Our Privacy Policy For Protecting Your Data

Auction Now (Private) Limited (trading as “AuctionNow”)

Last updated: 19th day of August, 2026

Auction Now (Private) Limited, trading as “AuctionNow” (“AuctionNow”, “the Company”, “we”, “us” or “our”) respects your privacy. This Privacy Policy (this “Policy”) explains how we collect, use, store, share and protect your personal information when you visit our website at https://www.auctionnow.com (the “Website”), use our mobile application (the “App”, together with the Website, the “Platform”), or otherwise interact with us (the “Services”), and what your rights are in respect of that information.

This Policy forms part of, and should be read together with, our Terms and Conditions. Capitalised terms not defined in this Policy have the meanings given to them in the Terms and Conditions.

1. WHO WE ARE AND HOW TO CONTACT US

1.1 Auction Now (Private) Limited, trading as “AuctionNow”, is the data controller in respect of the personal information collected through the Platform. We are a private limited company incorporated under the laws of the Islamic Republic of Pakistan, having our registered office at 107 Fairways Commercial, 1st Floor, DHA Phase 6, Lahore, Pakistan.

1.2 If you have any questions or concerns about this Policy or how we handle your personal information, you may contact us at:

Email: privacy@auctionnow.com / legal@auctionnow.com

Post: Auction Now (Private) Limited, 107 Fairways Commercial, 1st Floor, DHA Phase 6, Lahore, Pakistan

2. INFORMATION WE COLLECT

2.1 We collect information about you when you access or use the Platform, register an Account, communicate with us, subscribe to our Services, or otherwise interact with us. The categories of information we collect are described below.

(a) Information you provide directly to us

When you register, subscribe, post Content, communicate with other Users or contact us, you may provide:

Identity and contact information: full name, gender (if you choose to provide it), date of birth (where required for age verification), CNIC or passport number (where required for KYC), business name and registration number, NTN or sales tax registration number, postal address, billing address, email address, and mobile telephone number;

Account credentials: username and password (passwords are stored only as cryptographic hashes), OTPs, and biometric authentication identifiers (if used);

Profile information: profile picture, business logo, business description, areas of operation, professional credentials, and other information you choose to display on your User profile;

Subscription and billing information: Subscription tier selected, payment method (we do not store full card numbers; these are tokenised by our payment service providers), billing history, and invoicing details;

User Content: listings, Lead requests, quotations, bids, ratings, reviews, messages exchanged with other Users through the Platform, support tickets, and any other Content you submit;

Verification information: documents we require to verify your identity, business, or qualifications (for example, copies of CNIC, NTN certificate, business registration, professional licences);

Communications with us: records of correspondence, support tickets, complaints, and customer service interactions;

Survey, marketing and feedback responses: where you choose to participate in surveys, feedback requests, contests, promotions, or marketing communications.

(b) Information we collect automatically

When you access or use the Platform, we may automatically collect:

Device information: device type, operating system and version, browser type and version, screen resolution, mobile network information, unique device identifiers (such as IMEI, advertising IDs), and language settings;

Log and usage information: IP address, access times, pages or screens viewed, links clicked, referring URL, time spent on the Platform, App version, crash reports, and other diagnostic information;

Location information: approximate location derived from your IP address; and (only with your permission) precise location from your device’s GPS, if you have enabled location services for the App;

Cookies and similar technologies: we and our service providers use cookies, web beacons, pixel tags, conversion APIs, tag management technologies, and software development kits (SDKs) on the Website and within the App, as further described in Clause 9 below;

Transactional and behavioural data: Leads viewed, Leads responded to, Bids submitted (including through the Auto-Bid Engine, where enabled, and the parameters you set on it), conversion patterns, search history within the Platform, ratings given and received, and aggregate engagement metrics.

