5. Purposes and legal bases

5. Purposes and legal bases

·                   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.

·                   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.

We further aggregate user data collected in our database in order to provide data analysis services (e.g. regarding bike model usage (for example terrain information, battery use history, errors, etc.), gender ratio, average speed/distance/riding time, firmware status) to manufacturers of bikes, to bike brands and to bike dealers. In order to provide each party with the relevant aggregated data, as a first step, we match on our servers the serial number of Shimano components registered by users in the Apps with the serial numbers from our factory database. In a second step, by way of data aggregation, all Personal Data is anonymized by aggregation before it is included in the respective statistics so that it is not possible for the manufacturer or dealer to directly or indirectly identify you.

For this purpose, we rely on our legitimate interests to provide the added services to our cooperation partners and on the legitimate interests of our cooperation partners to be able to analyze model usage, see Art. 6 (1)(f) GDPR.

6. Recipients of Personal Data

6. Recipients of Personal Data

·                   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:

o   Amazon Web Services Inc., 410 Terry Avenue North, Seattle, WA 98109-5210, USA (cloud service provider acting as sub-processor) ("AWS"); and

o   SAP, Dietmar-Hopp-Allee 16, 69190 Walldorf, Germany (data processor; provider of customer relations and identity management services)

·                   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:

o   Amazon Web Services Inc., 410 Terry Avenue North, Seattle, WA 98109-5210, USA (cloud service provider acting as sub-processor) ("AWS"); and

o   SAP, Dietmar-Hopp-Allee 16, 69190 Walldorf, Germany (data processor; provider of customer relations and identity management services)

o   Sonix Co., Ltd., 7-9-5, Nishigotanda, Shinagawa-ku, Tokyo, 141-0031 Japan (data processor; development and maintenance provider)

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, 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.

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, Ecuador 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.

Attachment

Attachment

[…]

[…]
Ecuador
Águila Importaciones S.A.
Panamericana Norte y Luis H. Gordillo
Atuntaqui, 100214
(+593) 6 2530066 / +593 6 2530085
(+593) 997291777
aguilaimportaciones@gmail.com
URL: aguilaimportaciones.com/
[…]

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.

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
  - 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").

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
[…]