ReloSale Privacy & Personal Data Policy

1. General Provisions

This ReloSale Privacy & Personal Data Policy (hereinafter — the Policy) explains what data ReloSale collects and processes, for what purposes this is done, on what bases the processing is carried out, to whom the data may be disclosed, how long it is retained, what measures are taken to protect it, and what rights users and other data subjects have.

The Policy applies to data processing in connection with the use of the website, mobile version, applications, contact forms, built-in chats, advertising dashboards, payment services, moderation tools, analytics, support, verification, recommendations and other features of the ReloSale platform.

By using the Platform, creating an account, publishing listings, contacting other users, purchasing paid services, submitting requests or otherwise interacting with ReloSale, the user confirms that they have read this Policy.

If specific services, features, countries, user categories or processing methods require special notices, consents or local annexes, such documents apply together with this Policy.

2. Who Is Responsible for Processing Data

The operator / controller of data under this Policy is the entity specified in the details at the bottom of this document, unless otherwise expressly stated for a particular country, service, payment instrument, business dashboard or local annex.

If processing is carried out through subsidiaries, affiliates, local representatives, payment infrastructure providers, cloud providers, call-tracking services, analytics suppliers, verification or fraud-prevention solution providers, data may be processed jointly or on behalf of the operator within the purposes stated in this Policy.

3. What Data We May Collect

Depending on how the user interacts with the Platform, ReloSale may collect and process the following categories of data.

3.1. Registration and Contact Data

• name, display name, alias;
• email address;
• phone number;
• password in protected / hashed form;
• data used to confirm email, phone number or sign-in;
• account identifiers and internal IDs.

3.2. Profile Data

• profile photo, description, interface language, city, country, time zone;
• user status, business account status, agency account, verified account or other service statuses;
• information the user voluntarily adds to their profile.

3.3. Listing and User-Generated Content Data

• listing texts, titles, descriptions, categories, attributes;
• photos, videos, documents, 3D materials, geotags and other media files;
• price, deal terms, address, district, area, specifications, object description, contact methods and other information provided in a listing;
• reviews, comments, complaints, replies, support requests and other user-generated materials.

3.4. Communications Data

• messages sent via the built-in chat;
• support requests, feedback forms, email correspondence;
• communication metadata, including date, time, participant identifiers, technical dispatch and delivery logs;
• where voice or telephony functionality is available — call recordings, masked-call logs, call metadata and related technical data, where permitted by law and disclosed to the user.

3.5. Payment and Billing Data

• information on balance top-ups, charges, refunds, bonuses, paid services, invoices and transactions;
• partially masked payment details, payment instrument tokens, payment provider identifiers;
• country, currency, tax status, billing data, where necessary for settlement, reporting and compliance with mandatory requirements.

As a rule, ReloSale does not store full bank card data where processing of such data is delegated to specialised payment providers.

3.6. Technical and Device Data

• IP address;
• cookie identifiers, device identifiers, advertising identifiers;
• device type, OS, browser version, language, time zone, interface settings;
• access logs, session data, error logs, crash logs, referrers, technical events and anti-abuse signals.

3.7. Platform Usage Data

• search queries;
• listing views, saves, responses, clicks, transitions, favourites, hides, complaints;
• account activity history;
• data on the use of advertising and paid features;
• behavioural signals related to service quality, recommendations, security, anti-fraud and analytics.

3.8. Verification and Due-Diligence Data

Where required by category rules, law, partner procedures, anti-fraud controls or internal trust & safety procedures, ReloSale may process:

• identity documents;
• proof of address;
• company, sole proprietor, agency or other business-user registration documents;
• licences, permits, broker / agent documents;
• documents confirming the right to post a listing or act on behalf of the owner / business.

3.9. Data Received from Third Parties

ReloSale may receive data:

• from payment providers;
• from analytics and attribution services;
• from advertising partners;
• from email, phone, document and fraud-risk verification services;
• from users submitting complaints, reviews, claims or requests;
• from government authorities, rights holders, banks and other parties — in cases provided for by law.

4. Sources of Data

We collect data from the following sources:

• directly from the user during registration, listing placement, correspondence, service ordering and support requests;
• automatically during use of the Platform;
• from cookies and similar technologies;
• from our processors, contractors and partners;
• from third parties where necessary for security, contract performance, legal compliance or complaint handling.

5. Why We Use Data

ReloSale uses data only to the extent necessary for lawful, specified and pre-defined purposes. Such purposes may include:

5.1. Providing Access to the Platform

• creating and managing an account;
• authentication and authorisation;
• providing listing publication, search, communication and listing management features.

5.2. Fulfilling User Requests and Contractual Obligations

• publishing and displaying listings;
• providing paid services;
• processing payments, refunds, invoices and settlements;
• support, resolving technical issues and fulfilling requests.

5.3. Ensuring Security and Preventing Abuse

• detecting spam, fraud, scams, multi-accounts, scraping, attacks and other abuse;
• moderating content and communications;
• investigating incidents;
• protecting the rights of users, the Platform and third parties.

5.4. Compliance with Legislation and Mandatory Requirements

• fulfilling obligations under tax, accounting, payment, sanctions, consumer protection, anti-fraud, AML/KYC and other regulation, if and to the extent applicable;
• responding to lawful requests from government authorities;
• retaining information within mandatory retention periods.

5.5. Improving the Platform

• usage analytics;
• error diagnostics and service quality improvement;
• developing new features;
• testing interfaces, UX, search, anti-fraud and moderation tools.

5.6. Personalisation and Recommendations

• personalising the feed, search, sorting, suggestions and notifications;
• showing relevant listings, similar offers and recommendations;
• reducing irrelevant content and improving search result quality.

Where the law requires a separate notice or grants the user additional rights regarding recommendations, these are disclosed in a separate Recommendation Technologies & Advertising Transparency Notice.

5.7. Communications with the User

• service notifications;
• security messages;
• notifications on account status, listing, payment, complaints, disputes, verification;
• support responses;
• operational messages necessary for the functioning of the service.

5.8. Marketing

• sending news, offers, product updates, special promotions, reminders and other marketing information — to the extent permitted by law and user settings;
• personalising marketing communications and measuring their effectiveness.

Where applicable law requires prior consent for marketing communications, ReloSale will request it separately.

6. Legal Bases for Processing

Depending on the circumstances and applicable law, processing may be carried out on one or more of the following bases:

• necessity for the conclusion, performance or support of a contract with the user;
• necessity for compliance with a legal obligation;
• legitimate interest of ReloSale or third parties, including security, fraud prevention, protection of rights, service development, moderation, analytics and Platform administration, provided that such interests are not overridden by the rights and freedoms of the data subject;
• user consent, where required by law or where ReloSale relies on consent as the specific legal basis;
• other legal bases permitted by the law of the relevant jurisdiction.

Where processing is based on consent, the user has the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

7. When Data Is Required

Certain data is mandatory for registration, listing publication, payment for services, verification, use of certain categories or receiving a support response. If the user does not provide such data, some Platform features may be unavailable.

Provision of other data may be voluntary.

8. With Whom Data May Be Shared

ReloSale does not sell personal data as a standalone product. We may disclose data to the following recipients within the stated purposes:

• affiliates and group companies;
• cloud and hosting providers;
• payment providers, banks and settlement partners;
• analytics, anti-fraud, infrastructure protection and communications providers;
• email, SMS, push, masked-call and communications solution providers;
• KYC / verification / identity / document-check solution providers;
• legal, accounting, audit and security consultants;
• Platform users — to the extent that the user themselves publishes data in a listing, profile or communication;
• advertising and technology partners — within the limits permitted by law and consent settings;
• government authorities, courts, regulators, rights holders, banks and other parties, where required by law or necessary to protect rights and legitimate interests.

