1. Who We Are

Wacaracha is an independent online project operated by Ruslan Korolev, an individual located in Botswana.

This Privacy Policy explains how Wacaracha ("Wacaracha", "we", "us" or "our") collects, uses, stores, shares and protects personal information when you use wacaracha.com, related domains, applications, interfaces and services (collectively, the "Service").

For purposes of applicable data-protection law, Ruslan Korolev is generally the controller of personal data processed through Wacaracha unless otherwise stated.

2. Scope of This Policy

This Privacy Policy applies to personal information processed in connection with the Service.

It does not govern independent websites, sellers, buyers, advertisers, payment providers, social networks or other third-party services merely because they are linked from or accessible through Wacaracha.

3. Information You Provide

Depending on how you use the Service, we may collect information such as:

• name or display name;
• email address;
• telephone number;
• account credentials;
• country, city or region;
• preferred language;
• profile information;
• company or seller information;
• listing information;
• product or service descriptions;
• prices and commercial offer information;
• photographs, videos and other uploaded content;
• contact details that you choose to publish;
• messages and communications sent to Wacaracha;
• support requests;
• abuse, scam or illegal-content reports;
• intellectual-property complaints;
• information submitted when appealing a moderation decision; and
• other information you voluntarily provide.

4. Public Information

Wacaracha is a public listing and discovery platform. Information that you deliberately publish as part of a public listing may be visible to:

• other Wacaracha users;
• people who are not logged in;
• search engines;
• third-party indexing services;
• country-specific or language-specific versions of Wacaracha; and
• technical services used to distribute or display Wacaracha content.

You should not publish personal information that you do not want to be publicly available.

Removing information from Wacaracha may not immediately remove copies already indexed, cached or stored by independent third parties outside our control.

5. Information Collected Automatically

When you use the Service, certain technical information may be collected automatically, including:

• IP address;
• browser type and version;
• device type;
• operating system;
• language preferences;
• referring and destination pages;
• pages viewed;
• search activity;
• approximate location derived from IP address;
• dates and times of access;
• session identifiers;
• cookies and similar identifiers;
• error and diagnostic logs;
• security events;
• fraud-prevention signals; and
• information about your interaction with the Service.

6. Information From Third Parties

We may receive personal information from third parties when you use a feature that connects Wacaracha with another service.

Examples may include:

• authentication providers;
• email and communications providers;
• hosting and infrastructure providers;
• security and fraud-prevention providers;
• analytics providers;
• people reporting abuse, fraud or illegal content;
• intellectual-property rights holders;
• other users involved in a complaint or dispute; and
• competent public authorities where permitted or required by law.

7. Why We Use Personal Information

We may process personal information to:

• create and maintain user accounts;
• publish and display listings;
• provide search, localization and language features;
• allow users to manage their content;
• respond to support requests;
• send account, security and operational notices;
• protect accounts and infrastructure;
• detect spam, scams, fraud and abuse;
• moderate content and enforce our Terms of Use;
• review illegal-content and abuse reports;
• handle moderation appeals;
• investigate security incidents;
• prevent misuse of the Service;
• comply with applicable law;
• respond to lawful requests from competent authorities;
• establish, exercise or defend legal claims;
• improve reliability, usability and functionality of the Service; and
• understand how the Service is used.

8. Legal Bases for Processing

Where applicable data-protection law requires a legal basis for processing, we may rely on one or more of the following:

• Performance of a contract: where processing is necessary to provide the Service you requested.
• Legitimate interests: where processing is reasonably necessary to operate, secure, improve and protect Wacaracha, prevent fraud or enforce our rules, provided those interests are not overridden by applicable rights.
• Legal obligations: where processing is necessary to comply with applicable law or a binding legal requirement.
• Consent: where applicable law requires consent, including for certain optional cookies, analytics technologies or communications.
• Protection of rights and safety: where legally permitted and reasonably necessary to protect users, investigate serious abuse, preserve evidence or defend legal claims.

9. Cookies and Similar Technologies

Wacaracha may use cookies, local storage and similar technologies.

These technologies may be used for:

• authentication;
• session management;
• security;
• fraud prevention;
• language and country preferences;
• remembering user settings;
• analytics;
• performance monitoring; and
• other functions necessary to operate and improve the Service.

Where applicable law requires consent before using non-essential cookies or similar technologies, Wacaracha will request that consent.

10. How We May Share Personal Information

We do not sell personal information simply because you use Wacaracha.

Personal information may nevertheless be shared in the following circumstances:

10.1 Public Listings

Information that you deliberately publish as part of a public listing may be displayed publicly.

10.2 Service Providers

We may use service providers to operate the Service, including providers of:

• hosting and cloud infrastructure;
• content delivery networks;
• email delivery;
• authentication;
• security;
• fraud prevention;
• analytics;
• error monitoring;
• technical support; and
• communications infrastructure.

