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.
Notice on the information obtained from the Internet site concerning Non-European residents
2. Information Collected
Information Collected Automatically
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.
4. Sharing of Collected Information
Shimano may share your Personal Information as follows:
(1) Joint Users of Personal Information
(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
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
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.
(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)
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.
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:
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.
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
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
14. Third Party Advertising
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
Contact Information for Questions or Complaints
Please refer to contact information of Shimano and the respective Group Companies posted on our Sites.
*The following Sites included but are not limited to and may be updated without notice:https://www.shimano.com,
Notice on the (personal) data obtained from the Internet site concerning European residents
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. 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:
2. Purposes for which your personal data may be processed
We may process your personal data obtained through the Sites for the following purposes:
3. Types of personal data we process
We may collect your personal data in the following manner(s):
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.
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:
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.
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:
9. Security of personal data
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.
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. We also recommend not to re-use passwords on other websites.
10. Transfer of personal data
11. Links to websites of others
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
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: firstname.lastname@example.org.
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.
16. Contact information for questions or complaints
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: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number or state identification card number, passport number, or other similar identifiers.
- Internet or other similar network activity: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
- Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Professional Data: Current or past job history or performance evaluations.
- Educational Data: Educational background, grades, scores.
- Other Data: Financial information, medical information, health insurance information.
- Inferences: Profiles drawn from other Personal Information reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
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.
- 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.
Personal Information from Vendors and Business Partners
We collect Personal Information from representatives of our vendors and business partners in the course of our business when the representative or the company they work for is a customer or vendor of Company. We collect this information from:
- Their employer in connection with the work they do for their employer and how that relates to the Services.
- Third parties Company works with, such as business partners, and through introductions from other individuals or companies.
When you or the company you work for interacts with Company (for example, when providing technical services to us), we collect the following types of Personal Information:
- Contact information: such as your email address, phone number and any other information you provide relating to your work or to you personally (for example, your name, job title or other information in your email signature).
- Financial Information, which can include credit reports and tax returns.
- Information relating to our dealings with you or the company you work for: such as information used to administer your company account, verify financial transactions, details of goods or services that Company has exchanged with you, and information that you give us or we otherwise obtain when you interact with Company.
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 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 may use information collected about prospective employees to respond to and process your job application and to make inquiries about you for credit and reference purposes.
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:
- 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 or shared any Personal Information to facilitate advertising goods or serves by others.
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. Subject to certain exceptions, you have the following rights with respect to your Personal Information:
- To request that Company disclose what Personal Information it has collected, used, or disclosed, over the 12-month period preceding Company's receipt of such a request;
- To request that Company disclose whether any of your information was sold or shared with third parties, to whom such information was sold or shared, and the business purpose for selling or sharing the information;
- To request that any inaccurate or incomplete Personal Information maintained by Company be corrected or supplemented; and
- To request deletion of your Personal Information maintained by Company.
All of these rights are subject to certain conditions and exemptions. For example, Company will not be obligated to delete your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.
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:
- 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.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- 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.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- 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 by:
- Emailing the verifiable consumer request to email@example.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. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
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.
You may designate an authorized agent to exercise a CCPA right on your behalf. If you use an authorized agent to exercise your rights under the CCPA, we will need the following proof that you have authorized the agent to act on your behalf:
- Written proof that you have authorized the agent to act on your behalf, and separately verify your identity as described above; or
- Proof that the authorized agent holds a power of attorney to act on your behalf pursuant to California Probate Code §§ 4000-4465.
If you have any questions or comments about our Privacy Statement, 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:
Last Updated: January 1, 2023