Bu Verilerin Korunmasına Dair Bildirim (“Bildirim”), Shimano Inc. tarafından geliştirilen ve sunulan aşağıdaki uygulamaları kullanmanıza ilişkin verilerin işlenmesi faaliyetlerini açıklamaktadır.

• E-TUBE PROJECT App ("E-TUBE PROJESİ"); ve
• E-TUBE RIDE App ("E-TUBE RIDE", birlikte "App'ler ("Mobil Uygulamalar)" olarak anılacaklardır).

Aksi belirtilmedikçe, burada sağlanan bilgiler, genel olarak iki App'in (Mobil Uygulamaların) hepsi için geçerlidir.

Bu Bildirim, ayrıca, App'ler (Mobil Uygulamalar) ile bağlantılı veri işleme faaliyetlerinden sorumlu Shimano kuruluşları arasında yapılan düzenlemelerin en ilgili yönleri hakkında sizi bilgilendirir.

Kişisel Veri(ler); tanımlanan ya da tanımlanabilir bir gerçek kişi ile ilgili bilgiler anlamını taşır; tanımlanabilir bir gerçek kişi; özellikle, bir isme, bir kimlik numarasına, lokasyon verisine, online (çevrim içi) bir kimlik tanımlayıcıya veya o gerçek kişinin fiziksel, fizyolojik, genetik, zihinsel, ekonomik, kültürel veya sosyal kimliğine özgü bir ya da daha fazla sayıda unsura (“Kişisel Veriler”) atıfta bulunularak, doğrudan veya dolaylı olarak, kimliği tespit edilebilecek bir kimsedir.

Kişisel verilerin özel kategorileri; ırk ya da etnik köken, siyasi düşünceler, dini veya felsefi inançlar ya da sendika üyeliğini ortaya koyan veriler, genetik veriler, biyometrik veriler, sağlıkla ilgili veriler veya bir gerçek kişinin cinsel yaşamı ya da cinsel yönelimi ile ilgili verileri içerir (“Hassas Veriler” olarak da anılacaktır).

Kaliforniya’daki tüketicilere ait Kişisel verileri nasıl işlediğimiz hakkında daha fazla bilgiyi, bu Bildirim’in aşağıdaki “Kaliforniya’daki Tüketiciler için İlave Açıklamalar” kısmını gözden geçirerek bulabilirsiniz.

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 (i) in order to provide you with information about the Apps and their functionalities for the purpose of providing you with the Services, (ii) to send you information about similar products and/or services, (iii) upon your request or consent (for example, to obtain feedback from you in order to improve our products, services and/or marketing).

  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, and to provide you with product and/or service information, 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 only to the extent necessary, e.g. for the fulfillment of data subjects’ rights or to respond to your inquiries. 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").

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.

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.

U.S. residents may also contact us to appeal any decision we make relating to requests to exercise your rights. To appeal a decision, please contact us using the contact details above.

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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