Privacy Policy

Serica Agency Limited and its related entities (together, “Serica“) are committed to respecting and protecting your privacy. We comply with the European Data Protection regulation (EU 2016/679) and the local laws applicable in the various countries in which we operate.

1. Who we are

​Serica provides independent, conflict-free corporate agency, trust and escrow services to clients across the Asia region. Serica Agency Limited holds a Trust and Company Service Provider license and is subject to, among other relevant laws and regulations, the Anti-Money Laundering and Counter-Terrorist Financing Ordinance of Hong Kong(Cap. 6015). 

​Serica’s head office is located in Hong Kong SAR and controls the collection and processing of all personal data provided to it by its clients and counterparties. Any data sent to us directly by any third party is stored safely and securely with the same risk measures as Serica assigns to its own data.

​If you have any enquiry or question regarding data privacy, please contact Serica’s Compliance Officer directly (agent@sericatrust.com).

2. Personal data

“Personal data” refers to any information that relates to you and that identifies you either directly from that information or indirectly, by reference to other information that we have access to. The personal data that we collect, and how we collect it, depends upon how you interact with us. 

We collect personal data directly from you as follows:

• When you sign up to receive news or publications from us or attend any of our events, we may ask you to provide your contact information, including your name, email address, postal address and phone number.
• When you use our website, we collect information about your visit and how you interact with our website.
• When a client uses our services, we will first ask them to complete our Client Due Diligence (“CDD“) form. The types of personal data we collect through our CDD form includes: contact details (including email address, postal address and phone number), billing information, details of ultimate beneficial ownership and otherinformation necessary to conduct pre-clearance checks and information relevant to the services we provide. Information provided by a client may include personal data that relates to persons whose information is relevant to the instruction.

The personal data which we collect via our CDD form is mandatory for the purposes of providing our services to you in connection with any transaction on which we are engaged.  If we are not provided with such information, we may not be able to continue providing our services, including making any payments to you.

• When you apply for a job with us we will ask you for information relevant to your application, including your CV, your email address and phone number.
• If you visit our office premises we may collect information that we need in order to identify you and complete necessary security checks. The building management company may also collect your image on CCTV.

If you provide information to us about another person, you must ensure that you comply with any legal obligations that may apply to your provision of the information to us, and to allow us, where necessary, to share that information with our service providers.

3. Information from third parties

Most of the personal data that we collect about you will be information that you provide to us voluntarily. In some circumstances we may also receive information from:

• Our clients, when we handle personal data on their behalf;
• Regulatory bodies;
• Credit reference agencies; and
• Other companies providing services to us.

Some of these third-party sources may include publicly available sources of information.

We will also receive information about you from Google Analytics, a web analytics service provided by Google, Inc. whose servers are located in the United States of America. Google Analytics uses cookies to help us analysis how users use our site.

4. Data we collect automatically

When you visit our website, we automatically collect, store and use technical information about your equipment and interaction with our website. This information is sent from your computer to us using a variety of cookies.

5. How we use your personal data

We will only use your personal data fairly and where we have a lawful reason to do so.

We are allowed to use your personal data if we have your consent or another legally permitted reason applies. These include to fulfil a contract with you, when we have a legal duty to comply with, or when it is in our legitimate business interest to use your personal data. We can only rely on our legitimate business interest if it is fair and reasonable to do so.

We use your personal data in connection with the following activities:

• Sending news or publications to you, or invitations to attend any of our events.
• Evaluating how you interact with our website.
• Carrying out our services, including but not limited to: conflicts and “know-your-customer” checks; communicating with you in the course of any transaction(whether directly or via a third party loan administration service provider); and issuing invoices in connection with our services.
• Considering any job position for which you may have applied.
• Running any security checks if you visit our office.

6. Sharing and transferring your personal data

We treat your personal data with respect and do not share it with third parties except as described below.

• We may share your personal data to:
  • our employees;
  • any other business entity that is controlled by us, and their employees and officers;
  • any bank with whom we hold a client account for the purposes of the bank’s “know-your-customer” checks
  • any agent or third party service provider engaged by us in connection with the operation of our business, such as loan administration service providers; and
  • when necessary with law enforcement and regulatory authorities.
• We may also share your personal data with third parties other than the entities described above when you have consented to us doing so.

7. How we keep and protect your personal data

We do not keep your personal data for any longer than is necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against legal claims.

We protect your personal data and implement appropriate technical and organisational security measures to protect it against any unauthorised or unlawful processing and against any accidental loss, destruction, or damage.

8. Your rights regarding your personal data

You have certain rights regarding how we use and keep your personal data. These are:

• you can require us to update or correct any inaccurate personal data, or to complete any incomplete personal data, concerning you. If you do, we will take reasonable steps to check the accuracy of and correct the information. Please let us know if any of your information changes so that we can keep it accurate and up to date;
• you can require us to stop processing your information for direct marketing purposes; if you withdraw your consent, we may not be able to provide certain products or services to you; and
• you have the right to object to our use of your personal data more generally.

You may also have the right, in certain circumstances to:

• be provided with a copy of any personal data that we hold about you, with certain related information. There are exceptions to this right; for example where information is legally privileged or if providing you with the information would reveal personal data about another person;
• require us, without undue delay, to delete your personal data;
• “restrict” our use of your information, so that it can only continue subject to restrictions; and
• require personal data which you have provided to us and which is processed by using automated means, based on your consent or the performance of a contract with you, to be provided to you in machine readable format so that it can be “ported” to a replacement service provider.

You can exercise the above rights, where applicable, by contacting Serica’s Compliance Officer (agent@sericatrust.com). We will require you to provide satisfactory proof of your identity in order to ensure that your rights are respected and protected. This is to ensure that your personal data is disclosed only to you.