Automami Privacy Policy

1. Data we collect

• Account and identity data: name, date of birth, contact details, address, photograph, identity documents, signatures and authentication records.
• Business and compliance data: company information, directors, authorized representatives, beneficial owners, tax or registration information, source-of-funds evidence and screening results.
• Transaction data: wallet or escrow records, originating bank-account information, bids, purchase requests, invoices, refunds, vehicle selections, shipping, clearing and delivery records.
• Technical and usage data: IP address, device and browser identifiers, logs, timestamps, cookie or similar technology data, approximate location, pages viewed and account-security events.
• Communications and support data: calls, messages, emails, complaints, documents and feedback submitted to us.
• Vehicle and preference data: searches, saved vehicles, auction interests, desired specifications and related recommendations.

2. Why and on what basis we process data

We process personal data only where we have a lawful basis, including performance of a contract or steps requested before a contract; compliance with legal obligations; protection of vital interests where applicable; consent for genuinely optional processing; and our or another person's legitimate interests where those interests are not overridden by your rights.

• create, verify, secure and administer accounts;
• provide listings, estimates, bidding, purchasing, payment, escrow, import, shipping, clearing, delivery and support services;
• prevent fraud, money laundering, sanctions breaches, account misuse, cybersecurity incidents and other unlawful conduct;
• communicate transaction status, service notices and security alerts;
• improve Platform performance, customer service, analytics and relevant recommendations;
• establish, exercise or defend legal claims and comply with regulators, courts and lawful requests; and
• send marketing only where permitted, with a clear means to opt out.

3. Sharing

We may share relevant data with RC Brown affiliates; Zenith Bank or another approved custodian; banks, payment and digital-asset service providers; auction houses; suppliers such as Guazi; vehicle-history and inspection providers; shipping lines, freight forwarders, terminals, insurers, customs and clearing agents; identity, fraud, cybersecurity, hosting, analytics and communications providers; professional advisers; regulators, law-enforcement bodies and courts; and a buyer or investor in a lawful corporate transaction. Each recipient receives only data reasonably necessary for its role or as required by law.

4. International transfers

Vehicle sourcing and technology operations may require data to be accessed or processed outside Nigeria, including in the United States, China and other sourcing or transit jurisdictions. We will use a lawful transfer mechanism and appropriate contractual, organizational and technical safeguards as required by the Nigeria Data Protection Act.

5. Retention

We retain data for as long as necessary to operate the account or transaction, meet banking, tax, customs, AML/CTF, audit, warranty, complaint and legal requirements, resolve disputes and protect legitimate interests. Unsuccessful bid and dormant-account records will be reviewed and deleted or anonymized when no longer reasonably required. Completed-transaction and compliance records may be retained for the legally required period even after account closure.

6. Security

We use risk-appropriate administrative, technical and physical safeguards, including access controls, authentication, logging, vendor controls, encryption where appropriate, backups and incident response. No internet service is completely secure. You must protect your credentials and promptly report suspected compromise.

7. Your rights

Subject to applicable law and appropriate identity verification, you may request access to and copies of your data; correction; deletion; restriction; objection; portability where applicable; information about processing; withdrawal of consent without affecting earlier lawful processing; and review of certain solely automated decisions that produce legal or similarly significant effects. Some requests may be limited where retention or processing is required by law, needed for a transaction, or necessary to establish or defend legal claims.

8. Cookies and preferences

We may use essential technologies for login, security, session continuity and transaction integrity. Non-essential analytics or advertising technologies should be presented through a preference control where legally required. Rejecting non-essential cookies must not prevent basic account creation or purchasing functions.

9. Children

Automami accounts are not intended for anyone under 18. If we learn that a minor's data was collected without lawful authorization, we will take appropriate steps to delete or restrict it.

10. Contact and complaints

Privacy requests may be submitted through the privacy or support contact displayed on the Platform. We may request information reasonably necessary to verify identity. You may complain to the Nigeria Data Protection Commission if you believe your data-protection rights have been infringed.

11. Policy changes

We may update this Policy to reflect legal, operational or service changes. We will publish the current version and give appropriate notice of material changes. Where a new purpose requires consent, we will request it separately.