PRIVACY POLICY

1. Introduction

RAIRE LIMITED (“Raire”, “we”, “us”, “our”) operates the Raire website, mobile application, and related services (the “Platform”). We respect your privacy and process personal data in accordance with Nigerian law, including the Nigeria Data Protection Act 2023 (NDPA) and the Nigeria Data Protection Regulation 2019 (NDPR) (as amended).

This Privacy Policy explains what personal data we collect, why and how we use it, who we share it with, your rights, and how to contact us.

2. Data Controller

RAIRE LIMITED, Lagos, Nigeria. Contact: support@raireapp.com

3. Data We Collect

3.1 Account and Profile Information

• Name, username, email address, phone number
• City, state, delivery address
• Profile photo
• Bio and store description (for sellers)

3.2 Seller Verification

• Limited KYC information needed to enable payouts and prevent fraud
• This may include government ID metadata or BVN verification via trusted third-party partners
• Raire does not store full identity documents or raw BVN data
• Seller area/location within Lagos for operational purposes

3.3 Transaction Information

• Order details, amounts, payment confirmations
• Offer and counter-offer history
• Delivery information and tracking data
• Authentication selection and results (if applicable)

We do not store full card numbers or bank credentials.

3.4 Content You Provide

• Listings, photos, descriptions, pricing
• Direct messages between buyers and sellers
• Comments on listings
• Reviews and ratings

3.5 Device and Usage Data

• IP address, device type, operating system, app version
• Log data, cookies, SDK data (see Section 13)
• Device tokens for push notifications
• App usage patterns and feature interactions

3.6 Support Communications

• Emails, chats, surveys, bug reports, and feedback
• Dispute resolution records and communications

4. Legal Bases for Processing

We process personal data on one or more of the following legal bases under the NDPA and NDPR:

• Contract: to provide the Platform, process transactions, facilitate offers, and coordinate deliveries
• Legitimate interests: to prevent fraud, maintain safety, improve features, resolve disputes, and market similar services
• Consent: for optional features such as marketing communications, push notifications, or location-based discovery
• Legal obligation: to comply with applicable laws, tax requirements, and regulatory requests

5. How We Use Your Data

We use personal data to:

• Create and manage user accounts and seller profiles
• Enable buying, selling, and the offer/counter-offer system on the Platform
• Display listings, search results, profiles, and reviews
• Process payments via trusted payment partners (Paystack)
• Coordinate the two-stage delivery process: collection from sellers to the Raire Hub, and delivery from the Raire Hub to buyers
• Provide real-time delivery tracking and order status updates
• Facilitate optional third-party authentication for designer items
• Send push notifications for offers, order updates, reviews, messages, and other Platform activity
• Send email communications including OTP codes, order confirmations, delivery updates, and account deletion confirmations
• Prevent fraud, enforce our Terms, and resolve disputes between buyers and sellers
• Facilitate the review system, including post-delivery review prompts
• Improve the Platform using analytics and research (preferably aggregated or de-identified data)
• Send marketing communications where you have provided consent

6. Sharing Your Data

We share personal data only where necessary, including with:

• Payment partners (Paystack): to securely process card or bank transactions
• Courier and logistics partners: name, phone number, and delivery address for the two-stage fulfilment process
• Authentication partners (if selected by buyer): item details and relevant images for verification of designer items
• Service providers: hosting, analytics, push notification services, and customer support tools
• Other users: limited information required to complete transactions (e.g. first name or initial, city, order status), public listings, reviews, and follower/following information. In direct messages, buyers and sellers can see each other’s username and listing information relevant to the conversation.
• Law enforcement or regulators: where required by law or to protect rights, safety, or property
• Corporate transactions: such as mergers or acquisitions, subject to appropriate safeguards

We do not sell personal data.

7. Direct Messages

Messages sent between buyers and sellers on the Platform are stored to facilitate transactions and may be reviewed by Raire staff during dispute resolution. Each item inquiry creates a separate message thread to help sellers identify which item a buyer is asking about. If a user deletes their account, the other party can still see the conversation but the deleted user will appear as “Anonymous.”

