Legal Notice

The information offered by SB Opportunity Fund LLC (together with, as the context may require, any parallel fund, feeder fund, co-investment vehicle or alternative investment vehicle, “SBOF”) and its advisory affiliate, SB Opportunity Fund Manager LLC (“SBOM” and together with SBOF, the “Opportunity Fund”) on this site is subject to certain terms and conditions (the “Terms and Conditions”). These Terms and Conditions apply to all users. By entering this site or by transmitting any information to the site, you acknowledge and agree to all of the Terms and Conditions. Please read them carefully. If you do not agree to the Terms and Conditions, please do not use this site. Any use of this site in a manner inconsistent with these Terms and Conditions is deemed unauthorized access and may subject the user to civil or criminal penalties. We reserve the right to revise this legal information at any time and for any reason, without notice or obligation, by updating this posting. Your continued use of this site following the posting of any changes to the Terms and Conditions will mean that you accept such amendments. We strongly recommend that you periodically visit this page of the site to review the Terms and Conditions.

Legal and Privacy Notices

All information contained herein is for informational purposes and should not be construed as investment advice. This site is intended solely to provide information regarding potential financing capabilities of Opportunity Fund and its affiliates for prospective portfolio investments. The information provided on this page, including any information regarding Opportunity Fund’s current and historical portfolio investments, is not intended to recommend any investment described herein and is not an offer or sale of any security or investment product or investment advice.

There may be legal requirements in various countries and jurisdictions which may restrict the information that can be accessed or how it may be used. Persons who view or obtain information from this site should inform themselves about and observe any restrictions imposed in the jurisdiction in which the site is accessed.

Disclaimers

While Opportunity Fund uses reasonable efforts to help ensure that all material on this site is correct, accuracy cannot be guaranteed and Opportunity Fund makes no representations or warranties as to the accuracy, reliability or completeness of any information at this site. Any content on this site are subject to change without notice. THE SITE, AND ALL INFORMATION AND MATERIALS CONTAINED HEREIN, IS PROVIDED TO YOU “AS IS” WITHOUT WARRANTY OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING, WITHOUT LIMITATION, THE IMPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND NON-INFRINGEMENT TO THE FULL EXTENT PERMITTED BY LAW. Opportunity Fund further assumes no responsibility for, and makes no warranties that functions contained at this site will be uninterrupted or error-free, that defects will be corrected, or that the site or the server that makes it available will be free of viruses or other harmful components. Opportunity Fund shall not be liable for any damages, viruses, or services, repairs or corrections that must be performed on your computer or other property on account of your accessing or using this site. Please note that some jurisdictions do not allow the exclusion of implied warranties, so some or all of the above exclusions may not apply to you.

Although the site may include investment-related information, nothing on the site is a recommendation that you purchase, sell or hold any security or other investment, or that you should pursue any investment strategy, and no information or content on the site is to be relied upon for the purpose of making or communicating investment or other decisions. Nothing on the site is intended to be, and you should not consider anything on the site to be, investment, accounting, tax, legal, or other professional advice.

Opportunity Fund does not warrant the accuracy, adequacy or completeness of the information and material contained on the site and expressly disclaims liability for errors or omissions in the material and information. The site may contain forward-looking statements (including those relating to current and future market conditions and trends in respect thereof) that are not historical facts and are based on current expectations, estimates, projections, opinions and/or beliefs of Opportunity Fund. Such statements involve known and unknown risks, uncertainties and other factors, and undue reliance should not be placed thereon. In addition, no representation or warranty is made with respect to the reasonableness of any estimates, forecasts, illustrations, prospects, or returns, which should be regarded as illustrative only, or that any profits will be realized. Actual events or results or actual performance may differ materially from those reflected or contemplated in such forward-looking statements. As a result, investors should not rely on such forward-looking statements in making their investment decisions. No representation or warranty is made as to future performance or such forward-looking statements.

Opportunity Fund is not liable for any consequential, incidental, special, punitive or exemplary damages arising out of any use of or inability to use the site or any portion thereof, regardless of whether Opportunity Fund has been apprised of the likelihood of such damages occurring and regardless of the form of action, whether in contract, warranty, tort (including negligence), strict liability, or otherwise.

The names and logos of certain companies included in the site are provided for illustrative purposes only. Inclusion of such companies’ names and logos does not imply affiliation with or endorsement by such firms.

Material to be Consulted in its Entirety

All materials in this site are meant to be reviewed in their entirety, including any footnotes, legal disclaimers, restrictions or disclosures, and any copyright or proprietary notices. Any disclaimers, restrictions, disclosures or hedge clauses apply to any partial document or material in the same manner as they do to the whole, and will be deemed incorporated in the portion of any material or document that you consult or download.

Linking, Posting and Transmitting

Although Opportunity Fund provides the information accessible on the site for your personal, non-commercial use, Opportunity Fund retains all property rights, including, without limitation, property rights under U.S. and international copyright law, to all such information. Without the prior express written permission of Opportunity Fund, you MAY NOT do any of the following: (A) hyperlink to the site, whether to its homepage or to an interior page; (B) include information from the site on another site, on a server computer, or in documents; (C) modify or re-use the information from the site; or (D) transmit any commands, codes or information to the site, with the exception of those commands necessary to view the site. Opportunity Fund reserves all other rights.

Do not transmit to the site or to any Opportunity Fund personnel, any pornographic, obscene, profane, defamatory, libelous, threatening, or unlawful material or any unsolicited commercial communications. Do not transmit to the site or to any Opportunity Fund personnel any material that could constitute or encourage unlawful conduct that would be considered a criminal offense, give rise to civil liability, or otherwise violate any law or regulation. Notwithstanding the fact that Opportunity Fund, or other parties involved in creating, producing, or delivering the site, may monitor or review any transmissions to the site or to Opportunity Fund personnel, Opportunity Fund and such other parties assume no responsibility or liability that may arise from the content thereof, including, without limitation, claims for defamation, libel, slander, obscenity, pornography, profanity, or misrepresentation.

By entering the site you acknowledge and agree that any communication or material you transmit to the site or Opportunity Fund, in any manner and for any reason, will not be treated as confidential or proprietary. Furthermore, you acknowledge and agree that any materials you transmit to Opportunity Fund may be used by Opportunity Fund, anywhere, anytime and for any reason whatsoever.

By entering the site you acknowledge and agree that any communication or material you transmit to the site or Opportunity Fund, in any manner and for any reason, will not be treated as confidential or proprietary. Furthermore, you acknowledge and agree that any materials you transmit to Opportunity Fund may be used by Opportunity Fund, anywhere, anytime and for any reason whatsoever.

Copyright and Trademark Notice

Opportunity Fund is the copyright owner for everything on the site or has the permission to use the material on the site. No portion of the site, including, without limitation, the text or images may be used in any manner, or for any purpose, without the prior express written permission of Opportunity Fund, except as provided herein. The compilation of all content on the site is the exclusive property of Opportunity Fund and is protected by U.S. and international copyright laws. All software used on the site is the property of Opportunity Fund or its software suppliers and is protected by U.S. and international copyright laws.

By entering the site you acknowledge and agree that each name, logo, trademark, or service mark contained on the site is owned or licensed by Opportunity Fund and may not be used by you without the prior written approval of Opportunity Fund. All names, logos, trademarks or service marks that includes the SoftBank brand (“SoftBank”/ “SB”) is owned and licensed by SoftBank Group Corp. and may not be used by you without the prior written approval of SoftBank Group Corp. Opportunity Fund will aggressively enforce its intellectual property rights to the full extent of the law. Information or images of places or people are either the property of Opportunity Fund or used on the site by Opportunity Fund with permission. Your use of any such materials is prohibited unless specifically permitted by Opportunity Fund. Any unauthorized use of such materials may subject you to penalties or damages, including, without limitation, those related to violation of trademarks, copyrights, privacy and publicity rights.

Restricted Use of Site Materials

Opportunity Fund grants you a limited license to access and make use of this site. For your personal use only, you may print copies of the information from the site and you may store information from the site on your own computer. You may not modify the site, or any portion thereof, for any reason. Any unauthorized use terminates the permission or limited license granted by Opportunity Fund. Opportunity Fund reserves all other rights.

Limitations on Liability

By entering the site you acknowledge and agree that your use is at your own risk and that none of the parties involved in creating, producing, or delivering the site is liable for any direct, incidental, consequential, indirect, or punitive damages, or any other losses, costs, or expenses of any kind (including legal fees, expert fees, or other disbursements) that may arise, directly or indirectly, through access to the site, use or browsing of the site, or through your downloading of any text or images, from the site.

Applicable Law and Jurisdiction

By visiting the site, you agree that the laws of the State of New York, without regard to principles of conflict of laws, will govern these Terms and Conditions and any dispute of any sort that may arise between you and Opportunity Fund. You hereby consent to the jurisdiction of the federal and state courts in New York for the purpose of resolving any dispute in connection with your visit to the site. Opportunity Fund may seek injunctive or other appropriate relief in any state or federal court in the State of New York, and you consent to exclusive jurisdiction and venue in such court.

Severability

If any of the Terms and Conditions shall be deemed invalid, void, or for any reason unenforceable, such condition shall be deemed severable and shall not affect the validity and enforceability of any of the remaining Terms and Conditions.

No Offer

The distribution to you of the information included on this site is made for informational purposes only and does not constitute an offer to sell or a solicitation of an offer to buy limited partnership interests in SBOF. The information on this site is not intended to be relied upon as the basis for an investment decision, and is not, and should not be assumed to be, complete. The contents of the information included on this site are not to be construed as legal, business or tax advice, and a prospective investor in SBOF should consult its own attorney, business advisor and tax advisor.

No Reliance

None of SoftBank Group Corp. (together with its subsidiaries, “SoftBank”) or the Opportunity Fund or any of their applicable affiliates makes any representations or warranties, express or implied, as to the accuracy or completeness of the information included on this site. SoftBank, the Opportunity Fund and their applicable affiliates will not be liable with respect to use or reliance upon any of the information included on this site in the evaluation of a potential investment in the SBOF or otherwise with the SBOM, SoftBank or any of their applicable affiliates. The information included on this site speaks as of the date hereof, or where applicable as of the date indicated herein, and none of SoftBank, the Opportunity Fund or their respective affiliates, members, partners, stockholders, managers, directors, officers, employees or agents have any obligation to update any of the information included on this site.

Date and Accuracy of Information

The information included on this site contained herein speaks as of the date such information was uploaded or as of the specific date(s) noted herein, as applicable. The Opportunity Fund, SoftBank and their respective affiliates, members, partners, stockholders, other beneficial owners, managers, directors, officers, employees, representatives, advisers and agents do not have any obligation to update any of the information included on this site. None of the Opportunity Fund, SoftBank or any of their applicable affiliates makes any representation or warranty, express or implied, as to the accuracy or completeness of the information contained herein, and nothing contained herein should be relied upon as a promise or representation as to past or future performance of SBOF, any investment or any other entity. The Opportunity Fund, SoftBank or any of their applicable subsidiaries or affiliates, and its and their respective members, partners, stockholders, other beneficial owners, managers, directors, officers, employees, representatives, agents and advisors advisers cannot be held liable for the use of, and reliance upon, such materials and information and any opinions, estimates, forecasts and findings contained herein.

Recipients of this information included on this site should make their own investigations and evaluations of the information included on this site and should note that such information included on this site may change materially.

References to any specific investments of SBOF, to the extent included herein, are presented to illustrate SBOM’s investment process and operating philosophy only and should not be construed as a recommendation of any particular investment or security. The investment performance of individual investments in SBOF may vary and the performance of the selected transactions is not necessarily indicative of the performance of all of the applicable prior investments. The specific investments identified and described herein do not represent all of the investments made by SBOM, and no assumption should be made that investments identified and discussed herein were or will be profitable. There can be no assurance that any pending transaction will be completed on the current terms of the agreement or at all.

Third-party logos included herein are provided for illustrative purposes only. Inclusion of such logos does not imply endorsement by such firms or businesses. There is no guarantee that SBOF or its portfolio companies will work with any of the firms or businesses whose logos are included herein in the future.

Suitability

None of SoftBank, the Opportunity Fund or any of their applicable affiliate represents that the information included on this site is all-inclusive or that the information included on this site contains all information that may be desirable, necessary or required to properly evaluate a potential investment with SBOF.

The information included on this site is directed at and available only to persons to whom the information included on this site can be lawfully communicated without SoftBank, the Opportunity Fund and/or any respective affiliate requiring approval or any other action being taken to permit the information included on this site being made available to such persons where approval or other action is required. The information included on this site is not directed at and is not to be accessed by any other person. Persons who obtain access to the information included on this site should observe any restrictions imposed in the jurisdiction in which the information included on this site is accessed. Investments or investment services referred to in the information included on this site are only available on an invitation basis and are subject to procedures to assess status and suitability. For the avoidance of doubt, investments or investment services referred to in the information included on this site are not available to private or retail customers.

SoftBank and/or SBOM do not and will not act for you. In particular, SoftBank and/or SBOM do not and will not advise you or provide any other investment services to you and will not be responsible for providing you with any protections. No employee of, or other person associated with, SoftBank and/or SBOM has the authority to represent otherwise.

The information included on this site is not directed at any person domiciled or registered in any jurisdiction in which it is unlawful for them to receive the information included on this site.

If you have any questions, you may reach us at SBOFcompliance@softbank.com.

Data Protection Notice and Privacy Policy

Effective as of January 1, 2023.

SB Opportunity Fund LLC and its affiliates (together, “we” or the “Company”) want you to be familiar with how we collect, use, disclose, or otherwise process personal information.  We hold certain 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 an event we are hosting. We also collect your information where you are involved in a company we interact with as part of our business operations or investment activities. We are what is known as a “data controller” or “data user” or its functional equivalent in respect of that information. 

This data protection notice and privacy policy (the “Notice”) sets out the ways in which we have collected, used, disclosed, or otherwise processed personal information in the preceding 12 months and beyond as well as how we will collect, use, or otherwise process personal information in the future.  This Notice is neither intended for our employees or other members of our staff nor investors in funds managed by SoftBank.

We will communicate changes and updates to this Notice by posting an updated version of the Notice (with an updated date) on our website.  Please note that we may update this Notice from time to time and, if we do, appropriate steps will be taken to bring material amendments to your attention.

Any questions about this Notice may be directed to sbia-data-requests@softbank.com.

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.

What categories of personal information do we collect and from what sources?

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.

• For California residents, Cal. Civ. Code § 1798.80 Personal Information (which may overlap with other categories)           (e.g., name, signature, physical characteristics or description, address, telephone number) – When, for example, you visit our offices, provide such details for our business interactions, etc.

• 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., offerings considered, obtained, purchased) – 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 the Company’s 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 give us your business card or other contact details, connect with us on social media or publicly post such information online, or otherwise provide your professional background in connection with our relationship.

• Preferences (e.g., professional or personal interests, affinity groups, preferences regarding travel, hours, food for office visits or Company events, other details available on websites used for social media or networking purposes, etc.).

We may also receive personal information from:

• Your employer, e.g., where we interact with them 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

• Our affiliated companies, 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

• Automated technologies on the Company’s electronic resources, for example, to track RSVPs, logins, or activity across our network or applications

• Recording technologies installed by the Company, for example, CCTV in common areas of the Company’s facilities, voicemail technologies, webcams, audio-visual recording technologies, and bluetooth technologies 

Where we collect your sensitive personal information (which, depending on the requirements set out in relevant applicable data protection law, may include for example, your state identification card, financial information, and sexual orientation), we will process it in accordance with the requirements of 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.   

For what purposes do we process personal information?

We process this personal information for the following purposes:

• Providing the functionality of our website and other interactions with you and fulfilling your requests.

  • To provide the functionality of our website and related services;

  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online forms, send us emails, ask us questions, request connections, or when you request other information about us; and

  • To send administrative information to you, such as changes to our terms, conditions, and policies

We will engage in these activities to manage our contractual relationship and/or to comply with a legal obligation.

• Providing you with our newsletter and/or other marketing materials.

  • To send you marketing related emails, with information or news about the Company and its activities such as updates or upcoming events.

We will engage in this activity with your consent or where we have a legitimate interest.

• Managing our business operations.

  • Facilitate, manage, and protect our business operations and investment activities

  • Enable the Company to comply with contractual obligations

  • Facilitate communication, interaction, and collaboration

  • Ensure our premises and confidential information are kept secure

  • Conduct data analysis, for example, to improve the efficiency of our business operations and services and identify opportunities to develop our business

  • Engage in Company marketing, promotion, sponsorship, and event planning

  • Conduct audits to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements

  • Respond to and manage litigation, investigations, inspections, complaints, or claims involving the Company, and other legal disputes and inquiries, and to meet legal and regulatory requirements

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

We engage in these activities to manage our contractual relationship, to comply with a legal obligation, and/or based on our legitimate interest.

• Monitoring, Security, and Compliance.

  • Maintain security of staff and visitors and communicate incidents to ensure safety, including in the event of an emergency

  • Identify, monitor for, and mitigate against compliance risks, high-risk events and behaviors, and contravention of the Company’s policies and procedures

  • Monitor and protect the Company’s internal networks, electronic communications, endpoint assets, applications, and business data

  • Protect the safety and security of the Company’s facilities, including controlling access to secure facilities and preventing illicit activity

  • Administer the Company’s whistleblower hotline

  • Report suspected criminal conduct to law enforcement and cooperate in investigations

  • Help the Company comply with legal, regulatory, and reporting requirements applicable to its operations and investment activities

    • Exercise the Company’s rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel

We engage in these activities as necessary or appropriate to manage our contractual relationship, to comply with a legal obligation, and/or based on our legitimate interest.

We may aggregate and/or anonymize personal information so that it will no longer be considered personal information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

California Residents:  At times, the Company converts personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”).  The Company maintains Deidentified Information in a deidentified form and does not attempt to reidentify it, except that the Company 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.  The Company prohibits vendors, by contract, from attempting to reidentify the Company’s Deidentified Information. 

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 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.

California Residents: The following list details which 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; the Public; Legal Obligations and Rights, Corporate Transactions.

• Internet or other electronic network activity information – To Service providers; Affiliated companies; 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).

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 of your country, including to SoftBank Group companies and the third parties described above. This may include transfers to: the United Kingdom, the United States, and Japan.

Where 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 entering into appropriate data transfer agreements with the recipients of your personal information where possible.

If we are required to transfer your sensitive personal data or information to the persons set out above, we will do so in accordance with applicable data protection law (including obtaining express written consent, where required).

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).

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

You may have certain rights under applicable data protection legislation in your country in relation to the personal information about you that we process.  For example:

• Right to know what personal information is processed

• Right to access to your personal information

• Right to object to the processing of your personal information

• Where we have obtained your consent to process your personal information, the right to withdraw that consent

• Right to have your personal information rectified

• Right to have your personal information erased

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

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

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

We review and verify requests to protect your personal information. We apply non-discriminatory principles in actioning data protection rights requests, in accordance with applicable data protection laws and principles.

You can seek to exercise your data protection rights (where applicable) by contacting the Compliance team at sbia-data-requests@softbank.com or call 1 (800) 209-3191.

California Residents:  Verification Process.  To verify your identity when you make a request to know, correct, or delete your personal information, 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 make a deletion request, we may ask you to verify your request before we delete your Personal Information.  If we cannot verify your identity based on the above, we may ask you for additional verification information.  If we do so, we will not use that information for any purpose other than verification. If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.  Authorized Agents.  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.

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.

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.

Questions or complaints

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

Please also contact us at the email address above if you have a disability and require an alternative format of this notice.

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).  In California, this is the California Privacy Protection Agency.  Their website is available at https://cppa.ca.gov/.