Privacy Policy

1. Who we are

This privacy policy is issued by LIQUIDITY PROVIDERS PTE. LTD. (Company Registration No. 202506689M), a company incorporated in Singapore with its registered office at 10 Anson Road #20-05, International Plaza, Singapore 079903, trading as "Seconda Private Markets" ("we", "us", "our"). We are the data controller responsible for the personal data described in this policy. If you have any questions about this policy, or about how we handle your personal data, please contact us at [email protected].

2. What we collect

We collect the following categories of personal data about you:

• Form submissions. When you complete one of our forms, hosted for us by Tally, we collect your name, email address, phone number, firm, the companies and ticket sizes you express interest in, and any free text you choose to include.
• Meeting bookings. When you book a call with us through Calendly, we collect the details you provide as part of that booking.
• Document access. When you request access to a deal memo or other document hosted on DocSend, we collect the email address you provide in order to open it.
• Technical data. When you visit our website, we automatically log technical data, including your IP address, browser type, and the pages you view.
• Usage data. We record which pages are viewed and which links and buttons are clicked, for example a request for access or a request to open a deal memo, so that we can understand which parts of the site are useful. This is collected without cookies and is not linked to you personally.

3. Why we use it and our legal basis

We use your personal data for the following purposes:

• to respond to your enquiries and assess your eligibility for an opportunity, which is necessary for the performance of, or to take steps towards, a contract with you;
• to carry out know-your-customer (KYC) and anti-money laundering (AML) checks and to assess investor eligibility, which we do to meet our legal obligations and in our legitimate interests as a regulated business;
• to operate, maintain, and secure our website, which is in our legitimate interests.

We do not use personal data for advertising, and we do not sell personal data to any third party.

4. Who we share it with

We share personal data with the following processors, each engaged to help us provide our services:

• Tally, which hosts our forms and processes the information you submit through them.
• Calendly, which processes your meeting booking details.
• DocSend, a Dropbox service, which hosts deal memos and other documents and manages access to them.
• Cloudflare, which provides hosting, content delivery, security logging, and cookieless page-view analytics for our website.
• Umami, which provides cookieless website analytics. It records the pages you view and which links and buttons you click, so that we can understand how our site is used. It does not set cookies, does not store your IP address, and does not track you across other websites.

We may also share personal data with our broker-dealer partner, Finalis Securities LLC, and with SPV administrators, where this is necessary to progress a transaction, and with our professional advisers or with regulators, where we are legally required to do so.

5. International transfers

We are based in Singapore, and many of our service providers are based in the United States. As a result, your personal data may be transferred to, and processed in, countries outside your own, including outside the United Kingdom and the European Economic Area (EEA). Where this happens, we rely on appropriate safeguards, such as standard contractual clauses, to protect your personal data.

6. Retention

We keep personal data collected through enquiries only for as long as necessary for the purpose for which it was collected, and to meet our legal and regulatory record-keeping obligations. Once it is no longer needed for either purpose, we delete or anonymise it.

7. Your rights

Depending on where you are based, you may have the right to:

• access the personal data we hold about you;
• request that we correct or rectify inaccurate personal data;
• request that we erase your personal data;
• request that we restrict our processing of your personal data;
• receive a copy of your personal data in a portable format; and
• object to certain processing of your personal data.

To exercise any of these rights, contact us at [email protected]. You also have the right to lodge a complaint with a supervisory authority. In Singapore, this is the Personal Data Protection Commission (PDPC).

8. Cookies

We do not use advertising cookies, and we do not track you across other websites. Cloudflare, our hosting and security provider, may set strictly necessary cookies to protect our website and keep it running smoothly, and runs Cloudflare Web Analytics on our pages, which counts page views without setting cookies or building a profile of you. We also use Umami for analytics, which likewise sets no cookies, stores no IP addresses, and does not follow you to other websites, so no consent banner is needed to use this site. Our forms are hosted by Tally on their own site rather than embedded here, so no third-party form script runs on our pages. Our fonts are self-hosted, so simply loading a page on our site does not share your IP address with a third-party font provider.

9. Changes

We may update this policy from time to time. When we do, we will revise the "last updated" date at the top of this page.