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© 2021 SB Investment Advisers
  • Terms and Conditions of Use
  • Regulatory
  • Conduct
    • Disclaimers
    • Material to be Consulted in its Entirety
    • Linking, Posting and Transmitting
    • Copyright and Trademark Notice
    • Restricted Use of Site Materials
    • Limitations on Liability
    • Applicable Law and Jurisdiction
    • Severability
    • Legal Disclaimers
    • No Offer
    • No Reliance
    • Date and Accuracy of Information
    • Suitability
    • Data Protection Notice
    • What personal information do we collect and use?
    • For what purposes do we process personal information?
    • Who do we share your personal information with?
    • Transfers of your personal information overseas
    • How long do we retain your personal information?
    • Your rights in relation to the personal information we process about you
    • Other individuals’ personal information
    • Questions or complaints
    • What is personal information?
    • What personal information do we collect and use?
    • How do we use your personal information?
    • Will you rely on my consent?
    • Who do we share your personal information with?
    • Transfers of your personal information
    • How long do we retain your personal information?
    • Your rights in relation to the personal information we process about you
    • Security
    • Questions or complaints
    • What Are Cookies?
    • How Does SoftBank Investment Advisers Use Cookies?
    • How Can Users Change Their Cookie Settings?
    • Overview
    • Governance
    • Tax Risk Management
    • Working with tax authorities
    • Attitude to tax planning
    • Tax risk appetite
    • Legal
    • Information for Disclosing Market Participants
    • FRC Stewardship Code Disclosure
    • Shareholder Rights Directive (Directive (EU) 2017/828) ("SRD II")
    • Registered address
    • What is harassment?
    • What is bullying?
    • If you are being harassed or bullied
    • Protection and support for those involved

Terms and Conditions of Use

The information offered by SoftBank Vision Fund L.P. (together with, as the context may require, any parallel fund, feeder fund, co-investment vehicle or alternative investment vehicle, the “Fund”) and/or its advisory affiliates, SB Investment Advisers (UK) Limited, SB Investment Advisers (US) Inc. or SB Investment Advisers (Japan) Corp. (collectively, “SoftBank Investment Advisers”) 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.

Disclaimers

While SoftBank Investment Advisers use reasonable efforts to help ensure that all material on this site is correct, accuracy cannot be guaranteed and SoftBank Investment Advisers make no representations or warranties as to the accuracy, reliability or completeness of any information at this site. Any contents at 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. SoftBank Investment Advisers further assume 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. SoftBank Investment Advisers 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.

SoftBank Investment Advisers do not 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.

SoftBank Investment Advisers are 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 SoftBank Investment Advisers 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.

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

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 SoftBank Investment Advisers provide the information accessible on the site for your personal, non-commercial use, SoftBank Investment Advisers 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 SoftBank Investment Advisers, 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. SoftBank Investment Advisers reserve all other rights.

Do not transmit to the site or to any SoftBank Investment Advisers 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 SoftBank Investment Advisers 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 SoftBank Investment Advisers, or other parties involved in creating, producing, or delivering the site, may monitor or review any transmissions to the site or to SoftBank Investment Advisers personnel, SoftBank Investment Advisers 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 SoftBank Investment Advisers, 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 SoftBank Investment Advisers may be used by SoftBank Investment Advisers, anywhere, anytime and for any reason whatsoever.

Although the site may be linked to other sites upon permission, SoftBank Investment Advisers 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 SoftBank Investment Advisers 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 own risk.

Copyright and Trademark Notice

SoftBank Investment Advisers are the copyright owners for everything on the site or have 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 SoftBank Investment Advisers, except as provided herein. The compilation of all content on the site is the exclusive property of SoftBank Investment Advisers and is protected by U.S. and international copyright laws. All software used on the site is the property of SoftBank Investment Advisers or their 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 may not be used by you without the prior written approval of SoftBank Investment Advisers. SoftBank Investment Advisers will aggressively enforce their intellectual property rights to the full extent of the law. Information or images of places or people are either the property of SoftBank Investment Advisers or used on the site by SoftBank Investment Advisers with permission. Your use of any such materials is prohibited unless specifically permitted by SoftBank Investment Advisers. 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

SoftBank Investment Advisers 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 SoftBank Investment Advisers. SoftBank Investment Advisers reserve 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 SoftBank Investment Advisers. 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. SoftBank Investment Advisers 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.

Legal Disclaimers

THE INFORMATION CONTAINED HEREIN (THE “INFORMATION”) IS SUBJECT TO THE FOLLOWING DISCLAIMERS, NOTES AND QUALIFICATIONS.

No Offer

The distribution to you of the Information 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 the Fund. The Information 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 are not to be construed as legal, business or tax advice, and each prospective investor in the Fund should consult its own attorney, business advisor and tax advisor as to legal, business and tax advice.

No Reliance

None of SoftBank Group Corp. (together with its subsidiaries, “SoftBank”), the Fund, SB Investment Advisers (UK) Limited (the “Manager”), SVF GP (Jersey) Limited (the “General Partner”) or any of their applicable affiliates makes any representations or warranties, express or implied, as to the accuracy or completeness of the Information. SoftBank, the Fund, the Manger, the General Partner and their applicable affiliates will not be liable with respect to use or reliance upon any of the Information in the evaluation of a potential investment in the Fund or otherwise with the Manager, the General Partner, SoftBank of any of their applicable affiliates. The Information speaks as of the date hereof, or where applicable as of the date indicated herein, and none of SoftBank, the Manager, the General Partner, the Fund or their respective affiliates, members, partners, stockholders, managers, directors, officers, employees or agents have any obligation to update any of the Information.

Date and Accuracy of Information

The Information contained herein speaks as of the date such information was uploaded or as of the specific date(s) noted herein, as applicable. The Fund, the Manager, the General Partner, 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. None of the Fund, the Manager, the General Partner, 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 the Fund, any investment or any other entity. The Fund, the Manager, the General Partner, 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 should make their own investigations and evaluations of the Information and should note that such Information may change materially.

References to any specific investments of the Fund, to the extent included herein, are presented to illustrate the Manager’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 the Fund 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 the Manager, and no assumption should be made that investments identified and discussed herein were or will be profitable. Certain investments included herein have not yet been acquired by an SBIA fund and are subject to pending regulatory approvals. 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 the Manager 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 Fund, the Manager, the General Partner or any of their applicable affiliate represents that the Information is all-inclusive or that the Information contains all information that may be desirable, necessary or required to properly evaluate a potential investment with the Fund.

With respect to the United Kingdom, the Information is directed only at (i) persons falling within any of the categories of “investment professionals” as defined in Article 14(5) of the Financial Services and Markets Act 2000 (Promotion of Collective Investment Schemes) (Exemptions) Order 2001, as amended (the “CIS Order”) and Article 19(5) of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005, as amended (the “FPO”); (ii) persons falling within any of the categories of “high-net-worth entities” as described in Article 22(2) of the CIS Order and Article 49(2) of the FPO; (iii) any person who is a professional client (as defined under the FCA rules); (iv) or any other person to whom it may otherwise lawfully be communicated (all such persons together being referred to as “Relevant Persons“).

Any investment or investment activity to which this Information relates is available only to Relevant Persons on an invitation basis and will be engaged in only with such Relevant Persons. Furthermore, procedures are in place to assess the status of investment participants to ensure that they are Relevant Persons. Accordingly, persons who are not Relevant Persons (in particular, persons who would be classified as “retail clients” under the FCA rules) must not rely on on this Information.

In the case of persons outside the United Kingdom, the Information is directed at and available only to persons to whom the Information can be lawfully communicated without SoftBank, the Manager, the General Partner and/or any respective affiliate requiring approval or any other action being taken to permit the Information being made available to such persons where approval or other action is required. The Information is not directed at and is not to be accessed by any other person. Persons who obtain access to the Information should observe any restrictions imposed in the jurisdiction in which the Information is accessed. Investments or investment services referred to in the Information 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 are not available to private or retail customers.

SoftBank and/or the Manager do not and will not act for you. In particular, SoftBank and/or the Manager 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 the Manager has the authority to represent otherwise.

The Information is not directed at any person domiciled or registered in any jurisdiction in which it is unlawful for them to receive the Information.

Data Protection Notice

Data Protection Notice

SoftBank Investment Advisers hold certain personal information as part of our interactions with you, such as when you visit our offices, send us an email 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 investment activities. We are what is known as a “data controller” or “data user” in respect of that information.

“Personal information” is any information that relates to, describes, identifies or can be used, directly or indirectly, to identify an individual, such as name, address, date of birth, personal identification numbers, sensitive personal information, and economic information).

This data protection notice (the “Data Protection Notice” or the “Notice”) sets out the ways in which we will process that personal information.

Please note that we may update this Data Protection Notice from time to time and, if we do, appropriate steps will be taken to bring material amendments to your attention. This notice was last updated/reviewed: January 2020.

Any questions about this Data Protection Notice may be directed to [email protected].

This Notice is not intended for members of staff of SoftBank Investment Advisers or investors in the Vision Fund or any other funds managed by SoftBank Investment Advisers (who are subject to other notices specifically applicable and notified to them).

What personal information do we collect and use?

When you interact with us, for example by visiting our offices, corresponding with us by email, post or telephone, or speaking to us at an event or meeting, we collect personal information about you. Where we collect your sensitive personal information (which, depending on the requirements set out in relevant applicable data protection law, may include your passwords, financial information, biometric information, sexual orientation, medical records and history or information about physical, physiological and mental health conditions), we will process it in accordance with the requirements of applicable data protection law (including obtaining express written consent, where required).

When you visit our offices, we may process the following personal information about you:

  • Identifiers (e.g. your name, email address, and employer);
  • Visual and audio information (e.g. CCTV footage of you in our offices);
  • Geolocation data (e.g. the time and date of your visit(s))
  • Other security information we need for our records (e.g. your host at SoftBank Investment Advisers, and details about any non-disclosure agreements you have signed).

We need this information in order to give you access to our offices. If you do not provide it, you may not be permitted to access our offices.

If you are in our offices and log on to our guest WiFi, we will process your internet or other network activity information (e.g. IP address and device details). Further details about the use of our guest WiFi may be found in the Guest WiFi Terms of Use.

If you send us an email, we will collect any personal information included in your correspondence with us, including identifiers (e.g., your name and contact details).

If you give us your business card or other contact details, we may process personal information such as your:

  • Identifiers (e.g. name, job title, contact details, social media profiles)
  • Professional or employment information (e.g. employer and professional history)
  • Inferences drawn from other personal information (e.g. other details available on websites used for social media or networking purposes, such as LinkedIn).

This information may also be provided to us by your employer where we interact with them as part of our investment activities.

Depending on the nature of our relationship with you, we may have collected any of the information in these categories from you in the past twelve months (identifiers, internet or other network activity, geolocation data, visual and audio information, professional or employment information, and inferences drawn from other personal information).

For what purposes do we process personal information?

We process this personal information in our legitimate interests, which include:

  • ensuring our investor and business contact records are up-to-date,
  • for the management of our business,
  • identifying opportunities to develop our business,
  • providing a guest WiFi network for visitors to our offices,
  • in accordance with our internal compliance policies,
  • ensuring our premises and confidential information are kept secure, and
  • keeping a log of visitors to our offices.

We may also be required to process your personal information in accordance with our legal and regulatory obligations. If we are required to process your sensitive personal information, we will process it in accordance with applicable data protection law (including obtaining express written consent, where required).

We may provide you with information about our products and services and other information which we think you may find interesting. We may send you such information by post, e-mail and/or telephone, unless you have asked us not to do so.

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

Who do we share your personal information with?

For the purposes set out in the “For what purposes do we process personal information?” section above, we may share your personal information (as set out in the “What personal information do we collect and use?” section above) within the SoftBank Group (click here for further details), and with certain third parties, such as:

  • service suppliers: who provide (for example) our email, hosting, visitor log-in and client relationship management software,
  • legal and professional advisors: in order to seek advice in relation to our business, and
  • regulators and law enforcement agencies: to respond to investigations, court orders, legal process, or to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person.

For the purposes of Japanese data protection law requirements, SB Investment Advisers (UK) Limited is responsible for the joint-use of your personal data.

For California residents, in the preceding 12 months, we may have disclosed personal information listed in any of the categories in the " What personal information do we collect and use?" section above for business purposes. We have not sold personal information in the preceding 12 months.

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring person or entity.

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).

Transfers of your 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 UK, the US, Japan, Jersey, India, the United Arab Emirates (whether to an economic free zone or otherwise), Singapore, the Kingdom of Saudi Arabia, the People’s Republic of China and Hong Kong.

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.

How long do we retain your personal information?

We will retain your personal information only as long as is necessary for the purpose for which we have collected it or as otherwise authorised, in accordance with our internal data retention policies.

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:

  • the 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,
  • the right to request access to your personal information,
  • the right to have your personal information rectified,
  • the right to have your personal information erased,
  • the right to request that your personal information is only used for restricted purposes,
  • the right to inform us that you do not wish to receive marketing information, and
  • (in some circumstances) the right to require certain of your personal information to be transferred to you or a third party.

California residents may also request certain information about our disclosure of personal information during the prior year.

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 SBIA Compliance team at [email protected].

Other individuals’ personal information

If you intend to provide us with personal data (including any sensitive personal information if applicable) about other individuals, you must ensure that such individuals are aware of the matters in this Data Protection 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 SBIA Compliance team at [email protected] or +1 (650) 562-8100.

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

If you are an Indian resident, you may also contact our Grievance Officer, Simon Gregory at [email protected].

If you are a Singapore resident, you may also contact our Singapore Data Protection Officer at: [email protected].

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 the UK, this is the Information Commissioner’s Office. Their website is available at https://ico.org.uk.

Global Candidate Data Protection Notice

This candidate data protection notice (the “Candidate Data Protection Notice” or the “Notice”) has been sent to you because you have provided (or someone has done so on your behalf, for example a recruitment agency) SB Investment Advisers (UK) Limited or its overseas affiliates (referred to in this notice as the “Company”) with personal information in respect of a potential vacancy or role at the Company or within its Group.

The Company is what is known as a “data controller”, "data user" or "personal information handling business operator" (as the case may be under applicable law) in respect of any personal information we hold about you. This Candidate Data Protection Notice details the ways in which we will process your personal information during the course of your application or recruitment (and thereafter whether successful or unsuccessful).

Please note that the Company may update this Candidate Data Protection Notice from time to time and, if it does, appropriate steps will be taken to bring material amendments to your attention.

Please direct any questions regarding this Candidate Data Protection Notice to [email protected]

What is personal information?

“Personal information” means information relating to a living individual who can be identified, directly or indirectly, from that information (or from that information and other information in our possession). Personal information can be factual (for example, a name, address or date of birth) or it can be an opinion about a person, their actions and behaviour. Personal information may be held on paper, or on a computer or other media.

Some types of personal information are classed as “special category” or "sensitive" personal information. This can, subject to applicable law include, information about a person's racial or ethnic origin, political opinions, religious or similar beliefs, inherent social status, trade union membership, genetics, physical or mental health or condition, results of medical check – ups, criminal history, the fact of having suffered damage caused by a crime, sex life or sexual orientation. Special categories of personal information can only be processed under strict conditions, such as the express permission of the person concerned.

Personal information is subject to certain legal safeguards specified in the applicable data protection legislation. The applicable legislation prescribes the way in which the Company and its staff may collect, retain and handle personal information.

The Company will comply with the requirements of applicable data protection legislation and all employees who handle personal information in the course of their work must also comply.

What personal information do we collect and use?

When you engage with us (whether directly or indirectly) through the recruitment / application process we may collect the following personal information (subject to applicable local law):

  • basic information about yourself, such as name, nickname or alias, contact details including postal address, telephone number, and email address, government issued identification information, gender, signature, image and information provided to verify your identity;
  • information regarding your employment and educational history, any role or roles for which you are applying or being considered and your relevant personal interests, job performance or evaluations, membership in professional organisations, professional certifications, attributes and career aspirations and plans;
  • other information about yourself that you provide in a CV or similar document;
  • other information from any interview notes and records;
  • results of pre-employment assessments and questionnaires, including where permitted by law, criminal history, civil litigation, and credit checks; outstanding judgments, liens, and arrangements with creditors; and discipline imposed by regulatory or licensing authorities or by previous employers; and
  • only to the extent permitted by law, information regarding racial or ethnic origin, national origin, ancestry, age, gender, gender identity, gender expression, sexual orientation, military and veteran status, medical condition, and physical or mental disability (collected in accordance with local law, for example by obtaining written consent where required).

The Company needs to process this information in order to review your application, contact you in respect of such application and conduct recruitment. If you do not provide the personal information the Company requests from you, the Company may not be able to progress your application.

How do we use your personal information?

We will, subject to applicable law, process information about you pursuant to our legitimate interest of managing the application and recruitment process and assessing you for employment or other engagement, to communicate with you; to demonstrate your agreement to, or acceptance of, employment documents presented to you; to conduct fitness-for-duty examinations; to check your honesty, integrity and reputation, competence, capability and financial soundness; to monitor and improve our recruitment process and for related purposes (which may where permitted by local law include equality of opportunity monitoring); for recordkeeping purposes; compliance with law and regulation; for internal operations, including audits, investigations, research, statistical and survey purposes; to protect the safety and security of the Company’s facilities, ensuring the security of our business; for purposes relating to legal claims made by or against us; to manage licenses, permits and authorisations applicable to the Company’s business operations; and in connection with a merger, acquisition, sale or restructuring of all or a portion of our business or assets.

If you are unsuccessful in your application, we may also retain your personal information and use it to assess your suitability for future positions and roles within the organisation.

When processing is necessary for the legitimate interests of the Company, the Company ensures that processing is conducted in such a manner that the Company complies with the applicable data protection legislation (e.g. by, where applicable, outweighing any individual's interest).

Will you rely on my consent?

We will not rely on your consent to collect, use or otherwise process your personal information, other than: (i) where consent to the processing described in this notice is required by local law; (ii) in certain cases in respect of special category or sensitive personal information; and (iii) in specific circumstances where our processing is genuinely optional – in those circumstances we will ask for your separate consent (which is voluntary and can be withdrawn at any time). 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.

Who do we share your personal information with?

We share certain of your personal information, as applicable in your jurisdiction, with the following categories of third parties who will jointly use your personal information for the following reasons:

  • other members of the Group for the purposes of managing the Group’s business and its staff;
  • candidate management companies during the interview, recruitment and hiring processes, including the use of candidate database and management software such as Lever and recruitment agencies;
  • legal and professional advisers when requesting and receiving advice; and
  • other third party service providers as we may require from time to time.


In respect of the sharing and joint use of your personal information the Company is responsible for the management of your personal information.

The Company may also share your personal information with third parties (including legal advisors and law enforcement agencies) in order to respond to investigations, court orders, legal process, or to investigate, prevent or take action regarding illegal activities, suspected fraud, or situations involving potential threats to the physical safety of any person, or as otherwise required by the applicable law.

If the Company is involved in a merger, acquisition, sale or restructuring of all or a portion of its business or assets, your personal information may be transferred to the acquiring person or entity. In circumstances where the identity of the data controller, personal information handling business operator or data user (as the case may be under applicable law) of your personal information changes as a result of any such transaction, you will be notified, and provided with details of any choices you may have regarding the processing of your personal information.

Where we share your personal information with a third party, we require the recipients of that personal information to put in place adequate measures to protect it.

Transfers of your personal information

The Company may also transfer certain of your personal information to other members of the Group located outside of the jurisdiction in which you are based from time to time, for the purposes of the management of your assessment for employment with one of our Group entities. Such transfers shall be carried out in compliance with relevant legislation.

How long do we retain your personal information?

We will retain personal data about you throughout the application and recruitment process. Subject to applicable law, some personal data will be retained after the process ends, either because you are employed or otherwise engaged by us or, if your application is withdrawn or unsuccessful, we may retain your personal data in case a suitable alternative vacancy arises, you apply to work for us again or if a recruitment-related dispute arises between us.

The Company retains records containing personal information in line with its legal and regulatory obligations and risk management guidelines.

Please notify HR to update or correct any mistakes in the personal information that the Company processes about you.

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

You have various rights under data protection legislation regarding the personal information relating to you that the Company processes.

These may include, as applicable in your jurisdiction:

  • the right to object to the Company’s processing of your personal information and the right to request termination of the collection, process or use of your personal information;
  • the right to request access to your personal information and to request a copy of the same;
  • the right to have your personal information rectified or supplemented;
  • the right to have your personal information erased;
  • the right to request that your personal information is only used for restricted purposes;
  • the right to inform the Company that you do not wish to receive marketing information; and
  • (in some circumstances) the right to require certain of your personal information to be transferred to you or a third party.


You can seek to exercise any of these rights by contacting Compliance.

Security

We will take appropriate security measures against unlawful or unauthorised processing of your personal information, and against the accidental loss of, or damage to, your personal information.

Questions or complaints

If you have any questions or complaints regarding the Company’s processing of your personal information, in the first instance, please contact [email protected]

Complaints regarding the Company’s processing of your personal information may also be made directly to the appropriate data protection regulator, details of which can be found below:

UK

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF


Abu Dhabi Global Market

The ADGM Registration Authority
Abu Dhabi Global Markets Authorities Building
ADGM Square
Al Maryah Island
PO Box 111999
Abu Dhabi
United Arab Emirates
www.adgm.com/registration-authority


Hong Kong

Office of the Privacy Commissioner for Personal Data
12/F
Sunlight Tower
248 Queen's Road East
Wanchai
Hong Kong


Japan

The Personal Information Protection Commission
Kasumigaseki Common Gate West Tower 32nd Floor
3-2-1, Kasumigaseki
Chiyoda-ku
Tokyo, 100-0013
TEL +81 (0)3 6457 9849


Kazakhstan

The State Prosecutors Office


New York

The Federal Trade Commission
www.ftc.gov

California

The California Attorney General
www.ag.ca.gov


China
Cybersecurity Administration of China
11 Chegongzhuang Street
Xicheng District
Beijing
www.cac.gov.cn


S
ingapore

The Personal Data Protection Commission
460 Alexandra Road #10-02
PSA Building
Singapore
119963

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