Privacy Policy

Depending on how you use the Platform, you may provide the following categories of information:

Account information

• Full name (when you create or update your account profile);
• Email address (used for registration, email verification and account communication);
• Password (processed by the platform's authentication system — AAE does not store or access plain-text passwords); and
• Account role (e.g., buyer, dealer or administrator, assigned by the platform).

Dealer and business information

If you create or operate a dealer profile, you may provide:

• Business name, description and website;
• Phone number and WhatsApp number;
• Email address for dealer contact;
• Profile image and cover image;
• State, city and business address; and
• Years in business.

Dealer verification information

If you submit a dealer verification request, you may provide:

• Business registration number;
• Government-issued identity document (uploaded to private storage);
• Business document (uploaded to private storage);
• A personal photograph (selfie, uploaded to private storage); and
• Type of government ID used.

Verification documents are stored privately and are not publicly visible.

Vehicle listing information

If you publish a vehicle listing, you may provide:

• Vehicle make, model, year, trim and body type;
• Price, mileage, condition and transmission;
• Fuel type, engine and drive type;
• Exterior and interior colour;
• VIN or chassis number (optional);
• Registration status;
• State and city (listing location);
• Vehicle photographs (uploaded to public storage);
• A video link (external URL);
• Vehicle features;
• Seller-reported accident, flood, customs and document status; and
• A free-text description.

Communications and enquiries

When you contact a seller or dealer, or submit an enquiry, you may provide:

• Offers, including an offered amount and optional message;
• Inspection requests, including preferred date, time and an optional message;
• Contact messages, including your name, email, phone (optional), subject and message; and
• Reports about listings or users.

When you interact with the Platform, certain information is generated or recorded:

• Vehicle view events (recorded without buyer identity — see "Vehicle Inspection" and the retention section);
• Saved vehicles (linked to your account so you can revisit them);
• Compare lists (stored locally in your browser, not on the server);
• Listing draft data (stored locally in your browser during the Post Vehicle process);
• Account activity timestamps; and
• Analytics events (see the Cookies and Similar Technologies section).

AAE does not continuously track your precise device location. Listing locations are seller-entered (state and city), not derived from device GPS or IP-based geolocation.

The Platform uses the following categories of browser storage and cookies:

Strictly necessary

• Authentication tokens — managed by the platform's authentication system to keep you signed in. Without these, login and account features would not work.
• Theme preference — stored locally so your dark or light mode choice persists.
• Listing view preference — stores whether you prefer grid or list view.
• Post Vehicle draft and idempotency data — stored locally so an in-progress listing is not lost if the page reloads or a submission fails.
• Remembered listing location — stores the last state and city you used when creating a listing, so you do not have to re-select them each time.
• Compare list — stores the vehicle IDs you have added to your comparison, locally in your browser.

Analytics (optional)

The Platform uses Google Analytics 4 to measure how visitors use the site. Analytics cookies are only set when you grant analytics consent through the cookie banner.

Google Consent Mode v2 is implemented with all consent types denied by default. No analytics commands run until you choose to grant consent. You can accept, reject or customize your preferences at any time using the "Cookie settings" link in the footer.

AAE does not send personal details — names, email addresses, phone numbers, VINs or message contents — to Google Analytics. Only non-identifying event parameters are sent.

Advertising

AAE does not currently serve advertising or use advertising cookies. The consent banner includes advertising-related consent types for completeness, but AAE does not currently activate them.

AAE uses personal information for the following legitimate purposes:

• Creating and managing user accounts;
• Operating marketplace functionality, including publishing and displaying vehicle listings;
• Connecting buyers with sellers and dealers through offers, inspection requests and contact functionality;
• Processing dealer and account verification submissions;
• Managing vehicle inspection requests;
• Maintaining marketplace safety, including fraud prevention and moderation;
• Providing customer support;
• Measuring and improving the Platform through analytics;
• Securing the Platform and enforcing the Terms of Use and Marketplace Rules; and
• Complying with applicable legal obligations.

