable Data Protection Law”), you may submit a request via e-mail at info@sentinellab.io
We aim to respond to your request for access, correction, or deletion within the time required by Applicable Data Protection Law. If we need more time to respond to your request, we will let you know of the reason and the extension period in writing.
We do not share your personal data or any identifiers with any third parties other than listed above, but we may share your personal data with any companies or subsidiaries of the company.
RETENTION PERIOD
We will not use and store Personal Data longer than necessary to fulfil the above mentioned purposes and shall remove the collected Personal Data after the necessary period to achieve the purposes described in this Privacy Policy has passed, or as permitted or required by Applicable Data Protection Law.
SECURITY
We take technical and organizational security measures to protect your Personal Data managed by us from being tampered with, lost, destroyed, or accessed by unauthorized individuals. We are continuously improving our security measures in line with technological advancements.
OUR COMMITMENT TO CHILDREN’S PRIVACY
We do not knowingly collect, use, share or sell the Personal Data of children. If we learn that we have collected Personal Data from a child, we will delete that information.
CHANGES TO THIS PRIVACY POLICY
We reserve the right to amend this Privacy Policy at our discretion and at any time. If the changes allow us to use Personal Data in ways that materially affect your rights, we will post a special note and, if required by law, will prompt you for your consent for certain changes. When we make changes this Privacy Policy, we will post the updated Privacy Policy and update the “Last Updated” date. Each version of this Privacy Policy will be identified by their Last Updated date.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
YOUR RIGHTS
You have the following rights:
- the right to ask us to provide you with a copy of the personal information that we hold about you at any time free of charge.
- We reserve the right to charge the administrative cost of providing you with the requested information in situations where your request is excessive or unfounded, for instance where your request is repetitive, or you require multiple copies;
- the right to ask us to update and correct any out-of-date or incorrect personal information that we hold about you free of charge;
- the right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.
- All of our marketing communications will give you the opportunity to unsubscribe from receiving further marketing communications from us and you can update your marketing preferences.
COMPLAINTS
Although Nepal does not have a dedicated regulatory agency to enforce privacy laws, you have the right to make a complaint at any time to relevant government agencies, or at the Ministry of Information and Communications. https://mocit.gov.np/
We would, however, appreciate the chance to deal with your concerns before you approach the Ministry so please contact us in the first instance.
CONTACT US
Sentinel Lab Pvt Ltd, Mahabir Marg, Kupondole, Lalitpur 44700, Nepal
The laws and judicial precedents regarding data protection in Nepal
The Constitution of Nepal, 2015
The Constitution of Nepal has recognized right to privacy as a fundamental right under Article 28. This inviolable fundamental right guarantees the right to individuals to decide who may enter their residence and protects them from unauthorized intrusions. It also restricts a third party to use or disclose their property, documents, correspondence, etc.
The Privacy Act, 2018
Implementing the constitutional right to privacy, in September 2018, Nepal passed The Privacy Act, 2018 which had a major impact on the data privacy and security in Nepal.
However, this is not a unified law on privacy and it must be read in conjunction with the general laws of Nepal like Criminal code and Civil Code.
The Act contains provisions regarding privacy of body, character, family, residence, property, document, data, correspondence and privacy through electronic means.
The Act and Regulations provide no specific provision so as to regulate data transfers. The term “transfer” indicates transferring of personal information to the third party thereby requiring consent from a concerned individual.
Pursuant to the Act, consent of an individual is sufficient enough for transferring the data. The Act prohibits disclosing or transferring of personal data of an individual without obtaining consent from such an individual.