Privacy lives here

Effective from 25th September 2018.

We want Brunei buy and sell to be a safe and trusted place. We do this via the products and services we build, and our commitment to your privacy. It’s important to us that you trust Brunei buy and sell and the things we do with your personal information.
This policy is straight up about how we collect, use, disclose and protect your personal information. We bring diverse people together in our Brunei buy and sell community, and we take our responsibility to protect your personal information very seriously. We collect and use your personal information to deliver our vision of making life better for people in Brunei through online experiences you’ll love. We’re committed to following four principles in relation to your information:

  • We will respect your privacy—our brand is built on trust and integrity.
  • We’re committed to being transparent and honest, so you know what we do with your personal information (including if something goes wrong).
  • We use personal information to add value to your life.
  • We avoid getting involved in anything creepy that could breach your trust.

If you have any questions about your privacy or this policy, please contact us.

2. What information do we collect?

We collect information so that we can provide you with our Services, and so that we can build new Services that make life better for Kiwis through online experiences they love. We may collect the following personal information:

2.1 Information you give us, such as:

  • Account information. When you sign up for a Service, we may require your name, username, password, email address, date of birth, demographic information or other personal information.
  • Profile information. Certain Services may require you to complete a profile, which may include personal information such as your postal and delivery addresses, phone number, and gender. Parts of your profile (like your member number, user name, and feedback history) may be part of your public profile page, and will be publicly visible to others. For other Services we may also collect photos connected to your profile if you upload or publish these.
  • Listing content. We collect the listing content when you create a listing, which may include your description of the listing, photos, your user name and in certain cases your contact details. Listing content may include embedded information or other metadata (e.g. EXIF data in photos, such as when and where each photo was taken, and details of the device used to take it).
  • Authentication information. To help create and maintain a trusted environment, we may collect identification (like a photo of your government-issued ID, such as a firearms licence) or other authentication information. You will be told at the time of collection when this applies.
  • Payment information. We collect your financial information (like your bank account or credit card information) when you make payments to us or third parties using our Services (see below for how we use and hold this).
  • Communications and phone calls. When you communicate with us or other Users in relation to a Service, we may collect information about your communication and any other information you provide. This includes when you call us, in which case we may retain your call for fraud prevention, internal training and quality assurance purposes.
  • Other information. You may otherwise provide us information directly (by email or in other formats), such as when you provide feedback, fill in a form, conduct a search, update or add information to our Services, respond to surveys or other research activities, post to message boards, participate in promotions, upload into our Services or use other features of our Services.

2.2 Information we automatically collect such as:

  • Usage information. We collect information about your interactions with our Services, such as the pages or other content you view, your searches for listings, trades and bookings you have made, and emails and messages generated through your use of the Services.
  • Location information. When you use certain features of our Services, we may collect different types of information about your general location (e.g. your physical or postal address or your device’s IP address) or more specific location information (e.g. precise location from your mobile GPS). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu.
  • Analytics. We automatically collect analytics information when you use our Services, even if you have not created an account or logged in. We may use third party providers to help us with this. Information collected includes, among other things: details about how you’ve used our Services (including links to third party applications), your IP address, access times, hardware and software information, device information, device event information (e.g. crashes, browser type), and the pages, applications or services you’ve viewed or engaged with before or after using our Services.
  • Transaction and financial Information. We may collect information related to your transactions on our Services, including the date and time, amounts charged, and other related transaction details. Depending on your settings and the Services you use, we may collect financial information relating to your use of our Services and your financial history.
  • Via cookies and similar technologies. We use cookies, pixels, beacons and other similar technologies to collect and store information about you when you use our Services (e.g. through Google Analytics or Google Tag Manager) and this collection may occur across devices. Cookies may be “session” cookies (which temporarily store information and expire when you close your browser) or “persistent” cookies (e.g. when you select “remember me” when logging in). We may also allow our business partners to use these technologies on our Services (e.g. for advertising and remarketing), or engage others to track your behaviour on our behalf. You may disable the usage of cookies through your browser settings and may opt out of certain advertising as described in clause 3.4 below. Some Services also use social media features (e.g. the Facebook Like button or widgets, such as a share button or mini programmes running onsite) which may collect your IP address and the pages you visit, and which are generally governed by the terms of the social media business providing the features.

2.3 Information from third parties or external sources such as:

  • Information from third party services you use. If you link, connect, or log in to your account with a third party service (e.g. Facebook), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorised by you via your privacy settings at that service.
  • Background Information about you. For some Services, to the extent permitted by applicable laws, we may request that you provide or are subject to background or credit checks, and we may obtain reports from public records (e.g. the firearms register in relation to enquiries regarding firearms). If you refuse to provide or undergo a background or credit check in these circumstances, we may refuse you access to the Service. If we collect the information described in this paragraph, you will be notified before we do so.
  • Analytics information. We may collect analytics information from third parties (e.g. we may use Google Analytics, Google Analytics Demographics and Interest, Google AdWords, Flurry, and Nielsen//Online counting system). Analytics information is generally anonymised, but may include the device you’re using, the applications you use, your operating system, your IP address, and your geo-demographic information.
  • Information from public sources. To the extent permitted by applicable law, we may receive additional information about you that is publicly available (e.g. we may collect your property information held by local councils for our Property Insights Service).

3. How do we use your information

We use your personal information to provide you with Services and to maintain your trust in Brunei buy and sell and the people who use it. We also use your personal information with information from others so that we can analyse patterns across our data and improve our Services. For example, we can look across our Services to see online shopping habits to make sure we invest in product improvements that deliver benefits. We may use your personal information in the following ways:

3.1 To contact you about your account or use:

  • We may contact you by phone, email, text message, instant message or otherwise (e.g. by “push notifications” on your mobile device, subject to your application settings) in relation to your account or use. With our emails you can:
    • Unsubscribe from emailed newsletters and advertising materials.
    • For most Services, change your email preferences for Service related emails, such as alerts and Watchlist reminders.

3.2 To help provide our services, for example:

  • To enable your use of our Services. We may enable you to communicate with other Users or make payments on our Services, provide you with shipping services or verify your address (and we may use third parties to help enable your use of our Services – see clause 4.3 below). For example, if you are a Holiday Houses user and you make an enquiry about a house, we will send that information to the house owner, and will keep a record of the enquiry for administration of the site.
  • To personalise or enrich our Services. We may personalise, improve or enrich your experience by, among other things:
    • not asking you to log in unnecessarily (i.e. we may save your credentials for you);
    • ranking search results;
    • delivering information you might be interested in, such as recommendations and content specific to your interests;
    • for some Services, allowing you to store a delivery address against your profile (but we will never give a seller your address without permission, subject to clause 4.2 below);
    • allowing you to save and send standard payment instructions to a successful buyer (e.g., when you use Brunei buy and sell Marketplace or Brunei buy and sell Motors);
    • showing ads based on your use of our Services and your preferences;
    • allowing you to create a profile, or creating a profile for you, for relevant Services. If we ever create a profile for you, you will be notified before your profile is activated and you will be able to update or deactivate your profile (e.g. see more about Job Profiles at clauses 6.1 and 8.1 below);
  • To manage our Services. We may provide, operate, protect, improve, optimise and otherwise manage our Services, including by using analytics, accounting and customer relationship management tools.
  • To conduct research. We may conduct internal research in relation to Users’ demographics, interests, and behaviour to better understand and serve our community.
  • For training purposes. We may use your personal information to help train and improve our staff who help provide or support the Services (e.g. customer support staff may have access to calls for training purposes).

3.3 For trust, safety and assurance, for example to:

  • Protect the rights, property or safety of Users, third parties or us. We may use your information to keep our Services safe, and to protect the rights and property of Users, third parties or us.
  • Prevent harm to us or others. We may use your information to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity (e.g. if we believe you have used another person’s payment card or payment details without their permission or knowledge, we may disclose your personal information relating to the transaction to that person or their bank).
  • Ensure we comply with our obligations. We will use information to ensure we comply with the law, including disclosures authorised under the Privacy Act 1993.
  • Resolve disputes. We may use your information to resolve disputes with or between any of our Users (including claims under our Buyer Protection Policy). We will seek your permission before disclosing your contact details to a third party involved in a dispute, unless this is permitted under the Privacy Act 1993 (e.g. we may disclose your information where the other party has sworn a statutory declaration regarding the dispute).
  • Enforce agreements. We may use your information to enforce our agreements with Users or third parties.
  • Conduct investigations. We may use your information to conduct investigations relating to our Services and make risk assessments.
  • Allow our business to be audited. We may use your information to allow for auditing of our Services and businesses.
    Verify the identity of users or third parties. We may verify your identity or authenticate information provided by you, including information relating to others.
  • To obtain reference or credit checks. With your consent, we may conduct reference checks. We may also check against databases and other information sources; such as checks against the motor vehicle register in respect of car ownership. Also, if you give us your firearms licence details, you authorise us to provide this information to Police to verify that the Licence is current and valid. Where applicable for the Service, we may also obtain credit checks in accordance with the Credit Reporting Privacy Code (or engage a credit reporter to assist us with this).

3.4 For advertising and marketing, for example to:

  • Send you promotional messages, marketing or advertising. We may send you and other Users promotional messages, marketing, advertising, and other information. You authorise us to use your listing content for such purposes, including through display advertising, electronic direct mail or on social media. For clarity, products and services advertised on the websites which provide Services to you (e.g. display ads showing messages from third parties) are not endorsed by Brunei buy and sell.
  • Send you customised advertising (unless you opt out). We may send or show you promotional messages, marketing, advertising (including on-site display advertising), and other information that may be of interest to you based on your communication preferences (including information about campaigns and services of us or our business partners). We may make advertising space available through certain advertising platforms or exchanges, such as DoubleClick Ad Exchange, and you can manage what you see due to DoubleClick cookies through Google’s Ad Settings. You can also opt out of remarketing, a form of customised advertising (see clause 4.4 below). You may also be able to opt out of our advertising by visiting the websites of the the Network Advertising Initiative or Digital Advertising Alliance. If you opt out of customised advertising, the advertising you see may be less relevant to you.
  • Run promotions. We may use your information to administer referral programmes, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners.
  • Measure and improve our advertising. We may use your information to measure the effectiveness of our advertising and make improvements.

3.5 To help you publish things on our website, for example to:

  • Your public profile. Parts of your public profile page, such as your user name and your region may be publicly visible to others.
  • Your listing content. We may make listing content publicly available on the applicable Service when you publish it (and in such cases, you are solely responsible for such publication). Listing content will also be available to people who use our API (e.g. developers) and may appear on other websites or applications (see clause 4 below).
  • Your feedback. A number of our Services allow Users to provide feedback and rate each other. These may be publicly available on our Services.
  • Comments on message boards. If you submit content on a message board, social media post or other similar feature on our Services, that content will be publicly visible.

3.6 For other things with express consent:

We may disclose your information at your direction, or otherwise as you agree with us. Please note that we:

  • Do not have access to your passwords.
  • Only use your credit card details for purposes related to your transactions and for fraud prevention or law enforcement purposes.
  • Have included some Service-specific terms below, which cover how we use your information for particular Services.

4. Who do we disclose your information to?

We may need to disclose your personal information to others to provide you with our Services, to improve our Services or uphold the law or our terms. To help build your trust, we produce an Annual Transparency Report which details disclosures we have made for law enforcement purposes. As described above, we may disclose your information to our Brunei buy and sell Affiliated Services (unless you have opted out of these disclosures). We may also disclose your personal information in the following ways:

4.1 To others with your consent, for example when you:

  • Ask us or authorise us. We’ll share your information when you authorise us to send this to a third party (e.g. Afterpay or a job advertiser). For example, if you use Brunei buy and sell and are a buyer or seller in respect of a listing, you authorise us to release your name, email address and other contact details to the other party to facilitate the trade after the listing closes.
  • Authorise third party access. We may share your information when you authorise a third party application to access your information. This is most common for Top Sellers, and other professional listers (e.g. motor vehicle dealers, property agents and recruiters).