We may receive information about you from:

Other Users, when they interact with you through the Platform, rate or review you, or report you for breach of our Terms;

Payment service providers, regarding the status of your payments and any fraud or chargeback alerts;

Identity verification and KYC service providers, regarding the outcome of verification checks we have requested;

Public records and credit reference agencies, to the extent permitted by Applicable Law;

Third-party platforms (such as Google, Facebook, LinkedIn) if you choose to sign in or share information with us through those platforms (and only such information as you have authorised those platforms to share with us);

Marketing partners, advertisers and analytics providers, in respect of campaigns or insights about Platform usage.

3. HOW WE USE YOUR INFORMATION

3.1 We use your information for the following purposes:

To provide the Platform and the Services, including creating and maintaining your Account, processing your Subscription, facilitating Leads, Bids and connections between Users (including operating the Auto-Bid Engine in accordance with the parameters you set), hosting your Content, and operating the day-to-day functionality of the Platform;

To process payments, including verifying your billing details, charging Fees, issuing receipts, processing refunds, and managing chargebacks;

To verify identity and prevent fraud, including KYC checks, fraud detection, anti-money-laundering screening, sanctions screening, and ensuring compliance with Applicable Law;

To communicate with you, including sending transactional messages (such as Account, billing, security and service announcements), responding to your enquiries and support requests, and providing customer service;

To send marketing and promotional communications and to measure and improve the effectiveness of our marketing efforts, including through conversion tracking and audience matching with third-party partners, where you have consented to receive these and subject to your right to opt out at any time;

To personalise the Platform, including delivering tailored content, recommendations and Lead matches based on your profile, preferences and Platform activity;

To improve and develop the Platform, including conducting research, analytics, surveys, A/B testing, and developing new features, products and services;

To ensure safety, integrity and security, including monitoring for and investigating abusive, fraudulent or unlawful conduct, enforcing our Terms, and protecting the rights, property and safety of AuctionNow, its Users and the public;

To comply with Applicable Law, including responding to lawful requests from regulatory, tax and law-enforcement authorities, complying with court orders, and meeting our own legal, tax, accounting and audit obligations;

To exercise or defend legal claims, including in actual or anticipated legal proceedings; and

For any other purpose disclosed to you at the time we collect your information, or to which you subsequently consent.

4. LEGAL BASIS FOR PROCESSING

4.1 We process your personal information on one or more of the following bases, as in force from time to time under Applicable Law:

Performance of our contract with you (for example, to provide the Platform and Services for which you have registered and to charge your Subscription);

Your consent (for example, for direct marketing communications, location services, optional cookies, or other processing for which we ask for your specific consent);

Compliance with a legal obligation (for example, KYC verification, sanctions screening, anti-money-laundering checks, tax reporting, and response to lawful requests from authorities);

Our legitimate interests (for example, to ensure the security of the Platform, prevent fraud, improve our Services, manage our business, and pursue legal claims), where those interests are not overridden by your rights and freedoms; and

Protection of vital interests (for example, in emergency situations involving threat to life).

5. HOW WE SHARE YOUR INFORMATION

5.1 We do not sell your personal information. We share your information only in the circumstances described below.

(a) With other Users

Information you publish on your User profile, in listings, in Leads, in Bids and quotations, in messages exchanged with other Users, or in ratings and reviews, is shared with the other Users with whom you interact on the Platform. Once shared, AuctionNow has limited ability to control the further use of that information by recipient Users.

(b) With service providers

We share your information with carefully selected third-party service providers who perform functions on our behalf, including cloud hosting, data storage, payment processing, identity verification and KYC, fraud prevention, analytics, customer support, marketing automation, email and SMS delivery, mapping, and IT infrastructure. These providers are contractually bound to process your information only for the purposes for which we engage them, to maintain appropriate security, and to comply with Applicable Law.

We may share your information with our legal, accounting, audit, tax, banking and other professional advisers in connection with their services to us; and with investors, potential acquirers, lenders, or merger counterparties (and their advisers) in connection with any actual or proposed corporate transaction or financing, subject to appropriate confidentiality obligations.

