BLINKMARKETPLACE LIMITED

1. Introduction

BLINKMARKETPLACE LIMITED (“Blink Marketplace”, “Blink”, “we”, “our”, or “us”) is a premier destination for the curation, auction, and private sale of extraordinary assets operating within Nigeria.

Blink Marketplace facilitates the consignment, private viewing, auctioning, authentication, white-glove fulfillment, and secure transfer of eligible assets across specialized categories including, but not limited to:

• Vintage autos
• Fine arts
• Historic artifacts
• Fine wine and rare spirits
• Luxury accoutrements & timepieces
• Memorabilia & historical documents

The Platform provides exclusive digital auction rooms, specialist appraisals, secure escrow payment coordination, and dedicated concierge logistics to ensure the highest standards of discretion and elegance in every transaction.

We respect your privacy and are deeply committed to protecting the confidentiality and lawful processing of personal data entrusted to us by collectors, consignors, specialists, dealers, and all esteemed clients interacting with the Platform. This privacy policy will inform you as to how we look after your personal data when you visit our auction rooms or use our services, and tell you about your privacy rights.

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, digital auction rooms, concierge services, and associated private client offerings.
• “Curator” refers to an authorized expert responsible for vetting, selecting, and presenting collections within our auction rooms.
• “Blink Assure” refers to our proprietary verification and escrow framework ensuring authenticity, provenance, and secure asset transfer.
• “Specialist” refers to an independent or in-house appraiser providing condition reports, authentication, and valuation for high-value assets.
• “Consignor” refers to an individual, gallery, or institution entrusting extraordinary assets to Blink for auction or private sale.
• “Dealer” refers to a vetted commercial entity, gallery, or authorized merchant approved to present curated inventory on the Platform.
• “Concierge Team” refers to our dedicated support and logistics personnel managing white-glove fulfillment, secure transport, and private client relations.

3. Scope of This Policy

This Privacy Policy applies to:

• Collectors and active bidders
• Consignors and institutional dealers
• Curators and authentication specialists
• Logistics and secure transport partners
• Private and public auction participants
• Visitors to our digital auction rooms
• Individuals communicating with our Concierge Team

This Policy applies to all supported Platform features including:

• Digital auction rooms and bidding activities
• Private sales and direct acquisitions
• Escrow funding and secure financial processing
• Condition reporting and provenance verification
• White-glove logistics and secure transport coordination
• Consignor and dealer onboarding
• Client support and Concierge communications
• Compliance and institutional governance 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 location details, browser type and version, time zone setting, and device information to ensure a seamless viewing experience of our high-resolution galleries.
• Usage Data: includes platform engagement patterns, time spent in specific auction rooms, and general navigational preferences to better tailor our curatorial offerings to your tastes.

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. Auction Room Operations

• To register you as an esteemed client, collector, or consignor.
• To operate our digital auction rooms and facilitate your participation in exclusive auctions.
• To manage private sales, acquisitions, and condition reporting.
• To coordinate white-glove logistics and secure asset handover.

B. Financial Processing & Escrow

• Processing bidding deposits to qualify you for high-value auctions.
• Managing the Blink Assure escrow process, final settlements, fees, and disbursements.
• Ensuring accurate financial reconciliation for all consignors and buyers.

C. Trust, Security & Compliance

• Verifying the identity of our clients to maintain a secure and exclusive marketplace.
• Complying with Anti-Money Laundering (AML) and institutional governance standards.
• Monitoring high-value transactions to ensure the safety of our community.

D. Auction Integrity

We actively monitor bidding patterns and auction behavior to ensure total fairness, prevent artificial price manipulation, and uphold the prestige of our auction rooms. Our commitment to transparency ensures that every bid placed is legitimate and that the final hammer price reflects true market value.

E. Concierge & Dispute Resolution

• Providing dedicated support through our Concierge Team for private viewing arrangements and transport.
• Addressing any discrepancies regarding condition reports or asset provenance swiftly and discreetly.

