Pop-up stores in Seongsu-dong, Hyundai Seoul caught collecting personal data without consent

Every pop-up store inspected in Seongsu-dong and at Hyundai Seoul department store was found to be collecting visitors' personal information without consent, a Seoul Metropolitan Government investigation has found. About half also failed to properly inform customers of their exchange and refund policies.

The Seoul Metropolitan Government announced the findings Wednesday, releasing results of an on-site investigation conducted jointly with consumer advocacy group GCN Green Consumer Network at pop-up stores in the Seongsu-dong area and at Hyundai Seoul, along with a separate awareness survey of 1,000 pop-up shoppers.

Pop-up stores have proliferated in recent years as consumers increasingly seek offline experiences and companies place greater emphasis on experiential marketing. They now operate across a wide range of sectors, including food and beverage, beauty and fashion, webtoons, film, gaming and finance.

The city first conducted on-site inspections of 24 pop-up stores operating in Seongsu-dong and Hyundai Seoul from July 20 to Aug. 1 last year. All 24 collected personal information without obtaining visitor consent. Of those, 23 provided no guidance on portrait rights, while the remaining store posted a notice at its entrance stating that entering the store would be treated as consent to the use of portrait rights. Under the Personal Information Protection Act, entities that collect personal data must inform individuals of the purpose of collection, the items to be collected and the retention period, and must destroy the data without delay once it is no longer needed.

Disclosure of exchange and refund policies was also inadequate. Among the 23 stores that sold products, 12 displayed their exchange and refund policies only on receipts, five posted them at the checkout counter, three explained them verbally through staff, and three used a combination of verbal explanation and receipt notation. Applicable regulations require that consumers be clearly and easily informed of key terms and conditions before payment.

Similar problems had been flagged before. A 2024 Korea Consumer Agency investigation covering 20 pop-up stores in Seongsu-dong, Gangnam, Hongdae, Hyundai Seoul and Lotte Mall Jamsil produced comparable findings, yet conditions have not improved. Of the 20 stores surveyed, nine operated on-site waitlist reservation systems requiring customers to provide personal information; of those nine, four — or 44.4 percent — failed to disclose what personal data was being collected, how it would be processed or how long it would be retained. Some stores went further, informing customers that the operator could use their portrait rights without consent, or that entering the store constituted agreement to such use.

The city also conducted an awareness survey from Aug. 22 to Sept. 30 last year, polling 1,000 consumers nationwide — excluding Jeju Island — who had made purchases at pop-up stores. Respondents had visited an average of 3.1 pop-up stores over the previous year and spent an average of 50,500 won ($33) per visit. Their top reasons for buying were event-exclusive products not available elsewhere (57 percent), the ability to see and purchase items in person (49 percent), and prices discounted below regular retail (39 percent). The city said the findings suggest pop-up stores have taken root as a genuine consumer culture rather than a passing trend.

The survey also documented consumer grievances. The most common complaints were being unable to purchase due to insufficient stock (29 percent), waiting far longer than indicated because of queue-time errors (24 percent), failing to receive a free gift because event conditions had changed (15 percent), and being unable to obtain after-sales service once a store had closed (10 percent).

Based on the investigation, the city said it would ask operators with inadequate personal data consent procedures or insufficient disclosure of exchange and refund policies to bring their practices into legal compliance. It also urged consumers to carefully check personal data consent terms and exchange and refund conditions before making purchases.

"Pop-up shopping has become an established part of consumer culture, but we found cases where operators neglected their obligations on personal data protection and consumer notification on the grounds that their stores operate only briefly," said Kim Myeong-seon, head of the Seoul Metropolitan Government's Fair Economy Division. "The city will continue to monitor operators' legal compliance as the consumer environment evolves, and will do its utmost to protect citizens' consumer rights."