GLOBERIDE DATA PROTECTION COMPLIANCE PROJECT

GLOBERIDE DATA PROTECTION COMPLIANCE PROJECT:
APAC 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 Asia-Pacific region, including Australia, China, Hong Kong, Malaysia, Republic of Korea, Singapore, Taiwan, Thailand, and Vietnam (“APAC”). If You are located in the APAC, then Your personal data will be processed in accordance with the applicable laws based on Your involvement with a local office of GLOBERIDE including:

Australia’s Privacy Act for Customers in Australia;
China’s Personal Information Protection Law for Customers in China;
Hong Kong’s Personal Data Privacy Ordinance for Customers in Hong Kong;
Malaysia’s Personal Data Protection Act for Customers in Malaysia;
Republic of Korea’s Personal Information Protection Act for Customers in the Republic of Korea;
Singapore’s Personal Data Protection Act for Customers in Singapore;
Taiwan’s Personal Data Protection Act for Customers in Taiwan;
Thailand’s Personal Data Protection Act for Customers in Thailand; and
Vietnam’s Personal Data Protection Law for Customers in Vietnam,

and other 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 are similar in most material respects across APAC, individuals in all jurisdictions have similar rights, and in certain cases the Data Protection Laws apply to the same processing activities 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 APAC or whose personal data is otherwise protected under the Data Protection Laws of those jurisdictions (herein, “APAC Customers”). It also sets out how APAC 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 APAC Customers.

Please note that any personal data related processing activities undertaken by GLOBERIDE (including its group companies in the APAC) 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. The lawful bases outlined therein are designated based on general data protection law principles, but there may be certain differences in application. Please see country-specific Supplementary Information for more details. 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: (in the case of contracts with individual Customers) the processing is necessary to enter into or perform a contract with You; or (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: You have consented to receive the relevant information; or 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: You have consented to the processing; or 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 many data protection authorities in the APAC region as well as by the European Commission and the UK, which are the two main guiding authorities in the world, 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 APAC.
You should be aware that jurisdictions outside of the APAC 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. The rights outlined below are designated based on general data protection law principles, but there may be certain differences in application. Please see country-specific Supplementary Information for more details.

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:
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 or less depending on the law of each APAC country. 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, details of supervisory authorities for APAC jurisdictions can be found at:

Australia: https://www.oaic.gov.au/
China: https://www.cac.gov.cn/
Hong Kong: https://www.pcpd.org.hk/
Malaysia: https://www.pdp.gov.my/ppdpv1/en/main-page/
Republic of Korea: https://www.pipc.go.kr/eng/index.do
Singapore: https://www.pdpc.gov.sg/
Taiwan: https://www.pdpc.gov.tw/en/
Thailand: https://www.pdpc.or.th/
Vietnam: https://en.bocongan.gov.vn/

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 10 November 2025.

Daiwa Korea

Korean Law Supplementary Information

1. Introduction

This Korean Law Supplementary Information (“Supplement”) explains how Daiwa Korea (“Daiwa Korea”), its parent entity, GLOBERIDE, Inc. and its, and their, related group companies (collectively, “GLOBERIDE”, “we” or “us”) handle personal information relating to Customers located in Korea. If You are located in Korea, then Your personal information (as defined below) will be collected, used, disclosed and stored in accordance with Korean Data Protection Laws (as defined below).

This Supplement should be read in conjunction with the GLOBERIDE Personal Information Protection Policy and the Addendum, which describe the categories of personal information processed by GLOBERIDE, how that information is collected, the implications if You refuse to provide personal information, if and when personal information will be shared with third parties, as well as how personal information is managed and kept secure. Terms defined in the GLOBERIDE Personal Information Protection Policy and the Addendum will have the same meaning when used in this Supplement, except as expressly set out in this Supplement.

Please read this document carefully to understand how we collect, use, disclose, store, handle and protect Your personal information. We hope that this will help You make an informed decision about sharing personal information with us.

2. Scope of this Supplement

This Supplement sets out how GLOBERIDE, including Daiwa Korea, will handle personal information relating to Customers who are either located in Korea or whose personal information is otherwise protected under Korean Data Protection Laws (“Korean Customers”). It also sets out how Korean Customers may exercise their rights under Korean Data Protection Laws. In the event that there is any inconsistency or conflict between the GLOBERIDE Personal Information Protection Policy, the Addendum and this Supplement, this Supplement will prevail in respect of Korean Customers.

Please note that any personal information handling activities undertaken by GLOBERIDE (including Daiwa Korea) which do not fall within the scope of this Supplement, will be set out in separately published privacy notices.

3. Definitions

“Korean Data Protection Laws”, means the Personal Information Protection Act (PIPA), the Act on Promotion of IT Network Use and Information Protection (“Network Act”), as each may be amended, superseded or replaced from time to time, together with all statutory guidelines, codes and information guides issued by the privacy regulator from time to time.

“personal information”, is statutorily defined under PIPA as information pertaining to a living individual which contains information identifying a specific person with a name, address, or similar in a form of an image, etc. (including information that does not, by itself, make it possible to identify a specific person, but that enables to identify such a person easily when combined with other information).

"sensitive information", under the PIPA refers to personal information concerning ideology, faith, labor union membership, political views or membership in a political party, health information or medical treatment, sex life, genetic information, criminal records (e.g., sentencing, exemptions, suspended sentences, protective custody, probation, etc.), information that concerns an individual's physical, physiological and behavioral characteristics, which has been generated through technical means for the purpose of identifying a particular individual, and information that concerns race or ethnicity.

4. Daiwa Korea Details

The entity that handles (including collects, uses, discloses and stores Your personal information) is Daiwa Korea and its related GLOBERIDE group companies. For Korean Customer data, the data controller is Daiwa Korea. Other companies in the GLOBERIDE group may also handle Your personal information, including in respect of certain specific activities as further described in the GLOBERIDE Personal Information Protection Policy and the Addendum.

5. Collection and Use of Personal Information

The personal information of Korean Customers is collected and used based on the customer's consent.
We do not collect any personal information from any minor who we know to be under the age of 14, except where we have the explicit consent of their parent or guardian in accordance with Korean Data Protection Laws.

6. Disclosure and Provision to Third Parties

Third Party Provision: As explained in the GLOBERIDE Personal Information Protection Policy 7. Disclosure and Provision to Third Parties, we share Your personal information, with Your consent, with GLOBERIDE, Inc. and its group companies (“GLOBERIDE Group Companies”) (for a list of affiliates of the Company, please visit : https://www.daiwa.com/kr/brand/network).
Delegation: As explained in the GLOBERIDE Personal Information Protection Policy 7. Disclosure and Provision to Third Parties, we delegate the processing of personal information to GLOBERIDE Group Companies and service providers for management and internal administration purposes.

International Transfer: As explained above regarding third-party provision and delegation, Your personal information may be transferred from time to time via telecommunications networks to the countries where GLOBERIDE Group Companies are located, including Japan, Germany, the United Kingdom, and the Asia Pacific region (for a list of office locations, please visit: https://www.globeride.co.jp/about/#office). Such overseas transfers will take place either with Your consent or when processing or storage of personal information is necessary for the conclusion or performance of a contract.

If You do not agree to the international transfer of Your personal information as described above, You may refuse the overseas transfer by emailing: dpo@globeride.co.jp. However, please note that refusing the international transfer of personal data will prevent You from using the services.

7. Disposal of Your Personal Information

When personal information is no longer necessary due to the expiration of the retention period or the attainment of the purpose of processing, among others, personal information is destroyed based on the following procedure and method:

Destruction procedure: We select the personal information which is required to be destroyed and destroy it following the approval of the Data Protection Officer.
Method of destruction: We destroy personal information recorded and stored in the form of electronic files in a way that it cannot be re-generated, and personal information recorded and stored in the form of paper by shredding using shredding machines or by incineration.

8. Measures to Secure Safety of Personal Information

We have put in place the following measures in order to secure the safety of personal information:

Administrative measures: Establishment and execution of an internal plan for management, regular staff training, etc.
Technical measures: Management of access authority to the personal information management system, installation of the access control system, encryption, and installation of security programs.
Physical measures: Restriction of access to the computer room, the data storage room, etc.

9. Your Rights under the PIPA

In accordance with the PIPA, You, as a data subject, have the following rights (which may be amended pursuant to any regulations of the Korean Data Protection Law) which are exercisable in compliance with applicable laws:

Right to request for disclosure;
Right to request for correction and deletion; and
Right to request for cessation of management and withdrawal of consent.

Any of the rights set forth may be exercised through agents such as a legal representative or a delegated person of the data subject, in which case the power of attorney should be submitted in accordance with the Appendix Form No. 11 of the Notice on Personal Information Processing Methods.

10. Questions or Complaints

If You have any questions, concerns or complaints about our collection, use, disclosure or management of Your personal information, please contact GLOBERIDE’s DPO by emailing: dpo@globeride.co.jp.

GLOBERIDE will make all reasonable inquiries, and Your complaint will be assessed with the aim of resolving any issue in a timely and efficient manner.

If You believe Your rights have been infringed, You may contact the following government agencies:

Personal Information Dispute Mediation Committee (www.kopico.go.kr / 1833-6972)
Personal Information Infringement Report Center (privacy.kisa.or.kr / 118)
Supreme Prosecutors’ Office (www.spo.go.kr / 1301)
Korean National Police Agency Cyber Bureau (ecrm.cyber.go.kr / 182).

11. Changes to the Privacy Policy, Addendum and Supplement

This Supplement shall take effect as of 10 November 2025.

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