A. Foreword:

BarterX Ltd, (hereinafter referred to as,“we”, “us”, ”BarterX”) respects and protects your privacy and your personal information. This Privacy Policy will help you to fully understand the scope of your personal information that are collected by us. Further the usage of such personal information, and the entities whom we may disclose your information to. This Privacy Policy will also require your consent. The Privacy Policy is applicable to all "members", "visitors", and "partners" who use the BarterX Service, which described as following in the next point (a).

(a) Definitions of Service

This Privacy Policy is applicable to BarterX's official app and website, related websites to the BarterX website, and other off-site services other than the BarterX domain.

(b) Terms and Changes

We may modify this Privacy Policy, and if we make changes to it, we will provide you a notice through our Services to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account. You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal information is subject to the updated Privacy Policy.

B. Data collected by us:

(a) Information provided by you

1. Registration form

To register as a member, you must provide some personal information, including your name, e-mail address and/or mobile phone number and set a password.

2. Sharing and interacting

You may upload and share your personal information and related information such as your name, country, city/region, mobile phone number, email address, or mailing address on the BarterX app or website. You may publish and upload information regarding to your items such as articles, pictures, videos, descriptions, location, or other related information on the BarterX website. We may collect your related private information unless you delete such information.

3. Transaction information

If you wish to do a transaction, you may need to provide information depending on the payment method you choose, payment information (including credit card or debit card numbers, other personal numbers or accounts, etc.), payment methods, or transaction records.

(b) Information provided by others

1. Sharing and interactions

The content you and others publish on BarterX (e.g. articles, status updates, responses, and videos) may include information related to you. We may keep the content and the related private information unless you delete such information.

2. Synch contacts

When you use BarterX services, we may synch contacts from your other social media (e.g. Twitter) with your consent.

(c) Usage history

When you visit or use a BarterX service, including the BarterX app and website, if you browse or click on the contents or advertisements of the BarterX app and website, perform search, install an update, share information or use the“wish”function, we will keep this data. We keep login data, cookies, device information, and Internet Communication Protocol ("IP" address) to identify your identity and keep a track record.

(d) Your location

When you visit and after you leave the BarterX service (including our plug-ins, cookies), we may receive the URLs of the websites you come and go to. We may also receive information related to your IP address, proxy server, operating system, web browser and add-ons, device ID, and your ISP or telecommunication service provider. If you use the BarterX service with a mobile device, your device may share your location data with us based on your mobile phone and settings.

(e) Other websites and services

When you use your BarterX account to log into other services or visit other services that include BarterX plug-ins, ads, cookies, or similar technologies, we will receive information of your visit and interactions with such services.

C. How we use your information and the collected data:

We may collect, process, disclose and/or use your personal information for one or many of the following purposes (hereinafter referred to as "purpose"):

(a) Manage, operate, provide and/or process your usage and access of our service and website, your member account and the services in relationship with us;

(b) Process your registration and the transactions with us, and transactions and communication between you and a third party through the BarterX service;

(c) We may contact you and provide suggestions for you to access your account based on your interests and preferences;

(d) Process, or complete transactions and/or satisfy your requests for specific products and services, and notify you of service issues and unusual account operations; handle or process customer service, execute your instructions, respond to all inquiries submitted by you or on your behalf;

(e) Perform our "Terms of Use" or any applicable contract/agreement;

(f) For public interest or to protect the personal safety, rights, and properties of you and others;

(g) Identification and/or verification;

(h) Maintain the required software updates and/or other updates and support that ensure the operation of the BarterX service;

(i) Notify you when another user delivers a private message to you or posts feedback for you;

(j) Engage in research, analysis, surveys and development activities to analyze your usage of the service to improve our service and product and to improve your customer experience;

(k) Audits and investigations to ensure the scale and composition of the target audience to understand their experience of the service;

(l) With your prior consent, we may provide you marketing and promotional information regarding products and/or services that BarterX, its related partner or affiliate companies may be selling, marketing or promoting;

(m) Meet any applicable law, regulation, legal process, or enforceable governmental request that are binding to us, our related and affiliate companies. We share information about the number and type of requests we receive from governments in our transparency report.

(n) Detect, prevent, or otherwise address fraud, security, or technical issues.

(O) Protect against harm to the rights, property or safety of BarterX, our users, or the public as required or permitted by law.

(p) Generate statistical data and research results for internal and mandatory reports and/or record retention requirements;

(q) Perform due diligence investigations or other screening actions in accordance with legal or regulatory obligations or our risk management procedures;

(r) Storing, hosting, or backing up (whether for disaster recovery or other purposes) of your personal information regardless of whether such process is within or outside your jurisdiction;

(s) Involved in a merger, an acquisition, or sale of assets, we’ll continue to ensure the confidentiality of your personal information and will give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

(t) Any other purpose we inform you of when we obtain your consent.

