ReloSale Seller, Agency and Business Account Verification Rules

These Seller, Agency and Business Account Verification Rules (hereinafter referred to as the “Verification Rules”) govern the procedure and conditions for verifying the identity, status, authority and business characteristics of users acting as professional sellers, real estate agencies, brokers, agents, dealers, car dealerships, developers, construction companies, employers, recruitment agencies, service companies, service providers and other users engaged in commercial, professional or systematic activity on the ReloSale platform (hereinafter referred to as the “Platform”).

These Verification Rules apply in cases where ReloSale introduces mandatory or voluntary verification, assigns special statuses or badges, establishes requirements for certain categories of listings or users, requests confirmation of identity, company or publication rights, and in any other cases where it is necessary to distinguish between private and professional users, verify activity in high-risk categories, or confirm the right to publish listings.

Verification is not an endorsement of the user’s activity, a legal examination of their business, a guarantee of the quality of goods or services, a confirmation of the absence of risks, nor does it indicate ReloSale’s participation in any transactions between users.

Verification on the Platform is carried out for the following purposes:

• increasing trust between Platform users and creating a more transparent environment for interaction;
• reducing the risks of fraud, creation of fictitious accounts, use of fake identities, non-existent companies and false credentials;
• distinguishing between private users and professional market participants (agencies, brokers, dealers, developers, service companies, employers and other business accounts);
• confirming the user’s right to publish listings of a certain type, in certain categories or on behalf of certain persons;
• complying with applicable legislation, payment system rules, advertising platform policies, consumer protection standards, and trust & safety policies;
• providing access to certain categories, tools, commercial features and advanced capabilities of the Platform.

Verification may be requested or assigned in respect of the following categories of users:

• professional sellers — persons who systematically publish listings for the sale of goods, real estate, vehicles, services or other items;
• real estate agencies — companies and individual entrepreneurs providing intermediary services in the real estate market;
• brokers and agents — individuals or legal entities acting on behalf of or in the interests of third parties when publishing listings, conducting transactions or providing services;
• developers and construction companies — companies engaged in the construction, renovation or sale of real estate;
• dealers and car dealerships — companies and entrepreneurs engaged in the sale or brokerage of vehicles;
• employers and recruitment agencies — persons publishing job vacancies, hiring or employment listings;
• service companies and service providers — companies and specialists offering their services through the Platform;
• partners, affiliates and business clients — persons participating in partnership programs, advertising accounts or other commercial relationships with ReloSale;
• any other users whose activity, volume of listings, listing category, behavior on the Platform or risk profile indicates the need for verification.

Verification may also be requested from private users if the circumstances of their activity on the Platform indicate such a need.

ReloSale may apply one or more types of verification depending on the user category, type of activity, country, listing category and risk level.

As part of verification, ReloSale may request the following data and documents from the user (the list is not exhaustive and may depend on the type of verification, user category, country and other circumstances):

• full name (surname, first name, patronymic or other applicable designation);
• date of birth;
• email address and phone number;
• identity document (passport, ID card, driver’s license, residence permit or other acceptable document);
• selfie with document, video selfie, real-time photograph or result of passing a liveness check;
• founding and registration documents of the company (certificate of registration, extract from the register, charter, memorandum of association);
• registered address, actual location, legal address of the company;
• tax number, TIN, VAT ID, company registration number or other identification number;
• licenses, certificates, permits, approvals, accreditations, membership certificates in professional organizations, broker documents, agency or other special status documents;
• documents for real estate, vehicle or other asset (ownership certificate, vehicle title, technical passport, cadastral extract);
• power of attorney, contract, authorization letter, listing agreement or other document confirming the authority to publish a listing on behalf of another person;
• information about the website, brand, office, social media, portfolio or other public resources;
• other documents and information, the request for which is reasonable taking into account the type of verification, user category and applicable requirements.

ReloSale independently determines the sufficiency of the data and documents provided for verification purposes.

The user undergoing verification undertakes to:

• provide accurate, up-to-date and complete data and documents that correspond to the facts at the time of submission;
• not provide forged, falsified, third-party or invalid documents, not use fictitious companies, non-existent credentials or other knowingly false information;
• promptly update previously provided data and documents in case of their change, expiration, revocation of authority or change of status;
• reasonably cooperate with ReloSale during the verification process, respond to requests, provide additional documents or explanations upon request;
• not attempt to circumvent verification by creating other accounts, using front persons, nominee employees, technical bypass schemes or other methods of evading verification.

Failure to provide requested data or documents may constitute grounds for denial of verification, restriction of access to Platform features or blocking of certain capabilities.

Voluntary verification — the user may undergo verification on their own initiative to obtain a badge, increase trust in the account, access additional features, improve listing visibility or obtain other benefits provided by the Platform.

