This Data Protection Notice (the "Notice") describes the data processing activities in connection with your use of the following apps developed and offered by Shimano Inc.
Unless stated otherwise, the information provided herein applies to all two Apps in general.
This Notice also informs you about the most relevant aspects of the arrangement concluded between the Shimano entities responsible for the data processing activities in connection with the Apps.
Personal Data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental economic, cultural or social identity of that natural person ("Personal Data").
Special categories of personal data include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data, data concerning health or data concerning a natural person's sex life or sexual orientation (also referred to as "Sensitive Data").
You can find more information about how we process the Personal Data of California consumers by reviewing the “Additional Disclosures for California Consumers” section of this Notice below.
Shimano Inc.
("SIC")
3-77 Oimatsu-cho, Sakai-ku, Sakai City
Osaka 590-8577, Japan
SHIMANO
EUROPE
B.V.
("SEU")
High Tech Campus 92, 5656 AG Eindhoven,
The Netherlands,
SHIMANO NORTH
AMERICA
HOLDING, INC. ("SNAH")
One Holland, Irvine, California 92618 U.S.A.
SHIMANO SALES
CO.,
LTD. ("SSJ")
1-5-15 Chikukou-Shinmachi, Nishi-ku, Sakai-shi, Osaka,
592-8331,
Japan
are the entities responsible for the processing of your Personal Data in relation to E-TUBE RIDE PROJECT and E-TUBE RIDE as joint data controllers (SIC, SEU, SNAH and SSJ together referred to hereinafter as "we", "our" or "us").
You can contact each joint controller by postal mail at the address above.
We have appointed a group Data Protection Officer ("DPO") to manage all matters related to data protection and privacy. If you have any questions regarding the processing of your Personal Data, please contact our DPO at privacy@shimano-eu.com
Our Apps offer you a variety of functionalities, services and features (the "Services") which require or allow you to provide us with Personal Data about you. Additionally, we automatically collect information about you, including Personal Data, upon download and installation of the Apps on your device.
When using our Apps you have the option to enjoy our contents and Services which may require or allow you to provide us with Personal Data. The specific categories of Personal Data concerned depend on the specific app involved, as described below.
If certain information is required for us to be able to provide you with a specific service, we will for us mark it as such. Failure to provide us with the information results in the impossibility of providing you with the requested service.
E-TUBE PROJECT offers you the option of using the app without logging in. If you choose this option, we will not collect any user information or bike information as described above.
E-TUBE RIDE offers you the option of using the app without logging in. If you choose this option, we will not process bike information as information relating to an identified or identifiable natural person.
When using our Apps and Services we automatically collect Personal Data. The specific categories of Personal Data concerned depend on the specific app involved, as described below:
As a general rule we collect information directly from you. However, we also receive Personal Data about you from other sources in the following situations:
The use of our Apps does not require logging in or creating a profile. However, you are able to do so if you wish.
If you log into our Apps with your SHIMANO ID, we will merge the information we process about you in connection with our different Apps in order to simplify the registration for our Services.
You can register to SHIMANO ID by email address or by connecting with existing accounts on social media networks such as Facebook, Twitter, Apple ID and Google.
If you choose to use a social media account to register to SHIMANO ID, we will process the data of your social media user account. This information varies depending on the settings of your social media account and can consist of the following: account name, location, gender, age, email address, etc.
Our Apps use cookies and other tracking mechanisms to collect information.
Cookies are small text files stored on your device with a variety of purposes. You can manage and delete the cookies on your device in the corresponding device settings.
Our Apps use strictly necessary cookies. Strictly necessary cookies are essential for the operation and use of our Apps. Without these cookies, we would not be able to offer you with our Apps and Services. Therefore, you cannot opt out of them.
We use tracking tools to collect information about the users' behaviour and interactions with our Apps and Services, e.g. what features are most frequently used. The processing of Personal Data collected via these tools is based on the user's consent. You can withdraw your consent at any time with effect for the future. Please see Section 9 below for more information on how to exercise your rights.
Our Apps use the following cookies:
Name | Duration | Purpose | Type |
---|---|---|---|
apiDomain_<api> | 15 Years | The shared domain API calls for all sites in a group where it should be sent to. | Third Party |
_gig_llu | 15 Years | Last login provider username for Login "Welcome back" screen. | First Party |
_gig_llp | 15 Years | Last login provider name for Login "Welcome back" screen. | First Party |
_gig_lt / glt_<api> | forever | Login Token for authentication. | First Party |
gig_hasGmid | 15 Years | Internal cookie for the Web SDK | Third Party |
hasGmid | 13 Months | Internal cookie for the Web SDK | Third Party |
gst | 30 Minutes | Server ticket for 2nd phase of login. | First Party |
ucid | 13 Months | Unique computer identifier used for generating reports, and used by the Web SDK to get saved response. | Third Party |
glnk | -1 Days (Expiring the cookie) | Ticket for 2nd phase of login. | Third Party |
gmid | 10+ Years | User cookie. | Third Party |
GSLM_<siteID> | NA | Session magic cookie. | Third Party |
gig3pc | 48 hrs | Remembers if 3rd party cookies are blocked to avoid checking every time. | First Party |
gig3pctest | 1 second | A temp cookie used to check if 3rd party cookies are blocked. | First Party |
gig_debug | 2 second | Used to trigger the debug UI. | First Party |
_gig_dbgConsole_log | 3 second | Used to trigger logging for debugging. | First Party |
_gig_APIProxy_enabled | forever | Used to indicate whether to use APIProxy or not. | First Party |
gac_<APIKey> | forever | Used to trigger server initiated login. | First Party |
gltexp_<APIKey> | dynamic | Login Token Expiration. | First Party |
_gig_<ID>_cb | 10 years | Callback for listener. | First Party |
ua_<APIKey> | 24 hours | COPPA (under age). | First Party |
_gig_ssoToken | dynamic | SSO Token. | Third Party |
__gigAPIAdapterSettings_<APIKey>_<build> | forever | WebSDk settings. | First Party |
gmid | forever | User cookie. | Third Party |
ucid | forever | Unique computer identifier for unique user reporting purposes. | Third Party |
_gig_ssoToken_<APIKey> | dynamic | SSO Token by API. | Third Party |
_gig_gmidt | 30min | User cookie. | Third Party |
gig_canary | 1 year (only active ~3 days) | Indicates whether the client is using the canary version of the WebSDK. | First Party |
gig_canary_ver | 1 year (only active ~3 days) | The version name of the WebSDK's canary version. | First Party |
At this time, the Apps do not respond to “do not track” signals sent by Internet browsers.
We process your Personal Data only for specified, explicit and legitimate purposes and provided that we have a legal basis to rely on. Your Personal Data will not be processed for any purpose other than the one they were originally collected, unless the new purpose is compatible with the initial one or in the event you give us your consent.
We have summarized the purposes for which we process your Personal Data and the legal bases we justify the processing with in the list below:
User identification (applicable for all Apps):
We use your Personal Data to verify your identity when registering and logging into our Apps.
The processing of your Personal Data for this purpose is necessary for the performance of the contract concluded with you for the use of the Apps, see Art. 6 (1)(b) General Data Protection Regulation ("GDPR").
Use of the Apps (for each app see the information applicable below):
E-TUBE PROJECT offers you the option of using the app without logging in. In case of using the app with user log-in, the app operates on the basis of the user profile you have created. We use your Personal Data to manage your bike information associated with your user account. Our aim is to offer you a seamless experience by enabling you to access your data from any place and any device. We base the processing of your Personal Data for the above purposes on the performance of a contract to which you are party, see Art. 6 (1)(b) GDPR.
When configuring your user profile, you can choose to submit more information than the strictly required to provide you with our services. The provision of optional information to complete your user profile enables you to benefit from a more personalized experience on our Apps.
