Privacy Policy

This policy outlines the basic mindset that Shimano Inc. as well as its Group companies (hereinafter referred to as “the Company”) have with respect to the protection and handling of personal information obtained through business activities.

1. When handling personal information, the Company will comply with the items set forth by relevant law such as the Personal Information Protection Act, as well as this policy.

2. The Company will acquire personal information by lawful and fair means.

3. The Company will utilize personal information upon making clear the purpose of utilization, and will only use the personal information within the scope of the purpose.

4. The Company will not provide acquired personal information to a third party, except in cases in which the consent of the person is given or the provision is based on legal provisions.

5. The Company will appropriately manage personal information in order to secure its accuracy, and will also take reasonable safety measures in order to prevent leakage, loss, damage, etc. of personal information.

6. The Company will manage personal information appropriately and take reasonable safety measures when personal information is utilized jointly with Group companies or business partners within the scope of its purpose of utilization or if personal information handling is outsourced.

7. The Company will announce the procedures regarding inquiries and requests for disclosure of personal information that the Company possesses, and will respond promptly and sincerely to such requests.

8. In order to implement the aforementioned policy items, the Company will assign an individual responsible for the management of personal information.

9. The Company will continuously revise and improve its personal information management system and structure in order to effectively protect personal information in accordance with future changes in laws or circumstances.

Notice on the information obtained from the Internet site concerning Non-European residents

This Privacy Policy is designed to tell you about the practices regarding collection, use, and disclosure of information that may be collected by Shimano Inc. and the Group Companies (which mean the Joint Users of Personal Information as defined in Section 4(1) and together with Shimano Inc., hereinafter referred to as “Shimano”). Please be sure to read this entire Privacy Policy and the Terms and Conditions of Use (the “Terms”), available here, before using or submitting information to the websites owned or operated by Shimano (collectively, the “Sites”)*.

1. Consent

By using the Sites, you agree to the Terms of this Privacy Policy. Whenever you submit information via the Sites, you consent to the collection, use, and disclosure of that information in accordance with this Privacy Policy.

2. Information Collected

Personal Information

Shimano uses fair and proper means to collect your Personal Information (which means information about a living individual which can identify the specific individual by name, date of birth or other description contained in such information (including such information as will allow easy reference to other information and will thereby enable the identification of the specific individual) such as your name, date of birth, e-mail address, credit card information, shipping and billing address, etc.) to the extent necessary to achieve the purpose for use prescribed in this Privacy Policy. We do not collect information regarding your race, nationality, ancestry, lineage, religion, political views or membership of workers’ unions.

Information Collected Automatically

Shimano also automatically collects your IP address and referring website address, browser type, domain name and website access frequency. This information is intended to help facilitate your online experience on the Sites. Shimano uses cookies to track usage patterns on the Sites and to control the display of ads, as well as to offer other functionalities (such as screening for age and “recognizing” you to speed up your log-in when you visit the Sites). You can turn off cookies, but that will affect your online experience. See below for more detail on cookies.

3. Purposes of Use of Collected Information

Shimano uses information other than Personal Information you provide for the purpose of fulfillment of your requests and improvement of the Sites and materials contained thereon and for any other purposes which we deem reasonable and necessary. Shimano may, from time to time, produce reports for advertisers, sponsors, Group Companies and vendors containing anonymous, aggregate information about our users and customers, such as demographic, age and online usage information. This information allows Shimano to provide content and offers that are most relevant to our users to work more closely with advertisers. We do not include any Personal Information of our users in these reports.

Shimano uses Personal Information only for the purpose described in this Privacy Policy or otherwise. Shimano uses Personal Information so that we may supply specific information requested by customers, undertake surveys or competitions, etc., manage orders for products and services, display or send custom, personalized content to our users and send newsletters, mail, e-mails, features, promotional material, surveys and other updates, information or offers to our users. Shimano also uses collected information to evaluate and administer our products and services, fulfill customers request, respond to any future problems, such as difficulties in navigating our Sites or accessing certain features, and to gauge user trends to determine what products and services are most popular with users. Other uses of Personal Information are described on each Site page on which you record your Personal Information. Shimano may combine Personal Information with other collected information for the purposes of use unless otherwise specified.

4. Sharing of Collected Information

Shimano may share your Personal Information as follows:

(1) Joint Users of Personal Information

See Here for More Details on Joint Users of Personal Information

All companies working for and with Shimano must comply with our Privacy Policy, and are not permitted to sell or otherwise disclose your Personal Information to third parties except as authorized by us and you, or as permitted or required by law.

(2) Shared Personal Data
Your name, address, telephone number, gender, date of birth, occupation and e-mail address.

(3) Purposes of Use of Shared Information
Personal information is shared to enable joint users to supply specific information requested by customers, undertake surveys or competitions, etc., manage orders for products and services, display or send custom, personalized content to our users and send newsletters, mail, e-mails, features, promotional material, surveys and other updates, information or offers to our users.

(4) Manager of Shared Personal Information
Shimano Inc.
Sharing of Information Not Containing Personal Information
Shimano shares anonymous, aggregate demographic information, and anonymous information obtained from cookies and similar technologies, with each of our distributors, our sponsors, promotional and business partners, and participating vendors. No Personal Information, such as credit card information, is disclosed to any of these third parties in sharing such anonymous information.

5. Supply of Information to Customers

We may extend e-mail offers to users or customers on behalf of our business partners about a particular product or service that may be of interest to you without sharing your name or e-mail address with or disclosing your name or e-mail address to those business partners, Of course, you may opt out of receiving these offers at any time.

Sometimes we will give you the opportunity to opt in to receive e-mail offers from third parties not affiliated with us. If you decide to accept these offers, we will provide, upon your consent, your contact information to the third party. We urge you to review carefully the privacy policies of these firms. We are not responsible for the privacy policies and procedures of any third party.

You should be aware that if you voluntarily disclose information, personal or otherwise, online in any community area, that information can be collected and used by others. For example, if you use chat, forums, bulletin boards or message boards, or if you post Personal Information online (such as your e-mail address), you may receive unsolicited messages from others. We have no control over this use of your Personal Information.

6. Credit Card Companies

In the event that you choose to transact using a credit card, Shimano will supply to your credit card company all relevant information about the name of the vendor, item(s) purchased, purchase date, total cost and other information necessary to process the transaction. Shimano will not otherwise provide any Personal Information to your credit card company without your permission.

7. Disclosure to Third Parties

Shimano will not disclose your Personal Information to any third parties without your consent; provided, however, that Shimano reserves the right to use or disclose to a third party any information without a customer’s consent in the following circumstances:

(i) If it is requested by any laws and regulations;

(ii) If Shimano deems it necessary for protection and security of human life, body or assets (including the Sites);

(iii) If Shimano deems it particularly necessary for improvement of public health or enrichment of children’s welfare;

(iv) If Shimano deems it particularly necessary for cooperation with a governmental body or other public organization or its designee in discharging its duties pursuant to the laws and regulations (including investigating breach of laws), or otherwise deems it particularly necessary for the public interest;

(v) If Shimano outsources the handling of personal information to the extent necessary for its business operation.

8. Personal Data Request

(1) The individual customer that is identifiable by the personal information (the “Owner”) may request Shimano for the notification of the purpose of use of Retained Personal Data as defined in the Japanese Personal Information Protection Law (the “Personal Data”) of the Owner, disclosure of such Personal Data in Shimano’s possession, correction, addition to or deletion of the content of such Personal Data, cessation of use or deletion of such Personal Data or cessation of supply of such Personal Data to a third party (such request being referred to herein collectively as “Personal Data Request”).

(2) The Owner is requested to submit a Personal Data Request by using the method prescribed on the respective page of the Site on which the Owner recorded the subject personal information or by submitting a written application form prescribed by Shimano. The prescribed processing fee will be charged if we are requested to deliver a hard copy of our response to the Owner.

(3) In the event of a Personal Data Request, Shimano will confirm the identity of the applicant and/or the authority if he/she is an agent by one of the following means:

(i) Confirmation of the Owner’s Personal Information in our possession such as name, address, telephone number, e-mail address, etc.

(ii) Documentary evidence such as driver’s license, passport, basic resident register card, health insurance certificate, certificate of registered seal, etc.

(iii) Confirmation by personal phone call, etc. to the Owner.

(iv) In the event of an application by the Owner’s agent confirmation of the power of attorney from the Owner.
(The agent’s authority will be confirmed by conformance of the seal on the power of attorney with the certificate of registered seal or by personal phone call, etc. to the Owner)

(v) Other method of confirmation which Shimano deems appropriate.

(4) If the applicant’s identity is confirmed pursuant to paragraph (3) above, we will reply in writing or such other means as the Owner and we consider reasonable and respond in the following manner:

(i) In the event that the Personal Data Request is for disclosure of Personal Data or notification of purpose of use of Personal Data, we will make disclosure or notification within a reasonable timeframe and to a reasonable extent.

(ii) In the event that the Personal Data Request is for correction of, addition to or deletion of Personal Data for the reason that the content of the Personal Data is incorrect, we will correct, add to or delete the incorrect Personal Data within a reasonable timeframe and to a reasonable extent.

(iii) In the event that the Personal Data Request is for cessation of use or deletion of Personal Data, or cessation of disclosure of Personal Data to a third party, we will cease use, delete or cease disclosure to a third party within a reasonable timeframe and to a reasonable extent. Please note that if we partly or fully cease use of or delete the Personal Data, or cease disclosure of the Personal Data to a third party, we may be unable to provide services that meet the Owner’s requirements.

(5) We may be unable to respond to a Personal Data Request if:

(i) We are unable to confirm the applicant’s identity or authority pursuant to paragraph (3) above;

(ii) The applicant does not follow the procedures described above;

(iii) The information, in relation to which the Personal Data Request is made, does not fall within the definition of Personal Data;

(iv) Fulfillment of the request threatens to cause damage or injury to the life, body, assets or other rights or interests of the Owner or a third party;

(v) Fulfillment of the request threatens to cause material impediment to our business operation;

(vi) Fulfillment of the request constitutes violation of laws and regulations.

9. Cookies

Your web browser offers so-called “cookies” which, if you allow their use, store small amounts of data on your computer when you visit a website. Cookies do not contain any Personal Information about you and therefore cannot be used to identify you personally. However, cookies assist us in tracking which of our features you like best. Therefore, cookies enable us to customize our content according to your preferences. You have the ability to accept or decline cookies by modifying your browser settings. Our Sites are viewable even if you disable the cookie function on your browser. However, if you disable cookies, some advanced and customized features will not be available to you.

10. Hotjar

Some of our webpages use services provided by Hotjar Ltd. Hotjar provides services including Heatmaps, Visitor recordings, Funnels and Form Analysis, Feedback Polls, Surveys and Recruiters. The information generated by the tracking code and cookie about your use of the website will be transmitted to and stored by Hotjar on servers in Ireland. Through the Hotjar tracking code the information collected includes:

Device-specific data

The following information may be collected through your device and browser:

• your device's IP address (collected and stored in an anonymized format);

• your email address including first name and surname;

• device screen size;

• device type (unique device identifiers) and browser information;

• geographic location (country only);

• preferred language used to display the webpage.

Log data

Our servers automatically record information which is created upon using Hotjar. Data includes:

• referring domain;

• pages visited;

• geographic location (country only);

• preferred language used to display the webpage;

• date and time when website pages were accessed;

Hotjar will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Hotjar uses a variety of services hosted by third parties, such as Google Analytics and Optimizely. These services may collect information sent by your browser as part of a web page request, such as cookies or your IP request. For information on how Google Analytics and Optimizely collect and use your information, please refer to their privacy policies. By continuing to use this website, you consent to the processing of the above data by Hotjar and by the third parties used by Hotjar in accordance with their respective privacy policies. The cookies used by Hotjar have differing durations; some persist for the session only, others will persist for a longer period, with a maximum of 365 days.

To opt out please go to the following link:

https://www.hotjar.com/opt-out

11. Web Beacons

Some of our web pages may contain electronic images known as web beacons, which are also called “single-pixel gifs”. These images allow us to count users who have visited those pages and to deliver co-branded services. We may also include web beacons in promotional e-mail messages or newsletters in order to count how many messages have been opened and acted upon. Web beacons are not used to access your Personal Information but they are a technique we use to compile aggregated statistics about usage on the Sites. Web beacons collect only a limited range of information including the time and date of page view, cookie number and description of the page on which the web beacon resides.

12. Security of Personal Information

We use Secure Sockets Layer (SSL) technology to encrypt important information, such as your credit card data, in an effort to prevent unauthorized access during transmission of your orders over the Internet. We implement standard industry practices internally and with our service providers to maintain the security of your Personal Information depending on its sensitivity and to avoid disclosure of such Personal Information unpermitted under this Privacy Policy.

Although we have implemented systems and procedures to secure the data maintained by us, security during Internet transmissions can never be assured. Shimano employees are made aware of our privacy practices through periodic communications and training. Our policy is to limit access to Personal Information to those Shimano employees or agents with a specific need to access or retrieve the information. We store data on multiple service systems, in controlled environments. To maintain security, we conduct internal reviews of our security measures on a regular basis. Please note, however, that any Personal Information you post in chat rooms or message boards is available to anyone. WHILE SHIMANO HAS TAKEN COMMERCIALLY REASONABLE PRECAUTIONS TO SAFEGUARD PERSONAL INFORMATION, SHIMANO CANNOT AND DOES NOT GUARANTEE COMPLETE SECURITY OF PERSONAL INFORMATION BECAUSE COMPLETE SECURITY DOES NOT PRESENTLY EXIST ON THE INTERNET.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

13. Transfer of Personal Information

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for Shimano or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. Shimano will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

14. Third Party Advertising

Advertisements appearing on our Sites may be delivered to users by us or one of our advertising partners. Our advertising partners may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement. In this way, ad servers may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy covers the use of cookies by Shimano only, and does not cover the use of cookies by any advertisers.

15. Children

We will not knowingly collect Personal Information via the Sites from visitors younger than thirteen (13) years of age. We encourage parents to talk to their children about their use of the Internet and the information they disclose on websites.

16. Changes in Corporate Structure

In developing our business, we may engage in the sale or transfer of certain assets and the company itself, or parts of it, may be sold, merged or otherwise assigned. In such transactions and changes in ownership, user information, whether personally identifiable or otherwise, may constitute one of the transferred assets. If required by law, we will notify affected users of such transfer or assignment in accordance with the procedure for changing this Privacy Policy described below.

17. Changes to our Privacy Policy

We will occasionally update this Privacy Policy as necessary to protect our users and to accommodate a changing environment. The changes to our Privacy Policy will be deemed to be effective from the date of posting on our Sites unless we specify otherwise. We recommend that you check the Privacy Policy when you visit our Sites to be sure that you are aware of and understand our current policy. If we make material changes to this Privacy Policy, we will make efforts to prominently post such changes prior to implementing the change. We will not make any retroactive material changes in how we handle previously collected Personal Information unless you allow us to do so, or unless we are legally required to do so, and in such a case we will make efforts to inform registered visitors of information on material changes to this Privacy Policy via email.

Contact Information for Questions or Complaints
Please contact us if you have any questions, comments or complaints regarding this Privacy Policy, our privacy practices or our treatment of your Personal Information.
Please refer to contact information of Shimano and the respective Group Companies posted on our Sites.

This Privacy Policy was last updated on 21 March 2017. “Policy for protection of personal information” and “Handling of customer information”, which was posted on the Japanese website of Shimano, was abolished as of 19 June 2012.

*The following Sites included but are not limited to and may be updated without notice:

https://www.shimano.com,
http://www.shimano.com.au,
http://www.shimano-china.com,
http://cycle.shimano-eu.com,
http://www.shimano-benelux.com,
http://www.shimano-nordic.com,
http://www.shimano-france.com,
http://cycle.shimano.co.jp,
http://bike.shimano.com,
http://pro-bikegear.com,
http://www.shimano-eyewear.com,
http://www.shimano-cyclingwear.com,
http://techdocs.shimano.com,
http://www.shimanofish.com.au,
http://fish.shimano-eu.com,
http://shimanofireblood.com,
http://fishing.shimano.co.jp,
http://boat.shimano.com,
http://aifie.net,

https://lazer.us

https://lazersport.ca/

Notice on the (personal) data obtained from the Internet site concerning European residents

This Notice describes the manner in which Shimano Inc. as well as its group companies (hereinafter collectively referred to as “Shimano” or “we”) protect and process (personal) data concerning European residents obtained through Shimano’s websites (collectively, the “Sites”).*

The basic mind-set of Shimano in respect to the protection and processing of (personal) data concerning European residents can be summarized as follows:

1. Either Shimano Inc. or Shimano Europe B.V. is the controller within the meaning of the European General Data Protection Act (“GDPR”) for the handling of personal data concerning European residents obtained through the Site(s) in compliance with the obligations set forth by relevant data protection law such as the GDPR, as well as this privacy policy. Which entity is the controller depends on the Site you are visiting. Moreover, depending on the processing activity, other companies within Shimano may be joint controller(s). Please contact us at privacy@shimano-eu.com, if you wish to obtain more information.

2. Shimano will acquire personal data by lawful and fair means.

3. Shimano will utilize personal data upon making clear the purpose of utilization, and will only use the personal data within the scope of the purpose.

4. Shimano will not provide acquired personal data to a third party, except in cases in described in this privacy policy or the cookie policy.

5. Shimano will appropriately manage personal data in order to secure its accuracy, and will also take reasonable safety measures in order to prevent leakage, loss, damage, etc. of personal data.

6. Shimano will manage personal data appropriately and take reasonable safety measures when personal data is utilized internally within the group or by third parties within the scope of its purpose of utilization or if personal data handling is outsourced.

7. Shimano will announce the procedures regarding inquiries and requests for disclosure of personal data that Shimano possesses, and will respond promptly and sincerely to such requests. If you accidentally send your inquiry or request to the wrong group company of Shimano, we will take care that such inquired or request will be redirected to the correct group company.

8. In order to implement the aforementioned policy items, Shimano has assigned a privacy department, which can be reached at privacy@shimano-eu.com.

9. Shimano will continuously revise and improve its personal data management system and structure in order to effectively protect personal data in accordance with future changes in laws or circumstances.

Please be sure to read this entire privacy policy before using or submitting information to the Sites. For more information on Shimano’s use of cookies an similar technologies, please refer to our cookie policy.

1. Legal basis

We will process your personal data obtained through the Sites in accordance with applicable law, including the GDPR. When we process your personal data, such processing will be based on any of the following grounds listed in the GDPR:

(a) your consent;

(b) the performance of a contract to which you are a party (or in order to take steps at your request prior to entering into a contract);

(d) in order to protect the vital interests of you or of another natural person; or

(e) legitimate interests of Shimano or a third party.

2. Purposes for which your personal data may be processed

We may process your personal data obtained through the Sites for the following purposes:

(a) to send you information requested by you;

(b) to perform and manage your orders for products and/or services;

(d) to send you safety instructions or use instructions for your Shimano products and services;

(e) to send you information about new features or new products or services that may be relevant for you based on the Shimano products and services previously purchased by you;

(f) to ask you to participate in surveys and to manage the outcome of surveys in which you have participated;

(g) to analyze your use of our products and services for quality control, product development and marketing purposes;

(h) to send newsletters and commercial messages to you, which messages may be specifically tailored for you based on the type of services and products purchased by you and your use thereof;

(i) to organize joint marketing events with third parties;

(j) to satisfy statutory obligations of Shimano, such as obligations regarding bookkeeping and tax law;

(k) to enable Shimano to perform possible product recalls and to enforce and defend its rights in disputes;

(l) to test information security measures of Shimano, e.g. by performing pen tests;

(m) to improve your online experience on our websites;

(n) for any other purposes made known to you beforehand, e.g. to handle your application for a job or traineeship at Shimano.

3. Types of personal data we process

We may collect your personal data in the following manner(s):

(a) When contacting us or when purchasing or using our products or services you may be asked to submit certain personal data, such as contact information when requesting information or contact and payment information when ordering products or services.

(b) When you use a product or service that is designed to collect certain personal data, such as with respect to measurement data obtained during bike fitting services or with respect to products and services that assist you in remembering and applying your bike settings. The relevant product or service descriptions will further detail which personal data is processed.

(c) When you create and maintain a Shimano account, you may be asked to provide certain personal data, such as name, user name, email address and password, and to keep such personal data up to date.

(d) When you visit and use the Site, our servers automatically record certain data, such as URL, IP address, browser type and language, and the date and time of your visit. Also, we may collect personal data concerning your use of the Site. Your personal data is obtained by cookies and similar mechanisms. The Sites will inform you of our use of cookies and similar mechanisms.

(e) By obtaining certain personal data from third parties. We will always ask such third party to confirm that making the personal data available to us is in compliance of law, e.g. because you have consented to such transfer of personal data.

When we ask you to submit your personal data, we will indicate which data fields are optional. If you fail to provide us with the obligatory information, we may not be able to adhere to your request (e.g. to create a Shimano account).

Depending on the purpose of processing, Shimano may process the following personal data from you: name, contact information (including telephone number and e-mail address), shipping and billing address, date of birth, gender, the sort of products or services purchased or used by you, specific requests made by you, payment information (such as credit card information), and specific information that is requested or generated in order to use or benefit from a product or service (e.g. bike fitting), such as bodyweight, length, etc.

We will not store your personal data for a longer term than necessary for compliance with the storage terms provided for by law and the fulfilment of the purposes as mentioned in this privacy policy.

4. Sharing of personal data

In the event that you provide personal data on the Sites, in particular your name, address, telephone number, gender, date of birth, occupation, e-mail address, your response to surveys or competitions, and your requests, we may share internally such personal data. In addition, personal data (e.g. IP-addresses) collected by means of cookies and similar technologies may be shared if you applied the respective approvals. Where we share your personal data within our group, the following principles will be adhered to:

(a) All Joint Users of Personal data, meaning the group companies working for and with Shimano Inc., must comply with our privacy policy, and are not permitted to sell or otherwise disclose your personal data to third parties except as authorized by Shimano Inc. or Shimano Europe B.V. and you, or as permitted or required by applicable law.

(b) Shimano has applied adequate safeguards to ensure organizational and technical security measures, including by agreeing on standard contract clauses where your personal data is transferred to group companies that are established outside the EEA.

We may share your personal data, such as your name and e-mail address, with third parties not affiliated with us if you have consented to receive e-mail offers from such third parties. See Section 5 for more details. In addition, Shimano may share your personal data to your credit card company, bank or another payment service provider in the context of a transaction. See Section 6 for more details. In exceptional circumstances, Shimano may share your personal data with other third parties. See Section 7 for more details.

We may make use of processors to support certain of our business functions, such as IT providers that offer storage services. If and insofar as these third parties process your personal data while doing this, they will do so on the basis of a processing agreement in accordance with the GDPR.

We may also share anonymous, aggregate (demographic) information with third parties, such as our distributors, our sponsors, promotional and business partners, and participating vendors.

5. Marketing

We may use your contact information to send you newsletters and commercial emails, such as to inform your about new developments in relation to our products and services. Also, we may extend e-mail offers to you on behalf of business partners about a particular product or service that may be of interest to you, without sharing your name or e-mail address with or disclosing your name or e-mail address to those business partners. Where required under applicable law, we will only send you such commercial emails if you have consented to receiving such emails.

Sometimes we will give you the opportunity to opt in to receive e-mail offers from third parties not affiliated with us in accordance with applicable laws. If you decide to accept these offers, we will provide, upon your consent, your contact information to the third party. We urge you to review carefully the privacy policies of these firms. We are not responsible for the privacy policies and procedures of any third party.

At any time you may notify us that you no longer wish to receive newsletters or other commercial messages from us via email. We will process your notification in due course and remove you from our mailing list.

6. Credit card companies, banks and other payment service providers

In the event that you choose to transact using a credit card or debit card, we will supply to your credit card company, bank or other payment service provider all relevant information about the name of the vendor, item(s) purchased, purchase date, total cost and other information necessary to process the transaction. Shimano will not otherwise provide any personal data to your credit card company, bank or payment service provider without your permission.

7. Disclosure to third parties

We will not disclose your personal data to any third parties other than your credit card company, bank or other payment service providers or our processors without your consent; provided, however, that we reserve the right to use or disclose to a third party any information without your consent in the following circumstances:

(a) If it is requested by any laws and regulations, in order to comply with legal obligations Shimano is subject to;

(b) If we deem it necessary for protection and security of vital interests of you or third parties, including human life, body or assets (including the Sites), such as for improvement of public health or

(c) If we deem it particularly necessary for cooperation with a governmental body or other public organization or its designee in discharging its duties pursuant to the laws and regulations (including investigating breach of laws), or otherwise deems it particularly necessary for the performance of a task carried out in the public interest;

(d) If we outsource the handling of personal data to the extent necessary for its business operation.

We will use best efforts to inform you prior to such disclosure, including of the recipient of your personal data, by means of this privacy policy or, if appropriate, we will make efforts to inform you via other methods (e.g. email) when you are a registered visitor.

8. Cookies

We may collect and process information, including personal data, using cookies and similar technologies when you visit and use the Site. For example, we may collect URL, IP address, browser type and language, and the date and time of your visit. Also, we may collect personal data concerning your use of the Site. Please go to our cookie policy for a detailed overview on we handle cookies and similar technologies.

Moreover, our advertising partners may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement. In this way, ad servers may compile information about where you, or others who are using your computer, saw their advertisements and determine which ads are clicked on. This information allows an ad network to deliver targeted advertisements that they believe will be of most interest to you. Please go to our cookie policy for more information.

9. Security of personal data

We maintain state of the industry security measures to avoid unauthorized access to, alteration, disclosure or loss of your personal data. For example, we use Secure Sockets Layer (SSL) technology to encrypt important information, such as your credit card data, in an effort to prevent unauthorized access during transmission of your orders over the Internet. We implement 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 privacy policy.

Although we have implemented systems and procedures to secure the data maintained by us, security during Internet transmissions can never be assured. Shimano employees are made aware of our privacy practices through periodic communications and training. Our policy is to limit access to personal data to those Shimano employees or agents with a specific need to access or retrieve the information. We store data on multiple service systems, in controlled environments. To maintain security, we conduct internal reviews of our security measures on a regular basis. Please note, however, that any personal data you post in chat rooms or message boards is available to anyone. While we have taken commercially reasonable precautions to safeguard personal data, we cannot and do not guarantee complete security of personal data because complete security does not presently exist on the Internet.

10. Transfer of personal data

We may transfer your personal data collected through the Sites to, and store at, a destination outside the European Economic Area ("EEA"). For example, Shimano staff working outside the EEA may access and further process your personal data. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. Shimano will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy policy and applicable data protection laws, including the GDPR. For example, Shimano may use contracts approved by the European Commission for the transfer of data to such destinations.

11. Links to websites of others

The Sites may contain hyperlinks to third party websites, or embedded content of third party websites. The privacy policy of third parties are subject to the processing of personal data by third parties. Shimano is not responsible for the content of these third party websites and the processing of personal data by these third parties.

12. Children

We will not knowingly collect personal data via the Sites from visitors younger than thirteen sixteen (16) years of age. We encourage parents to talk to their children about their use of the Internet and the information they disclose on websites. If you are younger than 16 and wish to visit the Site(s), you may only provide your personal data to Shimano if you have obtained permission from your parent(s) or your legal representative(s).

13. Changes in corporate structure

In developing our business, we may engage in the sale or transfer of certain assets and Shimano itself, or parts of it, may be sold, merged or otherwise assigned. In such transactions and changes in ownership, user data, whether personal or otherwise, may constitute one of the transferred assets. If required by law, we will notify you of such transfer or assignment in accordance with the procedure for changing this privacy policy described in section 15 below.

14. Your rights

You have the right to request from Shimano access to and rectification or erasure of personal data or restriction of processing concerning you or to object to processing as well as the right to data portability.

