Privacy Policy

The SB Investment Group (we) are committed to protecting any personal data you provide to us.

We believe it is important for you to know what personal data we collect and how we use it. This policy (together with our terms and conditions and any other documents referred to in it) explains the personal data we process, what it is used for and the legal basis upon which we process this information. It also explains legal rights you may have to control that processing and how you can exercise them.

This policy does not apply to other third-party websites that you may reach through links on this Site. If you access other third-party sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their privacy policy, which will differ from ours.

About us and how to contact us

If you have any specific issues relating to this privacy policy, would like a list of The SB Investment Group companies who may process your data, or any wider privacy issues relating to us, please contact us at i nfo@thesbinvestmentgroup.com.

What personal information do we collect about you

We may collect personal information from you in the course of our business, including through your use of our Site, when you contact or request information from us, when you engage our services or as a result of your relationship with one or more of our properties.

There is no obligation on you to provide the information listed below; however, if you do not, we may be unable to engage with you, or send you the materials you have requested if we do not have the necessary information to do so.

The type of personal information that we collect and process about you includes:

Basic information, such as your name (including name prefix or title), the company you work for, your title or position and any contact information, such as your postal address, email address and phone number(s)
Recruitment related information such as your resume when you use the careers section on our Site or otherwise
Financial information, such as payment-related information
Alert preferences for documents or information you request from us
Technical information, such as information from your visits to our Site or in relation to materials and communications we send to you electronically or by post
Information you provide to us in the context of managing our relationship with you, including any identification or background information provided by you

How do we obtain your personal information

Information you give us voluntarily by filling in forms on our Site, or by interacting with us directly, either through our Site or engaging with our staff (including, through email communications), send an application for a vacancy using the careers section on our Site or otherwise, and when you report a problem with our Site.

Information we collect automatically when you use our services and/or when you visit our Site, including:

(a) Geolocation data provided by your smartphone or other mobile device to access our Site, provided that you have consented to the Site collecting this data on your smartphone or other mobile device.

(b) Device and website Use Information – When you use a computer, tablet, smart phone or other device to access our Site, we may collect information about the device and how you use it. This information may include the type of device, your operating system, your browser (for example, whether you used Internet Explorer, Firefox, Safari, Chrome or another browser), your internet service provider, your domain name, your internet protocol (IP) address, your device identifier (or UDID), the date and time that you accessed our service, the web pages you requested, the date and time of those requests.

How do we use your personal information

We use information we hold about you in the following ways:

To manage and administer our relationship with you, including the performance of a contract with you, including for recruitment purposes.

To provide information, that you request, or (with your consent, where appropriate) which we think may interest you to enhance and support your relationship with The SB Investment Group. We will use this data in accordance with any preferences you have selected, either on the basis of consent (where appropriate) or of legitimate interests where you have not objected to receiving such information.
Geolocation, Device and website Use information is used to determine how many people use the Site on particular browsers and different devices so that we can ensure adequate technical support for each type of device and browser and to improve the effectiveness and operation of the Site. We will also use anonymised statistical data about your browsing actions and patterns to help us to improve our Site and deliver a better and more personalised service. They enable us to store information about your preferences, and so allow us to customise our Site according to your individual interests, to speed up your searches; and to recognise you when you return to our Site. For more information, please see our Cookie Policy.
To fulfil our legal and regulatory obligations, including establishing, exercising or defending legal claims.
For our legitimate business interests such as to communicate with you about any changes to KW services and properties; for web analytics so we can improve and tailor services to you; to allow us to investigate and respond to any issues or correspondence received to provide appropriate technical support and security for our Site; or for fraud prevention.

Legal basis for processing personal information

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you, (ii) where the processing is in our legitimate interests and not overridden by your rights, or (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.

If we collect and use your personal information in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our platform and communicating with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our platform or undertaking marketing.

How long will we keep your information for

We will keep your personal information for as long we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Who do we share your information with

We may disclose your personal information to:

to our group companies, third party services providers, suppliers and partners that process information on our behalf and assist in providing our services to you (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Site), or who otherwise process personal information for purposes that are described in this Privacy Policy or notified to you when we collect your personal information;
to any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person. This includes exchanging information with other companies and organisations for the purposes of fraud protection; successors in title or replacement owners or operators of all or part of our business on the basis of our legitimate interests and the interests of our purchaser, so that they can appropriately value the business and assess any risks and continue doing business with you after the acquisition;
to any other person with your consent.

Where we store or process your information

The information we collect from you may be transferred to, processed and stored at, a destination outside the European Economic Area (“EEA”). Such destinations may not have laws which protect your information to the same extent as in the EEA. It may be processed by us or by our service providers operating outside the EEA, but we will take appropriate steps to ensure that your information is treated securely and in accordance with this Privacy Policy.

How do we keep your personal information secure

We have implemented security policies, appropriate organisational and technical measures to protect the information that we have under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. Where you have chosen a password that enables you to access certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information transmitted to our Site and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

Children’s Privacy

We do not knowingly collect information from children under 13 years of age.

Cookies and similar tracking technology

‘Cookies’ are small text files that are placed on your computer when you first visit a website and may subsequently be used by the website operator to obtain information when you return to that website. We may use cookies for technical administration of the Site, to recognise and count the number of visitors and to see how visitors move around the Site when they are using it, to remember your preferences, to allow us to customise our Site according to your individual interests and for traffic monitoring.

If you do not wish us to process your Geolocation and Device and website Use information, you may prevent this by disabling the function or blocking the cookies on your device or browser. However, if you select this setting you may be unable to access certain parts of our Site, or it may impact on the usability of our Site.

Your Rights

You have the right to opt-out from for marketing communications.

If you wish to withdraw your consent to receive marketing materials, this can be done by:

updating your preferences on your online account if you have one; or
by clicking on the unsubscribe link on any emails we have sent; or
emailing us at i nfo@thesbinvestmentgroup.com

If you withdraw your consent, this will not affect our rights to have sent you marketing material prior to your withdrawal, but we will not send any further marketing. Whilst we will endeavour to ensure that you do not receive any further marketing material immediately, there may be a slight delay for any changes to take effect.

You are also entitled to request that we:

provide you with a copy of any personal information we hold about you;
have any incorrect personal information corrected or completed (you can also update your records using your profile on your online account, if you have one);
delete any personal information that we no longer need for the above purposes, where you have withdrawn your consent and there are no other grounds to process that information, where the personal information has been unlawfully processed or where we are required by law to delete it; and
restrict the processing of your personal information whilst we confirm whether any information needs correcting following your request, the processing is unlawful and you do not want us to delete this personal information; where we no longer need to process the personal information, but you require the information to establish, exercise or defend legal claims. In these circumstances we will only process your personal information for purposes for which you have consented, or for the establishment, exercise or defence of legal claims or the protection of the rights of another person; and/or
object to our processing of your personal information, where we process it under the legitimate interests grounds and we are unable to show a compelling legitimate interest that overrides your interests, rights and freedoms, or for the purposes of defending, exercising or defending legal claims.

if we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you wish to make such a request, please email i nfo@thesbinvestmentgroup.com.

We may require additional information to either confirm your identity before we can process your request and/or to assist us in responding to your request. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

You are also entitled to lodge a complaint with your local data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

Changes to our Privacy Policy

We may revise this Privacy Policy from time to time. If we are going to use your personal information for any other additional purposes not set out in this privacy policy or if we make any changes to this privacy policy that may materially impact on you or our processing of your personal information, we will take appropriate measures to inform you in accordance with applicable data protection laws.

Any questions, comments and requests regarding this privacy policy are welcomed and should be addressed to i nfo@thesbinvestmentgroup.com.