Privacy Notice

For Personal Information processed in connection with our operations, Seres Consulting Limited, located at Unit 2A, 17/F, Glenealy Tower, No. 1 Glenealy, Central, Hong Kong S.A.R., acts as a data user (equivalent to "data controller" under other laws). Where multiple entities are involved in determining the purposes and means of processing your Personal Information, they act as joint data users.

If you are unsure which entity is responsible for the processing of your Personal Information, or if you wish to exercise your rights under the PDPO, you may contact us at the details provided in Section 5.6.

When you use the Sites or Services, we collect certain Personal Information from you which can be used to contact or identify you, including, but not limited to, your name, gender, date of birth, telephone number, postal address, and email address ("Identity Information"). If you place an order for Services and/or pay a fee, we will collect additional payment and billing information from you, including, but not limited to, your credit/debit card information or bank account information ("Billing Information").

For the avoidance of doubt, we do not store or retain sensitive payment information such as full credit card or debit card numbers, bank account information, or other financial information that could be used directly to access a person’s financial account; however, we do store the transaction tokens that can be used to retrieve, and in some cases submit, information associated with your transaction to our service providers (such as the last four digits of a payment card).

If you place an order for Services, you may also be required to provide information or documents necessary for preparation or filing of forms or applications to be submitted to government agencies, and if you file an application, we may receive from the government a unique receipt number assigned to your application ("Application Information").

Depending on the Services that you are seeking, Application Information may include certain sensitive personal information, including (without limitation) information about your age, race, disability, sexual orientation, religion, national origin, and/or racial or ethnic origin; your social security, driver’s license, state identification card, or passport number; your immigration status; birth certificate information; employment status and information about your employer.

Together, your Identity Information, Billing Information, Application Information, and Usage Data (defined below), along with other information that (i) can be used to identify you and (ii) qualifies as "personal data" under the PDPO, are referred to as "Personal Information."

You are responsible for verifying the accuracy of the Personal Information you submit to Seres and ensuring that any Personal Information that you provide is kept up to date for the purposes for which you provide it.

We also automatically collect certain Personal Information regarding your access to and use of the Sites and Services. This Personal Information includes your computer or device hardware and software, IP address, browser type, referring website URLs, domain names, access times, log files, pages on the Sites that you visit, and links you click on, and other information about how you interact with and use the Sites or Services which is linked to information that directly relates to or could be used to identify you ("Usage Data").

Like many websites, we utilize devices to recognize you when you visit the Sites or use Services, track your interactions with the Sites, and personalize your experience. These include devices such as cookies, web beacons, pixels and similar devices. Cookies are small data files we transfer to your computer hard drive. We utilize some cookies that remain on your computer after you leave the Sites so that we can recognize you when you return and provide a more personalized and helpful experience. We also utilize session cookies to enable certain features of the Sites, to better understand how you interact with the Sites and to monitor use of the Sites by Seres users and web traffic routing on the Sites.

Session cookies are deleted from your computer when you log off from the Sites and close your browser. You maintain control over some of the Personal Information we collect through the use of cookies, and you can set your preferences regarding the use of cookies through your browser settings. If you choose not to accept cookies, you may not be able to access portions of the Sites or all functionality of the Services.

If you are located in Hong Kong, the PDPO applies. Seres is a "data user" for any Personal Information that constitutes "personal data" under the PDPO. In some instances, Seres may be processing personal data as a data processor on behalf of a Sponsor as the data user.

We process your Personal Information in accordance with the PDPO, including under the following circumstances:

• it is necessary for the performance of a contract with you;
• the processing is in our legitimate interests, provided those interests are not overridden by your rights and freedoms; and/or
• the processing is taking place with your consent.

Where we use artificial intelligence or automated tools to assist in delivering our Services (as described in Section 2.4), we rely on contract performance as the lawful basis for AI-assisted service delivery, and on your explicit consent for any use of your identifiable Personal Information to train or improve AI models (as described in Section 2.4(c)).

We use Personal Information you submit to us at the time of account registration, such as your name and email address, and any updated Personal Information you subsequently submit, such as a new email address, to create and maintain your account.

We use your Personal Information to operate our business and provide the Services to you, including the completion of immigration forms and/or fulfilling your requests for Services (such as by emailing you regarding application updates).

We also use Personal Information to personalize the Services we provide to you (for example, by remembering the account settings and functions that you have selected when you log in). We may use your Personal Information to verify your identity, for fraud prevention, to enforce the applicable Terms of Use and to protect the integrity of the Services. We may also use your Personal Information to develop new features or Services and to improve the quality of our Services, to detect, investigate, and prevent malicious, deceptive, fraudulent, or illegal activities, or other activities that may violate our policies or be illegal, or otherwise to comply with our legal obligations.

In providing our Services, we use artificial intelligence and automated tools ("AI Tools") to assist with certain functions, including document processing, form preparation, error detection, customer support, and case timeline estimation. These tools process your Personal Information only as necessary to perform these functions and only in accordance with this Privacy Notice. Our use of AI Tools is subject to the following commitments:

(a) Human review before filing. Every immigration application prepared through our Services is reviewed by a human being before it is filed with the applicable government agency. While AI Tools may assist at various stages of the preparation process, no application is submitted without human legal review.

(b) No solely automated decisions with legal effect. The Services will not make decisions that produce legal effects concerning you or similarly significantly affect you based solely on automated processing of your Personal Information, except as expressly permitted by applicable laws.

(c) Use of data to improve our Services. Where the use of sensitive Personal Information for AI model training is necessary to provide, maintain, or improve our core immigration Services, we will do so only (i) with your explicit consent, obtained at or before the point of collection, (ii) using appropriate technical safeguards, and (iii) in accordance with the PDPO. You may withdraw your consent at any time.

(d) Data minimization for AI Technology Partners. When sharing Personal Information with third-party AI Technology Partners (as described in Section 2.9), we provide only the information necessary for the specific function being performed.

We may use your Personal Information to respond to questions you have regarding use of our Services or to provide technical assistance.

We may contact you using the contact information you provide in order to respond to inquiries you send to us, to communicate with you regarding our Services and the services of our partners, and to market our Services, or those of our partners, to you, in accordance with applicable laws. If you do not wish to receive marketing emails, you can choose to opt-out using the unsubscribe link within each email.

We may use information about you, including Personal Information, and other users, in aggregate form, for our own internal research and analytical purposes.

We may use your government receipt number from time to time to check your application status.

In providing the Services, we use third-party artificial intelligence tools and services ("AI Technology Partners") to assist with the functions described in Section 2.4. AI Technology Partners are subject to contractual obligations that require them to:

• process your Personal Information only as directed by Seres;
• maintain appropriate security measures;
• refrain from using your Personal Information to train their own AI models unless anonymized;
• delete or return your Personal Information upon termination; and
• not disclose your Personal Information to any sub-processor without Seres’s prior approval.

Seres does not share your Personal Information with third parties for their marketing purposes without your consent. Seres does not sell, rent, or lease its customer lists to third parties.

We may share your Personal Information with third parties if you provide us with authorization to do so.

We may share your Personal Information with third-party service providers, including AI Technology Partners, only to the extent necessary for them to assist us in providing our Services.

We may disclose your Personal Information as required by law, such as in response to a court order, subpoena, or similar legal process in Hong Kong.

Your Personal Information may be included in the event that some or all of our assets are sold, assigned or transferred in connection with a merger, acquisition, reorganization or sale of assets.

We may share non-personally identifiable and non-privileged information in aggregate form to third-party academic researchers.

Where permitted by applicable laws, we use various third-party tracking technologies for marketing, advertising, and administrative purposes. You may opt out of this type of ad serving through your browser settings.

We are located in Hong Kong. In providing our Services, your Personal Information may be transferred to or processed in jurisdictions outside of Hong Kong only in compliance with the PDPO. We will ensure that any such transfer is protected by appropriate safeguards, including but not limited to model contractual clauses or binding corporate rules.

If you are located in Hong Kong, you have the following rights under the PDPO:

• The right to request access to your Personal Information;
• The right to request correction of your Personal Information; and
• The right to request deletion of your Personal Information (where permitted by law).

To exercise these rights, email us at info@seresimmigration.com. We will respond within the timeframe required by the PDPO (generally 40 days).

If you are in Hong Kong, you have the following additional rights in connection with our use of AI Tools:

• Right to human intervention. You may request that a qualified human review any AI-assisted assessment related to your case.
• Right to contest. You may contest any outcome materially influenced by AI-assisted processing.
• Right to an explanation. You may request meaningful information about how AI Tools were used in connection with your case.

Contact us at info@seresimmigration.com to exercise these rights.

Where required by the PDPO, we conduct assessments before deploying AI Tools that may result in high risks to your rights.