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Privacy Notice

The purpose of this Privacy Notice (“Notice”) is to explain how Société Générale’s US and Canada branches, representative offices and subsidiaries (collectively referred to as “SG,” “we,” or “us”) collect, use, share and otherwise process information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with, a particular individual or household (“Personal Information”) with whom we interact in the areas of our brokerage and investment banking, global banking and advisory, global markets and securities services, and global transaction and payment services business units, and through our websites (collectively, the “Sites and Services”). These include employees, officers and directors of our clients, prospective clients, service providers, their affiliates and agents, legal and other authorized representatives and other individuals (together, “you”). Most importantly, this Notice covers how we protect that information. It also addresses the privacy rights you may have under the data protection laws of certain jurisdictions.

If you are a California resident, please also read our California Privacy Notice.

SG Privacy Principles

  • The protection of your Personal Information is important to us and we are committed to safeguarding your privacy. In the sections below we describe how we collect, use, share and safeguard your Personal Information.
  • We want you to understand the type of Personal Information we collect about you, whether directly from you through client onboarding or prospecting processes, through your interactions with us, through third parties or through public sources. For more information, see:
    • Types of Personal Information We Collect
    • How We Use Your Personal Information
  • We strive to keep the information in our records as up to date as possible, which allows us to continue to offer you the highest-quality service, and we rely on you to advise us when your information changes. Depending on how and where you interact with us, you may have a legal right to exercise control over your Personal Information. For more information, see:
    • Data Retention
    • Your Privacy Rights and Choices
  • We strive to safeguard the Personal Information we have about you. For more information, see:
    • How We Protect Your Personal Information
  • We strive to keep you updated about our collection, use and sharing of your Personal Information, even if our practices change over time. If you have any comments, questions, complaints or concerns about any of the information in this Notice, or any other issues relating to our use of your Personal Information, please contact us using the information provided in this Notice. For more information, see:
    • Changes to this Notice
    • Contact Us

Types of Personal Information We Collect and How We Collect It

We take reasonable steps to ensure that the -Personal Information we collect is limited to what we require in connection with the purposes set out in this Notice. Please note that we do not typically offer financial products or services to individuals directly. However, to provide our Sites and Services, we may collect some Personal Information about individuals by fair and lawful means.

We obtain Personal Information from the following categories of sources:

  • Directly from you. For example, from information provided by you in connection with our client onboarding and due diligence processes or your access to or use of our Sites and Services. You may choose not to provide us with your Personal Information. If you choose not to provide us with this information, you may still access and use portions of the Sites and Services. However, you may not be able to use our Sites and Services which require you to provide Personal Information.
  • Indirectly from you. For example, through information we collect in the course of providing the Services to our clients if you are an employee, corporate officer or representative of an SG client.
  • Automatically from you. For example, as you navigate through our websites, information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties. For example, from identify verification services, government or public sources, social media, employers, and service providers that provide services on our behalf. 

The types of Personal Information we collect depends on how you use the Sites and Services and include:

  • Personal Information of employees, officers or representatives of a company (for example, a client of SG) such as name, address, date of birth, nationality, financial information and identity documents;
  • Professional data such as email address, telephone number, professional status and job title;
  • Conversations and other communications with SG (such as calls with SG’s registered traders which are recorded in accordance with applicable regulations);
  • Data relating to your habits and preferences (data which relates to your use of our products and services);
  • Where required by law or regulation, we may collect Personal Information from or about persons connected to corporate representatives with whom we do not directly communicate such as dependents and family members; and
  • Data from your interactions with us through our internet websites and our social media pages (including cookies, connection to online services, IP address and geolocation data).

How We Use and Disclose Your Personal Information

We only collect and use your Personal Information for lawful purposes, such as the provision of financial services, including in particular:

  • To provide the Sites and Services;
  • To develop and maintain our client relationships and communicate with you;
  • For the purpose of performing our rights and obligations under our agreements with you or with the organization you are representing (for example, an SG client);
  • To research, develop, manage, protect and improve our Sites and Services;
  • Where reasonably necessary for compliance with legal and regulatory obligations; and
  • For managing disputes and to protect our rights.

We may need to disclose your Personal Information to our affiliates, our services providers, government entities, regulatory authorities and other third parties for purposes such as:

  • To comply with laws, regulations or binding court orders: We disclose Personal Information about you as required or permitted by law. This includes disclosing Personal Information with regulatory and law enforcement officials, or as necessary to comply with legal requirements, binding court orders or requests from regulatory authorities, exchanges or clearing houses. 
  • Fraud prevention: We disclose Personal Information to third parties where appropriate to protect against fraud, or verify or enforce our terms of use, our other rights or other applicable policies. 
  • Business development: As a global company, we sometimes disclose Personal Information among our affiliates and business units when we believe it will enhance the Sites and Services. We only disclose such Personal Information in conformance with the law and our policies and procedures. 
  • Vendor services: We sometimes disclose Personal Information about you pursuant to agreements with other companies that provide services to us, or to make the Sites and Services available to you. These service providers may provide services to SG such as processing payments and completing transactions, delivering services, data hosting, cloud services, survey administration, providing marketing campaign services and analytics services. These service providers may be located in countries outside of the U.S. or Canada.
  • Corporate transactions: We may also disclose your Personal Information in connection with an SG corporate change including a merger, acquisition or sale of all or any relevant portion of our business or assets.

How We Protect Your Personal Information

We use technical, administrative, physical, electronic, procedural and other reasonable measures to protect the Personal Information we collect or receive. Our information security program is developed in line with appropriate industry standards; however, no information security program is completely secure, and we are unable to guarantee that unauthorized access or disclosures of Personal Information will never occur.

Data Retention

We have developed an SG Records and Information Management Program.   As part of that larger program we maintain policies and procedures that outline how records and the data associated with records, which can include Personal Information, should be maintained. 

SG as a Service Provider

There may be certain circumstances where we process your Personal Information on behalf of one of our clients, customers, affiliates or other third parties, and not for our own purposes. In these circumstances, SG is acting as a service provider in relation to another company that determines how your Personal Information is handled. This Notice will not apply to us when we act as a service provider, and you should instead refer to the privacy notice of the organization that provided us with your Personal Information.

Your Privacy Rights and Choices

Depending on how and where you interact with us, the laws of certain jurisdictions grant privacy rights to individuals. For instance, Canadian data protection laws generally grant individuals the right to access and request the correction of their Personal Information. If you are a California resident, your rights are described in our California Privacy Notice. 

Contact us at the email address below for additional information on these rights and how to exercise them if applicable to you.

Personal Information Outside the United States and Canada

We may process or share Personal Information collected from or about you in any country in which the SG Group or its service providers operate, as permitted by applicable law. As a result, your Personal Information may be subject to the laws of the jurisdictions in which the entities to which it will be disclosed are located and may be made available to the courts and law enforcement authorities of those jurisdictions. SG’s affiliates located in Europe are subject to the General Data Protection Regulation (“GDPR”), which includes additional restrictions on the use and transfer of Personal Information of certain individuals. If you would like more information on GDPR and how SG complies with the regulation, please visit us at https://global.societegenerale.com/en/gdpr/.

Changes to this Notice

We may change this Notice from time to time. When we do, we will let you know by appropriate means such as by posting the revised text on this page with a new “Last Updated” date. All changes will become effective when posted unless indicated otherwise. We encourage you to regularly check this page to review any changes we might make.

Contact Us

If you have any comments, questions, complaints or concerns about any of the information in this Notice, or any other issues relating to our use of your Personal Information under this Privacy Notice, please contact our privacy team by emailing AMER-DPO-INFO@sgcib.com. For Canadian inquiries, the privacy team will include our Canadian Chief Privacy Officer.

Last Updated: January 1,2024

California Privacy Notice

This California Privacy Notice (“CA Notice”) applies to California consumers as that term is used in the California Consumer Privacy Act (“CCPA”). If you are a California consumer, this CA Notice contains relevant information about how Societe Generale’s US branches, agencies, representative offices and subsidiaries (collectively referred to as “SG,” “we,” or “us”) collect, use, share and otherwise processinformation that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with, a particular individual or household (“Personal Information”) about you and describes your rights under the CCPA.  Please note this CA Notice supplements, and should be read together with, our Privacy Notice above.

Within the last twelve (12) months, we have collected the following categories of Personal Information from individuals:

  • Identifiers: such as real name, alias, postal address, unique personal identifier, telephone number, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number or other similar identifiers.
  • Transactions: records regarding the transactions you conduct with us, the communications between us and the requests you make.
  • Internet and similar network activity: such as information about your interactions with or use of our websites, applications, digital ads or other digital platforms.
  • Professional or employment-related information: such as your current job or job history.
  • Call recordings: such as when you call us and subject to your consent.
  • Information that may is deemed “sensitive” under the CCPA, such as government identifiers, login credentials and access codes for your account,
  • Inferences derived from the above information. 

We collect such information for the following purposes:

  • Providing sites and services;
  • Maintaining or servicing accounts;
  • Verifying customer information;
  • Processing transactions;
  • Developing and maintaining customer relationships;
  • Exercising our rights and fulfilling our obligations;
  • Improving our business, our operations, and our websites, applications, and digital platforms;
  • Marketing;
  • Compliance with law and policy; and
  • Addressing, inquiries, disputes, and requests.

We do not “sell” or “share”, as those terms are defined under the CCPA, Personal Information (including Personal Information regarding individuals under 16 years of age). We do not use or disclose information that is deemed sensitive under the CCPA for marketing.  We use such information only for purposes expressly permitted under the CCPA.

We retain the Personal Information we collect for as long as reasonably necessary to achieve the purposes disclosed at the point of collection or in this Privacy Notice, unless a shorter retention period is required by law.  The length of retention may vary depending upon factors such as:

  • Whether we believe you may be eligible for another employment opportunity;
  • Legal, compliance or business recordkeeping requirements; and
  • The need to resolve inquiries or complaints.

We may disclose the Personal Information we collect for the business purposes described above in the following circumstances:

  • To service providers that perform services on our behalf, including shipping, identity verification, mailing, processing transactions, storing data, analyzing data and responding to requests.
  • To affiliates and subsidiaries for the purposes noted above.
  • To law enforcement, government agencies, or third parties as we deem reasonably necessary to comply with laws, support investigations, or protect the rights, property, or safety, or you, use, or others.
  • In connection with an actual or potential corporate change including a merger, acquisition or sale of all or any relevant portion of our business or assets.

Your Privacy Rights and Choices

Depending on how and where you interact with us, you may have a right to one or more of the following with respect to your Personal Information we collect and process.

Right to Know About Personal Information Collected or Disclosed and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you upon request:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting your Personal Information.
  • The categories of third parties to whom we disclose Personal Information.
  • The specific pieces of Personal Information we collected about you.

Right to Deletion

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and notify our service providers and/or contractors to delete) your Personal Information from our records, unless an exception applies.

Right to Correction

You have the right to request that we correct any inaccurate Personal Information that we maintain about you, taking into account the nature of the Personal Information and the purposes of the processing of the Personal Information. Once we receive and confirm your verifiable consumer request, we will use commercially reasonably efforts to correct the inaccurate information.

Exercising Access, Data Portability, Deletion, and Correction Rights

To exercise these rights, please submit a verifiable consumer request to us by contacting us using the contact information provided in this notice.  You will be asked to provide certain Personal Information when submitting your request including your relationship with us, first and last name, email address, telephone number, and postal address in order for us to determine if your Personal Information is in our systems.

We will verify and respond to your request in accordance with applicable law. We may need to request additional Personal Information from you in order to protect against fraudulent or spoofed requests. If you want to make a request through an authorized agent on your behalf, you may use the submission methods noted above. As part of our verification process, we may request that you provide us with the documentation specified under applicable law.

Right to Non-Discrimination

We will not discriminate against you for exercising any of your rights as set forth in this Notice. Unless permitted by the law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to this Notice

We may change this Notice from time to time. When we do, we will let you know by appropriate means such as by posting the revised text on this page with a new “Last Updated” date. All changes will become effective when posted unless indicated otherwise. We encourage you to regularly check this page to review any changes we might make.

Contact Us

If you have any comments, questions, complaints or concerns relating to our use of your Personal Information under this Notice, or to submit a rights request, please contact our Data Privacy Office at AMER-DPO-INFO@sgcib.com or toll free at +1-833-904-0800.

Last Updated: January 1, 2024