Privacy Policy

1. This is the Privacy Policy Statement of Serakai Group Limited and each of its subsidiaries   (collectively “Serakai”, “we”, “us” or “our”).
2. Serakai respects personal data privacy and is committed to implementing and complying with the data protection principles and provisions under the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“PDPO”) and data privacy laws applicable to the jurisdictions in which Serakai has business operations.
3. Please read the following Privacy Policy to understand how Serakai collects and handles your personal data.  By providing your personal data to us, you are consenting to this Privacy Policy and the collection, use, access, transfer, storage and processing of your personal data as described in this Privacy Policy.

1. Serakai collects and holds the following categories of personal data:
2. • Personnel records which include data on job applications, personal particulars, education and qualifications, employment history, salary and allowances, participation in mandatory provident schemes, terms and conditions of service, housing and medical benefits, leave records, training and development, appraisal reports, conduct and discipline;
   • KYC records which include personal data collected in the course of conducting counterparty due diligence in connection with contracts for supply of goods and services to, and transactions entered into by, Serakai; and
   • Other records which include operational and administrative records, personal data supplied by business partners, shareholders and investors and information collected in the course of handling enquiries made to Serakai.

1. The main purposes of keeping the personal data are as follows:
2. • Personnel records are kept for human resource management purposes, including postings and transfers, training and career development, performance appraisal and promotion, discipline and offer of benefits;
   • KYC records on our business partners, investors, vendors and other counterparties with whom we have business or contractual relationships are kept for counterparty due diligence and legal risk management purposes; and
   • Other records are kept on a need-to-know basis for various purposes depending on the nature of the records, including for the purposes of carrying out various office administration functions, responding to and taking follow-up actions on enquiries and complaints.

1. Serakai implements the following practices to ensure that personal data held by us is handled in accordance with the data protection principles enshrined in the PDPO.
2. a) Collection of personal data
3. When collecting personal data, we will ensure that:
4. • the purposes for which the data is collected are lawful and directly related to a function or activity of Serakai;
   • the manner of collection is lawful and fair in the circumstances of the case; and
   • the personal data collected is necessary but not excessive for the purpose(s) for which it is collected.
5. b) Accuracy and retention of personal data
6. Personal data collected and maintained by Serakai shall be as accurate, complete, and up-to-date as is necessary for the purpose for which it is to be used.
   
   Personal data will not be kept longer than is necessary for the fulfilment of the purpose for which the data is collected or used.  We will erase personal data that is no longer required unless such erasure of personal data is prohibited under any applicable laws.  Should there be a need to retain the personal data for statistical purposes, such data would be anonymised so that the individuals concerned could no longer be identified.
7. c) Use of personal data
8. All personal data collected will be used only for purposes which are directly related to the discharge of Serakai’s duties and responsibilities.  
   
   We may transfer personal data collected to our agents, professional advisers, contractors, service providers, or any persons under a duty of confidentiality to us during the discharge of Serakai’s functions if considered necessary and appropriate. Relevant personal data may also be disclosed to entities which are authorised to receive information for the purposes of law enforcement, prosecution or review of decisions.  
   
   If personal data is to be used for a purpose other than the purposes for which the data is collected, we would seek express prior consent from the data subject concerned.  
9. d) Security of personal data
10. Serakai observes strictly relevant security standards and regulations.  Security arrangements are reviewed regularly to ensure that personal data is protected against loss and unauthorised or accidental access, use, disclosure, modification and erasure.
11. e) Access to and correction of personal data
12. Serakai recognises your rights of access to, correction and deletion of your personal data.  To make a data access request, you may contact the Data Protection Officer of Serakai at privacy@serakaigroup.com.
    
    In accordance with the terms of the PDPO or other applicable laws, we may impose a fee for the direct and necessary cost of complying with a data access request.

1. We may only use your personal data for the purposes of direct marketing if you have consented to such use. You may indicate to us your consent to use your personal data for direct marketing by selecting the relevant option in the appropriate online or paper form or any other means submitted to us.
2. You can withdraw your consent for use by us of your personal data for direct marketing at any time by contacting us at privacy@serakaigroup.com or as indicated in the relevant materials.

1. We will keep our privacy policy and procedures under regular review and may amend or update this Policy from time to time without prior notice.  You are advised to visit our website regularly for the latest version of this Policy.  If the amendments or updates of this Privacy Policy involves substantial changes, we will seek your explicit consent subject to the circumstances and in accordance with the applicable laws.