Effective: April 2026

By creating an account on Auctioneer (operated by Fidara Solutions Limited), you consent to the collection, processing, and storage of your personal data as described below. This consent is required under the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation (NDPR).

1. What We Collect

• Identity data: full name, email address, phone number
• Organisation data: company name, registration number (RC), TIN, bank account details, contact persons
• Authentication data: hashed passwords, session tokens, 2FA secrets (encrypted)
• Auction data: bids placed, items won, payment records, collection evidence
• Technical data: IP address, browser type, device info, access timestamps

2. Why We Collect It

• To provide the auction platform services you registered for
• To verify your identity and prevent fraud
• To process payments through our licensed payment processor (Paystack)
• To comply with legal obligations (tax, regulatory reporting, audit trails)
• To enforce platform rules and resolve disputes
• To send transactional notifications (bid updates, payment confirmations, collection instructions)

3. Legal Basis

We process your data based on:

• Your consent (this agreement)
• Contractual necessity (to provide auction services)
• Legal obligation (tax compliance, regulatory reporting under CBN, FCCPA, NDPA)
• Legitimate interest (platform security, fraud prevention)

4. Data Sharing

We share your data only with:

• Paystack — payment processing (as required by CBN regulations)
• Termii — SMS and WhatsApp notifications
• Resend — email delivery
• Regulatory bodies — when required by law

We do not sell your personal data to third parties.

5. Data Retention

• Account data: retained while your account is active + 6 years after closure (tax/audit requirements)
• Auction records: retained permanently (append-only audit trail, regulatory requirement)
• Payment records: retained for 7 years (CBN requirement)
• Technical logs: retained for 90 days

6. Your Rights

Under the NDPA, you have the right to:

• Access your personal data
• Correct inaccurate data
• Request deletion (where not overridden by legal retention requirements)
• Withdraw consent (note: this may prevent use of the platform)
• Data portability
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC)

7. Security

We protect your data using:

• Encrypted storage (passwords hashed with bcrypt, secrets encrypted at rest)
• TLS encryption for all data in transit
• Row-level database locking for bid integrity
• Operator Blackout protocol — bidder identities sealed during live auctions
• Append-only audit logs protected by PostgreSQL rules

8. Contact

Data Protection Officer: legal@auctioneer.com.ng

Fidara Solutions Limited, Lagos, Nigeria