Sera Global

A leading, independent global private markets advisor

Terms & Privacy Policies

SeraAdvisory.com
Website Terms of Use

Introduction

Please read these seraadvisory.com Website Terms of Use (“Terms of Use”) carefully before using the www.seraadvisory.com website (the “Website”). By browsing, accessing or otherwise using the Website, you agree to accept these Terms of Use.

Your visit to the Website, including, but not limited to, all images, text, illustrations, designs, icons, photographs, programs, music clips, downloads, systems and methods of trading, video clips, graphics, user interfaces, visual interfaces, information, data, tools, products, written materials, services, design, structure, selection, coordination, expression content, information, design, marks and layout therein, including but not limited to the design, structure, selection, coordination, expression and arrangement of any of the foregoing available on or through the Website, together (the “Content”), is subject to these Terms of Use, our Website Privacy Policy and our Cookies Policy, which may be updated by us at any time without notice to you. If we update our Terms of Use, we will post the updated Terms of Use on the Website. Any such changes will be effective upon posting.

If you do not agree with these Terms of Use, you should not use the Website and you agree that your sole and exclusive remedy is to discontinue using the Website.

The Website is not designed for use by minors and minors should not provide personal information through this Website. You may not use the Website if you are under the age of majority in the jurisdiction in which you live or if you cannot form legally binding contracts under applicable law.

For the purposes of these Terms of Use “Sera Global,” “we” and “us” means collectively, Sera Global Securities Canada LP, Sera Global Securities UK LP, Sera Global Real Estate Group UK Limited, Sera Global Securities US LLC, Sera Global Real Estate Group US LLC, Sera Global Real Estate Group Germany GmbH and Sera Global Korea Limited, which control the Website and “User” means any person accessing the Website.

Nothing contained in these Terms of Use is intended to modify any other written agreement you may have with Sera Global (if any) that may be in effect. Additional terms and conditions of use may be applicable to password-restricted areas of the Website.

Any disputes between you and Sera Global in connection with these Terms of Use may be resolved in arbitration or small claims court, subject to applicable law.

If you have any questions or comments about these Terms of Use, please contact us at privacyoffice@seraadvisory.com.

Use of the Website and Content

You are responsible for your use of the Website and the Content. You undertake to use your best endeavors to ensure that nothing you do whilst accessing the Website will damage the Website or otherwise violate these Terms of Use.

The Website, including the Content, is the property of Sera Global or Sera Global’s service providers and is subject to copyright, trademark and other laws. To the extent expressly permitted herein, and subject to your compliance with these Terms of Use, Sera Global grants you a limited, revocable, non-exclusive and non-transferable personal right to view, download and print pages from the Website solely for your personal and non-commercial use. This right will terminate immediately upon your unauthorized use of the Website or Content. Subject to the foregoing, no intellectual property rights in respect of the Website or Content are granted or extended as a result of Sera Global making the Website available. All rights not expressly granted to you in these Terms of Use are reserved.

You may not (and may not procure, encourage or assist others) to:

(i) reproduce, republish, distribute, exploit commercially, use or modify without Sera Global’s express written consent, the Website or Content;

(ii) access, copy or download the Website or Content using automated methods, including but not limited to, “web scraping” or “bots”, “robots” or “spiders” that “harvest” the Website or Content, interfere with the functioning of the Website or Content or restrict or inhibit any others from using the Website or Content;

(iii) use any trademark, service mark or logo of Sera Global or any third party that appears on the Website without prior written consent or remove or obscure any copyright or other notices contained in the Website or the Content;

(iv) if you link other websites to the Website, imply or suggest that Sera Global has endorsed or is affiliated with such websites and you may not display the Website as “framed” or “mirrored” within another website;

(v) delete, decompose, decompile, reverse engineer, disassemble or otherwise deconstruct all or any portion of the Website or Content or any of the Websites’ source code or software;

(vi) transmit any virus, worm, time bomb or similar system interference through the Website;

(vii) violate these Terms of Use, the Website Privacy Policy or Cookies Policy or any law, regulation, rule or intellectual property rights or contractual rights of others, or attempt to violate the security of the Website, including attempting to gain unauthorized access to Content or use or gain access to the identities, information or computers of others through the Website;

(viii) impersonate any person or entity or create a user account for anyone other than yourself or create another user account without permission if Sera Global has suspended or terminated your user account;

(ix) use any hidden text or metatags using “Sera Global” on a website or content published on a website or otherwise; or

(x) use the Website or Content in a way that is not for its intended purpose or that will adversely affect or reflect negatively on Sera Global, or any of Sera Global’s goodwill, name or reputation.

Sera Global has the right (but not the obligation) to monitor the Website for any unauthorized or objectionable conduct and to take all appropriate actions in response, without notice to you, and we may at any time revoke your right to use all or any portion of the Website or Content. Sera Global may investigate any complaint regarding a suspected violation of these Terms of Use, and may report any activity relating to the Website or Content to regulators, law enforcement officials or other persons or entities that it deems appropriate.

The Website or any part of the Website may be periodically unavailable, and Content may be removed or modified at any time without notice. Sera Global may, in its sole discretion, restrict, suspend or cancel access to or use of the Website, for all or any one or number of Users. Users will have no right to compensation or other remedy for being unable to access the Website.

Restricted Access

The Website is operated and controlled by Sera Global in the United States. Access to the Website from countries or territories where such access is illegal is prohibited. Sera Global makes no representations that the transactions, financial or investment products, securities, and other services (“Products or Services“) discussed on or accessible through the Website are available or appropriate for sale or use in all jurisdictions or by all Users. Those who access the Website do so on their own initiative and are responsible for compliance with local laws, rules and regulations.

Website Disclaimers and Limitations of Liability

Subject to any applicable law that cannot be excluded, the Website and Content are provided “as is” and “as available” without any representation, warranty or condition. No reliance should be placed on any information on the Website or the Content. Users agree to bear all risks associated with their use of the Website and Content, including any reliance on the availability, accuracy, completeness, timeliness, usefulness or appropriateness of the Website or Content and you are cautioned to install and use appropriate anti-virus or other protection software in relation to your use of the Website and Content. You agree that Sera Global is not liable for any action you take, omission, or decision you make in reliance on the Website or the Content, subject to applicable law. You should consult directly with your applicable Sera Global professional or your other advisors before acting on any information on the Website or the Content.

The Content and the Website are for informational purposes only and are not investment, professional, legal or other advice nor are they to be relied upon in making an investment or other decision. The Website and Content is not an offer to sell, or a solicitation of an offer to buy and do not constitute an invitation or inducement of any sort to any person. Content available on or through the Website should not be considered as sufficient information upon which to base an investment decision.

Certain information contained on the Website and in the Content may constitute “forward-looking statements” as defined in applicable securities laws.  Forward-looking statements include statements that are predictive in nature, depend upon or refer to future events or conditions, and include statements regarding Sera Global’s competitive strengths, goals, expansion, growth, future success, operations, business, financial condition, expected financial results, performance, prospects, opportunities, priorities, targets, goals, ongoing objectives, strategies, and outlook. Words such as “anticipate”, “estimate”, “expect”, “project”, “intend”, “plan” and “believe” are intended to identify forward-looking statements. No reliance should be placed on forward-looking statements because they involve known and unknown risks, uncertainties, and other factors which may cause the actual results, performance, or achievements of Sera Global to differ materially. Except as required by law, Sera Global undertakes no obligation to update or revise statements or information on the Website or in Content.

Any transactions described on the Website or in any Content as having been engaged in by Sera Global are included as representative transactions for illustrative purposes only. Past performance is not indicative of future results. No assurance or representation is made, that comparable results or any target returns disclosed on the Website or in Content will be achieved.  

You agree that, to the maximum extent permitted by applicable law, in no event shall you seek to hold Sera Global, its affiliates and/or their respective officers, directors, managers, partners, members, shareholders, employees and agents (“Affiliates”), liable and in no event shall Sera Global or its Affiliates be liable to any party, whether in contract, tort (including negligence) or otherwise, for damages (including direct, indirect, incidental, consequential, special, punitive, exemplary and aggravated damages and damages for loss of use, profits or revenue) or any other remedy relating to the access, use, inability to use, availability of the Website or the Content, irrespective of whether Sera Global has been advised of the possibility of such damages and/or losses.

The liability of Sera Global and/or its Affiliates for breach of any condition, guarantee or warranty implied by statute that cannot be excluded, is limited to the maximum extent permitted by law, at Sera Global’s option, to the re-supply of goods or services, or the payment of the costs of having goods or services re-supplied.

Indemnification

You agree that a condition of your use of the Website and Content is that you indemnify the Sera Global, Sera Global Affiliates and their respective representatives harmless against any and all liabilities, losses, damages, suits, claims, demands, costs (including court costs and legal fees), fines and actions of any kind or nature suffered as a result of your use of the Website or Content, your breach, violation or non-performance of any term or condition of these Terms of Use, or your violation of any third party’s rights relating to the Website or Content.