8. Push Notifications

We collect device tokens to send push notifications, including notifications about new offers, offer responses, order updates, delivery tracking, review prompts, new followers, and messages. You can manage your notification preferences in the app Settings or through your device settings at any time.

9. International Data Transfers

Where personal data is transferred outside Nigeria (e.g. to cloud hosting providers), we apply appropriate safeguards, including contractual protections and security measures, in line with NDPA requirements.

10. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, including legal, accounting, tax, and dispute-resolution obligations. Data is securely deleted or anonymised when no longer required.

10.1 Account Deletion

When you request account deletion:

• Your account is deactivated for a 30-day grace period. During this time, you can log back in to reactivate your account.
• After 30 days without login, your account is permanently deleted.
• Personal information (name, email, phone number, address, profile photo) is permanently deleted.
• Transaction records are retained in anonymised form for legal, tax, and accounting purposes as required by Nigerian law.
• Reviews you have left on other users’ profiles will remain visible but your name will be changed to “Deleted User.”
• Your listings are removed from search results and the Platform.
• Your payment methods are disconnected.
• All active sessions are terminated.
• You are unsubscribed from all email and push notifications.
• In message threads with other users, your identity will appear as “Anonymous.”

You will receive an email confirming your deletion request and a final email confirming permanent deletion after the 30-day period. You cannot delete your account while you have active listings, pending orders, unresolved disputes, or outstanding balances.

11. Your Rights

Subject to applicable law, you may:

• Request access to, correction of, or deletion of your personal data
• Object to or restrict certain processing
• Withdraw consent at any time (without affecting prior lawful processing)
• Request data portability
• Lodge a complaint with the Nigeria Data Protection Commission (NDPC)

Requests: support@raireapp.com. We may request verification before responding.

12. Security

We implement technical and organisational safeguards, including encryption in transit, access controls, and monitoring, to protect personal data. No system is completely secure. Please report any security concerns to support@raireapp.com.

13. Cookies and Similar Technologies

We use cookies and SDKs for essential functionality, analytics, and preference storage. You can manage cookies through your browser or device settings. Essential cookies are required for core Platform features.

14. Children

Raire is intended for users 18 years and older. We do not knowingly collect personal data from anyone under 18. If you believe a minor has used the Platform, please contact support@raireapp.com.

15. Changes to This Policy

We may update this Privacy Policy to reflect legal, operational, or product changes. Updates will be posted with a revised effective date and, where material, notified via email or in-app notification.

16. Contact

For data protection questions or rights requests: support@raireapp.com

ACCEPTABLE USE POLICY

1. Purpose of the Platform

Raire is an online marketplace that enables users to buy and sell fashion and lifestyle items, including clothing, shoes, bags, and accessories. Raire also enables small fashion businesses and independent designers to sell new items directly to buyers. Raire acts as a technology platform connecting buyers and sellers and does not manufacture or own listed items. All items pass through the Raire Hub for quality verification before being delivered to buyers.

2. Eligible Users

Users must be at least 18 years of age to register, buy, or sell on the Platform. By creating an account, you confirm that you meet this age requirement. Raire reserves the right to suspend accounts where this requirement is not met.

3. Permitted Items

Sellers may list and sell the following items on the Platform:

• New or pre-owned clothing (women’s and men’s)
• Shoes and footwear
• Bags and accessories
• Jewellery and fashion accessories
• Lifestyle fashion-related items approved by Raire

All items must be authentic, legally owned, and accurately described. Sellers must select an accurate condition for each item from the following options: New with Tags, New without Tags, Like New, Gently Used, Good, or Fair.

4. Prohibited Items

The following items are strictly prohibited on Raire:

• Counterfeit or replica designer goods
• Stolen items or items without proof of ownership
• Illegal goods or regulated products
• Weapons or weapon-related items
• Drugs, narcotics, or controlled substances
• Adult content or services
• Hazardous materials
• Digital-only products or services not approved by Raire
• Any item that violates Nigerian law or applicable international regulations

Raire reserves the right to remove any listing at its sole discretion.

