May 2025
Parties
1.1
This Privacy Notice describes how SBI Chiliz Co., Ltd., the business operator, (or otherwise referred to herein as “SBI”, “Company”, “Us” or “We”) treats your personal information and the data provided to us in order to be able to manage our relationship. We manage any personal information You provide to Us either through the website: http://www.sbichiliz.com and/or via the SBI Mobile Application (hereinafter referred to as ‘this Website/App’ or ‘the Website/App’ and are kept by Us in relation to You in the manner specified in this Privacy Notice.
The primary purpose of SBI is to help fund and foster the development, growth and raise awareness of the potential offered by blockchain technology and the Chiliz ecosystem focused on enhancing fan engagement in sports and entertainment. Visitors and users of the SBI website are hereby informed that SBI holds no role as the issuer of any tokens associated with the Chiliz ecosystem, nor does it function as the developer of the Chiliz Chain. Furthermore, SBI does not occupy any leadership or directive position within the Chiliz ecosystem, which is a collaborative and decentralized project propelled by the contributions of various independent actors.
1.2
All natural persons or other subjects who log onto this Website/App shall be users of this Website/App. For the convenience of wording in this Agreement, the users are referred to as ‘You’ or any other applicable forms of the second-person pronouns.
1.3
For the convenience of wording in this Notice, You and We are collectively referred to as “both parties,” and individually as “one party.”
1.4
We take our responsibilities under the Act No. 57 of 2003 or Act on the Protection of Personal Information, (the “APPI”) seriously. We also recognize the importance of the personal data You have entrusted to Us and believe that it is our responsibility to properly manage, protect and process your personal data.
Who Are We
We are SBI Chiliz Co., Limited, a company registered under the Laws of Japan, having its registered office at 1-6-1 Roppongi, Minato-ku, Tokyo, Japan.
Our DPO is: Koichi Kano, the CEO of the Company, with contact information: sbichiliz-ga@sbichiliz.com
Purposes of the Privacy Notice
This Privacy Notice stipulates the types of information that We may collect through your log in to this Website/App, your interaction with this Website/App and/or use the services We offer, as well as how We shall use and protect the information collected or You provide Us.
To ensure that You have full confidence in our handling of personal data, You are advised to read and understand the terms of this Privacy Notice in detail. In particular, upon your log into our Website/App and/or use our services You shall be deemed to accept, undertake and confirm that:
3.1
You, on the basis of your own free will, agree to disclose and share your personal information to Us;
3.2
You will comply with all the terms of this Privacy Notice;
3.3
You agree that We may collect your information through your log into this Website/App and/or using the services offered by Us; You agree to any changes and modifications that We may make to our Privacy Notice in the future;
3.4
You agree that our branches, affiliates and employees may contact You in connection with the products and services that You may be interested in (unless You have indicated that You do not want to receive such information).
Information Collected
4.1
When You use this Website/App, You agree to permit Us and our third-parties to use cookies and other tracking technologies to provide and personalize the services and features of the services for you across sessions or learn about your preferences or your use of the services or our interactions with You. We will only collect your personal data in accordance with the legislative purpose of the APPI and other Applicable Laws.
For security purposes, We have integrated GeeTest Captcha on our Website/App: this tool will collect some personal data related to your browser window, in order to confirm that you are a human and not a bot. For further information, please refer to the third party’s Privacy Policy and Terms of service.
4.2
When you use this Website/App or the services this Website/App offers, We may collect more information necessary for the purpose of improving the functions of this Website/App, enhancing your experience of using this Website/App and its services as well as the security thereof, or as is required by any court order, any applicable law, administrative regulation or any order of any other competent government agency.
4.3
If you visit any of links to third-party Website/Apps as are listed on this Website/App or any link of any of our third-party partners, you shall agree to and comply with the separate and independent Privacy Notice and Terms of Use/Conditions of such third-party Websites/Apps. We will not bear any liability for the contents and activities of such Websites/Apps or the partners.
4.4
For the avoidance of doubt, in the event that APPI permits an organisation such as Us to collect, use or disclose your personal data without your consent, such permission granted by the APPI shall continue to apply.
To provide our services, and for the purpose of preventing illegitimate use of our services, We carry out profiling of our customers and their activities using automated processes. However, any decisions taken based on these profiles and information are taken by natural persons.
Cookies
When You visit our site or use our App, We will collect information about your use of the services and our interactions with You through the use of cookies and similar technologies.
For more detailed information including what cookies are and how and why We process such data in this manner (including the difference between ‘essential’ and ‘non-essential’ cookies) please read our detailed Cookies Notice.
5.1
When You visit our Website/App, We use Google stats via cookies to record our performance and check the effect of online advertising. Cookies are a small amount of data that is sent to your browser and stored on your computer hard drive. Only when You use your computer to access our Website/App can the cookies be sent to your computer hard drive.
5.2
Cookies are usually used to record the habits and preferences of visitors in browsing the items on our Website/App. The information collected by cookies is non-registered and collective statistical data and does not involve personal data.
5.3
Cookies, which enable the Website/App or service provider system to recognize your browser and capture and recall information, cannot be used to obtain data on your hard drive, your email address, or your personal data. Most browsers are designed to accept cookies. You can opt to set your browser to reject cookies, or to notify you as soon as possible if you are loaded on cookies. However, if You set your browser to disable cookies, it is possible that You may not be able to launch or use some functions of our Website/App.
Our Website/App may also feature social media widgets. These social media features are either hosted by a third party or directly on our website. When using these widgets, or our respective pages on these provider’s platforms, We encourage you to read and make reference to their respective privacy notices.
To find out more, please read our Cookies Notice (hyperlink).
6. Purposes of Information
6.1
We will use your information that We collect for the following purposes or in the following ways:
- to provide You with our services through our Website/App;
- to identify and confirm your identity when You use our Website/App and contact with Us;
- to improve and upgrade the services of the Website/App (your information and feedback received by Us can help Us improve the service of the Website/App, so that We can more effectively respond to your service requests and support needs);
- to keep statistics relating to the use of our Website/App and to be used for data analysis carried out in cooperation with government agencies, public affairs institutions;
- to personalize your experience (your information will help Us to better respond to your personalized needs);
- due to business changes We may transfer or share data to another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction; and
- to send e-mail regularly (the email address that You provide for the use of our services may be used to receive information in addition to newsletters, updates, marketing preferences, related products or services information, etc., that We may send to You from time to time) if You provide your consent.
6.2
We do not sell, trade, or otherwise transfer information or allow others to collect and use information. We may only share your information any other time You provide Us with your consent to do so.
We will not disclose your information to any third parties except when We outsource handling of personal information to a third party, or as described in the items below.
- When such disclosure is made upon your consent.
- When such disclosure is made for statistical calculations if such data does not reveal your identity.
- When such disclosure is made as required by law.
- When such disclosure is made to protect human life, body or assets if obtaining your consent for some reason proves difficult.
- When such disclosure is made to improve public health, to promote child development, or for some other special situation if obtaining your consent for some reason proves difficult.
- When such disclosure is made to cooperate with a governmental or a regulatory body, or an outsourcer of such bodies that must perform work to comply with Japanese law if obtaining your consent would be an obstacle to performing the relevant work.
7. Joint use of Personal Data
We will use Your information described under (1) below with the parties named under (2) for the purposes described in (3) below. The DPO named in (4) below will be responsible for the management of Your information between the parties named under (2). If the joint use of such information are regulated by applicable laws we will only make joint use of such information in compliance with those laws.
Information to be jointly used
- Name, address, date of birth, phone number, email address, information regarding your needs in our services, public information and other information related to your character;
- Historic record of your transactions with us or services we have rendered to you and other information related to such transactions; and
- Your client number or any other number that We label You with for the purpose of client management.
Parties to be in joint use of Your information
- SBI Group companies, as listed in https://www.sbigroup.co.jp/company/group/overview.html; and
- Chiliz Group: https://www.chiliz.com/
Purpose of the joint use
- Providing services related to the transaction between You and Us that are in fact rendered through the parties named in (2) above;
- Marketing of products, subject to compliance with the other provisions of this Privacy Notice;
- Maintaining our website and the servers under which the website is set under; and
- Responding to inquires made by You regarding services provided by the parties named in (2) above.
DPO
Koichi Kano, CEO of SBI Chiliz Co., Ltd., Izumi Garden Tower 13F, 1-6-1 Roppongi, Minato-ku, Tokyo Japan. Contact information is: sbichiliz-ga@sbichiliz.com
8. Protection of Personal Data
8.1
We adopt appropriate physical, electronic, management and technical measures so as to protect and safeguard the security of your personal data. We will, to the greatest extent possible, ensure that any personal data collected shall be free from being subject to nuisance by any third party unrelated to Us. The security measures that We may take include but are not limited to:
- Physical measures: records of your personal data will be stored in a properly locked place.
- Electronic measures: the computer data that contain your personal information will be stored in computer systems and storage medias that are subject to strict login restrictions.
- Management measures: only staff members duly authorized by Us can access your personal data, and these staff members shall comply with our internal code concerning personal data confidentiality.
- Technical measures: encryption may be used to convey your personal data.
- Other measures: our network servers are protected by proper ‘firewall’.
If You are aware of any security flaws in our Website/App, please contact Us immediately so that We can take appropriate action as soon as possible.
