Privacy Policy
Effective Date: 8th June 2026 | Last Updated: N/A
Table of Contents
This Global Privacy Policy explains how EXPIRINGSOON LTD and its international affiliates (collectively, "EXPIRINGSOON", "we", "us", or "Platform") collect, utilize, and protect your personal data when you interact with our marketplace services. This policy is designed to comply with global data protection standards, including the NDPR (Nigeria), UK GDPR, EU GDPR, UAE PDPL, and relevant U.S. privacy laws.
1. Who We Are
EXPIRINGSOON operates a digital marketplace connecting Buyers with independent third-party Sellers.
- Data Controller: EXPIRINGSOON acts as a data controller for information related to Platform operations, user accounts, and transaction facilitation.
- Independent Controllers: Sellers act as independent data controllers for personal data they receive to fulfill orders and meet their own regulatory obligations.
2. Data We Collect
We collect the following categories of personal data to facilitate the "recovery" of at-risk inventory:
Identity & Account Data
Name, email, phone number, and account credentials.
Transaction Data
Details of orders and purchase history (we do not store raw card data).
Technical & Geolocation Data
IP addresses, device identifiers, and location data required for local cluster fulfillment.
Communications
Records of customer support interactions and platform messages.
3. How We Use Your Data
We process your information for the following purposes:
- To operate the Platform and facilitate transactions between Buyers and Sellers.
- To process payments via licensed PCI-compliant third-party providers.
- To comply with legal, regulatory, and tax obligations across all jurisdictions.
- To prevent fraud, secure user sessions, and maintain platform integrity.
4. Legal Basis for Processing
Where required by law (e.g., UK/EU GDPR), we rely on these lawful bases:
| Lawful Basis | Description / Details |
|---|---|
| Contractual Necessity | To provide the marketplace services you requested. |
| Legal Obligation | To comply with regional tax and safety laws. |
| Legitimate Interests | For security, fraud prevention, and service optimization. |
| Consent | Where you have explicitly opted-in for marketing or non-essential cookies. |
5. Data Sharing & Disclosure
We do not sell your personal data. We share information only with:
Sellers
Necessary details (name, delivery address, recovery code) to fulfill your orders.
Buyers / Customers
Vendor business details are shared with customers for transparency and support purposes.
Service Providers
Payment processors (e.g., Stripe, Flutterwave), logistics partners, and secure hosting providers.
Authorities
When legally mandated by regulators in the UK, US, Nigeria, UAE or other jurisdictions of service.
6. International Data Transfers
As a global platform, your data may be transferred across borders. We ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs), to protect your data regardless of where it is stored.
7. Data Security & Retention
Security
We implement technical measures, including encryption and strict access controls, to protect your data.
Retention
We retain data only as long as necessary to fulfill contracts, resolve disputes, or comply with statutory retention periods.
8. Your Global Privacy Rights
Depending on your jurisdiction (e.g., GDPR, CCPA, NDPR, UAE PDPL), you may have the right to:
- Request access to or a copy of your data.
- Request correction of inaccurate information.
- Request deletion of your account or data.
- Object to or restrict certain types of processing.
- Withdraw consent for marketing at any time.
9. Seller Responsibilities
Sellers are independent controllers of the data they receive for fulfillment. EXPIRINGSOON is not responsible for the independent privacy practices of these Sellers.
10. Contact Us
For privacy-related inquiries or to exercise your rights, please contact our Global Data Protection Officer: