Privacy Policy

gunbuy.com.au ("GunBuy", "we", "us", "our") is committed to handling personal information responsibly and in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APPs") contained in Schedule 1 of the Privacy Act.

This Privacy Policy explains how GunBuy collects, holds, uses, discloses and manages your personal information when you access or use the gunbuy.com.au website, any associated mobile application or any related services (collectively the "Platform").

By accessing or using the Platform you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use and disclosure of your personal information as described in this Policy.

This Privacy Policy should be read in conjunction with our Terms of Service which govern your use of the Platform.

gunbuy.com.au is operated by Townsend Investment Group Pty Ltd ABN 42 649 952 983 of QLD Australia.

For privacy related enquiries contact our Privacy Officer at: Email: privacy@gunbuy.com.au

3.1 Information You Provide Directly

GunBuy may collect the following personal information that you provide to us directly:

Account Registration

• Full legal name
• Email address
• Password (stored in encrypted form)
• Phone number
• Residential state and postcode
• Date of birth
• Account type (private seller or dealer)

Firearms Licence Information

• Firearms licence number
• Licence category
• Licence expiry date
• Issuing state or territory
• Scanned or photographed copy of firearms licence document including any personal information contained on that document

Dealer Registration (Additional)

• Business name
• Australian Business Number
• Business address
• Dealer licence number
• Dealer licence document
• Contact person name and title

Listing Information

• Firearm details including make, model, calibre, condition and description
• Photographs uploaded to listings
• Asking price and transaction preferences
• Location information associated with listings

Communications

• All messages sent through the Platform's internal messaging system
• All enquiries submitted through listing pages
• All correspondence with GunBuy customer support
• Any other communications conducted through the Platform

Payment Information

• Credit or debit card details processed through our payment processor Stripe
• Billing address
• Transaction history
• Invoice records

Profile Information

• Profile photo if uploaded
• Any additional information you choose to add to your profile

3.2 Information We Collect Automatically

When you access or use the Platform we automatically collect the following information:

Device and Technical Information

• IP address
• Device type, model and operating system
• Browser type and version
• Unique device identifiers
• Mobile network information
• Time zone settings

Usage Information

• Pages viewed and features accessed
• Search queries entered on the Platform
• Listings viewed, saved or enquired about
• Time and duration of Platform sessions
• Referring website or source
• Links clicked within the Platform
• Filters and search parameters used

Location Information

• General location derived from IP address
• Precise location if you grant permission through your device settings
• Location associated with listings you create or view

Cookies and Tracking Technologies

• Cookie identifiers
• Pixel tag data
• Analytics identifiers
• Session data
• Advertising identifiers

3.3 Information We Collect From Third Parties

GunBuy may collect personal information about you from third parties including:

• Identity verification services used to validate licence documents
• Payment processors including Stripe
• Analytics providers including Google Analytics
• Advertising networks
• Social media platforms if you connect your account or interact with our social media presence
• Law enforcement agencies or government bodies where permitted by law
• Other users who provide information about you in the course of using the Platform

3.4 Sensitive Information

Given the nature of the Platform GunBuy necessarily collects certain sensitive information including:

• Firearms licence information which may reveal information about your lawful firearms ownership
• Government issued identification documents
• Financial information

By using the Platform you expressly consent to GunBuy collecting and handling this sensitive information for the purposes described in this Policy.

GunBuy uses the personal information we collect for the following purposes:

4.1 Operating the Platform

• Creating and managing your account
• Verifying your identity and firearms licence
• Processing and publishing your listings
• Facilitating communications between buyers and sellers through the messaging system
• Processing payments and managing subscriptions
• Providing customer support
• Sending transactional notifications including listing alerts, message notifications and payment confirmations
• Enforcing our Terms of Service and this Privacy Policy

4.2 Safety and Security

• Verifying the validity of firearms licences submitted to the Platform
• Detecting, investigating and preventing fraudulent, illegal or prohibited activity
• Monitoring platform communications for compliance with our Terms of Service
• Identifying suspicious listings or user behaviour
• Cooperating with law enforcement investigations
• Maintaining the safety and integrity of the Platform and its users
• Preventing the use of the Platform to facilitate illegal firearms transactions

