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 registered office at [●] (“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.

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 and transaction administration;
d) dispute resolution and returns administration;
e) fraud prevention and platform security;
f) customer support and communications; and
g) compliance with legal and regulatory obligations.

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 of their sales contracts with Buyers.

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.

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 and billing metadata processed through payment service providers (Wizbay does not store full payment card details).

(f) Logistics Data

Delivery tracking information, carrier confirmations, shipment status and return logistics records.

(g) Communication Data

Messages exchanged through the Platform, dispute submissions 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.

4. SOURCES OF PERSONAL DATA

4.1 Personal data is obtained from:

a) Users directly during registration or transactions;
b) third-party Sellers or Buyers involved in transactions;
c) payment service providers;
d) logistics and delivery partners;
e) fraud-prevention and verification services; and
f) automated technologies 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 accounts, process orders, administer shipping, handle returns and execute dispute resolutions.

(b) Legal Obligations

Compliance with tax, accounting, anti-fraud, consumer protection and regulatory requirements.

(c) Legitimate Interests

Including:

• platform security,

• fraud detection,

• dispute management,

• service improvement,

• prevention of abuse,

• enforcement of Platform Terms.

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

(d) Consent

Where required for marketing communications or non-essential cookies.

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 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 providers;
e) fraud-prevention and identity verification services;
f) professional advisers; and
g) public authorities where legally required.

7.2 Data disclosures are limited to what is necessary for the relevant purpose.

8. INTERNATIONAL DATA TRANSFERS

8.1 Due to worldwide Platform operation, 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 administration,

• dispute resolution,

• fraud prevention,

• legal compliance.

9.2 Transaction and dispute data may be retained for extended periods where required to defend legal claims or comply with 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].

12. COOKIES AND TRACKING TECHNOLOGIES

12.1 The Platform uses cookies and similar technologies to operate services, analyse usage and enhance functionality.

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.

15. CONTACT AND SUPERVISORY AUTHORITY

15.1 Data protection enquiries may be directed to:

Email: [privacy@wizbay.com]
Address: [Registered Address]

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.