PRIVACY POLICY

1. Introduction

BLINKMARKETPLACE LIMITED (“Blink Marketplace”, “Blink”, “we”, “our”, or “us”) is a digital infrastructure platform for high-value asset exchange operating within Nigeria.

Blink Marketplace facilitates the listing, auctioning, direct purchase, inspection coordination, verification, payment processing, fulfilment coordination, and transfer documentation of eligible assets and products across supported categories including but not limited to:

• Automotive assets
• Machinery and industrial equipment
• Real estate and land
• Agricultural produce
• Collectibles and luxury assets
• Distressed and recovery assets

The Platform also supports affiliate streamer participation, auction room management, automated bidding systems, inspection coordination, fulfilment operations, payment infrastructure integrations, and dispute resolution workflows.

We respect your privacy and are committed to protecting the privacy, confidentiality, and lawful processing of personal data entrusted to us by users, brands, streamers, inspection agents, logistics partners, and other stakeholders interacting with the Platform. This privacy policy will inform you as to how we look after your personal data when you visit our website or use our application and tell you about your privacy rights and how the law protects you.

By accessing or using Blink Marketplace, you acknowledge that you have read, understood, and agreed to this Privacy Policy.

2. Definitions

For the purpose of this Privacy Policy:

• “Platform” refers to Blink Marketplace’s website, mobile applications, systems, auction infrastructure, fulfilment systems, APIs, communication systems, and associated services.
• “User” refers to any individual accessing or interacting with the Platform.
• “Brand” refers to any verified business, seller, company, or merchant authorized to list products or assets on the Platform.
• “Streamer” refers to any approved affiliate creator or presenter authorized to create auction rooms, promote products, or facilitate auction sessions on behalf of brands.
• “Buyer” refers to any user participating in bids, purchases, auctions, or transactions on the Platform.
• “Inspection Agent” refers to any individual or representative assigned by Blink Marketplace or its partners to facilitate physical inspections, verification activities, fulfilment checks, or transaction coordination.
• “Auction Room” refers to any public or private auction session created on the Platform for the listing, bidding, promotion, or sale of assets.
• “Prestige Deposit” refers to the mandatory qualifying wallet balance required for users to participate in certain auctions or bidding activities.
• “Personal Data” refers to any information capable of identifying an individual directly or indirectly.

3. Scope of This Policy

This Privacy Policy applies to:

• Buyers and general users
• Brands and businesses
• Streamers and affiliate creators
• Inspection agents and fulfilment personnel
• Auction participants
• Visitors to our website and applications
• Individuals communicating with Blink Marketplace

This Policy applies to all supported Platform features including:

• Auction rooms and bidding systems
• Buy-now transactions
• Wallet funding and payment processing
• Inspection coordination
• Fulfilment and logistics coordination
• Asset verification systems
• Streamer onboarding
• Brand onboarding
• AI-assisted bidding systems
• Customer support interactions
• Legal and compliance processes

4. Information We Collect

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

A. Information You Provide Directly

B. Information Collected Automatically

We may automatically collect:

• Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, device identifiers, operating system information, app version, and login activities.
• Usage Data: includes platform usage patterns, auction engagement data, session duration, performance analytics, clickstream data, and approximate geolocation information.

5. Biometric / Facial Verification

To verify the identity of sellers and brands on the Blink platform, we use a third-party identity verification provider, Smile Identity (https://usesmileid.com). During the verification process, users may be asked to capture a selfie using their device’s camera.

On supported iOS devices, the Smile Identity SDK may use Apple’s TrueDepth camera system through ARKit to capture 3D facial orientation and facial expression data in order to perform liveness detection and confirm that the selfie is being taken by a real person.

The ARKit facial orientation and expression data used for liveness detection is processed locally on the user’s device and is not transmitted to Blink or any third party.

The captured selfie image used for identity verification is securely transmitted to Smile Identity for KYC verification. Blink does not store or retain facial biometric data on its own servers. Identity verification may be facilitated through trusted third-party providers including Smile Identity and other licensed verification providers. Blink Marketplace does not store raw biometric facial mapping data generated by device-level verification systems.

Facial verification is used solely to confirm the identity of sellers and brands, prevent fraud, and comply with regulatory KYC requirements. Blink does not use facial data for advertising, analytics, or profiling.

6. How We Use Your Information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following purposes:

A. Platform Operations

• To register you as a new customer (Buyer, Brand, or Streamer) and manage accounts.
• Operating auction systems and enabling you to partake in auctions and live streams.
• Facilitating transactions and managing auction rooms.
• Coordinating fulfilment activities, supporting inspections, and verification processes.

B. Payments, Wallets & Escrow

• Processing wallet funding and verifying Prestige Deposit qualification.
• Managing escrow workflows and processing payouts, fees, charges, refunds, and reversals.
• Managing transaction reconciliation.

C. Verification, Security & Compliance

• Identity verification and fraud prevention.
• AML (Anti-Money Laundering) and SCUML compliance processes.
• Transaction monitoring, risk assessment, and detecting suspicious activities.
• Enforcing Platform rules.

D. Auction Integrity & Automated Systems

Blink Marketplace may utilize automated systems and AI-assisted infrastructure to support:

• Auto-bidding systems and auction fairness monitoring.
• Bid integrity analysis and fraud detection.
• Suspicious bidding detection and behavioral analysis for auction security.

Automated Processing & Proxy Bidding Integrity: Where users configure automated proxy bidding parameters, processing occurs automatically via persistent background systems based on user-defined limits. Users retain control over these parameters and may modify or revoke auto-bid allocations at any time prior to auction finalization. These automated processes are strictly optimized to enforce platform security, prevent transaction latency, and ensure bid transparency.

E. Customer Support & Dispute Resolution

• Resolving disputes, investigating complaints, and reviewing inspection evidence.
• Processing settlement workflows and managing policy violations.

F. Communications

• To manage our relationship with you including notifying you about changes to our terms or privacy policy.
• To improve our website, products/services, marketing, and customer relationships.
• Sending transaction notifications, auction reminders, verification alerts, platform updates, security notifications, and administrative communications.

7. Payment Infrastructure & Financial Processing

Blink Marketplace utilizes regulated third-party financial infrastructure providers, payment processors, banking partners, and wallet service providers for payment processing and transaction infrastructure.

Users may be assigned dedicated virtual account numbers for wallet funding and transaction processing. Payment processing and wallet infrastructure services may be provided by regulated third-party payment providers including Paystack and associated banking infrastructure partners.

Blink Marketplace may receive transaction confirmations, settlement information, reconciliation data, and related payment records necessary to operate the Platform. Financial processing may involve integrations with:

• Paystack
• Licensed banking institutions
• Compliance providers
• Settlement infrastructure providers

8. Sharing of Information

We may share information where reasonably necessary with:

• Payment processors and banking partners
• Verification providers
• Law firms and legal partners
• Inspection agents, logistics, and fulfilment partners
• Regulatory authorities
• Fraud prevention providers
• Technology infrastructure providers
• Professional advisers

Information may also be disclosed where required by law, regulatory obligations, lawful requests, or court orders.

9. Data Retention

Blink Marketplace retains personal data only for as long as reasonably necessary to operate the Platform, complete transactions, maintain audit records, resolve disputes, comply with legal obligations, enforce agreements, and prevent fraud and abuse.

Auction activity logs, inspection records, transaction histories, and compliance records may be retained beyond room expiration or content deletion periods where required for legal, operational, or security purposes.

10. Security of Information

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

Blink Marketplace implements commercially reasonable administrative, technical, and organizational safeguards including:

• Encryption technologies
• Access controls and role-based permissions
• Audit logging and secure infrastructure practices
• Fraud monitoring systems and authentication protections
• Internal compliance controls

However, no platform or transmission method can be guaranteed to be completely secure.

11. User Rights & Statutory Compliance

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Subject to applicable law, users may have rights to:

• Access personal data and request information regarding stored data
• Correct inaccurate or incomplete information
• Request deletion of eligible data
• Withdraw consent where applicable
• Object to or request restriction of certain processing activities

All data collection and processing operations described under this Policy are performed in strict compliance with the Nigeria Data Protection Act (NDPA) 2023 and any subsidiary guidelines issued by the Nigeria Data Protection Commission (NDPC). Users maintain the right to lodge complaints directly with the supervisory regulatory authority if they believe their statutory data rights have been infringed.

12. Account Deletion & Restrictions

Users may directly initiate an account deletion request at any time natively through the User dashboard panel within the Blink mobile application.

Please note that account deletion requests are processed programmatically and final approval is bound by system-wide marketplace safety rules. To protect transaction counterparties and preserve high-value asset escrow security, the platform will automatically evaluate your account for active liabilities. If your profile contains pending transactions, unfulfilled purchases, active live-bidding entries, outstanding physical inspections, or unresolved dispute workflows, your deletion request will remain in a pending state and approval will be deferred until all obligations are thoroughly resolved and legally closed.

Certain transaction, compliance, legal, inspection, payment, audit, and dispute-related records may continue to be retained following an approved account deletion where required by law, regulatory obligations, fraud prevention requirements, or operational necessity.

13. Children & Age Restrictions

Transactional participation on Blink Marketplace is intended only for individuals legally capable of entering binding agreements under applicable laws.

Users under the age of 18 may not create seller, streamer, or brand accounts or participate in regulated financial or auction activities requiring legal contractual capacity.

Blink Marketplace does not knowingly collect personal information from children in violation of applicable laws.

14. International Access

Blink Marketplace currently operates primarily within Nigeria and supports transactions involving Nigerian-based buyers and brands with operational presence in Nigeria.

Cross-border access may be restricted or subject to additional verification requirements.

15. Third-Party Services

The Platform may integrate or interact with third-party systems including:

• Payment processors
• Logistics providers
• Verification providers
• Communication systems
• Cloud infrastructure providers

Blink Marketplace is not responsible for the independent privacy practices of third-party platforms or services.

16. Changes to This Policy

Blink Marketplace reserves the right to update or modify this Privacy Policy at any time. Updated versions may be communicated through:

• Platform notifications
• Email communications
• Website announcements
• Application updates

Continued use of the Platform following updates constitutes acceptance of the revised Privacy Policy.

17. Contact Information

If you have any questions about this privacy policy or our privacy practices, please contact us at: