ABUGGY recognizes that your personal information is important to you and that you are concerned with its collection, use and disclosure.
This policy contains information about:
- when you can deal with ABUGGY anonymously;
- the purposes for which ABUGGY collects, holds, uses and discloses personal information;
- the types of personal information that ABUGGY collects;
- how ABUGGY collects and holds personal information;
- how you may access the personal information that ABUGGY holds about you, and how you may seek correction of that personal information.
When can you deal with ABUGGY anonymously?
Generally, you can deal with ABUGGY anonymously (i.e. without identifying yourself). In certain circumstances however, ABUGGY will ask you to provide personal information because it is required by law or ABUGGY’s policies to do so, or because it would be impracticable to deal with you anonymously. These circumstances include where you order goods online, where you purchase an extended warranty on a product or accidental damage insurance, where you apply to purchase goods on finance, where you return goods for repair, where you purchase goods to be delivered or installed, collect goods from a ABUGGY warehouse or storeroom, where you enter one of our competitions, when you submit a request, enquiry, complaint, consumer guarantee or warranty claim, when you pre-order goods and when you purchase goods on lay-by.
Why does ABUGGY collect, hold, use and disclose personal information?
ABUGGY collects, holds, uses and discloses personal information for a number of purposes connected with our business operations, which include:
- providing you with products and/or services requested;
- dealing with requests, enquiries, complaints, consumer guarantee or warranty claims, and other customer care related activities;
- marketing our products and services and providing advice on our products;
- developing and improving our products and services;
- in connection with our loyalty or reward programmes and competitions;
- the operation and administration of accounts or subscriptions that you have with us;
- payment processing;
- carrying out certain checks (for example, for our fraud or theft prevention processes, if you wish to open an account with us, obtain credit from us, collect goods from a ABUGGY warehouse or storeroom, or pick-up goods in-store that have been ordered online);
- interacting with companies or organisations with whom ABUGGY has a business relationship (where you work for, or otherwise represent, such an organisation);
- reconciling payments due to ABUGGY from suppliers in relation to goods or services provided to you by those suppliers;
- purposes relating to any third party acquisition or potential acquisition of an interest in ABUGGY or its assets;
- complying with our obligations under agreements with third parties and
- carrying out any activity in connection with a legal, governmental or regulatory requirement that we have to comply with, or in connection with legal proceedings, crime or fraud prevention, detection or prosecution. In particular, ABUGGY is required by law to collect personal information in certain circumstances.
Documents (including hard copy documents and electronic documents such as emails) which coincidentally contain personal information will also be retained in accordance with ABUGGY’s normal document retention practices for accounting, legal and business purposes.
Generally, you have no obligation to provide any personal information requested by us. However, if you choose not to do so where we require this information, we may not be able to provide you with the goods and services that you want.
What personal information does ABUGGY collect?
The kinds of personal information we collect or which we may hold about you may include:
- your name;
- your address;
- your telephone number(s);
- your e-mail address;
- payment information;
- transaction information;
- your user name and password;
- information contained on identification documents (such as driving licences) and, in some specific cases, copies of such identification documents, where we require these to verify your identity;
- information on how you use our products and services;
- your Internet Protocol (“IP”) address, server address, domain name and information on your browsing activity when visiting one of our websites;
- your user name for social networking sites that you use, to refer to, or in conjunction with, our goods and services and personal preferences regarding products and services; and CCTV images of you whilst you are in one of our stores.
How does ABUGGY collect and hold your personal information?
We collect personal information in a number of ways including:
- when you order goods or services from us (either online, in-store or over the telephone);
- when you collect goods that you have ordered from us, including from a ABUGGY warehouse or storeroom;
- when you set up an account with us;
- when you purchase certain products or extended warranties from us;
- when you pay for goods by cheque;
- when you subscribe to our catalogues or mailing lists or those of certain partners of ours.
- when you subscribe to ABUGGY subscription service;
- when you sell second-hand goods to us or buy second-hand goods from us;
- when you enter competitions or promotions that we run;
- when you provide us your details for customer care purposes;
- when you submit an enquiry using one of our websites;
- when you complete surveys or provide online feedback or product reviews; and
- when you publicly comment about us on social media sites (for example so that we can answer questions about our products).
- Generally, ABUGGY will collect your personal information directly from you. However, ABUGGY also holds information, collected incidentally, concerning individuals who work for companies or organisations that have a business relationship with ABUGGY. Additionally, if you apply for a job with ABUGGY, we may collect personal information about you from any third parties that you nominate as your referees in your application.
ABUGGY holds personal information in a number of ways, including:
- as part of customer records and other electronic documents on which personal information is contained which are stored on our information technology systems and servers operated by third parties who provide services to us in connection with our business; and
- by securely storing hard copy documents on which personal information is contained, at our various premises and using third party document management and archiving services.
We may use your personal information that we have collected to promote and market products and services to you, including through methods such as email and SMS. We will not use your personal information for marketing purposes where you have opted out of receiving such communications.
When we send you marketing communications we may provide you a particular way to opt-out such as via SMS. Otherwise, you may opt-out of receiving marketing communications by sending a written request to The Privacy Officer, ABUGGY, either by email to firstname.lastname@example.org.
Please note that when you create an account with us your details will be added to our marketing database to receive information relating to ABUGGY and our products. You may also choose to receive such information by subscribing to our marketing database via one of our websites.
To opt-out of receiving ABUGGY marketing materials from our marketing database, you will need to unsubscribe from our database. To do this, simply select the “unsubscribe” option in one of the emails that you receive from us. Please note that if you have an account with ABUGGY, we may still need to send you essential information about your account.
Sharing your personal information
ABUGGY may disclose or receive personal information or documents about you, including to/from:
- organisations that provide services to us in connection with our business, including customer support, payment processing, administration, archival, data storage, hosting, research, mail and delivery, installation, distribution, logistics, marketing, auditing, share registry, consulting, financial and legal advisory, banking, debt collection, security or technical services and the operation of ABUGGY websites. In some cases these service providers may collect your personal information on our behalf;
- if you return goods to ABUGGY to be repaired, our repairs system administrator, the manufacturer of the goods and authorised repairers;
- law enforcement agencies to assist in the prevention, investigation and prosecution of criminal activities;
- parties involved in any third party acquisition or potential acquisition of an interest in ABUGGY or its assets;
- our insurers and insurance brokers;
- if goods you purchase from ABUGGY are subject to a product recall, the manufacturer or distributor of those goods; and
- to other third parties where you have specifically consented to the disclosure of information to these third parties.
- Additionally, if you return goods to us on which personal information is stored for repair (for example, on a mobile phone or computer) and do not delete that personal information, ABUGGY will send the goods to the repairer. By returning such goods to ABUGGY for repair, you consent to ABUGGY disclosing any personal information contained on the goods to the repairer, by way of ABUGGY sending the goods to the repairer.
Disclosure of personal information to overseas recipients
ABUGGY is likely to disclose the personal information that it collects and holds about you to third parties who are not in India (such as third parties who are located in the United States of America, Singapore, the United Kingdom, Holland and New Zealand). Some of the jurisdictions in which these third parties are located may have less protective privacy and data protections laws than India.
How we deal with your personal information if you apply for a job with us
If you apply for a job with us, you may be required to provide us with certain personal information, including your name, employment and educational background, and other personal information which we may require you to provide, or which you choose to provide us, in relation to your job application.
We will hold, use and disclose that information solely for the purpose of considering your application. In particular, in considering your application, it may be necessary for us to disclose some of that information to third parties to verify the accuracy of that information. In such circumstances, we will disclose only such information as is necessary in the circumstances.
In considering your application, we may also collect personal information about you from any third parties that you nominate as your referees in your application.
Security of your personal information
We will take reasonable steps to ensure that the personal information that we hold is stored in a secure environment protected from misuse, interference and loss and any unauthorised access, modification or disclosure.
How to access, correct and update your personal information
Upon your request, ABUGGY will provide access to your personal information that we hold. ABUGGY reserves the right to charge you an administration fee for providing access to your personal information and will, of course, require some proof of your identify before providing information to you.
You may also request us to correct the personal information that ABUGGY holds about you. If you do so and we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, ABUGGY will take such steps as are reasonable in the circumstances to correct your personal information to ensure that, having regarding to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.
To request access to the personal information that ABUGGY holds about you, or to update or correct that personal information, please send a written request to by email to email@example.com.
- if you are a subscriber to our marketing database you can also update your details via the “unsubscribe” option in one of the emails that you receive from us;
- if you subscribe to one of our services you can also update your details via that service.
How to make a complaint
If you are concerned that the way ABUGGY collects, holds, uses or discloses your personal information may be in breach of the Indian Privacy Principles, please send written details of your complaint to The Privacy Officer, ABUGGY to firstname.lastname@example.org.
How ABUGGY will handle complaints
After receiving a complaint, we will consider whether we need any further information from you to properly consider and investigate the complaint and may request such information from you. We will then:
- conduct internal discussions with the relevant business units involved in the collection, holding, use or disclosure of your personal information which is the subject of your complaint, and evaluate whether we believe that such collection, holding, use or disclosure of your personal information was in breach of the Indian Privacy Principles; and
- notify you of the results of our investigation of your complaint.
If the conclusion of our investigation is that our collection, holding, use or disclosure of your personal information was in breach of the Indian Privacy Principles, we will take steps to remedy the breach as soon as reasonably practicable.
We will endeavour to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex matters or requires extensive investigation and consultation, it may not be possible to respond within this timeframe.
Additional information for users of our websites
If you visit wwwabuggy.com or any other ABUGGY websites (the “Websites”) to read, browse or download information, our system may record information such as the date and time of your visit to the Website, the pages accessed and any information downloaded. This information is used (i) for statistical and reporting purposes; (ii) for website administration, security and maintenance purposes; and (iii) to direct you to material on our Websites that we believe will be of interest to you.
Like many websites, our Website may use “cookies” from time to time. Cookies are small text files that we transfer to your computer’s hard drive through your web browser to enable our systems to recognise your browser and your log-in status. Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes. Any such information will be aggregated and not linked to particular individuals. The default settings of browsers like Internet Explorer usually allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of the Website may not function fully for users that disallow cookies.
Our Website also uses tags, which are tiny bits of website code that allow us to measure traffic and visitor behaviour, and to understand the impact of online advertising, use remarketing and audience targeting. These tags do not collect any personally identifiable information.
While we take great care to protect your personal information on our Website and use state-of-the-art data transmission encryption, unfortunately no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information that you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us. Once we receive your transmission, we use our best efforts to ensure its security in our possession.
The Websites may contain links/ plug-ins to other sites. We are not responsible for content of, or the privacy practices or policies of, those sites.
Version 3 – Date of Publication 29 May 2020