SoftBank Telecom Europe Ltd.

PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY CAREFULLY

1. OUR PRIVACY STATEMENT

The protection of your personal data is of great importance to SoftBank Telecom Europe Ltd. (“Company”), a company of the SoftBank Corp. Group. This privacy policy (the “Privacy Policy”) therefore intends to inform you about how Company, established in 71-91 Aldwych, London WC2B 4HN, United Kingdom, acting as data controller, collects and processes your personal data that you submit or disclose to us. We also act as data controller when we process your personal data received or obtained through third-parties. We process this personal data in accordance with the applicable EU and Member State regulations on data protection in particular, the General Data Protection Regulation No 2016/679 (the “GDPR”).

We encourage you to read this Privacy Policy carefully. If you do not wish your personal data to be used by us as set out in this Privacy Policy, please do not provide us with your personal data. Please note that in such a case, we may not be able to provide you with our services, you may not have access to and/or be able to use some features of the Website, and your customer experience may be impacted.

If you have any queries or comments relating to this Privacy Policy, please contact sbtmgrp-gdpruk@g.softbank.co.jp.

2. HOW DO WE USE YOUR PERSONAL DATA?

We will always process your personal data based on one of the legal basis provided for in the GDPR (Articles 6 and 7). In addition, we will always process your sensitive personal data, for example, concerning your trade union membership, religious views, or health condition, in accordance with the special rules provided for in the GDPR (Articles 9 and 10).

We may collect and process your personal data for the purposes detailed below, which are required so that we can pursue our legitimate interests and provide you with adequate services and products:

  • to offer you products and services;
  • to inform you about our policies and terms;
  • to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies;
  • to provide, improve, and develop our products, services, and advertising;
  • to provide, improve, and develop our products, services, and advertising;
  • to use personal information for purposes such as data analysis, research, and audits;
  • to ensure business continuity.
  • to ensure that content from our site is presented in the most effective manner for you;
  • to notify you about changes to our service(s);
  • to manage your customer account.

We may also collect and process your personal data for the following purposes, based on the execution of our contractual relationship between you and us:

  • To process payments, orders and other services requested from you or from us.

Finally, in very specific circumstances, we may require your consent to process your personal data.

A more detailed explanation of the purposes for which we may process your personal data is written below.

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As an employee candidate, your personal data will be processed in order to enable us to consider and assess your employment application. The personal data that we may process for these purposes includes:

  • Name and surnames;
  • Position;
  • Address
  • Telephone number;
  • Family status;
  • Age/Birthday;
  • Salary;
  • Career information;
  • Certificates;
  • Reference letters;
  • Other information contained in your application.

We process your personal data in your interest, to ensure that all relevant information is taken into account in considering your application, as well as in ours, in order to enable us to make an informed decision regarding your application (Article 6(1)(f) GDPR).

Where you provide us with additional data to assess your application, we process such data based on your consent that we process the data volunteered to us (Article 6(1)(a) GDPR).

As an employee, we process your personal data for the following purposes:

  • To process your monthly salary, bonuses, allowances and calculate income taxes.
  • To manage your file, such as emergency contact details, other human resources management and administrative tasks.
  • To process your performance assessment.
  • To arrange for reimbursement of medical check-up costs, health insurance costs, and group insurance costs.
  • To authorize your business expenses and contracts on behalf of SoftBank Telecom Europe Ltd..
  • To apply for and renew documentation, such as visas, rental contract, mobile phone contract, online banking application, credit card application, insurance application, working permits and commune registration and ID of you and your families. [Only for expatriates]

In general, we process your personal data in your interest, in order to arrange for your necessary documentation with the public authorities, proceed with the payment of your salary and other allowances, and proceed with any reimbursements (Article 6(1)(f) GDPR).

Where we are obliged by our employment contract to perform these processes, such as to pay your salary, we do so in accordance with it (Article 6(1)(b) GDPR). Employment and immigration laws may also require us to process this data for you (Article 6(1)(c) GDPR).

As a business partner, customer or vendor, your personal data may be processed for the following purposes:

  • To manage the contact details of our current and future business partners, vendors and customers.
  • To help us manage and perform our current and future contracts and projects with our business partners, vendors and customers.
  • To process orders made from customers.
  • In order to achieve these purposes, we process contact detail data such as your name and surname, department, e-mail address, telephone number, title, company and bank account information.
  • We process your personal data in our interest, in order to manage all contracts with our suppliers, and to execute renewals and other measures as necessary (Article 6(1)(f) GDPR). We may also process the data to perform a contract with you (Article 6(1)(b) GDPR).

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We will process your data for these specified, explicit and legitimate purposes, and will not further process the data in a way that is incompatible with these purposes. If we intend to process personal data originally collected for one purpose in order to attain other objectives or purposes, we will ensure that you are informed of this. We will keep your personal data for as long as it is necessary for us to comply with our legal obligations, to ensure that we provide an adequate service, and to support its business activities (Article 5 and 25(2) GDPR).

3. WHAT TYPES OF PERSONAL DATA DO WE USE?

We process the personal data outlined above for the respective purposes that we have explained. We can obtain such personal data either directly from you when you decide to communicate such data to us (i.e., when you fill in forms displayed on the Website) or indirectly where such personal data is provided to us by your electronic communication terminal equipment or your Internet browser. We ensure that the personal data processed be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed.

4. HOW DO WE SHARE YOUR PERSONAL DATA?

We may share your personal data with Company Group entities and with third parties in accordance with the GDPR. Where we share your data with a data processor, we will put the appropriate legal framework in place in order to cover such transfer and processing (Articles 26, 28 and 29). Furthermore, where we share your data with any entity outside the EEA, we will put appropriate legal frameworks in place, notably controller-to-controller (2004/915/EC) and controller-to-processor (2010/87/EU) Standard Contract Clauses approved by the European Commission, in order to cover such transfers (Articles 44 ff. GDPR).

Strategic Partners

Subject to your prior consent, your personal data may be transferred to, stored, and further processed by strategic partners that work with us to provide our products and services or help us market to customers.

Service Providers

We share your personal data with companies which provide services on our behalf, such as hosting, maintenance, support services, email services, marketing, auditing, fulfilling your orders, processing payments, data analytics, providing customer service, and conducting customer research and satisfaction surveys. These companies include OrangeScape (United States and other jurisdictions), Box (United States and other jurisdictions), and Google (United States and other jurisdictions).

SoftBank Corp. Affiliates and Corporate Business Transactions

We may share your personal data with all SoftBank Corp. affiliates. In the event of a merger, reorganization, acquisition, joint venture, assignment, spin-off, transfer, or sale or disposition of all or any portion of our business, including in connection with any bankruptcy or similar proceedings, we may transfer any and all personal data to the relevant third party.

Legal Compliance and Security

It may be necessary for us – by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence – to disclose your personal data. We may also disclose your personal data if we determine that, due to purposes of national security, law enforcement, or other issues of public importance, the disclosure is necessary or appropriate.

We may also disclose your personal data if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.

Data Transfers

Such disclosures may involve transferring your personal data out of the European Union to the following country: Japan, and the United States. Such transfer may take place for internal reporting, management and business purposes. For each of these transfers, we make sure that we provide an adequate level of protection to the data transferred, in particular by entering into standard contract clauses as defined by the European Commission decisions 2001/497/EC, 2002/16/EC, 2004/915/EC and 2010/87/EU.

We will not use your personal data for online marketing purposes unless you have expressly consented to such use of your personal data. You can change your marketing preferences at any time by contacting us as detailed below.

5. OUR RECORDS OF DATA PROCESSES

We handle records of all processing of personal data in accordance with the obligations established by the GDPR (Article 30), both where we might act as a controller or as a processor. In these records, we reflect all the information necessary in order to comply with the GDPR and cooperate with the supervisory authorities as required (Article 31).

6. SECURITY MEASURES

We process your personal data in a manner that ensures their appropriate security, including protection against unauthorised or unlawful processing, accidental loss, destruction or damage. We use appropriate technical or organisational measures to achieve this level of protection (Article 25(1) and 32 GDPR).

We will retain your personal information for as long as it is necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law.

7. NOTIFICATION OF DATA BREACHES TO THE COMPETENT SUPERVISORY AUTHORITIES

In case of breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed, we have the mechanisms and policies in place in order to identify it and assess it promptly. Depending on the outcome of our assessment, we will make the requisite notifications to the supervisory authorities and communications to the affected data subjects, which might include you (Articles 33 and 34 GDPR).

8. PROCESSING LIKELY TO RESULT IN HIGH RISK TO YOUR RIGHTS AND FREEDOMS

We have mechanisms and policies in place in order to identify data processing activities that may result in high risk to your rights and freedoms (Article 35 of the GDPR). If any such data processing activity is identified, we will assess it internally and either stop it or ensure that the processing is compliant with the GDPR or that appropriate technical and organisational safeguards are in place in order to proceed with it.

In case of doubt, we will contact the competent Data Protection Supervisory Authority in order to obtain their advice and recommendations (Article 36 GDPR).

9. YOUR RIGHTS

You have the following rights regarding personal data collected and processed by us.

  • Information regarding your data processing: You have the right to obtain from us all the requisite information regarding our data processing activities that concern you (Articles 13 and 14 GDPR).
  • Access to personal data: You have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and certain related information (Article 15 GDPR).
  • Rectification or erasure of personal data: You have the right to obtain from us the rectification of inaccurate personal data concerning you without undue delay, and to complete any incomplete personal data (Article 15 GDPR). You may also have the right to obtain from us the erasure of personal data concerning you without undue delay, when certain legal conditions apply (Article 17 GDPR).
  • Restriction on processing of personal data: You may have the right to obtain from us the restriction of processing of personal data, when certain legal conditions apply (Article 18 GDPR).
  • Object to processing of personal data: You may have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, when certain legal conditions apply (Article 21 GDPR).
  • Data portability of personal data: You may have the right to receive your personal data in a structured, commonly used and machine-readable format, and have the right to transmit those data to another controller without our hindrance, when certain conditions apply (Article 20 GDPR).
  • Not to be subject to automated decision-making: You may have the right not to be subject to automated decision-making (including profiling) based on the processing of your personal data, insofar as this produces legal or similar effects on you, when certain conditions apply (Article 22 GDPR).

If you intend to exercise such rights, please refer to the contact section below. 

If you are not satisfied with the way in which we have proceeded with any request, or if you have any complaint regarding the way in which we process your personal data, you may lodge a complaint with a Data Protection Supervisory Authority.

10. CHILDREN

Our products and services are intended for adult customers. Thus, we do not knowingly collect and process information on children under sixteen (16). If we discover that we have collected and processed the personal data of a child under sixteen (16), or the equivalent minimum age depending on the concerned jurisdiction, we will take steps to delete the information as soon as possible. If you become aware that a child under sixteen (16) has provided us with personal data, please contact us immediately by using the contact address specified under this Privacy Policy.

11. LINKS TO OTHER SITES

We may propose hypertext links from the Website to third-party websites or Internet sources. We do not control and cannot be held liable for third parties’ privacy practices and content. Please read carefully their privacy policies to find out how they collect and process your personal data.

12. UPDATES TO PRIVACY POLICY

We may revise or update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy via the Services. If we make changes which we believe are significant, we will inform you through the Website to the extent possible and seek your consent where applicable.

CONTACT

For any questions or requests relating to this Privacy Policy, you can contact us by email (sbtmgrp-gdpruk@g.softbank.co.jp).

COOKIES

What are cookies?

Cookies are small text files which are placed on your computer or mobile phone when you visit a website. They are widely used in order to make websites work or to work more efficiently. The cookies help our Website to recognize your device and remember information about your visit (e.g., your preferred language, font size and other preferences).

How do we use cookies?

We do not use cookies to track you individually or to identify you, but to allow us to operate the Website as you have requested and facilitate your navigation on our Website and use of its features, so as to provide you with a seamless experience.

We use Google Analytics, analytics tools to help us measure traffic and usage statistics in order to understand how visitors access and use our Website. We use information collected through cookies to help improve our Website and to compile aggregate statistics about how our Website is used by visitors. Please note that in this context, Google Analytics collects your personal data through the use of cookies on our Website. Learn more about how Google Analytics uses cookies, and how it collects and processes data at Google Analytics.

How to manage your cookies preferences

Most browsers allow you to manage your cookies preferences by changing your browser settings. You may thus set your browser to: (i) automatically accept or refuse all cookies; (ii) automatically accept or refuse first party cookies and/or third party cookies; or (iii) notify you before any cookies are set on your terminal equipment so that you get the opportunity to accept or refuse such cookies.

Consequently, if you consent to our use of cookies but later wish to opt out, you may at any time through your browser settings delete the cookies which have been set and change your browser settings to block all or part of any further cookies. The “Help” function of your browser should tell you how. Alternatively, the following links provide instructions for managing cookie settings of commonly used browsers:

In addition, if you do not want Google Analytics to be used in your browser, you can

In addition, you may wish to visit www.aboutcookies.org, which contains comprehensive information on how to do this on a wide variety of browsers.

Moreover, you can use another online service enabling you to manage the advertisement cookies placed our your devices: http://www.youronlinechoices.com/.

Please note yet that if you block cookies, your experience on our Website may be impacted as we may then not be able to provide you with full access to all functionalities and contents of our Website.

How long do we retain cookies?

We consider that your consent to cookies is valid for a maximum period of 30 days. After such time frame, we will ask for your consent again.