Legal Pages

Privacy Policy

Bugaboo.com (the “Company”) considers privacy protection for the customers most valuable and makes its best efforts in protecting personal information of the customers. In order to protect the personal information of the customers under Article 30 of the Privacy Protection Act and make prompt and smooth treatment of customer grievances related thereto, Bugaboo.com establishes and discloses its following privacy policy. This privacy policy may be renewed if any change in laws, regulations or guidelines related to personal information is made, or be changed due to changes in the policy of Bugaboo.com and it is recommended that the users check the website of Bugaboo.com frequently while visiting such website. For the definitions used in this privacy policy (the “Policy”), please refer to the user agreement of Bugaboo.com

Article 1 (Purpose of Personal Information Processing)

1.1 Bugaboo comprocesses the personal information (the “PI”) for the following purposes. Any Personal Information Under processing will not be used for other purposes than the followings and, if any change in such purpose is made, Bugaboo.com will take necessary measures, including obtaining a separate consent as prescribed in Article 18 of the Privacy Protection Act:

1.1.1 self-identification, real-name verification, confirmation of intent to membership for service use and use of age limit services;

1.1.2 Delivery of noticed details, securing a communication route for handling complaints, and securing accurate shipment information while shipping the goods,

1.1.3 Management of overall operation, including carrying out entry, receipt and registration of events, promotion and survey which are held by the corporate body for the website management, Bugaboo Korea, and Bugaboo International b. v.  Or the service and shipment of giveaway, products, newsletter and various promotional materials

1.1.4 Delivery of various news and noticed details related to Bugaboo.com or the Service and confirmation of self intent,

1.1.5 Analysis of demographics necessary for marketing activities of Bugaboo.com or the Service

1.2 The personal information of the members of Bugaboo.com will be used within the scope of notice as stated in this Privacy Policy and will not be used beyond such scope or be provided to other companies/agencies except for the followings

1.2.1 If the member gives a prior consent, Bugaboo.com will inform the member of all the following matters prior to provision of Personal Information of such member to a 3rd party

1.2.1.1 Person to be provided such PI, 

1.2.1.2 Purpose of use of Personal Information by the person to be provided PI, 

1.2.1.3 Items of Personal Information to be provided, and 

1.2.1.4 The period of retention and use of Personal Information about the person to be provided such PI 

1.2.2 When a provision of Personal Information Is required under the provision of applicable laws or investigation agencies under the procedure and method as prescribed in applicable laws,

1.2.3 When a business is transferred: if a transfer of Personal Information of members is necessary due to occurrence of causes related to the business transfer, Bugaboo.com shall give a prior notice of the fact of such transfer to the member under the procedure and method as prescribed in applicable laws, including the Act on Promotion of Information and Communication Network Use and grant to the member the right to withdraw the consent on the transfer of Personal Information

Article 2 (Period of Processing and Retention of PI)

2.1 Bugaboo.com will process and retain the Personal Information Within the period of retention and use of Personal Information as prescribed in the laws and regulations or those to which has been consented while collecting Personal Information from the main agent of such information. 

2.2 The period of processing and retention for each Personal Information Are as follows:

2.2.1 Membership and management of homepage members: until withdrawal from the homepage of business provider/association: Provided that, if the case falls under any of the following, until relevant cause extinguishes,

2.2.1.1 If any investigation or examination is under progress due to violation of applicable laws and regulations, until such investigation or examination is completed; or

2.2.1.2 If any claim-obligation relationship due to the use of homepage remains, until such relationship is settled

2.2.2 Provision of goods or services: until the supply of goods and services is completed and the settlement and calculation of payment are completed: Provided that, if the case falls under any of the following, until relevant period lapses:

2.2.2.1 Record of transactions, including marketing, advertisement, details and performance of the contract:

- For the record of marketing and advertisement: 6 months

- For the record of withdrawal of contract or offer, payment settlement and supply of the goods: 5 years

- For the record of treatment of consumer complaint or dispute resolution: 3 years

2.2.2.2 Retention of documents confirming the communication under Article 41 of the Communications Privacy Act

- Date and time of commencement and completion of electric communication of members, number of opposite members, usage degree, and location tracking of base station: 1 year

- Documents of computer communication, internet log record and  tracking of connection place: 3 months

2.2.3 For the dormant members, Bugaboo.com will handle as followings under Article 29 of the Act on Promotion of Information and Communication Network Use and Article 16 of the Enforcement Ordinance of the same Act:

 - Criteria of non-use: as of the login date for the service of Company,

- Expiration period: 1 year or the period selected by the customer,

- Guidelines on treatment of dormant members: guidelines to be given through 30 days prior notice through the mail

- Personal Information procession for dormant members: measures for separation and storage

- Information to be separated and stored: including member information, information regarding the order/settlement and the civil claims,

- Retention period of information to be separated and stored: to be retained as prescribed in applicable laws and regulations

- Account activation: measures for account activation shall be taken upon request of customers

Article 3 (Provision of Personal Information to 3rd Party)

3.1 Bugaboo.com will process the Personal Information Only within the scope as expressly set forth in Clause 1 hereof (Purpose of Personal Information Processing) and provide the Personal Information to a 3rd party only when the case falls under Article 17 of the Privacy Protection Act including special provisions of the laws and the followings:

3.1.1 When minimum user information (including name, address, and telephone number) necessary for shipment to the delivery companies for delivery purpose,

3.1.2 When the Personal Information collected by Bugaboo.com through marketing agencies with which Bugaboo.com has concluded the contract is consigned,

3.1.3 When it is necessary for preparation of statistical data, academic researches or marketing research and it is provided in the form under which specific individual cannot be identified,

3.1.4 When it is necessary to calculate the payment for the transaction of the goods,

3.1.5 When it is necessary for self-identification to prevent theft and use,

3.1.6 When any inevitable cause exists as prescribed in the laws, or

3.1.7 When it is necessary for report and marketing of worldwide Bugaboo and their affiliates which are owned by website management companies, Bugaboo Korea, and Bugaboo International b. v.

3.2 Bugaboo.com may provide the customers with the link to the websites or documents of other companies and, in such event, Bugaboo.com has no right to control over external websites and documents, and will not be responsible for or guarantee the usefulness of the services and documents provided from such websites or documents. If the customer clicks the links, which are contained in Bugaboo.com and moves to the page of other websites, please examine the policy of the websites newly visited because the privacy policies of relevant website is not involved to Bugaboo.com

Article 4 (Consignment of Personal Information Processing)

4.1 For smooth processing of Personal Information Business, Bugaboo.com consigns such business as follows,

 

Consignees

Description of consigned business

Information to be provided

Intershop Communications AG

Handle the order

Member information, information related to order and shipment

Orderwave

Handle the order

Member information, information  related to order and shipment,

Emark

Send emails for marketing

Member information

Panalpina World Transport Ltd

Carry out shipment and delivery

Member information, information  related to order and shipment

Adyen

Handle the settlement with a credit card

Information related to encrypted settlement

Exact

Record information regarding the accounting & customer service

Member information, information  related to order and shipment

 

4.2 Upon execution of consignment agreement, Bugaboo.com clearly states therein the prohibition of Personal Information Processing for other purpose than those to perform the consigned business, measures to be taken for technical and managerial protection, restriction on sub-consignment, management and supervision of consignees and damage under Article 25 of the Privacy Protection Act and supervises whether the consignee process the Personal Information Safely or not

 

4.3 If the description of the consigned duties or consignee is changed, Bugaboo.com will disclose such change without delay through this Policy.

 

 

Article 5 (Rights, Obligation of Main Agent of Personal Information and Method of Exercise)

 

5.1 Main agent of Personal Information (the “MA”) may exercise the following right related to privacy protection at any time      :

 

5.1.1 Request for access to PI,

 

5.1.2 Request for making correction of error,

5.1.3 Request for removal, and

5.1.4 Request for suspension of processing.

5.2 Should an user’s consent is obtained by Bugaboo.com for collecting PI, Bugaboo.com shall make a prior statement or give a prior notice of the identity of person responsible for managing PI, (department, name, telephone number and other contact), purpose and use of Personal Informationcollection and the matters as prescribed in Article 22(2) of the the Act on Promotion of Information and Communication Network Use including those on provision of information to a 3rd parson (person receiving such information, purpose and details of provision of PI). The users may withdraw such consent at any time.

5.3 Any exercise of the right as set forth in the foregoing Paragraph 5.1 may be made through written documents, telephone call, electronic mail and fax and Bugaboo.com will take measures without delay.

5.4 If the MA request for correction or deletion of any error in his or her PI, Bugaboo.com will not use or provide such Personal Informationuntil such correction or deletion is completed. For the member information, the users may modify or access to his or her Personal Information Directly on the member information page after log-in

5.5 The exercise of rights under the foregoing Paragraph 5.1 may be made through agents, including a legal representative of MA or a person delegated by MA and, in such event, the power of attorney in the form of Exhibit 11 of the Enforcement Regulation of the Privacy Protection Act shall be submitted.

5.6 MA shall not infringe on the Personal Information or privacy of him/herself and others which are processed by Bugaboo.com in violation of applicable laws and regulations including Privacy Protection Act.

Article 6 (Item of Personal InformationItem Processed and Method of Collection)

6.1 Bugaboo.com arranges the procedure under which the users may click on the button ‘I agree’ or ‘I don’t agree’ to the details of the privacy policy or user agreement and, if the user clicks on the button ‘I agree’, such user shall be considered to have consented to the collection of PI. The users have the right to reject to make consent to the collection of Personal Information but may be limited to the service use.

6.2 Bugaboo.com processes the following items of PI:

6.2.1 Membership and management of homepage

- Required items: Name, e-mail address, whether to receive e-mail, mobile phone, whether SMS is received or not, desired ID (in case of member), password (in case of member), birth date, and sex

- Optional items: contact information

6.2.2 Provision of goods and services

- Required items: Name, birth date, ID, password, address, telephone number, e-mail address, I-PIN number, and payment information such as credit card number and bank account information 

- Optional items: interested areas and details of prior purchase

6.3 The following Personal Information Items may be automatically created and collected while the user uses the internet service

- IP address, cookie, MAC address, service use record, connection log, cookie, payment record, visit record, and wrongful use record.

6.4 The method of collection of Personal Information Is as follows,

6.4.1 Joining membership through the homepage, written form, telephone call and fax,

6.4.2 Provided by partner companies,

6.4.3 Collecting and cooperating through event entry, tool for collecting service use record, and

6.4.4 Provided from the website management company, Bugaboo Korea, and  Bugaboo International b. v.  

6.5 The non-member customers of Bugaboo.com may also purchase the goods and service products. If any non-member customer places an order for the goods, Bugaboo.com request only Personal Information Necessary for shipment, payment,  making inquiry of the details of the order or purchase confirmation. If a non-member purchases in Bugaboo.com, any information of the person placing an order or receiving the goods will not be used for other usage than the usages related to payment and shipment of the goods. 

Article 7 (Destruction of PI)

7.1 Bugaboo.com will destruct relevant Personal Information When such Personal Information becomes not necessarily including the lapse of retention period and achievement of purpose of processing.

7.2 If any Personal Information Is required to be retained continuously under other laws and regulations even though the lapse of retention period and achievement of purpose of processing of the Personal Information to which is consented by MA, Bugaboo.com will either transfer such Personal Information to a separate DB or preserve in a different storage.

7.3 The procedure and method of destruction of Personal Information Are as follows:

7.3.1 Procedure of destruction

- Bugaboo.com selects the Personal Information which is to be destructed with the approval of the person responsible for privacy protection of the Company

7.3.2 Method of destruction

- Any Personal Information recorded or stored in an electronic file will be destructed by using the methods, including Low Level Format to ensure that such Personal Information record cannot be regenerated and the Personal Information recorded and stored in a paper will be destructed by discarding or incinerating such Personal Information by pulverizer.

Article 8 (Installation/Operation of Equipment of Automatic Collection of Personal Information and Matters on Rejection)

8.1 The Service identifies the person connecting through Cookie and Pixel Tag and use the Cookie for the following purpose. Bugaboo.com may provide special customized services which are available only through the use of the Cookie and may use the Cookie in order to identify the uses and maintain the log-in conditions of the users.

- Cookie means a small text file which is transmitted by the websites and the service provider thereof through web browser in the computer of the users and such file allow the system of websites or service provider to identify the web browser of users, store and memorize a specific information. Pixel tags means a small graphic image which delivers any electronic mail in a stereotyped format to the users and informs when the user reads it.

