Privacy
Policy.

01 Who we are

SIB Enterprise operates as two legal entities: SIB Enterprise, Inc. (United States) and SIB Enterprise UK, Inc. (United Kingdom). Together these entities operate the SESI Intelligence platform, the sibenterprise.com website, and all associated services described in the Terms of Service.

Our Data Protection Officer is Gary Stanford. For all data protection enquiries, contact us here.

For users in Japan, our Personal Information Protection Manager (個人情報保護管理者) fulfils the equivalent role under APPI. Enquiries from Japan may be submitted in English or Japanese via the same contact form.

02 What data we collect

03 Legal bases for processing (UK/EU GDPR)

• Contract — Processing necessary to deliver the services you have subscribed to
• Legitimate interests — Platform security, fraud prevention, service analytics
• Consent — Marketing communications, non-essential cookies, children’s data processing
• Legal obligation — Responding to court orders, regulatory requests, safeguarding obligations

03a Legal basis for processing — Japan (APPI)

For users in Japan, SIB Enterprise processes personal information in accordance with the Act on Protection of Personal Information (APPI, Act No. 57 of 2003, as amended May 2022), supervised by the Personal Information Protection Commission (PPC).

Sensitive personal information (要配慮個人情報)

Under APPI, certain categories of data require explicit consent before collection. SIB Enterprise treats the following as sensitive personal information for Japanese users: racial or ethnic origin; physical or mental disability; criminal records; medical history. This data is only collected where strictly necessary and with explicit prior consent.

Third-party provision (第三者提供)

SIB Enterprise may share personal information with third parties (partner clubs, academies, payment processors, AI infrastructure providers) only where the user has provided consent or a statutory exception applies. A record of third-party provisions is maintained in accordance with Article 25 APPI.

Cross-border transfers from Japan

When personal data of Japanese users is transferred outside Japan (to the UK, EU, or USA), SIB Enterprise complies with APPI Article 24 by either:

• Obtaining explicit consent from the data subject for the transfer
• Transferring to a country recognised by the PPC as having an equivalent level of protection (currently the EU under adequacy)
• Entering into a data transfer agreement with the recipient that ensures equivalent protections

Users in Japan may request details of any cross-border transfers of their personal information by contacting our Personal Information Protection Manager.

04 Children's privacy (COPPA & UK AADC)

SIB Enterprise’s Family Pathway services are designed for use by parents and guardians on behalf of children under 18. We do not knowingly collect personal data directly from children under 13 without verified parental consent in accordance with the US Children’s Online Privacy Protection Act (COPPA).

Under the UK Age Appropriate Design Code, we apply the following defaults to any service that may be accessed by children: privacy settings are high by default; data collection is minimised; profiling for commercial purposes is off by default; no nudge techniques are used to encourage data sharing.

Parents and guardians may request deletion of their child’s data at any time by contacting our DPO.

05 Data sharing & third parties

We do not sell personal data to third parties. We share data only in the following circumstances:

• Partner clubs and academies — With player/parent consent, for pathway placement purposes
• Payment processors — Tokenised payment data only; processors are PCI-DSS compliant
• AI infrastructure — SESI AI agents operate under Anthropic’s Commercial Terms; no data is used for model training
• Video partners — Shotstack, Magnifi, Synthesia process video under data processing agreements
• Legal obligation — Courts, regulators, or law enforcement where legally required

06 International transfers

SIB Enterprise operates globally. Personal data may be transferred between the UK, EU, US, and Japan. All transfers outside the UK/EU are protected by appropriate safeguards including UK International Data Transfer Agreements (IDTAs), EU Standard Contractual Clauses (SCCs), or adequacy decisions where applicable. Transfers of Japanese users’ personal information outside Japan are governed by APPI Article 24 — see Section 03a above for full details.

07 Retention

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Player performance data is retained for the duration of the active player profile plus 2 years. Payment records are retained for 7 years in accordance with UK tax law. Contact us to request deletion of your data.

08 Your rights

You have rights over your personal data. See our Your Rights page for full details and how to exercise them, including our rights request form. Users in Japan have additional rights under APPI, also set out on that page.