Privacy

Last Updated:  December 1, 2024

SoftBank Global Advisers and its affiliates (together, “we” or the “Company”) want to inform you about what personal information we collect and why, to whom we disclose it, and how we protect it, as well as your respective privacy rights under applicable laws. This data protection notice and privacy policy (the “Notice”) applies to you when we process your personal information as part of our interactions with you, such as when you visit our offices, send us an email, visit our website, or attend a meeting or event we are hosting. We also process your information if you are involved in a company with whom we interact as part of our business operations or investment activities. 

This Notice is not intended for our employees or other members of our staff (who are subject to other notices specifically applicable and provided to them). 

We may revise this Notice from time to time in our sole discretion. We will communicate changes and updates to this Notice by posting an updated version of the Notice (with an updated date) on our website. In case of a conflict between this Notice and applicable law, applicable law will govern.

1. What is personal information?

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual, such as name, address, telephone number, email, IP address, education or professional background, and sensitive personal information.

2. What personal information do we collect and use? 

The categories of personal information we collect depend on the nature of our relationship with you as well as your interactions with us. We may have collected any of the information in these categories about you in the past twelve months and may collect such information in future interactions.  

• Identifiers (e.g., name, alias, telephone number, postal address, e-mail address, signature, and photographs) – When, for example, you send us an e-mail, sign up for a Company event or newsletter, visit our offices and check in with our front desk (including signing a non-disclosure agreement).  We need identifiers in order to give you access to our offices. If you do not provide it, you may not be permitted to access our offices.

• Characteristics of Protected Classifications Under Certain Jurisdictional Laws (e.g., race, age, national origin, disability, sex, and veteran status) – Only if you choose to provide this information in connection with your relationship with us, for example, to support diversity and inclusion efforts, speak on panels, etc.

• Commercial Information (e.g., purchasing or consuming histories) – If you share such information with us during the course of our relationship. 

• Internet or other electronic network activity information (e.g., IP address, browser and device details, etc.) – When, for example, you send us an e-mail, use our network, including guest WiFi, visit our website, or interact with our office applications.

• Geolocation data – When, for example, you visit our offices, participate at our events.

• Audio, electronic, visual, or similar information (e.g., CCTV footage for security purposes; visual-audio recordings during meetings or events) – When, for example, you visit our offices, attend video conferences with Company staff, or participate in Company webinars or other meetings or events.

• Professional or employment-related information (e.g., education, certifications, licenses, work experience and previous employers, professional memberships and affiliations) – When, for example, you share with us such details in connection with our relationship, request information or seek communications with us, connect with us on social media, or when such information is publicly posted online.

• Preferences (e.g., professional or personal interests, affinity groups, preferences regarding travel, schedule, food) – When, for example, you visit our offices or attend our events, provide such details in connection with our working relationship, or when such details are publicly available.

Where we collect your sensitive personal information (based on the relevant applicable data protection law), we will process it in accordance with the requirements of the applicable data protection law (including obtaining express written consent where required). We do not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about you.  

3. Where do we collect your personal information?

We collect your personal information from a variety of sources. We get personal information from you, for example, when you provide it to us during the course of your relationship with us. We also collect information from:

• what’s internally generated, for example, we may generate emails, summaries, tables, memos, or notes based on interactions we’ve had during the course of your relationship with us; 

• your employer (e.g., where we interact with your employer as part of our business operations or investment activities) 

• our vendors and service providers (e.g., where you are acting on their behalf or are otherwise involved in related communications and/or transactions or provided your information to such vendors or service providers)

• our affiliated companies as part of our business operations or investment activities or so that we may better communicate with you or fulfil your requests

• third parties (e.g., business partners or professional organizations, where we interact with them as part of our business operations or investment activities)

• public internet sources (e.g., social media, public profiles, and other online sources)

• public records (e.g., credentialing and licensing organizations, government records)

• recording and automated technologies implemented by the Company, for example, to track logins and activity across our network; video surveillance in common areas of our facilities; Bluetooth technologies, voicemail, webcams, audio-visual recording technologies; and

• companies we acquired (where you previously worked). 

If you disclose any personal information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Notice.

4. Why and how do we use your personal information?

We use your personal information for the following purposes:

• Providing the functionality of our website and/or supporting our interactions with you, including responding to your inquiries and fulfilling your requests when you contact us, sending you administrative information such as changes to our terms, conditions, and policies

• Arranging and managing Company sponsorships and promotional or marketing events and activities to build and maintain business relationships and company culture, such as providing you with our newsletter and/or other marketing materials with information or news about the Company and its activities such as updates or upcoming events

• Facilitating, managing, and protecting our business operations and investment activities, including managing company assets and finances, complying with internal policies and procedures, addressing corporate governance matters, complying with recordkeeping and reporting responsibilities, managing investor relations, complying with tax and legal obligations, conducting internal audits, monitoring and managing risk, conducting data analysis (e.g., to improve the efficiency of our business operations and services, to identify opportunities to develop our business); conducting strategic planning, business continuity, and crisis management

• Maintaining the safety and security of our employees, staff, and visitors (e.g., in case of emergency)

• Monitoring, safeguarding, and managing IT infrastructure, laptops and computer equipment, mobile devices, office facilities, and other Company property

• Protecting our legal rights, including monitoring staff performance and conduct, assessing compliance with policies and procedures, monitoring telephone, email, internet and other Company resources, conducting investigations including reporting of allegations of wrongdoing, policy violations, fraud, or financial reporting concerns

• Complying with legal and other requirements applicable to our businesses in all countries in which we operate, such as tax deductions, record-keeping and reporting obligations, conducting audits, compliance with government inspections and other requests from government or other public authorities, responding to legal process such as subpoenas, pursuing legal rights and remedies, defending litigation, and managing any internal or external complaints or claims (including those received through the Company hotline or e-mail)

• In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or changes of control or financial status of the Company or any of its subsidiaries or affiliates

We engage in these activities as necessary or appropriate to comply with our legal obligations, to protect life or physical safety, and based on our legitimate interest to operate and protect our business (unless your fundamental rights outweigh our interests). In certain instances, we may process personal information based on your consent if (i) consent to the processing described in this Notice is required by local law, (ii) the processing involves sensitive personal information, or (iii) the specific processing activity is not required in connection with the purposes described above. Subject to applicable law, some processing may also be necessary so that we can perform a contract with you or because it is required by law.

We may occasionally utilize enterprise tools that incorporate artificial intelligence (“AI”) to support general business administration. These tools help increase efficiency by performing functions such as analyzing data, creating text or visual content, conducting high-level research, or summarizing or transcribing meetings. Importantly, we do not use these AI tools to make inferences or profiles about individuals, to substantially facilitate human decision-making, nor to perform automated individual decision-making. Instead, we use such tools solely to support task automation, making routine processes faster and more efficient. All AI-enabled tools are carefully assessed and monitored before implementation with reasonable safeguards in place to protect privacy, address risk, and comply with applicable regulations.

5. With whom do we share personal information?

From time to time, we may have a legitimate business need to disclose personal information for one of the purposes listed above to one or more of the categories of recipients listed below. In that event, we disclose personal information and/or sensitive personal information only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by applicable laws.  

For the purposes set out above, we may share personal information with:

• Service providers:

  • We disclose personal information to trusted service providers, professional advisers, consultants, suppliers, and contractors to assist us in meeting our business purposes (e.g., business operations, legal and compliance, etc.).

  • Service providers include providers of website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, communications, email delivery, auditing, and other services, as well as auditors, administrative service providers, law firms, other professional advisors

  • We disclose your personal information to such providers subject to written contracts in compliance with applicable law.   

• Affiliated companies: 

  • We disclose personal information to certain of our affiliates within the SoftBank Group for the purposes described in this Notice and applicable law.

• Business partners:

  • We may disclose personal information to a business partner in relation to a training, webinar, conference, or corporate event in which you will be participating.  

  • We may disclose personal information to a business partner in support of investment activities or business operations subject to written contracts in compliance with applicable law.   

  • We will not provide your personal information to external organisations for their own marketing purposes unless we seek your explicit consent before doing so.

• Public: 

  • By using our website or interacting with us online, you may elect to disclose personal information on message boards, chat, profile pages, blogs, and other services to which you are able to post information and content (including, without limitation, our social media pages).  Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. 