These providers may process information as necessary to provide their services.

10.3 Legal and Safety Reasons

We may preserve or disclose information where required or permitted by applicable law, including where reasonably necessary to:

• comply with legally valid requests or orders;
• respond to competent authorities;
• investigate fraud, scams or serious abuse;
• protect users from serious harm;
• protect the security of Wacaracha;
• enforce our Terms of Use; or
• establish, exercise or defend legal claims.

10.4 Transfer of the Project

If Wacaracha is transferred to a company, reorganized, sold or otherwise transferred to another operator, information associated with the Service may be transferred as part of that transaction, subject to applicable law.

11. International Data Transfers

Wacaracha is designed as an international service. Users, infrastructure and service providers may be located in different countries.

Personal information may therefore be processed outside the country where you live.

Where applicable law requires specific safeguards for international transfers, we will seek to use a lawful transfer mechanism or other legally recognized safeguard.

12. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy and as required or permitted by applicable law.

Retention periods may depend on factors such as:

• whether your account remains active;
• whether a listing remains published;
• the type of information involved;
• security and fraud-prevention requirements;
• moderation and enforcement history;
• pending disputes;
• legal claims;
• applicable limitation periods;
• regulatory requirements; and
• backup and disaster-recovery processes.

Information may be retained for a longer period where reasonably necessary to comply with law, preserve evidence, investigate fraud or establish, exercise or defend legal claims.

13. Account and Listing Deletion

Where functionality is available, users may remove listings or request deletion of their account.

Account deletion may not require immediate deletion of every item of information. Limited information may be retained where reasonably necessary for:

• fraud prevention;
• security;
• legal obligations;
• enforcement history;
• pending disputes;
• legal claims; or
• backup integrity.

14. Your Privacy Rights

Depending on where you live and which laws apply, you may have rights to:

• request access to personal information;
• obtain a copy of certain personal information;
• correct inaccurate or incomplete information;
• request deletion of personal information;
• request restriction of certain processing;
• object to certain processing;
• request data portability where applicable;
• withdraw consent where processing is based on consent; and
• complain to an applicable data-protection authority.

Some rights may be subject to exceptions or limitations provided by law.

To exercise a privacy right, contact privacy@wacaracha.com.

We may need to verify your identity before fulfilling certain requests.

15. European and Other International Users

Where data-protection laws outside Botswana apply to Wacaracha, we will seek to comply with mandatory requirements applicable to the relevant processing activities.

Where legally required, Wacaracha may appoint a representative, contact point or other local representative in a relevant jurisdiction and publish that representative's details in this Privacy Policy.

16. Automated Moderation and Security Tools

Wacaracha may use automated systems to help identify:

• spam;
• suspicious accounts;
• fraud indicators;
• duplicate or abusive content;
• security threats; and
• content potentially prohibited by our Terms of Use.

Automated systems may make mistakes. Where appropriate and required by applicable law, users may request reconsideration of significant moderation decisions.

17. Children

Wacaracha is not intended for persons under 18 years of age to create accounts or publish commercial offers.

If we become aware that personal information has been collected from a child in circumstances where such collection is not permitted, we will take reasonable steps to delete or otherwise appropriately handle that information.

18. Security

We use reasonable technical and organizational measures intended to protect personal information against unauthorized access, alteration, loss, misuse or disclosure.

However, no internet service, transmission method or storage system can guarantee absolute security.

Users are responsible for protecting their own credentials and should notify us if they believe their account has been compromised.

19. Data Breaches

Where a personal-data breach occurs, Wacaracha will investigate the incident and take reasonable mitigation steps.

Where applicable law requires notification to an authority or affected individuals, Wacaracha will provide such notification in accordance with applicable requirements.

20. Third-Party Links and Services

Wacaracha may link to websites, stores, payment services, social networks, authentication providers or other third-party services.

Those services operate independently from Wacaracha and their own terms and privacy policies apply.

21. Law-Enforcement Requests

Wacaracha seeks to cooperate appropriately with legitimate investigations while respecting the privacy and legal rights of users.

Personal information may be preserved or disclosed when required or permitted by applicable law.

Where legally and practically appropriate, we may:

• require suitable legal process;
• verify the identity or authority of the requesting body;
• assess whether the request is sufficiently specific;
• disclose only information responsive to a lawful request;
• challenge invalid or excessively broad requests; and
• notify an affected user unless prohibited from doing so.

Nothing in this Privacy Policy gives any government, law-enforcement body, private party or other person an automatic right to obtain user information.

22. Changes to This Privacy Policy

We may update this Privacy Policy as the Service, technology or applicable law changes.

The latest version will be published on Wacaracha together with its effective date. Where applicable law requires additional notice or consent for a material change, we will seek to provide it.

23. Contact