As we shall/may collect, use, disclose, or process your personal information for the purpose dependent on the conditions at the time, the purpose may not be covered in this Privacy Policy. However, we’ll ask for your consent before using your information for a purpose that isn’t covered in this Privacy Policy. Nevertheless, information that we are permitted to process and apply by law without your consent shall not be restricted by this clause.

D. Your rights and obligations:

(a) Rights to access and control of personal information

1. Right to erasure (right to be forgotten): You may ask us to erase all or part of your personal information of the service.

2. Right to rectification: You may edit the inaccurate personal information in your account. Under certain conditions, particularly when there is an error in the information that you cannot rectify independently, you may also ask us to modify, update, or correct your personal information.

3. Right to object or right to restriction of processing: You may ask us to cease the process of all or a part of your personal information (e.g. in cases where we do not have the legal rights for the process) or restrict our process (e.g. if your personal information is incorrect or illegally obtained by us).

4. Access and/or obtain your information: You may ask us to make a copy of your personal information and provide you a machine-readable copy of your personal information.

5. Right to data portability: If it is technically feasible for us, you may ask us to directly transfer your personal information to another third party; however, the exercise of this right shall be without prejudice to the right to erasure.

6. Your aforementioned rights are "not applicable" to the execution of duties for compliance with public interests; where processing is necessary for the exercise of public power assigned to the data controller of the information; for the establishment, exercise or defense of legal claims.

(b) Methods of exercise

1. Send an application to support@barterx.ng.

2. We shall perform the aforementioned obligations within the statuary period based on your application, we may require verifiable personal identity documents. However, we shall keep related documents as evidence. If any third party files the application on your behalf, please provide personal identity certification for verifications. We may charge certain fees, if you apply to access or request to review personal information, or for the production of copies. The fee shall be paid in accordance with the standards we have established. If we are unable to process your application within the statuary period, we will inform you of the reason in writing.

3. You have the right to choose to provide personal information. However, if you do not provide personal information or request erasure, we retain the right of stop providing the service to you and the right of terminating your current relationship and contracts with us and such termination shall not compel us to perform rights or obligations related to your contract.

4. You may provide personal information such as your email and name to the BarterX service in private. This information shall not be regulated and protected by the Agreement.

E. How we protect your personal information:

(a) Security protection measures

1. We adopt security protection measures designed to protect data such as Hypertext Transfer Protocol Secure (HTTPS) encryption connection. We will periodically monitor the system for potential loopholes and attacks. However, we cannot guarantee the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial protection measures that cannot attributed to us.

2. We will monitor our systems for possible vulnerabilities and attacks. Please safely use our Services and do not destroy/breach the security protection measures we provide through the service.

3. Limited access: your personal information is stored behind secure networks and accessible only to a limited number of employees with special access privileges in the system.

(b) Legal authorization

1. We will collect and use your information in accordance with the law or with your consent. You may withdraw the statement of consent you provided at any time.

2. When we rely on your consent to process personal information, you have the right to withdraw or refuse consent at any time; when we process information based on legal interests, you have the right to refuse.

3. If you cease your use of our website or if your right to use our website and/or service is terminated, we will continue to store, use, and/or disclose your personal information in accordance with this Privacy Policy and the obligations set forth in the privacy laws. We may dispose your personal information securely without prior notice in accordance with applicable laws.

(c) Transfers of personal data to third countries or international organizations

If your personal information is transmitted or stored across borders, we may use transmission and storage encryption to securely control and manage your personal information. The countries in which we process data may apply laws that may offer less protection than the laws of your country.

(d) Third-Party Websites Disclaimer

1. We do not guarantee the security of the personal information and/or other information you provide on third-party websites.

2. We may choose to connect various third-party websites to our website or place third-party websites within the framework of our website. We may also participate in brand collaborations and other relationships to provide visitors with e-commerce and other services and functions. Connected websites have individual and independent privacy policies and security measures. Even if the third party is related to us, we have no controlling rights over the linked websites and we have no responsibilities or obligations whatsoever with regard to the content, security measures (or lack of security measures), and activities of the linked websites. Therefore, you are solely liable for risks when you access these websites. Nevertheless, we may still manage to protect the integrity of the website and links provided on the website.

F. Contact Us:

If you have questions or opinions regarding the "Privacy Policy", please contact us by sending an email to support@barterx.ng.