PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS

This PRIVACY STATEMENT FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Policy of Shimano Inc. and its affiliates and subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We have adopted this notice to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this Privacy Statement for California Residents.

This Privacy Statement for California Residents should be read together with our Privacy Policy, which provides important information on our collection and use of personal data.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). In particular, we have collected the following categories of Personal Information from consumers within the last twelve (12) months:

• Identifiers: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number or state identification card number, passport number, or other similar identifiers.
•  Internet or other similar network activity:  Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
• Commercial information:  Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
• Professional Data:  Current or past job history or performance evaluations.

• Educational Data:  Educational background, grades, scores.

• Other Data:  Financial information, medical information, health insurance information.
• Inferences:  Profiles drawn from other Personal Information reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from our customers. For example, when a customer enrolls in a newsletter or orders products.
• Indirectly from our customers. For example, through information we collect from our customers in the course of providing services to them.
• Directly and indirectly from activity on our website (www.shimano.com). For example, from submissions through our website portal or website usage details collected automatically.
• From third-parties that interact with us in connection with the services we perform. For example, from government agencies when we prepare readiness assessments for projects that receive government funding.

Personal Information from Vendors and Business Partners

We collect Personal Information from representatives of our vendors and business partners in the course of our business when the representative or the company they work for is a customer or vendor of Company.  We collect this information from:

• Their employer in connection with the work they do for their employer and how that relates to the Services.
• Third parties Company works with, such as business partners, and through introductions from other individuals or companies.

When you or the company you work for interacts with Company (for example, when providing technical services to us), we collect the following types of Personal Information:

• Contact information: such as your email address, phone number and any other information you provide relating to your work or to you personally (for example, your name, job title or other information in your email signature).
• Financial Information, which can include credit reports and tax returns.
• Information relating to our dealings with you or the company you work for: such as information used to administer your company account, verify financial transactions, details of goods or services that Company has exchanged with you, and information that you give us or we otherwise obtain when you interact with Company.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order for us to respond to requests for information or to fulfill orders for our products.
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

We may use information collected about prospective employees to respond to and process your job application and to make inquiries about you for credit and reference purposes.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your Personal Information to a third party for a business purpose.  When we disclose Personal Information for a business purpose, we enter an agreement that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for a business purpose:

• Identifiers.
• California Customer Records Personal Information categories.

• Protected classification characteristics under California or federal law.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any Personal Information or shared any Personal Information to facilitate advertising goods or serves by others.

Your Rights and Choices

The CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.  Subject to certain exceptions, you have the following rights with respect to your Personal Information:

• To request that Company disclose what Personal Information it has collected, used, or disclosed, over the 12-month period preceding Company's receipt of such a request;
• To request that Company disclose whether any of your information was sold or shared with third parties, to whom such information was sold or shared, and the business purpose for selling or sharing the information;
• To request that any inaccurate or incomplete Personal Information maintained by Company be corrected or supplemented; and
• To request deletion of your Personal Information maintained by Company.

All of these rights are subject to certain conditions and exemptions.  For example, Company will not be obligated to delete your Personal Information if we need to retain it to protect ourselves in the event of a legal claim.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by:

• Emailing the verifiable consumer request to ccpa@shimano.com.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Authorized Agents

You may designate an authorized agent to exercise a CCPA right on your behalf.  If you use an authorized agent to exercise your rights under the CCPA, we will need the following proof that you have authorized the agent to act on your behalf:

• Written proof that you have authorized the agent to act on your behalf, and separately verify your identity as described above; or
• Proof that the authorized agent holds a power of attorney to act on your behalf pursuant to California Probate Code §§ 4000-4465.

Changes to this Privacy Policy.  We reserve the right to amend this Privacy Statement at our discretion and at any time. When we make changes to this Privacy Statement, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about our Privacy Statement, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: shimano.com / LazerSport.us
Email: ccpa@shimano.com

Last Updated:  January 1, 2023