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This document is published in English, and the English version is the binding one. The French version is a translation provided for convenience; if the two differ in meaning, the English prevails.
This Privacy Policy explains how CYAMUNARA RWANDA Ltd, trading as Online Auctions24 ("Online Auctions24", "we", "us", or "our"), collects, uses, stores, shares, transfers, and protects personal data when you use our website, auction platform, buyer or seller services, support channels, and related services (collectively, the "Platform").
Online Auctions24 is an international online auction platform based in Rwanda. We process personal data in accordance with applicable data-protection laws, including Rwanda's Law No. 058/2021 relating to the Protection of Personal Data and Privacy, and, where applicable, other laws that protect users in the countries where we operate or offer services.
Please read this Policy together with our Terms of Service and any auction-specific terms.
This Policy applies to:
Depending on how you use the Platform, we may collect the following categories of personal data.
Account and identity data
This may include your full name, email address, telephone number, username, password in protected form, nationality, identification information, business registration information, job title, and authorised-representative details.
Auction and transaction data
This may include auction registrations, lots viewed, bids placed, bid amounts, bid times, auction results, invoices, payment-status information, collection records, communications relating to auctions, and records of disputes or complaints.
Verification and compliance data
Where required, we may collect information and documents used to verify identity, authority to act for an organisation, ownership, source of payment, anti-fraud controls, sanctions screening, and compliance with legal or institutional requirements.
Technical and usage data
This may include IP address, device type, browser type, operating system, approximate location derived from IP address, login activity, pages visited, auction activity, cookies, and security logs.
Communications data
This may include emails, support requests, telephone records where lawfully recorded, feedback, survey responses, and messages exchanged with us.
Information from third parties
We may receive personal data from sellers, institutional clients, payment providers, identity-verification providers, publicly available sources, fraud-prevention providers, professional advisers, and government or law-enforcement bodies where permitted or required by law.
We use personal data only where we have a lawful basis to do so. We may use your data to:
Our legal bases may include performance of a contract, compliance with a legal obligation, our legitimate interests in operating a secure and trustworthy auction platform, protection against fraud, consent, or another lawful basis permitted by applicable law.
Online Auctions24 uses system controls to record bids, apply auction closing times, identify unusual activity, and help protect auction integrity. Bids are recorded using Platform server time.
We do not make solely automated decisions that produce legal or similarly significant effects on you without appropriate safeguards. Buyer approval, account restrictions, and material compliance decisions may involve human review. You may contact us at info@onlineauctions24.com to request information or review where applicable.
As an international platform, we may process or allow authorised service providers to process personal data in Rwanda and in other countries where we, our clients, or our service providers operate.
When personal data is transferred outside Rwanda or your country of residence, we will take reasonable and appropriate steps to ensure that the transfer is lawful and that your data receives an appropriate level of protection. These steps may include contractual safeguards, data-processing agreements, security measures, approved transfer mechanisms, consent where required, or another lawful transfer basis.
You may contact us at info@onlineauctions24.com for further information about the safeguards used for international transfers, where applicable.
We retain personal data only for as long as necessary for the purposes described in this Policy, including to operate auctions, meet legal and tax obligations, maintain audit records, prevent fraud, and resolve disputes.
Retention periods depend on the nature of the data and the applicable legal or contractual requirements. In general:
We may retain data for longer where necessary to establish, exercise, or defend legal claims, comply with a legal obligation, or respond to an investigation.
We use reasonable technical, organisational, and administrative measures designed to protect personal data against unauthorised access, loss, misuse, alteration, disclosure, or destruction.
These measures may include access controls, password protection, secure transmission, logging, system monitoring, staff confidentiality obligations, role-based access, vendor controls, and security review procedures.
No internet-based service can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for informing us immediately if you suspect unauthorised access to your account.
If we become aware of a personal-data breach, we will investigate it, take appropriate steps to contain and remediate it, and notify affected individuals, regulators, clients, or other parties when required by applicable law.
Subject to applicable law, you may have the right to:
To exercise your rights, contact us at info@onlineauctions24.com. We may need to verify your identity before responding. We will respond within the period required by applicable law.
Some requests may be limited where we must retain data for legal, regulatory, fraud-prevention, audit, contractual, or dispute-resolution reasons.
We may send you service communications that are necessary to operate your account or an auction, such as account-verification messages, bid confirmations, auction notices, payment reminders, and security alerts.
We may send promotional or marketing communications where permitted by law. You can opt out of marketing emails at any time by using the unsubscribe link in the email or by contacting us at info@onlineauctions24.com. Opting out of marketing does not stop essential service communications.
The Platform may contain links to third-party websites, payment providers, social-login services, or other external services. Their privacy practices are governed by their own policies, not this Privacy Policy.
If you choose to use a third-party sign-in provider, such as Google, we may receive the information that you authorise that provider to share with us. We recommend that you review the third party's privacy policy before using its services.
The Platform is not intended for persons under 18 years of age. We do not knowingly collect personal data from children. If you believe that a child has provided personal data to us, contact us at info@onlineauctions24.com and we will take appropriate action.
When Online Auctions24 provides services to a bank, insurer, public institution, UN agency, development partner, or other organisation, we may process personal data under a separate auction-services agreement, data-processing agreement, or other contractual arrangement.
Where we process personal data on behalf of an institutional client, that client may be the data controller and Online Auctions24 may act as a data processor for specified activities. The applicable written agreement will govern that processing where it conflicts with this Policy.
We may update this Privacy Policy from time to time to reflect changes in law, technology, Platform features, or our processing activities.
We will publish the updated version on the Platform and revise the effective date. Where a change is material, we will provide additional notice where required by law.
This Policy is published in English. A French translation is provided for convenience only. If there is any difference in meaning between the two versions, the English version prevails.
For privacy questions, requests, complaints, or concerns, contact:
Online Auctions24, CYAMUNARA RWANDA Ltd, Nyarugenge, Kigali, Rwanda.
Email: info@onlineauctions24.com
Telephone: +250 787 334 130 / +250 788 822 147
If you are dissatisfied with our response, you may have the right to complain to the competent data-protection authority in Rwanda or in your country of residence, where applicable.
The agreement governing accounts, bidding, successful bids, payment, and collection on Online Auctions24.
The operating standards for every auction: notice, inspection, bidding, closing, bid integrity, fees, and complaints.
Each auction also publishes its own terms, which you must accept before your first bid on that lot. Where auction-specific terms conflict with these documents, the auction terms and any signed written agreement prevail to the extent of the conflict.