Linked Websites

The Website may contain links to other websites. We make no representations or warranties with respect to and are not responsible or liable for the content, security or privacy practices of other websites and we do not endorse other websites or their content by virtue of linking to them from the Website. Visiting any other website is at your sole risk and you should review the terms of use and privacy policies of any third-party website that you visit.

Password Protected Links

Some pages on the Website are available only to clients with registered accounts and log-on credentials. You are responsible for the confidentiality of your log-on credentials and account information, and for all actions taken on the Website while logged on with your credentials. You should not disclose your log-on credentials or account information and you should choose a unique password. Sera Global reserves the right to suspend or cancel Website accounts and log-on credentials at any time, for any, or no, reason and without notice. If you suspect that your log-on credentials have been compromised, please notify us immediately using the support contact information provided on the relevant account log-on page.

Pages on the Website that are accessible only via registered accounts and with log-on credentials are only available to institutional or professional Users. By accessing such pages, Users will be deemed to have confirmed that they meet the criteria for this classification. Such confirmation will be treated by Sera Global as the User’s acceptance that they understand the classification of these Terms of Use as applicable under the regulatory regime of their country of residence.

User Content

Electronic communications can be intercepted by third parties and electronic mail and other transmissions to and from the Website and Sera Global may not be secure. Any communications to Sera Global should be sent to the contact information provided in the “Contact Us” section of the Website. You are responsible for any content that you post on the Website or submit to us via contact forms on the Website, email, social media accounts or otherwise, including your feedback, comments, questions, ideas, suggestions, survey responses or other information or materials (“User Content”). You hereby represent and warrant that any User Content you submit to us is either your original content or that you have obtained all necessary rights to your User Content, including the right to authorize us to use your User Content as set forth in these Terms of Use. By submitting any User Content, you hereby grant to Sera Global an irrevocable, perpetual, worldwide, non-exclusive, transferable, royalty-free, fully paid-up, sub-licensable license to use, display, reproduce, publish, transmit, store, modify and create derivative works of your User Content.

Material Interests

Any part of Sera Global and/or its Affiliates may have or have had an interest or holding, relationship or other arrangement with the Products or Services, which may be material. Potential investors should refer to the applicable offering documents for any Product or Service and in particular, the potential conflicts of interest discussed therein.

Applicable Definitive Agreements

All Products and Services of Sera Global are offered and governed by the terms of applicable definitive agreements entered into with the relevant Sera Global entity(ies).

Notice to California Residents

Under California Civil Code Section 1789.3, you may contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs in writing at 1625 N. Market Blvd., Suite S-202, Sacramento, California 95834, or by telephone at (800) 952-5210 in order to resolve a complaint regarding the service or to receive further information regarding use of the service.

Dispute Resolution by Binding Arbitration

Subject to applicable law, in the interest of resolving disputes between you and Sera Global, you agree that Sera Global may, at its sole discretion, require that a dispute arising out of or in connection with these Terms of Use or your use of the Website or Content shall be resolved through binding arbitration or small claims court, at Sera Global’s option, instead of in courts of general jurisdiction. Arbitration is more informal than a lawsuit in court. Arbitration uses a neutral arbitrator instead of a judge or jury, allows for more limited discovery than in court, and is subject to very limited review by courts.  Arbitrators can award the same damages and relief that a court can award. Any arbitration under these Terms of Use will take place on an individual basis; class arbitrations and class actions are not permitted.  You acknowledge and agree that the arbitrator may award relief (including monetary, injunctive, and declaratory relief) only in favor of the individual party seeking relief and only to the extent necessary to provide relief necessitated by that individual party’s claim(s).  Any relief awarded cannot affect other Users.

Governing Law

Subject to the Disputes Resolution by Binding Arbitration section above, these Terms of Use and the rights and obligations of any recipient or viewer of the Website or the Content (and any person that they represent) arising out of or in connection with the Website or the Content, whether contractual, non-contractual, pre-contractual or otherwise, are governed by the laws of the State of New York and any disputes arising out of or in connection with the foregoing shall be subject to the exclusive jurisdiction of the state or federal courts located in New York City. You agree to waive trial by jury in any such action.

Additional Terms

No waiver by Sera Global or any of its Affiliates of any right under or term or provision of these Terms of Use will be deemed a waiver of any other right, term or provision of these Terms of Use. If any provision of these Terms of Use shall be deemed unlawful, void or for any reason unenforceable, then that provision shall be deemed severable from these Terms of Use and shall not affect the validity and enforceability of any remaining provisions.

Except as expressly set forth in these Terms of Use, Sera Global’s rights and remedies under these Terms of Use are cumulative and not exhaustive or exclusive of any other rights or remedies to which Sera Global may be lawfully entitled under these Terms of Use or at law, and Sera Global will be entitled to pursue any and all of its rights and remedies concurrently, consecutively and alternatively.

The provisions of these Terms of Use will inure to the benefit of and be binding upon you and Sera Global and your respective successors and permitted assigns.

You will not assign, transfer, delegate, license, sub-license or grant these Terms of Use or your rights, duties and obligations under these Terms of Use without Sera Global’s express prior written consent, which consent may be withheld in Sera Global’s discretion. Sera Global may, without your consent, assign these Terms of Use or any of Sera Global’s rights, duties or obligations under these Terms of Use.

 These Terms of Use set forth the entire agreement between you and Sera Global regarding the subject matter of these Terms of Use and supersede all previous communications, representations, negotiations, discussions, agreements, or understandings, whether oral or written, with respect to the subject matter of these Terms of Use.

 You should be aware that any rules and/or regulations applicable to the provision of financial services (and the resultant investor protection benefits that may be available), may not be applicable to interfacing conducted through the internet and its various applications, of which this material forms part.

Scope of Sera Global Operations

Any person interested in seeking the Products of Services of Sera Global should consult with individuals associated with the Sera Global entity(ies) in their financial center. Products and Services described herein may be conducted by certain Sera Global entities and not others. Sera Global entities are operated generally corresponding to the financial centers in which they cover and are located. Certain Sera Global entities are licensed, registered or regulated to conduct the Products and Services described.

Canada

In Canada, Sera Global operates under its entities Sera Global Securities Canada LP. Sera Global Securities Canada LP is a Dealer Member of the Investment Industry Regulatory Organization of Canada (“IIROC”) and a Member of the Canadian Investor Protection Fund (“CIPF”). Products and Services provided by Sera Global Securities Canada LP are intended only for use by clients that each qualify as an “Institutional Customer,” as such term is defined in the rules and regulations promulgated by the IIROC, including IIROC Dealer Member Rules (generally includes Acceptable Counterparties, Acceptable Institutions, Regulated Entities and non-individuals with total securities under administration or management exceeding $10 million). You and Sera Global have each expressly requested and required that these Terms of Use be drawn up in the English language. Les parties conviennent et exigent expressément que ce contrat et tous les documents qui s’y rapportent soient rédigés en anglais.

United Kingdom

In the United Kingdom, Sera Global operates under its entities Sera Global Securities UK LP and Sera Global Real Estate Group UK Limited.  Sera Global Securities UK LP is authorized and regulated by the Financial Conduct Authority of the United Kingdom (“FCA”) (authorisation number 507475). Its registered office is at 85 King William Street, London EC4N 7BL, United Kingdom. Products and Services provided by Sera Global Securities UK LP are intended only for use by clients that each qualify as a “Professional Client,” as such term is defined for purposes of the FCA Handbook (generally includes an authorized institutional investor or any undertaking meeting two of the following on a company basis (i) balance sheet total of EUR 20,000,000, (ii) net turnover of EUR 40,000,000 and (iii) own funds of EUR 2,000,000).  Nothing in these Terms of Use shall exclude or restrict any duty or liability of Sera Global Securities UK LP under the United Kingdom regulatory system, as defined for the purposes of the FCA Handbook.  In the United Kingdom, the Content contained on the Website are intended only for persons having professional experience in matters relating to investments falling under the Financial Services and Markets Act 2000 or for persons to whom it can otherwise lawfully be distributed.

United States

In the United States, Sera Global operates under its entities Sera Global Securities US LLC (“BFS US”) and Sera Global Real Estate Group US LLC.  BFS US is a broker-dealer registered with the U.S. Securities and Exchange Commission and a Member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and of the Securities Investor Protection Corporation (“SIPC”). Products and Services provided by Sera Global are intended only for clients that each qualify as an “Institutional Account” as defined under FINRA Rules (generally includes any entity with total assets of at least US$50 million) and other institutional-quality clients. Clients may check the background of Sera Global and its registered individuals on FINRA’s BrokerCheck.

Under FINRA Rule 2267, Sera Global hereby provides Users with the following information:

FINRA publishes an investor brochure that includes information describing FINRA

Website Data Protection Policy and Privacy Notice for Sera Global

1. What is the purpose of this Notice?

This is the website data protection policy and privacy notice (“Notice”) for Sera Global (i.e. the Sera Global entities and Sera Global affiliated entities listed in Appendix A, being the Sera Global entity to which this Website relates).

