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.
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 1 October 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 1 October 2025.
Daiwa Thailand
Thai Law Supplementary Information
1. Introduction and scope of this supplementary information
This Thai Law Supplementary Information (“Supplement”) applies to the processing of personal data by GLOBERIDE within Thailand but may also apply to processing outside Thailand in limited circumstances, such as offshore cloud storage or remote access by our employees, which is subject to the Thai Laws (as defined below). GLOBERIDE will take all reasonable and necessary measures to safeguard Personal Data (as defined below) in accordance with the Personal Data Protection Act, B.E. 2562 (2019) and regulations (collectively, the “Thai Laws”).
2. Personal data and definition
Thai Laws recognize the following terms as defined terms as follows:
“Personal Data” means any data about an individual which can be used to trace back to any such individual, whether by such data alone or in combination or in conjunction with other data available for any particular processing, but excludes data of a deceased person.
“Sensitive Personal Data” means personal information about race, ethnicity, political opinions, religion, philosophy, sexual behavior, criminal records, medical information, disability information, trade union information, genetic information, biological information (e.g., finger scans, face scanning, etc.) or any other information that affects the data subject in a similar way as announced by the Personal Data Protection Committee (PDPC).
In circumstances where this Supplement applies, the definitions set out in this Section shall apply to any reference in the Addendum to the corresponding defined term.
“Personal Data” means any data about an individual which can be used to trace back to any such individual, whether by such data alone or in combination or in conjunction with other data available for any particular processing, but excludes data of a deceased person.
“Sensitive Personal Data” means personal information about race, ethnicity, political opinions, religion, philosophy, sexual behavior, criminal records, medical information, disability information, trade union information, genetic information, biological information (e.g., finger scans, face scanning, etc.) or any other information that affects the data subject in a similar way as announced by the Personal Data Protection Committee (PDPC).
In circumstances where this Supplement applies, the definitions set out in this Section shall apply to any reference in the Addendum to the corresponding defined term.
3. Controller details
You can contact GLOBERIDE's Data Protection Officer with any questions or concerns You have about Your Personal Data at the following channels:
GLOBERIDE Group’s Data Protection Officer (DPO)
Address: 3-14-16, Maesawa, Higashikurume-shi, Tokyo, Japan
Email: dpo@globeride.co.jp, dpo@daiwaseiko.co.th
Tel: (+66) 02-739-4200
Address: 3-14-16, Maesawa, Higashikurume-shi, Tokyo, Japan
Email: dpo@globeride.co.jp, dpo@daiwaseiko.co.th
Tel: (+66) 02-739-4200
4. Legal basis for the handling (processing) of Your Personal Data
In addition to Section 4 of the Addendum, we will process Your Personal Data: (i) for Your vital interest, (ii) for the prevention and/or preparation of potential lawsuits, or (iii) for the preparation of the historical documents or the archives for public interest, or for purposes relating to research or statistics.
Please note that in some instances, if You do not provide the requested Personal Data, we may not be able to provide our services to You.
Please note that in some instances, if You do not provide the requested Personal Data, we may not be able to provide our services to You.
5. International transfers
GLOBERIDE may transfer Your Personal Data to its subsidiaries or related companies in the GLOBERIDE Group or external service providers in Thailand so these service providers can perform certain tasks on our behalf, such as for cloud and non-cloud storage, payment management, analytics, and general assistance, or when there is a legal obligation or legitimate interest to do so, such as for audits and a corporate sale or restructuring. We will rely on the same legal basis as notified or consented by You for these domestic transfers and processing activities. In such cases, we will ensure a standard of protection for the Personal Data so transferred that is comparable to the protection under the Thai Law and our standards.
GLOBERIDE may transfer Your Personal Data to its subsidiaries or related companies in the GLOBERIDE Group (including its affiliates situated outside of Thailand such as in Australia, Germany, Hong Kong, Indonesia, Japan, Malaysia, South Korea, Singapore, Taiwan, UK, USA, Vietnam) or external service providers throughout the world so these service providers can perform certain tasks on our behalf, such as for cloud and non-cloud storage, payment management, analytics, and general assistance, or when there is a legal obligation or legitimate interest to do so, such as for audits and a corporate sale or restructuring. Some countries will be recognized by the PDPC as providing an adequate level of data protection according to standards set by the PDPC. If we have a contractual basis for any such processing, we will also rely on such for offshore transfers or processing. In general, for future transfers from Thailand to countries not considered adequate by the PDPC, we have put in place adequate measures, such as standard contractual clauses which meet the requirements set by the PDPC, to protect Your Personal Data.
GLOBERIDE may transfer Your Personal Data to its subsidiaries or related companies in the GLOBERIDE Group (including its affiliates situated outside of Thailand such as in Australia, Germany, Hong Kong, Indonesia, Japan, Malaysia, South Korea, Singapore, Taiwan, UK, USA, Vietnam) or external service providers throughout the world so these service providers can perform certain tasks on our behalf, such as for cloud and non-cloud storage, payment management, analytics, and general assistance, or when there is a legal obligation or legitimate interest to do so, such as for audits and a corporate sale or restructuring. Some countries will be recognized by the PDPC as providing an adequate level of data protection according to standards set by the PDPC. If we have a contractual basis for any such processing, we will also rely on such for offshore transfers or processing. In general, for future transfers from Thailand to countries not considered adequate by the PDPC, we have put in place adequate measures, such as standard contractual clauses which meet the requirements set by the PDPC, to protect Your Personal Data.
6. Data security measures
We adopt a high-standard security system in both technology and procedures to prevent any possible data theft and other types of unlawful access. We place emphasis on the retention of high security standards. We make substantial investments and effort, and provide substantial human resources to ensure that we maintain high-standard measures and Your Personal Data remains safe. We implement various measures to protect our computer system, such as Firewall.
7. Retention of Personal Data
Your Personal Data will be retained for period(s) as are necessary to meet GLOBERIDE legal and/or business purposes, and GLOBERIDE will cease to retain Your Personal Data as soon as it is reasonable to assume that the purpose for collecting such Personal Data is no longer being served by such retention, and such retention is no longer necessary for legal and/or business purposes. Our current policy is to retain certain Personal Data of You for up to ten (10) years after ceasing to be necessary, subject to the applicable anonymization procedures and at all times in accordance with our document retention and disposal policy, and applicable laws and regulations.
8. Your rights under Thai Laws
In accordance with the Thai Laws, You, as a data subject, have the following rights (which may be amended pursuant to any regulations of the data protection law) which are exercisable in compliance with applicable laws:
In case You consider that we fail to comply with Your request to exercise Your right as a data subject, or that we fail to comply with the Thai Laws, You may contact the PDPC. Nevertheless, we would appreciate the opportunity to address Your complaint in the first instance.
In cases where You have given consent for the processing of Personal Data to GLOBERIDE (where
the consent is not required by other applicable laws), You shall have the right to withdraw the consent at any time. Should a withdrawal of any consent affect any transactions or provision of services, You will be informed at the time of the withdrawal request.
- To access Personal Data;
- To rectify Personal Data;
- To erase or destroy Personal Data;
- To restrict the use of Personal Data;
- To object to the collection, use and disclosure of Personal Data;
- To data portability; and
- To withdraw the consent.
In case You consider that we fail to comply with Your request to exercise Your right as a data subject, or that we fail to comply with the Thai Laws, You may contact the PDPC. Nevertheless, we would appreciate the opportunity to address Your complaint in the first instance.
In cases where You have given consent for the processing of Personal Data to GLOBERIDE (where
the consent is not required by other applicable laws), You shall have the right to withdraw the consent at any time. Should a withdrawal of any consent affect any transactions or provision of services, You will be informed at the time of the withdrawal request.
This Supplement was last updated on 1 October 2025.