PRIVACY POLICY

1. Who We Are

Controller: The Art Exchange Limited (RC 714963). Registered address: 10 Ilabare Avenue, Ikoyi, Lagos, 106104, Nigeria.
Contact: privacy@wwwtheae.com

This Privacy Policy explains how we collect, use, disclose and protect personal information when you use our Digital Platforms, contact us, subscribe to updates, or buy/sell Items through us.

2. Scope

This Policy applies to website visitors, enquirers, prospective and actual buyers/sellers, and newsletter subscribers. Additional terms may apply to particular services and will be provided where relevant.

3. Personal Data We Collect

Identity data: name, title, date of birth, nationality, government identifiers (where required by KYC law).
Contact data: email, phone, postal address.
Transaction data: enquiries, invoices, payments, delivery details.
Verification data: KYC/AML information (identity documents, proof of address, source of funds/wealth).
Technical data: IP address, device identifiers, logs, cookies (see Cookies Notice).
Marketing preferences and communications.

4. How We Use Personal Data & Lawful Bases

To respond to enquiries and provide services (performance of a contract or steps prior to contract).
To conduct due diligence and comply with law (legal obligation; public interest in AML/CTF).
To operate, secure and improve the Digital Platforms (legitimate interests).
To send updates and marketing (consent where required; otherwise legitimate interests with opt-out).
To protect our rights, users and property (legitimate interests; legal claims).
We will flag where we require personal data to comply with law or perform a contract; failure to provide it may prevent us from proceeding.

5. Sharing & International Transfers

We share personal data with:

(a) service providers (IT hosting, email, payments, KYC vendors, logistics and insurers);

(b) professional advisers;

(d) authorities where required by law. Where data is transferred outside Nigeria, we will adopt appropriate safeguards (e.g., contractual protections) consistent with applicable data-protection laws.

6. Retention

We retain personal data only for as long as necessary for the purposes above, including to meet legal, accounting or reporting requirements.

Enquires and marketing-related contact information are retained for a period of seven years. Transaction records and know-your-customer documentation are retained for a period of seven years from the end of the relevant relationship, or for a longer period where retention is required under applicable anti-money-laundering or financial regulations.

7. Security

We implement appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access.

8. Your Rights

Subject to applicable law, you may have rights to access, rectify, erase, restrict or object to processing, and to data portability. Where processing is based on consent, you may withdraw consent at any time. To exercise rights, contact legal@wwwtheae.com You may also lodge a complaint with the Nigeria Data Protection Commission (NDPC) or your local authority.

9. Children

Our services are not intended for minors. We do not knowingly collect personal data from persons under 18 without appropriate consent. If you believe a child has provided us personal data, contact us to request deletion.

10. Marketing & Cookies

You can opt-out of marketing at any time by using the unsubscribe link or contacting us. We use cookies and similar technologies; see our Cookies Notice for details and manage your choices via the cookie banner.

11. Changes to this Policy

We may update this Policy from time to time. The Effective Date above indicates the latest version.

12. Contact

Questions about this Policy or your data rights: privacy@www.theae.com. General queries: info@wwwtheae.com

LAST UPDATED: 04/02/2026