1 About this policy
Bugaboo Australia Pty Limited (ACN 129 828 280) and its related entities (as set out in the Schedule) (together, Bugaboo) is committed to protecting the privacy of the personal information which it collects and holds.
Bugaboo must comply with the Australian Privacy Principles under the Privacy Act 1988 (Cth).
(a) the kinds of information that Bugaboo may collect about you and how that information is held;
(b) how Bugaboo collects and holds personal information;
(c) the purposes for which Bugaboo collects, holds, uses and discloses personal information;
(d) how you can access the personal information Bugaboo holds about you and seek to correct such information; and
(e) the way in which you can complain about a breach of your privacy and how Bugaboo will handle that complaint.
personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable:
(a) whether the information or opinion is true or not; and
(b) whether the information or opinion is recorded in a material form or not;
3 Collection and use of personal information
3.1 Types of personal information collected by Bugaboo
Bugaboo collects information from you which is necessary to supply you with goods and services. This includes collecting personal information such as your name, address, email address, IP address, telephone and fax numbers, and any other information which is necessary to assist Bugaboo in providing you with goods and services.
(b) Suppliers / Service providers
Bugaboo collects information from you which is necessary to properly operate its business. This includes collecting personal information such as your name, address, email address, telephone, fax numbers, ABN and professional experience and expertise, and any other information which may be necessary to appropriately conduct its business.
(c) Job applicants
Bugaboo collects information from you which is necessary to assess and engage employment applicants. This includes collecting personal information such as your name, address, date of birth, professional experience, qualifications, references, past employers, and any other information which is necessary to assist Bugaboo assess your suitability for employment.
3.2 How we collect personal information
Bugaboo will usually collect your personal information directly from you, either face to face, over the telephone, via post, fax or email or over the internet. From time to time, Bugaboo may also collect personal information from third parties, such as:
(a) retailers through which you have submitted your warranty registration or claim. For job applicants, information may be collected from past employees/referees/recruitment agencies;
(b) related entities (being those listed in the Schedule).
We will only collect information from third parties where:
(a) you have consented to such collection;
(b) such collection is necessary to enable us to provide you with appropriate services;
(c) such collection is reasonably necessary to enable us to appropriately manage and conduct our business (such as in assessing applications from job applicants); or
(d) it is legally permissible for us to do so.
Bugaboo will only collect information which is necessary to provide you with goods and services or appropriately manage and conduct our business.
3.3 How Bugaboo uses your personal information
Bugaboo only uses your personal information for the purpose for which it was collected by Bugaboo (primary purpose), unless:
(a) there is another purpose (secondary purpose) and that secondary purpose is directly related to the primary purpose, and you would reasonably expect, or Bugaboo has informed you, that your information will be used for that secondary purpose;
(b) you have given your consent for your personal information to be used for a secondary purpose; or
(c) Bugaboo is required or authorised by law to use your personal information for a secondary purpose (including for research and quality improvements within Bugaboo).
For example, Bugaboo may use your personal information to:
(d) provide goods and services to you;
(e) updating you on safety risks relating to any of our products;
(f) assess your suitability for employment;
(g) contact you about our products and services which may be relevant to you, where you have provided us with consent to do so;
(h) appropriately manage or assist us in the running of our business, such as assessing insurance requirements, conducting audits, quality assurance programs, billing, improving our services, implementing appropriate security measures and training personnel;
(i) compile statistics regarding inquiries and customer information for purposes of improving our goods, services and tailoring our marketing; and
(j) effectively communicating with third parties, including any related bodies corporate.
3.4 Complete and accurate details
Where possible and practicable, you will have the option to deal with Bugaboo on an anonymous basis or by using a pseudonym. However, if the personal information you provide us is incomplete or inaccurate, or you withhold personal information, we may not be able to provide the goods and services or support to you are seeking, or deal with you or your application effectively.
