California Privacy Notice
Effective: January 1, 2020
This California Privacy Notice applies to Personal Information, as defined below, that is processed by Bugaboo in the course of our business, including via the Bugaboo Site, social media accounts, blogs, retail showrooms, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Bugaboo, the “Services”).
This California Privacy Notice is not intended to apply to Personal Information we collect about our employees, applicants for employment, or contractors in the employment context.
“Personal Information” is defined under California law as “information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”
WHAT PERSONAL INFORMATION WE COLLECT
The table below defines the categories of Personal Information we collect as well as examples of Personal Information in such categories. For more information about the personal information we collect, please visit www.bugaboo.com/privacy-policy.
|Identifiers||Name, email address, mailing address, shipping address, phone number, username, alias, unique personal identifier, online identifier, Internet Protocol (IP), or other similar identifiers|
|Protected classification characteristics||Age, gender|
|Commercial information||Purchase history, Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies|
|Internet or other similar network activity||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement, IP address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services, and other actions taken through use of the Services such as preferences|
|Geolocation data||Physical location, Internet Protocol (IP) address, GPS location, longitude/latitude, city, county, zip code, and region|
|Financial information||Payment information, such as credit card number|
|Inferences drawn from other personal information||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes|
HOW WE USE PERSONAL INFORMATION
WHAT PERSONAL INFORMATION WE SHARE
- Business Partners. Bugaboo may share Personal Information with our business partners and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. Bugaboo may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Bugaboo.
- Displaying to Other Users. The content you post to the Services may be displayed on the Services. Other users of the Services may be able to see some information about you, such as your name if you submit a review or provide a testimonial to our Site. We are not responsible for the privacy practices of the other users who view and use posted information.
- Marketing – Interest-Based Advertising and Third-Party Marketing. Bugaboo may allow third party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities on our Sites (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information as well as selected Personal Information (such as demographic information and past purchase history) we have collected with third party advertising partners. These advertising partners may use this information (and similar information collected from other companies) for purposes of delivering targeted advertisements to you when you visit non-Bugaboo related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising”. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you.
- Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve and disclose your Personal Information, other account information and content if we believe doing so is required or appropriate: (i) to comply with law enforcement or national security requests and legal process, such as, a court order or subpoena; (ii) to respond to your requests; (iii) to protect yours, ours or others’ rights, property or safety; (iv) to enforce Bugaboo policies or contracts; (v) to collect amounts owed to Bugaboo; (vi) to comply with records retention policies; (vii) when we believe access, preservation, or disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (viii) if we, in good faith, believe that access, preservation, or disclosure is otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order to allow them to identify users in connection with their investigation of the unauthorized activities.
California law requires that we also list the categories of Personal Information that we have disclosed to third parties for business purposes in the last 12 months. In the last 12 months, we have disclosed all of the categories of Personal Information we describe in the “What Personal Information We Collect” section for business purposes. For example, we may share your shipping address with a third party logistics company the fulfills Bugaboo’s ecommerce orders.
California residents have the right to opt-out of our disclosures of Personal Information that we have disclosed to third parties for valuable consideration (which may be considered “sales” under California law even if no money is exchanged). What is covered as a “sale” under California law is not yet clear, but we currently do not “sell” your information as we understand it. However, Bugaboo respects and understands that you may still want to minimize sharing of your information with third parties for marketing purposes.
If you are a California resident and you would like to minimize sharing of your information with third parties for marketing purposes, please contact:
Bugaboo North America, Inc.
142 W. 57th Street
New York, NY 10019
Or email: firstname.lastname@example.org
As a resident of California, you have certain rights, such as:
- Right to access Personal Information. You may be entitled to receive the specific pieces of your Personal Information we have collected in the 12 months preceding your request.
- Right to data portability. You may be entitled to receive a copy of your electronic Personal Information in a readily-usable format.
- Right to know. You may be entitled to receive information regarding the categories of Personal Information we collected, the sources from which we collected Personal Information, the purposes for which we collected and shared Personal Information, the categories of Personal Information that we sold and the categories of third parties to whom the Personal Information was sold, and the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding your request.
- Right to deletion. You may be entitled to request that we delete the Personal Information that we have collected from you. We will use commercially reasonable efforts to honor your request, in compliance with applicable laws. Please note, however, that we may need to keep such information, such as for our legitimate business purposes or as required to comply with applicable law.
- Right to opt-out of certain sharing with third parties. You may be entitled to direct us to stop disclosing your Personal Information to third parties for monetary or other valuable consideration. What is covered as a “sale” under California law is not yet clear, but we currently do not “sell” your information as we understand it.
You may freely exercise these rights without fear of being denied goods or services. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your personal information. If you are a California resident and would like to exercise one of your rights, please contact us at email@example.com or at 800-460-2922.
California law requires us to verify the requests we receive from you when you exercise certain of the rights listed above. We (or third parties we engage to assist us) may ask you to provide certain information to us in order for us to verify the request.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format. We respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period.
We will deliver our written response by mail or electronically, at your option (depending on how you make your request).
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
In addition to these rights, pursuant to California’s “Shine the Light” law, California residents who share personal information with us have the right to request and obtain from us once per year, free of charge, a list of the third parties to whom we have disclosed their Personal Information (if any) for direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. If you would like to exercise this right, please use the contact information listed in this section to contact us at firstname.lastname@example.org or at 800-460-2922.
Bugaboo reserves the right to amend this privacy notice/policy at our discretion and at any time. When we make changes we will post the updated notice’s effective date. Your continued use of our applications following the posting of changes constitutes your acceptance of such changes.
Personal information does not include:
- Publicly available information from government records.
- Deidentified, anonymized or aggregated consumer information.
- Information excluded from the CCPA’s scope, including: Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.