PRIVACY POLICY FOR VASUKO APP SOLUTIONS PVT. LTD.

Vasuko exists to simplify the way people find suitable living spaces and to make the process of living, renting, and moving across Nepal more accessible, transparent, and secure. We are a community built on the foundation of trust between neighbors, tenants, and landlords. A fundamental part of earning and maintaining that trust is being fully transparent about how we collect, use, and protect your personal information, ensuring your fundamental right to privacy as enshrined in the Individual Privacy Act, 2075.

This Privacy Policy explains how Vasuko App Solutions Pvt. Ltd. and its affiliates (“we,” “us,” or “Vasuko”) process personal information in connection with your use of the Vasuko Platform. Depending on your role—whether you are a Tenant (Guest) searching for a room, apartment, or other accommodation, or a Landlord (Host) listing a property—specific sections of this policy will apply to you.

1. WHAT IS PERSONAL INFORMATION?

“Personal Information” refers to any information which is related to, associated with, or could be reasonably linked to an identified or identifiable individual. At Vasuko, we categorize this information to ensure we handle each type with the appropriate level of security and legal care.

Consistent with the Individual Privacy Act, 2075 (2018) of Nepal, this includes:

1.1 Contact and Profile Information

Information that allows us to identify and communicate with you, such as:

• Your Identity: Full name, gender, date of birth,
• Communication: Verified mobile number, email address, and permanent/current address.
• Personal Image: Profile photographs and any media you choose to upload to your public profile.

1.2 Statutory Identity Information (KYC)

Under the laws of Nepal for digital marketplaces, we are required to verify who you are to prevent fraud and ensure community safety. This includes:

• Government Identifiers: Scanned images or details of your Citizenship Certificate (Nagakrita), Passport, or National ID (NID).
• Verification Metadata: Data derived from these documents, such as your citizenship number, issue date, and issuing district.
• Biometric Data: Fingerprints, thumbprints, or facial recognition metadata (selfies) used for secure authentication.

1.3 Financial and Transactional Information

To facilitate room bookings and payments, we collect:

• Payment Details: Information related to your eSewa or other mobile wallets, including transaction IDs and timestamps.
• Banking Data: Bank account numbers and branch details (primarily for Hosts to receive rental payouts).
• Audit Trail: History of payments made, refunds processed, and any tax-related information (such as your PAN number for TDS compliance).

1.4 Technical and Usage Data

Information collected automatically when you use the Vasuko App:

• Precise Geolocation: Real-time location data (via GPS or IP address) used to show you available rooms "Near Me".
• Device Telemetry: Your IP address, device model (e.g., iPhone 15, Samsung S24), operating system, and unique device identifiers (IMEI/UDID).
• Behavioral Data: Your search history, room "favorites," and patterns of how you interact with listings.

2. WHO CONTROLS MY PERSONAL INFORMATION?

2.1 The Data Controller

Where this Policy mentions “Vasuko,” “we,” “us,” or “our,” it refers to Vasuko App Solutions Pvt. Ltd., a company registered under the laws of Nepal (Registration No. [Insert No.]), with its registered office at Ghorahi-15, Dang, Nepal.

As the Data Controller, we are responsible for the collection, storage, and processing of your personal information in accordance with this Privacy Policy and the Individual Privacy Act, 2075.

2.2 Payments Controller

When you use our Platform to pay rent or receive payouts, certain financial information is processed to facilitate these services.

• Internal Control: Vasuko acts as the primary controller for your transaction history and payout details (e.g., bank account numbers or wallet IDs).
• Third-Party Processing: While Vasuko controls the metadata of your transactions, your sensitive financial credentials (like passwords or PINs) are processed by our licensed payment partners (e.g., eSewa, or partner banks). These entities act as independent controllers for the data they collect during the payment process.

2.3 Booking Refunds and Security

If a Tenant (Guest) is unable to complete a booking or chooses to cancel, Vasuko provides a refund according to our Refund Policy. Refunds are available for cancellations made at least 24 hours prior to the scheduled move-in or stay. Any personal information related to the booking, cancellation, or refund process will be securely handled by Vasuko App Solutions Pvt. Ltd. and, if applicable, by third-party payment providers.

Financial records of cancelled transactions and processed refunds will be archived for 7 years to comply with Nepal's tax auditing requirements.

