Information about the changes in the data protection notice
Please find below in red the material changes made to the data protection notice dated Apr. 2024
| Version Aug. 2023 | Version Apr. 2024 |
|---|---|
| 4.1 Information you provide to us | 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 process bike information as information relating to an identified or identifiable natural person. (b)E-TUBE RIDE - User information: username (nickname), login password (encrypted). gender, birthday, home address (state/prefecture level), and email address; - Health-related data: heart rate and weight information; 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 health-related or bike information as information relating to an identified or identifiable natural person. |
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, and may in particular include your Personal Data 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 process bike information as information relating to an identified or identifiable natural person. (b)E-TUBE RIDE - User information: username (nickname), login password (encrypted). gender, birthday, home address (state/prefecture level), and email address; - Health-related data: heart rate and weight information(max./ave. heart rate, body weight included in the bike ride log); - 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)); and - Bike ride log: latitude/longitude, time, elevation, distance, speed, pedaling cadence, gear position, ave. power, assist mode, error log, calorie consumption based on health related information (max./ave. heart rate, body weight) E-TUBE RIDE offers you the option of using the app without logging in. If you choose this option, we will not process health-related, bike, or bike ride log information as information relating to an identified or identifiable natural person. |
| 4.3 Information we receive from other sources | 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. […] |
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, Apple ID and Google. […] |
| 7. International data transfers | 7. International data transfers |
| All data collected via the Apps will be stored centrally in the European Union ("EU") on servers provided by AWS. As (joint) data controller, SIC has 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. AWS is located in the USA. An adequacy decision by the EU Commission does not exist for the USA. The data transfer to AWS is subject to standard contractual clauses for the transfer of personal data to processors established in third countries. A copy of the clauses can be requested from the data processing officer. | All data collected via the Apps will be stored centrally in the European Union ("EU") on servers provided by AWS. As (joint) data controller, SIC has 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. AWS is located in the USA. The data transfer to AWS is based on the EU-US-Data Protection Framework which is an adequacy decision by the EU Commission determining that the USA provide an adequate level of data protection. In addition, standard contractual clauses for the transfer of personal data to processors established in third countries have been concluded. A copy of the clauses can be requested from the DPO. For more information on international data transfers in connection with the Apps and adequate safeguards implemented for this purpose you may contact our DPO. |
Please find below in red the material changes made to the data protection notice dated Aug. 2023.
| Version Jan. 2023 | Version Aug. 2023 |
|---|---|
| 2. Data controller | 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 PROJECT and E-TUBE RIDE as joint data controllers (SIC, SEU, SNAH and SSJ together referred to hereinafter as "we", "our" or "us"). In derogation of the above, controller responsible for the processing of your Personal Data in relation to E-TUBE PROJECT and E-TUBE RIDE in - Australia, Taiwan, New Zealand, South Korea, Brazil, Indonesia, and Thailand is SIC, - Switzerland, Israel and Turkey are SIC and SEU, and - Canada are SIC and SNAH. If you are from these countries, by referring to “we”, “our” or “us” and by referring to SIC and/or SSJ and/or SNAH and/or SEU we only refer to the respective company or companies named above for the respective country. You can contact each joint controller by postal mail at the address above. |
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 PROJECT and E-TUBE RIDE as joint data controllers (SIC, SEU, SNAH and SSJ together referred to hereinafter as "we", "our" or "us"). In derogation of the above, controller responsible for the processing of your Personal Data in relation to E-TUBE PROJECT and E-TUBE RIDE in - Australia, Taiwan, New Zealand, South Korea, Brazil, Indonesia, Thailand, Argentina, Chile, Colombia, Costa Rica, Guatemala, India, Malaysia, Mexico, Panama, Philippines, Singapore, Uruguay and Venezuela is SIC, - Switzerland, Israel Turkey, Andorra, Bosnia and Herzegovina, Monaco, and Republic of South Africa are SIC and SEU, and - Canada are SIC and SNAH. If you are from these countries, by referring to “we”, “our” or “us” and by referring to SIC and/or SSJ and/or SNAH and/or SEU we only refer to the respective company or companies named above for the respective country. You can contact each joint controller by postal mail at the address above. |
| 6. Recipients of Personal Data | 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 - 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"). |
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: - Amazon Web Services Inc., 410 Terry Avenue North, Seattle, WA 98109-5210, USA (cloud service provider acting as sub-processor) ("AWS"); and - SAP, Dietmar-Hopp-Allee 16, 69190 Walldorf, Germany (data processor; provider of customer relations and identity management services) - 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 | 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. | All data collected via the Apps will be stored centrally in the European Union ("EU") on servers provided by AWS. As (joint) data controller, SIC has 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. AWS is located in the USA. An adequacy decision by the EU Commission does not exist for the USA. The data transfer to AWS is subject to standard contractual clauses for the transfer of personal data to processors established in third countries. A copy of the clauses can be requested from the data processing officer. |
| Attachment | Attachment |
| […] | […] Andorra SHIMANO IBERIA, S.L. Avenida Doctor Severo Ochoa 34, 28100 Alcobendas, Madrid, Spain Phone: +34 91 902 25 86 E-mail: info.iberia@shimano-eu.com […] Argentina SHIMANO ARGENTINA SAU ESTADOS UNIDOS 20 PISO 5 CABA, C1101AAB Argentina TEL: 0800-345-2423 […] Bosnia and Herzegovina SBM-EUROTRADE TRGOVINA DOO Istocna Obilaznica 4, 37000 Krusevac Phone: +381 37 310 1669 E-mail: info@sbm-eurotrade.com […] Chile Andes Industrial Ltda Santa Elena #1511 – Santiago Santiago, 8360349 Phone: (+56) 2 2650-3100 […] Colombia HA Bicicletas S.A Calle 14 Nº 52 A - 187 Medellin, 050023 Phone: (+57) 4 285-5040 Email: servicioalcliente@habicicletas.com […] Costa Rica Ciclo San Nicolas S.A. Av. 10 entre calles 4 y 6 o de la Bomba la Castellana 125 mts Este - San José, 10103 Phone: (+506) 2521-6090 Email: info@ciclosannicolas.com […] Guatemala Bicimania Calzada la paz 18-40 zona 5 ofibodegas centro 5 bodega 123 Bicimania. Phone: (+502) 23367763 […] India Shimano South Asia Pvt. Ltd. No. 19, Kumarakrupa Road, Bangalore, Bangalore, Karnataka, India, 560001 Phone: +91-80-4125-3331 E-mail: sales@ssa.shimano.com.sg […] Malaysia Bike Science Sdn Bhd No. 29 & 31, Jalan TPP 5/17,Taman Perindustrian Puchong,section 5, 47100 Puchong,Selangor, Malaysia. Phone: +603-8061-0222 Fax: +603-8062-4855 E-mail: lerun@lerun.com.my […] Mexico Shimano Latin America Alameda Santos, 415 – 6º andar – Cj 61 Cerqueira César, São Paulo - SP, 01419-000 Brazil Email: contato@shimano.com.br […] Monaco SHIMANO FRANCE S.A.S. Zone Actiparc, 777 Rue Commios, 62223 St.-Laurent-Blangy Cedex, France Phone: +33 (0)321 732525 E-mail: contact-france@shimano-eu.com […] Panama Comercial Rali, S.A. Av. Balvoa, Edficio Sky Business, Planta Baja Republica de Panamá, 080807 Phone: (+507) 223-8054 Email: info@ralistoreonline.com […] Philippines Neo Zigma Cycle Corporation 39 Kapiligan Street, Brgy. Dona Imelda, Quezon City, Philippines E-mail: inquiry@zigma-sales.com […] Singapore SHIMANO (SINGAPORE) PTE. LTD. 11 Bulim Walk, Singapore 648105 Phone: +65-6265-4777 Fax: +65-6265-1575 E-mail: sales@shimano.com.sg […] Republic of South Africa COOLHEAT CYCLE AGENCIES (PTY) LTD. 57 Lake Road Longmeadow Business, Estate North extension no.7 Edenvale, 1609, P.O.Box 2984, Edenvale, 1610 Phone: +27 (0) 11 608 2003 […] Uruguay Villa Agreste SA Juan Benito Blanco 975 Montevideo - 11113 Phone: +598 27091549 Email: montevideo@global-cycle.com […] Venezuela Invebica C.A. Av.64 N° L-8 (Zona Industrial Castillito) San Diego - Carabobo Venezuela Phone: +58-2418716105 Email: ventas@kamikaze.com.ve […] |