BLINKMARKETPLACE LIMITED

1. Introduction

BLINKMARKETPLACE LIMITED ("Blink Marketplace", "Blink", "we", "our", or "us") operates a private, curated marketplace connecting eligible collectors around the world with reputable African galleries, professional dealers, and other approved consignors offering exceptional and collectible objects.

Blink supports the presentation and discovery of objects, collector account review, access to Private Offer Rooms, private offers, seller decisions, transaction communications, and—where available—payment, documentation, collection, and delivery coordination. Categories may include fine art, historic artifacts, memorabilia and historical documents, luxury accessories and timepieces, vintage and classic automobiles, and fine wine or rare spirits where lawful.

Blink is designed around considered private offers rather than public bidding competitions. A gallery or consignor may review an offer together with relevant information about the collector before deciding whether to accept it. Blink does not require a deposit simply to submit a private offer.

This Privacy Policy explains how we collect, use, disclose, retain, and protect personal information when you visit our website, use our mobile application or other services, request access to a Private Offer Room, make or receive an offer, apply for a partnership, or contact us.

Please read this Policy together with any notices presented when you use a specific feature. Where consent is the appropriate legal basis for a particular activity, we will request it as required by applicable law. This Policy does not remove any rights you may have under applicable data protection law.

BLINKMARKETPLACE LIMITED determines how personal information is processed for the Blink services it operates, subject to the role of any independent gallery, consignor, payment provider, identity verification provider, or other third party involved in a particular activity. A separate notice or agreement may apply where a third party independently determines how it uses information or where a specific transaction requires additional terms.

2. Definitions

• "Platform" means Blink's website, mobile application, Private Offer Rooms, account features, and related services.
• "Collector" means an individual or representative using Blink to discover objects or submit private offers.
• "Consignor" means an approved gallery, professional dealer, reputable organization, or authorized representative offering an object through Blink.
• "Private Offer Room" means a space in which eligible collectors can review one or more objects and submit private offers where the room permits it.
• "Personal information" means information relating to an identified or identifiable person, as defined by applicable law.
• "Blink Concierge" means the client support service that may assist with transaction steps, documentation, collection, or delivery arrangements.
• "Service providers" means third parties that help us operate the Platform or deliver requested services, such as identity verification, hosting, communications, payment processing, or logistics providers.
• "Processing" includes collecting, recording, organizing, storing, using, disclosing, transferring, restricting, or deleting personal information.
• "Collector standing" means relevant profile or participation information that Blink makes available to a gallery or consignor to help it consider an offer; it does not mean that an offer must be accepted.

3. Scope of This Policy

This Policy applies, as relevant, to:

• Collectors and people applying for collector access;
• Galleries, professional dealers, consignors, and their authorized representatives;
• People who request or receive access to Private Offer Rooms;
• People who submit offers or take part in a transaction;
• People who contact Blink Support or Blink Concierge;
• Visitors to Blink's websites and other digital services; and
• Prospective gallery or commercial partners.

It covers relevant activities such as:

• Account registration and collector review;
• Collection discovery, follows, invitations, and room-access requests;
• Private offers, seller decisions, and transaction records;
• Gallery and consignor onboarding and object presentation;
• Identity verification and fraud prevention where applied;
• Payment and settlement coordination after an offer is accepted;
• Questions, support requests, disputes, and delivery arrangements; and
• Platform security, maintenance, and legal compliance.

4. Information We Collect

The information we collect depends on how you use Blink, the choices you make, and the checks or services needed for the relevant activity. It may include the following categories.

A. Information You Provide

B. Information Collected Automatically

When you use the Platform, we and our service providers may collect technical and usage information, such as:

• Device and Log Data: device type, operating system, application or browser version, diagnostic information, log events, and security-related records.
• Usage Data: pages or features accessed, interactions with collections or rooms, timestamps, referral information, and performance or crash reports.
• Approximate Network Information: information such as an IP address that may be used for security, fraud prevention, diagnostics, and general service operation.

The information collected automatically depends on the device settings, Platform features used, and applicable permissions. We do not need every category of information for every user or transaction.

C. Information from Other Sources

Where relevant and lawful, we may receive limited information from a service provider or another participant in a Blink transaction. Examples include:

• Verification outcomes or reference numbers from an identity verification provider;
• Payment or settlement confirmations from a payment or banking provider, without necessarily receiving the full payment credentials held by that provider;
• Object descriptions, ownership or provenance materials, and transaction details supplied by a gallery, consignor, or authorized representative;
• Delivery status or service-related information supplied by a carrier or other transaction partner; and
• Information you have made available to us directly or through a channel you use to contact Blink.