F. Client Communications

• To notify you about upcoming curations, private sales, or changes to our policies.
• To send essential transaction updates, auction reminders, and secure transport itineraries.

7. Financial Infrastructure

To guarantee the security of high-value exchanges, Blink Marketplace partners with regulated financial institutions, trusted payment processors, and secure escrow services.

Clients may be provided with dedicated, secure accounts to facilitate deposits and final settlements. Financial processing and escrow services may be securely facilitated by licensed banking partners and esteemed providers such as Paystack.

We may receive settlement confirmations and reconciliation data necessary to finalize acquisitions. Our financial framework integrates strictly with:

• Licensed banking institutions
• Regulated payment processors
• Institutional compliance providers

8. Sharing of Information

We maintain strict discretion, sharing information only where reasonably necessary with:

• Secure logistics and fine-art transport partners
• Independent specialists and authentication experts
• Banking partners and escrow providers
• Law firms and professional advisers
• Regulatory authorities and compliance monitors

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

9. Data Retention

Blink Marketplace retains personal data only for as long as necessary to facilitate acquisitions, maintain historical provenance records, comply with legal obligations, and ensure the ongoing security of our auction rooms.

Auction history, provenance documentation, and final settlement records associated with high-value assets may be retained indefinitely to preserve the historical integrity of the items sold through our platform.

10. Security of Information

We have implemented rigorous, institutional-grade security measures to protect your personal data from unauthorized access, alteration, or disclosure. Access to your information is strictly limited to our Concierge Team, Curators, and authorized partners who require it to fulfill your requests.

Blink Marketplace utilizes advanced safeguards including:

• Secure encryption protocols
• Strict access controls and confidentiality agreements
• Continuous infrastructure auditing
• Advanced fraud prevention systems

While we uphold the highest standards of security, no digital transmission can be guaranteed to be entirely invulnerable.

11. Client Rights & Compliance

Under applicable data protection laws, you possess specific rights regarding your personal information, including the right to:

• Request access to your stored client profile
• Update or refine your personal details
• Request the removal of eligible data
• Withdraw consent for optional communications

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). Clients 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

Clients may initiate an account closure request at any time through our Concierge Team or natively via the platform dashboard.

To preserve the integrity of our auction rooms and the security of the Blink Assure escrow process, closure requests are carefully reviewed. If your portfolio contains active bids, pending consignments, outstanding settlements, or unresolved provenance inquiries, your request will be deferred until all obligations are elegantly and legally concluded.

Certain historical acquisition records and compliance data must be retained post-closure to satisfy legal, audit, and historical provenance requirements.

13. Age Restrictions

Participation in Blink Marketplace is strictly reserved for individuals legally capable of entering into binding contracts for high-value acquisitions.

Individuals under the age of 18 are not permitted to register as clients, consignors, or participate in any bidding or financial activities on the Platform.

14. International Access

While Blink Marketplace celebrates global heritage, our primary operations and legal jurisdiction are based in Nigeria. We proudly serve Nigerian-based clients and institutions.

International collectors and consignors may access our auction rooms subject to enhanced verification and cross-border compliance protocols.

15. Trusted Partners

To deliver an uncompromised experience, we collaborate with select third parties including:

• Secure financial and escrow institutions
• White-glove logistics and art-handling professionals
• Independent authentication specialists
• Secure cloud infrastructure providers

Blink Marketplace is not responsible for the independent privacy practices of these external services outside our direct mandate.

16. Policy Updates

Blink Marketplace may periodically refine this Privacy Policy to reflect enhancements in our services or legal obligations. Clients will be elegantly informed of significant updates via:

• Direct email from our Concierge Team
• Platform notifications
• Announcements within our digital auction rooms

Continued engagement with our platform following such updates constitutes your acceptance of the refined terms.

17. Contact Information

Should you require clarification on this policy or wish to exercise your privacy rights, our team remains at your disposal: