GLOBERIDE DATA PROTECTION COMPLIANCE PROJECT:
US Addendum to the GLOBERIDE Personal Information Protection Policy
US 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”, or “we”) processes personal data relating to customers and business partners (hereinafter referred to as “Customers”, “You” or “Your”) located in the United States of America (“US”). If You are located in the US, then Your personal information will be processed in accordance with the applicable U.S. State Privacy Laws (as defined below) for the state which You are a resident, and any other applicable data protection and privacy laws (together, “Data Protection Laws”).
For the purposes of this Addendum, “U.S. State Privacy Laws” means the California Consumer Privacy Act of 2018 (including as amended by the California Privacy Rights Act of 2020, “CCPA”), the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Iowa Consumer Data Protection Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Privacy Act, the New Jersey Data Privacy Act, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act and the Virginia Consumer Data Protection Act including any implementing regulations, and in each case as may be amended or superseded from time to time.
This Addendum should be read in conjunction with the GLOBERIDE Personal Information Protection Policy, which further describes the categories of personal information processed by GLOBERIDE, how they are collected, the implications if You refuse to provide personal data, if and when personal information 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.
For the purposes of this Addendum, “U.S. State Privacy Laws” means the California Consumer Privacy Act of 2018 (including as amended by the California Privacy Rights Act of 2020, “CCPA”), the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Iowa Consumer Data Protection Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Privacy Act, the New Jersey Data Privacy Act, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act and the Virginia Consumer Data Protection Act including any implementing regulations, and in each case as may be amended or superseded from time to time.
This Addendum should be read in conjunction with the GLOBERIDE Personal Information Protection Policy, which further describes the categories of personal information processed by GLOBERIDE, how they are collected, the implications if You refuse to provide personal data, if and when personal information 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 information relating to Customers who are located in the US or whose personal information is otherwise protected under the Data Protection Laws of the US (herein, “US Customers”). It also sets out how US 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 US Customers.
Please note that any personal information related processing activities undertaken by GLOBERIDE (including its group companies in the US) 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 information related processing activities undertaken by GLOBERIDE (including its group companies in the US) 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) (“business” under the CCPA) in respect of Your personal data is GLOBERIDE Inc. Other companies in the GLOBERIDE group may make decisions about Your personal information 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. Purpose, collection and disclosure of Your personal information
The following chart details which categories of personal information we collect and process, as well as which categories of personal information we disclose to third parties for our operational business purposes, including within the 12 months preceding the date this Addendum was last updated.
Your personal data may also be processed by GLOBERIDE for other purposes in respect of certain specific activities (such as aftersales support) as set out in Section 2 of this Addendum.
GLOBERIDE may also disclose your Personal Information to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Notwithstanding, GLOBERIDE does not sell Your personal information as defined under applicable Data Protection Laws and has not engaged in such activities in the preceding 12 months. Additionally, GLOEBRIDE does not sell the Personal Information of minors under 16 years of age.
| Type of Information | Disclosed to Which Categories of Third Parties for Operational Business Purposes (as discussed further in Section 5): | |
|---|---|---|
| Identifiers, such as name, alias, postal address, email address, unique personal identifiers, online identifiers such as device ID, and IP addresses. | affiliates; employees; service providers; marketing partners; joint businesses partners; legal authorities | |
| Commercial information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | affiliates; employees; service providers; marketing partners; joint businesses partners; legal authorities | |
| Internet or network activity information, such as browsing history, search history and interactions with our online properties or ads. | affiliates; employees; service providers; marketing partners; joint businesses partners; legal authorities | |
| Audio/Video Data. Audio, electronic, visual, thermal, olfactory, or similar information, such as photos, audio/video recordings. | affiliates; employees; service providers; joint businesses partners; legal authorities | |
| Geolocation Data, such as device location, and approximate location derived from IP address. | affiliates; employees; service providers; marketing partners; joint businesses partners; legal authorities | |
| Sensitive Personal Information | Account log-in information (for our website/services). | affiliates; employees; service providers; marketing partners; joint businesses partners; legal authorities |
| Contents of mail, email, and text messages unless GLOBERIDE is the intended recipient of the communication. | ||
| The processing of biometric information for the purpose of uniquely identifying a consumer. | ||
GLOBERIDE may also disclose your Personal Information to a third party in the event of any reorganization, financing transaction, merger, sale, joint venture, partnership, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).
Notwithstanding, GLOBERIDE does not sell Your personal information as defined under applicable Data Protection Laws and has not engaged in such activities in the preceding 12 months. Additionally, GLOEBRIDE does not sell the Personal Information of minors under 16 years of age.
5. Purposes for the collection and use of Your personal information
We collect and use Your personal information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including to:
- Sell, supply, develop, improve, operate, repair, and maintain GLOBERIDE’s products, services, and related goods;
- Review and analyze the purchase and usage status of GLOBERIDE’s products, services, and related goods;
- Conduct surveys related to GLOBERIDE’s products, services, and related goods;
- Develop new products, services, and related goods;
- Contact You regarding GLOBERIDE products, services, and related goods (excluding direct marketing);
- Plan and manage various activities handled by GLOBERIDE and its external subcontractors or partner companies (such as events and campaigns);
- Provide 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;
- Analyze 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;
- Respond to Your inquiries and requests;
- Share 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);
- Perform accounting, audit, and other internal functions, such as internal investigations; and
- Maintain records, comply with law, legal processes, and internal policies, and to exercise and defend legal claims.
6. Processing and sharing of Your personal information for (i) targeted advertising and/or (ii) profiling, as defined under applicable Data Protection Laws
The following chart details which categories of personal information GLOBERIDE may collect, process, and share for the purposes of (i) targeted advertising and/or (ii) profiling, as defined under applicable Data Protection Laws. Additionally, it contains the categories of third parties which Your personal information may be shared with for such purposes as well as a further description of the purpose of GLOBERIDE’s targeted advertising and profiling activities. Notwithstanding the foregoing, GLOBERIDE will not process the personal information (a) of minors under 16 years of age or (b) that would be classed as sensitive personal information under applicable Data Protection Laws, for either targeted advertising or profiling purposes without the required consent under applicable Data Protection Laws.
Please see Sections 11 and 12 of this Addendum for further information to opt-out of processing for targeted advertising and/or profiling purposes where applicable.
| Purpose | Type of Information | Disclosed to Which Categories of Third Parties for (i) targeted advertising and/or (ii) profiling |
|---|---|---|
| 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. | Identifiers, Commercial information, Internet or network activity information, Geolocation data, and Sensitive personal information | affiliates; employees; service providers; marketing partners; joint businesses partners; legal authorities |
| 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. | Identifiers, Commercial information, Internet or network activity information, Geolocation data, and Sensitive personal information | affiliates; employees; service providers; marketing partners; joint businesses partners; legal authorities |
7. Purposes for the collection and use of sensitive personal information
Subject to Your consent, and strict necessity, where required by applicable Data Protection Laws, GLOBERIDE may process Your sensitive personal information for certain purposes, as defined by applicable Data Protection Laws, including but not limited to account log-in information, payment information, biometric information for the purpose of uniquely identifying a consumer, and the contents of mail, email, and text messages unless GLOBERIDE is the intended recipient of the communication. These purposes may include performing services for our business, providing goods or services as requested by you, ensuring security and integrity, short term transient use such as displaying first party, non-personalized advertising, order processing and fulfillment, servicing accounts, providing customer service, verifying customer information, processing payments, providing financing, activities relating to quality and safety control or product improvement, or any other purpose set forth in this Addendum.
Notwithstanding, GLOBERIDE does not sell Your sensitive personal information as defined under applicable Data Protection Laws and has not engaged in such activities in the preceding 12 months. Please see the chart contained in Section 4 for a further description of how GLOBERIDE may share your sensitive personal information.
Notwithstanding, GLOBERIDE does not sell Your sensitive personal information as defined under applicable Data Protection Laws and has not engaged in such activities in the preceding 12 months. Please see the chart contained in Section 4 for a further description of how GLOBERIDE may share your sensitive personal information.
8. Children under the age of 13
GLOBERIDE’s website and online services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on GLOBERIDE’s website or other online services. We do not knowingly collect personal information from children under 13. If You are under 13, do not use or provide any information on the website or through any of its features, register on the website, or provide any information about yourself to GLOBERIDE, including Your name, address, telephone number, or email address. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If You believe we might have any information from or about a child under 13, please contact GLOBERIDE's Data Protection Officer by emailing: dpo@globeride.co.jp.
9. Sources of Personal Information
GLOBERIDE collects Your personal information in fair and appropriate means including (i) directly from You, and (ii) from third-party sources, such as affiliates, business partners, group companies, public databases, joint marketing partners, and social media platforms.
10. Retention period
GLOBERIDE retains Your personal information for as long as is necessary for the purpose(s) it was collected for or, where permitted, for a related compatible reason. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with You and provide services to You (for example, for as long as You have an account with GLOBERIDE or keep using GLOBERIDE’s services) and the length of time thereafter during which GLOBERIDE may have a legitimate need to reference Your Personal Information to address issues that may arise;
- Whether there is a legal obligation to which GLOBERIDE is subject to (for example, certain laws require GLOBERIDE to keep records of Your transactions for a certain period of time before GLOBERIDE can delete them); or
- Whether retention is advisable in light of GLOBERIDE’s legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
11. Your rights under Data Protection Laws
Subject to the applicable 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 confirm whether GLOBERIDE is processing Your personal information and ask for details of the personal information which GLOBERIDE holds, and processes, and for a copy of that information. Please note that there are limitations on this right under some Data Protection Laws and GLOBERIDE may not be able to provide You with all of Your personal data.
- If you are a California resident, you may request that we disclose to You the following information covering the 12 months preceding your request:
- The categories of personal information GLOBERIDE collected about You and the categories of sources from which GLOBERIDE collected such personal information;
- The business or commercial purpose for collecting personal information about You; and
- The categories of personal information about You that GLOBERIDE disclosed, and the categories of third parties to whom GLOBERIDE disclosed such Personal Information (if applicable).
- If you are a California resident, you may request that we disclose to You the following information covering the 12 months preceding your request:
- 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 including, but not limited to, when retention is required by applicable law.
- Right to limit disclosure or use of sensitive personal information: You have the right to limit the disclosure or use of your sensitive personal information that has been collected or processed to limited purposes, such as providing You with the services You requested from GLOBERIDE.
- Right of Portability: In some circumstances, You may ask GLOBERIDE to provide You with Your personal information in a format commonly used for storing and accessing such data that allows You to transmit the personal information to another controller without hindrance.
- Right to Opt-Out of Certain Processing of Your personal data: You may opt-out of GLOBERIDE processing Your personal data for the purposes of:
- targeted advertising;
- profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning You; or
- the sale of Your personal information. Please note that GLOBERIDE does not process personal data in a way that constitutes a sale of Your personal information.
- Right to Appeal: If you are a Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, Oregon, Texas, or Virginia Customer, and we refuse to take action on your request, you may appeal our refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us at 20155 Ellipse, Foothill Ranch, CA 92610 or 1-800-736-4653 or privacypolicy@daiwa.com
12. Submitting and responding to requests
The process for exercising the data subject rights set out in Section 11 above is as follows:
Submitting Your request
To submit a rights request under any of Your rights outlined under Section 11 or as otherwise granted under applicable Data Protection Laws, please contact us at privacypolicy@daiwa.com or 1-800-736-4653 or Click here.
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, but GLOBERIDE will respond within the timeframe as required by applicable Data Protection Laws. Please also note that there are exceptions to Your rights and some circumstances in which they do not apply.
Additional information about You
When You request to exercise certain rights, GLOBERIDE may need to ask You for additional information in order to verify Your identity. This is a security measure to ensure that personal information is not provided to persons who do not have the right to receive it. We may also contact You to clarify Your request.
If an agent would like to make a request on your behalf as permitted under applicable Data Protection Laws, the agent may use the submission methods noted in this Section 12 entitled “Submitting and responding to requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent.
Fees
You generally do not need to pay to access Your personal data or to exercise any of Your other rights. However, in certain instances applicable Data Protection Laws allow GLOBERIDE to charge a reasonable fee where a request is unreasonable, unfounded, excessive or repetitive, 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.
Submitting Your request
To submit a rights request under any of Your rights outlined under Section 11 or as otherwise granted under applicable Data Protection Laws, please contact us at privacypolicy@daiwa.com or 1-800-736-4653 or Click here.
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, but GLOBERIDE will respond within the timeframe as required by applicable Data Protection Laws. Please also note that there are exceptions to Your rights and some circumstances in which they do not apply.
Additional information about You
When You request to exercise certain rights, GLOBERIDE may need to ask You for additional information in order to verify Your identity. This is a security measure to ensure that personal information is not provided to persons who do not have the right to receive it. We may also contact You to clarify Your request.
If an agent would like to make a request on your behalf as permitted under applicable Data Protection Laws, the agent may use the submission methods noted in this Section 12 entitled “Submitting and responding to requests.” As part of our verification process, we may request that the agent provide, as applicable, proof concerning his or her status as an authorized agent.
Fees
You generally do not need to pay to access Your personal data or to exercise any of Your other rights. However, in certain instances applicable Data Protection Laws allow GLOBERIDE to charge a reasonable fee where a request is unreasonable, unfounded, excessive or repetitive, 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.
13. Do-Not-Track / Global Privacy Control
Customers can set privacy preferences through the Do Not Track (“DNT”) mechanism in certain web browsers. In addition, some browsers or plug-ins use a “Global Privacy Control” (“GPC”), which allows You to opt out of certain data processing. (You can learn more about the GPC at https://globalprivacycontrol.org/). If our site or online services detect a DNT and/or GPC signal from Your device, we will interpret it as either a Do Not Sell request or a request to limit the sale or sharing of personal information for targeted advertising or profiling depending on the applicable Data Protection Laws.
14. Cookies
GLOBERIDE may collect information through cookies to improve Your use of our online services. A "cookie" is a small string of text sent by our online services to Your browser and then stored by Your browser on your computer's hard drive. Storage of cookies on Your system provides an easy and convenient method for us to personalize and enhance Your experience on our online Services, and to help us diagnose problems with our servers and to administer our online services. For example, cookies allow us to remember Your screen name and date of birth, tell us that you have visited our online services before, track Your usage of our online services, and make Your next visit to our online services more enjoyable. Most web browsers automatically accept cookies, but You can always disable cookies or set Your browser to alert You when cookies are being sent to your computer. However, rejecting cookies may prevent You from taking advantage of certain portions of our online services.
Third Party Cookies
GLOBERIDE and our third-party service providers may use cookies and similar technologies to manage and optimize our internet business and communications, such as for marketing purposes, to help us deliver advertisements, to measure the effectiveness of our advertising, and to understand how visitors use our online services. These technologies may collect customers’ browsing and other traffic activity; the date and time of visit; and product codes and pricing information for purchased products, not only on GLOBERIDE’s online services and sites and at the time You access those services and sites, but also over time and across different web sites and online services. This information helps GLOBERIDE learn things like what pages are most attractive to our visitors, which of our products or online services most interest our Customers, and what kinds of offers our Customers like to see. Although our third-party service providers log the information coming from the online services on our behalf, GLOBERIDE controls how that information may be used. You can opt out of the use of cookies by submitting a rights request as outlined in Section 12, or by incorporating DNT or GPC mechanisms under Section 13.
Third Party Cookies
GLOBERIDE and our third-party service providers may use cookies and similar technologies to manage and optimize our internet business and communications, such as for marketing purposes, to help us deliver advertisements, to measure the effectiveness of our advertising, and to understand how visitors use our online services. These technologies may collect customers’ browsing and other traffic activity; the date and time of visit; and product codes and pricing information for purchased products, not only on GLOBERIDE’s online services and sites and at the time You access those services and sites, but also over time and across different web sites and online services. This information helps GLOBERIDE learn things like what pages are most attractive to our visitors, which of our products or online services most interest our Customers, and what kinds of offers our Customers like to see. Although our third-party service providers log the information coming from the online services on our behalf, GLOBERIDE controls how that information may be used. You can opt out of the use of cookies by submitting a rights request as outlined in Section 12, or by incorporating DNT or GPC mechanisms under Section 13.
15. California’s “Shine the Light” Law
If you are a California resident, you have the right to request certain information regarding our disclosure of your information to third parties for direct marketing purposes pursuant to Section 1798.83 of California Civil Code. If you request such information, please contact GLOBERIDE's Data Protection Officer by emailing: dpo@globeride.co.jp, with “California Privacy Rights” in the subject line.
16. Nevada residents as covered by the Nevada privacy law (Nevada Revised Statutes Chapter 603A)
GLOBERIDE does not sell Covered Information as defined under Nevada law. If You would like to inquire regarding the sale of your Covered Information, as defined under Nevada law, please contact GLOBERIDE's Data Protection Officer by emailing: dpo@globeride.co.jp
This Addendum was last updated on January 1, 2026.
This Addendum was last updated on January 1, 2026.