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.
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.
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.
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:
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.
| 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:
|
| 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:
|
| 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:
|
| 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). |
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:
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.
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: In some circumstances, You can ask GLOBERIDE to delete 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:
- 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;
- for direct marketing purposes, in which case GLOBERIDE will cease using Your personal data for this purpose; or
- 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 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.
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 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.
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 France
French Law Supplementary Information
SECTION 4: LEGAL BASIS FOR THE HANDLING (PROCESSING) OF YOUR PERSONAL DATA
- Local specificity in terms of direct marketing and protection of personal data
- Direct marketing by electronic means (e-mail, SMS) to natural persons is generally prohibited, unless the recipient has given his or her prior, free, specific and informed consent ("opt-in"). In this case, the appropriate legal basis is consent.
- Consent is not required if the recipient is already a customer and the direct marketing relates to similar products or services provided by the same company, provided that the recipient has a clear and easy way to object ("opt-out") to these marketing messages at the time their contact details are collected and to each subsequent message. In this case, the appropriate legal basis is the legitimate interest of GLOBERIDE.
- Local specificity in terms of cookies
If GLOBERIDE uses cookies or similar tracking technologies on its websites (or applications), French law requires (i) that the explicit consent of users to deposit "non-essential" cookies (e.g. marketing cookies, analytics cookies, audience measurement cookies, etc.) be obtained and (ii) that users must have the possibility to refuse cookies as easily as to accept them (French Data Protection Act, Art. 82; CNIL guidelines on cookies).
SECTION 7: YOUR RIGHTS UNDER DATA PROTECTION LAWS
In French law:
Last updated: 1 October 2025
- You also have a "post-mortem" right, i.e. the right to give instructions to GLOBERIDE concerning the retention, deletion and communication of Your personal data after Your death (French Data Protection Act, art. 85).
- You also have a specific right to object to telemarketing (commercial phone calls) by subscribing to the "Bloctel list" (Consumer Code, Art. L.223-1 to L.223-3).
Last updated: 1 October 2025