3. PERSONAL INFORMATION WE COLLECT

3.1 Personal Information Necessary to Use the Vasuko Platform

We collect personal information about you when you use the Vasuko Platform. Without this information, we may not be able to provide all requested services (such as booking a room or processing a payout). This information includes:

3.1.1 Contact, Account, and Profile Information (Manual Registration)

If you choose to register an account manually, we require:

• Full Name: To identify you and facilitate trust between Tenants and Hosts.
• Email Address: Used for account recovery, official notifications, and identity validation.
  • Verification Method: Upon signup, a Secure Verification Link is sent to your email. You must click this link to authenticate your account.
• Password: Securely hashed (using industry-standard algorithms like bcrypt or Scrypt) and stored to protect your account from unauthorized access.

3.1.2 Information Collected via Third-Party Login (Continue with Google/Facebook)

By selecting 'Continue with Google,' you provide explicit authorization for the transfer of your basic profile information to the Vasuko Platform. If you choose to link, connect, or login to the Vasuko Platform with a third-party service, such as Google, you direct that service to send us specific information as controlled by that service or as authorized by you via your privacy settings. This typically includes:

• Your Profile Identity: First name, last name, and profile photograph.
• Account Credentials: Your verified email address and unique Google/Third-party identifier.
• Note on Passwords: When you use "Continue with Google," Vasuko never receives or stores your Google password. The authentication is handled entirely by Google’s secure servers.

3.1.3 Identity Verification Information

To maintain a high-trust marketplace and comply with the Individual Privacy Act, 2075, we may ask for an image of your government-issued ID. This includes your Citizenship Certificate (Nagarikta), National ID (NID), or Passport. We may also require a "Live Selfie" to verify that the person using the app matches the ID provided.

3.1.4 Payment and Transaction Information

To facilitate bookings and rent collection, we collect transaction details including the payment instrument used (e.g., eSewa, or Bank Transfer), transaction date and time, payment amount, and billing address. While we do not store your private wallet PINs, we retain transaction IDs for auditing and refund purposes.

3.1.5 Host Property & License Information

If you are a Host (Landlord), we may collect documentation regarding your property’s legal status, such as a copy of the Land Ownership Certificate (Lalpurja), house maps, or any local ward-level permits required to offer a rental listing.

3.1.6 Background Screenings

Consistent with the laws of Nepal and for the safety of our users, we may require Hosts or Guests to provide relevant background clearances (such as a Police Clearance Report) to participate in or offer a listing.

3.2 Personal Information You Choose to Give Us

You can choose to provide us with additional personal information to improve your experience and build trust within the Vasuko community.

• 3.2.1 Additional Profile Information: You may provide details such as your gender, preferred language(s), current city, a personal description ("About Me"), hometown. This information helps other community members get to know you before a booking.
• 3.2.2 Biometric Information: With your explicit consent (as required by the Privacy Act, 2075), we may process facial recognition data derived from the "Live Selfies" and ID documents you submit. This is used solely for the purpose of ensuring that "You are who you say you are" and preventing fraudulent account takeovers.
• 3.2.3 Communications Information: When you communicate with Hosts or Guests through the Vasuko Platform, we collect information about your communication and any information you choose to provide. This includes message content, timestamps, and routing information. We may also monitor these communications for fraud prevention and safety investigations.
• 3.2.4 User-Generated Content: This includes any photos of rooms, videos of properties, written reviews, and ratings you post on the Platform. Once posted, some of this information may be visible to the public or other users.
• 3.2.5 Support and Grievance Information: When you contact our support team, we collect your chat history, email transcripts, and (where applicable) call recordings to resolve your concerns and improve our service quality.
• 3.2.6 Business and Professional Information: If you are a professional property manager or a registered company, we collect your registered business name, VAT/PAN registration number, and office address to comply with Nepal’s Tax Laws and the Company Act.
• 3.2.7 Preferences and Requirements: You may disclose specific requirements for your stay, such as dietary preferences, accessibility needs (e.g., wheelchair access), or health-related requirements. By disclosing this sensitive information, you provide Vasuko with consent to process it to fulfill your specific request.
• 3.2.8 Other Information: This includes information you provide when you respond to Vasuko surveys, participate in community forums, enter promotions, or share your "Vasuko Story" with us.

3.3 Personal Information Automatically Collected by Using the Vasuko Platform

When you navigate the Vasuko Platform, we automatically collect certain information. This is necessary for the technical functionality of the app and to provide location-based room-rental services.

