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GLOBERIDE DATA PROTECTION COMPLIANCE PROJECT:
UK/EEA Addendum to the GLOBERIDE Personal Information Protection Policy
1. Introduction
This Addendum explains how GLOBERIDE, Inc. and its group companies (hereinafter referred to as “GLOBERIDE”) processes personal data relating to customers and business partners (hereinafter referred to as “Customers”, “You” or “Your”) located in the United Kingdom (“UK”) and/or the European Economic Area (“EEA”). If You are located in the UK or the EEA, then Your personal data will be processed in accordance with (for UK Customers) the UK Data Protection Act 2018 and the UK GDPR, or (for EEA Customers) the EU General Data Protection Regulation 2016/679 (“GDPR”) and related national data protection laws, as well as any other applicable data protection and privacy laws (together, “Data Protection Laws”).

Please note, the Data Protection Laws of the UK are similar in most material respects to those of the EEA, individuals in both jurisdictions have similar rights, and in certain cases the Data Protection Laws of both the UK and the EEA apply to the same processing by GLOBERIDE.

This Addendum should be read in conjunction with the GLOBERIDE Personal Information Protection Policy, which describes the categories of personal data processed by GLOBERIDE, how those data are collected, the implications if You refuse to provide personal data, if and when personal data will be shared with third parties, as well as how personal data are managed and kept secure. Terms defined in the GLOBERIDE Personal Information Protection Policy shall have the same meaning when used in this Addendum, except where expressly stated otherwise.
2. Scope of this Addendum
This Addendum sets out how GLOBERIDE will process personal data relating to Customers who are either located in the UK and/or the EEA or whose personal data is otherwise protected under the Data Protection Laws of those jurisdictions (herein, “UK/EEA Customers”). It also sets out how UK/EEA Customers may exercise their rights under Data Protection Laws. In the event that there is any inconsistency between the GLOBERIDE Personal Information Protection Policy and this Addendum, this Addendum shall prevail in respect of UK/EEA Customers.

Please note that any personal data related processing activities undertaken by GLOBERIDE (including its group companies in the UK/EEA) which do not fall within the scope of this Addendum, will be subject to the provisions of separately published privacy notices.
3. Controller details
The controller (which makes decisions about how and why Your personal data are used) in respect of Your personal data is GLOBERIDE Inc. Other companies in the GLOBERIDE group may make decisions about Your personal data as independent or joint controllers in respect of certain specific activities, as described in Section 2 of this Addendum.

You can contact GLOBERIDE's Data Protection Officer with any questions or concerns You have about Your personal data by emailing: dpo@globeride.co.jp.
4. Legal basis for the handling (processing) of Your personal data
Data Protection Laws require GLOBERIDE to have a valid ‘legal basis’ under Data Protection Laws in order to process personal data. The table below sets out the purposes we will process Your personal data for and the relevant legal basis which applies. Each legal basis is described in more detail below:
Purpose Type of Information Lawful basis
The sale and supply of GLOBERIDE products, services, and related goods. Personal information, contact information, and payment information; Membership information. Either:
  1. (in the case of contracts with individual Customers) the processing is necessary to enter into or perform a contract with You; or
  2. (in all other cases) the processing is necessary for GLOBERIDE’S legitimate interests purposes (to conclude contracts with You or with another customer or supplier).
Review and analysis of the purchase and usage status of GLOBERIDE products, services, and related goods. Personal information, contact information; IT and system information. The processing is necessary for GLOBERIDE’S legitimate interests purposes (to manage, develop and improve our business and the products, services and related goods we offer).
Conducting surveys of GLOBERIDE products, services, and related goods. Personal information, contact information; Content of inquiries and opinions; IT and system information. The processing is necessary for GLOBERIDE’S legitimate interests purposes (to manage, develop and improve our business and the products, services and related goods we offer).
Development of new products, services, and related goods. Membership and service usage information; IT and system information. The processing is necessary for GLOBERIDE’S legitimate interests purposes (to manage, develop and improve our business and the products, services and related goods we offer).
To contact You regarding GLOBERIDE products, services, and related goods (excluding direct marketing). Personal information, contact information; Membership and service usage information; Content of inquiries and opinions. The processing is necessary for legitimate interests purposes (to provide the best possible experience for You and to ensure that You have all the information necessary to make full use of our products, services, and related goods).
Planning and management of various activities handled by GLOBERIDE and its external subcontractors or partner companies (such as events and campaigns). Personal information, contact information; IT and system information. The processing is necessary for legitimate interests purposes (to manage, develop and promote our business and that of our subcontractors and partner companies).
Providing information regarding the services, products, events, and campaigns handled by GLOBERIDE and GLOBERIDE’s external subcontractors or partner companies, through various methods, including direct mail, email newsletters, notifications, and advertisements. Personal information, contact information; IT and system information. Either:
  1. You have consented to receive the relevant information; or
  2. the processing is necessary for legitimate interests purposes (to manage, develop and promote our business and that of our subcontractors and partner companies, and to offer products, services, and related goods which may be of interest). Note that legitimate interests will only be relied on if consent is not specifically required by Data Protection Laws, including e-privacy rules regarding cookies and direct marketing.
The analysis of personal information or technical information (such as the usage of products and services) browsing history of websites and mobile apps planned and operated by GLOBERIDE) to estimate a Customer's hobbies, preferences, purchasing tendencies and other attributes in order to deliver more relevant advertising. Personal information, contact information; IT and system information. Either:
  1. You have consented to the processing; or
  2. the processing is necessary for legitimate interests purposes (to manage, develop and promote our business and that of our subcontractors and partner companies, and to offer products, services, and related goods which may be of interest). Note that legitimate interests will only be relied on if consent is not specifically required by Data Protection Laws, including e-privacy rules regarding cookies and direct marketing.
Responding to inquiries and requests. Personal information, contact information; Content of inquiries and opinions. The processing is necessary for legitimate interests purposes (to communicate with, respond to and resolve inquiries and requests).
Sharing information within the GLOBERIDE group, as well as with subcontractors and business partners (as set out in Section 8 "Joint Use" of the GLOBERIDE Personal Information Protection Policy). Any of the above. The processing is necessary for legitimate interests purposes (to manage, develop and improve our business and the products, services and related goods which we offer; to prevent fraud; in the context of a business reorganisation or group restructuring exercise).
Your personal data may also be processed by GLOBERIDE for other purposes and on other legal bases in respect of certain specific activities (such as aftersales support) as set out in Section 2 of this Addendum.