Mandatory verification — ReloSale may establish mandatory verification for certain categories of users, listing categories, paid services, participation in the partner program, access to business features or other cases in which verification is a necessary condition for publishing listings or using certain Platform capabilities.

ReloSale reserves the right at any time to convert previously voluntary verification into mandatory verification for certain categories of users, countries, types of activity or listing categories, notifying users within a reasonable period.

Based on the results of verification, ReloSale may assign the user one or more statuses, badges or labels, for example:

• Verified;
• Business;
• Agency;
• Dealer;
• Developer;
• Trusted;
• Identity Verified;
• Phone Verified;
• Email Verified;
• other statuses and labels provided by the Platform.

Such statuses and badges:

• reflect solely the level of verification completed by the user in accordance with ReloSale’s rules;
• do not constitute a guarantee of the quality of goods or services, the legality of the activity, the good faith of the user or the absence of risks;
• may be limited in terms of validity period, country, listing category or scope of granted rights;
• may be revoked, suspended or modified in accordance with these Verification Rules.

ReloSale may refuse verification in the following cases:

• the documents provided are insufficient, illegible, damaged, expired or raise reasonable doubts about their authenticity;
• the data provided by the user contains contradictions, is inconsistent or does not correspond to other information available to the Platform;
• there are signs of document forgery, fraud, impersonation of another person, use of someone else’s data or other bad faith actions;
• the user has previously violated Platform rules, been blocked, received warnings or is in the process of violation review;
• the user’s account is linked to previously restricted, blocked or rejected accounts;
• there are reasonable doubts about the user’s identity, authority, good faith or purposes of registration;
• verification is impossible for technical, legal, sanctions-related or operational reasons.

ReloSale is not obligated to disclose all internal evaluation criteria, verification algorithms and grounds for verification decisions.

ReloSale reserves the right at any time to:

• suspend the verification status;
• request re-verification;
• revoke a badge, business status or other assigned status;
• restrict account features until the data update is completed.

The grounds for such actions may include:

• expiration of documents, licenses, permits or other previously provided data;
• change in the status of the company, license, agency, brand, authority or other circumstances on which the verification was based;
• receipt of complaints, claims or reports related to the user’s activity;
• emergence of new circumstances indicating increased risk, bad faith or violation of rules;
• changes in verification standards, Platform rules or applicable legislation.

In the event of failing verification, refusing to undergo verification, failing to provide requested data or losing verification status, ReloSale may:

• refuse to publish listings;
• restrict access to certain listing categories;
• hide previously published listings;
• disable listing promotion capabilities;
• restrict communication features with other users;
• prohibit the use of business tools and advertising accounts;
• suspend paid features and services;
• refuse participation in the partner program;
• restrict or block the account in whole or in part.

Processing of data provided during verification is carried out in accordance with ReloSale’s Privacy Policy.

Data obtained during verification is used exclusively for:

• establishing and confirming the user’s identity, status and authority;
• verifying the authenticity of provided documents and information;
• complying with applicable legislation requirements;
• preventing fraud, abuse and violations of Platform rules;
• protecting users and the Platform from risks;
• maintaining verification logs and resolving potential disputes.

ReloSale may use third-party verification service providers, KYC providers, identity verification services and other tools necessary for conducting verification, within the purposes specified in these Verification Rules and the Privacy Policy.

Based on verification results, ReloSale may publicly display the following information:

• user status (business, agency, dealer, developer, etc.);
• company or brand name;
• country and city of activity;
• indicators of verified contact information;
• other limited information provided by the Platform interface.

By undergoing verification, the user agrees that some of their business data may be accessible to other Platform users as part of profile display, badges and statuses.

Verification carried out by ReloSale is not:

• a legal opinion on the user’s activity;
• an audit of the business, financial condition or reputation;
• a financial, tax, technical or legal examination;
• a verification of each individual transaction, listing or interaction;
• a guarantee of solvency, good faith, absence of disputes or claims against the user.

Platform users are obligated to exercise their own due diligence when interacting with other users, verify information, documents and transaction terms, and make their own decisions based on available data.

A user who disagrees with a verification decision may contact ReloSale support or use the appeal mechanism provided by the Platform.

ReloSale may request additional information, documents or explanations for reviewing the decision. If the decision to refuse or revoke verification is justified and confirmed, ReloSale reserves the right to maintain it in force.

ReloSale reserves the right to amend, supplement or update these Verification Rules at any time. Changes take effect from the moment the updated version is published on the Platform, unless a different period is expressly indicated in the notification.

For certain countries, categories, types of activity or business models, additional special verification rules may apply alongside these Verification Rules.