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SHIMANO APPS DATA PROTECTION NOTICELast Updated: September 2020

 
  • 1. Introduction and Scope

      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.

      • E-TUBE PROJECT App ("E-TUBE PROJECT"); and
      • E-TUBE RIDE App ("E-TUBE RIDE", collectively the "Apps").

      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.

  • 2. Data controller

      Shimano Inc. ("SIC")
      3-77 Oimatsu-cho, Sakai-ku, Sakai City
      Osaka 590-8577, Japan

      together with

      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.

      and

      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.

  • 3. Data Protection Officer

      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

  • 4. Information we collect

      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.

  • 4.1 Information you provide to us

      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.

      (a) E-TUBE PROJECT
      • User information: username (nickname), login password (encrypted), gender, birthday, home address (state/prefecture level), and email address; and
      • Bike information: nickname, components information (product name, gear teeth number, serial number, firmware version, unit log, component name pass key, and Universally Unique Identifier of wireless unit)

      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.

      (b) E-TUBE RIDE
      • User information: username (nickname), login password (encrypted). gender, birthday, home address (state/prefecture level), and email address; and
      • Bike information: nickname, components information (serial number, name and Universally Unique Identifier of wireless unit), bike ride log (latitude/longitude, time, elevation, distance, speed, pedaling cadence, gear position, assist mode, error log)

      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.

  • 4.2 Information we automatically collect

      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:

      (a) E-TUBE PROJECT
      • Device information: IP address, unique device ID (such as Instance ID, IDFV, Firebase ID); and
      • App usage log information: information about your interactions with the app, including error logs and crash recovery logs, date/time stamps and clickstream data

      (b) E-TUBE RIDE
      • Device information: IP address, unique device ID (such as Instance ID,IDFV; and
      • App usage log information: information about your interactions with the app, including error logs and crash recovery logs, date/time stamps and clickstream data
  • 4.3 Information we receive from other sources

      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:

      SHIMANO ID and Social Media

      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.

  • 4.4 Cookies and other tracking tools

      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.

      (a)

      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.

      (b)

      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.

  • 5. Purposes and legal bases

      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):

        • (a) E-TUBE PROJECT

        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.

        (b) E-TUBE RIDE

        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.

  • 6. Recipients of Personal Data

      We share your Personal Data with the following recipients:

      • Other group companies and distributors. Given the international footprint of our business, our group companies work closely together. To be able to do so, we share data, including Personal Data, within the group. This means that your Personal Data will be shared to other group companies and distributors. You can find a list of all the group companies and distributors with whom we share your Personal Data as attached.
      • Service providers acting on our behalf. We engage service providers to assist us in our daily business such as IT support and maintenance providers, web server providers. All service providers are legally and contractually required to respect and comply with applicable data protection legislation. Our service providers include:
        • SAP; and
        • Google
      • To other app users, if you have given us your consent to do so.

      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").

  • 7. 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.

  • 8. Retention periods

      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:

      • in the event of inactivity of your user profile for a period of 5 years; and/or
      • when you delete your user profile
  • 9. Your rights

      Under applicable data protection law, you have certain rights with regard to the processing of your Personal Data by us:

      • Right of access to your Personal Data;
      • Right to rectification of inaccurate or incomplete Personal Data;
      • Right to erasure of your Personal Data;
      • Right to restriction of processing;
      • Right to data portability, when the processing of your Personal Data is based on your consent or on a contract, and the processing is carried out by automated means;
      • Right to withdraw consent with effect for the future
      • Right to lodge a complaint with a supervisory authority; and
      • Right to object to the processing of your Personal Data on grounds relating to your particular situation, and right to object to the processing of your Personal Data for direct marketing purposes.
  • 10. Joint controllership agreement

      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.

  • 11. Data security

      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.

  • 12. Third-party links and websites

      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.

  • 13. Children

      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.

  • 14. Miscellaneous

      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.

      Attachment

      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

      Additional Disclosures for California Consumers

      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”).

      Personal Data We Collect

      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:

      • E-TUBE PROJECT
        • Identifiers (e.g., username and login password, home address, email address, IP address, unique device ID (such as Instance ID, IDFV, Firebase ID))
        • Demographics (e.g., gender, birthday)
        • Commercial Information (e.g., bike information such as nickname, components information (product name, gear teeth number, serial number, firmware version, unit log, component name pass key, and Universally Unique Identifier of wireless unit))
        • Internet Activity (e.g., app usage log information (error and crash recovery logs, date/time stamps, clickstream data))
        • Location Data
      • E-TUBE RIDE
        • Identifiers (e.g., username and login password, home address, email address, IP address, unique device ID (such as Instance ID, IDFV))
        • Demographics (e.g., gender, birthday)
        • Commercial Information (e.g., bike information such as nickname, components information (serial number, name and Universally Unique Identifier of wireless unit))
        • Biometric Information (e.g., bike ride log information such as pedaling cadence)
        • Internet Activity (e.g., bike ride log (time, distance, speed, gear position, assist mode, error log), app usage log information (error and crash recovery logs, date/time stamps, clickstream data))
        • Location Data (e.g., bike ride log information (latitude/longitude, elevation))

      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.

      How We Share Personal Data

      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 Rights

      California law grants certain rights to California consumers. These include the rights to:

      • Access specific pieces of Personal Data (“Right to Access”)
      • Learn about how we process and share Personal Data (“Right to Know”)
      • Request deletion of Personal Data we collected from you (“Right to Request Deletion”)
      • Opt out of “sales” of Personal Data, as that term is defined under California law
      • Not to be denied goods or services for exercising these rights

      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

      Contact Us

      If you have any questions regarding the processing of your Personal Data, please contact us at privacy@shimano-eu.com

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