Performance of a contract: This means that GLOBERIDE will process Your personal data to the extent necessary to enter into or perform a contract with You. This includes the processing of payment, billing and delivery information. This will only apply where GLOBERIDE is contracting with an individual.

Legitimate Interests: This means that GLOBERIDE (or a third party, such as a subcontractor or business partner) has a legitimate interest in processing Your personal data for a specific purpose and that the interest is not outweighed by Your own rights and interests. For example, aggregating and analysing anonymised usage information to improve GLOBERIDE products or services, or using Your email address to notify You about an important product safety announcement.

Legal obligation: GLOBERIDE can process Your personal data to the extent necessary to comply with a legal obligation. For example, sharing information with tax authorities or law enforcement.

Consent: GLOBERIDE will use personal information to the extent that an individual has provided their specific and informed consent to that use. Consent is only valid if freely given and it can be withdrawn at any time. This would be the case, for example, if a Customer has opted-in to receive marketing.

Additional rules apply when processing sensitive personal data (also known as ‘special category data’), such as information about a person’s race, creed, medical history, or when processing information about criminal records. GLOBERIDE will not generally process sensitive personal data about You and, in the unlikely event that it does, we will ask for Your explicit consent and/or provide You with additional information explaining how and why such information is processed.
5. International transfers
GLOBERIDE Inc., is located in Japan, which has been recognised by the European Commission and the UK as providing adequate protection for personal data. However, your personal data may be shared with GLOBERIDE companies and service providers in other jurisdictions and Your data may be stored in secure data centers which are located outside of the UK or EEA.

You should be aware that jurisdictions outside of the EEA and UK do not necessarily provide equivalent protection for Your personal data. The methods we use to protect Your personal data transferred to other jurisdictions are usually one or more of the following:
  • ensuring the recipient is in a country which has been approved in accordance with Data Protection Laws as providing adequate protection for personal data. Where GLOBERIDE, Inc. is making the transfer from Japan, we will also ensure compliance with the onward transfer requirements of the EU/UK-Japan Adequacy Decisions and related Japanese laws;
  • (if the recipient is based in the United States) ensuring the recipient is indicated on the Data Privacy Framework List as participating in the EU-US Data Privacy Framework (“EU-US DPF”) or (where applicable) the UK Extension to the EU-US DPF, and the transfer will be subject to the EU-US DPF Principles upon receipt by the recipient;
  • implementing appropriate safeguards such as requiring the recipient to enter into Standard Contractual Clauses or Standard Data Protection Clauses approved in accordance with Data Protection Laws; or
  • Data Protection Laws otherwise permit us to make the transfer.

If You would like more information regarding where Your personal data are stored and transferred, or the methods we use to protect Your personal data to adequate standards, then please contact us.
6. Retention of personal data
GLOBERIDE retains personal data for so long as is necessary for the purpose it was collected for or, where permitted, for a related compatible reason, provided always that there is a valid legal basis for GLOBERIDE to continue processing. As a result, the appropriate retention period will be determined by the nature of the information and the purpose for having it, as well as by applicable legal and accounting requirements and GLOBERIDE’S legitimate business needs. For detailed information about retention periods, please contact us.
7. Your rights under Data Protection Laws
You have the following legal rights in relation to Your personal data.
  • Access to Your personal data: You have the right to ask for details of the personal data which GLOBERIDE holds and for a copy of that information. Please note that there are limitations on this right and GLOBERIDE may not be able to provide You with all of Your personal data.
  • Correction of Your personal data: You have the right at any time to ask GLOBERIDE to correct Your personal data if it is not accurate or if it is incomplete.
  • Deletion of Your personal data: Please note that this is not an absolute right and there are a number of situations when we will not be able to delete Your personal data.
  • Restriction on the use of Your personal data: In some circumstances, You may ask GLOBERIDE to restrict how Your personal data are used, in which case your personal data will continue to be stored but will only be used for limited purposes (such as legal claims).
  • Data portability of Your personal data: In some circumstances, You may ask GLOBERIDE to transfer Your personal data to another organisation or to You in a format commonly used for storing and accessing such data. This only applies if You have provided GLOBERIDE with Your personal data and the legal basis for GLOBERIDE's use of Your personal data is either Your consent or that the information is necessary for the performance of a contract.
  • Withdrawal of consent: If You have consented to GLOBERIDE's legal basis for using Your personal data, You have the right to withdraw Your consent at any time, in which case GLOBERIDE will cease using Your personal data.
  • Object to GLOBERIDE using Your personal data: You may object to GLOBERIDE using Your personal data either:
    1. on the basis of legitimate interests, in which case GLOBERIDE will only continue to process Your information if there is a compelling reason which override any risk to You;
    2. for direct marketing purposes, in which case GLOBERIDE will cease using Your personal data for this purpose; or
    3. in connection with automated decision making or profiling. Please note that GLOBERIDE does not process personal data in a way that constitutes automated decision-making.
8. Submitting and responding to requests
The process for exercising the data subject rights set out in Section 7 above is as follows:
Response time
GLOBERIDE aims to respond to requests for personal data within one month. In some cases (for example, if Your request is complex or You have made a large number of requests), it may take longer than one month to respond. Please also note that there are exceptions to Your rights and some circumstances in which they do not apply.

Additional information about You
GLOBERIDE may need to ask You for additional information in order to verify Your identity. This is a security measure to ensure that personal data is not provided to persons who do not have the right to receive it. We may also contact You to clarify Your request.

Fees
You generally do not need to pay to access Your personal data or to exercise any of Your other rights. However, if GLOBERIDE determines that a request is unreasonable then it may charge a reasonable fee for responding. For example, if You make multiple requests or request an multiple copies of information.

Please note that if a request is manifestly unfounded or vexatious (for example, it is clear the request is made to harass or disrupt GLOBERIDE), then we will refuse to comply with it.
9. How to make a complaint
If You believe that GLOBERIDE has mishandled Your personal data or has not complied with its legal obligations then You have the right to complain to Your country’s data protection regulator or supervisory authority, or else to seek a judicial remedy. However, in the first instance we would appreciate it if You could contact GLOBERIDE and the Data Protection Officer (“DPO”) so that we can try and resolve the issue directly.

For reference, the UK’s supervisory authority is the Information Commissioner’s Office, details of which can be found at ico.org.uk. Details of supervisory authorities for EEA jurisdictions can be found at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

