Privacy Policy
ACTIVE SALES PRIVACY POLICY
Version: AS-PP-v1.0 | Effective Date: 13 August 2026
1. ABOUT THIS PRIVACY POLICY
Active Sales is operated by Stibbard Holdings Pty Ltd t/as Active Sales, ABN 15 661 021 334 (Active Sales, we, us or our).
We respect the privacy of individuals who use the Active Sales website, marketplace, buyer portal, AI information portal and related services.
This Privacy Policy explains how we collect, hold, use and disclose personal information. We handle personal information in accordance with applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and Australian Privacy Principles where they apply to us.
2. WHAT IS PERSONAL INFORMATION?
Personal information is information or an opinion about an identified individual or an individual who is reasonably identifiable. The information does not necessarily have to include a person's name to constitute personal information.
3. WHO THIS POLICY APPLIES TO
This Privacy Policy applies to personal information we handle about business owners, authorised seller representatives, business brokers and their personnel, prospective purchasers, registered Active Sales users, website visitors, people subscribing to business alerts or marketing, people communicating with us, service providers and professional advisers, and other individuals whose personal information is legitimately provided to us in connection with our services.
4. PERSONAL INFORMATION WE MAY COLLECT
4.1 Identity and contact information
We may collect names, email addresses, telephone numbers, business or postal addresses, account usernames, employer or organisation details, position or job title, ABN or ACN associated with your organisation, and other information reasonably required to identify or communicate with you.
4.2 Seller and broker information
We may collect business ownership or authority information, business broker or agency details, licence details where relevant, listing preferences, business-sale enquiries, correspondence, billing details, information contained in documents uploaded through Active Sales and information provided when preparing or administering a Listing.
4.3 Buyer information
We may collect buyer contact details, company or acquisition information, business interests, preferred business categories and locations, investment or purchase criteria voluntarily supplied by you, confidentiality agreement records, Listings viewed, enquiries submitted, documents accessed and communications concerning a potential acquisition.
4.4 Payment information
We may collect information concerning amounts paid, invoices, payment status, transaction identifiers and limited payment information supplied by our payment processor. Where payment processing is undertaken by a third-party payment provider, full payment card information may be collected and processed directly by that provider rather than Active Sales.
4.5 Website and technical information
We may collect IP addresses, device information, browser type, operating system, login history, referring website, pages viewed, dates and times of access, approximate location derived from technical information, cookie identifiers, analytics information, and platform security and audit data.
4.6 Communications
We may collect emails, support requests, enquiry forms, complaints, feedback, telephone notes and other communications with us.
5. AI PORTAL INFORMATION
Where you use an Active Sales AI-assisted information portal, we may collect and hold your identity and account information, questions or prompts submitted by you, AI-generated responses, date and time of interactions, the Listing associated with the conversation, documents or information accessed, source information used to generate a response where technically available, questions escalated to the seller or their authorised representative, seller responses, feedback concerning AI responses, and related security and audit information.
Users will be informed when they are interacting with an AI-assisted service. AI Portal interactions may be made available to Active Sales and, where relevant, the relevant seller, business broker or authorised representative for purposes including responding to buyer enquiries, verifying information, correcting inaccurate responses, answering unanswered questions, maintaining consistent information, operating the business-sale process, security, audit and dispute management, and improving the operation of the relevant Listing and platform.
6. CUSTOMER DOCUMENTS AND PERSONAL INFORMATION
Business owners and brokers may upload documents relating to businesses advertised through Active Sales. Those documents may incidentally contain personal information about employees, contractors, customers, members or other individuals. We require users supplying documents to avoid providing unnecessary personal or sensitive information and to redact or de-identify information where reasonably practicable. Users supplying personal information about another person are responsible for ensuring they have lawful authority to provide that information.
7. SENSITIVE INFORMATION
Sensitive information includes certain information concerning matters such as a person's health, racial or ethnic origin, political opinions, religious beliefs, professional or trade association membership, trade union membership, sexual orientation, criminal record and biometric information. Active Sales does not generally require sensitive information to provide its marketplace services. You should not upload sensitive information unless it is reasonably necessary for the relevant purpose and you have lawful authority to provide it. Where applicable law requires consent before we collect sensitive information, we will obtain that consent or otherwise only collect the information where permitted by law.
8. HOW WE COLLECT PERSONAL INFORMATION
8.1 Directly from you
We may collect personal information when you create an account, purchase or prepare a Listing, enquire about a business, sign a confidentiality agreement, use the AI Portal, upload documents, submit a form, contact us, subscribe to communications, request broker assistance, make a payment or otherwise use the Active Sales platform.
8.2 From another Active Sales user
For example, a seller may provide information relevant to a prospective purchaser enquiry, a broker may provide contact details for an authorised seller representative, or a business owner may nominate advisers or representatives.
8.3 From service providers
We may receive information from payment providers, analytics providers, authentication providers, email providers, website hosting providers, security providers and other technology providers used to operate Active Sales.
8.4 From publicly available sources
Where appropriate and lawful, we may collect business contact or professional information from publicly available sources.
9. WHY WE COLLECT AND USE PERSONAL INFORMATION
We may collect, hold, use and disclose personal information for purposes including creating and managing accounts, providing and administering Listings, processing payments, communicating with users, providing buyer enquiry functionality, facilitating communications between buyers and sellers or brokers, facilitating confidentiality agreements, managing confidential-document access, operating the AI Portal, escalating buyer questions, maintaining an audit trail of information provided through the platform, authenticating users, preventing fraud and unauthorised access, managing cybersecurity, customer service, resolving complaints and disputes, analytics and platform improvement, administering subscriptions, maintaining records, complying with legal and regulatory obligations, sending marketing where permitted by law, and other purposes disclosed to you at the time information is collected.
10. AI AND PERSONAL INFORMATION
We may use artificial intelligence and automated software to assist with locating relevant information within approved business-sale materials, responding to questions about a listed Business, summarising approved information, organising documents, identifying unanswered questions and assisting with platform administration.
Our buyer-facing AI Portal is intended to operate as an information retrieval and question-answering tool. It is not intended to independently make significant decisions about an individual's rights or interests. We do not intend to use the AI Portal to automatically determine whether a person may purchase a business, whether a person has sufficient financial capacity, whether a buyer should be accepted or rejected by a seller, whether an offer should be accepted, or another material transaction decision concerning an individual. Where personal information is processed through AI systems, we seek to limit that information to what is reasonably necessary for the relevant function.
11. AI MODEL TRAINING
Active Sales does not intentionally authorise confidential business-sale documents, confidential buyer communications or identifiable AI Portal conversations to be used to train publicly available general-purpose artificial intelligence models unless that use has been clearly disclosed, Active Sales has determined that the use is lawful, and any consent required by law has been obtained. We may use appropriately de-identified or aggregated information to analyse and improve our services where permitted by law.
12. DISCLOSURE TO SELLERS AND BUSINESS BROKERS
Where you enquire about a Business, we may provide relevant information about you to the Business owner, the person authorised to manage enquiries for that Business or the licensed business broker responsible for that Listing. Information provided may include your name, contact information, buyer profile information provided by you, confidentiality agreement status, your enquiry, questions you submit, relevant AI Portal questions and information reasonably required to respond to the business-sale enquiry.
13. DISCLOSURE TO PROSPECTIVE PURCHASERS
Where you advertise a Business, information you approve for publication may be displayed publicly. Information approved as confidential may be disclosed to prospective purchasers who satisfy the access requirements associated with the relevant Listing. We will not intentionally publish information identified as confidential for general public access.
14. SERVICE PROVIDERS
We may disclose personal information to third parties that assist us to operate Active Sales, including providers of website hosting, cloud infrastructure, database services, document storage, artificial intelligence services, email and messaging services, customer relationship management systems, payment processing, electronic signing, analytics, cybersecurity, technical support, professional advice and other services reasonably required to operate the platform. We seek to provide those service providers only with information reasonably required for the services they perform.
15. BUSINESS BROKER REFERRALS
Active Sales may offer users the opportunity to request professional business brokerage assistance. If you expressly request an introduction to a business broker, we may disclose information you have authorised us to disclose to that broker for the purpose of responding to your request. For example, where you request an introduction to Vision Brokers & Advisors, we may disclose your authorised contact and business information to Vision Brokers Pty Ltd. Vision Brokers' handling of personal information after it receives the referral will be governed by its own privacy practices and applicable law. Active Sales will not disclose your details to a business broker for a requested brokerage consultation unless you have requested or authorised that referral or another lawful basis permits the disclosure.
16. OTHER DISCLOSURES
We may also disclose personal information to our employees and contractors who require access to perform their duties, to accountants, lawyers, insurers and professional advisers, where required or authorised by law, in response to valid legal process, to prevent or investigate suspected fraud, security incidents or unlawful conduct, to protect our legal rights, with your consent, or in connection with a genuine proposed or completed sale, restructure, financing or transfer of all or part of the Active Sales business, subject to appropriate confidentiality arrangements.
17. OVERSEAS DISCLOSURE AND PROCESSING
Some technology providers used by Active Sales may store, process or access information outside Australia. The countries in which overseas recipients are likely to be located will depend upon the providers used by Active Sales.