4 Disclosing your personal information
Bugaboo will confine its disclosure of your personal information to the primary purpose for which that information has been collected, or for a related secondary purpose. This includes when disclosure is necessary to provide services to you, assist us in running our organisation, or for security reasons.
We may provide your personal information to:
(a) third parties involved in providing services to you (such as suppliers and mail order partner entities);
(b) third parties contracted to provide services to Bugaboo, such as:
(i) third party managers of Bugaboo's website and online ordering capabilities;
(ii) credit reporting/reference agencies and debt collection agencies;
(c) anyone authorised by you to receive your personal information (your consent may be express or implied);
(d) our related entities (being those entities set out in the Schedule);
(e) anyone Bugaboo is required by law to disclose your personal information to.
4.2 Disclosing personal information overseas
Bugaboo is not likely to disclose your personal information to overseas recipients, except:
(a) as disclosed to our related bodies corporate (including those operating in The Netherlands and the United States of America) in the ordinary course of business; or
(b) to the extent that Bugaboo or its related bodies corporate or any third party uses overseas-based servers or service providers.
5 Data storage, quality and security
5.1 Data quality
Bugaboo will take reasonable steps to ensure that your personal information which is collected, used or disclosed is accurate, complete and up to date.
All your personal information is stored securely by Bugaboo or third party storage providers, (including those operating in The Netherlands and the United States of America in either hard copy or electronic form.
5.3 Data security
Bugaboo strives to ensure the security, integrity and privacy of personal information, and will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure. Bugaboo has adopted both technical and organisational measures to protect your data against loss, theft and unauthorised access. We continually review and improve our security measures in case of technological advances and developments.
5.4 Online transfer of information
While Bugaboo does all it can to protect the privacy of your personal information, no data transfer over the internet is 100% secure. When you share your personal information with Bugaboo via an online process, it is at your own risk.
There are ways you can help maintain the privacy of your personal information, including:
(a) always closing your browser when you have finished your user session;
(b) always ensuring others cannot access your personal information and emails if you use a public computer; and
(c) never disclosing your username and password to third parties.
5.5 Credit card payments
All credit card payment information is sent in encrypted form using SSL (Secure Sockets Layer), meaning this information is sent through a secure connection and your credit card details cannot be seen by external parties.
Bugaboo works with an authorised payment partner whenever you pay by credit card. This allows us to immediately verify with your bank the validity of your credit card and the ability to complete your purchase. We reserve the right to verify your identity where you make any payment using a credit card.
(b) Statistical purposes: to record how many visitors visit a specific website, or have clicked on a particular advertisement, so Bugaboo knows which parts of its website are most popular.
7 Links to other sites
Our bugaboo.com website provides links to third party websites. These linked sites may not be under our control and Bugaboo is not responsible for the content of or privacy practices adopted by those websites. Before disclosing your personal information on any other website, we recommend that you carefully read the terms and conditions of use and privacy statement of the relevant website.
8 Accessing and amending your personal information
You have a right to access your personal information which Bugaboo holds about you. If you make a request to access your personal information, we will ask you to verify your identity and specify the information you require.
You can also request an amendment to any of your personal information if you consider that it is inaccurate.
You can contact Bugaboo about any privacy issues as follows:
Contact: Bugaboo Privacy Officer
Address: Paasheuvelweg 9a-b, 1105 BE Amsterdam, The Netherlands
If you would like to unsubscribe from our newsletter at any time or no longer wish to be approached with information about our products and services, you can do so by sending an email to Legal_Australia@bugaboo.com.
If you have a complaint about Bugaboo's information handling practices or consider we have breached your privacy, you can lodge a complaint with:
(a) Bugaboo Privacy Officer, on the contact details listed in clause 8 above; or
(b) the Office of Australian Information Commissioner.
Bugaboo aims to deal with all complaints in a fair and efficient manner.
Company number (if relevant)
Bugaboo International B.V