4.2 To other users in certain cases, for example:

  • Your trading history. Your membership trading history is published in your feedback if someone places feedback about you. Although we allow this functionality, the person posting feedback is solely responsible for the content of their feedback.

4.3 To our service providers, to provide and manage our Services.

In order to provide and manage our Services, we may need to disclose some of your personal information to our third party service providers. These providers have limited access to your personal information to perform tasks on our behalf, and are contractually obliged to use your personal information consistently with this Privacy Policy. These disclosures will be consistent with the Service-specific terms and the rest of this privacy policy.

4.4 To other third parties, such as:

Advertisers providing customised ads, unless you opt out. We may give advertisers your personal information to facilitate them sending you promotional messages, marketing, advertising, and other information that may be of interest to you (unless you opt out or unsubscribe). This may be provided on our Services or on services provided by those advertisers. The advertiser’s own privacy policy will apply to the personal information we send them. Depending on the privacy policy of the advertiser, the advertiser may combine the personal information we give them with personal information they hold about you, to assist with their advertising to you. This is particularly relevant for Google’s Customer Match and Facebook Customer Audience. If any personal information is shared, we require that it is done so securely.

4.5 To authorities or other entities to uphold the law or our terms, for example:

  • For legal compliance or law enforcement purposes. We may disclose your personal information to courts, law enforcement or government agencies, or third parties, to the extent we believe that disclosure is appropriate or permitted by the Privacy Act.
  • To facilitate legal processes. If you wish to take Disputes Tribunal (or other) proceedings against another User, you can contact us for a statutory declaration form which must be completed before we will consider releasing anyone else’s information to you. You may only request contact details for the sole purpose of making a claim.
  • To enforce or apply our terms and conditions or policies. Despite anything else in this clause
    4.5, if you are involved in a dispute to which our Buyer Protection Policy applies, you authorise us to (at our discretion) provide the other party with any correspondence or evidence relevant to the dispute which you’ve provided to us. In limited circumstances, we may also provide your contact details to the other party to help resolve the dispute (but will always seek your permission first).
  • To protect the rights, property or safety of us, our Users or others. This includes collecting money you owe us and making such disclosures as are necessary for the purpose of trust, safety and assurance in accordance with clause 3.3 above (e.g. we have authorisation to access name and address details registered in respect of a vehicle on the motor vehicle register for fraud prevention purposes).

4.6 To our other Services.

We may disclose your personal information to entities partly or fully owned by Brunei buy and sell which are governed by this privacy policy, subject to your privacy options and the service-specific terms in clause 8.

4.7 To others where necessary to reorganise or sell our business.

If we undertake or are involved in any merger, acquisition, reorganisation, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

4.8 To other third parties, where your identity is anonymised.

We may share non-personally identifiable information (e.g., aggregated information about our Users that we combine together so that it no longer identifies or references an individual User), for industry and market analysis, demographic profiling, marketing and advertising, and other business purposes. For example, we may disclose aggregated anonymised information to Users of DealerBase for the purpose of understanding trends in the motor industry.

4.9 Also, some interactions with our sites and Services may be subject to additional third party terms. For example

  • External links. Our Services may contain links to third party websites or services. We don’t own or control those websites or services or endorse them in any way and, if you interact with them, you may be providing information directly to the third party concerned. The third parties will have their own rules about the collection, use, and disclosure of your personal information. We encourage you to review their privacy policies accordingly.
  • Certain embedded third party services. Some of our Services use embedded third party services, e.g. Google Maps/Earth. Use of those services may be subject to third party terms, e.g. Google Maps/Earth Additional Terms of Use and the Google Privacy Policy.
  • Information indexed by search engines. Information you share publicly on our Services may be indexed through third party search engines. We do not control the practices of third party search engines, and they may use caches containing your outdated information.

5. How do we hold and protect your information?

We’re big on security. We publish lots of tips on how to keep your personal information secure. We also work hard to ensure we keep your personal information safe and to avoid any harm to you or your personal information. We delete personal information after it is no longer reasonably necessary for us to use it. In particular:

5.1 We use industry recognised security practices and measures.

  • We are committed to keeping your personal information as safe and secure as possible and follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it.
  • We continuously implement and update our administrative, technical, and physical security measures to help protect your personal information against unauthorised access, loss, destruction, or alteration. However, despite all of our measures we can’t 100% guarantee the security of the transmission or storage of your personal information.

5.2 We store your information in Brunei or overseas subject to standards that will comply with our privacy obligations

  • You authorise us to transfer, store, and process your personal information in Brunei and possibly other countries.

5.3 We retain your information as long as reasonably required, unless we are legally required to hold it longer.

  • We will keep your personal information for as long as is reasonably required for us to use it in accordance with this policy, unless we are required by law to hold it longer. In particular, we may retain:
    • Recordings of your phone calls for a period of up to two years (and sometimes longer, where necessary for business purposes, to help prevent fraud or facilitate legal processes).
    • All listing content after listings have expired. We do this for various reasons, including in case of disputes, to help prevent fraud and facilitate legal processes, to comply with financial record-keeping and to help personalise or recommend products in future. Listing content may also persist elsewhere when third parties access and cache listings while they are live. For example, Google do this when they index the web for searching and so old listings may show in Google searches for a period of time.
  • Other personal information that is deleted by you may persist for a limited time in our backup systems.

6. How can I manage my information?

We know your circumstances, details and preferences will change. So, we’ve built a number of tools for you to manage your personal information. You can:

6.1 Update your information by:

  • Managing your profiles, where this is available.
  • Updating your account information. In most cases, you may review and update the account information we hold about you (such as your email address, password and phone numbers) by logging into the relevant Service and updating the information in your account. If this isn’t available and you want to update your information, please get in touch with us.
  • Managing your listings, where allowed. Some listings enable you to change the details that can be seen on our Services.

6.2 Ask us to update, provide or delete your information

  • If you wish to access or correct any of your personal information, you can contact us directly. We will respond to your request promptly, and always within 20 working days. If you want us to delete any personal information you have submitted to us, please contact us. We will consider each request for deletion on a case by case basis taking into account the terms and conditions of the particular Service(s) and our legal obligations to retain certain information. Note that information that you have shared with others may continue to be publicly visible on our Services in association with your first name, even after your account is cancelled.
  • If you want to cancel your account for any of our Services, please contact us.

7. How do we amend this policy?

We may make updates from time to time by a Brunei buy and sell site announcement or other notice, usually with two weeks’ notice or more.
Occasionally urgent changes will be required, but we will generally give you at least two weeks’ notice by announcements via email and on the Brunei buy and sell website. To review any changes, unless the Service-specific terms do not require notice of changes to them. From time to time, we may seek your feedback on proposed changes on the Brunei buy and sell message board or via other forms of consultation. For significant changes we may notify you directly via email. As we update this policy from time to time, we encourage you to periodically review this page for the latest information on our privacy practices.

8. What do the terms in this policy mean?

8.1 “User”

  • User means anyone using our Services, including any Brunei buy and sell member.

8.2 “personal information”

  • Personal information means information about an identifiable individual.

8.3 “Services”

  • Services means our Services, as defined in clause 1.1.

8.4 “Tailored Product”

  • Tailored Product means a product that provides tailored personal information (as further described in clause 4.4).

8.5 “we”, “us” or “our”

  • We, us, or our means: (a) Brunei buy and sell Limited, and (b) any entity that Brunei Buy and sell ultimately partly or fully owns that provides a Brunei buy and sell Affiliated Service to which this privacy policy applies.

8.6 “you” or “your”

  • You or your, in relation to any personal information, means any individual who is identifiable from the personal information.