This privacy statement provides information on the processing of Personal Information by Bugaboo International B.V. and Bugaboo Australia Pty Ltd (ACN 129 828 280), hereafter “Bugaboo”, “We” or “Us”. We respect your privacy and aim to carefully and safely use your Personal Information.
Bugaboo recognises the importance of privacy and is committed to the management and handling of Personal Information and Sensitive Information (as those terms are defined in the Australian Privacy Act 1988 (Cth) (Privacy Act)) in an open and transparent way in compliance with the Privacy Act and this policy creates a framework to ensure that any Personal Information we hold is collected, used, stored and disclosed in accordance with the Australian Privacy Principles in the Privacy Act.
This Privacy Statement is applicable to the processing by Bugaboo of all Personal Information of its customers, suppliers and business partners and other individuals.
In this Privacy Statement we describe who we are, how and for which purposes we process your Personal Information, how you can exercise your privacy rights and all other information that may be relevant to you.
We try to make all information clear and readable. However, if you have any questions about our use of your Personal Information after reading this Privacy Statement, you can of course always contact us. Further, on in this Privacy Statement you can read how you can get in touch with us.
Finally, we would like to point out that our service provisions develop and with this also our Privacy Statement. We recommend you to regularly check if there has been any modification to the Privacy Statement, so that you exactly know where you stand. All the way at the bottom of this Privacy Statement, you can read when this Privacy Statement has been modified for the last time. In case of significant modifications, we will inform you by email and/or notify you on our homepage.
Please notify Bugaboo in writing if you are currently, or in the future become, a resident of the European Union, so that we can assess whether any Personal Information we hold falls within the scope of the GDPR.
Who are we?
At Bugaboo our mission is, and always has been, to help you move freely. We design and manufacture mobility products that combine design with engineering and beauty with functionality. We are established in the Netherlands at the Paasheuvelweg 9a-b, 1105 BE Amsterdam, The Netherlands.
Bugaboo is established worldwide and operates correspondingly. Bugaboo provides several kinds of services. With regard to the activities as described in this Privacy Statement, Bugaboo together with Bugaboo Australia Pty Ltd can be qualified as ‘Joint Controllers’ within the meaning of the law.
Which Personal Information does Bugaboo collect from you?
Bugaboo collects several categories of Personal Information:
Personal and contact details (for example name, ship- and bill-to address, email address, telephone number);
- Account details (for example username and password);
- Purchase details (for example date of purchase and type of product);
- Marketing and market research preferences (for example whether you have registered or signed off for e-mail offers and/or our research survey);
- Device information (for example: IP-address, language and browser settings, time zone, screen resolution, operating system);
- Interaction details including pictures (for example your contact with our customer service, digital and/or written correspondence and for instance, when you upload pictures to support your service requests).
When you purchase a product, you will also receive a request to provide your payment details. That Personal Information will be collected and processed directly by one of our third party payment providers. Those third parties are responsible for processing your payment details within the limits set by law. Bugaboo does not have access to your payment details and that Personal Information will not be collected and/or processed by us. Thus, this Privacy Statement does not apply on the aforementioned payment processing activity. For more information about the way your payment details are collected and processed, we refer you to the privacy statement on the website of the payment provider you choose for payment processing.
We receive the categories of Personal Information as described above directly from you.
Personal data directly provided by and about you
- Personal data which you provide when creating an account and/or a register a product and/or other information which you enter or provide through the use of our website;
- Personal data which you provide when you purchase a product;
- Personal data which you provide when filling in our paper form during an event;
- Personal data you provide as part of (among other things) service requests, correspondence, feedback, help (Q&A), dispute settlements, and suchlike.
Personal data about others directly provided by you
It is possible that you will share Personal Information about other persons with us. For example, address or contact details of others when you provide us with alternative shipping addresses during the checkout. It is your own responsibility to verify whether those persons approve the disclosure of their Personal Information to Bugaboo.
Personal data we receive from third parties
We can receive (among other things) additional Personal Information, for example with the help of social media platforms or services of third parties, in so far as permitted by law. The limits set by the law can, for example, require you giving consent in advance.
When you communicate or interact with or about us via social media (for example when you post a message, upload media, or press the 'Like' button) we can (or third parties acting on our behalf) collect Personal Information about you (information contained in your public profile such as your (user)name, profile picture, gender, age-range, country, e.g.). We don’t store this information. We use this information to enhance our presence on these platforms and identify the interests and preferences of our (future) customers.
For which purposes does Bugaboo process your Personal Information?
Bugaboo collects and processes your Personal Information for the performance of the purchase agreement(s) entered into with you, administration, service, communication and (personalized or not) marketing, fraud investigation, quality and management purposes and to fulfil all our legal obligations.
Here you will find more detailed information about the different purposes as described above.
Performance of a contract. To prepare, effect, perform and (possibly) terminate the purchase agreement(s) between you and Bugaboo.
Administration. For the performance and monitoring of the administration of Bugaboo in a broad sense.
Service, communication, marketing and personalization purposes. For the performance of customer service, to make (possible personalized) offers, and/or to provide and share information about activities of Bugaboo to you.
Quality and management purposes. To monitor and improve the quality of the services, products, processes and systems, to inform management and to perform internal reviews.
Legislation and regulation. For identification, to counter fraud, to perform audits, to secure safety within Bugaboo and to comply with legislation and regulation.
Which legitimate interest of Bugaboo makes the processing of your Personal Information lawful?
For Bugaboo the processing of your Personal Information is necessary to create and maintain a lasting relationship with its customers, to monitor and improve our products, services and processes and to protect its reasonable corporate interests. For example, to inform our customers about new products, services and activities, to ask consumers to provide us with feedback on our products, to prevent security incidents and abuse of our applications or to protect Bugaboo’s interests in (possible) legal proceedings.
If possible, we will use and apply to our communication the so-called ‘opt-out scheme’. That way you can easily inform us when you no longer want to receive communication of Bugaboo. Of course you can also always contact us directly via firstname.lastname@example.org.
To whom does Bugaboo provide your Personal Information?
Bugaboo can provide your Personal Information to third parties in accordance with this Privacy Statement and in so far as permitted by law. Without your explicit consent Bugaboo does not provide your Personal Information to third parties for their own marketing purposes.
Your Personal Information can be received by the following categories of recipients:
Group companies. As a global organisation, data we collect may be transferred internationally throughout our worldwide organisation. Your Personal Information may be exchanged with our group company’s working under the name ‘Bugaboo’. We exchange your data for administrative purposes and so that we can have a complete overview of your contacts and contracts with Bugaboo. We may also exchange your data in order to offer you a complete package of services and products. We may share Personal Information with our group companies for the purpose of providing jointly content and products and/or services (such as registration and customer support), the development of new products, websites, applications, services, tools and communication, and to prevent, trace and examine possible illegal activities, infringements of our policies, fraud and/or breaches of our data security.
Authorities. For example, supervisory authorities, Tax and Customs Administration, police and other statutory bodies. We may provide your Personal Information:
- to comply with a statutory obligation or court order;
- if this is necessary to prevent, trace or prosecute criminal acts; or
- if this is necessary to enforce our policies, or to protect the rights and freedoms of others.
Business service companies. To provide our services we use third parties. For example, a transportation company which is requested by Bugaboo to deliver the product you have purchased, or an online payment provider to that is requested by Bugaboo to handle online payments. In addition, we also engage third parties such as analytics companies, advertising agencies and social media platforms to analyse the data about your website use, to perform possible personalization of the website and communication, and the display of relevant offers and advertisements.
Other. Each third party to which we – with your consent – provide your Personal Information (for example within the context of a collaboration), and/ or to which Bugaboo now or in the future forms part of as a result of a restructuring, merger or acquisition.
As far as these third parties process your data they do so in the capacity of processor for Bugaboo. Bugaboo has taken the necessary measures to ensure that your data is exclusively used for the above purposes.
How do we protect your data?
We have adopted both technical and organisational measures to protect your data against loss, theft and unauthorised access. Examples are IT security policies, staff training and secure servers.
We continually improve our security measures in case of technological advances and developments. We also recommend that you properly and correctly secure your own passwords and electronic data carriers you use.
In the event of an actual or suspected data breach, we will follow the procedures outlined in our mandatory Data Breach Response Plan, including:
• containing the data breach;
• conducting a risk assessment to assess the severity rating of a suspected or known data breach;
• assessing whether an Eligible Data Breach has occurred.
If an Eligible Data Breach has occurred, we may report the data breach to third parties as required by law, or to other Bugaboo business partners or service providers. We will contact you if you have been personally impacted by an Eligible Data Breach.
Is your Personal Information being transferred outside Australia?
Your Personal Information may be stored and processed in any country where Bugaboo (and its group companies) are located. All Bugaboo entities operate under EU Standard Contractual Clauses, which provide safeguards for cross-border transfers.
We may share Personal Information about you with third parties, such as business partners, service providers, and/or vendors who help us execute our business. If your Personal Information are transferred to a third party in a country that does not provide an adequate level of protection for Personal Information, we will, where required, take measures to ensure that your Personal Information are adequately protected.
European General Data Protection Regulation (GDPR)
If you are a European resident, we may be subject to GDPR in relation to Personal Information it holds about you. Accordingly, we request that you notify us if you are a European resident when you transfer your Personal Information to us or if you are aware that we are collecting your Personal Information. Your Personal Information will still be subjected to the same information security standards as are applied to all Personal Information held by Bugaboo and its global affiliates. However, we may manage your Personal Information in a different manner to take account of data portability entitlements and other GDPR-specific requirements.
How long does Bugaboo store your Personal Information?