This Notice applies to users of the Sera Global website https://www.seraadvisory.com/ and any other Sera Global websites that link to this Notice (“Websites”).

At Sera Global, we respect your privacy, and this policy, together with the Website Terms of Use and our Cookie Policy which can both be found on the Website here [Terms of Use] and here [Cookies Policy], governs how Sera Global collects, processes, and uses your Personal Data (as defined below) when you use the Websites. For the purposes of certain data protection and privacy laws Sera Global acts as a controller in respect of your Personal Data.

Sera Global may, from time to time, review and update this Notice and you should review it periodically. Sera Global will maintain the latest version of this Notice on the Websites. This Notice was last updated 1st February 2021.

2. What is Personal Data?

“Personal Data” has the meaning given in applicable data protection legislation (and for the purposes of California residents means ‘Personal Information’ as defined under the California Consumer Privacy Act) and for the avoidance of doubt means any information which directly or indirectly identifies a natural living person, which is in the possession of, or likely to come into the possession of, Sera Global (or its representatives or service providers). Such Personal Data includes name, an identification number, email address, address, telephone number, location data, financial data, or an online identifier of that natural person. In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Sera Global or any other person in respect of an individual.

3. What Personal Data does Sera Global collect and why?

If you are a Sera Global employee or a Sera Global client, Sera Global’s policies and practices regarding the collection and processing of your Personal Data are detailed in Sera Global’s Employee Data Protection Policy and Privacy Notice and External Data Protection Policy and Privacy Notice, respectively. If you make an application for employment with Sera Global, the collection and processing of your Personal Data is detailed in Sera Global’s Applicant Data Protection Policy and Privacy Notice which is also available on the Website.

For all other individuals, Sera Global may collect and process the following categories of Personal Data about you from the sources identified as follows:

I. Websites Data. We may collect and process Personal Data about you when you browse the Websites. Websites Data may include information submitted as part of completing online forms on the Websites (including, but not limited to, name, age, date of birth, address, gender, nationality, citizenship and contact information); and technical information collected by cookies (see below) about the services that you use and how you use them, which may include device-specific information, your navigation throughout the Websites, and other technical and browsing preferences including your location and entry point to the Websites. Please note that if you do not provide certain Personal Data to Sera Global when requested (and where relevant, provide your consent) we may not be able to provide you with access to all areas of the Websites and associated services.

II. Identity Verification Information. To help us respond to requests for data access and/or deletion requests as required by applicable laws, as well as create and maintain a trusted environment, we may collect identity verification information from you, such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws, or other authentication information.

III. Communications Data. We may collect Personal Data that you provide when you contact Sera Global for any reason, such as to express an interest in obtaining additional information about our services, direct questions or concerns about our services to us, use a “Contact Us” form or similar features, sign up for our emails or attend an event, or download certain content. Such information may include contact information such as name, job title, company name, phone number, and email address.

IV. Reputation & Background Check Data. We may collect Personal Data from you and from third parties in connection with performing diligence on our service providers and business partners. This data may include contact details, information concerning business practices, creditworthiness, reputation and business history, and job titles or roles.

V. Cookies. Please refer to our Cookie Policy, which can be found here [Cookies Policy], which forms part of this Notice.

VI. Do Not Track. Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals via your browser settings to express your preferences regarding online tracking. Due to the lack of any standard for how do-not-track should work on commercial websites, we do not currently respond to such signals. Third parties, such as our analytics providers, from time to time may collect Personal Data that relates to you on the Websites, over other websites. We cannot control third parties’ responses to do-not-track signals or other such mechanisms. Third parties’ use of Personal Data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.

4. How does Sera Global use your Personal Data?

Your Personal Data may be collected, stored, disclosed, and processed by Sera Global for the following purposes:

I. to provide you with marketing communications and inform you about news and information relating to our business and services, including new product launches, product updates and general business news;

II.  to assess your application for Sera Global ‘s products and services, where applicable;

III.  to understand your needs and interests and to respond to your enquiries;

IV.  to analyze and improve our services;

V.   for the management and administration of our business;

VI.  to provide you with the products and services for which you subscribe;

VII. to comply with and in order to assess compliance with applicable laws, rules and regulations (including tax reporting purposes pursuant to tax legislation), industry codes, voluntary codes we decide to adopt, or good practice, anywhere in the world and internal policies and procedures;

VIII. to confirm and verify your identity and to conduct due diligence, background and related checks (this may involve the use of a credit reference agencies and/or other third parties acting as our agents to conduct these verifications and related reviews including screens against publicly available government and/or law enforcement agency sanctions lists);

IX.  to detect, investigate and prevent fraud and other crimes or malpractice;

X.  for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings);

XI.  to obtain legal advice or to establish, exercise or defend legal rights;

XII. the administration and maintenance of databases storing Personal Data;

XIII. to comply with our contractual obligations;

XIV.  for ongoing review and improvement of the information, content and services provided on the Websites to ensure they are user friendly and to prevent any potential disruptions such as cyber-attacks;

XV.  to analyze and report on the Websites traffic, marketing and usage trends;

XVI. to allow you to use and access functionality provided by the Websites;

XVII. to conduct analysis required to detect malicious data and understand how this may affect your IT system;

XVIII.  for statistical monitoring and analysis of current attacks on devices and systems for the on-going adaption of the solutions provided to secure systems and devices against current attacks;

XIX. for in-depth threat analysis; and

XX. for purposes otherwise set out in this Notice.

Sera Global is entitled to use your Personal Data for the purposes listed above because one or more of the following legal bases applies:

I.  Sera Global needs to do so in order to perform its contractual obligations to you;

II. Sera Global has obtained your specific and informed consent (which may include written consent) in accordance with applicable data protection and privacy laws unless an exemption provided under applicable law permits the use and disclosure of your Personal Data without your consent;

III. Sera Global has legal or regulatory obligations that must be discharged;

IV.  Sera Global may need to do so to establish, exercise or defend its legal rights or for the purpose of legal proceedings;

V.  the use of your Personal Data as described is necessary for our legitimate business interests or the legitimate interests of a third party provided such interest are not overridden by your rights or interest, including

i. allowing Sera Global to effectively and efficiently, administer and manage the operation of its business;

ii. maintaining compliance with internal policies and procedures;

iii. considering you for a position at Sera Global; or

iv. for internal research purposes.

If you are located in a jurisdiction which requires us to obtain your consent to collect, use, store, process and disclose your Personal Data, you understand that by accepting the terms of this Notice you expressly provide your consent to Sera Global collecting, using, storing, processing and disclosing your Personal Data as set out in this Notice.

5. For what purpose does Sera Global disclose your Personal Data to third parties and which third parties does Sera Global disclose your Personal Data to?

Sera Global does not sell Personal Data to third parties. Sera Global may share anonymous or aggregated data with third parties such as service providers to facilitate our business operations. Sera Global may share or provide access to your Personal Data among its affiliates and business units and third-party agents, service providers and contractors outside of Sera Global:

I. for the purpose of the management and administration of Sera Global’s business;

II. to assess your application and verify the information you have provided;

III. for the purpose of the administration and maintenance of the databases storing Personal Data;

IV.  for the purposes of Sera Global receiving or enhancing services (for example, Sera Global’s accountants, administrators, auditors, service providers, custodians, depositories, third party managers, paying agents, professional advisors, IT and communications providers or any entity we reasonably consider necessary for the purposes outlined above). These third parties are expected to be subject to confidentiality requirements (either by contract, professional obligation, duty or otherwise) that require them to only use your Personal Data as described above;

V.   to the extent required by law (for example, if Sera Global is compelled by an obligation or a duty to disclose your Personal Data where we believe it is necessary or appropriate to comply with any legal obligation, rule, regulations or internal Sera Global policies and procedures, including (without limitation) to comply with tax reporting requirements and other statutory reporting and disclosures to regulatory authorities), or to establish, exercise or defend its legal rights. This may include disclosure to regulatory bodies or government agencies);

VI.  as part of a transaction, financing, or for other business needs (for example, if Sera Global sells any of its businesses or assets, applies for a loan, or opens bank accounts, in which case Sera Global may need to disclose your Personal Data to the prospective buyer, lender or bank as part of certain due diligence processes); or

VII. if Sera Global or any of its affiliates, divisions or business units is acquired by a third party, including in the unlikely event of a bankruptcy, in which case the Personal Data held by Sera Global about you will be accessible to, and may be acquired by, the third-party buyer.

6. Is Sera Global responsible for third party websites linked in the Websites?

The Websites may contain links to other party websites that are not governed by this Notice. Linked sites may have their own privacy notices or policies, which you should review. Sera Global is not responsible for the content of links or third-party websites and your use of such third party websites is at your own risk.

7. Does Sera Global transfers your Personal Data to other jurisdictions?

Sera Global operates globally. This means Personal Data may be processed and disclosed as described above, in any country in which we conduct business or have a service provider. Accordingly, when you provide your Personal Data to Sera Global, you acknowledge and agree that we may disclose your Personal Data to recipients (including, but not limited to service providers, Sera Global affiliates or agents, and Sera Global IT severs) located in jurisdictions other than your own, including but not limited to the following countries: Canada, South Korea, UK, USA and Germany.

To the extent that applicable data protection and privacy laws do not allow or permit us to obtain your valid consent by virtue of providing this Notice to you, or otherwise rely on the other grounds set out in this Notice for disclosing your Personal Data outside of your jurisdiction under the data protection and privacy law of your jurisdiction, we will obtain your explicit consent through other means (if applicable) or, where relevant, ensure that the recipient is bound by data protection and privacy laws of its jurisdiction to provide a standard of protection to your Personal Data that is equivalent to that under the data protection and privacy laws of your jurisdiction.

In other circumstances, data protection and privacy laws may permit Sera Global to otherwise transfer your Personal Data outside your jurisdiction provided it is compliant with such data protection and privacy laws.

8. How does Sera Global safeguard your Personal Data?

Sera Global has implemented commercially reasonable controls and appropriate technical and organizational measures to protect Personal Data, as well as to maintain the security of our information and information systems in respect of Personal Data. Files containing Personal Data are protected with safeguards according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems and used where appropriate. Reasonable measures are taken to ensure physical access to Personal Data is limited to authorized employees.

As a condition of employment, Sera Global employees are required to follow applicable laws and regulations, including in relation to data protection and privacy laws. Unauthorized use or disclosure of confidential information by a Sera Global employee is prohibited and may result in disciplinary measures.

When you contact a Sera Global employee about your file, you may be asked to confirm some details relating to the Personal Data Sera Global holds about you. This type of safeguard is designed to ensure that only you, or someone authorized by you, has access to your file.

 Other procedures, which Sera Global has in place to ensure your Personal Data is kept safe and secure include:

I. Firewalls;

II. intrusion detection;

III. 24/7 physical protection of the facilities where your Personal Data is stored;

IV.  background checks for personnel that access physical facilities; and

V.  security procedures across all service operations

9. How long does Sera Global retain your Personal Data?

The period for which Sera Global will hold your Personal Data will vary and will be determined by the following criteria:

I.  the purpose for which Sera Global is using it. Sera Global is required to retain the Personal Data for as long as is necessary to satisfy or meet the purposes for which it was obtained including applicable legal or regulatory requirements; and

II. legal Obligations. Laws or regulations may set a minimum period for which Sera Global must retain your Personal Data.

Depending on the requirements of the data protection law of your jurisdiction, Sera Global will take reasonable steps in the circumstances to destroy your Personal Data when we no longer have a legal basis to retain it or to ensure that the Personal Data is anonymized.

10.   What are your rights in respect of your Personal Data?

To the extent provided by the law of your jurisdiction, you may have legal rights in relation to the Personal Data about you that Sera Global holds. These rights may include:

I.  the right to refuse to provide any Personal Data and the right to object at any time to the processing of your Personal Data. Please note that such refusal or objection may prevent us from providing services to you;

II.  the right to obtain information regarding the processing of your Personal Data and access to the Personal Data about you that Sera Global holds (including any available information as to the source of the Personal Data);

III. where consent was provided for certain processing activities, the right to withdraw your consent to the collection, processing, use and disclosure of your Personal Data at any time. Please note, however, that this will not affect the lawfulness of any collection, processing, use, or disclosure undertaken before your withdrawal and that Sera Global may still be entitled to process your Personal Data if it has another legitimate reason (other than consent) or a consent exception for doing so. In some cases, withdrawing your consent to the collection, use process or disclosure of some or all your Personal Data may prevent us from providing services to you;

IV.  in some circumstances, the right to receive some Personal Data in a structured, commonly used, and machine-readable format and/or request that Sera Global transmit that data to a third party where this is technically feasible. Please note that this right may, depending on the jurisdiction, only apply to Personal Data that you have provided to Sera Global;

V.   the right to request that Sera Global rectify your Personal Data if it is inaccurate or incomplete;

VI.  in some circumstances, the right to request that Sera Global erase your Personal Data. Please note that there may be circumstances where Sera Global is legally entitled to retain Personal Data regardless of any such request;

VII. in some circumstances, the right to request that Sera Global restrict, anonymize, or block its processing of your Personal Data. Again, there may be circumstances where Sera Global is legally entitled to refuse that request;

VIII. in some circumstances, the right to obtain information about the public and private entities with which Sera Global made shared use of the Personal Data as a joint controller

IX.  in some circumstances, the right to receive information on the possibility of not providing consent and on the consequences of the refusal;

X.   in some circumstances, the right to non-discrimination against you for exercising your legal rights in relation to your personal data; and

XI. where applicable, the right to lodge a complaint with the data protection regulator in your jurisdiction if you think that any of your rights have been infringed by Sera Global.

You can enquire about your rights, which are applicable to you, by contacting Sera Global’s privacy Office using the details listed below in Section 16. Sera Global will respond to your requests within the time frames set out in applicable data protection laws.

11.   Does Sera Global collect Personal Data from children?

The Websites are intended for use by those over 18. We do not knowingly solicit or collect Personal Data on the Websites from children under the age of 18.

12.   Does Sera Global process your Personal Data for marketing purposes?

To the extent permitted by applicable law, we may contact you by mail, e-mail, SMS/text, telephone and other electronic means to provide information on products and services that we believe will be of interest, unless you object to receiving such information. If you do not want to receive such communications from us, please contact Sera Global’s Privacy Office on the details set out below in Section 16 or by using the opt-out facilities provided within the relevant marketing material.

Your option not to receive promotional and marketing material:

I.  shall not preclude us from corresponding with you, by email or otherwise, regarding your relationship with us (e.g., your account status and activity or our responses to questions or inquiries you pose to us);

II. shall not preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing your Personal Data for our internal business purposes; and

III. shall not preclude us from disclosing your Personal Data as described in this Notice for purposes other than sending you promotional and marketing materials.

13.   Does Sera Global use Personal Data in relation to data subjects in Canada and Australia?

Canadian Anti-Spam Legislation requires that commercial electronic messages (“CEMs“) sent within Canada or into Canada from another jurisdiction may only be sent to individuals who opt into receiving them, subject to certain exceptions. Similar legislation applies in Australia (Spam Act 2003 (Cth)). Such consent may be implicit, such as by engaging in a prior business relationship, or by virtue of having one’s email address listed in a public directory. These anti-spam laws also require senders to include an opt-out function such as an “unsubscribe” mechanism within a CEM. You may opt-out of the collection or use of your information by Sera Global. In some cases, withdrawing your consent to the collection, use or disclosure of some or all of your personal information will prevent us from providing services to you.

To opt-out, please contact Sera Global’s Privacy Office using the details set out below in Section 16. Please note that in some cases Sera Global is permitted to send you certain material after you opt out, such as where required to enforce legal rights.

14.   What are your rights in respect of your Personal Data under the California Consumer Privacy Act?

If you are a California resident, you have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies you for the third-parties’ direct marketing purposes. Sera Global does not share Personal Data with third parties for those third parties’ own direct marketing purposes.

Effective 1 January 2020, the California Consumer Privacy Act (“CCPA”) provides you with certain rights that are in addition to the rights set out in Section 10 above:

I.  the right to request, up to twice in a twelve-month period, your Personal Data in a format that is portable and, to the extent technically feasible, in a readily useable format that will allow you to transmit it to another entity;

II.  the right to request that Sera Global delete your Personal Data, except in circumstances where Sera Global is legally entitled to retain Personal Data regardless of any such request; and

III.  the right to opt out of any sale of your Personal Data to any third parties, without experiencing any discrimination, as defined under applicable law, as a result of your exercise of this right.  Please note that Sera Global does not sell Personal Data to third parties.

If you are a California resident, Personal Data will include the full definition of “Personal Information” under the CCPA. If you wish to exercise any of the rights enumerated in this Section 14, please contact Sera Global’s Privacy Office using the details set out below in Section 16.

15.   Additional information required for Australian residents

If We will deal with your Personal Data (which has the same meaning as “Personal Information” under the Privacy Act 1988 (Cth), namely any information from which your identity is apparent or can be reasonably ascertained), in accordance with Australian privacy requirements including the Privacy Act 1988 (Cth) and Australian Privacy Principles, the Spam Act 2003 (Cth), the Do Not Call Register Act 2006 (Cth) and any applicable state/territory privacy laws or industry codes. Information that is not “about” an individual is not considered “Personal Data” under Australian law.

If you contact us to access your Personal Data, to seek to correct it, or to make a complaint about privacy, we will respond as soon as we reasonably can, and in any event within any timescales stipulated by applicable law. We do not impose any charge for a request, but we may charge you a reasonable fee for our costs associated with providing you access and retrieval costs. For complaints about privacy, we will establish in consultation with you a reasonable process including time frames, for seeking to resolve your complaint.

16.   How can you contact Sera Global?

If you have any questions or concerns about Sera Global’s handling of your Personal Data, or about this Notice, please contact our Sera Global Privacy Office using the contact information set out below:

Email: privacyoffice@seraadvisory.com

We are typically able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Privacy Office, you may escalate concerns to the applicable privacy regulator in your jurisdiction, the details of which can be obtained from the Privacy Office.