9. International Transfers of Data

ReloSale may store and process data in countries outside the user's country of residence, including countries where cloud providers, technical infrastructure, contractors, support services, analytics systems or group companies are located.

Where applicable law requires special measures for cross-border data transfers, ReloSale endeavours to use permissible safeguards, including contractual obligations, organisational measures, available legal instruments and other safeguards provided for by law.

By using an international Platform, the user understands that their data may be processed across borders to the extent necessary for the operation of the service.

10. Data Retention

ReloSale retains data for no longer than is necessary for the purposes for which it was collected, unless a longer period is required by law, accounting and tax rules, dispute resolution obligations, fraud prevention, enforcement of claims, protection of rights or other mandatory requirements.

General retention approaches:

• account data — while the account is active and for a reasonable period after its closure;
• listing data — during the publication period and an archive period after delisting;
• correspondence and support request data — for the period necessary for security, dispute resolution and support;
• payment and billing data — for the period required by financial and tax regulation;
• security logs and anti-fraud signals — for a limited period proportionate to the purpose of their processing.

After the expiry of retention periods, data is deleted, anonymised, aggregated or archived in accordance with the law and internal procedures.

11. Data Security

ReloSale applies reasonable technical, organisational and administrative measures to protect data against unauthorised access, loss, alteration, destruction, disclosure and other unlawful actions.

Such measures may include:

• access control;
• logging and monitoring;
• encryption and pseudonymisation where applicable;
• infrastructure protection, backup and disaster recovery measures;
• contractor vetting procedures;
• internal access and confidentiality policies;
• staff training and incident management.

Notwithstanding the above, no method of data transmission over the internet or method of data storage guarantees absolute security.

13. Public Nature of Listings and Profile Information

The user understands and agrees that data they voluntarily include in listings, profile, reviews, messages, public descriptions, photos, videos and other public fields may become available to an indefinite number of persons, be indexed by search engines, distributed through partner surfaces and retained in caches, archives and logs to the extent permitted by law and the technical architecture of the network.

The user is solely responsible for assessing which information they make public.

14. Cookies and Similar Technologies

ReloSale uses cookies, local storage, SDKs, pixels, tags, device identifiers and other similar technologies for:

• ensuring basic website functionality and account sign-in;
• remembering settings;
• analytics and performance measurement;
• security;
• anti-fraud;
• personalisation;
• advertising attribution and marketing, where permitted by law and user settings.

Where applicable law requires prior consent for certain types of cookies or tracking technologies, ReloSale provides an appropriate consent management mechanism.

Additional details may be disclosed in a separate Cookie Notice.

15. Children and Minors

The Platform is not intended for use by persons below the age permitted by applicable law for the independent use of digital services without the consent of a legal guardian.

If ReloSale becomes aware that a child's data has been collected in violation of applicable law, such data may be deleted and access to the service may be restricted.

For certain categories where the participation of minors is permitted, the Platform may establish special rules and request confirmation of a legal guardian's consent.

16. Automated Systems and Decision-Support Tools

ReloSale may use automated systems for listing ranking, spam detection, fraud-risk assessment, duplicate detection, technical moderation, anti-bot protection, abuse mitigation and personalisation of the user experience.

Such systems are generally not intended for making solely automated decisions that produce legal effects for the user without the possibility of additional review, unless otherwise permitted by law.

Where specific legislation requires special notices regarding automated decisions, such notices may be provided separately.

17. Changes to This Privacy Policy

ReloSale reserves the right to amend, update and supplement this Policy. The revised version takes effect upon publication on the Platform or from such other date as expressly stated in the text.

If the changes are material, ReloSale may additionally notify users via the interface, email or other available channels.

18. Privacy Contacts

For questions regarding the processing of personal data, exercise of rights, withdrawal of consent, filing complaints, requests for deletion or clarification of information, the user may contact us using the details provided below.

If a local representative, DPO or privacy contact has been appointed for a particular country, the relevant details are also provided at the bottom of this document or in a local annex.