Before publication of this Policy, Active Sales should confirm its production technology providers and insert the likely countries here, where practicable: [INSERT CONFIRMED COUNTRIES].
Where the Australian Privacy Principles apply to an overseas disclosure, Active Sales will take reasonable steps required by applicable law in relation to the overseas recipient, subject to any applicable exception.
18. SECURITY
We take reasonable steps appropriate to the nature of the information we hold to protect personal information against misuse, interference, loss, unauthorised access, unauthorised modification and unauthorised disclosure. Security measures may include access controls, authentication, encryption, secure hosting, logging, monitoring, backups, role-based permissions and appropriate contractual arrangements with service providers. No internet or electronic storage system can be guaranteed to be completely secure.
19. DATA BREACHES
Where applicable, Active Sales will respond to suspected data breaches in accordance with its legal obligations. Where the Notifiable Data Breaches scheme applies and an eligible data breach occurs, Active Sales will notify affected individuals and the Office of the Australian Information Commissioner where required.
20. RETENTION
We retain personal information only for as long as reasonably required for the purposes for which it is held and any applicable legal, accounting, contractual, security, dispute-management or record-keeping requirements. Different information may be retained for different periods. We may retain account and transaction records, evidence of contract acceptance, payment records, confidentiality agreement records, security logs, business-sale enquiry records, AI Portal audit records, and records required to establish what information was provided during a Listing. Where personal information is no longer required and applicable law requires us to do so, we will take reasonable steps to destroy or de-identify it.
21. DIRECT MARKETING
We may send marketing communications where permitted by law. Where express consent is requested, marketing consent will be separate from acceptance of our Listing terms. You may withdraw consent or unsubscribe from marketing communications at any time using the unsubscribe facility included in the communication or the contact details below. We may still send non-marketing service communications reasonably necessary to administer your account, Listing, transaction or security.
22. BUSINESS ALERTS
If you subscribe to business alerts, we may use information including your email, preferred industries, price range, location preferences and other criteria supplied by you to provide relevant Listing notifications. You may unsubscribe from those alerts at any time.
23. COOKIES AND ANALYTICS
Active Sales may use cookies and similar technologies to operate the website, remember preferences, maintain logged-in sessions, protect account security, understand website usage, measure performance and support marketing where permitted. We may use third-party analytics and advertising technologies. Where required, information about particular cookie technologies and available controls will be provided through our website or cookie controls. You may be able to restrict cookies through your browser settings, although doing so may affect some platform functions.
24. THIRD-PARTY WEBSITES
The Active Sales website may contain links to websites operated by third parties. Active Sales does not control the privacy practices of those third-party websites. You should review the privacy policies of third parties before providing personal information to them.
25. ANONYMITY AND PSEUDONYMS
You may browse publicly available Active Sales content without creating an account where the platform permits this. Some services require identification. For example, we may reasonably require your identity where necessary to purchase a Listing, process payment, sign a confidentiality agreement, access confidential business information, manage security, communicate a business-sale enquiry or comply with applicable law.
26. ACCESS TO PERSONAL INFORMATION
You may request access to personal information Active Sales holds about you. To make a request, contact us using the details below. We may need to verify your identity before providing access. In some circumstances permitted by law, we may refuse access or provide access in another form. Where required by law, we will explain a refusal and available complaint mechanisms.
27. CORRECTION
If you believe personal information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, you may request correction. We will take reasonable steps required by applicable law to correct information where appropriate.
28. DELETION REQUESTS
You may ask us to delete personal information about you. Whether we can comply will depend on matters including why the information is held, contractual obligations, confidentiality records, security requirements, dispute or legal requirements, applicable record retention obligations and applicable privacy law. Where we cannot delete particular information, we may explain why and consider whether access or use can appropriately be restricted.
29. PRIVACY COMPLAINTS
If you have a concern or complaint about the way Active Sales handles your personal information, please contact us. Please provide sufficient information for us to understand and investigate the issue. We will seek to investigate and respond within a reasonable period. If the Privacy Act applies to the relevant matter and you are not satisfied with our response, you may be entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).
30. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes to our services, new technology, changes to our information-handling practices or changes to applicable law. The current version and effective date will be published on the Active Sales website. Where a change materially affects how we handle personal information already collected, we will consider what further notification or consent may be required.
31. CONTACT ACTIVE SALES
For privacy enquiries, access requests, correction requests or complaints:
Privacy Officer
Active Sales
Operated by Stibbard Holdings Pty Ltd t/as Active Sales
ABN: 15 661 021 334
Email: info@activesales.com.au
Website: www.activesales.com.au
Privacy Policy Version: AS-PP-v1.0
Effective Date: 13 August 2026