©2022 Serai Limited, all rights reserved.
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 to all the personal data we collect when you use Serai and services on or via Serai (collectively, Serai), including
We know that legal terms can sometimes be difficult to navigate, so we want to give you a roadmap of our Privacy Policy:
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 someone other you is also covered by this Privacy Policy.
See Term >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.
See Term >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.
See Term >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.
See Term >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.
See Term >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.
See Term >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.
See Term >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.
Serai users must be adults. Our services are not designed for children under 16 years of age.
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.
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
(b) Information we automatically collect about you when you use Serai, for example:
(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
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.
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:
3.2 We use and intend to use the information we collect or hold about you for the following purposes:
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).
4.1 We may disclose your personal data to the following categories of third parties:
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.
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. All of our servers are located in Hong Kong. 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:
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
5.1 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:
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.
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.
6.1 We may use "cookies" or other tracking software on Serai. Cookies are small pieces of data that are stored on your browser when you visit Serai. We use cookies to save your preferences and to improve your experience using Serai. We use cookies to save your preferences and to improve your experience using Serai. The cookies we use are either strictly necessary, meaning that Serai will not be able to function properly without them; or optional, meaning that they are used to help improve your experience.
6.2 A list of all cookies and other tracking softwares used can be found in our Cookie Policy.
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.
8.1 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:
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.
9.1 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.
10.1 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.
We will use your information for purposes including:
We will use your data to:
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.
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.
We will process your information to prevent and detect crime and fraud as well as to manage risk. From our side, this includes:
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.
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.
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.
We will analyse your information to identify relevant opportunities:
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
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:
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.
We may need to use your data to protect our legal rights and interests. This may include:
The lawful basis for processing your information is our legitimate interest.
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: