Privacy Policy

This Privacy Policy applies immediately to new users and from June 1, 2025 for existing users. This Privacy Policy replaces all previous versions.
Budna Marketplace AB · Effective from June 1, 2025 · support@budna.se · Updated Oct 9, 2026

Scope and consent

This Privacy Policy describes how we collect, use, store, share and protect your personal data. It applies to Budna’s website and all related websites, applications, services and tools that reference this Privacy Policy, regardless of how you access or use them.
In this Privacy Policy we use the term "personal data" to describe information that can directly or indirectly identify a natural person. We do not consider personal data to include information that has been anonymised or aggregated in a way that cannot be used, either in combination with other information or otherwise, to identify a specific natural person.
We may update this Privacy Policy from time to time. The latest version is always available on our website budna.se. In the event of material changes, for example due to new legislation, we may notify you by email.

Data controller

Budna Marketplace AB, Nilssonsberg 20, 411 43 Göteborg, Sweden is the data controller for the processing described in this Privacy Policy. Budna is responsible for processing your personal data and for providing the services set out in the User Agreement in accordance with the principles established in this Privacy Policy. Processing is carried out in accordance with the EU General Data Protection Regulation (GDPR).

Collection of personal data

When you register an account with us, you also provide personal data. We need to process certain personal data about you in order to verify and identify you as a user, to meet certain requirements under the User Agreement or by law, and to improve our services and give you the best possible user experience.

Information we collect automatically

When you visit our websites, use our applications, services and tools, or interact with our advertising or content, we automatically collect information sent to us from your computer, mobile device or other device used for access.

Information you provide

We collect information directly from you that you provide on our websites, or that you give us when you register an account, use our websites, applications, services or tools.
  • Information you provide when registering an account, such as name, email address, telephone number, mobile number, personal identity number, contact details.
  • Financial information related to you, such as bank account number, tax identification number and VAT registration number.
  • Information you provide when using our services, such as search history, bid history, purchase and sale information, reviews and feedback.
  • Information from communications with us, such as emails, chats or support requests.

Information from other sources

We may also obtain information about you from third parties, for example credit reference agencies to verify identity and prevent fraud, payment providers to process transactions, and social media if you link your account.

Use of personal data

We use your personal data for the following purposes:
  • To provide and improve our services, including managing your account, processing transactions, providing customer support and personalising the user experience.
  • To verify identity and prevent fraud, abuse and illegal activity.
  • To enforce payment obligations and prevent reservation abuse, as described in Payment obligations and reservation abuse.
  • To comply with legal requirements, such as the Accounting Act, tax legislation and anti-money laundering rules.
  • For marketing purposes, such as sending newsletters or offers, if you have consented.
  • For statistics and analysis to improve our products and services.
The processing of your personal data is based on the following legal grounds under the GDPR:
  • Performance of a contract: to fulfil the User Agreement and provide the services, including payment deadlines, the fees in the Payment Terms and the restriction of an account while such fees are outstanding.
  • Consent: for marketing and certain non-essential features.
  • Legal obligation: to comply with legal requirements.
  • Legitimate interest: for fraud prevention, security, preventing reservation abuse and service improvement, where your interests are not overridden.

Payment obligations and reservation abuse

We process data about how you handle your orders as a buyer, so that purchases on Budna are paid for and items are not kept from other buyers by reservations that are never paid. The rules themselves are set out in the Payment Terms. This covers:
  • Auction wins, accepted offers and binding Buy Now purchases that close unpaid: when and how the order closed (the seller closed it after the payment deadline, it closed automatically, or you cancelled it).
  • Buy Now, checkout and combined-shipping reservations that you did not pay for or that you cancelled, and whether they ended because of you, the payment system, Budna’s platform or the seller.
  • Failed attempts to start a payment, so that failures on our side or the payment provider’s side are not held against you.
  • Non-payment fees, buyer cancellation fees, seller cancellation fees, return shipping costs charged to a seller and fees imposed by Budna staff: the amount, the order the fee relates to, whether it is outstanding, paid or waived, and the staff member’s note when staff impose or waive a fee.
  • Warnings about repeated abandoned reservations, and whether you have acknowledged them.

How we use this data

When an auction win, accepted offer or binding Buy Now purchase closes unpaid, or you cancel it, the non-payment fee or, if you cancelled, the buyer cancellation fee is created on your account automatically, unless one of the exceptions in the Payment Terms applies. While any fee is outstanding, your account is restricted automatically: you cannot buy, bid, make offers or accept counter-offers, publish, relist or restock listings, or buy boosts or search priority. When a fee arises, your automatic bids are stopped and your pending offers are withdrawn, while bids you have already placed stay valid. You can still pay orders you already have, pay the fee, send messages, handle disputes and your own sales, and keep your live listings. The restriction lifts automatically as soon as all outstanding fees are paid or waived.
We count the reservations you abandon over a rolling 60 days. A combined-shipping request counts once, and reservations that ended because of the payment system, Budna’s platform or the seller, or for a reason we cannot determine, are not counted. When the count reaches 3, we send you a warning and open a case for Budna staff to review the account. The warning carries no fee and no restriction. If staff find clear abuse, they may impose a fee on one of the abandoned orders (see the Payment Terms).
Tracking payment deadlines, creating fees and restricting an account while fees are outstanding are necessary for the performance of our contract with you (GDPR Article 6(1)(b)), because the User Agreement and the Payment Terms set out these consequences.
Counting abandoned reservations, sending warnings, opening staff reviews and recording why a payment could not be started are based on our legitimate interest (GDPR Article 6(1)(f)) in keeping items available to buyers who intend to pay and in protecting sellers from reservations that block their sales. You have the right to object to this processing (see "Your rights").

Who receives this data

Budna staff who handle payments, account reviews and complaints have access to this data. The seller of an order sees that it closed unpaid or was cancelled. For an auction win, accepted offer or binding Buy Now purchase, the seller is also told when your payment is overdue and may leave a public review of you as set out in the Review rules. When your pending offers are withdrawn because a fee has arisen, the sellers are told that the offers were withdrawn, and a seller who tries to accept an offer from you while a fee is outstanding may be told that this is why the offer cannot be accepted. When you pay a fee, the Payment Partner receives the payment data as for any other payment, and our logging provider (Axiom) processes technical records of these events as a data processor (see "Third-party providers").

How long we keep this data

We keep records of unpaid orders, fees and warnings for as long as they are relevant for your account and for the fees on it. The 60-day count only includes reservations from that period, but older records are not deleted when they drop out of the count. Records of fee payments are also financial records and are kept for the periods in "Retention periods".

Use of personal data for marketing purposes

We may use your personal data to send you marketing communications by email, SMS or app notifications, based on your consent or legitimate interest. This includes offers, news and recommendations based on your activity on budna.se.
You can withdraw your consent at any time by clicking the unsubscribe link in our emails, changing the settings in your account or contacting us. Opting out does not affect other processing.

Disclosure of personal data

We do not transfer data outside the EEA without adequate safeguards, such as Standard Contractual Clauses.
We share your personal data with:
  • Other users in connection with transactions (e.g. name and address for delivery).
  • Our Payment Partner, which receives the data needed to initiate, execute and settle payments and processes it as an independent data controller for its own regulatory purposes (see "Third-party providers" below).
  • Service providers such as shipping companies and IT providers, under strict data processing agreements.
  • Authorities where required by law, such as tax authorities or police.
  • In the event of a merger or acquisition, to new owners.

Tax authorities — DAC7 reporting

Budna is a rapporteringsskyldig plattformsoperatör under Lag (2022:1681) implementing Council Directive (EU) 2021/514 (DAC7). For sellers that meet the reporting thresholds (30 or more relevant activities or at least EUR 2,000 in total consideration in a calendar year, and any immovable-property rental), we collect and verify the seller’s name, primary address, taxpayer identification number, VAT number where applicable, date of birth (individuals) or business registration (entities), financial account identifier, and consideration paid per quarter. We report this information to Skatteverket by 31 January of the year following the reportable period.
Information right. We provide each reportable seller, by 31 January, a copy of the information we report (Seller Dashboard, Tax section).
Onward exchange. Skatteverket exchanges the data under DAC7 to the tax authority of the seller’s country of residence and, for immovable property, to the tax authority of the location State.
Payout suspension. If a reportable seller fails after two reminders to provide the required DAC7 information, Budna will close the account for new listings and suspend payouts as required by Skatteverket guidance.
Legal references: DAC7 Annex V; Lag (2022:1681).

AML and financial-crime reporting

In Budna’s payment flow, the Payment Partner is the payment service provider responsible for transaction monitoring and for reporting suspicious activity to Finanspolisen, Sweden’s Financial Intelligence Unit, under Penningtvättslagen (2017:630). Budna provides the Payment Partner and the competent authorities with the information required for this, and files reports itself where Budna is subject to a reporting obligation of its own. Such reports are made without notice to the user: under the tipping-off prohibition (Penningtvättslagen chapter 4 section 9), neither Budna nor the Payment Partner may tell you that a report has been made or is being considered.
Legal references: AMLD5/6 Article 39; Penningtvättslagen (2017:630).

Third-party providers

We use the following third-party providers to deliver our services. Unless otherwise indicated, they act as data processors on Budna’s behalf. The Payment Partner is not a processor: it processes personal data as an independent data controller (see below).
Provider
Purpose
Location / transfer basis
the Payment Partner
Payment processing (independent data controller)
Sweden
Resend
Email delivery
USA / Standard Contractual Clauses (SCCs)
Firebase FCM
Push notifications
USA / Standard Contractual Clauses (SCCs)
Axiom
Logging and observability
USA / Standard Contractual Clauses (SCCs)
Cloudflare
CDN and DNS
USA / Standard Contractual Clauses (SCCs)
OpenPanel
Analytics (loaded only with consent)
Only with user consent
AWS
Infrastructure
EU region

Safeguards

Providers that act as data processors are bound by data processing agreements that ensure your personal data is processed in accordance with the GDPR. For transfers outside the EEA, Standard Contractual Clauses (SCCs) are in place. The Payment Partner processes personal data under its own regulatory obligations as an independent controller and is therefore not bound by a data processing agreement with Budna; the exchange of data between Budna and the Payment Partner takes place in accordance with the GDPR rules that apply to disclosures between independent controllers.

The Payment Partner’s role (independent data controller)

The Payment Partner, Ping Payments AB (reg. no. 559123-5378), is a Swedish payment service provider authorised by and under the supervision of Finansinspektionen. When processing payments, the Payment Partner acts as an independent data controller — not as Budna’s processor — because it must process personal data for its own regulatory purposes, including customer due diligence (KYC), transaction monitoring, anti-money-laundering and counter-terrorist-financing controls, sanctions screening, the safeguarding of client funds, fraud prevention, and regulatory reporting. That processing is described in the Payment Partner’s own privacy notice. Budna and the Payment Partner exchange the personal data necessary to initiate, execute, and settle payments, each acting as an independently responsible controller for its respective processing.

Automated content moderation

To ensure a safe platform, messages and content may be reviewed by automated systems (artificial intelligence) to detect breaches of our policies, including spam, fraud and inappropriate content. Recommender systems and the parameters that materially shape ranking are described in accordance with Regulation (EU) 2022/2065 (Digital Services Act) Article 27.
You have the right to request human review of decisions made by automated moderation systems. Contact our support to complain about or appeal an automated moderation action.
Where automated systems materially restrict your account or content, we issue a statement of reasons under DSA Article 17 (see Rightsholders policy section 3 at /legal/rightsholders) and you may appeal under DSA Article 20 (see Rightsholders policy section 4).
The legal basis for this processing is legitimate interest (GDPR Article 6(1)(f)) to maintain the security and integrity of the platform.

Automated decision-making

The platform may make automated decisions related to content moderation and approval of listings. These decisions are based on predefined rules and machine learning models.
The platform also makes automated decisions about payment obligations, based on the predefined rules in the Payment Terms. When an auction win, accepted offer or binding Buy Now purchase closes unpaid, or you cancel it, a fee is created on your account automatically unless one of the exceptions in the Payment Terms applies, and while any fee is outstanding your account is restricted automatically as described in Payment obligations and reservation abuse. The same rules count abandoned reservations and send a warning. The warning carries no fee or restriction, and a fee for abusing reservations is only imposed by Budna staff after a review.
No permanent account actions are taken without human review. Automated decisions may result in temporary actions, such as warnings, temporary holds on content or on an account pending review, or the restriction for outstanding fees, which lifts automatically as soon as all outstanding fees are paid or waived. Final decisions to suspend or close an account always involve human assessment.
Under GDPR Article 22, you have the right to contest automated decisions, to express your point of view and to request human intervention. Contact us at support@budna.se to exercise this right. You can also contest a fee or a restriction through the internal complaint procedure. A member of staff then reviews the decision and can waive a fee that has not yet been paid, for example where a failure on our side or the payment provider’s side prevented the payment. Waiving the fee lifts the restriction unless another fee is still outstanding.

Cookies, web beacons and similar technology

We use cookies for functionality, analytics and marketing. See our cookie policy for details. You can manage your preferences through your browser.

Security and storage of personal data

We use industry-standard security measures such as encryption and access control. Data is stored only for as long as necessary for the purposes set out in this Privacy Policy. Statutory retention periods, including the Swedish Bokföringslagen (7 years) for accounting records, apply where required.

Retention periods

After the retention period expires, data is deleted or anonymised, unless the law requires longer retention.
We retain your personal data according to the following periods, depending on the data category and legal basis.
Data category
Retention period
User account data
Until deletion is requested
Financial records (orders, transactions)
7 years (Swedish Bokföringslagen)
Unpaid orders, fees and warnings
As long as relevant for the account and its fees; fee payments as financial records
Messages
365 days
Notifications
90 days
Analytics data
365 days
Moderation results
12 months
Push tokens
90 days after inactivity

Account termination and retention of personal data

You can close your account at any time to stop further use of our services. To delete your account and request deletion of your personal data (the right to be forgotten under GDPR Article 17), follow these steps:
  • Log in to your account on budna.se.
  • Go to account settings (found under your profile).
  • Choose "Delete account" or "Close account" and follow the on-screen instructions.
  • Confirm the request via email or another verification method we send you.

How we process your request

After you request deletion, we will process the request within 30 days (or up to 90 days in complex cases, with notice to you). We will delete or anonymise your personal data, except for data we are required by law to retain, for example for accounting purposes (7 years under the Swedish Bokföringslagen) or to handle disputes and legal claims.
If you close your account without a specific deletion request, we may retain data to meet legal requirements or legitimate interests, but you can always exercise your rights as described below.

Your rights

If you are not satisfied with how we handle your request, you can lodge a complaint with a supervisory authority. Lead supervisory authority: Integritetsskyddsmyndigheten (IMY), Sweden, imy.se. IMY is the lead authority for Budna’s processing because Budna Marketplace AB is established in Sweden.
Under the GDPR you have the right to access, rectification, erasure (the right to be forgotten), restriction of processing, data portability and to object to processing. To exercise these rights:
  • For access, rectification or data portability: log in to your account and use the tools under account settings, or contact us.
  • For erasure: follow the procedure described in "Account termination and retention of personal data" above.
  • For objection or restriction: contact us directly with your reasons, and we will handle the request within 30 days.

Data protection officer

Given the current scale of operations, Budna has not appointed a dedicated Data Protection Officer (DPO). We will keep this under review in line with GDPR Article 37.
For privacy enquiries, please contact: privacy@budna.se.

Contact us

For questions about this Privacy Policy or the processing of your personal data, you can contact us in the following ways.
  • Email: support@budna.se.
  • Address: Budna Marketplace AB, Nilssonsberg 20, 411 43 Göteborg, Sweden.

Need Help?

If you have questions, contact us at the address below.