Your Personal Information will be removed and/or made anonymous when your Personal Information is no longer necessary for the purposes for which these Personal Information are processed. Your Personal Information will be stored for as long as necessary to provide the services you have requested. We may also need to store your Personal Information for when we have a legal obligation or to resolve disputes. In addition to that, we can assure you that Bugaboo will not store your Personal Information longer than permitted by law.
How long we keep Personal Information can vary widely depending on the context of the services we offer, our legal obligations and the (local) entity that is processing your Personal Information. The following criteria are often used to determine the retention period: nature of the Personal Information, the context in which the Personal Information have been collected, the consequences for the data subject and the existence of appropriate safeguards (such as pseudonymization). Generally Personal Information will be retained for 7 years from the last date of any transactions or agreements entered into between you and Bugaboo.
If you have any questions regarding how long your Personal Information is stored, please contact us via email@example.com.
How to exercise your privacy rights and manage your Personal Information?
You have the right to obtain confirmation as to whether or not Personal Information concerning yourself are being processed by Bugaboo and, if so, to request access to an overview of the Personal Information, and rectification and/or erasure of it. In addition to this, you also have the right of restriction of processing concerning your Personal Information, the right to object to the processing as well as the right to data portability. Below you can read where and how you can invoke all those rights.
You have the right to request access of an overview of your Personal Information, and under certain conditions, rectification and/or erasure of Personal Information. In addition, you may also have the right of restriction of processing concerning your Personal Information, the right to object to processing as well as the right to data portability.
To invoke your right of access, rectification, and/or erasure of Personal Information, your right of restriction of processing, and/or your right to object to processing as well as to invoke your right to data portability, please contact us in the following matter:
- If you have your own account at Bugaboo you have access to a part of the Personal Information which is registered by us. At every desired moment you can rectify or erase these Personal Information.
- In case you want to have access to an overview of all process activities and/or you want to rectify or erase (in so far as permissible) Personal Information and you are not able to do so yourself, you can contact us here: firstname.lastname@example.org.
- In case you do not have an account and you do want to invoke your right of access, rectification, and/or erasure of Personal Information, you can contact us via: email@example.com.
- To invoke your right of restriction of processing, and/or your right to object to the processing as well as to invoke your right to data portability, please contact us here: firstname.lastname@example.org.
Please keep in mind that Bugaboo may ask for additional information to verify your identity.
May you withdraw your consent?
If you gave your consent for a specific process activity concerning your Personal Information, you can at any time withdraw this consent. Keep in mind that withdrawal does not have retrospective effect and the withdrawal of your consent is only possible in case you first have given your consent.
You can contact us to advise of your withdrawal of consent by contacting us via email@example.com.
Can you lodge a complaint?
If you have any further questions about the way we process your Personal Information, please contact firstname.lastname@example.org first.
Should you still be of the opinion that we did not handle your request or complaint satisfactorily, you have the right to lodge a complaint with your local data protection supervisory authority. For example, if you believe that Bugaboo does not use your Personal Information carefully, or because you have sent us a request to access or rectification of your Personal Information and you are not satisfied with our reply.
If you are not satisfied with our reply we can refer you to the Office of the Australian Information Commissioner (as applicable) for further investigation.
Are you obliged to provide your Personal Information to us and what are the consequences if you do not?
In some cases, the provision of your Personal Information is necessary for Bugaboo. For example, to enter into an agreement with you or to provide a service or to create an account. Information fields which are not marked with a * enquire Personal Information of which the provision is not necessary.
When the provision of your Personal Information is necessary for us, we will point that out by using a *. In case you decide not to provide the enquired Personal Information, we shall not be able to enter into the agreement or to provide the service in question. By your act of providing Personal Information enquired by information fields which are not marked with a *, you give your consent to process this Personal Information by and to Bugaboo.
Does Bugaboo use profiling techniques?
We would like to approach you in a personal and relevant way. To make that possible, we bundle, combine and analyse Personal Information so that we can determine the most relevant target groups and segments, content, advertisements, information, moments and channels, and limit the contact requests.
For our profiling purposes the following Personal Information, in alternating combinations, can be combined, analysed or segmented:
- Demographic details: This does not concern Personal Information, but for example district level data. When demographic data is being bundled to an individual, the data could become Personal Information.
- Transactional details: Personal Information which result from a transaction between Bugaboo and you.
- Interaction details: Personal Information which result from correspondence between Bugaboo and you. For example, the products you have ordered or registered, the service requests you created, what kind of browser you use, what kind of device you have and other cookies identifiers. Offline interactions are also included.
- Behaviour details: Personal Information about your behaviour that Bugaboo processes, such as your preferences, opinion, wishes and needs. We can gather this data, for example, by monitoring your surfing behaviour on our website or your link with a social media account. Only with your consent we collect and process information with the help of tracking cookies.
In case you do not want to receive personalized marketing, you can contact us to manifest this by email@example.com.
When was this Privacy Statement last modified?
This Privacy Statement is version 2.1. It has been applicable since 25th of May 2018 and was last modified on 15 November 2021.