If You have a complaint, concern or question regarding Your personal data please contact GLOBERIDE’s DPO by emailing: dpo@globeride.co.jp.
This Addendum was last updated on 1 October 2025.
Daiwa Germany
German Law Supplementary Information
Section 4: Legal basis for the handling (processing) of Your personal data
Legal basis for the handling (processing) of Your personal data
Data Protection Laws require GLOBERIDE to have a valid ‘legal basis’ under Data Protection Laws in order to process personal data. The table below sets out the purposes we will process Your personal data for and the relevant legal basis which applies. Each legal basis is described in more detail below:
Purpose Type of Information Lawful basis
The sale and supply of GLOBERIDE products, services, and related goods. Personal information, contact information, and payment information; Membership information. Either:
  1. (in the case of contracts with individual Customers) the processing is necessary to enter into or perform a contract with You; or
  2. (in all other cases) the processing is necessary for GLOBERIDE’S legitimate interests purposes (to notify you of material matters such as changes to our privacy policy).
Review and analysis of the purchase and usage status of GLOBERIDE products, services, and related goods. Personal information, contact information; IT and system information. The processing is necessary for GLOBERIDE’S legitimate interests purposes (to manage, develop and improve our business and the products, services and related goods we offer).
Conducting surveys of GLOBERIDE products, services, and related goods. Personal information, contact information; Content of inquiries and opinions; IT and system information. The processing is necessary for GLOBERIDE’S analytical purposes (to manage, develop and improve our business and the products, services and related goods we offer) and your personal data will be processed on your given consent.
Development of new products, services, and related goods. Membership and service usage information; IT and system information. The processing is necessary for GLOBERIDE’S legitimate interests purposes (to manage, develop and improve our business and the products, services and related goods we offer).
To contact You regarding GLOBERIDE products, services, and related goods (excluding direct marketing). Personal information, contact information; Membership and service usage information; Content of inquiries and opinions. The processing is necessary for legitimate interests purposes (to provide the best possible experience for You and to ensure that You have all the information necessary to make full use of our products, services, and related goods that are similar to your purchased items and services).
Planning and management of various activities handled by GLOBERIDE and its external subcontractors or partner companies (such as events and campaigns). Personal information, contact information; IT and system information. If we run an event, we collect personal data in connection with your attendance at this event to fulfill our contract with you (e.g., communication before and after the event (logistics, changes etc.)). Moreover, the processing is also necessary for legitimate interests purposes (to manage, develop and promote such events/campaigns and our business and that of our subcontractors and partner companies). In all other cases of invitations or usage of your personal data for campaigns we will process such data only with your given consent.
Providing information regarding the services, products, events, and campaigns handled by GLOBERIDE and GLOBERIDE’s external subcontractors or partner companies, through various methods, including direct mail, email newsletters, notifications, and advertisements. Personal information, contact information; IT and system information. Either:
  1. You have consented to receive the relevant information; or
  2. the processing is necessary for legitimate interests purposes (to manage, develop and promote our business and that of our subcontractors and partner companies, and to offer products, services, and related goods which may be of interest). Note that legitimate interests will only be relied on if consent is not specifically required by Data Protection Laws, including e-privacy rules regarding cookies and direct marketing.
The analysis of personal information or technical information (such as the usage of products and services) browsing history of websites and mobile apps planned and operated by GLOBERIDE) to estimate a Customer's hobbies, preferences, purchasing tendencies and other attributes in order to deliver more relevant advertising. Personal information, contact information; IT and system information. Either:
  1. You have consented to the processing; or
  2. the processing is necessary for legitimate interests purposes (to manage, develop and promote our business and that of our subcontractors and partner companies, and to offer products, services, and related goods which may be of interest). Note that legitimate interests will only be relied on if consent is not specifically required by Data Protection Laws, including e-privacy rules regarding cookies and direct marketing.
Responding to inquiries and requests. Personal information, contact information; Content of inquiries and opinions. The processing is necessary to fulfil our contractual obligations towards you (to communicate with, respond to and resolve inquiries and requests) or, if necessary, for legitimate interests purposes (to respond to requests that are unrelated to any contract with you).
Sharing information within the GLOBERIDE group, as well as with subcontractors and business partners (as set out in Section 8 "Joint Use" of the GLOBERIDE Personal Information Protection Policy). Any of the above. The processing is necessary for legitimate interests purposes (to manage, develop and improve our business and the products, services and related goods which we offer; operational support; in the context of a business reorganisation or group restructuring exercise).
Security and protection of rights. Any of the above. We also need to process your personal data for security purposes and therefore for our legitimate interests, in particular, to prevent, detect, and investigate fraud and other unauthorised activities and access, and where necessary to protect ourselves, our business and third parties.
Operate and improve our Website and our business. Personal information, contact information; IT and system information. To display our Website and its fonts and technical maintain the Website, the processing is necessary for our legitimate interests purpose to provide you with a properly functioning website. We also process your personal data for other research and analytical purposes, such as to evaluate and improve our business operations, to develop services and features, and for internal qual-ity control and training purposes, based on your given consent.
Compliance with law and legal process Any of the above. The processing is required to comply with the law and our legal and regulatory obligations, to respond to legal process and in relation to legal proceedings.
Your personal data may also be processed by GLOBERIDE for other purposes and on other legal bases in respect of certain specific activities (such as aftersales support) as set out in Section 2 of this Addendum.

Consent: GLOBERIDE will use personal information to the extent that an individual has provided their specific and informed consent to that use. Consent is only valid if freely given and it can be withdrawn at any time. This would be the case, for example, if a Customer has opted-in to receive marketing.

Performance of a contract: This means that GLOBERIDE will process Your personal data to the extent necessary to enter into or perform a contract with You. This includes the processing of payment, billing and delivery information. This will only apply where GLOBERIDE is contracting with an individual.

Legal obligation: GLOBERIDE can process Your personal data to the extent necessary to comply with a legal obligation. For example, sharing information with tax authorities or law enforcement.

Legitimate Interests: This means that GLOBERIDE (or a third party, such as a subcontractor or business partner) has a legitimate interest in processing Your personal data for a specific purpose and that the interest is not outweighed by Your own rights and interests. For example, aggregating and analysing anonymised usage information to improve GLOBERIDE products or services, or using Your email address to notify You about an important product safety announcement.

Additional rules apply when processing sensitive personal data (also known as ‘special category data’), such as information about a person’s race, creed, medical history, or when processing information about criminal records. GLOBERIDE will not generally process sensitive personal data about You and, in the unlikely event that it does, we will ask for Your explicit consent and/or provide You with additional information explaining how and why such information is processed.

Cookies and Personalisation

When visiting our Website, cookies and similar technologies are used. Cookies are small files that your browser automatically creates and that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our site and agree to the cookies according to our cookie banner, or if they are technically necessary cookies. A cookie stores information that is specific to the particular device being used. However, this does not mean that we thereby obtain knowledge of your identity. Essential cookies are required for the basic functionality of the Website. They contain only technically necessary services. We process such data on the basis of our legitimate interest to display our Website to you.
Any use of cookies that is not absolutely necessary for technical reasons constitutes data processing which is only permitted with your express and active consent. In addition, we will only pass on your personal data processed by cookies that are set by third parties to such third parties if you have given your express consent.
Section 5: International Transfers
GLOBERIDE Inc., is located in Japan, which has been recognised by the European Commission and the UK as providing adequate protection for personal data. However, your personal data may be shared with GLOBERIDE companies and service providers in other jurisdictions and Your data may be stored in secure data centers which are located outside of the UK or EEA.

You should be aware that jurisdictions outside of the EEA do not necessarily provide equivalent protection for Your personal data. If we transfer personal data outside the EU and EEA we will ensure that your privacy rights are adequately protected by appropriate safeguards. The methods we use to protect Your personal data transferred to other jurisdictions are usually one or more of the following:
  • ensuring the recipient is in a country which has been approved in accordance with Data Protection Laws as providing adequate protection for personal data. Where GLOBERIDE, Inc. is making the transfer from Japan, we will also ensure compliance with the onward transfer requirements of the EU/UK-Japan Adequacy Decisions and related Japanese laws;
  • (if the recipient is based in the United States) ensuring the recipient is indicated on the Data Privacy Framework List as participating in the EU-US Data Privacy Framework (“EU-US DPF”) or (where applicable) the UK Extension to the EU-US DPF, and the transfer will be subject to the EU-US DPF Principles upon receipt by the recipient;
  • implementing appropriate safeguards such as requiring the recipient to enter into Standard Contractual Clauses or Standard Data Protection Clauses approved in accordance with Data Protection Laws; or
  • Data Protection Laws otherwise permit us to make the transfer.
If You would like more information regarding where Your personal data are stored and transferred, or the methods we use to protect Your personal data to adequate standards, then please contact us.
Section 7 Your rights under Data Protection Law
  • Object to GLOBERIDE using Your personal data: You may object to GLOBERIDE using Your personal data either:
  1. on the basis of legitimate interests or the performance of a task in the public interest or exercise of official authority, in which case GLOBERIDE will only continue to process Your information if GLOBERIDE can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is necessary for the enforcement, exercise, or defense of legal claims;
  2. for direct marketing purposes, in which case GLOBERIDE will cease using Your personal data for this purpose; or
  3. in connection with automated decision making or profiling. Please note that GLOBERIDE does not process personal data in a way that constitutes automated decision-making.
10. How to make a complaint
If You believe that GLOBERIDE has mishandled Your personal data or has not complied with its legal obligations then You have the right to complain to Your country’s data protection regulator or supervisory authority, or else to seek a judicial remedy. Details of supervisory authorities for EEA jurisdictions can be found at https://www.edpb.europa.eu/about-edpb/about-edpb/members_en.

However, in the first instance we would appreciate it if You could contact GLOBERIDE and the Data Protection Officer (“DPO”) so that we can try and resolve the issue directly.
If You have a complaint, concern or question regarding Your personal data please contact GLOBERIDE’s DPO by emailing: dpo@globeride.co.jp.
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