Appendix A

Canada

  • Sera Global GP Inc.
  • Sera Global Securities Canada LP
  • Sera Global International Holdings Inc.
  • Sera Global Holding LP
  • Sera Global Securities Canada (GP) Limited
  • Sera Global Administration Canada LP
  • Sera Global Administration Canada (GP) Limited

USA

  • Sera Global Real Estate Group US LLC
  • Sera Global Securities US LLC
  • Sera Global Real Estate California Corporation Inc.
  • Sera Global US Holdings LLC

United Kingdom

  • Sera Global Securities UK LP
  • Sera Global Real Estate Group UK Limited
  • Sera Global Securities UK (GP) Limited
  • Sera Global Europe Holdings Limited 

Germany

  • Sera Global Real Estate Group (Germany) GmbH

Korea

  • Sera Global Korea Limited

Cookies Policy

Last updated: 1st February 2021

Cookies are used on this website. “Cookies” are small text files that store information about your interactions with a website, either temporarily or more permanently on the hard drive of your device. This website uses cookies to distinguish you from other users of this website, which helps us to provide you with a good experience when you browse this website and also allows us to improve this website. By continuing to browse this website, you are agreeing to our use of cookies.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of this website. They include, for example, cookies that enable you to log into secure areas of this website.
  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around this website when they are using it. This helps us to improve the way this website works for example, by ensuring that users are finding what they are looking for easily.

Please note that third parties (including, for example, our affiliates, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access important functions or areas of this website.

Users may allow, block or remove cookies installed on their computer or device by changing the configuration of the used browser. Example (for Internet Explorer): Go to Tools > Internet Options > Privacy.

External Data Protection Policy & Privacy Notice for Sera Global

1. Introduction

This is the client data protection policy and privacy notice (“Policy”) for Sera Global (as defined below). This Policy applies to clients (as defined below).

At Sera Global, we respect Your privacy, and this Policy governs how Sera Global collects, processes and uses Your Personal Data (as defined below). For the purposes of certain data protection and privacy laws, Sera Global acts as a controller in respect of Your Personal Data.

The purpose of this Policy is to tell You what to expect Sera Global to do with Your Personal Data when You contact us or use one of our services. The Policy sets out the essential information such as the what, where, when and how Your Personal Data is collected. The information in this Policy should help You to feel more confident about the privacy and the security of Your Personal Data which Sera Global collects and uses.

Please read this Policy carefully. This Policy may change from time to time and You should review it periodically. The most recent version of this Policy can be found on the Sera Global website.

This Policy was last updated 1st February 2021.

2. Definitions The following definitions shall apply to this Policy:

“Sera Global”, “we”, “us”, “our” means the Sera Global entities and Sera Global affiliated entities listed in Appendix A.

“Client” means an individual or entity that uses Sera Global for advisory services or uses Sera Global as an intermediary to deploy their capital in a managed investment vehicle that Sera Global is helping to raise money for.

“Personal Data” has the meaning given in applicable data protection legislation (and for the purposes of California residents means ‘Personal Information’ as defined under the California Consumer Privacy Act) and for the avoidance of doubt means any information which directly or indirectly identifies a natural living person, which is in the possession of, or likely to come into the possession of, Sera Global (or its representatives or service providers). Such personal data includes name, an identification number, email address, address, telephone number, location data, financial data, or an online identifier of that natural person. In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Sera Global or any other person in respect of an individual.

You“, “Your” means a living individual, who may be:

a) A Client or prospective Client; or

b) an employee, director, officer, trustee, beneficiary, or representative or intermediary of a Client or prospective Client.


3. What Personal Data does Sera Global collect and why?

We will collect Personal Data from You when You register with Sera Global, apply to use any of Sera Global services, become a Sera Global Client, or contact Sera Global in person, by telephone, by email or by post.

We also collect Personal Data from You when You provide feedback or complete a contact form on the Sera Global Website. Please see the Sera Global Website Terms of Use, Sera Global Website Privacy Policy and Sera Global Cookies Policy for further information about how we collect and use Your Personal Data when You use the Sera Global Website.

We may collect information about You from fraud prevention agencies and other organisations when we undertake checks such as identification verification checks, as explained further below.

Many of the services offered by Sera Global require us to obtain Personal Data about You in order to perform the services we have been engaged to provide, and to comply with applicable law or policies (for example, Know Your Client and Anti-Money Laundering). In connection with the provision of those services, Sera Global will collect Personal Data about You:

a)  directly from You;

b)  from a third party acting on Your behalf, for example an intermediary, lawyer, or service provider;

c)  from other Sera Global entities;

d)  from publicly available sources;

e)  from other organizations; and

f)   when we generate it ourselves.

Such Personal Data may include (by way of non-exhaustive list):

a)  details of Your name, age, date of birth, address, gender, nationality, citizenship and contact information;

b)  financial information or other information obtained as a result of Your investment in any of the funds we are helping raise capital for (such as advisor details, investment details, banking details, and financial details);

c)  Your national insurance, National Health Service number, Medicare or social security number or other tax identification number and details of tax residency for any tax implications;

d)  data provided by You in the context of us carrying out background checks, anti-money laundering, regulatory, tax and ‘Know Your Client’ checks (such as data included in identification documents, details of criminal records and sanctions);

e)  a file with Your contact history

f) information relating to the services we provide to our Clients or prospective Clients; and

g)  information required as a result of legal, tax and regulatory requirements or internal policies.

Please note that if You do not provide certain Personal Data to Sera Global when requested (and where relevant, provide Your consent), we may not be able to provide You with some or all of our services and products (including those set out in this Policy or in other agreements we enter into with You).

4. How Sera Global uses Your Personal Data

Your Personal Data may be collected, stored, disclosed and processed by Sera Global for the following purposes:

a)  to provide You with marketing communications and inform You about news and information relating to our business and services, including new product launches, product updates and general business news;

b)  to assess Your application for Sera Global’s products and services, where applicable;

c)   to understand Your needs and interests and to respond to Your enquiries;

d)  to analyze and improve our services;

e)  for the management and administration of our business;

f)   to provide You with the products and services for which You subscribe;

g) to comply with and in order to assess compliance with applicable laws, rules and regulations (including tax reporting purposes pursuant to tax legislation), industry codes, voluntary codes we decide to adopt, or good practice, anywhere in the world and internal policies and procedures;

h)  to confirm and verify Your identity and to conduct due diligence, background and related checks (this may involve the use of a credit reference agencies and/or other third parties acting as our agents to conduct these verifications and related reviews including screens against publicly available government and/or law enforcement agency sanctions lists);

i)   to detect, investigate and prevent fraud and other crimes or malpractice;

j)   for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings);

k)  to obtain legal advice or to establish, exercise or defend legal rights;

l)   the administration and maintenance of databases storing Personal Data;

m)   to comply with our contractual obligations; and

n)  for purposes otherwise set out in this Policy or as notified to You at the specific time of collection.

Sera Global is entitled to use Your Personal Data for the purposes listed above because one or more of the following legal bases applies:

a)  Sera Global needs to do so in order to perform its contractual obligations to You (for example, in order to manage Your investments, and verify the information You provide);

b)  Sera Global has obtained Your specific and informed consent (which may include written consent) in accordance with applicable data protection and privacy laws unless an exemption provided under applicable law permits the use and disclosure of Your Personal Data without Your consent.

c)  Sera Global has legal or regulatory obligations that must be discharged;

d)  Sera Global may need to do so in order to establish, exercise or defend its legal rights or for the purpose of legal proceedings;

e)  there may be certain exemptions provided under applicable laws which permit the use and disclosure of Your Personal Data without Your consent; or

f)   the use of Your Personal Data as described is necessary for Sera Global’s legitimate business interests or the legitimate interests of a third party provided such interest are not overridden by Your rights or interest, including:

i. allowing Sera Global to effectively and efficiently, administer and manage the operation of its business;
ii. maintaining compliance with internal policies and procedures;
iii. monitoring the use of our copyrighted materials; or
iv.  for internal research purposes.

If You are located in a jurisdiction which requires us to obtain Your consent to collect, use, store, process and disclose Your Personal Data, You understand that by accepting the terms of this Policy You expressly provide Your consent to Sera Global collecting, using, storing, processing and disclosing Your Personal Data as set out in this Policy.

To the extent permitted by applicable law, we may record and/or monitor electronic communications (including email and telephone) to ensure compliance with our legal and regulatory obligations and internal policies and for the purposes outlined in this Policy.

5. Special Category and Sensitive Data

Certain forms of Personal Data are subject to specific protection or restriction by law in certain territories. Depending on the jurisdiction, “Special Category” or “Sensitive” data can include data relating to racial or ethnic origin, or communal origin, political opinions, religious or philosophical beliefs, trade union membership information, genetic data, biometric data, and data concerning health or sex life or sexual orientation, data relating to criminal activity or proceedings, passwords, and financial information such as bank account details, credit card and debit card details.

