Exhibit: California

Enacted March 28, 2022
Revised July 21, 2023

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) and the Shine the Light law (Cal. Civ. Code § 1798.83) afford consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Consumer Privacy Act

1 Personal information we collect

In the preceding 12 months, we have collected the following categories of personal information:

  • Identifiers (e.g., your name, online identifier, internet Protocol address, etc.).
  • Any categories of personal information described in subdivision (e) of Section 1798.80(e.g., signature, bank account number, credit card number, debit card number, or any other financial information).
  • Internet or other electronic network activity information (e.g., browsing history and information regarding a consumer’s interaction with an internet website, advertisement or application).
  • Inferences drawn from any information (e.g., your interests and preferences based on your use of our website and other information we may have about you).

We collect personal information about you from the following sources:

  • Information consumers provide to us. For example, information acquired through credit card and other payments through our payment services by consumers using a credit card or other payment method.
  • Information we collect automatically when you interact with us. For example, information acquired by consumers who use our website.

For further details about the precise data points we collect, please see the “Personal information processed” section of our Global Privacy Notice. We collect personal information for the business and commercial purposes described in the “Purpose and legal basis for processing personal information” section in our Global Privacy Notice. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:


Category of Personal Information Categories of Recipients
Identifiers Group companies, cloud service providers, system vendors, settlement institutions and advertising networks
Any categories of personal information described in subdivision (e) of Section 1798.80 Group companies, cloud service providers, and system vendors
Internet or other electronic network activity information Group companies, cloud service providers, system vendors, advertising networks, advertising service providers
Inferences drawn from any of the information Web marketing consulting firms

California law requires that we provide transparency about personal information we “sell,” which, for the purposes of the CCPA, broadly means scenarios in which we have shared personal information with third parties in exchange for valuable consideration. We “sell” personal information for the following commercial purposes: We use third-party services to measure our traffic and deliver targeted advertisements based on activity on our website. In the preceding 12 months, we have “sold” the following categories of personal information to the following categories of third parties:


Category of Personal Information Category of Third Parties
Identifiers Advertising networks, advertising service providers
Internet or other electronic network activity information Advertising networks, advertising service providers

You have the right to opt out of these sales at any time by visiting our “Do Not Sell My Personal Information” webpage. We do not knowingly sell personal information about consumers under the age of 16.

Response to “Do Not Track” signals
Certain browsers have built-in “Do Not Track” (DNT) features that provide the opportunity to make selections with regard to the collection of personally identifiable information. This site currently responds to DNT signals, and you can change these settings in your browser.

2 Consumer rights

Subject to certain limitations, you have certain rights in connection with your personal information.

  1. The right to request to know more about the categories and specific pieces of personal information we collect, use, disclose, and sell.
  2. The right to request deletion of the personal information concerning you that we have collected from you.
  3. The right to opt-out of any “sales” of your personal information that may be occurring.
  4. The right not to be discriminated against by us by exercising these rights.

You may make these requests by emailing us at privacy@sbpayment.jp. We will verify your request by asking you to provide information related to your recent interactions with us, such as name, email address, etc. We will not discriminate against you if you exercise your rights under the CCPA. If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us by using above methods.

Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. Under the law, a business must either provide this information or permit California residents to opt in to, or opt out of, this type of sharing. SB Payments qualifies for this alternative option. To opt out of having information about you shared with third parties for direct marketing purposes, please e-mail us at privacy@sbpayment.jp.