• 3.3.1 Geolocation Information: Depending on your device settings, we collect precise or approximate location data determined from your IP address, mobile device’s GPS, or Wi-Fi signals. This allows us to show you "Rooms Near Me." We may collect this even when the app is in the background if you have enabled "Always On" location permissions.
• 3.3.2 Usage Information: We track your interactions with the Vasuko Platform, including searches for rooms, bookings made, additional services selected, and access timestamps. We also monitor the content you view and links you click. This helps our recommendation engine suggest better matches for you.
• 3.3.3 Device Information: We collect hardware and software information such as your device model, operating system version, advertising IDs, and crash data. This is vital for debugging and ensuring the app runs smoothly on all Nepali network carriers.
• 3.3.4 Cookies and Tracking Technologies: We use cookies, pixels, and mobile identifiers (via Firebase Analytics) to recognize you across different sessions and to measure the effectiveness of our marketing campaigns.

3.4 Personal Information We Collect from Third Parties

To the extent permitted by the Individual Privacy Act, 2075, we may collect information about you from other sources:

• 3.4.1 Third-Party Applications: If you choose to link or login to Vasuko via Google, you direct that service to send us information such as your profile name and email address as controlled by your privacy settings on that platform.
• 3.4.2 Verification and Background Providers: Consistent with local laws, we may collect information from background screening providers or police clearance databases to verify your suitability as a Host or Guest.
• 3.4.3 Referrals and Co-Tenants: If a friend invites you to Vasuko or lists you as a co-tenant in a rental agreement, they may provide us with your name and contact information.
• 3.4.4 Complainants: If a Host, Guest, or neighbor submits a complaint about your conduct, we will collect information related to that specific report to investigate and resolve the dispute.
• 3.4.5 Financial Institutions and Wallets: If you pay via eSewa, we receive transaction confirmation metadata from these institutions to verify that your rent has been successfully paid.
• 3.4.6 Building & Ward Management: We may receive information from house owners, Tole Sudhar Samitis, or local Ward offices to verify that a property is legally authorized for rental.
• 3.4.7 Corporate Affiliates and Partners: We may receive additional info from our partners or other platforms we operate to provide a more seamless "belonging" experience across our ecosystem.
• 3.4.8 Publicly Available Sources: Where permitted, we may collect info from public records, social media profiles, or other rental platforms where you have listed your property, to ensure the data on Vasuko is accurate and up-to-date.

4. HOW WE USE PERSONAL INFORMATION WE COLLECT

We use personal information to carry out the processing described in the sub-sections below. This includes using automated systems and AI technologies that we develop and improve to provide a seamless "Vasuko" experience.

4.1 Provide the Vasuko Platform

We process personal information to:

• Enable you to access the Vasuko Platform and make or receive rent payments.
• Enable you to list, search for, and book accommodation services.
• Enable communication between Tenants and Hosts via in-app messaging.
• Provide customer support and respond to your inquiries.
• Send you administrative messages, security alerts, and account notifications.
• Determine your local jurisdiction to ensure compliance with specific Ward or Municipality rental regulations.

4.2 Develop and Improve the Platform

We process personal information to:

• Perform data analytics and debug software issues to ensure the app works on all Nepali mobile networks.
• Train and improve our recommendation AI to suggest rooms that better fit your preferences.
• Conduct research to understand housing trends in Nepal and develop new products.

4.3 Personalize and Customize Your Experience

We process personal information to:

• Infer your preferences (e.g., preference for "flat-mates" vs. "independent rooms") based on your search history.
• Customize the home feed to show listings relevant to your specific city (e.g., Kathmandu vs. Dang).

4.4 Promote Trust, Safety, and Quality

This is a high-priority area to ensure the Vasuko community remains safe:

• Identity Verification: Authenticate your Citizenship/NID or Passport to ensure every user is a real person.
• Fraud Prevention: Detect and prevent "Fake Listings," "Double Bookings," or payment scams.
• Background Checks: Consistent with the laws of Nepal, conduct checks against public databases to protect our community from illegal activities.
• Dispute Resolution: Resolve conflicts between Tenants and Hosts, which may involve reviewing communication logs.
• Health & Wellbeing: Comply with legal obligations to protect the safety of the public (e.g., reporting illegal rental activities to the Nepal Police).

4.5 Advertising and Marketing

We process personal information to:

• Send promotional messages and marketing info that we think might interest you (you can opt-out at any time).
• Administer referral programs (e.g., "Refer a Friend" rewards).
• Analyze your preferences to show you relevant advertisements for household services or moving companies.

4.6 Analyze Your Communications

• Purpose: We may scan and analyze in-app messages to identify potential fraud (e.g., users trying to bypass the platform for off-site payments) or inappropriate content.
• Methods: We use automated methods where possible. Manual review is only conducted for specific investigations or support tickets.
• Safety: We scan uploaded images for illegal content (such as evidence of exploitation) and will report violations to the National Information Technology Center (NITC) or Nepal Police.

4.7 Provide Payment Services

Personal information is used to enable secure financial transactions via eSewa or Bank Transfers to:

• Verify your identity before processing large rent payments.
• Detect and prevent money laundering, fraud, and security incidents.
• Comply with Anti-Money Laundering (AML) regulations in Nepal.
• Conduct collection activities if a payment is disputed.

5. WHO WE DISCLOSE PERSONAL INFORMATION TO

To facilitate a seamless rental experience and ensure the safety of our community, we may disclose your personal information to the following parties:

5.1 Other Members (Tenants and Hosts)

To enable the booking process and interactions between members, we disclose information as follows:

• Booking Requests: When a Tenant requests a booking, certain information is shared with the Host, including their profile, review history, and "Identity Verified" status.
• Confirmed Bookings: Once a booking is confirmed, Vasuko discloses additional information to both parties, such as full legal names and mobile numbers, to coordinate the move-in and stay.
• Host Information: When a Host creates a listing, certain information is public, such as the property location (approximate), room description, and Host profile.

5.2 Members’ Vendors or Partners

Hosts may use third-party services to manage their properties (e.g., cleaning services, security guards, or property managers). Hosts may use Vasuko features to share Guest contact information with these authorized assistants. Please note that these third-party services are outside of Vasuko’s direct control and are subject to their own privacy policies.

5.3 Building, Ward, and Community Management

We may disclose personal information of Hosts and Guests to Building Owners, Homeowners' Associations (Tole Sudhar Samitis), or local Ward Offices to ensure compliance with local rental laws, security protocols, and tax regulations. This may include guest identity information required for local resident registries.

5.4 Business and Enterprise Partners

If a booking is made for professional or corporate purposes (e.g., a company renting a flat for its employees), we may disclose booking-related information to the affiliated Enterprise to the extent necessary for contract performance and reporting.

5.5 Professional Service Providers (Vendors)

We share personal information with affiliated and unaffiliated vendors to help us run our business. These providers are contractually bound to protect your data under the Privacy Act, 2075. They assist us in:

• Identity Verification: Authenticating your Nagarikta/Passport via specialized verification tools.
• Fraud Prevention: Checking information against public databases and conducting risk assessments.
• Technical Infrastructure: Providing cloud hosting and maintenance via Google Cloud Platform (GCP) and Firebase.
• Payment Processing: Facilitating secure transactions through partners like eSewa or commercial banks.
• Communications: Sending SMS alerts and emails through third-party delivery services.

5.6 Events and Promotions Providers

If you participate in a Vasuko-sponsored event or contest, we may share your information with event organizers or partners to facilitate your participation (e.g., issuing entry passes or prizes).

5.7 Corporate Affiliates

As Vasuko grows, we may share personal information within our corporate family of companies to improve our integrated services. Even if your data is processed by an affiliate, it remains protected under the high standards of this policy.

5.8 Legal and Governmental Authorities

We may disclose your personal information to the Nepal Police, Department of IT, or Tax Authorities if we believe such disclosure is reasonably necessary to:

• Comply with a valid legal request (e.g., a court order or warrant).
• Protect the safety and rights of Vasuko, our members, or the public.
• Prevent or address fraud, security, or technical issues.

6. WHY WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your personal information for the following specific purposes:

6.1 Acting with Your Consent or at Your Direction

Where you provide explicit consent or direct us to share your information, we do so as described at the time of consent. This includes:

• Authorizing a third-party website or app to access your Vasuko account.
• Applying for rent-financing or installment payment products via partner banks/wallets.
• Participating in promotional activities managed by Vasuko’s commercial partners.

6.2 Building Your Public Profile and Listings

To help you connect with others, certain information is made visible to the public:

• Public Profile: Your first name, profile photo, and "Verified" status.
• Listing Pages: Approximate location of the room, calendar availability, room photos, and your public description of the property.
• Public Feedback: Reviews, ratings, and feedback left by previous Tenants or Hosts.
• Search Engine Indexing: Information you choose to make public on the Platform may be indexed by search engines (like Google). You can control this via your account privacy settings.

