In-App Privacy Policy
CUSTOMER_PRIVACY
BAZR S.P.A.
PRIVACY POLICY
Last updated: October 2026.
We at Bazr S.p.A. (hereinafter also “Bazr”, “we”, “us” or “our”) respect and protect the privacy of non-professional users who register on the platform (hereinafter, “Users”), of registered sellers who use it in the course of a business, commercial, craft or professional activity (hereinafter, “Vendors”), and of Users, whether natural or legal persons, who operate on the platform with a significant presence on social media or other online platforms (hereinafter, “Creators”).
In accordance with Regulation (EU) 2016/679 (hereinafter, “GDPR”) and with the national harmonising legislation, Legislative Decree No. 196 of 2003, as amended (hereinafter, “Privacy Code” and, together with the GDPR, “Privacy Laws”), this notice on the processing of personal data (hereinafter, “Privacy Policy”) describes, pursuant to Articles 13 and 14 GDPR, how we collect, use and share Users’ personal data when they register for, access or use our “Services” (described in more detail in the terms and conditions of service, accessible here and hereinafter also referred to as the “T&C”) through the Bazr mobile app (hereinafter, the “App”).
If you take part, as a User, in the online auction sale format organised on the Platform (hereinafter, the “Auction”), governed by the Supplementary Addendum to the General Terms of Purchase on Bazr concerning Online Auction Sales (hereinafter, the “Auction Addendum”), the additional processing operations described in this Privacy Policy in relation to taking part in and possibly winning an Auction will also apply, including identification and, where the relevant conditions are met, customer due diligence (KYC/AML) through the dedicated questionnaire provided by Bazr (hereinafter, the “AML/KYC Questionnaire”).
We consider it essential to inform you fully about the processing of your personal data, so we invite you to read this Privacy Policy in full. For ease of reading, its key points and some useful links are summarised below:
Table of Contents
1. WHAT DATA WE COLLECT AND WHY WE PROCESS IT
2. HOW AND WHY WE SHARE YOUR DATA
3. HOW LONG WE KEEP YOUR PERSONAL DATA
4. CHILDREN’S PERSONAL DATA
5. INTERNATIONAL TRANSFERS
6. YOUR PRIVACY RIGHTS AND CHOICES
7. HOW TO CONTACT US
8. CORPORATE TRANSACTIONS
9. THIRD-PARTY WEBSITES AND SERVICES
10. CHANGES TO THE PRIVACY POLICY
1. WHAT DATA WE COLLECT AND WHY WE PROCESS IT
We collect and process your personal data in order to create, provide, personalise, manage, improve and develop our Services, so as to offer you a safe, interactive, efficient and personalised experience. Below we set out in detail the reasons why we process personal data (i.e. the purposes of processing), the legal bases for such processing, the specific personal data of yours that we process, and the source of that personal data.
a. Processing of personal data necessary for the performance of the contract to which the User is a party
The personal data processed for the purposes listed below are necessary for the proper provision and use of the Services, as governed by the T&C accepted by the User upon registration. Failure to provide this personal data to Bazr would make it impossible for the User to use the Services of the Platform. Bazr has identified the legal basis for the processing as Article 6(1)(b) GDPR.
Why we collect your personal data
What personal data we collect
Where we collect your personal data
Registration on the Platform and creation of an account.
Basic information required to register on the Platform and create the account: first and last name, date of birth, nationality, phone number, e-mail address, username and password.
Information you provide to us.
Collection of additional, optional information to personalise the User’s profile.
Profile picture, home address.
Information you provide to us.
Disclosure of data to the Vendor to intermediate purchase and sale transactions through the Platform (e.g. to allow the Vendor to handle invoicing for the product you purchased, shipping, etc.) and the related follow-up activities (e.g. chargeback, return, withdrawal and warranty return procedures), as well as issuing the related receipt.
Information necessary to intermediate purchase and sale transactions through the Marketplace and the related follow-up activities (e.g. return and withdrawal procedures, etc.): first name, last name, home address, payment card number, expiry date, CVC, billing address and bank account (Bazr will not collect or process the personal data listed above if you use third-party payment systems, e.g. Apple Pay).
