Terms and Conditions of Use
The information offered by LDH Growth Corp. I, LDH Sponsor LLC, SoftBank Group Corp., SoftBank Latin America Fund
L.P. and their respective affiliates, officers, directors, managing partners, partners, employees and
representatives (“LDH”, “we”, “us”, or “our”) and/or its advisory affiliates, SB Group US, Inc, and its directors,
managing partners, partners, employees and representatives (together with its affiliates and subsidiaries “SBGI”)
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 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 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 LDH. The information provided on this page 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.
While LDH uses reasonable efforts to help ensure that all material on this site is correct, accuracy cannot be
guaranteed and neither 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
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. Neither LDH nor
assumes 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. LDH and SBGI 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.None of LDH and SBGI warrant the accuracy, adequacy or completeness of the information and material
contained on the site and expressly disclaim 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 LDH and SBGI. 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.None
of LDH and SBGI are 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 the LDH or SBGI have 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 LDH and SBGI provide the information accessible on the site for your personal, non-commercial use, LDH
and SBGI retain 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 LDH and/or SBGI, 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. LDH and SBGI reserve all other rights.Do not transmit to the site or to
any LDH or SBGI 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 LDH or SBGI 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 LDH or SBGI, or
other parties involved in creating, producing, or delivering the site, may monitor or review any transmissions to
the site or to LDH or SBGI personnel, LDH or SBGI 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 LDH or SBGI, 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
LDH and SBGI may be used by LDH and SBGI, anywhere, anytime and for any reason whatsoever.Although the site may be
linked to other sites upon permission, LDH and SBGI are not, directly or indirectly, implying any approval,
association, sponsorship, endorsement, or affiliation with the linked site, unless specifically stated therein. By
entering the site you acknowledge and agree that LDH and SBGI have not reviewed all the sites that may be linked
to the site and is not responsible for the content of any off-site pages or any other site linked to the site. You
further acknowledge and agree that when you follow links to pages not maintained on the site, you do so at your
COPYRIGHT AND TRADEMARK NOTICE
SoftBank Global Advisors (“SBGA”) 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 LDH or SBGA, except as provided
herein. The compilation of all content on the site is the exclusive property of LDH and SBGI and is protected by
U.S. and international copyright laws. All software used on the site is the property of LDH and SBGA 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 LDH or
SBGA and may not be used by you without the prior written approval of LDH and SBGA. 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. LDH and SBGI 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 LDH or SBGA or used on the site by LDH and SBGA with permission. Your
use of any such materials is prohibited unless specifically permitted by LDH and SBGA. 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
LDH and SBGA grant 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 LDH and SBGA. LDH and SBGA 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 LDH or
SBGI. 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. LDH and SBGI 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.
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
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 securities of LDH, any strategy managed by
SBGA or any other affiliated investment vehicle. 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 LDH should consult its own attorney, business advisor and tax advisor.
None of SoftBank Group Corp. (together with its subsidiaries), LDH or SBGI 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 Group Corp., LDH and SBGI 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 LDH or otherwise with SBGI, SoftBank Group Corp. 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 Group Corp., LDH or SBGI 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. LDH, SBGI, SoftBank Group Corp. 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 LDH, SBGI, SoftBank Group Corp. 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 LDH, any
investment vehicle managed by SBGI or any other entity. LDH, SBGI, SoftBank Group Corp. 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 LDH or any other SBGI managed investment vehicle, to the extent included
herein, are presented to illustrate LDH or SBGI’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 LDH or any other strategy managed by SBGI and any affiliated investment vehicle 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 SBGI, 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 LDH, any strategy managed by SBGI or any
other affiliated investment vehicle or their respective portfolio companies will work with any of the firms or
businesses whose logos are included herein in the future.
None of SoftBank Group Corp., LDH or SBGI 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 LDH, any investment
vehicle managed by SBGI or any other affiliated investment vehicle.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 Group Corp., LDH or SBGI 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 Group Corp., LDH and/or SBGI do not and will not act for you. In particular,
SoftBank Group Corp. LDH and/or SBGI 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 Group Corp. LDH and/or SBGI 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.
Last Updated: April 21, 2023
LDH Growth Corp. I, LDH Sponsor LLC, SoftBank Group Corp., SoftBank Latin America Fund L.P. and their respective
affiliates and/or its advisory affiliates, SB Group US, Inc., (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.
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.
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 email@example.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
- 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
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.
We will engage in these activities to manage our contractual relationship and/or to comply with a legal
- 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
- Providing you with our newsletter and/or other marketing materials.
We will engage in this activity with your consent or where we have a legitimate interest.
- To send you marketing related emails, with information or news about the Company and its activities such
as updates or upcoming events.
- Managing our business operations.
We engage in these activities to manage our contractual relationship, to comply with a legal obligation,
and/or based on our legitimate interest.
- 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
- Monitoring, Security, and Compliance.
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.
- 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 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
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
- We disclose your personal information to such providers subject to written contracts in compliance with
- 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.
- 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
- 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
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
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
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
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
- 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
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 firstname.lastname@example.org
or call 1
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.
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 email@example.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
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):