4.3 Platform Improvement

• Analysing usage patterns to improve Platform features and functionality
• Conducting research and analytics
• Testing new features and product development
• Generating aggregated and anonymised market data and insights
• Understanding user behaviour and preferences

4.4 Marketing and Communications

• Sending you service updates, platform announcements and policy changes
• Sending you marketing communications about GunBuy products and services where you have consented or where permitted by law
• Personalising your experience on the Platform
• Displaying relevant listings and recommendations based on your browsing and search history

4.5 Legal and Compliance Purposes

• Complying with applicable laws and regulations
• Responding to lawful requests from law enforcement and government agencies
• Establishing, exercising or defending legal claims
• Complying with court orders, subpoenas and other legal processes
• Meeting our obligations under the Privacy Act and other applicable legislation

4.6 Business Operations

• Managing dealer relationships and subscriptions
• Generating invoices and financial records
• Conducting business due diligence in connection with any sale or restructuring of the GunBuy business
• Insurance and risk management purposes

5.1 No Private Communications

You acknowledge and agree that communications conducted through the GunBuy Platform messaging system are not private communications. All messages, enquiries and communications sent through the Platform are transmitted through and stored on GunBuy's systems. GunBuy has full visibility over all platform communications at all times.

5.2 Monitoring of Communications

GunBuy actively monitors platform communications for the following purposes:

• Detecting illegal activity including attempts to facilitate unlawful firearms transactions
• Identifying communications that violate our Terms of Service
• Detecting fraud, scams or deceptive conduct
• Ensuring platform safety and integrity
• Cooperating with law enforcement investigations
• Detecting attempts to circumvent platform rules including taking transactions off platform

5.3 Automated Monitoring

GunBuy uses automated systems to scan platform communications for:

• Keywords and phrases associated with illegal firearms activity
• Indicators of fraud or scam behaviour
• Prohibited content
• Attempts to share contact details to circumvent platform systems
• Other policy violations

5.4 Human Review

In addition to automated monitoring GunBuy staff and contractors may read, review and retain any platform communication at any time without notice to either party for any of the purposes described in this Policy.

5.5 No Expectation of Privacy

By using the Platform messaging system you expressly acknowledge that you have no expectation of privacy in any communication sent through the Platform. You consent to GunBuy monitoring, recording, storing and disclosing your platform communications as described in this Policy.

5.6 Use of Communication Content

Content from platform communications may be used by GunBuy to:

• Investigate suspected breaches of our Terms of Service
• Respond to law enforcement requests
• Support legal proceedings
• Improve automated detection systems
• Train staff on platform safety

6.1 Disclosure to Law Enforcement

GunBuy will disclose personal information including account details, listing history, communication records, licence documents, IP addresses, device information and any other relevant data to law enforcement agencies, regulatory bodies and government authorities in the following circumstances:

• Upon receipt of a valid warrant, subpoena, court order or other lawful legal process
• Where GunBuy reasonably believes disclosure is necessary to prevent or investigate a criminal offence including any offence relating to firearms
• Where disclosure is required or authorised by Australian law including the Privacy Act, the Surveillance Devices Act, applicable firearms legislation or any other Commonwealth, state or territory legislation
• Where GunBuy reasonably believes a user poses a risk to public safety
• Where we are requested to do so by a firearms registry, police firearms unit or other regulatory authority with jurisdiction over firearms

GunBuy proactively cooperates with law enforcement agencies including the Australian Federal Police, state and territory police services and firearms registries. We do not require a formal legal process before disclosing information where we reasonably believe disclosure serves a legitimate law enforcement or public safety purpose.