6.3 Complying with Law and Preventing Harm

In accordance with the Civil Code of Nepal and the Electronic Transactions Act, we may disclose your information to courts, law enforcement, or tax authorities if we believe it is reasonably necessary to:

• 6.3.1 Legal Requests: Comply with a subpoena, court order, or a valid legal request from the Nepal Police relating to a criminal investigation (e.g., unauthorized or illegal rental activities).
• 6.3.2 To Tax Authorities: Disclose Host and Tenant information to the Inland Revenue Department (IRD) to determine compliance with rental tax (House Rent Tax) and TDS obligations.
• 6.3.3 To Local Government Units: In municipalities where Vasuko facilitates registration, we may share Host contact details and registration numbers with the relevant Ward Office or Municipality authorities.
• 6.3.4 Emergency Situations: Disclose information where there is an urgent risk of death, serious physical harm, or a threat to public safety.
• 6.3.5 Notification: We will notify you about legal requests for your data unless prohibited by a court order, or if we believe notification would create a risk of injury or increase the risk of fraud.

6.4 Effectuating Business Transactions

If Vasuko App Solutions Pvt. Ltd. is involved in a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred as part of that transaction. In such a case, we will notify you via the app or email before your data becomes subject to a different privacy policy.

7. THIRD-PARTY PARTNERS AND INTEGRATIONS

7.1 Linking Third-Party Services

You may choose to link your Vasuko account with third-party services, such as social networks (Google) or smart-home providers. When you authorize this data sharing:

• Profile Syncing: Information provided to us from the linked account (such as your profile picture or verified email) may be used to populate your Vasuko public profile.
• Security & Risk Assessment: Data from linked accounts may be processed to enhance our fraud prevention measures and verify that the user is a real person.
• User Control: The publication and display of information sourced from third-party links are subject to your specific privacy settings both on the Vasuko Platform and the third-party service.

7.2 Third-Party Service Terms

The Vasuko Platform integrates various professional APIs and services. Vasuko does not own or control these third parties. When you interact with them, you are providing your personal information directly to them, subject to their respective privacy policies.

Key integrations include:

• 7.2.1 Google Maps Platform: We use Google Maps to show room locations and provide "Near Me" search functionality. Your use of these features is subject to the Google Maps/Google Earth Additional Terms of Service and the Google Privacy Policy.
• 7.2.2 Firebase (by Google): We use Firebase for critical infrastructure, including:
  • Authentication: To manage secure logins and OTPs.
  • Analytics & Crashlytics: To monitor app performance and identify bugs.
  • Cloud Messaging: To send you real-time booking notifications. Data processed by Firebase is handled according to the Firebase Privacy and Security Terms.
• 7.2.3 Payment Gateways (eSewa): To facilitate secure rent payments in Nepal, we integrate with licensed Payment Service Providers.
  • When you initiate a payment, you are redirected to the secure environment of eSewa.
  • Vasuko does not store your payment PINs or passwords. Your data is handled under the eSewa Privacy Policy.
• 7.2.4 Background Screening Partners: Where offered and with your explicit consent, we may use third-party services to obtain police clearance reports or verify professional licenses to maintain the safety of the Vasuko community.

11. SECURITY AND PRIVACY-ENHANCING TECHNOLOGIES

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your personal information against unlawful or unauthorized access, loss, destruction, or alteration.

When we use personal information to develop and improve our Platform’s AI and recommendation engines, we take appropriate measures to safeguard your privacy. This includes:

• De-identification: Removing references to your name and specific identifiers prior to model training.
• Encryption: Using industry-standard protocols (AES-256 and TLS 1.3) for data at rest and in transit.
• Pseudonymization: Replacing private identifiers with artificial identifiers to reduce the risk of re-identification.
• Restricted Access: Limiting access to sensitive data to a small number of authorized Vasuko personnel subject to strict confidentiality obligations.

12. CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time in accordance with the laws of Nepal. If we do so, we will post the revised Privacy Policy on the Platform and update the “Last Updated” date at the top.

In the case of material changes (changes that significantly affect your rights), we will provide you with notice by email or a prominent in-app notification at least thirty (30) days before the effective date. If you disagree with the revised Privacy Policy, you may cancel your Account. Continued use of the Vasuko Platform after the effective date will constitute your acceptance of the revised policy.

13. CONTACT INFORMATION

For any questions regarding this Privacy Policy or to exercise your data rights (Access, Correction, or Deletion), please contact: