WIZBAY LTD — PRIVACY POLICY

1. INTRODUCTION, STATUS AND SCOPE

1.1 This Privacy Policy (the “Policy”) describes how WIZBAY LTD, a company incorporated under the laws of the Republic of Cyprus with Company No. 481061 and registered office at Siafi 1, PORTO BELLO, 3042 Limassol Cyprus (“Wizbay”, “we”, “us” or “our”), collects, uses, stores, discloses and otherwise processes personal data in connection with the operation of the Wizbay online marketplace platform (the “Platform”).

1.2 This Policy applies to all individuals who access or use the Platform, including Buyers, Sellers, visitors and other users (collectively, “Users”).

1.3 Wizbay processes personal data in compliance with:

• Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR),

• applicable national implementing legislation,

• electronic communications and privacy laws,

• and other applicable data protection frameworks.

1.4 This Policy forms part of the Platform’s legal framework together with the General Terms & Conditions, Seller Terms, Shipping Policy and Returns & Refund Policy, Cookies Policy and any supplemental privacy notices or feature-specific disclosures made available through the Platform, including in relation to AI-assisted tools and automated processing.

2. DATA CONTROLLER STATUS AND PROCESSING ROLES

2.1 Wizbay acts as Data Controller in relation to personal data processed for:

a)    operation and administration of the Platform;

b)    account registration and management;

c)    payment coordination, transaction administration, shipping administration, and refund processing;

d)    dispute handling, resolution and returns administration;

e)    fraud prevention and platform security;

f)      customer support and communications;

g)    compliance with legal and regulatory obligations; and

h)    operation, support, monitoring, improvement and lawful deployment of AI-assisted tools, automated moderation systems, image-analysis tools, translation tools, listing-support tools and similar platform technologies.

2.2 Depending on the transaction concerned, Wizbay may process data in different operational capacities:

a) as marketplace operator facilitating transactions between Buyers and Sellers;
b) as seller where Wizbay is identified as seller of record; and
c) as dispute and returns administrator coordinating resolution processes.

2.3 Third-party Sellers act as independent data controllers regarding personal data necessary for performance, fulfilment and delivery of their sales contracts with Buyers and also for customer service, statutory remedies and compliance connected with their own transactions.

2.4 Wizbay is not responsible for the independent privacy practices of third-party Sellers, although Sellers are contractually required to comply with applicable data protection laws. Where a User’s request concerns data processed by a third-party seller in its own capacity, Wizbay may direct the request to that seller or coordinate with that seller as appropriate.

2.5 Depending on the relevant feature or workflow, Wizbay may use third-party AI, translation, moderation, image-analysis or automated processing providers acting as independent controllers or processors/service providers, as applicable. Where Wizbay introduces materially different AI-enabled processing activities, Wizbay may provide additional notices or feature-specific disclosures.

3. CATEGORIES OF PERSONAL DATA COLLECTED

3.1 Wizbay may collect and process the following categories of personal data:

(a) Identification Data

Name, username, date of birth (where required), business registration details, identification documents where verification is required.

(b) Contact Data

Email address, telephone number, billing and shipping addresses.

(c) Account Data

Login credentials, account preferences, transaction history and platform activity records.

(d) Transaction Data

Orders, payments, refunds, returns, communications with Sellers or support services.

(e) Payment-Related Data

Payment identifiers, transaction references, settlement status, refund status, chargeback-related information from payment providers and billing metadata processed through payment service providers (Wizbay does not store full payment card details).

(f) Logistics Data

Delivery tracking information, carrier confirmations, failed-delivery records, customs-related logistics events, re-delivery events, shipment status and return-route logistics records.

(g) Communication Data

Messages exchanged through the Platform, dispute submissions, complaint records, evidence submitted through the Platform and support requests.

(h) Technical Data

IP address, device identifiers, browser type, operating system, session logs and usage analytics.

(i) Risk and Fraud Indicators

Behavioural signals, transaction patterns and risk assessment outputs generated for fraud prevention.

(j) Listing and Content Data

Product titles, descriptions, attributes, category selections, tags, seller-provided content, listing drafts, formatting data, translation inputs and outputs, and other content submitted, generated, standardised or edited through the Platform.

(k) Image and Visual Data

Product photographs, uploaded images, image metadata, image-quality indicators, visual analysis outputs, authenticity-related indicators, duplicate-detection results, image-enhancement records and other image-related data processed through the Platform.

(l) Moderation and Screening Data

Review content, listing reports, policy flags, moderation outcomes, risk labels, authenticity alerts, safety signals, abuse indicators and similar screening or compliance-related outputs.

(m) AI Interaction and Derived Data

Prompts, text inputs, instructions, generated outputs, summaries, translations, recommendations, classifications, scores, confidence indicators, audit logs and similar data created, submitted or generated through AI-assisted or automated platform features.

4. SOURCES OF PERSONAL DATA

4.1 Personal data is obtained from:

a)    Users directly during registration, listing creation, transactions, uploads, reviews, support interactions, disputes, or other use of the Platform;

b)    third-party Sellers or Buyers involved in transactions;

c)    payment service providers;

d)    logistics and delivery partners;

e)    fraud-prevention, moderation, verification, translation, image-analysis and other technology services;

f)      publicly available or lawfully available sources where relevant to fraud prevention, authenticity review or compliance; and

g)    automated technologies, AI-assisted features and system-generated processes used on the Platform.

5. PURPOSES AND LEGAL BASES FOR PROCESSING

5.1 Wizbay processes personal data on the following legal bases under Article 6 GDPR:

(a) Contract Performance

Processing necessary to create and manage accounts, enable listings, process orders, administer shipping, handle returns, execute refunds, process disputes, provide customer support, generate or translate listing content requested through the Platform, and otherwise perform Platform services requested by Users.

(b) Legal Obligations

Compliance with tax, accounting, anti-fraud, consumer protection, product-safety, regulatory, law enforcement, sanctions -screening and other legal obligations and regulatory requirements.

(c) Legitimate Interests

Including:

• platform security,

• fraud detection and prevention,

• dispute management,

• service improvement and operational efficiency,

• prevention of abuse, spam, manipulation or misuse,

• listing quality control and standardisation,

• translation, localisation and content consistency,

• image-quality checks, authenticity screening and trust-and-safety measures,

• moderation and enforcement of Platform Terms and policies.

(d) Consent

Where required for marketing communications, non-essential cookies, or any other processing activity for which consent is required by law.

5.2 Wizbay conducts legitimate interest balancing assessments to ensure such processing does not override Users’ fundamental rights.

6. AUTOMATED DECISION-MAKING AND FRAUD PREVENTION

6.1 Wizbay uses automated systems and algorithmic tools to detect suspicious activity, classify disputes and manage fraud risk.

6.2 Such processing may include:

• transaction pattern analysis,

• behavioural anomaly detection,

• delivery verification logic,

• automated dispute routing.

6.3 Automated processing and the use of AI may influence operational decisions such as additional verification requirements, temporary restrictions or enhanced review procedures.

6.4 Final decisions affecting Users are subject to administrative oversight and may involve human review.

7. DISCLOSURE OF PERSONAL DATA

7.1 Personal data may be shared with:

a)    Sellers or Buyers involved in a transaction;

b)    payment service providers;

c)    logistics and delivery partners;

d)    IT infrastructure, cloud hosting and software providers;

e)    fraud-prevention, identity verification, moderation, translation, image-analysis, AI and other technology services and service providers;

f)      professional advisers; and

g)    public authorities, regulators, law enforcement bodies, courts or other third parties where legally required or lawfully justified.

7.2 Data disclosures are limited to what is necessary for the relevant purpose. These may include buyer contact and delivery data with sellers or logistics providers, where needed for fulfillment or seller identification and transaction-related information shared with buyers where needed for the transaction, returns, complaints, statutory rights or compliance, or dispute, inspection, delivery and return evidence may be shared with the relevant counterparty and operational partners when and if needed.

7.3 Where necessary for the operation of AI-assisted or automated Platform features, Wizbay may disclose relevant personal data and content to third-party providers offering translation services, moderation services, image-processing or authenticity-analysis tools, cloud infrastructure, trust-and-safety tools, or related technical services, subject to contractual, confidentiality, security and data-protection safeguards.