(d) With authorities

We may disclose your information to regulatory, tax, law-enforcement, judicial or other competent authorities (i) where required by Applicable Law, court order, subpoena or other legal process, (ii) to respond to lawful requests for information, (iii) to enforce our Terms, (iv) to detect, prevent or otherwise address fraud, security or technical issues, or (v) to protect the rights, property and safety of AuctionNow, our Users or the public.

(e) With your consent

We may share your information for any other purpose with your specific consent.

(f) In aggregated or anonymised form

We may share aggregated or anonymised information, which cannot reasonably be used to identify you, with partners, advertisers, researchers, and the public for any purpose.

(g) With third-party partners

We share limited information about your interactions with the Platform, such as Content viewed, pages visited, conversion events (for example, Account registration, RFQ submission, or Bid placement), and hashed identifiers derived from your email address or phone number (which cannot on their own be used to identify you), with third-party partners, for the purposes of measuring the performance of our user activities and building custom or lookalike audiences. You can control this sharing through your cookie preferences.

6. INTERNATIONAL DATA TRANSFERS

6.1 Some of our third-party service providers and infrastructure are located outside Pakistan. Where we transfer your personal information outside Pakistan, we will ensure that the transfer is permitted under Applicable Law and is subject to appropriate safeguards (such as contractual protections, encryption in transit, and selection of providers with international privacy and security certifications), to maintain a level of protection comparable to that available in Pakistan.

7. DATA SECURITY

7.1 We implement technical, organisational and procedural security measures designed to protect your personal information against unauthorised access, alteration, disclosure or destruction. These measures include (without limitation) encryption of data in transit using industry-standard protocols (such as TLS), encryption of selected data at rest, access controls, authentication mechanisms, network security controls, regular security testing, incident response procedures, and personnel training.

7.2 Despite our reasonable efforts, no method of transmission over the internet or method of electronic storage is fully secure. We cannot guarantee absolute security of your information, and your use of the Platform is at your own risk in this respect.

7.3 You play an important role in safeguarding your information. You should keep your Account credentials confidential, use strong passwords, enable available security features such as two-factor authentication, and notify us immediately of any suspected unauthorised access to your Account.

7.4 In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and (where required) the relevant authorities in accordance with Applicable Law.

8. DATA RETENTION

8.1 We retain your personal information for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, tax, accounting, audit, regulatory, reporting or evidentiary requirements, and to exercise or defend legal claims.

8.2 The specific retention periods we apply depend on the category of information, the purpose of collection and the requirements of Applicable Law. As a general guide:

Account data is retained for the duration of your Account and for a period of up to seven (7) years after closure;

Billing and transactional data is retained for the period required under the Income Tax Ordinance 2001, the Sales Tax Act 1990, the Companies Act 2017 and the rules thereunder, generally six (6) years from the end of the relevant financial year;

Messages and User Content are retained for the duration of your Account and for up to twenty-four (24) months thereafter, save where retained for a longer period to comply with Applicable Law or to defend legal claims;

Log and analytics data is typically retained in identifiable form for up to twelve (12) months, and thereafter in aggregated or anonymised form indefinitely;

Marketing data is retained until you withdraw consent or otherwise opt out of marketing communications.

8.3 On expiry of the applicable retention period, we will delete or irreversibly anonymise your personal information, save where Applicable Law requires longer retention or where the information is required for an ongoing legal matter.

9. COOKIES AND TRACKING TECHNOLOGIES

9.1 What cookies are. Cookies are small text files placed on your device when you visit a website. We use cookies and similar technologies (such as web beacons, pixels, SDKs and local storage) on the Website and within the App.

9.2 Categories of cookies we use. We use the following categories:

Strictly necessary cookies, which are essential for the Platform to function (for example, authentication, session management, and security). These cannot be switched off in our systems;

Functional cookies, which remember your preferences (such as language, region, display settings) to enhance your experience;

Analytics cookies, which help us understand how Users interact with the Platform so that we can improve it (for example, Google Analytics, Mixpanel, Firebase);

Advertising and marketing cookies, which we and our partners use to deliver advertisements that are relevant to you, and to measure the effectiveness of our marketing campaigns.

