Overview & Acceptance
This Privacy Policy describes how Delwar Enterprise (“Service Provider,” “we,” “us,” or “our”) collects, uses, stores, discloses, and protects information in connection with the Subheccha mobile application and any associated services (collectively, the “Application”).
By downloading, accessing, or using the Application, you acknowledge that you have read and understood this Privacy Policy. Where applicable law requires consent for specific data processing activities, we will obtain your consent before carrying out those activities.
1. Information We Collect
When you download, install, or use the Application, certain information may be collected automatically or provided directly by you.
1.1 Automatically Collected Information
Depending on your device settings, Application functionality, and applicable permissions, we may collect technical and usage-related information, including:
- Internet Protocol (IP) address of your device.
- Device identifiers and technical information necessary for application functionality.
- Mobile operating system and version.
- Application version and device configuration information.
- Pages, screens, and features accessed within the Application.
- Date, time, and duration of Application usage.
- Interaction patterns and diagnostic information relating to application performance.
1.2 Information You Provide
Certain features may require you to voluntarily provide information, including information submitted through forms, support requests, or other interactive features.
We will process such information only for the purposes described in this Privacy Policy or otherwise disclosed to you at the time of collection.
We do not intentionally request information that is unnecessary for the operation of the relevant feature.
2. How We Use Your Information
Information collected through the Application may be used for the following purposes:
- To provide, operate, and maintain Application functionality.
- To improve application performance, reliability, usability, and user experience.
- To identify, investigate, and resolve technical issues.
- To monitor application usage and understand feature engagement.
- To respond to user inquiries, support requests, and complaints.
- To communicate important service announcements, policy updates, and legally required notices.
- To protect the Application against unauthorized access, misuse, fraud, and security threats.
- To comply with applicable legal obligations and enforce our legitimate rights.
Where permitted by applicable law, we may also use voluntarily provided contact information to communicate relevant product updates or promotional information. You may opt out of promotional communications at any time.
We will not use personal information for purposes materially different from those described here without providing appropriate notice and obtaining consent where legally required.
3. Cookies and Similar Technologies
The Application or its authorized third-party service providers may use cookies, software development kits (SDKs), pixels, device identifiers, and similar technologies to support application functionality, analytics, diagnostics, and service delivery.
These technologies may help us:
- Maintain essential application functionality.
- Understand application usage and performance.
- Identify technical errors and improve stability.
- Evaluate the effectiveness of application features.
Where applicable law requires consent for non-essential cookies or tracking technologies, we will obtain consent before activating them.
You may be able to manage certain tracking preferences through your device settings or available application controls. Disabling certain technologies may affect the availability or performance of some features.
4. Third-Party Services and Data Sharing
We may engage trusted third-party service providers to support application operations, analytics, technical maintenance, security, and related services.
Where information is shared with such providers, we require them, where contractually and legally appropriate, to:
- Process information only for authorized purposes.
- Apply reasonable confidentiality and security measures.
- Refrain from using disclosed information for unrelated independent purposes.
- Comply with applicable data protection obligations.
Where permitted by applicable law, we may share aggregated or anonymized information that does not reasonably identify individual users to evaluate application performance, improve services, and conduct internal analysis.
We do not authorize third-party service providers to independently exploit personal information entrusted to them for purposes unrelated to their contracted services.
4.1 Legal Disclosures
We may disclose information where reasonably necessary:
- To comply with applicable laws, regulations, court orders, subpoenas, or other lawful governmental requests.
- To protect the rights, property, safety, or security of the Service Provider, Application users, or other individuals.
- To investigate suspected fraud, unauthorized activity, security incidents, or violations of applicable terms.
- To enforce our legal rights or respond to legal proceedings.
Any disclosure will be limited to what is reasonably necessary and legally permitted.
5. International Data Transfers
Information processed by the Service Provider or its authorized service providers may be stored or processed in countries outside your country of residence, including countries outside the European Economic Area (EEA).
Because data protection laws may differ between jurisdictions, we will implement appropriate safeguards for international transfers where required by applicable law.
Depending on the circumstances, such safeguards may include:
- Standard Contractual Clauses approved by the European Commission.
- Applicable adequacy decisions.
- Other legally recognized transfer mechanisms.
- Explicit consent, where required and legally permitted.
We will take reasonable steps to ensure that personal information transferred internationally receives an appropriate level of protection consistent with applicable legal requirements.
6. Data Retention
We retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce applicable agreements.
Unless a longer retention period is required or permitted by law, the following retention periods apply:
| Information Category | Retention Period |
|---|---|
| User-provided information | Duration of Application use and up to 12 months thereafter |
| Automatically collected information | Up to 24 months from collection |
| Aggregated and anonymized information | May be retained indefinitely, provided it cannot reasonably identify individuals |
| Information required for legal compliance | As required by applicable law |
When information is no longer necessary, we will take reasonable steps to securely delete, anonymize, or otherwise dispose of it.