6.2 Disclosure to Service Providers

GunBuy discloses personal information to third party service providers who assist us in operating the Platform including:

• Cloud hosting and infrastructure providers
• Payment processors including Stripe
• Email and communications service providers
• Analytics providers including Google Analytics
• Identity verification service providers
• Customer support platform providers
• Marketing and advertising platforms
• Legal and professional advisors
• Accounting and financial service providers

All service providers are required to handle personal information in accordance with our instructions and applicable privacy law. However GunBuy is not responsible for the privacy practices of third party service providers beyond our contractual arrangements with them.

6.3 Disclosure in Business Transactions

If GunBuy is involved in a merger, acquisition, sale of assets, restructuring or other business transaction your personal information may be disclosed to the counterparty and their advisors as part of due diligence and may be transferred to a successor entity as part of that transaction. You consent to such disclosure and transfer.

6.4 Disclosure to Other Users

Certain information is displayed publicly on the Platform as part of normal marketplace operations including:

• For private sellers: first name, state, member since date, verified licence badge, ratings and reviews
• For dealers: full business name, address, phone number, opening hours and all listing information

You acknowledge that information you choose to include in listings, profiles or public communications may be viewed by any Platform user or member of the public.

6.5 Disclosure With Your Consent

GunBuy may disclose your personal information to any other third party with your express consent.

6.6 No Sale of Personal Information

GunBuy does not sell your personal information to third parties for their own marketing purposes.

7.1 Special Handling of Licence Data

Given the sensitive nature of firearms licence information GunBuy may apply the following specific practices:

• Licence documents are stored in encrypted form on secure servers
• Access to licence documents is restricted to authorised GunBuy personnel on a need to know basis
• Licence documents are used only for the purposes of verifying your eligibility to use the Platform and cooperating with law enforcement
• Licence numbers are not displayed publicly on the Platform

7.2 Retention of Licence Documents

GunBuy may retain firearms licence documents and associated information for a minimum period of 7 years following account closure. This retention period reflects our obligations to cooperate with law enforcement investigations which may relate to historical transactions on the Platform.

7.3 Disclosure of Licence Information

Firearms licence information including licence numbers, categories, expiry dates and document copies may be disclosed to:

• State and territory firearms registries
• Police firearms units
• Law enforcement agencies investigating firearms related offences
• Courts and tribunals as required by legal process
• Any other authority with lawful jurisdiction over firearms licensing

8.1 Use of Cookies

GunBuy uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies required for Platform functionality including login sessions and security
• Analytics cookies to understand how users interact with the Platform
• Preference cookies to remember your settings and preferences
• Marketing cookies to deliver relevant advertising and measure campaign effectiveness

8.2 Third Party Cookies

Third parties including Google Analytics and advertising networks may place cookies on your device when you use the Platform. These third parties have their own privacy policies governing their use of cookie data. GunBuy is not responsible for third party cookie practices.

8.3 Cookie Management

You may manage cookie preferences through your browser settings. Disabling certain cookies may affect Platform functionality. Essential cookies cannot be disabled without preventing you from using the Platform.

8.4 Do Not Track

GunBuy does not currently respond to Do Not Track signals from browsers.

9.1 Security Measures

GunBuy implements reasonable technical and organisational security measures to protect personal information from unauthorised access, disclosure, alteration or destruction including:

• Encryption of data in transit using SSL/TLS
• Encryption of sensitive data at rest
• Access controls and authentication requirements for staff
• Regular security assessments
• Secure cloud infrastructure with reputable providers

9.2 No Absolute Security

Despite our security measures no data transmission or storage system can be guaranteed to be completely secure. GunBuy does not warrant that personal information will be protected against all possible security threats.

9.3 Data Breach Notification

In the event of an eligible data breach as defined under the Notifiable Data Breaches scheme in the Privacy Act GunBuy will notify affected individuals and the Office of the Australian Information Commissioner as required by law.

9.4 User Responsibility

You are responsible for maintaining the security of your account credentials. GunBuy accepts no liability for unauthorised access to your account resulting from your failure to maintain credential security.