8.1.1 Memorize the contents used while prior visiting of the Service by the users and provide the users with improved service environments,

8.1.2 Analyze traffic of service visit and identify the form of use of the Service, or

8.1.3 Utilize for analyzing service visit traffic through the conclusion of an agreement with a 3rd party based on the needs.

8.2 The user may make the warning window appear while cookie collection at the web browser of computer used by him/herself or stop the function of Cookie (for further details, please refer to the ‘Help & Support’ or ‘Help’ function of the web browser)

8.3 If the Cookie is stopped, various contents or functions in the Service which have been available through such function cannot be used and the Service may not be run properly.  

Article 9 (Consent to Overseas Transfer of PI)

9.1 Any part of the customer information provided by the users to Bugaboo.com may be stored in the server located in overseas countries under the purpose of data back-up or company policy.

9.2 Bugaboo International b. v., as a multinational corporation, has a lot of users worldwide and the management of Personal Information of users are processed strictly as required in privacy protection policies in Korea. Thus, please be informed that any information provided by the users to Bugaboo.com may be transferred to, stored in and backed up in the server as described above and the details of them are as follows,

9.2.1 A person receives PI:  Bugaboo.com transfers your Personal Information Collected as described above by complying with its privacy policy to the other companies owned by Bugaboo International b. v. Worldwide including Netherland. Any Personal Information to be collected by Bugaboo.com will be transmitted to the system owned by Bugaboo International b. v. Which is located in Netherland as of the time of collection. For the name of other companies receiving the PI, please refer to the privacy protection policy.

9.2.2 Purpose of Personal Information use of person receiving Personal Information Bugaboo International b. v. Personal Information may be stored in the server located in overseas countries for the integration of customer data with the website of Bugaboo International b. v.  (Bugaboo.com) for the purpose of data back-up and company policy

9.2.3 Items of Personal Information to be provided: member information, information related to order and shipment,

9.2.4 The period of retention and use of Personal Information by the person receiving PI: If the Personal Information Becomes unnecessary including the case of achievement of the purpose of processing or upon request of MA, such Personal Information Will be destructed

9.2.5  Right to reject to consent and disadvantages: share of the required information is necessary for performing the agreement with you without fail. However, you may reject to give a consent to such share of optional information and, if any consent is rejected, any information and benefit in the service will not be provided by Bugaboo.com

Article 10 (Restriction on Transmission of Commercial Information)

10.1 Bugaboo.com will not transmit any commercial information for profit seeking against the member’s intent to reject to receive

10.2 If a member consents to transmission of e-mail such as newsletter, Bugaboo.com will take measures to ensure that the member can check easily in the column of the title and main text of e-mail as follows:

10.2.1 Column of title of the email: the text of (commercials) may not be marked in the column of the title and the main details of the column of the main text of emails will be marked

10.2.2 Column of the main text of the email: the name, e-mail address, telephone number and address of the transmitter who may present intent to reject to receive will be marked and the method of easy marking such intent, date and details of consent of members will be stated.

10.2.3 If any commercial information for profit seeking is transmitted through the text message transmission other than e-mail such as transmission of fax or mobile phone message, the word of (commercials) will be marked at the beginning of details of such transmission and Bugaboo.com will take measures to ensure that the contact information about transmitter will be stated in the text transmitted.

10.2.4 Any member may express its intent to reject to receive at any time when he or she receives commercial information for profit seeking and Bugaboo.com will take measures to stop such transmission immediately and inform to the member.

Article 11 (Measures to Secure Safety of PI)

11.1 Bugaboo.com takes the following measures in order to secure safety of PI

11.1.1 Technical measures

- In handling the Personal Information of the members, Bugaboo.com seeks for the following technical measures to secure safety to ensure that the Personal Information Will not be lost, stolen, leaked, altered or damaged.

- Any Personal Information of members is protected by the password and important data are protected through a separate security function by encrypting files and transmitted data and using file lock up functions.

- Bugaboo.com takes measures to prevent any damage caused by computer virus by using vaccine program

- Vaccine programs are updated on a regular basis and, if any sudden virus appears, the vaccine against it will be immediately provided in order to prevent infringement on PI.