We will not process Your Special Category or Sensitive data unless such processing is compliant with applicable data protection and privacy laws.

6. Disclosure of Your Personal Data to Third Parties

Sera Global does not sell Personal Data to third parties. Sera Global may share or provide access to Your Personal Data among its affiliates and business units and third-party agents, service providers and contractors outside of Sera Global:

a) for the purpose of the management and administration of Sera Global’s business;

b) in order to facilitate the provision and enhancement of services to You (including the management of Your investments);

c) for the purpose of the administration and maintenance of the databases storing Personal Data;

d) for the purposes of Sera Global receiving services (for example, Sera Global’s accountants, administrators, auditors, service providers, custodians, depositories, third party managers, paying agents, professional advisors, IT and communications providers or any entity we reasonably consider necessary for the purposes outlined above). These third parties are expected to be subject to confidentiality requirements (either by contract, professional obligation, duty or otherwise) that require them to only use Your Personal Data as described above;

e) to the extent required by law (for example, if Sera Global is compelled by an obligation or a duty to disclose Your Personal Data where we believe it is necessary or appropriate to comply with any legal obligation, rule, regulations or internal Sera Global policies and procedures, including (without limitation) in order to comply with tax reporting requirements and other statutory reporting and disclosures to regulatory authorities), or to establish, exercise or defend its legal rights. This may include disclosure to regulatory bodies or government agencies);

f)  as part of a transaction, financing, or for other business needs (for example, if Sera Global sells any of its businesses or assets, applies for a loan, or opens bank accounts, in which case Sera Global may need to disclose Your Personal Data to the prospective buyer, lender or bank as part of certain due diligence processes); or

g) if Sera Global or any of its affiliates, divisions or business units is acquired by a third party, including in the unlikely event of a bankruptcy, in which case the Personal Data held by Sera Global about You will be accessible to, and may be acquired by, the third-party buyer.

Sera Global may share anonymous or aggregated data with third parties such as service providers to facilitate our business operations.

7. Transfers of Your Personal Data

Sera Global operates globally. This means Personal Data may be processed and disclosed as described above, in any country in which we conduct business or have a service provider. Accordingly, when You provide Your Personal Data to Sera Global, You acknowledge and agree that we may disclose Your Personal Data to recipients (including, but not limited to service providers, Sera Global affiliates or agents, and Sera Global IT severs) located in jurisdictions other than Your own, including but not limited to the following countries: Canada, South Korea, UK, USA and Germany.

To the extent that applicable data protection and privacy laws do not allow or permit us to obtain Your valid consent by virtue of providing this Policy to You, or otherwise rely on the other grounds set out in this Policy for disclosing Your Personal Data outside of Your jurisdiction under the data protection and privacy law of Your jurisdiction, we will obtain Your explicit consent through other means (if applicable) or, where relevant, ensure that the recipient is bound by data protection and privacy laws of its jurisdiction to provide a standard of protection to Your Personal Data that is equivalent to that under the data protection and privacy laws of Your jurisdiction.

In other circumstances, data protection and privacy laws may permit Sera Global to otherwise transfer Your Personal Data outside Your jurisdiction provided it is compliant with such data protection and privacy laws.

8. How Sera Global safeguards Your Personal Data

Sera Global has implemented commercially reasonable controls and appropriate technical and organizational measures to protect Personal Data, as well as to maintain the security of our information and information systems in respect of Personal Data. Client files are protected with safeguards according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems and used where appropriate. Reasonable measures are taken to ensure physical access to Personal Data is limited to authorized employees.

As a condition of employment, Sera Global employees are required to follow applicable laws and regulations, including in relation to data protection and privacy laws. Unauthorized use or disclosure of confidential information by a Sera Global employee is prohibited and may result in disciplinary measures.

When You contact a Sera Global employee about Your file, You may be asked to confirm some details relating to the Personal Data Sera Global holds about You. This type of safeguard is designed to ensure that only You, or someone authorized by You, has access to Your file.

Other procedures, which Sera Global has in place to ensure Your Personal Data is kept safe and secure include:

a) Firewalls;

b) intrusion detection;

c) 24/7 physical protection of the facilities where Your Personal Data is stored;

d) background checks for personnel that access physical facilities; and

e) security procedures across all service operations.

9. Retention & Destruction of Your Personal Data

The period for which Sera Global will hold Your Personal Data will vary and will be determined by the following criteria:

a) the purpose for which Sera Global is using it. Sera Global is required to retain the Personal Data for as long as is necessary to satisfy or meet the purposes for which it was obtained including applicable legal or regulatory requirements; and

b) legal Obligations. Laws or regulations may set a minimum period for which Sera Global must retain Your Personal Data.

Depending on the requirements of the data protection law of Your jurisdiction, Sera Global will take reasonable steps in the circumstances to destroy Your Personal Data when we no longer have a legal basis to retain it or to ensure that the Personal Data is anonymized.

Where Personal Data is retained by Sera Global, it will usually (but not always) held in the following formats:

a) call recordings, electronic communications and minutes of face-to-face meetings;

b) suitability and appropriateness assessments;

c) periodic statements (for example, valuations); and

d) all orders and transactions in financial instruments on Your behalf.

10. Your Rights

To the extent provided by the law of Your jurisdiction, You may have legal rights in relation to the Personal Data about You that Sera Global holds. These rights may include:

a) the right to refuse to provide any Personal Data and the right to object at any time to the processing of Your Personal Data. Please note that such refusal or objection may prevent us from providing services to You;

b) the right to obtain information regarding the processing of Your Personal Data and access to the Personal Data about You that Sera Global holds (including any available information as to the source of the Personal Data);

c) where consent was provided for certain processing activities, the right to withdraw Your consent to the collection, processing, use and disclosure of Your Personal Data at any time. Please note, however, that this will not affect the lawfulness of any collection, processing, use or disclosure undertaken before Your withdrawal and that Sera Global may still be entitled to process Your Personal Data if it has another legitimate reason (other than consent) or a consent exception for doing so. In some cases, withdrawing Your consent to the collection, use process or disclosure of some or all Your Personal Data may prevent us from providing services to You;

d) in some circumstances, the right to receive some Personal Data in a structured, commonly used, and machine-readable format and/or request that Sera Global transmit that data to a third party where this is technically feasible. Please note that this right may, depending on the jurisdiction, only apply to Personal Data that You have provided to Sera Global;

e) the right to request that Sera Global rectify Your Personal Data if it is inaccurate or incomplete;

f)  in some circumstances, the right to request that Sera Global erase Your Personal Data. Please note that there may be circumstances where Sera Global is legally entitled to retain Personal Data regardless of any such request;

g) in some circumstances, the right to request that Sera Global restrict, anonymize, or block its processing of Your Personal Data. Please note that such a request may prevent us from providing services to You and that there may be circumstances where Sera Global is legally entitled to retain Personal Data regardless of any such request;

h) in some circumstances, the right to obtain information about the public and private entities with which Sera Global made shared use of Your Personal Data as a joint controller;

i)  in some circumstances, the right to receive information on the possibility of Your not providing consent and on the consequences of the refusal;

j)  in some circumstances, the right to non-discrimination against You for exercising Your legal rights in relation to Your Personal Data; and

k) where applicable, the right to lodge a complaint with the data protection regulator in Your jurisdiction if You think that any of Your rights have been infringed by Sera Global.

You can enquire about Your rights, which are applicable to You, by contacting Sera Global’s Privacy Office using the details listed below in Section 14. Sera Global will respond to your requests within the time frames set out in applicable data protection laws.

11. Processing of Your Personal Data for Marketing Purposes

To the extent permitted by applicable law, we may contact You by mail, e-mail, SMS/text, telephone and other electronic means to provide information on products and services that we believe will be of interest, unless You object to receiving such information. If You do not want to receive such communications from us, please contact Sera Global’s Privacy Office on the details set out below in Section 14 or by using the opt-out facilities provided within the relevant marketing material.

Your option not to receive promotional and marketing material:

a. shall not preclude us from corresponding with You, by email or otherwise, regarding Your relationship with us (e.g., Your account status and activity or our responses to questions or inquiries You pose to us);

b. shall not preclude us, including our employees, contractors, agents and other representatives, from accessing and viewing Your Personal Data for our internal business purposes; and

c.  shall not preclude us from disclosing Your Personal Data as described in this Policy for purposes other than sending You promotional and marketing materials.

12. Use of Personal Data in relation to data subjects in Canada and Australia

Canadian Anti-Spam Legislation requires that commercial electronic messages (“CEMs”) sent within Canada or into Canada from another jurisdiction may only be sent to individuals who opt into receiving them, subject to certain exceptions. Similar legislation applies in Australia (Spam Act 2003 (Cth)). Such consent may be implicit, such as by engaging in a prior business relationship, or by virtue of having one’s email address listed in a public directory. These anti-spam laws also require senders to include an opt-out function such as an “unsubscribe” mechanism within a CEM. You may opt-out of the collection or use of Your information by Sera Global. In some cases, withdrawing Your consent to the collection, use or disclosure of some or all of Your personal information will prevent us from providing services to You.

To opt-out, please contact Sera Global’s Privacy Office using the details set out below in Section 14. Please note that in some cases Sera Global is permitted to send You certain material after You opt out, such as where required to enforce legal rights.

13. California Privacy Rights

If You are a California resident, You have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies You for the third-parties’ direct marketing purposes. Sera Global does not share Personal Data with third parties for those third parties’ own direct marketing purposes.

Effective 1 January 2020, the California Consumer Privacy Act (“CCPA”) provides You with certain rights that are in addition to the rights set out in Section 10 above:

a) the right to request, up to twice in a twelve-month period, Your Personal Data in a format that is portable and, to the extent technically feasible, in a readily useable format that will allow You to transmit it to another entity;

b) the right to request that Sera Global delete Your Personal Data, except in circumstances where Sera Global is legally entitled to retain Personal Data regardless of any such request; and

c) the right to opt out of any sale of Your Personal Data to any third parties, without experiencing any discrimination, as defined under applicable law, as a result of Your exercise of this right.  Please note that Sera Global does not sell Personal Data to third parties.

If You are a California resident, Personal Data will include the full definition of “Personal Information” under the CCPA.

If You wish to exercise any of the rights enumerated in this Section 13, please contact Sera Global’s Privacy Office using the details set out below in Section 14.

14. Questions & Concerns

If You have any questions or concerns about Sera Global’s handling of Your Personal Data, or about this Policy, please contact our Privacy Office using the contact information set out below:

Email: privacyoffice@seraadvisory.com

We are typically able to resolve privacy questions or concerns promptly and effectively. If You are not satisfied with the response You receive from our Privacy Office, You may escalate concerns to the applicable privacy regulator in Your jurisdiction, the details of which can be obtained from the Privacy Office.

Appendix A

 Canada

  • Sera Global GP Inc.
  • Sera Global Securities Canada LP
  • Sera Global International Holdings Inc.
  • Sera Global Holding LP
  • Sera Global Securities Canada (GP) Limited
  • Sera Global Administration Canada LP
  • Sera Global Administration Canada (GP) Limited

USA

  • Sera Global Real Estate Group US LLC
  • Sera Global Securities US LLC
  • Sera Global Real Estate California Corporation Inc.
  • Sera Global US Holdings LLC

United Kingdom

  • Sera Global Securities UK LP
  • Sera Global Real Estate Group UK Limited
  • Sera Global Securities UK (GP) Limited
  • Sera Global Europe Holdings Limited 

Germany

  • Sera Global Real Estate Group (Germany) GmbH 

Korea

  • Sera Global Korea Limited

Job Applicant & Job Candidates Data Protection Policy & Privacy Notice for Sera Global

1. Introduction

This is the applicant data protection policy and privacy notice (“Notice”) for Sera Global (as defined below). This Notice applies to You when You make an employment related query or make an application for a position at Sera Global.

At Sera Global, we respect Your privacy, and this Notice governs how Sera Global collects, processes, and uses Your Personal Data (as defined below). For the purposes of certain data protection and privacy laws, Sera Global acts as a controller in respect of Your Personal Data. This Notice sets out the basis on which any Personal Data about You that You provide to Sera Global, that Sera Global creates, or that Sera Global obtains about You from other sources, will be processed.

Please read this Notice carefully before submitting Your employment query, resume, CV and/or application form. This Notice may change from time to time and You should review it periodically. The most recent version of this Notice can be found on the Sera Global website.

This Notice was last updated 1st February 2021.


2. Definitions

The following definitions shall apply to this Notice:
“Sera Global”, “we”, “us”, “our”
means the Sera Global entities and Sera Global affiliated entities listed in Appendix A.

“Personal Data” has the meaning given in applicable data protection legislation (and for the purposes of California residents means ‘Personal Information’ as defined under the California Consumer Privacy Act) and for the avoidance of doubt means any information which directly or indirectly identifies a natural living person, which is in the possession of, or likely to come into the possession of, Sera Global (or its representatives or service providers). Such personal data includes name, an identification number, email address, address, telephone number, location data, financial data, or an online identifier of that natural person. In addition to factual information, it includes any expression of opinion about an individual and any indication of the intentions of Sera Global or any other person in respect of an individual.

“You”, “Your” means the person submitting their employment query, resume, CV and/or application form to Sera Global.

3. What Personal Data does Sera Global collect and why?

Sera Global will collect Personal Data about You:

a) directly from You;

b) from a third party acting on Your behalf, for example an intermediary, lawyer, or service provider’

c) from other Sera Global entities;

d) from publicly available sources;

e) from other organizations; and

f) when we generate it ourselves.

Such Personal Data may include (by way of non-exhaustive list):

a) details of Your name, age, date of birth, address, gender, nationality, citizenship, contact information, right to work status (including passport, driving license, birth, or adoption certificate), marital status, emergency contact details, qualifications, skills and work experience, details of previous compensation, benefits and terms of employment, signature;

b) information about Your entitlement to work in the jurisdictions in which Sera Global operates;

c) pension and superannuation details;

d) information about Your health;

e) details of Your suitability to work with us Your past performance at work, regulatory references, Your character, details of Your fitness to work, verification of the information that You provide to us as part of Your application, and if legally permitted, any history concerning criminal convictions and/or health checks, from third party references that You provide to us, from Your previous and/or current employers, opinions expressed by others about You and from third party background checking services or a previous employer or other referee;

f) whether or not You have a disability for which Sera Global needs to make reasonable adjustments during the recruitment process;

g) Your social insurance or Medicare or social security number or national insurance or National Health Service number or other tax identification number and details of tax residency;

h) data provided by You in the context of us carrying out background checks, anti-money laundering, regulatory, tax and know Your client checks (such as data included in identification documents, details of criminal records and sanctions);

i) information required because of legal, tax, compliance and regulatory requirements or internal policies.

Please note that if You do not provide certain Personal Data to Sera Global when requested (and where relevant, provide Your consent), we may not be able to consider You for a position at Sera Global.

4. How Sera Global uses Your Personal Data

Your Personal Data may be collected, stored, disclosed, and processed by Sera Global for the following purposes:

I. to carry out pre-employment, background, and related checks and to conduct due diligence (such as to verify the details that You provide and to ensure that You are suitable for the role for which You have applied), as determined by applicable laws. Please note that it is our standard practice to request employment references once You have agreed, either verbally or in writing, to accept a position with Sera Global. This may involve the use of a credit reference agency or other third parties acting as our agents to conduct these verifications and searches. We will also screen against publicly available government and/or law enforcement agency sanctions lists;

II. if Your application is unsuccessful, we may keep Your information on record to notify You of relevant job vacancies with Sera Global that may be of interest to You, in the future;

III. for equal opportunity and diversity monitoring purposes;

IV. to respond to Your enquiries;

V. for the management and administration of our business;

VI. to comply with and to assess compliance with applicable laws, rules and regulations (including tax reporting purposes pursuant to tax legislation), industry codes, voluntary codes we decide to adopt, or good practice, anywhere in the world and internal policies and procedures;

VII. to detect, investigate and prevent fraud and other crimes or malpractice;

VIII. for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), including to obtain legal advice or to establish, exercise or defend legal rights;

IX. the administration and maintenance of databases storing Personal Data;

X. to comply with our contractual obligations;

XI. for purposes otherwise set out in this Notice or as notified to You at the specific time of collection.

Sera Global is entitled to use Your Personal Data for the purposes listed above because one or more of the following legal bases applies:

I. Sera Global has obtained Your specific and informed consent (which may include written consent) (except where certain exemptions provided under applicable laws which permit the use and disclosure of Your Personal Data without Your consent apply;

II. Sera Global has legal or regulatory obligations that must be discharged;

III. Sera Global may need to do so to establish, exercise or defend its legal rights or for the purpose of legal proceedings;

IV. the use of Your Personal Data as described is necessary for our legitimate business interests or the legitimate interests of a third party provided such interest are not overridden by Your rights or interest, including:

i. allowing Sera Global to effectively and efficiently, administer and manage the operation of its business;

ii. maintaining compliance with internal policies and procedures;

iii. considering You for a position at Sera Global; or

iv. for internal research purposes.

If You are located in a jurisdiction which requires us to obtain Your consent to collect, use, store, process and disclose Your Personal Data, You understand that by submitting Your employment query, resume, CV and/or application form, You expressly provide Your consent to Sera Global collecting, using, storing, processing and disclosing Your Personal Data as set out in this Notice.

To the extent permitted by applicable law, we may record and/or monitor electronic communications (including email and telephone) to ensure compliance with our legal and regulatory obligations and internal policies and for the purposes outlined in this Notice.

5. Special Category and Sensitive Data

Certain forms of Personal Data are subject to specific protection or restriction by law in certain territories, including the EU and the UK. Depending on the jurisdiction, “Special Category” or “Sensitive” data can include data relating to racial or ethnic origin, or communal origin, political opinions, religious or philosophical beliefs, trade union membership information, genetic data, biometric data, and data concerning health or sex life or sexual orientation, data relating to criminal activity or proceedings, passwords, and financial information such as bank account details, credit card and debit card details.

