Privacy Notice
This notice explains what personal information HBC collects, why, who processes it, how long it is kept and what you can ask us to do. It is written under the Privacy Act 2075 and the Electronic Transactions Act 2063.
1. Who is responsible
2. What we collect and why
| Information | Collected when | Used for | Legal basis |
|---|---|---|---|
| Name, email, mobile number, address, membership number | Registration, guest purchase, in store | Your account, receipts and documents, transactional messages | Contract |
| PAN | Before first purchase | Tax records, PAN bills, anti-money-laundering identification | Legal obligation |
| Government photo ID (image or PDF), business registration, beneficial-owner details | KYC, in app or in store | Identity verification required by anti-money-laundering law | Legal obligation |
| Payments, orders, plans, custody, buy-backs, gifts, Credits | Each transaction | Performing the contract, accounting, ownership records | Contract; legal obligation |
| Receipts, PAN bills, certificates, settlement documents | Each transaction | Permanent records of what HBC sold and holds for you | Legal obligation |
| Device sign-in key or passkey (public key only) | If you enable it | Confirming it is you when spending Credits or selling to HBC | Consent |
| Push-notification token (stored encrypted) | If you enable notifications | Transactional and, if you opt in, marketing messages | Consent |
| Support emails and HBC AI chat messages, including screenshots you send | When you contact us | Answering you; keeping a record of the matter | Contract |
| App crash reports (no personal content), web page analytics (page, IP, browser) | Using the app or web | Keeping the service working | Legitimate operation |
| Audit log of who did what, including IP address | Every action | Security and attribution | Legitimate operation; legal obligation |
| Wallet pass data (name, membership number, tier) | If you add the membership card to Apple or Google Wallet | Showing your card | Consent |
We do not collect biometric data; your face or fingerprint never leaves your device. Beyond what appears on the identity document you provide, we do not collect date of birth, nationality or occupation unless the law requires it.
3. Who processes it
HBC uses service providers to run the app and its systems. Each processes only what its service needs, under contract with HBC, and may not use your data for its own purposes. The categories are:
| Category of provider | Data processed |
|---|---|
| Cloud database, hosting and authentication | Account and transaction data |
| Payment gateway (Nepal Payment Solutions, HBC's official payment partner) | Amount, membership number, payment reference |
| Transactional email and push-notification delivery | Email address, device token, documents sent to you |
| AI language-model service for the HBC AI assistant and support inbox | Your messages, screenshots you send, and the account facts needed to answer (orders, plans, Credits, KYC status). Never your ID images, PAN or phone number. |
| Crash reporting and web analytics | Scrubbed error data, device model, page visited, IP address |
| Apple and Google | Wallet passes and push delivery, where you enable them |
| Market-chart provider | Your IP address and browser when the chart loads |
| Insurer | Product and claim details, and your name where a claim is made |
Some providers are outside Nepal. Your data is transferred to them for the purposes above and protected by contract. By using the app you consent to these transfers; if you do not, you may transact in store. A current list of named providers is available on request from info@himalayanbullion.com.
4. Who else may receive it
- Regulators and law enforcement: HBC discloses information to the Financial Information Unit, the Inland Revenue Department, courts and law-enforcement agencies where the law requires, without notice to you where the law prohibits notice.
- Auditors: HBC's statutory auditors see transaction records.
- No one else. HBC does not sell, rent or share your data for marketing.
5. HBC AI and automated assistance
5.1The HBC AI assistant in the app and the assistant that answers support emails use a third-party large-language-model service. They answer from HBC's published policies and your account facts. They do not see your ID images, PAN or phone number. A human reviews any matter the assistant cannot resolve. You may ask for a human at any time.
5.2No decision about your account, KYC or a transaction is made by automated means alone.
6. How long we keep it
| Category | Retention |
|---|---|
| Transaction, ownership, payment and document records | For as long as the law requires HBC to keep its financial and ownership records, and in any case while you own silver or products recorded with HBC |
| KYC records | At least five years after the relationship ends, as anti-money-laundering law requires, then deleted |
| Support emails and HBC AI chat | Chats 90 days; email and ticket summaries 3 years |
| Audit log | 7 years |
| Crash and analytics data | Provider default, not more than 2 years |
| Marketing preferences and push tokens | Until withdrawn or account deleted |
7. Your rights
You may at any time:
- see the personal information HBC holds about you (statement within 15 days);
- correct it in the app or by writing to us;
- withdraw consent to notifications, marketing or device sign-in, in the app;
- object to processing that is not required by contract or law;
- delete your account (section 8).
Write to info@himalayanbullion.com. HBC answers within fifteen days.
8. Deleting your account
8.1Ask in the app (More → Account → Delete my account) or at member.himalayanbullion.com/delete. HBC confirms your identity, then deletes your sign-in, sessions, device keys, notification tokens, preferences and unfinished checkouts within 30 days.
8.2An account with a product in custody, an open plan, unused Credits, an open complaint or a pending gift cannot be deleted until those are resolved. HBC tells you what is outstanding.
8.3HBC keeps, in restricted storage, what the law requires it to keep: transaction, ownership and document records, KYC records for the statutory period, and your name, PAN and contact details attached to them. These are not used for any other purpose and are deleted when the legal retention period ends.
9. Security
9.1Access to your data is controlled per staff role. ID documents are held in restricted storage with every access logged. Financial records cannot be altered once written; a correction is a new record. HBC keeps encrypted backups.
9.2If a breach affects your data, HBC tells you and the relevant authority without undue delay, and tells you what to do.
10. Marketing
10.1HBC sends transactional messages (receipts, readiness notices, custody reminders) because the contract requires them. HBC sends rate alerts only if you set them. HBC sends marketing or broadcast messages only if you opt in, and you may opt out in the app at any time.
11. Children
11.1HBC's services are for adults. HBC does not knowingly collect data from anyone under 18 and deletes it if found.
12. The public bar verification page
12.1Every HBC bar carries a verification link. The page confirms the bar is genuine and whether it is in HBC custody. It shows no name, membership number, price or location. It verifies the product, not who owns it.
13. Changes
13.1HBC publishes a new version when this notice changes, with notice in the app. Every version is in the Version History.