8.2
Despite of the above-mentioned technical and security measures, We cannot guarantee that the information transmitted via the Internet is absolutely safe, so We cannot absolutely guarantee that the personal data that You provide to Us through will be safe at any time. We will not be held liable for any loss or damage arising from or caused by any event that may occur in connection with unauthorized access to your personal data, and We shall not be held liable for compensation for such loss or damage.
9. Direct Marketing
We only send mail messages, emails and other communications relating to marketing where We are authorized to do so at law. We will rely on Your consent to do so (especially where We use electronic communications). If, at any time, You no longer wish to receive direct marketing communications from Us please let Us know by contacting Us at the details below or update Your preference on any of our Site(s) or Apps.
In the case of direct marketing sent by electronic communications (where We are legally authorized to do so) You shall be given an easy way of opting-out (or unsubscribing) from any such communications at any time and without costs.
Please note that even if You withdraw any consent You may have given Us or if You object to receiving such direct marketing material from Us (in those cases where We do not need your consent), from time to time We may still need to send You certain important communications from which You cannot opt-out.
10. Cross-border Transfers of Personal Data
Our Company is located in the Japan so, to comply with EU data protection laws, We have measures in place to ensure that your personal data is granted the same level of protection as in the EU. However any cross-border transfer of your data between Japan and the EU is granted by Adequacy Decision under Article 45 of the GDPR from the EU and the UK, therefore personal data can be transferred between the EU, the UK and Japan without requiring the consent of the data subject or taking other individual measures.
11. Third-party service providers
We ensure that data transfers to service providers are made in compliance with the APPI.
We may combine personal information We receive from You with personal information falling within one of the categories identified above that We obtain from other sources as these third-party services. Furthermore, We may integrate technologies operated or controlled by other parties into part of the services. For example, the services may include links that hyperlink to websites, platforms, and other services not operated or controlled by Us. Please note that when You interact with these other parties, including when You leave the Site, those parties may independently collect information about You or solicit information from You. This data may include your username, profile picture, details of last log-in, and other information associated with your account on that third-party service that is made available to Us based on your account settings on that service, such as Google. This data may include your Google username, profile picture and other information associated with your Google account on that third-party service that is made available to Us based on your account settings on that service. Our use and disclosure of information received from Google’s APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Third party services also encompass any virtual currency account services You link to the services. This data may include your wallet address and other information associated with your account on that third-party service that is made available to Us based on your account settings on that service.
A list of our third-party suppliers can be provided upon request.
12. For how long do We keep your data?
After your last log-in, activity or interaction with our services, We will retain certain elements of personal data only for the necessary period of the purpose which was provided and up to five (5) years from last activity and/or to meet our legal obligations towards.
We will also keep personal data for the purpose of presenting and processing in case of a litigation or a legal process which You, the relevant authorities or Us may be party to, due to our provision of services to You.
All this information is stored in accordance with this Privacy Notice. All personal data shall not be kept for longer than is necessary and, alternatively, any personal data can be anonymized so that it is no longer in a form which permits identification of users/data subjects.
13. Your Rights
Under the APPI, You have the right to:
- request access to the personal information provided by You;
- request rectification of personal data that You consider incorrect;
- request for restriction of processing of data;
- request erasure of data; and
- request cessation of disclosure of Your information to third parties
Your rights may be exercised in accordance with the APPI, which might include restrictions on when You can exercise these rights.
You can contact with our DPO, a CEO at sbichiliz-ga@sbichiliz.com
You have also the right to lodge a complaint with your local Data Protection Authority. If you are based in Japanese territory the local authority is the Personal Data Protection Commission (PPC): https://www.ppc.go.jp/index.html.
If You are residing out of Japan You may find a list with your local Data Protection Authority contact details at https://edpb.europa.eu/about-edpb/board/members_en or through this link https://ombudsman.ky/data-protection
14. Changes to this Privacy Notice
We reserve the right to amend the Privacy Notice from time to time and at any time. We will inform You of the modifications made to the Privacy Notice by updating and publishing the effective date of the release of new versions hereof and highlighting the amendments. Sometimes, We may issue a notice to inform You of the modification made in the Privacy Notice. You shall regularly review the Privacy Notice and focus on its modifications, and if You do not agree to such modifications, You shall immediately stop accessing this Website/App. When an updated version of this Privacy Notice is released, your continued visit to this Website/App shall indicate and show that You agree to the update and agree to comply with the updated Privacy Notice.
15. Communication with Us
15.1
If You have any requests and comments, You can send an email to our DPO which are the only valid and official means through which We communicate with You, so We will not bear any liability for your failure to using effective contact information, any act or omission.
15.2
We only publish announcements and information on the basis of the valid and effective contact information on this Website/App or post announcements on this Website/App; therefore, We shall not be held liable for any loss arising from your trust in the information that has not been obtained through the above-mentioned means.
15.3
If you have any questions regarding our Privacy Notice, You are welcome to contact Us at any time.
