Privacy Policy and the Handling of Personal Information
We Societe Generale Private Banking Japan aims to earn the confidence of customers and be the trust bank of choice. We therefore establish internal rules regarding personal data protection and comply with the relevant laws and regulations and other standards relating to customers' personal data. In order to manage personal data appropriately and safely, we periodically review and improve this policy. We also make every effort to maintain the accuracy and confidentiality of our customers' personal data by conducting regular audits to ascertain that personal data is used in accordance with this policy.
1. ACQUISITION OF PERSONAL DATA
After taking adequate security measures, we may acquire your personal data, including your name, address, date of birth, gender, telephone number, and other identifying information that you provide when transactions are commenced, by mail, internet or telephone. Such information will be acquired only as required for business purpose, using lawful and appropriate means.
2. PURPOSE TO USE PERSONAL DATA
We may use your personal data for services that we are authorized to provide, such as deposits, exchange, loans, foreign exchange, trust, insurance solicitation, and for activities ancillary to these services (including the services we may be authorized to provide in the future).
Your personal data may be used for the following purposes:
(This applies to deposits, exchange, loans, foreign exchange, trust, and insurance solicitation.)
- Receipt of applications and consultation requests related to our financial products and services, such as account applications;
- Recommendations concerning our products and services;
- Identification of a customer or his/her/its agent under the Law for Prevention of Transfer of Criminal Proceeds;
- Confirmation/judgment of suitability of our products and services offered;
- Management of continuing transactions, such as due date control for deposits, loans, or trust transactions, and reporting to and meeting with customers;
- Provision to third parties such as institutions providing personal credit information for the purpose of credit or other operations, only as required for the appropriate conduct of the business operations;
- Provision of information concerning products and services offered by our affiliates, etc;
- Information sharing with our group companies/affiliates, as named in article 5 (1) below, for the purpose of credit operations (including the cases in which both credit and trust operations are conducted) or remittances (including overseas remittances), only as required for the appropriate conduct of business operations;
- Appropriate performing of outsourced operations, where all or part of the processing of personal information is carried out by other enterprises;
- Exercising rights or fulfilling obligations in accordance with a law or an agreement with you;
- Research and development relating to financial products and services, through market research, data analysis and questionnaires;
- Sending of messages of congratulation or condolence;
- Cancellation of transactions, and post-cancellation administration;
- Other matters necessary to the appropriate and efficient performance of transactions and agreements.
We disclose the purposes for which personal information is used, as stated above, by posting this privacy policy on our website, and by making hard copies available for perusal at the reception desk in our office.
We use personal data only for the purposes stated here, and only as required for the performance of business operations. We will also limit the purpose of use in accordance with customers' requests.
3. HANDLING OF SENSITIVE INFORMATION
In accordance with the Ordinance for Enforcement of the Banking Law, etc., we do not use data on our customers' ethnicity, beliefs, lineage, domicile of origin, medical records or criminal background or any other special non-public data, except for purposes deemed necessary for the appropriate performance of business operations, or provide such information to any third party.
4. USE AND PROVISION OF PERSONAL DATA
We do not provide any customer's personal data to a third party without the prior agreement of the customer, except for the purposes of information-sharing or outsourcing, as stipulated herein, and in the following cases:
- When disclosure is required by law;
- When disclosure is required to prevent loss of life, injury, or to protect property (including corporate property), AND it is not possible to obtain the consent of the customer;
- When disclosure is specifically required to improve public health or promote the sound development of children, AND it is not possible to obtain the consent of the customer;
- When disclosure is required in order to assist a national governmental organization or local government, or a party contracted by such organizations, in the performance of their administrative tasks as required by law, AND if the performance of those administrative activities might be hindered by seeking the consent of the customer business;
- When personal data pertaining to real estate, which is held by us in connection with our real estate brokerage business is provided to the following third parties through documents, mails, telephone, the Internet, electronic mail, and advertisements:
- A counterparty to an agreement with us or the counterparty's prospective customers;
- Other building lots and building transaction service providers;
- Internet advertising firms, real estate industry groups;
- The Real Estate Information Network System (for registration of properties, notification of conclusion of a contracmarketing using their data, and property valuation);
- Administrators involved in real estate management;
- Organizations conducting property surveys (surveys on declared prices, benchmark land prices, etc.).We may provide real estate-related information, as necessary, including the relevant customer's name and address, to the following third parties:
- A counterparty to an agreement with us or the counterparty's prospective customers;
- A building lots and building transaction service provider working for the counterparty (including a prospective counterparty) to an agreement with us;
- Judicial scriveners, in relation to property registration, land and building surveyors;
- Financial institutions, in relation to loans.
We will suspend the provision of personal data if so required by the customer concerned.
5. SHARING USE OF PERSONAL DATA
We may share your personal data with other entities only where this is necessary to achieve the purpose for which the personal data are used.
(1) Sharing Entities
The sharing of our customers’ personal data is limited to the following Societe Generale Group companies:
- Societe Generale head office in Paris
- Societe Generale, Tokyo Branch
- Societe Generale Bank and Trust
- Societe Generale Securities (North Pacific) Limited, Tokyo Branch
(For further information on the above Societe Generale Group companies/affiliates, please visit www.privatebanking.societegenerale.co.jp)
(2) Personal Data to be Shared
Name, birth date, address, telephone number, e-mail address, asset situation, etc.
(3) Purpose of Use by Parties to Information Sharing
Appropriate credit and remittance operations (including overseas remittance).
(4) Person responsible for personal data management
Our personal data protection manager.
6. OUTSOURCING OF PERSONAL DATA
We outsource handling of your personal data to third parties only where this is necessary to the performance of outsourced operations. In such cases, we select appropriate outsourcing service providers and supervise them as necessary to ensure appropriate handling and protection of the outsourced personal data by the providers of outsourced services.
The main outsourced operations are as follows:
- Custody and management of securities in relation to our business activities and operations ancillary to those activities;
- Management of documents at external warehouses;
- Systems maintenance and support for systems upgrading.
7. SECURITY OF PERSONAL DATA
We are constantly taking appropriate measures to ensure that our customers’ data is accurate and up-to-date. In addition, we maintain safeguards to protect our customers’ personal data against unauthorized access and computer viruses, etc. in order to prevent data loss, destruction, falsification, leakage, etc.
8. REQUEST FROM CUSTOMERS FOR NOTIFICATION OF PURPOSE OF USE, DISCLOSURE AND CORRECTION OF PERSONAL DATA, AND SUSPENSION/DISCONTINUATION OF USE
(1) Notification, Disclosure, Correction, Suspension of Use, etc.
If you request us to disclose or correct your personal data, to disclose the purpose for which such data are used, or to discontinue our use of such data, we will, after confirming your identity, strive to honor your request in good faith and expeditiously. Such requests should be submitted to the Inquiry Desk, as detailed in article 9 below.
Please note that we may charge you any costs incurred in relation to the disclosure of personal data or notification of the purpose for which it is used.
(2) Discontinuation of Use
If you do not wish to be contacted by direct mail, post, telephone, electronic mail, or any other means, please contact the Inquiry Desk detailed in article 9 below. Thereafter we will cease contacting you by the specified means.
9．INQUIRIES, COMPLAINTS, AND REQUESTS FOR ADVICE
You may contact the Inquiry Desk to request disclosure of purpose for which we use your personal data, the disclosure or correction of such data, or suspension/ discontinuation, etc. of the use of such data, or if you have any question or complaint. regarding our privacy policy.
Privacy Policy Inquiry Desk:
Societe Generale Private Banking Japan
Customer Service Headquarters Privacy Policy Inquiry Desk:
Ark Mori Building 16F,
1-12-32 Akasaka,
Minato-ku,
Tokyo 107-6016 Japan
Tel : 03-6229-4434 （Legal &Compliance Department）
Office Hours 9:00～17:00 (excluding Saturdays, Sundays, national holidays, and year-end/new year holidays)
We are a member of the Trust Companies Association of Japan, a certified personal data protection organization under the Personal Data Protection Law. The Trust Companies Association of Japan maintains an advice center (Shintaku Sodanjo) through which it accepts complaints and requests for advice regarding the handling of personal data by members of the Association.
Trust Company Association of Japan (Shintaku Sodanjo) :
www.shintaku-kyokai.or.jp
Contact for complaints/consultation requests:
Tel : 0120-81-7335 (Free Dial)
10．AMENDMENT
This privacy policy may be amended from time to time to reflect changes in the applicable laws and regulations. When such amendments are made, we will make the amended privacy policy available for perusal on this website and at the reception desk of our office.
July 2010
Christophe Billard
President & CEO
Societe Generale Private Banking Japan