We will not process Your Special Category or Sensitive data unless such processing is compliant with applicable data protection and privacy laws.

6. Disclosure of Your Personal Data to Third Parties

Sera Global does not sell Personal Data to third parties. Sera Global may share or provide access to Your Personal Data among its affiliates and business units and third-party agents, service providers and contractors outside of Sera Global:

I. for the purpose of the management and administration of Sera Global’s business;

II. to assess Your application and verify the information You have provided;

III. for the purpose of the administration and maintenance of the databases storing Personal Data;

IV. for the purposes of Sera Global receiving or enhancing services (for example, Sera Global’s accountants, administrators, auditors, service providers, custodians, depositories, third party managers, paying agents, professional advisors, IT and communications providers or any entity we reasonably consider necessary for the purposes outlined above). These third parties are expected to be subject to confidentiality requirements (either by contract, professional obligation, duty or otherwise) that require them to only use Your Personal Data as described above;

V. to the extent required by law (for example, if Sera Global is compelled by an obligation or a duty to disclose Your Personal Data where we believe it is necessary or appropriate to comply with any legal obligation, rule, regulations or internal Sera Global policies and procedures, including (without limitation) to comply with tax reporting requirements and other statutory reporting and disclosures to regulatory authorities), or to establish, exercise or defend its legal rights. This may include disclosure to regulatory bodies or government agencies);

VI. as part of a transaction, financing, or for other business needs (for example, if Sera Global sells any of its businesses or assets, applies for a loan, or opens bank accounts, in which case Sera Global may need to disclose Your Personal Data to the prospective buyer, lender or bank as part of certain due diligence processes); or

VII. if Sera Global or any of its affiliates, divisions or business units is acquired by a third party, including in the unlikely event of a bankruptcy, in which case the Personal Data held by Sera Global about You will be accessible to, and may be acquired by, the third-party buyer.

Sera Global may share anonymous or aggregated data with third parties such as service providers to facilitate our business operations.

7. Transfers of Personal Data

Sera Global operates globally. This means Personal Data may be processed and disclosed as described above, in any country in which we conduct business or have a service provider. Accordingly, when You provide Your Personal Data to Sera Global, You acknowledge and agree that we may disclose Your Personal Data to recipients (including, but not limited to service providers, Sera Global affiliates or agents, and Sera Global IT severs) located in jurisdictions other than Your own, including but not limited to the following countries: Canada, South Korea, UK, USA and Germany.

To the extent that applicable data protection and privacy laws do not allow or permit us to obtain Your valid consent by virtue of providing this Notice to You, or otherwise rely on the other grounds set out in this Notice for disclosing Your Personal Data outside of Your jurisdiction under the data protection and privacy law of Your jurisdiction, we will obtain Your explicit consent through other means (if applicable) or, where relevant, ensure that the recipient is bound by data protection and privacy laws of its jurisdiction to provide a standard of protection to Your Personal Data that is equivalent to that under the data protection and privacy laws of Your jurisdiction.

In other circumstances, data protection and privacy laws may permit Sera Global to otherwise transfer Your Personal Data outside Your jurisdiction provided it is compliant with such data protection and privacy laws.

8. How Sera Global safeguards Your Personal Data

Sera Global has implemented commercially reasonable controls and appropriate technical and organizational measures to protect Personal Data, as well as to maintain the security of our information and information systems in respect of Personal Data. Files containing Personal Data are protected with safeguards according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems and used where appropriate. Reasonable measures are taken to ensure physical access to Personal Data is limited to authorized employees.

As a condition of employment, Sera Global employees are required to follow applicable laws and regulations, including in relation to data protection and privacy laws. Unauthorized use or disclosure of confidential information by a Sera Global employee is prohibited and may result in disciplinary measures.

When You contact a Sera Global employee about Your file, You may be asked to confirm some details relating to the Personal Data Sera Global holds about You. This type of safeguard is designed to ensure that only You, or someone authorized by You, has access to Your file.

Other procedures, which Sera Global has in place to ensure Your Personal Data is kept safe and secure include:

I. Firewalls;

II. intrusion detection;

III. 24/7 physical protection of the facilities where Your Personal Data is stored;

IV. background checks for personnel that access physical facilities; and

V. security procedures across all service operations.

9. Retention & Destruction of Your Personal Data

The period for which Sera Global will hold Your Personal Data will vary and will be determined by the following criteria:

I. the purpose for which Sera Global is using it. Sera Global is required to retain the Personal Data for as long as is necessary to satisfy or meet the purposes for which it was obtained including applicable legal or regulatory requirements; and

II. legal Obligations. Laws or regulations may set a minimum period for which Sera Global must retain Your Personal Data.

Depending on the requirements of the data protection law of Your jurisdiction, Sera Global will take reasonable steps in the circumstances to destroy Your Personal Data when we no longer have a legal basis to retain it or to ensure that the Personal Data is anonymized.

10. Your Rights

To the extent provided by the law of Your jurisdiction, You may have legal rights in relation to the Personal Data about You that Sera Global holds. These rights may include:

I. the right to refuse to provide any Personal Data and the right to object at any time to the processing of Your Personal Data. Please note that such refusal or objection may prevent us from providing services to You;

II. the right to obtain information regarding the processing of Your Personal Data and access to the Personal Data about You that Sera Global holds (including any available information as to the source of the Personal Data);

III. where consent was provided for certain processing activities, the right to withdraw Your consent to the collection, processing, use and disclosure of Your Personal Data at any time. Please note, however, that this will not affect the lawfulness of any collection, processing, use, or disclosure undertaken before Your withdrawal and that Sera Global may still be entitled to process Your Personal Data if it has another legitimate reason (other than consent) or a consent exception for doing so. In some cases, withdrawing Your consent to the collection, use process or disclosure of some or all Your Personal Data may prevent us from providing services to You;

IV. in some circumstances, the right to receive some Personal Data in a structured, commonly used, and machine-readable format and/or request that Sera Global transmit that data to a third party where this is technically feasible. Please note that this right may, depending on the jurisdiction, only apply to Personal Data that You have provided to Sera Global;

V. the right to request that Sera Global rectify Your Personal Data if it is inaccurate or incomplete;

VI. in some circumstances, the right to request that Sera Global erase Your Personal Data. Please note that there may be circumstances where Sera Global is legally entitled to retain Personal Data regardless of any such request;

VII. in some circumstances, the right to request that Sera Global restrict, anonymize, or block its processing of Your Personal Data. Again, there may be circumstances where Sera Global is legally entitled to refuse that request;

VIII. in some circumstances, the right to obtain information about the public and private entities with which Sera Global made shared use of the Personal Data as a joint controller;

IX. in some circumstances, the right to receive information on the possibility of not providing consent and on the consequences of the refusal;

X. in some circumstances, the right to non-discrimination against You for exercising Your legal rights in relation to Your personal data;

XI. where applicable, the right to lodge a complaint with the data protection regulator in Your jurisdiction if You think that any of Your rights have been infringed by Sera Global.

In some jurisdictions You may be entitled to access a copy of this Notice in another language.

You can enquire about Your rights, which are applicable to You, by contacting Sera Global’s Privacy Office using the details listed below in Section 12. Sera Global will respond to Your requests within the time frames set out in applicable data protection laws.

11. California Privacy Rights

If You are a California resident, You have the right to request certain information from us regarding the manner in which we share with third-parties certain categories of information that identifies You for the third-parties’ direct marketing purposes. Sera Global does not share Personal Data with third parties for those third parties’ own direct marketing purposes.

Effective 1 January 2020, the California Consumer Privacy Act (CCPA) may provide You with certain rights that are in addition to the rights set out in Section 10 above:

a) the right to request, up to twice in a twelve month period, Your Personal Data in a format that is portable and, to the extent technically feasible, in a readily useable format that will allow You to transmit it to another entity;

b) the right to request that Sera Global delete Your Personal Data, except in circumstances where Sera Global is legally entitled to retain Your Personal Data regardless of any such request; and

c) the right to opt out of any sale of Your Personal Data to any third parties, without experiencing any discrimination, as defined under the law, as a result of Your exercise of this right.  Note that Sera Global does not sell Personal Data to third parties.

If You are a California resident, Personal Data will include the full definition of “Personal Information” under the CCPA. If You wish to exercise any of the rights enumerated in this section, please contact us at +1 646 561 4469 or privacyoffice@seraadvisory.com

12. Questions & Concerns

If You have any questions or concerns about Sera Global’s handling of your Personal Data, or about this Notice, please contact our Sera Global Privacy Office using the contact information set out below:

Email: privacyoffice@seraadvisory.com

We are typically able to resolve privacy questions or concerns promptly and effectively. If You are not satisfied with the response You receive from our Privacy Office, You may escalate concerns to the applicable privacy regulator in Your jurisdiction, the details of which can be obtained from the Privacy Office.