Where the processing of your personal data is based on your consent, you have the right to withdraw the consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You have the right to lodge a complaint about our processing of your personal data with the Dutch Data Protection Authority (Autoriteit persoonsgegevens) or the possible competent supervisory authority in your country.

You may invoke any of these rights by sending your request to: privacy@shimano-eu.com.

We reserve the right to refuse any requests if your identity cannot be demonstrated by you and/or we can invoke any of the exceptions stated in the GDPR. In such case, we will inform you of the refusal.

15. Changes to our privacy policy

We will occasionally update this privacy policy as necessary to protect our users and to accommodate a changing environment. The changes to our privacy policy will be deemed to be effective from the date of posting on our Sites unless we specify otherwise. We recommend that you check the privacy policy when you visit our Sites to be sure that you are aware of and understand our current privacy policy. If we make material changes to this privacy policy, we will make efforts to prominently post such changes prior to implementing the change. We will not make any retroactive material changes in how we handle previously collected personal data unless you allow us to do so, or unless we are legally required to do so, and in such a case we will make efforts to inform visitors of information on material changes to this privacy policy.

16. Contact information for questions or complaints

Please contact our privacy department if you have any questions, comments or complaints regarding this privacy policy, our privacy practices or our treatment of your personal data, using the following contact details:

privacy@shimano-eu.com.

This privacy policy was last updated on 1 October 2018.

*Please note that this privacy policy also applies to any processing of personal data concerning non-EU residents obtained through the Sites to which the GDPR applies.

PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS

This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Shimano Inc. as well as its group companies (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We have adopted this Privacy Statement for California Residents to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this Privacy Statement for California Residents.

This Privacy Statement for California Residents should be read together with our Privacy Policy, which provides important information on our collection and use of personal data.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

・Identifiers: These include a person’s real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, and other similar identifiers.

・Personal Information: Including a name, signature, address, telephone number.

・Internet or other similar network activity: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

We do not collect:

・Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

・Protected Characteristics: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

・Biometric Information:

・Geolocation data

・Sensory Data

・Employment Data

・Educational Data

We obtain the categories of personal information listed above from the following categories of sources:

・Directly from our customers. For example, when a customer enrolls in a newsletter or orders products or completes a consumer warranty claim form.

・Indirectly from our customers. For example, through information we collect from our customers in the course of providing services to them.

・Directly and indirectly from activity on our website (www.shimano.com). For example, from submissions through our website portal or website usage details collected automatically.

・From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

・To fulfill or meet the reason for which the information is provided. For example, if you provide us with personal information in order for us to respond to requests for information or to process warranty claims or to fulfill orders for our products.

・To provide you with information, products or services that you request from us.

・To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.

・To improve our website and present its contents to you.

・For testing, research, analysis and product development.

・As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

・To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

・As described to you when collecting your personal information or as otherwise set forth in the CCPA.

・To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.
When we disclose personal information for a business purpose, we enter an agreement that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

・Identifiers.

・California Customer Records personal information categories.

・Protected classification characteristics under California or federal law.

We disclose your personal information for a business purpose to the following categories of third parties:

・Our affiliates.

・Service providers.

・Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

*In the preceding twelve (12) months, we have not sold any personal information.
Moreover, we do not sell personal information.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

・The categories of personal information we collected about you.

・The categories of sources for the personal information we collected about you.

・Our business or commercial purpose for collecting that personal information.

・The categories of third parties with whom we share that personal information.

・The specific pieces of personal information we collected about you (also known as a “data portability request”).

・If we disclosed your personal information for a business purpose, a separate list disclosing:

・disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).

6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

・To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at ccpa@shimano.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

・Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

・Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

・Deny you goods or services.

・Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

・Provide you a different level or quality of goods or services.

・Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Statement for California Residents

We reserve the right to amend this Privacy Statement for California Residents at our discretion and at any time.
When we make changes to this Privacy Statement for California Residents, we will notify you.

Contact Information

If you have any questions or comments about Shimano North America Holding, Inc.’s Privacy Statement for California Residents, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at ccpa@shimano.com.