You may request deletion of your personal information by contacting us at delwarenterprise50@gmail.com. Certain information may need to be retained where required by law or necessary for legitimate legal purposes.
7. Your Privacy Rights
Depending on your location and applicable data protection laws, you may have the right to:
- Request confirmation of whether we process your personal information.
- Access personal information held about you.
- Request correction of inaccurate or incomplete information.
- Request deletion of personal information.
- Object to or restrict certain processing activities.
- Withdraw consent where processing is based on consent.
- Request a copy of eligible information in a portable format.
- Lodge a complaint with an applicable data protection authority.
To exercise any applicable rights, contact us at delwarenterprise50@gmail.com.
We may request reasonable information to verify your identity before processing a request. We will respond within the timeframe required by applicable law.
Exercising your privacy rights will not result in unlawful discrimination or retaliation.
8. California Privacy Rights (CCPA/CPRA)
If you are a California resident and the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), applies to our processing of your information, you may have the following rights:
To submit a privacy request, contact delwarenterprise50@gmail.com.
We will verify requests as required by law and respond within applicable statutory deadlines.
Where legally required, we will provide an accessible method for submitting opt-out requests and honor applicable preference signals.
9. Opt-Out and Withdrawal of Consent
You may stop further collection of information through the Application by uninstalling it from your device.
Uninstalling the Application does not automatically delete information previously transmitted to the Service Provider or authorized third parties.
Where processing is based on consent, you may withdraw that consent at any time by contacting us or using available application controls.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal or processing conducted under another applicable lawful basis.
To request deletion of previously collected information, contact delwarenterprise50@gmail.com.
10. Children's Privacy
The Application is not intended for children under 16 years of age, or any higher minimum age established by applicable law.
We do not knowingly solicit or collect personal information from children in violation of applicable children's privacy laws.
We encourage parents and legal guardians to supervise children's use of mobile applications and to educate them about the importance of protecting personal information online.
If we become aware that personal information has been collected from a child in circumstances where such collection is prohibited or requires parental consent that has not been obtained, we will take appropriate steps to delete the information or obtain the required consent, as applicable.
Parents or legal guardians who believe that a child has provided personal information through the Application may contact us at delwarenterprise50@gmail.com.
Where parental or guardian consent is legally required, we will obtain such consent before processing the relevant information.
11. Information Security
We recognize the importance of protecting personal information against unauthorized access, disclosure, alteration, loss, or destruction.
We implement reasonable administrative, technical, physical, and organizational safeguards designed to protect information processed and maintained by the Service Provider.
These safeguards may include access restrictions, confidentiality obligations, security monitoring, and appropriate data-handling procedures.
However, no electronic transmission, storage system, or security mechanism can be guaranteed to be completely secure. Accordingly, while we take reasonable measures to protect information, we cannot guarantee absolute security.
12. Data Breach Notification
In the event of a personal data breach affecting information processed by the Service Provider, we will investigate the incident and take reasonable steps to contain, mitigate, and remediate its effects.
Where notification is required by applicable law, we will notify affected individuals and relevant regulatory authorities within the legally prescribed timeframe.
Such notification may include information about the nature of the incident, potentially affected information, mitigation measures, and recommended protective actions.
13. Third-Party Websites and Services
The Application may contain links to external websites, platforms, or services operated by third parties.
Those external services maintain their own privacy policies and data-handling practices. The Service Provider does not control their independent operations and encourages users to review the applicable privacy policies before providing personal information.
This Privacy Policy applies only to the Subheccha Application and services operated by Delwar Enterprise.
14. Changes to This Privacy Policy
We reserve the right to revise this Privacy Policy periodically to reflect changes in application functionality, operational practices, legal requirements, or data protection standards.
When material changes are made, we will publish the revised policy and update its effective date.
Where required by applicable law, we will provide additional notice or obtain consent before implementing changes that materially affect the processing of personal information.
Previous versions of this Privacy Policy may be requested by contacting delwarenterprise50@gmail.com.
Continued use of the Application following publication of an updated policy constitutes acknowledgment of the revised policy, except where affirmative consent is legally required.
15. Your Consent
Where consent is the applicable legal basis for processing personal information, consent will be obtained through an affirmative action, such as enabling a relevant feature, selecting an appropriate option, or otherwise expressly agreeing to the specified processing activity.
You may withdraw consent at any time, subject to applicable legal requirements.
Withdrawal will not affect processing lawfully performed before consent was withdrawn.
Where processing relies on another lawful basis, such processing will be conducted in accordance with applicable data protection laws and the purposes described in this Privacy Policy.
16. Contact Information
If you have questions, concerns, requests, or complaints regarding this Privacy Policy or the handling of your personal information, you may contact the Service Provider using the details below.
We will make reasonable efforts to review and respond to privacy-related inquiries within a reasonable period and in accordance with applicable legal requirements.
This Privacy Policy is intended to provide transparency regarding information handling practices associated with the Application. It should be interpreted in accordance with applicable data protection and privacy laws.