- Bugaboo.com adopts a security device (SSL or SET) with which Personal Information Can be safely transmitted in the networks by using encryption algorithm

- In preparation for external intrusion such as hacking, the Company makes a full security preparation by using a system for blocking such intrusion and system for analyzing weak points in each server

11.1.2 Managerial measures

- Bugaboo.com limits the number of persons authorized to access to Personal Information of members to the minimum and the persons authorized to access to the Personal Information Are as follows

   - The person carrying out marketing business directly to the members,

   - The person carrying out the business to manage Personal Information Including persons responsible or in charge of managing the PI,

   - A person who has no choice but to handle the Personal Information in carrying out his or her duties.

- The Company provides regular internal education and commissioned education on acquisition of new security technologies and obligations to protect the Personal Information for its employees handling the PI,

- The Company prevents information leakage by the employees through non-disclosure agreement and  arranges internal procedures to inspect whether the employees comply with the obligations under privacy protection policy.

- Any transfer of the duties of the person handling Personal Information Is carried out under the condition where security is maintained strictly and the responsibilities for the accident of Personal Information Are clearly set forth for the employees joining and leaving the Company 

- Personal Information and other general data are separately stored in separate servers not to be commingled 

- The Company controls over the access to the Personal Information by establishing the special protection area for the computer room and data storage room.

11.2 Bugaboo.com will not responsible for the matters which arise out of individual mistake of users or basic danger in internet. In order to protect the Personal Information of himself or herself, each member shall properly manage his or her own ID and password, and responsible for such management in order to protect his or her own Personal Information.

Article 12 (Person Responsible for Privacy Protection)

12.1 Bugaboo.com designates a person responsible for privacy protection as follows to ensure that such person will handle general affairs of or be responsible for the business of Personal Information Processing and handle the complaint of MA and damage relief.  

▶ Department in charge of privacy protection  

Name of Dept.: Bugaboo International Legal team

Contact: Legal_Europe@bugaboo.com

12.2 MA may make an inquiry on the privacy protection, complaint treatment and damage relief arising in the course of using the Service (or business) of Bugaboo.com to the person responsible for the Personal Information and the department in charge of PI. Bugaboo.com will make a prompt response and treatment to such inquiry. 

Article 13 (Claim for Access to PI)

MA may claim for access to Personal Information to the department as described below under Article 35 of the Privacy Protection Act and Bugaboo.com will make its best efforts in ensuring that such claim will be promptly treated. 

▶ Department receiving and handling claim for access to Personal Information

Name of Dept.: Bugaboo International Legal team

Contact: Legal_Europe@bugaboo.com

Article 14 (Method of Relief of Right Infringement)

MA may make inquiry on the damage, relief and consultation on infringement on Personal Information to the following agencies

<The following agencies are different agencies from Bugaboo.com and, for further help or if you are not satisfied with the result of treatment of complaint on Personal Information and damage relief, please contact the following agencies>

▶ Report Center of Personal Data Infringement (operated by the Korea Internet Promotion Institute)

- Businesses: reporting and filing for consultation on Personal Informationinfringement

- Homepage : privacy.kisa.or.kr

- Tel.: (without telephone exchange code) 118

- Address: Report Center of Personal Data Infringement

135 Jungdae-ro, Songpa-gu, Seoul, Republic of Korea (138-950)

▶ Personal Information Dispute resolution commission  (operated by the Korea Internet Promotion Institute)

- Businesses: filing for Personal Information Dispute mediation and mediation of collective dispute (civil resolution)

- Homepage : privacy.kisa.or.kr

- Tel.: (without telephone exchange code) 118

- Address: Report Center of Personal Data Infringement

135 Jungdae-ro, Songpa-gu, Seoul, Republic of Korea (138-950)

▶ Cyber Crime Investigation Team of the Supreme Prosecutor’s Office

: 02-3480-3573 (www.spo.go.kr)

▶ Cyber Terror Response Center of the National Police Agency: 1566-0112 (www.netan.go.kr)

Article 15 (Modification of Privacy Protection Policy)

15.1 This Policy will be applied from the first day of April, 2017. If any addition, deletion and amendment is made in the details thereof, the Company will inform through the notice bulletin of the website at least 7 days prior to the revision (in case of changes in important matters, at least 30 days prior to revision). If any change in collection, utilization or provision to a 3rd party of Personal Information is made and when a consent is to be obtained, the Company will arrange and proceed a separate procedure of consent.

15.2 Any existing privacy protection policy may be checked in the following.