Privacy Notice

Hypes SB UK Ltd. (the "Company", "we", "us" or "our") acts as the data controller for the processing of personal data in connection with recruitment for roles at our UK entity. This notice explains how we collect, use, disclose and otherwise process personal data about individuals who apply for a role with us or participate in recruitment-related activities that we organize or host—such as applications, assessments, interviews, seminars and information sessions (together, "Applicants" and "Recruitment Activities").

We are committed to processing your personal data lawfully, fairly and transparently and in accordance with applicable data protection laws. Unless otherwise stated, terms used in this notice have the meanings given in the UK General Data Protection Regulation ("UK GDPR") and the Data Protection Act 2018. Where there is any conflict between this notice and applicable data protection law, the latter shall prevail. Our contact details (and, where applicable, those of our data protection officer ("DPO") and EU representative) are set out in Section 11 below.

Where other Reazon group companies or third-party service providers process personal data on our behalf in connection with Recruitment Activities, they do so as our processors pursuant to appropriate contractual safeguards. If, in limited cases, we act as joint controllers with another entity, we will make the essence of that arrangement available upon request.

1. Categories of personal data we process

We may process the following categories of personal data (to the extent relevant to recruitment):

  • Identification and contact details (e.g., name, postal address, email, phone).
  • Demographic and professional information (e.g., date of birth, education, employment history, qualifications, professional memberships, current/desired remuneration).
  • Application materials and communications (e.g., CVs, cover letters, forms, interview notes, correspondence, call recordings where lawful and notified).
  • Assessment, verification and vetting data (e.g., test results, right-to-work checks, reference responses, background screening results where proportionate and lawful).
  • Recruitment process metadata (e.g., application/participation history, outcomes). Special category data and criminal offence data are addressed in Section 7.

2. Sources of personal data

We obtain personal data:

  • Directly from you (e.g., CVs, forms, interviews, assessments).
  • From third parties where lawful (e.g., referees, background-screening providers, recruitment agencies/head-hunters).
  • From public sources (e.g., professional networking sites) where appropriate for role-related screening.

3. Purposes and lawful bases

We process personal data for the following purposes and on the corresponding lawful bases:

  • Finding candidates / providing information about openings: to publicise roles and manage talent pipelines. Legitimate interests (efficient recruitment and hiring). For any electronic direct marketing (e.g., job alerts by email/SMS to individual subscribers), we will comply with PECR and obtain consent where required; "soft opt-in" is generally limited to marketing of similar products/services to existing customers and is unlikely to apply to recruitment messaging to new contacts.
  • Accepting and managing applications (including arranging interviews/assessments, communications, scheduling, travel logistics): Legitimate interests and, where we take steps at your request to enter into a contract of employment, performance of a contract (pre-contractual).
  • Assessing skills, qualifications and suitability (shortlisting, testing): Legitimate interests (to hire suitable candidates and manage an effective recruitment process).
  • Verification and right-to-work checks (identity, eligibility to work): Legal obligation (immigration/employment law).
  • Offer management and onboarding administration (following a conditional offer): Performance of a contract (pre-employment steps you request) and legal obligations.
  • Diversity monitoring / adjustments (where applicable and compliant): see Section 7 for conditions and safeguards.
  • Improving recruitment processes (metrics, audits): Legitimate interests (quality and fairness monitoring), using aggregated or de-identified data where feasible.
  • We will conduct and record Legitimate Interests Assessments (LIAs) where appropriate.

4. Disclaimer

We share personal data, where necessary and proportionate, with:

  • Reazon group entities involved in the relevant recruitment decision.
  • Recruitment platforms, assessment providers, background screening and right-to-work service providers, travel administrators, IT/communications and hosting vendors (each acting as processor under Article 28 UK GDPR).
  • Referees (to obtain references), professional regulators (if applicable), and public authorities where we are legally required to do so. We do not sell your personal data.

5. International Data Transfers

Your personal data may be transferred outside the UK (and, if relevant, outside the EEA). Where we do so, we rely on:

  • UK adequacy regulations where available (e.g., Japan—partial adequacy; US recipients certified under the UK-US Data Bridge), or
  • Appropriate safeguards such as the UK International Data Transfer Agreement (IDTA) or the UK Addendum to the EU Standard Contractual Clauses, and apply supplementary measures as needed. Details are available on request.

6. Special category data and criminal offence data

We process special category data (e.g., health data for reasonable adjustments) only where strictly necessary and where a relevant Article 9 UK GDPR condition applies—typically Article 9(2)(b) (employment, social security and social protection) and/or 9(2)(h) (occupational health). Where required by the DPA 2018 Schedule 1, we maintain an Appropriate Policy Document (APD) setting out safeguards, retention and access controls. If processing is genuinely optional and no relevant condition applies, we will seek your explicit consent.

For criminal convictions and offences data, we process only where permitted by Article 10 UK GDPR together with a relevant Schedule 1 condition and appropriate safeguards.

7. Automated decision-making

We do not make decisions solely on automated processing (including profiling) that produce legal effects or similarly significantly affect you. If we introduce such processing, we will inform you in advance and implement the Article 22 safeguards (including the right to obtain human review and to contest the decision).

8. Retention of Data

We store the personal data we collect as described in this notice for as long as you engage with the Company, necessary to fulfill the purpose(s) for which it was collected, provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. The specific retention period is determined based on the purpose of acquisition and processing, the nature of the personal data, and its necessity for legal or business grounds.

9. Your Rights (subject to applicable law)

You may exercise the following rights by contacting us or a representative or data protection officer. If you request to exercise the following rights, please contact us as set forth in section 11 below.

Right of access: You have the right to obtain confirmation as to whether we process personal data about you and, where that is the case, access to such personal data and certain information about our processing.

  • Right to rectification: You have the right to have inaccurate personal data corrected without undue delay and to have incomplete data completed.
  • Right to erasure: You may obtain the erasure of your personal data, subject to certain exceptions under the GDPR, where: (i) such personal data is no longer necessary in relation to the purposes for which we collected and processed it; (ii) you withdraw your consent to our processing solely based upon your consent; (iii) you object to our processing and there are no overriding legitimate grounds for such processing; (iv) our processing is unlawful; (v) your personal data has to be erased in compliance with a legal obligation.
  • Right to restriction of processing: You may obtain restriction of processing of your personal data, subject to certain exceptions under the GDPR, where: (i) you contest the accuracy of your personal data: (ii) our processing is unlawful and you select to restrict our processing instead of requesting erasure of your personal data: (iii) you request us to establish, exercise or defense legal claims that need your personal data no longer necessary for the purposes of our processing; or (iv) you exercise the right to object to our processing and wait for verification on where we have overriding legitimate grounds.
  • Right to data portability: Where processing is based on your consent or a contract and is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format and to have those data transmitted to another controller where technically feasible.
  • Right to object: You may object to the processing of your personal data where our processing is based upon the exercise of our official authority or our legitimate interests, including "profiling" or for direct marketing purposes. You may also object at any time to processing for direct marketing, including related profiling; in that case we will stop processing for such purposes.
  • Rights related to automated decision-making (including profiling): You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you, and to obtain human intervention, express your point of view, and contest the decision, subject to applicable exceptions.
  • Right to the withdrawal of your consent: You may withdraw your consent at any time to the processing of your personal data that we have collected about you. The lawfulness of processing based on consent before its withdrawal will not be affected. Withdrawal of consent does not affect processing that is carried out on other lawful grounds, and we will inform you if certain services or recruitment steps can no longer be provided without your consent.
  • Right to lodge a complaint: Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a data protection supervisory authority. In the EU, you may complain in the Member State of your habitual residence, place of work, or place of the alleged infringement. In the United Kingdom, you may complain to the Information Commissioner's Office (ICO). The supervisory authority (or the ICO) will inform you of the progress and outcome of the complaint, including the possibility of a judicial remedy.

10. Requirement to provide data

Provision of certain personal data may be a statutory or contractual requirement, or necessary to enter into or perform a contract, or otherwise necessary for the purposes set out in this notice. Where we indicate that provision of particular data is mandatory, failure to provide it may mean we are unable to proceed or fulfil the relevant request. We will indicate where information is mandatory.

11. Contact

If you have any questions about our privacy practices or this notice, or to exercise your rights as detailed in this notice, please contact us at:
Email: privacy@hypes-bet.com

For EU data subjects, you can contact our EU representative at:
Name: Classmethod (Europe) GmbH
Email: rh@gdpr-contact.email

Data Protection Officer (DPO) Contact
For any data protection inquiries, you may also contact our Data Protection Officer.
Email: dpo@reazon.jp

Data Protection Authority
You can also raise a concern or lodge a complaint with the relevant data protection authority or other official with jurisdiction in your country or region of residence.

If you are in the UK, you may lodge a complaint with the Information Commissioner's Office (ICO).

12. Cookies and Similar Technologies

If you use our website or application portals, we use strictly necessary cookies for core functionality. Non-essential cookies (e.g., analytics such as Google Analytics) will be used only with your consent under PECR; you can manage choices at any time via our consent banner.

Opt-out: You can use Google's opt-out methods (e.g., browser add-on). For more information, please visit Google Analytics' Privacy Policy. To learn more about how to opt-out of Google Analytics' use of your information, please click here.

13. Changes To This Notice

The Company will strive to make appropriate improvements to this notice. The Company may change this notice without notifying Applicants. Unless otherwise specified by the Company, the revised notice will take effect from the time it is posted on this website.

Established: August 1, 2025