GLOBERIDE DATA PROTECTION COMPLIANCE PROJECT:
APAC Addendum to the GLOBERIDE Personal Information Protection Policy
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:
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.
- 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,
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.
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.
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:
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 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:
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 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:
- 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 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:
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 December 2025.
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 December 2025.
Daiwa Malaysia
Malaysian Law Supplementary Information
1. Introduction
This Malaysian Law Supplementary Information (“Supplement”) explains how Daiwa Sports (M) Sdn. Bhd. (201601004061 (1174987-X)) (“Daiwa Malaysia”), its parent entity, GLOBERIDE, Inc. and its, and their, related group companies (collectively, “GLOBERIDE”, “we” or “us”) handle personal information relating to Customers who are either located in Malaysia or whose personal data is otherwise protected by Malaysian Data Protection Laws. If You are not located in Malaysia but Your personal data is nevertheless protected by Malaysian Data Protection Laws, the provisions of the Policy (as defined below) and Addendum (as defined below) will apply to Your personal data by virtue of this Supplement notwithstanding provisions of the Policy and/or Addendum on their scope of applicability that may be to the contrary.
This Supplement should be read in conjunction with the GLOBERIDE Personal Information Protection Policy (“Policy”) and the APAC Addendum to the GLOBERIDE Personal Information Protection Policy (“Addendum”). Terms defined in the Policy and the Addendum will have the same meaning when used in this Supplement, except as otherwise expressly set out in this Supplement.
The provisions of the Policy and Addendum shall apply in respect of Customers located in Malaysia only to the extent not inconsistent with Malaysian Data Protection Laws. In the event that there is any inconsistency between the Policy, Addendum, and this Supplement, this Supplement shall prevail in respect of Customers located in Malaysia.
This Supplement should be read in conjunction with the GLOBERIDE Personal Information Protection Policy (“Policy”) and the APAC Addendum to the GLOBERIDE Personal Information Protection Policy (“Addendum”). Terms defined in the Policy and the Addendum will have the same meaning when used in this Supplement, except as otherwise expressly set out in this Supplement.
The provisions of the Policy and Addendum shall apply in respect of Customers located in Malaysia only to the extent not inconsistent with Malaysian Data Protection Laws. In the event that there is any inconsistency between the Policy, Addendum, and this Supplement, this Supplement shall prevail in respect of Customers located in Malaysia.
2. Data Controller
The entity that processes Your personal data is Daiwa Malaysia and/or its related GLOBERIDE group companies. Other companies in the GLOBERIDE group may also handle Your personal data, including in respect of certain specific activities as further described in the Policy and the Addendum.
You may contact GLOBERIDE to raise any question, concern, or complaint in respect of Your personal data, or exercise Your statutory rights over Your personal data (e.g. right to request access and request correction), through the following contact details:
You may contact GLOBERIDE to raise any question, concern, or complaint in respect of Your personal data, or exercise Your statutory rights over Your personal data (e.g. right to request access and request correction), through the following contact details:
3. Correction of Your Personal Data
In relation to Section 7 of the Addendum, You also have the right at any time to ask GLOBERIDE to correct Your personal data if it is misleading or not up-to-date.
4. Restriction on the Use of Your Personal Data
In relation to Section 7 of the Addendum, situations in which You may ask GLOBERIDE to restrict the processing of Your personal data include a situation where the processing of that personal data or the processing of personal data for any specific purpose or in any specific manner is causing or is likely to cause substantial damage or substantial distress to You or to another person, and the damage or distress is or would be unwarranted.
5. Cross-border Transfer of Personal Data
In the course of our business, and depending on the nature of Your relationship with us, it may be necessary for us to transfer Your personal data to locations outside Malaysia. This provision supplements the provisions of cross-border transfer of personal data found in the Policy and Addendum.
Where cross-border transfers of Your personal data out of Malaysia are necessary for purposes as set out in the Policy, Addendum, and this Supplement, you hereby consent to such transfers.
Such transfers may occur in various circumstances, including but not limited to the following:
The classes of third parties to whom Your personal data may be transferred outside Malaysia include, without limitation, our parent company, subsidiaries, group entities, affiliates, business partners, payment gateways, IT and cloud service providers, professional advisers, and other vendors or service providers engaged in connection with the purposes stated in the Policy, Addendum, and this Supplement.
The purposes of such transfers include, among others, membership administration, customer relationship management, transaction processing, product and service delivery, system maintenance, data analytics, customer support, and any other legitimate business purposes related to Your use of our products or services.
Where cross-border transfers of Your personal data out of Malaysia are necessary for purposes as set out in the Policy, Addendum, and this Supplement, you hereby consent to such transfers.
Such transfers may occur in various circumstances, including but not limited to the following:
- where our data storage, processing, or hosting facilities are located outside Malaysia;
- where our service providers are located outside Malaysia and they assist us in providing customer support, analytics, payment processing, marketing, IT services, or any other services; or
- where the transfer is otherwise required or permitted under applicable laws.
The classes of third parties to whom Your personal data may be transferred outside Malaysia include, without limitation, our parent company, subsidiaries, group entities, affiliates, business partners, payment gateways, IT and cloud service providers, professional advisers, and other vendors or service providers engaged in connection with the purposes stated in the Policy, Addendum, and this Supplement.
The purposes of such transfers include, among others, membership administration, customer relationship management, transaction processing, product and service delivery, system maintenance, data analytics, customer support, and any other legitimate business purposes related to Your use of our products or services.
6. Sources of Personal Data
Depending on the nature of Your relationship with us and the products or services You use or purchase, we may collect or otherwise obtain Your personal data from one or more of the following sources, without limitation:
- Directly From You – including but not limited to information provided through account registration, online or paper forms, service sign-ups, order forms, correspondence (such as emails, messages, or calls), surveys, participation in marketing activities, or in the course of Your use or purchase of our products or services.
- From Third Parties – including but not limited to affiliates within the GLOBERIDE group companies, business partners, resellers, payment processors, analytics or marketing service providers, social media platforms, and other service providers or vendors engaged by us in connection with our products or services. We may also collect personal data from publicly available sources, including official registries, public websites, and social or professional networking platforms.
7. Obligatory Supply of Data
Unless otherwise indicated by us, the personal data that we collect or obtain about You is generally mandatory for us to process in order to achieve the purposes as stated in the Policy, Addendum, and this Supplement (e.g. establish and manage Your membership or customer relationship with us, facilitate Your purchase and use of our products, services, and related goods, process Your payments and transactions, fulfil our legal duties and obligations, etc.). If you consider that certain information is not mandatory, please contact us for clarification before withholding such information.
8. Consequences of Not Providing Obligatory Data
Depending on the circumstances, if You do not provide us with the personal data we require, or if You request that we cease processing Your personal data, we may be unable to provide You with the products, services, or benefits You have requested, achieve any purposes stated in the Policy, Addendum, and/or this Supplement, or to otherwise perform our contractual or legal obligations. This may include, without limitation, our inability to verify Your identity, process Your orders, deliver the products or services requested, communicate with You regarding Your account or transactions, or respond to Your enquiries or complaints.