• Legal Obligations and Rights: 

  • We may be required to disclose personal information in a court proceeding, in response to a court order, subpoena, civil discovery request, other legal process, or as otherwise required by law. 

  • We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of the Company, our workforce, or others.

• Corporate Transactions: 

  • We may disclose personal information to a third party in connection with any proposed or actual corporate merger, joint venture, assignment, transfer, consolidation, bankruptcy, the sale of all, or substantially all, of our membership interests and/or assets or other corporate change. 

We may otherwise collect, use, and/or disclose personal information with your consent.  If we collect, use, or disclose your personal information based on your consent, you may withdraw your consent at any time.

6. Transfers of personal information overseas

For the purposes set out above and any directly related purposes, we may transfer certain of your personal information outside your country, including to SoftBank Group companies and the third parties described above. Some recipients of your information will be located outside your home jurisdiction, including any country in which we or they have operations. This may include transfers to the United Kingdom, the United States, and Japan.  If we transfer your personal information (including sensitive personal information) overseas, we will take appropriate steps to ensure it is adequately protected as required under the applicable data protection law, including by requiring service providers to implement technical and organizational measures to protect personal information and entering into data processing and transfer agreements (including standard contractual clauses where legally appropriate).

7. How long do we retain personal information?

We will take reasonable steps to ensure that the personal information collected and used is reliable for its intended use and is accurate and complete for carrying out the purposes described in this Notice.  We will retain personal information for the period necessary to fulfil the purposes outlined in this Notice unless a longer retention period is required or permitted by law.  The criteria used to determine our retention periods are:   

• As long as we have an ongoing relationship with you or your employer; 

• As required by a legal obligation to which we are subject (for example, certain laws require us to keep records for a certain period of time before we can delete them); and

• As advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations).

8. Your rights in relation to the personal information we process about you

Depending on the applicable laws in your country of residence, you may have certain rights related to your personal information, for example, the right to:

• know what personal information is processed 

• access your personal information

• object to the processing of your personal information

• withdraw your consent if we obtained your consent to process your personal information

• have your personal information rectified

• have your personal information erased

• request that your personal information is only used for restricted purposes

• inform us that you do not wish to receive marketing information

• (in some circumstances) require certain of your personal information to be transferred to you or a third party

You can seek to exercise your data protection rights (where applicable) by contacting the privacy team at privacy@softbank.com or call 1 (800) 209-3191. To help protect your privacy and security, we will verify and respond to your request consistent with applicable law, taking into account the nature of the request and the applicable circumstances. We will make reasonable attempts to promptly investigate, comply with, or otherwise respond to your requests as may be required by applicable law. Please note that, depending upon the circumstances and the request, we may not be permitted to provide you with access to your personal information or otherwise fully comply with your request.

9. Security

We seek to use reasonable organizational, technical, and administrative measures to protect personal information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Questions or complaints” section below.

10. Other individuals’ personal information

If you intend to provide us with personal information (including any sensitive personal information if applicable) about other individuals, you must ensure that such individuals are aware of the matters in this Notice and agree that such personal data may be provided to us and processed as described herein.

11. Questions or complaints

If you have any questions or complaints regarding our processing of your personal information, in the first instance, please contact the Privacy team at privacy@softbank.com or call 1 (800) 209-3191.

Complaints regarding our collection and processing of your personal information may also be made directly to the data protection regulator in your jurisdiction (where available).  

12. Specific Provisions for Brazil

• Sensitive personal data means personal data on racial or ethnic origin, religious conviction, political opinion, membership of a trade union or religious, philosophical or political organization, data concerning health or sex life, genetic or biometric data, when linked to a natural person;

• To the extent Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados or LGPD) covers your personal information, you have certain rights as specified in Article 18 of the LGPD:   

  • Confirmation as to the existence of the processing of your personal information

  • Access to your personal information

  • Correction of incomplete, inaccurate, or out-of-date personal information

  • Anonymization, blocking, or deletion of personal information that is unnecessary, excessive, or being processed in noncompliance with the LGPD

  • Portability of your Personal information to another service or product provider, by means of your express request, pursuant with applicable regulations, and subject to commercial and industrial secrets

  • Deletion of personal information processed with your consent, except in certain situations as provided by the LGPD

  • Information about public and private entities with whom we have shared personal information

  • Information about the possibility of denying consent and the consequences of such denial

  • Revocation of your consent as provided by the LGPD

• If you have any questions and/or complaints regarding the processing of your personal data, as a Brazilian citizen and/or an individual located in Brazil, please reach out to the Data Protection Officer through the contact information below: 

13. Specific Provisions for California

• We may also collect Cal. Civ. Code § 1798.80 Personal Information (e.g., name, signature, physical characteristics or description, address, telephone number), which may overlap with other categories previously disclosed in this notice.  Such information may be collected, for example, when you visit our offices, provide such details for our business interactions, etc.

• At times, we convert personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”).  We maintain Deidentified Information in a deidentified form and does not attempt to reidentify it, except that we may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual.  We prohibit vendors, by contract, from attempting to reidentify our Deidentified Information.  

• The following list details the categories of personal information we may disclose, as well as which categories of personal information we have disclosed in the preceding 12 months.

  • Identifiers and Cal. Civ. Code § 1798.80 Personal Information – To Service providers; Affiliated companies; Business partners; the Public; Legal Obligations and Rights, Corporate Transactions.

  • Characteristics of Protected Classifications Under Certain Jurisdictional Laws (provided on voluntary basis) – To Service providers; Affiliated companies; Business partners; the Public; Legal Obligations and Rights.

  • Commercial Information – To Service providers; Affiliated companies; Business partners; Legal Obligations and Rights, Corporate Transactions.

  • Internet or other electronic network activity information – To Service providers; Affiliated companies; the Public; Legal Obligations and Rights, Corporate Transactions.

  • Geolocation data – To Service providers; Affiliated companies; Business partners; the Public; Legal Obligations and Rights, Corporate Transactions.

  • Audio, electronic, visual, or similar information – To Service providers; Affiliated companies; Business partners; the Public; Legal Obligations and Rights, Corporate Transactions.

  • Professional or employment-related information – To Service providers; Affiliated companies; Business partners; the Public; Legal Obligations and Rights, Corporate Transactions.

  • Preferences – To Service providers; Affiliated companies; Business partners; the Public; Legal Obligations and Rights.

• We do not sell your personal information nor disclose your personal information for cross-context behavioral advertising (which is considered “sharing” under California privacy law).

• We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the personal information subject to the request. We may need to request additional personal information from you, such as mailing address, telephone number and/or email address, in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your personal information. If you make a deletion request, we may ask you to verify your request before we delete your personal information.  If an authorized agent submits on your behalf a request to know, correct, or delete, the authorized agent must submit with the request either (a) a power of attorney, signed by you, that is valid under California law; or (b) another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity. 

If a resident of California, you may contact the California Privacy Protection Agency (https://cppa.ca.gov/) and the California Attorney General (https://oag.ca.gov/consumers)

Cookie Policy

Last Updated: February 25, 2025 

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. 

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive. 

We may use the following cookies: 

• Strictly necessary cookies. These are cookies that are required for the operation of our website. These essential cookies are always enabled because our website won’t work properly without them. They include, for example, cookies that enable you to log into secure areas of our website. You can switch off these cookies in your browser settings but you may then not be able to access all or parts of our website.    

• Performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. These are also used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). 

• Marketing cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose so that they can serve you with relevant advertising on their websites. 

You can find more information about the individual cookies we use and the purposes for which we use them in the table below: 

Please note that the following third parties may also use cookies, over which we have no control. These named third parties may include, for example, advertising networks and providers of external services like web traffic analysis services. These third party cookies are likely to be performance or marketing cookies: 

Google Analytics 

Vimeo 

To deactivate the use of third party marketing cookies, you may visit the relevant consumer page to manage the use of these types of cookies. 

To opt out of being tracked by Google Analytics across all websites, visit http://tools.google.com/dlpage/gaoptout. 

You can choose which performance and marketing cookies we can set by clicking on the button(s): 

• Strictly necessary cookies    ALWAYS ACTIVE 

• Performance cookies    OFF 

• Marketing cookies    OFF 

You can also choose to "Reject All" cookies in the cookie banner. 

However, if you use your browser settings to block all cookies (including strictly essential cookies), you may not be able to access all or parts of our website. 

If you have any questions or concerns about our use of cookies, please send us an email at privacy@softbank.com.