Last Updated: 4/28/2022

This Privacy Notice explains how SMBC collects, uses, discloses, and otherwise processes personal information.

When we use the terms “SMBC”, “we”, “us”, or “our”, we mean the following U.S. Affiliates of Sumitomo Mitsui Banking Corporation:

• SMBC Nikko Securities America, Inc.
• SMBC Capital Markets, Inc.
• SMBC Leasing and Finance, Inc.
• SMBC Rail Services LLC
• Sumitomo Mitsui DS Asset Management (USA) Inc.
• Sumitomo Mitsui Finance and Leasing Co., Ltd. New York Branch
• JRI America, Inc.

SMBC provides financial products and services to businesses. SMBC does not provide any financial services to individuals for personal, family, or household purposes.

This Privacy Notice does not apply to Manufacturers Bank, which maintains its own separate privacy notice.

This Privacy Notice is not a contract and does not create any legal rights or obligations.

If you are a resident of the State of California in the United States, please click here for additional California-specific privacy disclosures.

If you are a resident of the Cayman Islands, the European Economic Area, or the United Kingdom, please click here for additional privacy disclosures.

If you are a resident of Brazil, please click here for additional privacy disclosures.

OVERVIEW

As used herein, “personal information” means information that identifies, is identifiable to, or can be used to identify an individual alone or in combination with other information such as your name, phone number, driver’s license number, or social security number. Personal information does not include aggregate information that cannot be associated with a specific individual, and in certain jurisdictions, it also excludes business contact information. 

We collect and use personal information in the following contexts:

• To Provide Financial Products and Services. The primary reason that we collect and maintain information is to administer our customer relationship. It allows us to identify, improve and develop products and services that we believe could be of benefit. It also permits us to provide efficient, accurate and responsive service, to help protect from unauthorized use of your information and to comply with regulatory and other legal requirements. These include those related to institutional risk control and the resolution of disputes or inquiries.
• Social Media and Online Interactions. We collect personal information from users of our website and from individuals who interact with us through our social media accounts. We may use the personal information we collect from our website and social media accounts for the administration of the website and social media accounts, market research, data analytics, and compliance with our legal obligations, policies and procedures.
• Employment. We collect the personal information of our employees, agents, and contractors when they are applying for employment with us and while they are working for us, which we use in the context of allowing our employees to perform their jobs, in employment and hiring decisions, to maintain emergency contact information, and to provide benefits to our employees. 
• Business Partners and Third-Party Service Providers. We collect personal information of the employees, contractors, owners, officers, and contact persons of our business partners, third-party service providers, and other entities with which we have business relationships, which we use in conducting due diligence, engaging in transactions, and in offering or receiving products or services with these entities.

HOW WE COLLECT PERSONAL INFORMATION

We collect personal information from a variety of sources:

• Information you provide to us at the time you establish a relationship. When you submit an application or complete a form to open an account or start a relationship with us, you will be required to provide us with certain information about your business, and its owners and officers. We collect personal information about owners, officers and guarantors which includes name and personal contact information, date of birth, tax identification number and ownership information. When you open an account or submit an application, we also obtain credit, financial and other personal information about your business, and its officers, owners and guarantors from consumer reporting agencies, credit bureaus, relevant financial institutions, and other entities.
• Information related to any transactions you conduct through us or any services you use. When you engage in financial transactions with us or use our financial services, we may collect personal information about you and any other parties to the transaction, including personal information of your customers and business partners.
• Information you provide when you communicate with us. When you communicate with us or provide us instructions on how to manage your account, whether by letter, telephone, email, or by interacting with our website or social media profiles, we may collect personal information from you to respond to your inquiry or assist in managing your account.
• Information you provide when subscribing to news, alerts and publications. On our website, you may sign up to receive news, alerts and publications from us. To sign up, we may ask you for information such as your name, address, telephone number, email address and topics of interest. We use the information you provide to send you the communications you request. We also may use the information to communicate with you about other topics that we believe may be of interest to you.
• Information you provide when interacting with our social media accounts. You may be able to submit comments or otherwise interact with our website and social media accounts. You may include personal information in your comments, and you also may submit your name and email address with your comments. We may use your name to identify you as a commenter. We may also review or collect the information you provide in your social media profiles.
• Information you provide when you seek employment with us. We collect personal information when you submit your resumé and other information to apply for a job with us and, for current employees, information they provide in the course of their employment. 
• Information about your usage of our website. We may collect certain information about your use of our website and any online services. For example, we may capture the IP address of the device you use to connect to our website, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access, and the site you visit next. We or our third-party partners may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our online services. In addition, we may later associate the usage and other information we collect online with personal information about you. 
• Information from background checks and due diligence. Consistent with applicable law, we may use third parties to conduct background checks on potential and current employees and new customers and due diligence on potential business partners and third-party service providers.
• Information from our business partners and service providers. Our business partners and third-party service providers may provide the personal information of their contact persons and employees so that we may conduct business with them.

HOW WE USE PERSONAL INFORMATION

• To process orders, complete transactions, perform contracts, provide you with financial services and products, and manage your accounts. 
• To evaluate job applicants and contractors for engagements, make employment-related decisions, maintain a list of emergency contacts, and provide benefits to employees and contractors of SMBC.
• We use the personal information of employees and contractors of our business partners and third-party service providers to conduct due diligence, engage in transactions, and offer or receive products or services to and from these entities.
• To ensure that only authorized persons have access to our systems, network, and data.
• To verify your identity and ensure that only authorized individuals have access to customer accounts and funds.
• To respond to your inquiries and provide you with updates or changes to our products, services, and policies, or to otherwise communicate with you.
• To improve our products and services, and to develop new products and services.
• Performing analytics concerning your use of our online services, website, and social media, including your responses to our emails and the pages and advertisements you view.
• Providing you tailored content and marketing messages.
• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.
• To prevent, detect, and investigate fraud and other violations of law or of our policies.
• We may use your personal information to comply with legal obligations, protect and defend the rights and property interests of SMBC, protect against legal liability, prevent or investigate possible wrongdoing, and protect the safety of our employees and the public.
• As otherwise described to you at the point of collection or pursuant to your consent or as otherwise permitted by law.

HOW WE SHARE PERSONAL INFORMATION

We may share the information we collect from and about you with our affiliates and other third parties. For example, we may share your information with:

• Third-Party Service Providers. We may share personal information with third-party service providers that perform services on our behalf, such as processing transactions, providing information technology services, providing employee benefits and services, performing analyses, and conducting due diligence. 
• Our Affiliates. We may share our personal information with our affiliated businesses in an effort to bring you improved service across our family of products and services, when permissible under relevant laws and regulations.
• Other Financial Institutions or Companies. Other companies to bring you co-branded services, products, or programs.
• Third-Party Acquirer(s). In the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). 
• As Required by Law and Legal Proceedings. We may have a legal obligation to disclose personal information to government and law enforcement entities or other third parties pursuant to valid regulatory requests, subpoenas, or court orders. We may also need to disclose your personal information to pursue and defend our legitimate interests and rights, for example, in civil and criminal litigation, to investigate potential misconduct, or to protect the safety of our employees or the public.
• Anonymized or Aggregated Data. We may share anonymous or aggregated information with third parties to help deliver products, services, and content that are better tailored to the users of our online services and for other purposes.

CHILDREN'S PRIVACY

Our products and services are not intended for children or anyone under the age of 13. We do not knowingly collect, maintain, or process personal information from children without parental consent or another form of consent that may be required under applicable law.

LINKS TO OTHER WEBSITES

Occasionally we provide links to other websites for your convenience and information. These websites operate independently from our website and are not under our control. These sites may have their own privacy notices or terms of use, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of the linked sites.

SECURITY

We use reasonable physical, electronic, and procedural safeguards that comply with industry standards to protect and limit access to personal information. This includes device safeguards and secured files and buildings. Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information (such as your tax identification number) to us.

UPDATES TO THIS PRIVACY NOTICE

SMBC is committed to upholding this Privacy Notice. We will update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the "Last Updated" date at the beginning of this Privacy Notice. All changes shall be effective from the date of publication unless otherwise provided.

QUESTIONS?

• Click here: https://secure.ethicspoint.com/domain/media/en/gui/42084/index.html
• Call us at 1-844-201-9810