Information contained in your chargeback, return, withdrawal or warranty return request.
Information necessary for the Vendor to invoice and ship the products: first and last name, home address, any additional information you consider necessary (delivery instructions, etc.).
Information provided by you and by third parties.
The User’s participation in the online Auction sale format and management of any Award of the Lot, including basic identification of the Winning Bidder through submission of a copy of their identity document, as a condition precedent to the Shipment of the awarded Lot.
Information relating to the Auction and the Award: account ID, Auction/live ID, awarded Lot, Award price, Award date; copy of the Winning Bidder’s valid identity document.
Information you provide to us.
Publication of content on the Platform.
Content that can be published: images and videos.
Information you provide to us.
Interactions, live chats and comments on content on the Platform.
Live chats, comments and reviews: username, profile picture and the information entered in each comment.
Information you provide to us.
Indexing of Platform content based on interactions and on how in-app Services are used.
Activity information, i.e. information about what you view and the User’s clicks, likes and follows, for the sole purpose of indexing content.
Information collected automatically.
In-app notice about content or Creators that the User has asked to follow through the “notify me” feature.
Information for sending e-mail notifications and in-app notices (according to the notification settings and preferences set by the User in the Profile section of the App): username, e-mail, first and last name.
Information you provide to us.
In-app notice and/or e-mail notification about purchase orders for the Vendor’s products and services and their fulfilment status.
Registration and administrative notifications for the App, as well as announcements of changes to the App, the T&C, this Privacy Policy or other legal documentation, by e-mail and/or in-app notice.
Management of customer support services and related notifications and notices by e-mail.
Information for managing customer support services: username, description of the problem encountered on the Platform, e-mail.
Information you provide to us.
Management of reports of violations of Bazr’s policies.
Information necessary to manage reports of violations of the policies published on the Bazr website [●] (hereinafter, the “Website”) and accessible via the App, such as information on conduct contrary to the T&C and all Bazr policies, and in particular: (i) non-payment; (ii) providing false data during registration; (iii) making the account available to unauthorised third parties; (iv) publishing commercial listings in breach of the T&C; (v) registering multiple accounts and using them in breach of the T&C; (vii) sending spam messages to other Users.
Information you provide to us.
Verification of violations of Bazr’s policies and adoption of any measures (such as warnings or account suspension).
Information we obtain from third parties.
b. Processing of personal data to comply with legal obligations to which Bazr is subject
Bazr is subject to laws and regulations that require it to collect, use and retain your personal data in certain ways. Failure to provide this personal data to Bazr would make it impossible for the User to use the Services of the Platform. Pursuant to Article 6(1)(c) GDPR, the legal basis for the processing listed below is compliance with a legal obligation to which Bazr is subject.
Why we collect your personal data
What personal data we collect
Where we collect your personal data
Management of reports of violations of applicable law.
Information necessary to handle cases of violations of applicable law (for example, arising from content monitoring carried out as required by law).
Information you provide to us.
Verification of violations of legal and regulatory obligations and adoption of any measures (such as warnings or account suspension).
Information we obtain from third parties or collect automatically
Compliance with accounting and/or tax obligations.
Information relating to tax and/or accounting obligations: any information Bazr needs to comply with its legal and tax obligations.
Information you provide to us.
Identification of the Winning Bidder under public security rules on auctions (Article 115 et seq. of Royal Decree No. 773 of 18 June 1931, Consolidated Law on Public Security – TULPS) and, where the relevant conditions are met (transactions worth EUR 10,000 or more, including split or linked transactions, if Bazr is an obliged entity under Legislative Decree No. 231 of 21 November 2007), customer due diligence (KYC/AML) through the AML/KYC Questionnaire.
Copy of the Winning Bidder’s identity document. Where required, data collected through the AML/KYC Questionnaire: identification data of the Winning Bidder and, where applicable, of the party on whose behalf they act (natural person, company, entity, trust) and the related authority to represent; information on whether they, their family members or close associates are politically exposed persons; data of the third-party payer, if payment is not made by the Winning Bidder; purpose and nature of the transaction and of any linked transactions; source of funds and, where required, source of wealth; country of tax residence and links with high-risk countries; supporting documentation attached to the Questionnaire.
Information you provide to us, including with regard to third parties for whom you are the collection channel (e.g. the party on whose behalf you act, a third-party payer): Bazr processes this information as data controller, by virtue of its legal obligations.
c. Processing of personal data for Bazr’s legitimate interests
Following a careful balancing test, we have established that your rights and freedoms do not override, and are not in any way, even potentially, limited and/or harmed by, the processing activities described below. Accordingly, the legal basis on which we will process your personal data in the cases described below is the pursuit of our legitimate interest, pursuant to Article 6(1)(f) GDPR.
Why we collect your personal data
What personal data we collect
From whom/where we collect your personal data
Possible processing of personal data for the purpose of defending legal claims.
Information concerning the protection of the right of legal defence: information necessary to bring or allow Bazr’s defence in judicial and out-of-court proceedings.
Information you provide to us.
Activities to maintain the security of the Platform and the Marketplace and to prevent fraud.
App and device information: information about the device and operating system used; other device characteristics or identifiers (e.g. plugins, the network you connect to); IP address. Diagnostics and troubleshooting information: information about the performance of our Services when you use them, i.e. diagnostic and performance information about the Service, crash data, App performance logs and error messages or reports.
Information collected automatically.
Analysis to improve the Platform and the Services.
App and device information: information about the device and operating system used; other device characteristics or identifiers (e.g. plugins, the network you connect to); IP address.
Information collected automatically.
d. Processing of personal data based on your consent
Bazr will process your personal data for the purposes described below only and exclusively with your specific, free and informed consent. You may withdraw your consent at any time as described in Section 6 of this Privacy Policy. In light of the above, the legal basis for the processing listed below is your prior, specific and informed consent, pursuant to Article 6(1)(a) GDPR. Providing your personal data for the purposes described below is optional; if you refuse, Bazr will be unable to pursue those purposes, but this will in no way affect your ability to use our Services.
Why we collect your personal data
What personal data we collect
From whom/where we collect your personal data
Profiling in order to offer, by e-mail and/or in-app, content in line with the interests and preferences shown by the User on the Platform.
Information used for User profiling: first and last name, date of birth, nationality, phone number, e-mail address, username, home address, activity information, i.e. information about what you view and the User’s clicks, likes and follows.
Information you provide to us and information collected automatically.
Requests to take in-app surveys and give customer satisfaction feedback on the Platform and on the products and/or services offered on it.
Information provided by the User in response to surveys and customer satisfaction feedback requests.
Information you provide to us.
Transfer of your contact details to the Vendor so that the Vendor can contact you to promote its products and services.
Information transferred by Bazr to the Vendor, at the User’s request following an expression of interest (i.e. consent) in one of the Vendor’s products, so that the User can be contacted by the Vendor: username, first name, last name, e-mail, phone number.
Information you provide to us.
Device geolocation.
Location of the User’s device.
Information collected automatically after the User enables the relevant feature on the device.
Commercial sponsorship through e-mail communications about content on Bazr (e.g. live streams) and/or Vendors’ products/services.
Information for sending e-mail notifications and in-app notices: username, e-mail, first and last name.
Information you provide to us.
e. Processing of anonymised data
Anonymised data is information that has been altered, through a data processing technique, so that it can no longer be linked to an identified or identifiable natural person. The GDPR does not apply to the processing of such anonymised data.
Bazr may use anonymised or aggregated data for various purposes, for example for business purposes, including to better understand the needs and behaviour of the User base, improve the Platform, carry out business intelligence and marketing activities, and detect security threats.
Please note that, except for this Section, none of the other provisions of the Privacy Policy apply to anonymised and/or aggregated data.
2. HOW AND WHY WE SHARE YOUR DATA
a. We disclose some of your personal data to Vendors
The personal data we process and collect may be transferred to third parties registered on our Platform with a Vendor account. In particular, Bazr will disclose your personal data to the Vendor:
For these processing activities, Vendors will act as independent data controllers.
b. We also disclose your personal data to other parties
Bazr works with and relies on carefully selected service providers, partners and other third parties that support us in providing our Services. For this reason, we may share some information about you with these third parties. In particular:
Privacy role of the party
Types of third-party providers we work with
What data we share
We work with providers that support us in providing our Services. When we share information with these providers, we make sure that they process your personal data in accordance with our instructions and terms. These parties act as data processors pursuant to Article 28 GDPR. To obtain a full list of data processors, you can write to [email protected].