AAE processes personal information on grounds that may include, depending on the circumstances:

• Performance of a contract or steps requested by you before entering one — for example, creating an account, publishing a listing or submitting an offer;
• Consent — for example, analytics processing where you have granted consent through the cookie banner;
• Legitimate interests — where legally available and appropriately balanced, such as fraud prevention, security and marketplace integrity; and
• Compliance with legal obligations.

Where processing relies on consent, you may withdraw consent at any time without affecting the lawfulness of processing already carried out.

Information that you deliberately include in public vehicle listings or dealer profiles may be visible to other users and, where the relevant page is public and indexable, may be accessible to search engines.

This may include:

• Dealer or business name;
• Listing information, including price, mileage, condition and location;
• Vehicle photographs;
• Dealer phone number, WhatsApp number and email (where you have chosen to display them); and
• Dealer profile description and images.

You should not include unnecessary personal or sensitive information in public listing descriptions or images. AAE is not responsible for personal information you choose to make publicly visible in your listings.

A Vehicle Identification Number (VIN) or chassis number may be provided by sellers when creating a vehicle listing. Providing a VIN is optional.

The VIN is stored as part of the vehicle listing and may be visible where vehicle details are publicly accessible. AAE does not guarantee that VIN information is restricted from all API responses or public views.

If you have concerns about VIN visibility, you may choose to omit the VIN when creating a listing. However, including an accurate VIN can help buyers verify vehicle identity.

AAE provides the following communication features:

• In-house messaging — offers and inspection requests submitted through the Platform;
• Seller or dealer contact — telephone and contact functionality displayed on dealer profiles and vehicle listings; and
• Contact messages — submitted through the Platform's contact and support page.

When you submit an offer or inspection request, the details (including any message you write) are stored and made visible to the relevant dealer and AAE administrators so the enquiry can be processed.

Lead notifications may be sent to the AAE team via internal channels (including a team chat tool and email) so marketplace activity can be tracked and responded to. These notifications are minimized and do not include your personal contact details. Authorized users access full lead details through the controlled AAE system.

AAE does not promise that communications are end-to-end encrypted. You should avoid sharing unnecessary sensitive personal or financial information through marketplace communications.

AAE may process information to verify seller or dealer accounts where this functionality is used. This may include reviewing government-issued identity documents, business documents and a personal photograph submitted by the dealer.

Verification documents are stored privately and are read-restricted to the submitting dealer and AAE administrators.

Account verification and vehicle inspection are separate processes.

A verification label indicates that AAE has completed certain identity, business or account checks. It does not guarantee vehicle condition, ownership or the outcome of any transaction.

AAE does not publicly disclose its internal anti-fraud, moderation or security methodology.

Where AAE provides or facilitates vehicle inspection functionality, the following information may be processed:

• Inspection requests, including preferred date, time and an optional buyer message;
• Inspection status and scheduling information; and
• Inspection report references, where applicable.

Vehicle inspection is separate from account verification.

An inspection does not constitute a warranty unless AAE separately provides an express written warranty. AAE does not currently provide such a warranty.

AAE may process information for the following purposes:

• Fraud prevention and detection;
• Account security;
• Abuse prevention;
• Policy enforcement, including enforcement of the Terms of Use;
• Dispute handling;
• Listing and review moderation; and
• Legal compliance.

AAE does not disclose internal fraud-detection rules, thresholds, security controls or implementation details.

AAE may share information in the following circumstances:

• With other marketplace users — when information is intentionally included in public listings or profiles, or when a buyer chooses to contact a dealer;
• With service providers that support AAE's operations — such as the analytics, email and team communication tools described in the Third-Party Services section;
• With the AAE team — minimized lead notifications so marketplace activity can be tracked; authorized users access full lead details through the controlled AAE system;
• With professional advisers where legitimately required;
• With authorities where disclosure is legally required; and
• In connection with a business restructuring where legally applicable.

AAE does not sell personal data.