10.1 Retention Periods

GunBuy retains personal information for as long as necessary to fulfil the purposes described in this Policy subject to the following minimum retention periods:

• Account information: 7 years after account closure
• Listing information including sold and expired listings: 7 years from listing creation
• Platform communications and messages: 7 years from the date of the communication
• Firearms licence documents: 7 years after account closure
• Payment records: 7 years from transaction date in accordance with taxation law
• IP address and device logs: 2 years from collection
• Analytics data: 3 years from collection

10.2 Retention for Legal Purposes

GunBuy may retain personal information beyond the periods specified above where:

• Retention is required by applicable law
• Retention is necessary for the establishment, exercise or defence of legal claims
• We have received a preservation request from law enforcement
• Retention is necessary for ongoing investigations

10.3 Account Deletion

Requesting account deletion does not result in immediate deletion of all personal information. GunBuy will deactivate your account and remove publicly visible information but will retain personal information for the minimum periods specified above and as required by law.

11.1 Access to Your Information

Under the Privacy Act you have the right to request access to personal information GunBuy holds about you. To make an access request contact our Privacy Officer at privacy@gunbuy.com.au. We will respond to access requests within 30 days.

11.2 Correction of Your Information

If you believe personal information we hold about you is inaccurate, incomplete or out of date you may request correction by contacting our Privacy Officer. We will respond to correction requests within 30 days.

11.3 Limitations on Access

GunBuy may refuse or limit access to personal information in the following circumstances:

• Where providing access would pose a serious threat to the life, health or safety of any person
• Where providing access would have an unreasonable impact on the privacy of other individuals
• Where the request is frivolous or vexatious
• Where the information is subject to legal professional privilege
• Where providing access would be unlawful
• Where denial is authorised or required by Australian law
• Where the information relates to existing or anticipated legal proceedings
• Where providing access would prejudice an investigation by a law enforcement agency
• Where providing access would prejudice GunBuy's commercial interests unreasonably

11.4 Marketing Opt Out

You may opt out of receiving marketing communications from GunBuy at any time by using the unsubscribe link in any marketing email or by contacting us at privacy@gunbuy.com.au. Opting out of marketing communications does not affect transactional or service communications which are necessary for Platform operation.

11.5 Complaints

If you believe GunBuy has breached the Australian Privacy Principles you may lodge a complaint with our Privacy Officer at privacy@gunbuy.com.au. We will acknowledge your complaint within 5 business days and respond substantively within 30 days. If you are not satisfied with our response you may lodge a complaint with the Office of the Australian Information Commissioner at www.oaic.gov.au.

The Platform is not directed at persons under the age of 18. GunBuy does not knowingly collect personal information from persons under 18. If you are under 18 you must not use the Platform. If GunBuy becomes aware that personal information has been collected from a person under 18 we will take steps to delete that information promptly.

13.1 Offshore Service Providers

GunBuy uses cloud infrastructure and third party service providers who may store or process personal information outside Australia including in the United States and other jurisdictions. By using the Platform you consent to your personal information being transferred to and processed in countries outside Australia.

13.2 APP 8 Compliance

Where GunBuy discloses personal information to overseas recipients we take reasonable steps to ensure those recipients handle the information in accordance with the Australian Privacy Principles. However where an overseas recipient handles information in a manner inconsistent with the APPs GunBuy will not be accountable for that handling to the extent permitted by the Privacy Act.

GunBuy may use aggregated and anonymised data derived from user activity and listing information for any purpose including publishing market reports, selling insights to third parties, improving the Platform and conducting research. Aggregated and anonymised data does not identify individual users and is not subject to this Privacy Policy.

GunBuy reserves the right to update or modify this Privacy Policy at any time. Changes take effect immediately upon publication on the Platform. We will notify registered users of material changes by email or through a Platform notification. Your continued use of the Platform following notification of changes constitutes your acceptance of the revised Policy.

For all privacy related enquiries, access requests, correction requests or complaints contact:

Privacy Officer gunbuy.com.au ABN: 42 649 952 983 Email: privacy@gunbuy.com.au Response timeframe: 5 business days for acknowledgment, 30 days for substantive response.

This Privacy Policy was last updated in March 2026.