7.4 Where relevant to a transaction, dispute or moderation process, data exchanged through the Platform, including listings, images, reports, reviews, support materials and authenticity-related evidence, may be shared with the relevant Seller, Buyer or service provider to the extent necessary for fulfilment, dispute resolution, fraud prevention, authenticity review, policy enforcement or legal compliance.

8. INTERNATIONAL DATA TRANSFERS

8.1 Due to worldwide operation of the Platform and the use of third-party, service providers, including payment processors, logistics partners, support systems, hosting/infrastructure providers, fraud-prevention providers, cloud providers, AI providers, moderation services, translation providers, image-analysis providers and sellers involved in cross-border transactions, personal data may be transferred outside the European Economic Area.

8.2 Where transfers occur, Wizbay ensures appropriate safeguards including:

• European Commission adequacy decisions,

• Standard Contractual Clauses,

• or equivalent lawful transfer mechanisms.

9. DATA RETENTION

9.1 Personal data shall be retained only for as long as necessary for the purposes described in this Policy, including:

• account data and administration,

• transaction and payment data and processing,

• shipping returns,

• dispute data and resolution and refund data,

• content moderation and supports communications,

• authenticity review (if and when necessary),

• fraud prevention and compliance data,

• platform security,

• operation or review of AI-assisted tools, and

• legal claims’ evidence and legal compliance.

9.2 Transaction, dispute, content moderation, authenticity review if and when applicable, fraud-prevention and AI-interaction data may be retained for extended periods where necessary to investigate abuse, ensure platform integrity, respond to regulatory or law-enforcement requests, verify historic decision-making, required to defend legal claims or comply with legal and regulatory obligations.

10. DATA SECURITY

10.1 Wizbay implements appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure.

10.2 Such measures include encryption, access controls, monitoring systems and secure infrastructure management.

11. USER RIGHTS

11.1 Users have the right to:

• access personal data;

• request rectification;

• request erasure where applicable;

• restrict processing;

• object to processing based on legitimate interests;

• data portability;

• withdraw consent where applicable.

11.2 Requests may be submitted through Platform support channels or via [privacy email]. Where applicable, Users may also request information about AI-assisted or automated processing affecting them, request human review of materially significant decisions, submit additional information, and contest relevant outcomes, subject to applicable law and lawful limitations.

11.3 Wizbay may take reasonable steps to verify the identity of a person making a request and therefore Users may be required to provide identity verification. Also, Wizbay may decline, limit or defer compliance in accordance to applicable law, including where rights are restricted by overriding legal obligations, fraud-prevention requirements, platform security needs, the rights of others, or the need to retain evidence for the establishment, exercise or defence of legal claims. Also, some requests may need to be referred to a third-party seller acting as independent controller.

12. COOKIES AND TRACKING TECHNOLOGIES

12.1 The Platform uses cookies and similar technologies to operate services, analyse usage support security, enhance and improve functionality and where applicable enable or support certain automated or AI-assisted features, subject to the Cookies Policy and applicable consent requirements.

12.2 Detailed information is provided in the Wizbay Cookies Policy.

13. THIRD-PARTY LINKS

13.1 The Platform may contain links to third-party websites. Wizbay is not responsible for external privacy practices.

14. AMENDMENTS

14.1 Wizbay may amend this Policy from time to time.

14.2 Updated versions shall be published on the Platform and take effect upon publication.

14.3 Where Wizbay introduces materially new AI-enabled features, materially expands the purposes for which AI Tools are used, or changes the way personal data is processed through such tools, Wizbay may update this Policy and, where required by law, provide additional notice, implement additional safeguards, or seek consent before such processing takes place.

15. CONTACT AND SUPERVISORY AUTHORITY

15.1 Data protection enquiries may be directed to:

Email: [privacy@wizbay.com]

Address: Siafi 1, PORTO BELLO, 3042 Limassol Cyprus

15.2 Users have the right to lodge a complaint with a competent supervisory authority, including the Office of the Commissioner for Personal Data Protection of Cyprus.

15.3 Users should not upload or submit personal data that is unnecessary for the relevant transaction, listing, review, dispute, support request or AI-assisted feature. Where a User uploads or submits content containing personal data relating to another person, that User is responsible for ensuring that the submission is lawful.