1. Introduction

Updated on: 08/07/2025

BaloTrade Global Ltd (“BaloTrade”, “we”, “us”, or “our”) is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, retain, and safeguard your personal information across our digital platforms.

This policy applies to all services, applications, tools, and websites offered by BaloTrade where this Privacy Policy is referenced, regardless of how you access or use them — including through mobile devices or third-party platforms.

By accessing or using our Services, or by registering with us, you confirm that you have read and understood this Privacy Policy and agree to our collection and use of your information in accordance with this policy and our [Terms and Conditions].

This Privacy Policy is governed by the laws of the Federal Republic of Nigeria, where BaloTrade is legally registered as BaloTrade Global Ltd with company registration number RC 1457510. BaloTrade is the data controller responsible for your personal information collected through our services.

2. Changes to This Privacy Policy

We may update or modify this Privacy Policy at any time to reflect changes in our data practices, technology, legal requirements, or business operations.

When we make significant changes, we will revise the "Updated on" date at the top of this page and, where appropriate, notify you via email or display a notice on our website.

All modifications will become effective immediately upon posting. Your continued use of our Services after any updates constitutes your acceptance of those changes. We encourage you to review this Privacy Policy regularly to stay informed about how we are protecting your information.

3. Information We Collect

We collect different types of personal and non-personal information from users depending on how you interact with our platform. The information we collect may include:

A. Information You Provide Directly

• Account Registration: Full name, email address, phone number, business name, country, address, and password.
  
  

• Business Verification (for Suppliers): Company registration number, tax identification number, business license, product categories, and identity documents.
  
  

• Payment Information: Bank account details, billing address, credit/debit card information (processed via third-party payment processors).
  
  

• Communications: Any information you provide when contacting support, submitting inquiries, or participating in surveys.
  
  

• Marketing Preferences: Your opt-in/out status for newsletters and marketing campaigns.
  
  

B. Information Collected Automatically

When you access or use our services, we automatically collect certain data, including:

• IP address and geolocation data
  
  

• Browser type and version
  
  

• Device type, model, and operating system
  
  

• Access times and pages visited
  
  

• Clickstream data and user interactions on the site
  
  

• Referral URLs and other diagnostic data
  
  

C. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar technologies to enhance your experience, provide security, analyze traffic, and deliver personalized content and ads. For more information, see our [Cookie Policy].

D. Information from Third Parties

We may also collect information about you from:

• Social media platforms (if you sign in via Facebook, Google, etc.)
  
  

• Business directories and public records (for supplier verification)
  
  

• Third-party analytics or marketing platforms
  
  

• Advertising networks
  
  

4. How We Use Your Information

We process your personal data for a variety of business purposes in accordance with applicable laws. The primary purposes include:

A. To Provide and Manage Our Services

• Register and manage your BaloTrade account
  
  

• Facilitate B2B trade connections between buyers and suppliers
  
  

• Enable product listings, orders, and communications between users
  
  

• Process payments and manage billing
  
  

B. To Ensure Security and Compliance

• Detect and prevent fraud, unauthorized access, or illegal activity
  
  

• Enforce our Terms and Conditions and other legal policies
  
  

• Comply with anti-money laundering (AML), tax, or legal obligations
  
  

C. To Improve and Personalize Services

• Analyze usage trends to enhance platform performance
  
  

• Customize content, offers, and recommendations based on user behavior
  
  

• Conduct surveys, market research, or user satisfaction feedback
  
  

D. To Communicate with You

• Respond to inquiries and provide customer support
  
  

• Notify you of account activity, platform updates, or policy changes
  
  

• Send transactional messages, newsletters, or promotional campaigns (only with consent, where required)
  
  

E. For Legal and Business Operations

• Retain business records as required by Nigerian corporate or tax laws
  
  

• Facilitate internal auditing, troubleshooting, and operational improvements
  
  

• Support a potential merger, acquisition, or asset sale
  
  

5. Legal Basis for Processing Personal Data

BaloTrade processes your personal data in accordance with applicable data protection laws. The legal bases for processing include:

A. Contractual Necessity

We process your personal information to fulfill our contractual obligations to you. This includes:

• Registering and maintaining your account
  
  

• Facilitating trade interactions, messaging, and order fulfillment
  
  

• Processing transactions and handling customer service inquiries
  
  

B. Legitimate Interests

We process your data for our legitimate business interests, such as:

• Improving and personalizing our services
  
  

• Preventing fraud and ensuring platform security
  
  

• Analyzing user behavior for business insights
  
  

• Sending service-related communications
  
  

We only rely on this basis when our interests do not override your privacy rights.

C. Legal Obligations

We process personal data to comply with Nigerian and international laws, including:

• Tax reporting and accounting
  
  

• Anti-money laundering and fraud detection
  
  

• Consumer protection laws
  
  

• Corporate recordkeeping requirements
  
  

D. Consent

In certain cases, we rely on your explicit consent to process data. For example:

• Sending promotional or marketing emails
  
  

• Collecting optional profile data
  
  

• Using cookies for behavior-based advertising
  
  

You can withdraw your consent at any time by updating your preferences or contacting us.

6. Disclosure of Your Information

We do not sell your personal data. However, we may disclose your information in the following cases:

A. With Service Providers

We may share your data with trusted third-party service providers who support us in:

• Payment processing and financial services
  
  

• Hosting, cloud storage, and IT infrastructure
  
  

• Identity verification and KYC compliance
  
  

• Marketing and analytics services
  
  

• Logistics, shipping, and customs services
  These providers are contractually obligated to handle your data securely and only for the specified purposes.
  
  

B. With BaloTrade Affiliates

We may share your information with subsidiaries or affiliates of BaloTrade Global Ltd for:

• Platform operations and support
  
  

• Regional service delivery
  
  

• Business continuity and internal management
  
  

C. For Legal Compliance

We may disclose data to law enforcement, courts, regulators, or other authorities:

• When required by law or legal process
  
  

• To respond to claims or protect legal rights
  
  

• To enforce our Terms and Conditions or prevent fraud
  
  

D. During Business Transfers

If BaloTrade undergoes a merger, acquisition, restructuring, or asset sale, your information may be transferred to the acquiring entity under appropriate confidentiality agreements.

E. With Your Consent

Where legally required, we will ask for your consent before disclosing your personal data to third parties not covered by this Privacy Policy.

7. Data Retention

BaloTrade retains your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

We retain data to:

• Maintain and manage your user account
  
  

• Complete ongoing transactions
  
  

• Resolve disputes and enforce agreements
  
  

• Comply with legal and regulatory obligations (e.g., tax, anti-money laundering)
  
  

• Maintain accurate business and financial records
  
  

• Improve service performance through historical data analysis
  
  

Once your data is no longer necessary for any of the above purposes, we will securely delete, anonymize, or isolate it from further processing.

If you request deletion of your personal information, BaloTrade will honor the request in accordance with applicable law, subject to data that must be retained for legal, regulatory, or legitimate business purposes.

8. International Data Transfers

As a global B2B platform, BaloTrade may store or process your Personal Data on servers located in multiple jurisdictions. This means your information may be transferred to, stored in, and processed in countries outside your own, including countries that may not offer the same level of data protection.

A. Transfers Outside Nigeria

Since BaloTrade operates internationally, your data may be transferred to third-party service providers, affiliates, or cloud infrastructure providers located outside Nigeria, including in the European Union (EU), Asia, or the United States.

When such transfers occur, we ensure that:

• Appropriate legal safeguards are in place (such as standard contractual clauses approved by regulatory authorities);
  
  

• The recipients are contractually obligated to protect your Personal Data in accordance with our Privacy Policy and applicable data protection laws;
  
  

• Data transfers are limited to what is necessary for legitimate business purposes.
  
  

B. Your Consent

By using our Services, you explicitly consent to the transfer of your data to jurisdictions that may not offer the same level of protection as your country of residence, provided adequate security measures are applied.

9. Security Measures

BaloTrade takes data security seriously and employs a variety of administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, misuse, or destruction.

Key Safeguards Include:

• Encryption of sensitive data in transit and at rest
  
  

• Firewall and intrusion detection systems to prevent unauthorized access
  
  

• Regular security audits and vulnerability assessments
  
  

• Access controls and authentication procedures for data access by personnel
  
  

• Ongoing security training for staff and contractors handling personal data
  
  

While we implement robust security measures, no method of transmission over the Internet or method of electronic storage is 100% secure. We therefore cannot guarantee absolute security. You are responsible for keeping your login credentials secure and confidential.

If you believe your account or interaction with BaloTrade is no longer secure, please notify us immediately at: support@balotrade.com

10. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights regarding your personal information held by BaloTrade:

A. Access and Correction

You may request access to your personal information and request corrections to any inaccuracies.

B. Data Deletion

You may request that we delete your personal data where it is no longer necessary or required by law.

C. Objection and Restriction

You may object to or request restrictions on the processing of your personal data under certain circumstances, particularly where we rely on legitimate interests as our legal basis.

D. Data Portability

You may request a copy of your personal data in a structured, commonly used, and machine-readable format.

E. Consent Withdrawal

If we rely on your consent for any processing, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

F. Marketing Preferences

You can opt out of receiving promotional emails by clicking the “unsubscribe” link in our emails. You may also update your preferences in your account settings or by contacting us directly.

To exercise any of these rights, please contact us at: support@balotrade.com

We will respond to your request in accordance with applicable data protection laws. We may ask for verification of identity before processing your request.

11. Cookies and Tracking Technologies

BaloTrade uses cookies and similar tracking technologies to improve user experience, provide personalized content, and analyze user behavior on our platform.

A. What Are Cookies?

Cookies are small data files stored on your browser or device when you visit a website. They are widely used to make websites function properly or more efficiently, and to provide information to the site owners.

B. Types of Cookies We Use:

• Essential Cookies: Necessary for the basic functionality of the Site, including access to secure areas.
  
  

• Analytical/Performance Cookies: Help us understand how visitors interact with our Site (e.g., Google Analytics).
  
  

• Functional Cookies: Enable the Site to remember choices you make (e.g., your language preference).
  
  

• Targeting/Advertising Cookies: Used to deliver relevant ads to you, and to measure the effectiveness of ad campaigns. We may share this data with third-party advertising platforms.
  
  

C. Your Choices:

You can control and manage cookies in your browser settings. You may also opt out of certain advertising cookies via tools such as:

• Network Advertising Initiative (NAI)
  
  

• YourAdChoices
  
  

Note: Disabling cookies may affect the functionality of some parts of the BaloTrade platform.

12. Third-Party Links and Services

Our Services may contain links to third-party websites, services, or applications that are not operated or controlled by BaloTrade. These include but are not limited to:

• Payment gateways
  
  

• Logistics providers
  
  

• External authentication services (e.g., Google, Facebook)
  
  

• Embedded content (e.g., YouTube videos, external forms)
  
  

BaloTrade is not responsible for the privacy practices or content of these third parties. We encourage you to review their privacy policies before providing them with your personal data.

Embedded Third-Party Services

Some services may be embedded within the BaloTrade platform but are still operated by third parties. For example, embedded maps, chatbots, or plug-ins.

By interacting with such services, your data may be collected by the external provider under their own privacy policy.

13. Legal Basis for Processing Personal Data

We process your Personal Data based on one or more of the following legal grounds, as permitted under applicable laws such as the Nigeria Data Protection Act and global standards like the GDPR:

A. Contractual Necessity

Processing your information is necessary to perform the contract between you and BaloTrade — for example, to:

• Create and manage your user account;
  
  

• Fulfill your orders;
  
  

• Provide support services.
  
  

B. Legal Obligations

We may process your Personal Data to comply with legal requirements such as:

• Tax or regulatory obligations;
  
  

• Anti-fraud or anti-money laundering (AML) checks;
  
  

• Court orders or legal investigations.
  
  

C. Legitimate Interests

We may process your data where it is necessary for our legitimate business interests — unless your rights and interests override those. Legitimate purposes include:

• Improving our platform;
  
  

• Sending you service-related updates;
  
  

• Preventing fraud and abuse;
  
  

• Analyzing usage patterns.
  
  

D. Consent

In specific cases (e.g. marketing or newsletter subscriptions), we will ask for your clear and express consent before collecting or using your Personal Data. You can withdraw your consent at any time by contacting us at support@balotrade.com.

1. Automated Decision-Making and Profiling

We may use automated tools or algorithms to help make decisions regarding user accounts, such as identifying potentially fraudulent behavior, determining account eligibility, or improving platform recommendations. These processes are designed to protect our platform and ensure fair use.

You have the right to request information about the logic involved in any automated decisions made about you, as well as the significance and potential consequences of those decisions. If you believe such profiling has affected you unfairly, you may request a human review by contacting us at support@balotrade.com.

2. Do Not Track (DNT) and Global Privacy Control Signals

Some web browsers allow users to send a "Do Not Track" (DNT) signal. BaloTrade does not currently respond to DNT signals or similar mechanisms, as there is no industry-standard approach to interpreting them.

However, we respect browser-based global privacy control (GPC) signals in jurisdictions where required by law. If you are using a supported browser and enable GPC, we will make reasonable efforts to interpret your preferences accordingly.

3. Information Collected from Third-Party Sources

In addition to data you provide directly, we may collect business-related information about you from third-party sources, including trade show directories, publicly available databases, business partners, and commercial information vendors. This helps us verify supplier legitimacy, complete business profiles, and offer better services.

If you believe we’ve collected your business or personal information from a third party and you wish to request its deletion or correction, please contact us at support@balotrade.com.

4. Cookie Policy Summary (https://www.balotrade.com/cookie-policy)

BaloTrade uses cookies and similar technologies to improve user experience, provide analytics, and deliver personalized content and ads. By using our site, you agree to our use of cookies as described in our separate [Cookie Policy].

We recommend reviewing the full Cookie Policy to understand the types of cookies we use, their purpose, and how to manage your preferences.

5. Country/Region-Specific Rights

BaloTrade is based in Nigeria, but we may process data from users in other countries. Users from certain regions, such as the European Union or California, may have additional data rights under their local laws.

• EU residents may have enhanced rights under the GDPR, including the right to data portability and to object to certain types of processing.
  
  

• California residents may have specific rights under the CCPA/CPRA, including the right to know what personal data is collected and to opt out of the sale of personal data.
  
  

You may exercise these rights by contacting us via the “Contact Us” page or emailing support@balotrade.com.