5. Categories and Sizes

When creating a listing, sellers must select from the following categories:

• Women: Tops, Bottoms, Dresses, Co-ords and Sets, Jackets and Outerwear, Loungewear and Sleepwear, Footwear, Accessories
• Men: Tops, Bottoms, Jackets and Outerwear, Streetwear, Suits/Formal, Loungewear, Footwear, Accessories

Sellers must select an appropriate size. Size options vary by category (clothing sizes range from XXS to UK 24; shoe sizes range from EU 35 to EU 49). Sellers who produce the same item in multiple sizes (e.g. small business sellers) may add multiple sizes with individual stock quantities to a single listing.

6. Seller Responsibilities

All sellers must:

• Provide accurate and truthful listing descriptions
• Upload real photographs of items being sold
• Select the correct category, size, and condition for each item
• Ship items to the Raire Hub within stated timeframes
• Deliver items that match listing descriptions
• Respond to buyer inquiries and disputes promptly
• Comply with all applicable laws and regulations

Sellers who produce items in multiple sizes must accurately specify the quantity available for each size. Repeated customer complaints, fraudulent activity, or policy violations may result in suspension or permanent removal from the Platform.

7. Seller Onboarding

Selling on Raire is currently available to Lagos-based sellers only. When setting up a seller account, sellers must provide their personal details and select their area within Lagos. Raire verifies seller information before approving accounts. Expansion to additional states is planned.

8. Authenticity and Anti-Counterfeit Policy

Raire has zero tolerance for counterfeit goods. If a seller is found listing fake or replica items:

• Listings will be removed immediately
• Funds may be withheld
• Account may be suspended or terminated
• Authorities may be notified where required

Raire may request proof of authenticity for designer or high-value items. Buyers purchasing items marked as “Designer” may opt for third-party authentication at checkout for an additional fee.

9. Commission and Fees

Raire charges a commission on each completed sale. The current commission rate is displayed in the app and may be updated from time to time. Raire will notify sellers of any changes to the commission rate in advance. Shipping fees are charged to buyers at checkout and vary depending on the delivery destination.

10. Pricing, Offers, and Purchases

10.1 Buy Button

When a buyer taps “Buy,” the item is added to their bag at the full listed price. A notification confirms the item has been added with options to continue shopping or proceed to checkout.

10.2 Offer System

Buyers may submit offers at a lower price. The following rules apply:

• The minimum offer is 50% of the listed price
• Each buyer can have only one active offer per item at a time
• Sellers can accept, decline, or counter an offer
• A maximum of 3 rounds of countering is permitted per offer
• If the seller does not respond within 48 hours, the offer expires automatically
• If an offer is accepted, the buyer must complete payment within 24 hours or the offer expires
• If any buyer purchases the item at full price, all other pending offers for that item are automatically declined

10.3 Seller View

When a seller views their own listing, they see “Edit Listing” instead of the Buy and Offer buttons.

11. Shipping and Delivery

All items sold on Raire pass through the Raire Hub before being delivered to the buyer. The shipping process works as follows:

• Stage 1: The seller ships the item (or drops it off) to the Raire Hub in Lagos
• Stage 2: Raire performs a quality check and, if applicable, facilitates authentication
• Stage 3: Raire dispatches the item to the buyer via a courier partner

Shipping fees are calculated at checkout based on the buyer’s delivery state. Estimated delivery times vary by destination. Buyers receive tracking updates throughout the delivery process.

12. Payment and Fraud Prevention

All payments must be processed through the Raire Platform via Paystack. Off-platform payments are strictly prohibited. Raire monitors transactions for suspicious or fraudulent activity and reserves the right to hold funds for investigation, cancel transactions, suspend accounts, and report fraudulent activity to relevant authorities.

13. Disputes and Refunds

Buyers may raise disputes within 72 hours of confirmed delivery. Eligible grounds include non-delivery, incorrect item, or item significantly not as described. Raire may intervene in disputes between buyers and sellers. Where a valid claim is established, Raire may issue refunds to buyers and seller payouts may be reversed or withheld. Repeated disputes may lead to account suspension.

14. Reviews

The review system operates as follows:

• After an order is delivered, the buyer receives a push notification and an in-app notification prompting them to leave a review
• Buyers can rate sellers from 1 to 5 stars and optionally write a comment
• Buyers can also access the review screen from their order history at any time
• A buyer can only leave one review per order
• A buyer can only review a seller from whom they have made a purchase
• Reviews cannot be edited after submission
• Buyers may delete their own review, but cannot re-review that item after deletion
• Sellers cannot delete reviews. If a seller believes a review is unfair, they may report it for admin review
• Reviews appear on the seller’s profile and are visible to all users

15. Comments

Users may leave comments on listings. Users can delete their own comments by long-pressing and selecting “Delete.” Users can report another user’s comment by long-pressing and selecting “Report.” Raire reserves the right to remove comments that violate this Policy.

16. Following and Social Features

Users can follow other users on the Platform. Follower and following counts are displayed on user profiles. Users can view a list of their followers and the users they follow. These features are designed to help users discover new sellers and stay updated on new listings.

17. Account Deletion

Users may request account deletion from their profile settings. Before deletion can proceed:

• All active listings must be removed or sold
• All pending orders must be completed or resolved
• All outstanding balances must be settled
• All unresolved disputes must be closed

If any of the above conditions are not met, the user will be prompted to resolve them before proceeding. The deletion process follows the steps described in the Privacy Policy (Section 10.1), including a 30-day deactivation period before permanent deletion.

18. Sold Items

When an item is sold, the listing remains visible on the Platform with a “SOLD” badge overlay. The Buy and Offer buttons are disabled for sold items. For items with multiple sizes, only fully sold-out sizes are marked; remaining sizes stay available for purchase. The SOLD badge appears in search results, on the home page, and on the seller’s profile.

19. Enforcement

Violation of this Policy may result in:

• Removal of listings
• Temporary suspension of account
• Permanent account termination
• Withholding of funds
• Reporting to regulators or law enforcement where required

20. Governing Law

This Policy is governed by and construed in accordance with the laws of the Federal Republic of Nigeria. Any disputes arising under this Policy shall be subject to the exclusive jurisdiction of Nigerian courts.

21. Policy Updates

Raire may update this Policy at any time. Where changes are material, we will notify users via email or an in-app notice. Continued use of the Platform after such notice constitutes acceptance of the updated Policy.

22. Contact

For questions regarding this Acceptable Use Policy: support@raireapp.com

TERMS OF SERVICE

1. Agreement

By accessing or using the Raire Platform (website, mobile application, and related services), you agree to be bound by these Terms of Service (“Terms”), our Privacy Policy, and our Acceptable Use Policy. If you do not agree, do not use the Platform.

2. About Raire

Raire is a peer-to-peer fashion marketplace operated by RAIRE LIMITED, a company registered in Lagos, Nigeria. Raire enables users to buy and sell new and pre-owned fashion items, and enables small fashion businesses to sell directly to buyers. Raire is not a party to transactions between buyers and sellers. Raire acts as a technology platform and facilitator, providing the marketplace, payment processing, quality verification, and logistics coordination.

3. Eligibility

You must be at least 18 years old and capable of forming a binding contract under Nigerian law to use the Platform. By registering, you represent and warrant that you meet these requirements.

4. Accounts

You are responsible for maintaining the confidentiality of your account credentials and for all activity that occurs under your account. You must provide accurate and complete information when creating your account and keep it up to date. You may not create more than one account. Raire reserves the right to suspend or terminate accounts that violate these Terms.

5. Usernames

Usernames must be between 3 and 30 characters and may contain only letters, numbers, underscores, and periods. Usernames are not case-sensitive. Raire reserves the right to reclaim or reassign usernames that are inactive, misleading, or that infringe on the rights of others.

6. Buying on Raire

When you purchase an item on Raire, you enter into a transaction with the seller. Raire facilitates the transaction by processing payment, coordinating quality verification at the Raire Hub, and arranging delivery. Raire does not guarantee the accuracy of any listing. If an item is significantly not as described, you may raise a dispute within 72 hours of confirmed delivery.

7. Selling on Raire

Sellers must comply with the Acceptable Use Policy, including providing accurate descriptions, authentic items, and timely shipping to the Raire Hub. Sellers are responsible for the accuracy of their listings. Raire charges a commission on each completed sale. Seller payouts are processed after the buyer confirms receipt or after any applicable dispute window has closed. Raire reserves the right to withhold payouts where fraud is suspected or a dispute is pending.

8. The Raire Hub

All items sold on Raire are routed through the Raire Hub for quality verification before being dispatched to the buyer. This process is designed to protect buyers by ensuring items match their descriptions. Raire reserves the right to reject items that do not meet quality standards or do not match the listing description. If an item is rejected, the seller will be notified and the item will be returned.

9. Payments

All payments are processed through Paystack. By using the Platform, you agree to Paystack’s terms of service. Raire does not store your full payment card details. Off-platform payments are prohibited and may result in account suspension.

10. Shipping and Delivery

Raire coordinates delivery through third-party courier partners. Shipping fees are charged to buyers at checkout. Estimated delivery times are provided at checkout and may vary. Raire is not liable for delays caused by courier partners, but will work to resolve delivery issues. Risk of loss passes to the buyer upon confirmed delivery.

11. Buyer Protection

Raire provides buyer protection for items that are not delivered, are significantly not as described, or are confirmed as counterfeit. Buyers must raise disputes within 72 hours of confirmed delivery. Raire will review disputes and may issue refunds where appropriate. Buyer protection does not cover items that the buyer simply does not like or that have minor differences from the listing.

12. Intellectual Property

All content on the Platform, including the Raire name, logo, design, and software, is the property of RAIRE LIMITED or its licensors. You may not use, copy, or distribute Raire’s intellectual property without prior written consent. By posting content on the Platform (listings, photos, reviews), you grant Raire a non-exclusive, worldwide, royalty-free licence to use, display, and distribute that content in connection with the operation of the Platform.

13. Prohibited Conduct

You agree not to:

• Violate any applicable law or regulation
• List counterfeit, stolen, or prohibited items
• Provide false or misleading information in listings or profiles
• Manipulate prices, reviews, or search results
• Harass, threaten, or abuse other users
• Attempt to circumvent Raire’s payment system
• Use the Platform for any purpose other than buying and selling permitted items
• Create multiple accounts
• Scrape, crawl, or use automated means to access the Platform without permission

14. Limitation of Liability

To the maximum extent permitted by Nigerian law, Raire’s total liability to you for any claims arising from your use of the Platform shall not exceed the total fees you have paid to Raire in the 12 months preceding the claim. Raire is not liable for indirect, incidental, special, consequential, or punitive damages, including lost profits, data loss, or business interruption.

15. Indemnification

You agree to indemnify and hold harmless RAIRE LIMITED, its officers, directors, employees, and agents from any claims, losses, damages, liabilities, and expenses (including legal fees) arising from your use of the Platform, your violation of these Terms, or your violation of any third-party rights.

16. Disclaimers

The Platform is provided “as is” and “as available.” Raire does not warrant that the Platform will be uninterrupted, error-free, or free from harmful components. Raire does not endorse or guarantee any items listed by sellers. Raire is not responsible for the conduct of buyers or sellers.

17. Termination

Raire may suspend or terminate your account at any time for violation of these Terms or the Acceptable Use Policy. You may delete your account at any time, subject to the account deletion process described in the Privacy Policy and Acceptable Use Policy. Upon termination, your right to use the Platform ceases immediately. Provisions that by their nature should survive termination (including intellectual property, limitation of liability, indemnification, and governing law) will survive.

18. Governing Law and Dispute Resolution

These Terms are governed by the laws of the Federal Republic of Nigeria. Any disputes arising under these Terms shall be subject to the exclusive jurisdiction of Nigerian courts.

19. Changes to These Terms

Raire may update these Terms at any time. Material changes will be communicated via email or in-app notification. Continued use of the Platform after notification constitutes acceptance of the updated Terms. If you do not agree to updated Terms, you must stop using the Platform and delete your account.

20. Severability

If any provision of these Terms is found to be unenforceable, the remaining provisions will continue in full force and effect.

21. Entire Agreement

These Terms, together with the Privacy Policy and Acceptable Use Policy, constitute the entire agreement between you and Raire regarding the use of the Platform.

22. Contact

For questions regarding these Terms of Service:

RAIRE LIMITED

Email: support@raireapp.com

WhatsApp: +234 913 680 9841