Privacy Policy

At Market360 we believe that privacy is a fundamental right, not a premium feature. We have engineered the entire platform around the principles of data minimisation, purpose limitation, and transparency. We collect the smallest amount of data necessary to operate a safe and useful marketplace, we use it only for the purposes you would reasonably expect, and we tell you exactly what happens to it.

This Policy is written for both buyers and sellers. Wherever a section applies only to one group (for example, payout data only applies to sellers), we say so clearly. Throughout this Policy, capitalised terms have the meaning given to them in our Terms of Service.

This Policy should be read alongside our Terms of Service, Cookie Notice, and any product-specific disclosures presented to you in the app or on this website.

For the purposes of applicable data protection law (including the EU GDPR, the UK GDPR, the California Consumer Privacy Act, and the Sierra Leone Data Protection Bill), the data controller of your personal information is:

If your local law requires a designated representative in your region, please contact our Data Protection Officer at the email address above and we will appoint one.

We collect the following categories of personal information:

We do not intentionally collect special categories of data (such as racial origin, religion, political opinions, health, biometric or genetic data) unless you provide it to us voluntarily, for example via a support message.

We collect personal information through the following sources:

• Directly from you when you register an account, list a product, place an order, complete identity verification, or contact our support team.
• Automatically when you use our Services — through cookies, mobile SDKs, server logs, and similar technologies.
• From third parties such as payment processors, identity verification partners, fraud-prevention networks, and public business registries.
• From other users — for example, when a buyer leaves you a review or a seller flags a transaction for investigation.

We use your personal information for the following purposes:

• Operate the marketplace — list products, process orders, route payments, and manage refunds and disputes.
• Verify your identity and prevent fraud, money laundering, and other abuse of the platform.
• Personalise your home feed, search results, and product recommendations.
• Send transactional updates such as order confirmations, payout notifications, and security alerts.
• Send marketing messages — only with your explicit, revocable consent.
• Improve product quality through anonymised analytics, A/B testing, and crash diagnostics.
• Provide customer support and respond to enquiries you send us.
• Comply with legal, tax, accounting, and regulatory obligations in Sierra Leone and other jurisdictions where we operate.
• Enforce our Terms of Service and other policies, including investigating suspected violations.

Where data protection law requires a legal basis, we rely on one or more of the following:

We share personal information only in these limited circumstances:

When you use the Market360 Wallet, we process additional financial information including wallet balances, top-ups, payouts, and transaction history. This data is required to operate the wallet, calculate fees, and comply with anti-money-laundering and counter-terrorism financing laws.

Card numbers, mobile-money PINs, and other sensitive payment credentials are tokenised by our payment partners and are never stored on Market360 servers in readable form.

For high-value transactions and seller payouts above regulatory thresholds, we may request additional verification documents (such as proof of address, business registration, or source of funds). This information is retained for the periods required by Sierra Leone financial regulations.

We use a small set of cookies and similar technologies (such as mobile SDK identifiers and local storage) to keep you signed in, remember preferences, and measure how our Services perform. You can disable non-essential cookies at any time from the consent banner or your browser settings.

We use first-party analytics to understand how Market360 is used, which features are popular, where users get stuck, and how to improve. Whenever possible, analytics events are aggregated and stripped of identifying details before storage.

Personalised recommendations (such as your home feed and product suggestions) are generated from your browsing and purchase history within Market360. You can reset your personalisation profile at any time from Settings → Privacy → Personalisation.

We send marketing messages — including emails, SMS, and push notifications — only with your explicit consent. Every marketing message includes a one-click unsubscribe link, and you can manage your communication preferences at any time from Settings → Notifications.

Transactional messages (such as order confirmations, payout notifications, security alerts, and policy updates) are not marketing and cannot be turned off while you maintain an active account.

We retain personal information only for as long as necessary to deliver the Services and meet our legal obligations. Typical retention windows are:

• • Account data — kept while your account is active and for 90 days after deletion.
• • Transaction records — retained for up to 7 years for tax and accounting compliance.
• • KYC / identity verification — retained for 5 years after the end of the customer relationship, as required by anti-money-laundering law.
• • Support messages — retained for 2 years from the date of last contact.
• • Marketing data — deleted immediately upon unsubscribe.
• • Server logs & security events — retained for 12 months.

After the applicable retention period expires, your data is securely deleted or anonymised so it can no longer be linked back to you.

Regardless of where you live, Market360 honours the following data rights:

To exercise any of these rights, email privacy@market360.shop or use the controls in Settings → Privacy. We will respond within 30 days, and never charge a fee for reasonable requests.

Market360 follows industry-leading security practices to protect your data from unauthorised access, disclosure, alteration, or destruction:

• • Encryption — AES-256 at rest, TLS 1.3 in transit, hardware-backed key storage.
• • Network isolation — production data lives in private VPCs with no public IP addresses.
• • Access control — principle of least privilege, mandatory two-factor authentication for all staff.
• • Monitoring — continuous intrusion detection, anomaly alerting, and 24/7 on-call security response.
• • Testing — regular third-party penetration testing and a public vulnerability disclosure programme.
• • Backups — encrypted, geographically distributed backups with quarterly restore drills.

No system is perfectly secure, but we are committed to using reasonable and appropriate safeguards and to continuously improving our security posture.

Market360 operates globally and uses cloud infrastructure that may store and process your data outside Sierra Leone, including in the European Union, the United Kingdom, and the United States. When data is transferred across borders, we rely on appropriate safeguards such as Standard Contractual Clauses, adequacy decisions, and equivalent mechanisms approved by your local regulator.

You can request a copy of the safeguards we use by contacting privacy@market360.shop.

Market360 is not directed to children under the age of 16, and we do not knowingly collect personal information from minors. If you are under 16, please do not register an account or send us any personal information.

If we discover that we have inadvertently collected personal data from a child without verified parental consent, we will delete that information promptly. Parents and guardians who believe their child has provided personal data to Market360 should contact us at privacy@market360.shop.

The Services may contain links to third-party websites, apps, or content that are not operated or controlled by Market360. This Policy does not apply to those third parties, and we are not responsible for their privacy practices.

We encourage you to review the privacy policies of any third-party service you interact with through Market360 — including payment processors, delivery providers, and external login providers — before providing them with your personal information.

In the unlikely event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority within 72 hours of becoming aware of the breach, where required by law.

Where the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay, providing clear information about the nature of the breach, the data involved, the likely consequences, and the steps you can take to protect yourself.

We use automated systems to detect fraud, score risk on transactions, rank search results, and personalise your home feed. These systems do not produce legal effects or similarly significant consequences without meaningful human review.

Where an automated decision (such as blocking a payment for suspected fraud) materially affects you, you have the right to request human review, to express your point of view, and to contest the decision by emailing privacy@market360.shop.

We may revise this Privacy Policy from time to time as Market360 evolves, as our data practices change, or as required by law. The latest version will always be available at this URL, and the "Last updated" date at the top of the page will reflect the most recent revision.

We will notify you of material changes by email and/or via an in-app banner at least 14 days before they take effect. Continued use of the Services after the effective date of the revised Policy constitutes your acceptance of the updated terms.

Questions, requests, or complaints? Please contact our Data Protection team — we respond within 5 business days to ordinary enquiries and within 30 days to formal rights requests.