We rely on your consent to process any Personal Data you have freely chosen to provide us with, see Art. 6 (1)(a) GDPR. In case you withdraw your consent, for example, by updating your user profile, we will stop processing your Personal Data for this purpose.
E-TUBE RIDE offers you the option of using the app without logging in. In case of using the app with user registration, the app operates on the basis of the user profile you have created. We use your Personal Data to manage your bike information and riding log associated with user account. Our aim is to offer you a seamless experience by enabling you to access to your data from any place and any device. We base the processing of your Personal Data for the above purposes on the performance of a contract to which you are party, see Art. 6 (1)(b) GDPR.
When configuring your user profile, you can choose to submit more information than the strictly required to provide you with our services. The provision of optional information to complete your user profile enables you to benefit from a more personalized experience on our Apps.
We rely on your consent to process any Personal Data you have freely chosen to provide us with, see Art. 6 (1)(a) GDPR. In case you withdraw your consent, for example, by updating your user profile, we will stop processing your Personal Data for this purpose.
Communication with you (applicable for all Apps):
We use your Personal Data to contact you, either upon your request, or when you have allowed us to do so, for example, to obtain feedback from you in order to improve our app Services and the products.
We base the processing of your Personal Data on your consent, as well as on the performance of a contract to which you are party and our legitimate interests to provide customer support, to improve the quality of our services and to grow as a business, see Art. 6 (1)(a), (b) and (f) GDPR.
Product development (applicable for all Apps):
We process your Personal Data for quality improvement purposes, e.g. to detect and analyse problems in our products, to carry out predictive maintenance and calculate the necessary product replacement timing, to introduce new products and test their compatibility, etc.
We base the processing of your Personal Data on our legitimate interests to improve the quality of our products and services, for product development research and to expand and grow as a business, see Art. 6 (1)(f) GDPR.
App user measurement and usage analysis (applicable for all Apps):
We analyse the performance of our Apps and Services content in order to understand how users interact with them and improve them accordingly.
We rely on your consent to process your Personal Data for this purpose, see Art. 6 (1)(a) GDPR. In case you withdraw your consent, we will stop processing your Personal Data for this purpose.
Detect and avoid misuse of the Apps (applicable for all Apps):
We analyse technical data gathered via the Apps to detect and avoid misuse thereof, for example, by a breach of the terms of use of the software license agreement.
We base the processing of your Personal Data on the performance of a contract to which you are party, as well as on our legitimate interests in prosecuting any misuse of our Apps which could affect Shimano and could have legal consequences, see Art. 6 (1)(b) and (f) GDPR.
Where the above purposes require or involve the processing of Sensitive Data, we will ask for your express consent, as required by law, see Art. 9 (2)(a) GDPR.
We share your Personal Data with the following recipients:
The transfer of your Personal Data to recipients located in third countries outside of the European Economic Area ("EEA") is subject to the provisions set out in Section 7 below ("international data transfers").
All data collected via the Apps will be stored centrally in the European Union ("EU"). As (joint) data controller, SIC will have access to that database. Accordingly, your Personal Data will be transferred and/or disclosed to recipients located outside of the EEA in Japan which has been recognized by the European Commission in its adequacy decision (Commission Implementing Decision 2019/419 of 23 January 2019) as providing for an adequate level of data protection.
We will not process your Personal Data longer than necessary for the purpose for which it was originally collected.
Subject to statutory retention periods, we will delete your Personal Data:
Under applicable data protection law, you have certain rights with regard to the processing of your Personal Data by us:
SIC, SSJ, SNAH and SEU jointly determine the purposes and the means of the processing of your Personal Data in connection with the Apps as described in Section 2 above. Consequently, as required by law, SIC, SSJ, SNAH and SEU have entered into a joint controllership agreement pursuant to Art. 26 GDPR. SIC, SSJ, SNAH and SEU will coordinate and cooperate with each other in order to comply with their data protection obligations, to observe your rights and to process your request and reply to any of your inquiries.
SEU is the designated point of contact for Apps users requesting to exercise their rights under Section 9 above. If you want to do so, or in case you have questions regarding them, please contact SEU by phone at +31-40-2612222 or by email at privacy@shimano-eu.com In addition, If you are located in the EU, please note that in addition to your designated point of contact, you may also contact SIC, SNAH and SSJ to exercise your rights.
We have implemented standard industry practices internally and with our service providers to maintain the security of your Personal Data depending on its sensitivity and to avoid disclosure of such Personal Data unpermitted under this Notice.
Our Services offer you the possibility of accessing third party content, such as websites, apps and online services. Please note that we are not responsible for the data processing activities of these third parties. We encourage you to read the data protection notices of any third party website, app or online service you connect with.
We do not knowingly process Personal Data from individuals under the age of 16 without parental or guardian consent. If you are the parent or the guardian of a child and you believe that we have processed Personal Data about him or her, please contact our DPO using the contact details described above in Section 3.
This Notice may be revised from time to time to reflect and comply with changes in applicable legislation. We will inform you about any updates in an appropriate manner, e.g. via email or a message in the Apps. The date of the last update is available at the top of this Notice.
Austria |
Thalinger Lange GmbH Schubertstraße 12 A-4600 Wels, Austria Tel.: +43 7242 497 - 0 Fax: +43 7242 497 - 248 E-Mail: mail@thalinger-lange.com Web: www.thalinger-lange.com |
Belgium |
Shimano Belgium N.V. Zandvoortstraat 21, 2800 Mechelen, Belgium Phone: +32-15-209480 / Fax: +32-15-209410 |
Bulgaria |
BG-Eurotrade Ltd. Iztochna Tangenta Str., Nr. 102 District Slatina, 1592 Sofia Bulgaria Phone: (+3592) 418 3615 Fax:(+3592) 4167690 |
Croatia |
CS-Eurotrade d.o.o. CKZ 135 8270 Krsko Slovenia Phone: 386-7-4902500 Fax: 386-7-4902549 |
Cyprus |
Eurotrade Ltd. Ag. Vassilios 26500 Patras Greece Phone: +26 10 91 14 50 E-mail: info@eurotrade.com.gr URL: www.bikesworld.gr |
Czech Republic |
Paul Lange Ostrava s.r.o. Sabinova 2 CZ-72100 Ostrava-Svinov, Czech Republic Tel.: +420 596 616-836 Fax: +420 596 780-995 E-Mail: info@paul-lange.cz Web: www.paul-lange.cz |
Denmark |
Shimano Nordic Denmark Forbindelsesvej 4 2100 København Ø Denmark Phone: +4569911660 E-mail: infodk@shimano-eu.com URL: www.shimano-nordic.dk |
Estonia |
Shimano Polska Bicycle Parts Sp. z o.o. ul. Gutenberga 9 62-023 Żerniki Poland Phone: 061-62 52 100 / 106 E-mail: infopoland@shimano-eu.com URL: www.shimano-polska.com |
Finland |
Shimano Nordic Cycle OY Teknobulevardi 3-5, 01530 Vantaa, Finland Phone: +35-8201-550800 / Fax: +35-8201-55080 |
France |
Shimano France Composants Cycles S.A.S.. Zone Actiparc, 777 Rue Commios, 62223 St.-Laurent-Blangy Cedex, France Phone: +33-321-732525 |
Germany |
Paul Lange & Co. OHG Hofener Straße 114 D-70372 Stuttgart Germany Tel.: +49 711 2588 - 02 Fax: +49 711 2588 - 305 E-Mail: info@paul-lange.de Web: www.paul-lange.de |
Greece |
Eurotrade Ltd. Ag. Vassilios 26500 Patras Greece Phone: +26 10 91 14 50 E-mail: info@eurotrade.com.gr URL: www.bikesworld.gr |
Hungary |
