Last Updated: February 9, 2023
I. Sensitive Information
We have collected in the preceding twelve (12) months and may continue to collect the following Personal Information which may be classified as “sensitive” under California and Virginia Laws (“Sensitive Information”):
- Account access credentials such as credit/debit card number plus expiration date, username and password collected directly from you when you open an account on the Website or purchase a product from us; and
- Precise geolocation data when you visit our Website.
We have disclosed, sold (within the meaning of the term “sale” under California Law) and shared the Sensitive Information set forth above to/with the following third-party categories in the preceding twelve (12) months and may continue to do so: Affiliates, Advertisers (data analytics provider).
II. Categories of Third Parties We Share Personal Information With
III. Disclosure of Personal Information to Third Parties for Business or Commercial Purpose
We have disclosed in the preceding 12 months and may continue to disclose the following categories of Personal Information for business or commercial purposes to the categories of third parties listed below.
|Category of Personal Information||Category of Third Party|
|Identifiers||Affiliates, Service Providers, Business Partners, Advertisers|
|Commercial Information||Affiliates, Service Providers, Business Partners, Advertisers|
|Internet or Other Network Activity||Affiliates, Service Providers, Business Partners, Advertisers|
|Financial Information||Affiliates, Service Providers|
|Geolocation Data||Affiliates, Service Providers, Business Partners, Advertisers|
|Inferences||Affiliates, Service Providers, Business Partners, Advertisers|
IV. Selling or Sharing of Personal Information
The categories of Personal Information that California Law may consider as having been “sold” or “shared” by Bugaboo (as described under California Law) or used for targeted advertising or profiling (as described under Virginia Law) in the preceding twelve (12) months include: Identifiers, Commercial Information, Internet or Other Network Activity, Geolocation Data, Inferences. Bugaboo intends to continue such “sales” and “sharing” on or after the date of the last update of this State Specific Notice.
The categories of third parties to whom Personal Information have been “sold” or “shared” (under California Law) by Bugaboo or used for targeted advertising or profiling (under Virginia Law) include: Affiliates, Business Partners, and Advertisers (e.g., marketing partners, data analytics providers, and social media networks).
You can opt out of the sale or sharing of your Personal Information, targeted advertising or profiling, by following the instructions under Section V “Your Privacy Choices”, and more specifically “Right to opt-out of sale to or sharing with third parties” (for California residents) or “Right to opt-out of targeted advertising, sale, or profiling” (for Virginia residents) of this State Specific Notice.
We do not knowingly sell the Personal Information of consumers under 16 years of age.
V. Your Privacy Choices
You may exercise any or all of the following rights subject to exemptions and limitations set forth in this State Specific Notice:
Right to know or access. The right to receive confirmation on whether we are processing your Personal Information, and, under some state laws, to obtain certain personalized details about the Personal Information we have collected about you, including:
- the categories of Personal Information we collected;
- the sources from which we collected Personal Information;
- the business or commercial purposes for which we collected Personal Information;
- the categories of Personal Information that we sold or shared (if any) and the categories of third parties to whom the Personal Information was sold or shared;
- the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding your request;
- the specific pieces of Personal Information we have collected about you.
Right to data portability. The right to obtain a copy of your electronic Personal Information in a portable, and, to the extent technically feasible, readily-usable format allowing you to transmit the data from us to another entity.
Right to correction. The right to request that we correct inaccurate Personal Information. Upon your verified request, we will correct your Personal Information and will direct our service providers to do the same.
Right to deletion. The right to request that we delete the Personal Information that we have collected from you and retained, subject to certain exemptions. 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 if an exemption applies. Below is a list of such exemptions. Upon your verified request, we will delete your Personal Information (unless an exemption applies) and will direct our service providers to do the same.
We may deny your deletion request if retaining the Personal Information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with applicable law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the Personal Information’s deletion may likely render impossible or seriously impair the research’s achievement if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Right to opt-out of sale to or sharing with third parties. The right to direct us to stop disclosing your Personal Information to third parties for monetary or other valuable consideration such as cross-contextual behavioral advertising. In case our activities are qualified as a “sale” or “sharing” of your Personal Information, you can request to opt out of the “sale” or “sharing” by clicking HERE to be directed to our Cookie Settings. To opt out, click on the "Details" tab, slide the Cookie Settings toggles to the left and then click “Confirm selection.”
Right to limit use and disclosure of Sensitive Information. The right to limit the use or and/or disclosure of your sensitive Personal Information to only those purposes that are necessary for us to provide our products or services to you. To limit the use and disclosure of Sensitive Information, click HERE to be directed to our Cookie Settings. To limit the use and disclosure of Sensitive Information, click on the "Details" tab, slide the Cookie Settings toggles to the left and then click “Confirm selection.”
We note that even after you have exercised your right to limit the use of your Sensitive Information, we may continue using or disclosing your Sensitive Information to (i) perform services or provide goods that an average consumer requesting those goods or services would reasonably expect, (ii) ensure security and integrity, if that use is reasonably necessary and proportionate, (iii) perform short-term, transient uses, including but not limited to non-personalized advertising shown as part of your current interaction with us, so long as we do not disclose the Sensitive Information to another party or use it to build a profile about you or otherwise alter your consumer’s experience outside your current interaction with us, (iv) perform services for the business (including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage or similar services to us), (v) verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, (vi) improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us, and (vii) perform other actions that the applicable state privacy laws may require.
Right to opt-out of automated decision-making technology. The right to opt-out of the use of automated decision-making technology that is used in connection with your personal preferences, interests, behavior, location, or economic status. We do not use your Personal Information to make automated decisions about you.
Right to opt-out of targeted advertising, sale, or profiling. The right to opt-out of the processing of your Personal Information for the purposes of targeted advertising, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
Right to appeal. In the event Bugaboo refuses to take action on your request within a reasonable period of time after your receipt of our decision, you may contact us at the addresses/phone number under “Contact Information”. We will respond to your appeal within 60 days from our receipt of the appeal or such shorter time period as permissible by applicable law with an explanation of the reason for our decision. If we deny your appeal and you are a Virginia resident, you may contact the Attorney General of the Commonwealth of Virginia to submit a complaint as provided on its website accessible at https://www.oag.state.va.us/consumer-protection/index.php/file-a-complaint.
Alternatively, you can exercise your opt out rights for the sale to or sharing of Personal Information with third parties through an opt-out preference signal such as the Global Privacy Control (GPC) (on the browsers and/or browser extensions that support such a signal). Our Website is configured to detect and process these GPC signals, and as a result we do not sell or share your Personal Information following a detection of such signal. Please note that an opt-out preference signal will be linked to your browser, so you will need to renew your opt-out preference if you visit our website with another device or browser, or if you clear your cookies.
Submitting a Rights Request
In addition to the mechanisms mentioned above for the exercise of your rights, if you want to submit a request in order to exercise one of your rights, please contact us via mail, phone or email at the addresses set forth below under “Contact Information”.
Depending on your state of residency, we may need 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.
Where we are entitled or required to verify your identity under the applicable state privacy law, 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. We will inform you that your identity cannot be verified. 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.
Submitting Authorized Agent Requests
Depending on your state of residency, you may designate an authorized agent to submit a request on your behalf to access or delete your Personal Information. To verify the authorized agent’s authority, we require the authorized agent’s written and signed permission to submit such request and verify their own identity directly with us. Please note, we may deny the request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf. We may need to contact you separately to confirm the authorized agent’s permission to act on your behalf.
Response timing and format
We will confirm receipt of your verifiable consumer request within ten (10) business days after receiving your request and provide information about how we will process it. We respond to a verifiable consumer request no later than 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.
Upon your request, unless impossible or involving disproportionate effort, we will also provide you with disclosures beyond the 12-month period.
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.
VI. Specific Disclosures under California Law:
Categories of Personal Information Collected
The table below sets forth such categories of Personal Information we have collected in the preceding twelve (12) months and may continue collecting on and after the date of this State Specific Notice was last updated:
|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 on our Website, 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 on the Website, and other actions taken on the Website such as selection of your 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|
Sources of Personal Information
Uses of Personal Information
Sale or Sharing of Personal Information; Right to Opt-Out
Please refer above under Section IV. Selling or Sharing of Personal Information and Section V. Your Privacy Choices in this State Specific Notice for more information.
Retention of Personal Information
Bugaboo offers certain discounts to visitors to the Website who agree to receive text messages or emails from Bugaboo (“Email and Text Program”). You may opt-in the Email and Text Program by providing Bugaboo with certain Personal Information such as email address and phone number when prompted via a pop-up window on the Website. After signing up, Bugaboo will send you a discount code to the phone number you provided. The discount code can be used for a one-time purchase of select products on the Website. The use of this discount code is subject to the terms, conditions and limitations stated on the sign-up window as may be amended by Bugaboo from time to time. You can also find such terms here: http://attn.tv/bugaboo/terms.html
Under California Laws, the discounts provided to you under the Email and Text Program may be deemed as a “financial incentive”. The categories of Personal Information we collect in connection with the Email and Text Program include: email address and phone number. We use the Personal Information you provided to us when you joined the Email and Text Program to send you the discount code, relevant messages, and other information about Bugaboo and our products that may be of interest to you.
If you no longer wish to participate in the Email and Text Program, you can opt out at any time by (i) clicking on the “Unsubscribe” link on the email sent to you with the discount code, (ii) following the instruction on any text message sent to you by Bugaboo (i.e., responding with “STOP”) or (ii) contacting us by mail, email or phone using the contact information listed under “Contact Information”.
We estimate the value of the Personal Information you provided to us in connection with the Email and Text Program based on the amount you spent using the discount code and the expenses incurred by Bugaboo in connection with the Email and Text Program. This value varies based on the amount of discount offered at the time of participation, the amount of products purchased using the discount code and the amount of expenses incurred by Bugaboo. Based on our good faith estimate, the value of the Personal Information we collect through the Email and Text Program is reasonably related to the value of the financial incentive offered to the participants of the Email and Text Program.
California’s “Shine the Light” Law
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 email@example.com or at 800-460-2922. We note that without your explicit consent Bugaboo does not disclose your Personal Information to third parties for such third parties’ own marketing purposes.
We will not discriminate against you for exercising any of your rights pursuant to Section V of this State-Specific Notice. Unless permitted by the California Law, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services; or
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
VII. Specific Disclosures under Nevada Law:
The State of Nevada provides its residents with a limited right to opt out of the sale of Personal Data following Chapter 603A of the Nevada Revised Statutes. Residents who wish to exercise such opt-out right may submit a request by contacting us via email at firstname.lastname@example.org. However, please note that we do not currently sell Personal Data triggering the statute’s opt-out requirements.
VIII. Changes to this Privacy Notice
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.
IX. Contact Information
Bugaboo North America Inc.
Phone: +1 (800) 460-2922
Email: email@example.com or firstname.lastname@example.org
Postal Address: 142 W. 57th Street, New York, NY 10019, USA
If you need to access this State Specific Notice in an alternative format due to having a disability, please contact email@example.com or 800-460-2922.