Basic User information, additional identification information, information on use of the Platform, transaction information, additional information you provide.
Third parties acting as independent data controllers.
3. HOW LONG WE KEEP YOUR PERSONAL DATA
We retain your personal data as needed to provide our Services, comply with legal obligations or protect our interests or those of others. Bazr has adopted internal retention policies that set out how long and how personal data is retained for each processing activity, taking into account, for example, the need for processing to ensure that you can use our Services properly, compliance with any legal obligations requiring us to retain your personal data, or the need to retain it to ensure the security, protection and integrity of our Services.
In line with these considerations, the retention periods for personal data in relation to the purposes listed above are as follows:
4. CHILDREN’S PERSONAL DATA
Except for the Services related to intermediating the purchase and sale of products and/or services, which are intended for persons aged 18 or over, the App and the Services are not intended for persons under the age of 16, and we do not knowingly request or collect any information about persons under 16. Despite Bazr’s efforts to monitor and prevent the registration of such Users, it is not possible to guarantee that no Users under the age of 16 are registered. If we suspect that you are under 16, we will ask you for further proof of your age and, if you do not respond or it is established that you are under 16, we will immediately suspend your account and then close it, deleting the related personal data.
If you hold parental responsibility for a User under the age of 16 who is registered on the Platform, please write to [●] so that we can immediately suspend and then close the account, deleting the related personal data.
5. INTERNATIONAL TRANSFERS
Bazr informs you that personal data may also be transferred to countries outside the European Union or the European Economic Area (so-called Third Countries) that are recognised by the European Commission as providing an adequate level of personal data protection or, otherwise, only if all Bazr providers located in the Third Country contractually guarantee a level of personal data protection adequate to that of the European Union (e.g. by signing the standard contractual clauses adopted by the European Commission) and the exercise of your rights is always ensured.
6. YOUR PRIVACY RIGHTS AND CHOICES
With regard to the processing of personal data, you may exercise the rights set out in Articles 15 to 22 GDPR. In particular, where applicable and under the conditions and in the manner provided for by the GDPR, you have the right to exercise:
If you believe that the processing of your personal data infringes the GDPR, you also have the right to lodge a complaint with the Italian Data Protection Authority (Garante) pursuant to Article 77 GDPR, following the instructions published on the official website of the Garante per la protezione dei dati personali (www.garanteprivacy.it).
7. HOW TO CONTACT US
The data controller is Bazr S.p.A. (VAT No. 17122741006), with registered office at Viale Bruno Buozzi, 64, 00197,
Rome, Italy.
If you have any questions or concerns about this Privacy Policy, wish to exercise any of the rights described above, or have a complaint, please contact us at [email protected].
8. CORPORATE TRANSACTIONS
If Bazr is acquired by or merges with another company, transfers some or all of its assets to a third party, or in the event of bankruptcy or winding-up of the business, your personal data may be transferred to an acquiring company or a third party, including in anticipation of or in connection with the due diligence carried out before such business transactions, within the limits and with the safeguards provided for by applicable law. In any case, you will be promptly informed of any corporate transaction so that you can decide whether to close your profile or continue to use the Services.
9. THIRD-PARTY WEBSITES AND SERVICES
While using the Platform, you may come across links to third-party websites and services. This Privacy Policy does not cover any processing of personal data carried out by such third parties. Bazr has no control over, and no responsibility for, any processing of personal data carried out by third parties through their websites and/or services. For more information on processing carried out by third parties, please refer to their privacy policies.
10. CHANGES TO THE PRIVACY POLICY
We are constantly working to improve our Services, so we may need to amend this Privacy Policy from time to time by publishing all changes on this page and, where appropriate, we will give you reasonable notice of any material changes before they take effect or as otherwise required by law. The date of the last update of this Privacy Policy is shown at the top of this page.