We use information from other sources only where relevant to the purposes described in this Policy or another purpose permitted by applicable law. We may ask you to clarify information that appears inaccurate or inconsistent.

D. Device Permissions, Notifications, and Local Storage

Certain features may ask for access to device functions, such as the camera for a verification or content-submission flow, or notification permissions for service updates. You can manage device permissions through your device settings, although disabling a permission may prevent the related feature from working.

Where cookies, software development kits, local storage, or similar technologies are used on a website or in the app, they may support essential functions, security, preference retention, diagnostics, or analytics. Their use depends on the particular service and configuration. Where consent or another notice is required by law, we will provide the applicable choice or notice.

E. Information You Should Not Send

Unless a verified Blink process specifically asks for it, do not send account passwords, one-time login codes, complete payment-card credentials, banking passwords, or unrelated sensitive personal information in ordinary chat, email, or support messages. Use only the official in-app or provider-controlled verification and payment flows made available for the relevant transaction.

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 use personal information for purposes that are relevant to operating Blink and providing the services you request, including:

A. Accounts and Collector Access

• Creating and administering accounts;
• Reviewing collector applications and room-access requests;
• Managing invitations, follows, account preferences, and relevant notifications; and
• Helping maintain a trusted environment for galleries, consignors, and collectors.

B. Private Offers and Transactions

• Recording and communicating private offers and seller decisions;
• Providing the consignor or gallery with information relevant to considering an offer, which may include the collector's profile or standing on Blink;
• Communicating accepted-offer terms, payment instructions, and settlement status; and
• Maintaining records of transactions and responding to related questions or disputes.

C. Gallery and Object Presentation

• Onboarding and communicating with eligible galleries, dealers, organizations, and authorized consignors;
• Displaying object descriptions, images, provenance information, and other material they provide; and
• Helping respond to questions about objects and supporting relevant documentation or delivery arrangements.

D. Security and Compliance

• Conducting identity or account checks where required or appropriate;
• Detecting, investigating, and preventing fraud, misuse, unauthorized access, or unlawful activity;
• Protecting platform integrity and enforcing our Terms; and
• Meeting legal obligations and responding to lawful requests.

E. Support and Service Improvement

• Responding to questions, complaints, and support requests;
• Monitoring application reliability and fixing technical issues; and
• Sending service-related notices and, where permitted, optional updates about collections or Blink activities.

F. Lawful Bases for Processing

The lawful basis we rely on depends on the information and purpose. Where applicable, this may include:

• Contract or steps requested before a contract: creating and administering an account, responding to a request to access a room, recording an offer, or coordinating an accepted transaction;
• Legal obligation: retaining records or responding to a lawful request where the law requires us to do so;
• Legitimate interests: protecting accounts, preventing fraud, securing the Platform, maintaining reliable services, and managing or defending legal claims, where those interests are not overridden by your rights;
• Consent: where we ask you to agree to a particular use and consent is the appropriate basis, such as for certain optional communications or technologies; and
• Other lawful grounds: where another basis recognized by applicable law is appropriate for the circumstances.

Where we rely on consent, you may withdraw it for future processing. Withdrawal does not make earlier processing unlawful and does not affect processing that can continue on another valid legal basis. If information is needed to provide a feature or complete a transaction, not providing it may mean that we cannot provide that feature or proceed with the requested activity.

7. Offers, Payments, and Settlement

Blink facilitates private offers. A consignor or gallery may consider the offered amount together with relevant information about the collector and may accept, decline, or continue discussions. Blink does not automatically award an object to the highest offer.

No deposit is required merely to submit a private offer. If an offer is accepted, the information needed to complete the transaction may include the accepted amount, applicable currency, payment instructions, deadlines, fees, delivery arrangements, and records of settlement.

The currency applicable to an object is shown in its Private Offer Room or transaction details. NGN or USD may be available for applicable transactions. Do not assume a currency or payment method that is not displayed for the relevant transaction.

Blink may use third-party payment or banking providers where applicable. Those providers may process information under their own privacy notices and terms. Blink's role is limited to the functions it actually provides for the transaction; this Policy does not represent that Blink operates an escrow service or holds customer funds unless that is expressly stated in the relevant transaction terms.

A gallery or consignor considering an offer may receive the collector information Blink makes available for that purpose, which can include relevant profile or standing information. Other collectors are not generally shown one another's personal account information or private offers as a public contest. The information shown may vary with the room, feature, and applicable privacy settings.

Transaction communications may include the object, offer amount, applicable currency, accepted terms, and information necessary for settlement or delivery. We seek to limit access to information to the people and providers who need it for the relevant activity.

8. How We Share Information

We do not make collectors' personal information publicly available to other collectors as a general feature of the Platform. We may share relevant information with the following categories of recipients where reasonably necessary and permitted by law:

• Galleries and Consignors: information needed to review an offer, communicate about an object, or complete an accepted transaction. This may include the collector information Blink makes available for that purpose.
• Service Providers: providers supporting hosting, application infrastructure, communications, support, analytics or diagnostics, identity verification, payment processing, and other Platform operations.
• Delivery and Professional Partners: logistics providers, object-handling specialists, insurers, legal advisers, or other professionals where their involvement is needed for a requested transaction or service.
• Authorities and Other Parties: courts, regulators, law enforcement, or other parties where disclosure is required by law, needed to protect rights or safety, or appropriate to investigate suspected fraud or unlawful activity.
• Business Transfers: a prospective or actual successor or acquirer, subject to appropriate confidentiality and legal safeguards, if our business or relevant assets are reorganized, transferred, or sold.

We do not sell personal information as that phrase is commonly used to describe selling data to data brokers. If a specific activity requires consent or a separate notice under applicable law, we will provide it as required.

Where a provider processes information on Blink's instructions, we expect it to handle the information for the relevant service and under appropriate contractual and legal safeguards. Some providers, such as payment or identity verification services, may act as independent controllers for certain processing they perform under their own obligations; their own privacy notices may explain that processing.

We may also share information with professional advisers, insurers, or prospective business successors where reasonably necessary and lawful. We will not deliberately disclose more information than is reasonably relevant to the specific purpose, subject to legal requirements and legitimate transaction needs.

9. International Processing and Transfers

Blink is operated from Nigeria and may serve eligible collectors or business partners in other countries. Some service providers or transaction partners may process information outside the country where you are located.

Where personal information is transferred internationally, Blink will take steps required by applicable data protection law for the relevant transfer. The available safeguards may depend on the destination, the recipient, the type of information, and the service involved.

Depending on the circumstances, safeguards may include reviewing the recipient and destination, using contractual protections, limiting the information transferred, relying on a lawful transfer mechanism, or obtaining consent where legally appropriate. Cross-border processing may be needed to support hosting, identity checks, communications, payment, or delivery for an international transaction.

10. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including to provide the Platform, administer offers and transactions, respond to disputes, maintain appropriate business records, protect against fraud, and comply with legal obligations.

Retention periods depend on the type of information, the nature of the relationship, the status of a transaction, applicable limitation periods, and legal requirements. We do not promise to retain every record indefinitely. Where information is no longer needed and no lawful basis for retention remains, we will take appropriate steps to delete it, anonymize it, or otherwise handle it in accordance with applicable law.

Different categories may be retained for different periods. For example:

• Account and access records may be retained while an account is active and for a reasonable period afterwards for security and administration;
• Offer, accepted transaction, payment, delivery, complaint, and dispute records may be retained as needed to administer the transaction, comply with legal obligations, or establish or defend legal claims;
• Verification information may be retained by Blink or a verification provider according to the provider's role, the verification flow, applicable law, and relevant contractual arrangements; and
• Technical logs may be retained for a limited period appropriate to troubleshooting, security, and fraud prevention, unless a longer period is needed for a specific incident or legal obligation.

Back-up copies may persist for a limited time as part of normal security and recovery processes. If information is retained in a restricted archive, access and further use will remain limited to the purposes for which retention is justified.

11. Security of Information

We use reasonable technical, organizational, and access-control measures intended to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. Access is limited where appropriate to people and service providers who need information to perform relevant duties.

Depending on the system and activity, safeguards may include:

• Access controls and account protections;
• Secure communication and storage practices where supported;
• Monitoring and diagnostic processes to identify suspicious or faulty activity; and
• Confidentiality and service-provider controls where appropriate.

No internet service or electronic transmission can be guaranteed to be completely secure. You should use a strong, unique password, protect your login credentials, and notify us if you believe your account has been compromised.

No safeguard eliminates every risk. We review and adjust measures as appropriate to the nature of the information, the services we use, the risks identified, and available technology. You should avoid sending sensitive information over channels that have not been designated for it.

If we identify a personal data breach, we will assess it and notify the relevant authority or affected individuals where and to the extent required by applicable law. We may also take steps to contain the incident, investigate its cause, and reduce the risk of recurrence.

12. Your Privacy Rights

Subject to applicable law and any relevant limitations, you may have the right to:

• Request access to personal information we hold about you;
• Request correction of inaccurate or incomplete information;
• Request deletion or restriction of certain information;
• Object to, or request limits on, certain processing activities;
• Withdraw consent where processing relies on consent, without affecting processing that took place before withdrawal;
• Request a copy of certain information in a portable format where the law provides that right; and
• Complain to the relevant data protection authority.

To exercise a right, contact us using the details in Section 19. In your request, tell us how you use Blink, the account email or other detail that helps us identify the relevant record, and the right you wish to exercise. Please do not send passwords or full identity documents unless we request them through a suitable verification process. We may need to verify your identity before responding.

Some information may need to be retained or processing may continue where permitted or required by law, including to complete a transaction, preserve required records, establish or defend legal claims, respond to a lawful request, or protect the Platform and its users. Where a request cannot be fully granted, we will explain the applicable limitation where the law requires us to do so.

You may also have rights relating to processing based on consent, direct marketing, data portability, restriction, objection, and decisions made solely by automated means, subject to the law and the circumstances. Where legally available, you may ask for relevant information about a decision or request review by an appropriate person.

Blink operates from Nigeria and handles personal information in accordance with applicable data protection requirements, including the Nigeria Data Protection Act 2023 where applicable. You may complain to the Nigeria Data Protection Commission or another competent supervisory authority where the law gives you that right. The rights available to you and the process for exercising them may depend on the law that applies to your circumstances.

13. Account Closure and Deletion Requests

You may request account closure or deletion through the account features available to you or by contacting Blink Support. We may ask you to verify the request before acting on it.

Closing an account does not automatically erase every record. Where necessary and lawful, we may retain limited information relating to an accepted offer, transaction, payment, complaint, security event, or legal obligation. If an active transaction or dispute needs to be resolved, we may need to retain relevant information or delay certain steps until we can do so lawfully.

When information is no longer required for a lawful purpose, we will handle it in accordance with our retention practices and applicable law.

14. Age Restrictions

Blink is intended for adults who are legally capable of entering into binding agreements. You must be at least 18 years old to create an account or use the Platform for transactions, and must meet any higher age requirement or other legal restriction that applies to a particular object or transaction in your jurisdiction.

We do not knowingly permit anyone under the applicable minimum age to participate in transactions. If you believe a minor has provided personal information inappropriately, please contact us.

15. Third-Party Services and Links

The Platform may link to or integrate with third-party services, including identity verification providers, payment providers, communications tools, hosting services, or delivery partners. When those providers process information for their own purposes, their privacy notices and terms may also apply.

We encourage you to review relevant third-party privacy notices before using their services. This Policy does not describe practices that are controlled solely by a third party, except to explain how that provider may support a Blink-related activity.

16. Changes to This Policy

We may update this Policy to reflect changes to Blink, the information we process, our service providers, or applicable law. The updated version will be posted on this page with a revised date.

Where required by law, we will provide additional notice or seek consent for a material change. Please review this page periodically to remain informed about our privacy practices.

17. Cookies and Similar Technologies

Where used on our websites or digital services, cookies and similar technologies may remember preferences, support sign-in and security, help measure service reliability, or provide aggregate information about how features are used. The exact technologies depend on the site, application version, and service configuration.

Essential technologies may be necessary for a feature you request. For non-essential technologies that require consent under applicable law, we will provide an appropriate notice or choice. Browser settings may allow you to block or delete some cookies, but doing so can affect site functionality. Mobile operating systems may provide separate controls for app permissions and notifications.

We do not treat device permissions as unlimited permission to access unrelated information on your device. Any access depends on the feature, the permission granted, and the applicable operating-system controls.

18. Automated Processing and Collector Review

Blink may use rules, verification tools, security signals, or other technical processes to help review accounts, protect the Platform, or identify suspicious activity. The tools used may change as the service evolves.

Collector admission and room access are subject to Blink's review and any room-specific approval process. A request or verification result should not be understood as a guarantee of admission or of a seller accepting an offer. Where automated processing is used, its role depends on the particular process and applicable law.

Where required by applicable law, you may request relevant information about a decision and exercise rights relating to human review or objection. You may contact us using the details below if you believe a decision was made using inaccurate information or wish to ask how to raise a review request.

19. Contact Information

For questions about this Policy or to make a privacy request, contact Blink using the details below: