Terms of usePrivacy policyContent policy

Serai Privacy Policy

Welcome to Serai. We are committed to transparency about the data we collect about you and your Business on Serai.

Please read our Privacy Policy carefully. Our Privacy Policy applies nto all the personal data we collect when you use Serai and services on or via Serai (collectively, Serai), including

  • seraitrade.com
  • seraitrade.net
  • network.seraitrade.net 
  • any other applications or software we provide.

Our Privacy Policy lets you know how your personal data is used and who we share it with. We collect your personal data to provide services for you. We will never sell your personal data.

We know that legal terms can sometimes be difficult to navigate, so we want to give you a roadmap of our Privacy Policy:

About Serai and our Terms

You confirm that by using Serai you agree to our Privacy Policy.

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The types of personal data we collect and how we collect personal data 

This section is about information that you give us in the course of signing up for and maintaining your Serai account, what types of information and data are gathered automatically by our systems and information we collect from third parties. In particular, you agree that any personal data you provide about someoneother you is also covered by this Privacy Policy.

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How we use personal data 

We need your personal data in order to provide Serai solutions and products to you. We also use this information to improve existing solutions and products and to come up with new and innovative ways to improve and expand your experience on Serai and other purposes listed in this Privacy Policy. We will seek your consent if we wish to use your personal data for purposes other than those listed in this Privacy Policy.

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Disclosure and transfer of personal data

We may disclose or share your personal data with certain trusted third parties (which may be within or outside of the country or region where you live or work) that host our platform, power our emails or provide necessary services to us.

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Use of personal data for direct marketing 

We may use your personal data to send you promotional offers and invitations to events via email, telephone or other means of communication. You may unsubscribe if you no longer wish to receive these.

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Use of cookies and other tracking software

Cookies and other tracking software are used to store your preferences and improve your experience when using Serai. You may disable these settings but this may interfere with your ability to use certain functionalities on Serai.

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 Data security

We work to keep your personal data secure. However, transmission of data via the Internet or mobile networks is inherently risky and we will not be liable for any related loss or damage.

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Your rights

We work to keep your personal data secure. However, transmission of data via the Internet or mobile networks is inherently risky and we will not be liable for any related loss or damage.

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Changes to our Privacy Policy

We may revise our Privacy Policy from time to time and we will let you know of any material changes by sending you an email or other notification.

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Serai users must be adults 

Serai users must be adults. Our services are not designed for children under 16 years of age.

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Appendix A.
How we process your data 
(EEA residents only) 

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Appendix B. 
Personal data we do and do not share (California resident only) 

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1. About Serai and our Privacy Policy

1.1 Serai Limited (us, we, or Company) operates and provides Serai to you (you).

1.2 This Privacy Policy sets out how we collect, use and share personal data collected from you as a user of Serai.

1.3 This Privacy Policy also explains how we ensure that your personal data stays secure and confidential and how we comply with data protection laws.  

1.4 Serai Limited is the data controller (or similar role as is used in applicable data protection laws) and can be contacted at Level 23, One Island East, 18 Westlands Road, Quarry Bay, Hong Kong or at privacy@seraitrade.com

1.5 Capitalised terms used in our Privacy Policy have the same meanings as those defined in our Terms of Use.

1.6 Reference to "personal data" in this Privacy Policy, shall also include reference to "sensitive personal data" (or such similar term), if any, as defined in applicable data protection laws.

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2. The types of personal data we collect and how we collect personal data

2.1 For the purposes outlined in Clause 3, we may request, collect and process the following information about you:

(a) Information you give us (for example when you register for an account, sign up to newsletters or otherwise communicate with us)–, which may include personally identifiable information of you, your employees and individual shareholders such as

  • names
  • email addresses
  • telephone numbers
  • street addresses
  • profession
  • work titles
  • work experience
  • social media accounts
  • solutions and products
  • information and demographic data
  • proprietary information about your business
  • photographs
  • audio responses
  • any other personal information you give us

(b) Information we automatically collect about you when you use Serai, for example:

  • information about how you use Serai, including which solutions your have purchased, details of transactions conducted on Serai, what you click on and/or tap when using our services and transaction pattern behaviour
  • general diagnostic and usage data, including various unique system or hardware identifiers, information about your device, operating system and application software
  • if you enable location services, the real-time geographic location of your device and location search queries
  • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
  •  information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), profiles and products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

(c) Information you give us (for example when you register for an account, sign up to newsletters or otherwise communicate with us)–, which may include personally identifiable information of you, your employees and individual shareholders such as

  • when you are being invited to join Serai
  • provided to us by your employer or colleagues
  • details of solutions you have purchased via Serai from our partners and external providers of Third Party Solutions

2.2 We only retain personal data for so long as it is reasonably necessary to fulfil the purposes outlined in this Privacy Policy and as required under applicable data protection laws.

In some circumstances, we may retain your personal data for longer periods of time, for instance where we are required to do so to meet legal, regulatory, tax or accounting requirements. 

In specific circumstances, we may also retain your personal data for longer periods of time (and where permitted to do so under applicable data protection laws), so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your personal data or dealings.

2.3 Where you provide to us personal data about another person, you must give to that person a copy of this Privacy Policy and, in particular, tell him or her how we may use his or her data, and obtain their permission to share their details with us.

2.4 Certain personal data is required for the provision of our solutions and products. If you are unable to provide us with the personal data we require (for example, data which is marked as mandatory), we may not be able to provide you with all or some of our solutions and products.

2.5 For California, USA residents, please see Appendix B for the categories of personal data collected, and specific information required under applicable data protection laws.

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3. How we use personal data

3.1 We will only use your information where we have your consent or we have another lawful reason for using it. These reasons include where we: 

  • need to process the information to enter into or carry out an agreement we have with you
  • need to process the information to comply with a legal obligation
  • need to pursue our legitimate interests
  • believe the use of your information as described is in the public interest, e.g. for the purpose of preventing or detecting crime
  • need to establish, exercise or defend our legal rights.

3.2 We use and intend to use the information we collect or hold about you for the following purposes:

  • providing our services and solutions and products such as account creation and management, providing the search, connect and messaging functions on Serai and access to Third Party Solutions
  • providing you with alerts, updates, materials or information about our services or other types of services or information
  • conducting data analytics, such as analysing trends, usages and other user behaviours (whether on an individualized or aggregated basis to derive insights
  • administrating your account, including sending push notifications from time to time in order to update you about your Serai account activities and service related information
  • identifying your Account’s tier, subscriptions and purchased solutions
  • communicating with you and responding to your questions or requests
  • improving and designing new solutions
  • improving and developing Serai, such as launching and supporting new features so we can present content and information on Serai in the most effective manner for you and for the device you use
  • conducting big data analytics and commercial exploration of big data applications;
  • verifying your identity
  • detecting anomalies and preventing and/or remediating fraud or other potentially prohibited or illegal activities and otherwise protecting the integrity of Serai
  • responding or taking part in legal proceedings, including seeking professional advice
  • complying with laws and regulations applicable to us
  • all other legitimate business purposes and purposes directly related or incidental to the above.

3.3 We will notify you if we wish to use your personal data for purposes other than those stated in this Privacy Policy and, where required by applicable data protection laws, shall obtain your consent for such purposes.

3.4 Where you are a resident or place of work is in the European Economic Area (EEA), we need to have a lawful reason for processing your personal data. We have set out in Appendix A further details of how we will use your information, including the lawful reasons we rely on when processing your personal data as described in this Privacy Policy. Please note, that where you are in the EEA, we will not rely on your consent to the collection and processing of your personal data (other than for direct marketing).

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4. Disclosure and transfer of personal data

4.1 We may disclose your personal data to the following categories of third parties:

  • any agents, contractors, and service providers which provide services to us in relation to the operation of our business (including without limitation administrative, telecommunications, computer, payment, processing or investigation services)
  • other users of Serai who may be associated with your Business for account creation and management purposes
  • other users of Serai to perform searches and communicate with you
  • any member of our group, which includes our ultimate holding company, and its subsidiaries or affiliates
  • our partners and external providers of Third Party Solutions who may offer their solutions on Serai (on a need-to-know basis only and in order to connect your Account to your selected Third Party Solutions)
  • any persons under a duty of confidentiality to us who requires the personal data in the course of their duties (including auditors and advisors)
  • any person to whom we propose to sell, assign or transfer, or has sold, assigned or transferred, all or any part of our business and/or asset
  • persons to whom we are required to make disclosure under applicable laws and regulations in or outside of the country or region of your residence or place of work (which may include the government, regulatory authorities or law enforcement bodies) or if a regulatory authority or law enforcement body so requires.

4.2 We use a third party payment processor (Payment Processor) to assist in processing your payment information when you make a purchase on Serai. Your payment details such as your credit card number and CVV are collected directly by our Payment Processor. We do not have visibility or store your credit card details and we do not control and are not responsible for the Payment Processor or their collection or use of your information. You may find out more about how our Payment Processor stores and uses your payment information by accessing our Payment Processor’s privacy policy.

We comply with data protection laws when we disclose or transfer personal data

4.3 All of the transfers referred to in Clause 4.1 may occur within or outside the country or region in which you live or work. If we transfer your personal data outside such country or region, we will ensure a comparable degree of security in accordance with the applicable data protection laws and (where required under applicable data protection laws) ensure at least one of the following safeguards is in place:

  • only transferring data to countries that have been approved by the relevant data protection regulatory authority as providing an adequate level of protection for personal data
  • ensuring appropriate contractual protections with the entity to which we are transferring the personal data to as required under applicable data protection laws, which may include entering into standard contractual clauses or data processing agreements
  • ensuring there is no unnecessary sharing of personal data
  • tracking data that has been shared by way of a data log.

4.4 Where you are a resident or place of work is in the EEA, you have the right to ask us for more information about the safeguards we have put in place as mentioned above.

4.5 Where you are a California, USA resident, we need to provide you with information about why we disclose your personal data. Please see Appendix B. Where such disclosure constitutes a sale, you have the right to opt out of the sale of your data to such third party

5. Use of personal data for direct marketing

5.1 We intend to use your personal data in direct marketing, and in certain jurisdictions we can only do this with your consent. You undertake to us that you have the authority to provide personal data to us for this purpose. 

5.2 We may use your name, contact details (including address, contact number, email address, profession, social media accounts), solutions  information, transaction pattern and behaviour, background and demographic information for direct marketing. 

5.3 We may send you targeted and promotional offers, and invitations to events (such as seminars/webinars/tele-seminars, conferences or live programmes) via fax, email, direct mail, telephone (including push notification) and other means of communication. 

5.4 In jurisdictions where we are required by applicable data protection laws to inform you the specific categories of solutions which the direct marketing will relate to, the categories of solutions offered by us, our group members or our Third Party Solutions providers our business partners are:

  •  financial, insurance, credit card, banking, risk and related solutions and products (including marketing affiliates programs we are a part of)
  • business networking services, buyer/supplier discovery tools, import/export facilitation services, marketplace services, market research and competitor intelligence reports
  • counterparty verification, search and insight tools and solutions
  • reward, loyalty or privileges programmes
  • solutions and services for which you have indicated interest for or which we believe may be of particular relevance to you.

5.5 We may also transfer your personal data to our group members so that they may also send you direct marketing on the solutions and products mentioned above. However, in certain jurisdictions we cannot do so without your consent.

You can opt out of our direct marketing

5.6 Where required under applicable laws, we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you. If at any time you, or any other person whose personal data you have provided to us (and provided such person has provided consent to direct marketing), do not wish us to use the personal data for direct marketing as described in Clauses 5.1 to 5.5 above, please contact us at unsubscribe@seraitrade.com, or use the unsubscribe link at the bottom of the direct marketing communication, and we will cease to do so, without charge.

6.  Use of cookies and other tracking software

6.1 We may use "Cookies" or other tracking software on Serai, which are text files placed in your Internet browser or software in Serai.  We use cookies to save your preferences and improve your experience using Serai.  

6.2 Cookies or tracking software on Serai are used to:

  • collect statistical information on how you use Serai to help us understand how users use Serai and help us improve its structure and content
  • collect non-identifiable information to gain a better understanding of user behaviour on Serai to develop engagement strategies to better serve you and to improve the overall user experience
  • gather information such as IP address and browser type or other data to authenticate you and your computer
  • maintain security and verify your details while you use Serai as you navigate Serai, which enables you to avoid having to re-enter your details each time you enter a new page
  • customise settings to offer maximum convenience to you when you use Serai, such as to remember usernames, passwords and preferences
  • track the efficiency of our online advertising campaigns and marketing communications and allow us to deliver advertisements more relevant to you and your interests.

6.3 We may link the data stored in the "Cookies" or other similar tracking software with your personal data. Most browsers are initially set to accept "Cookies", but you can set your Internet browser to reject all "Cookies" or accept just selected types of "Cookies". We will request your consent to use tracking software on Serai if you choose to. Please note that if you decide not to accept "Cookies" or not allow us to use tracking software on your use of Serai, this may interfere with your ability to use certain functionalities of Serai.

7. Data security

7.1 We are committed to safeguarding your personal data and have implemented, and maintain, technical and organisational security measures to secure and keep confidential your personal data against accidental destruction or loss, or the authorised, disclosure or access, theft, misuse, alteration or deletion of your personal data. Such measures shall be appropriate to the nature of the information concerned, including but not limited to ensuring personal data is properly encrypted, adopting authentication techniques and access controls, adopting processes to conduct regular security audits and inspections.

7.2 The transmission of information via Internet or mobile network is not completely secure. The security measures described above do not preclude us from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and we do not warrant that our servers or network will be immune from such attacks.  

7.3 Although we will implement security measures to protect your data, we cannot guarantee the security of the data transmitted to and from Serai via Internet or mobile network. 
7.4 We are not liable for any loss or damage arising from risks relating to any transmission.

8. Your rights

8.1 In accordance with applicable data protections laws, and depending on the country or region in which you live or work, you may have the right to:

  • check whether we hold any personal data about you
  • access any personal data we hold about you and, in some cases, receive information about what information has been collected and how we have used or shared that data
  • require us to correct any inaccuracy or error in any personal data we hold about you
  • where we have obtained your consent, withdraw such consent to processing your personal data (including to ask us not to process your personal data for direct marketing purposes), or where you have registered for an account with us, to request de-registration of your account
  • erase or delete your personal data under certain circumstances
  • request data portability (where processing is carried out by automatic means)
  • object to or restrict the use of your personal data
  • opt-out of the sale of your data to a third party.

8.2 We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you. We reserve the right to charge a reasonable fee where permitted by law, for instance if your request is manifestly unfounded, time-consuming or excessive.

8.3 We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are otherwise legally entitled to deal with the request in a different way.

8.4 To exercise your rights or ask questions about this Privacy Policy, please contact our Data Protection Officer in writing at privacy@seraitrade.com or Level 23, One Island East, 18 Westlands Road, Quarry Bay, Hong Kong. 

8.5 If you have a complaint or concern about how we use your personal data, please contact us or our Data Protection Officer in the first instance and we will attempt to resolve the issue as soon as possible. Where you are resident or place of work is in the EEA, you also have a right to lodge a complaint with your local data protection supervisory authority at any time. We ask that you please attempt to resolve any issues with us before contacting your local supervisory authority.

9.  Changes to our Privacy Policy

9.1 We may amend this Privacy Policy from time to time by posting the updated policy on Serai. By continuing to use Serai after the changes come into effect, you agree to be bound by the revised Privacy Policy. 

9.2 If we make material changes to this Privacy Policy, we will seek to inform you by notice on Serai or email. We will obtain your consent to such changes, if required by data protection laws.

10.  Serai users must be adults

10.1 Serai users must be adults. Our services are not designed for children under 16. 

10.2 If we discover that a child under 16 has provided us with personal information, we will take steps to delete such information from our systems in accordance with applicable laws.

Appendix A.
How we process your information (EEA residents only)

We will use your information for purposes including:

1. Delivering our solutions and products

We will use your data to:

  • administer your Account
  • provide access to Serai
  • provide services that allow you to search, connect and message other users on Serai
  • provide access to solutions provided by Third Party Solutions providers on or off Serai.

The lawful bases for using your information are to perform our contract with you. Processing your information for this purpose is in our legitimate interest.

2. Enabling Serai operations

We will use your data to enable Serai functions and services. Your information helps us provide services such as complaints management and exit management.  

The lawful bases for processing your information are our legitimate interest, legal obligation and to perform our contract with you.

3. Preventing and detecting crime and fraud

We will process your information to prevent and detect crime and fraud as well as to manage risk. From our side, this includes:

  • name screening
  • content screening
  • user risk identification
  • carrying out user due diligence
  • managing, monitoring and mitigating risk

We do this to comply with our legal obligations and because it is in our legitimate interest. We may share your information with relevant agencies, law enforcement and other third parties where the law allows us to for the purpose of preventing or detecting crime. Additionally we, our group companies and our partnering organisations may take steps to help prevent financial crime and manage risk. 

We will do this because we have a legitimate interest, a legal obligation to prevent or detect crime or it is in the public interest. We may be required to use your information to do this, even if you have asked us to stop using your information.

4. Managing risk

We will use your information to measure, detect and prevent the likelihood of financial, reputational, legal, compliance or customer risk. 
We will do this because we have a legitimate interest in ensuring that we carry out a proper risk assessment prior to providing access to Serai and the platform services.

5. Product and service improvements

We will analyse your information to identify possible improvements. We do this to improve our solutions and products to best meet the needs of our customers.

The lawful basis for processing your information is our legitimate interest.

6. Data analytics

We will analyse your information to identify relevant opportunities:

  • to promote solutions to existing or prospective customers
  • to conduct big data analytics and commercial exploration of big data applications
  • to understand how our solutions and products are used.

For example, this may include reviewing your company profile and recommending a connection with another user on Serai with capabilities that we believe will benefit you and vice versa. We do this to help us provide you with solutions and products we think will be of most relevance to you. 

The lawful basis for processing your information is our legitimate interest

7. Marketing

We will use your information to send you information about our products and services, and solutions offered by our partners and other Third Party Solutions providers.

This includes marketing by:

  • post
  • email
  • telephone
  • text
  • messages on Serai
  • social media
  • other online channels

We may need your consent to communicate with you via certain channels. We will always make sure we get this where we need to. You can change your mind on how you receive marketing messages or choose to stop receiving them at any time. To make these changes, contact us in the usual way.

The lawful basis for processing your information is our legitimate interest.

8. Protecting our legal rights

We may need to use your data to protect our legal rights and interests. This may include:

  • managing complaints or disputes
  • defending legal rights and interests, such as intellectual property rights
  • court actions
  • supporting a company restructure or other mergers or acquisition.

The lawful basis for processing your information is our legitimate interest.

Appendix A.
How we process your information (EEA residents only)

For residents of California, USA, this appendix supplements our Privacy Policy regarding categories of personal data that we do and do not disclose to third parties.

Categories of personal data

YES

Collect?

Sale to a third party?

Disclosure to a third party for business / commercial purpose?

Disclosure to a third party service provider

Name, Contact Information and Identifiers
Including real name, alias, postal address, unique personal identifier, online identifier Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

NO

YES

YES

Customer Records
Paper and electronic customer records containing personal data, such as name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

YES

NO

YES

YES

Protected Classifications
Characteristics of protected classifications under California or federal law.

NO

N/A

N/A

N/A

Commercial Information
Including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

NO

YES

YES

Biometric Information

NO

N/A

N/A

N/A

Internet or Network Information
Including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, or advertisement.

YES

NO

YES

YES

Geo-location Data

YES

NO

YES

YES

Audio and Visual Data

NO

N/A

N/A

N/A

Professional or Employment Related Information

YES

NO

NO

YES

Education Information
Defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, 34 C.F.R. Part 99).

NO

N/A

N/A

N/A

Customer Profiling
Information identified to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, preferences, predispositions, behaviour, attitudes, intelligence, abilities and aptitudes.

YES

NO

YES

YES

 We may disclose your personal data to the following categories of third parties:

  • any agents, contractors, and service providers which provide services to us in relation to the operation of our business (including without limitation administrative, telecommunications, computer, payment, processing or investigation services)
  • other users of Serai to perform searches and communicate with you
  • any member of our group, which includes our ultimate holding company, and its subsidiaries or affiliates
  • our partners and Third Party Solutions providers who may offer their solutions on Serai (on a need-to-know basis only) and in order to connect your Account to your selected Third Party Solutions providers
  • any persons under a duty of confidentiality to us who requires the personal data in the course of their duties (including auditors and advisors)
  • any person to whom we propose to sell, assign or transfer, or has sold, assigned or transferred, all or any part of our business and/or asset
  • persons to whom we are required to make disclosure under applicable laws and regulations in or outside of the country or region of your residence or place of work (which may include the government, regulatory authorities or law enforcement bodies) or if a regulatory authority or law enforcement body so requires.