The following third-party services are actively used by the Platform:

• Google Analytics 4 — measures how visitors use the site. Processes device and browser information and non-identifying event parameters. No personal details are sent.
• Google (sign-in) — provides Google OAuth for account registration and login. Google's own terms and privacy policy apply to your use of Google sign-in.
• Google Fonts — delivers web fonts used by the Platform.
• Slack — used by the AAE team to receive minimized lead notifications (new offers and inspection requests). Notifications include event type, vehicle, dealership, timestamp and a non-secret record reference. They do not include buyer personal information such as name, email, phone or message content.
• Gmail — used by the AAE team to receive lead notification emails. These emails include vehicle and dealer information but do not include buyer personal information.

Third-party services may operate under their own terms and privacy policies. AAE is not responsible for the independent privacy practices of third-party services.

Some packages may be installed in the application but are not actively used for data processing. AAE only processes data through the services listed above.

The Platform's infrastructure and third-party services may process or store data outside Nigeria. For example, Google Analytics, Google sign-in, Google Fonts, Slack and Gmail may process data in their respective infrastructure locations.

Where cross-border processing occurs, AAE relies on applicable safeguards and requirements under Nigerian data-protection law. AAE has not established a specific international data-transfer mechanism beyond what is provided by its service providers.

AAE retains personal information only for as long as reasonably necessary for the purposes described in this policy, taking into account:

• Account operation and marketplace services;
• Security and fraud prevention;
• Dispute handling;
• Legal obligations; and
• Legitimate recordkeeping.

AAE has not established a comprehensive fixed retention schedule with specific time periods for every data category. Retention is based on the criteria above. When information is no longer needed for these purposes, it may be deleted or anonymized, subject to any legal or legitimate retention requirements.

The Platform does not currently offer a self-service account deletion interface. If you wish to request deletion of your account or associated data, you may contact AAE using the contact details in the Contact section below.

Deletion requests may not result in immediate deletion of every record where retention remains legally required or legitimately necessary for matters such as fraud prevention, security, dispute handling, legal compliance or accounting requirements.

Depending on applicable Nigerian data-protection law, you may have rights concerning your personal information, which may include:

• Access — requesting information about the personal data AAE holds about you;
• Correction — requesting correction of inaccurate or incomplete information;
• Deletion — requesting deletion of your personal data, subject to legitimate retention requirements;
• Restriction — requesting restriction of processing in certain circumstances;
• Objection — objecting to certain processing activities;
• Withdrawal of consent — where processing relies on consent; and
• Complaint — the right to lodge a complaint with the appropriate supervisory authority.

These rights are subject to applicable law and may not apply in all circumstances. AAE does not guarantee a specific internal response deadline beyond what is required by applicable law.

To exercise any of the rights described above, you may contact AAE at:

Email: support@asabaautoexchange.com

AAE may need to verify your identity before fulfilling certain privacy requests. You will not be asked to provide unnecessary sensitive information for verification.

AAE uses reasonable organizational and technical measures appropriate to the nature of the service to protect personal information.

No online system can guarantee absolute security. AAE does not promise perfect security or zero breaches.

AAE does not disclose specific technical security controls that could be exploited.

AAE is an automotive marketplace and is not intended to be used by children in circumstances where they lack the legal capacity required for relevant marketplace transactions or accounts under applicable Nigerian law.

AAE does not knowingly collect personal information from children in a manner inconsistent with applicable law. If you believe a child has provided personal information to AAE, please contact AAE so it can be addressed.

The Platform may contain links to third-party websites or services. These third-party websites may have their own privacy policies and practices.

AAE is not responsible for the privacy practices of third-party websites. You should review the privacy policies of any third-party websites you visit.

AAE may update this Privacy Policy from time to time. When material changes are made, AAE will update the "Last updated" date at the top of this page.

For material changes, AAE will provide notice where legally required or appropriate. Continued use of the Platform after changes take effect does not automatically waive any statutory privacy rights you have under applicable law.

For questions, requests or communications regarding this Privacy Policy or your personal information, you may contact AAE at:

Email: support@asabaautoexchange.com

AAE operates from Asaba, Delta State, Nigeria.

The following related legal documents apply to the Platform:

• Terms of Use — available at /terms
• Vehicle Listing & Marketplace Rules — available at /marketplace-rules

These documents are separate from this Privacy Policy.