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.

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. This includes health-related data (heart rate and weight information). 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 us and could have legal consequences, see Art. 6 (1)(b) and (f) GDPR.

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").

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:

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

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.

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 for personal data of users located in the EEA 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.

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