9.3 Your choices. Where the Platform presents a cookie banner or cookie preference centre, you may use it to accept or reject non-essential categories of cookies, and you may change your preferences at any time through the cookie settings made available on the Platform. In addition, and at any time, you may configure your browser or device settings to refuse, restrict or delete cookies and similar technologies, and (in the App) manage tracking through your device’s privacy and advertising settings. Strictly necessary cookies cannot be switched off, as they are essential to the operation of the Platform. Refusing or deleting cookies may affect the functionality of the Platform.

10. YOUR RIGHTS AND CHOICES

10.1 Subject to Applicable Law, you have the following rights in respect of your personal information:

Access: you may request a copy of the personal information we hold about you;

Correction: you may request correction of inaccurate or incomplete personal information;

Deletion: you may request deletion of your personal information, subject to our right to retain information that we are required or permitted to retain under Applicable Law;

Restriction: you may request that we restrict our processing of your personal information in certain circumstances;

Objection: you may object to our processing of your personal information where the processing is based on our legitimate interests or for direct marketing purposes;

Data portability: you may request a copy of your information in a structured, commonly-used, machine-readable format, to the extent technically feasible;

Withdraw consent: where our processing is based on your consent, you may withdraw consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal;

Lodge a complaint: you may lodge a complaint with the competent data protection authority in Pakistan.

10.2 To exercise any of these rights, please contact us at privacy@auctionnow.com. We may need to verify your identity before processing your request. We will respond to your request within the period required by Applicable Law (and, in any case, within thirty (30) days of receipt, unless extension is permitted).

10.3 Marketing opt-out. You may opt out of marketing communications at any time by clicking the “unsubscribe” link in any marketing email, by replying “STOP” to a marketing SMS, or by updating your communication preferences in your Account settings. Transactional and service-related communications cannot be opted out of for as long as you maintain an Account.

11. CHILDREN’S PRIVACY

11.1 The Platform is not directed at children under the age of eighteen (18). We do not knowingly collect personal information from children under eighteen (18). If you are a parent or guardian and believe that a child has provided personal information to us, please contact us at privacy@auctionnow.com and we will take steps to delete such information from our records.

12. THIRD-PARTY LINKS AND INTEGRATIONS

12.1 The Platform may contain links to, or integrations with, third-party websites, applications, plug-ins, and services. We do not control these third parties, and this Policy does not apply to their practices. We encourage you to review the privacy policies of any third party before providing any information.

13. CHANGES TO THIS POLICY

13.1 We may amend this Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will notify you by posting a prominent notice on the Platform, by email, or by in-App notification, not less than seven (7) days prior to the effective date of the change. The date at the top of this Policy indicates when it was last updated.

13.2 Your continued use of the Platform after the effective date of an updated Policy constitutes your acceptance of the updated Policy. Where we consider a change to be material, we may additionally require you to affirmatively re-accept the updated Policy before continuing to use the Platform. If you do not agree to the updated Policy, you should discontinue use of the Platform and may exercise the rights described in Clause 10.

14. GOVERNING LAW AND JURISDICTION

14.1 This Policy shall be governed by, and construed in accordance with, the laws of the Islamic Republic of Pakistan, including the Prevention of Electronic Crimes Act 2016 and any law for the time being in force relating to personal data protection. Subject to the dispute resolution provisions of our Terms and Conditions, the courts at Lahore shall have exclusive jurisdiction in respect of any matter arising out of or in connection with this Policy.

15. HOW TO CONTACT US

15.1 If you have any questions, comments, complaints, or requests regarding this Policy or the processing of your personal information, please contact us at:

Auction Now (Private) Limited (trading as “AuctionNow”)

Attention: Privacy Officer

Email: privacy@auctionnow.com

Post: 107 Fairways Commercial, 1st Floor, DHA Phase 6, Lahore, Pakistan

Thank you for trusting AuctionNow with your information.