Paul Lange Hungary Kft. Központi út 28-32 H-1211 Budapest, Hungary Tel.: +36 (1) 445-0371 Fax: +36 (1) 445-0676 E-Mail: info@paul-lange.hu Web: www.paul-lange.hu |
Iceland |
Shimano Nordic Cycle AB Edsbrogatan 1F 752 28 Uppsala Sweden Phone: +46-18-56-16-00 Fax: +46-18-50-03-95 Email: infose@shimano-eu.com URL: www.shimano-nordic.com |
Ireland |
Madison Burnell House, 8 Stanmore Hill HA7 3BQ Stanmore, Middlesex United Kingdom Phone: +44 (0)1908 326000 Fax: 0800 1300 599 URL: www.madison.co.uk |
Italy |
Shimano Italy Bicycle Components SRL. Via Jucker 22, 20025 Legnano (MI), Italy Phone: +39-0331-936911 / Fax: +39-0331-936955 |
Japan |
シマノセールス株式会社(大阪府堺市) 〒592-8331 堺市西区築港新町1-5-15 (代表) Phone: 072-243-2820 / Fax: 072-243-2830 |
Latvia |
Shimano Polska Bicycle Parts Sp. z o.o. ul. Gutenberga 9 62-023 Żerniki Poland Phone: 061-62 52 100 / 106 Fax: 0047-66778011 E-mail: infopoland@shimano-eu.com URL: www.shimano-polska.com |
Lithuania |
Shimano Polska Bicycle Parts Sp. z o.o. ul. Gutenberga 9 62-023 Żerniki Poland Phone: 061-62 52 100 / 106 Fax: 0047-66778011 E-mail: infopoland@shimano-eu.com URL: www.shimano-polska.com |
Luxembourg |
Shimano Benelux Industrieweg 24 8071 CT Nunspeet Netherlands Phone: +31(0)341-272327 Fax: +31(0)341-272291 E-mail: salessbx@shimano-eu.com URL: www.bikegear.cc |
Malta |
Shimano Italy Bicycle component SRL Via Jucker, 22 20025 Legnano (MILANO) Italy Phone: +39 0331 936911 Fax: +39 0331 936955 E-mail: bikeinfo.shimanoitaly@shimano-eu.com |
Netherlands |
Shimano Benelux B.V. Industrieweg 24, 8071 CT Nunspeet, the Netherlands Phone: +31-341-272327/ Fax: +31-341-272291 |
Norway |
Shimano Nordic Cycle AS Vakåsveien 7, 1395 Hvalstad, Norway Phone: +47-66-77-80-10 / Fax: +47-66-77-80-11 |
Poland |
Shimano Polska Sp. z o.o Ul. Jana Gutenberga, 62-023 Żerniki, Poland Phone: +48-61-62-52-100 / Fax: +48-61-62-52-110 |
Portugal |
Sociedade Comercial do Vouga Lda. Apartado 7 3754-909 Águeda Codex Portugal Phone: +351 234 601500 Fax: +351 234 601159 E-mail: scvouga@scvouga.pt |
Romania |
ROM-Eurotrade S.R.L Bucharest west Industrial park Equest logistic Center Strada DE 287/1, Building E2, Unit A1-A2 077096, Judetul Ilfov Romania Phone: +40.21.350.5624 Fax: +40.21.350.5457 E-mail: info@rom-eurotrade.ro |
Slovakia |
Paul Lange Oslany s.r.o. Mierová 854/37 SK-97247 Oslany, Slovakia Tel.: +421 465 492 344 Fax: +421 465 491 056 E-Mail: office@paul-lange-oslany.sk Web: www.paul-lange.sk |
Slovenia |
CS-Eurotrade d.o.o. CKZ 135 8270 Krsko Slovenia Phone: 386-7-4902500 Fax: 386-7-4902549 Email: info@cs-eurotrade.com |
Spain |
Macario Llorente S.A. CALLE TALES DE MILETO Nº2 POLÍGONO INDUSTRIAL MAPFRE 28806 - ALCALÁ DE HENARES (MADRID), Spain |
Sweden |
Shimano Nordic Cycle AB Edsbrogatan 1F, 75228 Uppsala, Sweden Phone: +46-18-56-16-00 / Fax: +46-18-50-03-95 |
United Kingdom |
Madison Burnell House, 8 Stanmore Hill HA7 3BQ Stanmore, Middlesex United Kingdom Phone: +44 (0)1908 326000 Fax: 0800 1300 599 URL: www.madison.co.uk |
United States of America |
Shimano North America Bicycle, Inc. One Holland, Irvine, California 92618 U.S.A. Phone: +1-949-951-5003 / Fax: +1-949-768-0920 |
These disclosures describe how we collect, use, process, and disclose Personal Data of California consumers in the context of our Apps and Services (as defined above), as well as the rights you may have under California law. These disclosures are intended to supplement the Data Protection Notice with information required by the California Consumer Privacy Act (“CCPA”).
California law requires that we describe the Personal Data we collect about California consumers, including by identifying specific categories of data. We collect Personal Data directly from consumers, automatically when consumers use our Apps and Services, and from other sources (such as from social networks, when you use a social media account to register to SHIMANO ID). As we describe in more detail above in the “Information We Collect” section of this Notice, we have collected the following categories of Personal Data in the past 12 months in the context of each App:
For information about our business or commercial purpose(s) for collecting, or possibly sharing, your Personal Data, please refer to the “Purposes and Legal Bases” section of the Notice above.
We may share your Personal Data with third parties as described in the “Recipients of Personal Data” section of the Notice above. We do not sell Personal Data. California law also requires that we provide you with information about certain disclosures of Personal Data to third parties, where the disclosures are made for “business purposes”, such as disclosures to service providers. We disclose the following types of Personal Data for our business purposes:
Category of Personal Data | Recipient |
---|---|
Identifiers |
Other group companies and distributors IT support and maintenance providers Web server providers |
Demographics |
Other group companies and distributors IT support and maintenance providers Web server providers |
Commercial Information |
Other group companies and distributors IT support and maintenance providers |
Biometric Information |
Other group companies and distributors IT support and maintenance providers |
Internet Activity |
Other group companies and distributors IT support and maintenance providers |
Location Data |
Other group companies and distributors IT support and maintenance providers |
California law grants certain rights to California consumers. These include the rights to:
To exercise the Right to Access, Right to Know, or Right to Request Deletion: please contact us at privacy@shimano-eu.com or +1-800-423-2420. Only you or a person that you authorize to act on your behalf may make a request related to your Personal Data. A request to exercise any of these rights must (1) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected Personal Data (or an authorized representative of that person); and (2) describe your request with sufficient detail that allows us to understand, evaluate, and respond to your request. We will verify your identity by sending email to your registered email address and confirming reply from your email address. In certain cases, we may need to ask for more information. We may not be able to respond to your request or provide you with the information you requested if we are unable to verify your identity (or establish the authority of an authorized agent acting on your behalf). Authorized agents wishing to exercise rights on behalf of a California consumer should submit requests to privacy@shimano-eu.com along with a copy of the consumer’s signed authorization designating you as their agent. If you do not have an account with SHIMANO, while you may contact us at privacy@shimano-eu.com with questions or concerns, we may not be able to respond to requests to exercise your rights under the CCPA, including the right to know or delete your Personal Data. Because we only collect limited data about individuals without an account, we are unable to verify requests from non-accountholders to the standard required by the CCPA.
Additionally, under California Civil Code Section 1798.83, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of personal data that a business has disclosed to third parties during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of such third parties. To exercise this right, please contact us at privacy@shimano-eu.com
If you have any questions regarding the processing of your Personal Data, please contact us at privacy@shimano-eu.com