SERA IQ Privacy Policy

Last updated: October 20, 2026

This Privacy Policy explains how Facto Global LLC ("Facto", "we", "us" or "our"), the operator of SERA IQ, handles information about subscribers and their users (Part A), information about people named in public filings shown in SERA IQ (Part B), information about subscribers to the SERA IQ Capital Brief, its free weekly email (Part C), and information about the partners in SERA IQ's referral program (Part E). Capitalized terms not defined here have the meanings in the SERA IQ Terms of Service.

Part A. Subscribers and Their Users

A1. Information we collect

(a) Account information you give us: name, company, email address and password. Passwords are stored only as a one-way hash. If you sign up from a link on our public website, we also keep the name of the website page the link was on and, where the link that brought you to our website carried a tag (for example the channel it was shared on), that tag, so we know which pages and channels bring subscribers.

(b) Use of the Service: the raises you save and, for each, the words the follows email last gave about the money around it, so that it tells you only when one changes, the firms and issuers you follow, the workspaces you make (their names, what you file in them and the notes you write in them, which only your account sees), your email preferences (including how often the follows email comes) and whether you closed the notice of a change to the Terms of Service, so that it does not show again, which emails we sent you, and any bounce or complaint our email provider reports for your address.

(c) Activity records: sign-in and sign-up records, including IP address; a log of exports, each with its export code; which SERA IQ pages your account opens, counted by day; and, for each filing page and profile opened, each firm whose contact details you open, each name search made and, on demo access or in a first subscription's first days, each Find capital search, the time and your account, never the name searched. For each firm whose contact details you open, and for each profile opened and Find capital search made on demo access or in a first subscription's first days, we also keep a short code made from what was opened or searched, never its name, so that each counts once a day.

(c-1) Use summary. To protect the Service from automated copying, SERA IQ keeps an hourly summary of each account's use for thirty (30) days: how many requests, pages and data requests it made, how many different filing and firm pages it opened, and from how many network addresses and browsers. To make that summary, SERA IQ records each request your account makes (its time, the kind of page and the filing or firm it opened) for two (2) days. Network addresses and browser descriptions are kept only as one-way codes made with a secret key, never as written, and are used only to tell them apart. If an account's use looks automated, SERA IQ may pause it for up to an hour and tells you so on every page while it lasts; a pause does not cancel or change your subscription.

(c-2) Searches. A name you type into the firm search, into name search or into either search of the Records search page is used only to answer that search. It is sent from your browser in the body of the request, never in a web address, and SERA IQ does not store it or write it to its logs. A search leaves only the records described in Sections A1(c) and A1(c-1): the page counted by day, the request, and for a name search the time and your account.

(d) Export contents. For each export of filings or name-search results, a record of which filings the file held and which parts of each filing it printed, so that we can ask you to delete a record later removed from SERA IQ (Part B).

(e) Acceptance of the Terms. Each time you accept the Terms of Service, the version accepted, the time and how it was accepted.

(f) Payment information: payments are processed by Stripe. We receive the status of your subscription and payments; the name, business name, billing address and any tax identification number given at checkout or in the billing portal; the country of your card and billing address; and the last digits and expiry of your card. We do not receive or store full card numbers. To prevent self-referral and other abuse of the referral program, and to apply the first-month refund only to a first subscription as Section 5.5 of the Terms of Service provides, we also keep a one-way code, made with a secret key, of the identifier Stripe gives each payment card used on a paying account, never the card number itself.

(g) Communications: messages you send to us. A message sent through the contact form at app.seraiq.io/contact holds your name, your email address, your organisation if you give one, its topic and the message; we use it only to answer you and to protect the form against abuse, and it is deleted one hundred eighty (180) days after it is received. A request to cancel and refund sent through the form is linked to your account, if you have one, and kept with the state of your first-month refund when it arrived, so that it can be decided as of that time. A refund request that pauses your account's exports while it waits for our decision is kept until it is decided, if that is later.

(h) Demo requests: the information described in Section A9.

(i) Promotion codes. If we issue a promotion code to your email address, we keep a one-way hash of that address with the code, never the address itself. When a code is redeemed, we record which account redeemed it, when, and for which subscription.

(j) Referrals. If you follow a referral partner's link to SERA IQ, enter a referral partner's code, or ask for the Capital Brief through a referral partner's link, we record which partner referred you and when. When your account first subscribes, we decide once whether it is credited to a referral partner, and keep that decision and the commission records for it. Before crediting an account, we check whether the account or its user has had a demonstration or complimentary access, and whether its payment card, network or email domain is shared with another paying account or with a partner; for these checks we use the one-way codes described in Sections A1(f) and A9(c). A partner learns only what Section A3(e) states.

We do not use advertising cookies, and no cookie we set follows you to any other website. No page you see signed in to the Service carries an analytics script. On our public website, seraiq.io, and on the Service's public pages (sign-up, sign-in, the demo request, contact and removal request forms, the Capital Brief's pages, and the legal pages), we measure visits through web analytics providers acting for us. They record the page viewed, how the visit arrived (the referring site or a tagged link), and the visitor's approximate country, browser and device type, and they do not tell us who you are. Where a provider uses cookies or similar technologies to recognize a returning browser, it runs only after you agree, where the law requires your consent, and you can withdraw that agreement at any time from a link on every public page. When you sign up, we record the page or tagged link that brought you to the sign-up and, if you followed a referral partner's link, that partner, as described below. The Service uses cookies and browser storage only to keep you signed in, protect forms against forgery, remember display preferences, remember for as long as you stay signed in the last raise you described and the notices you have already seen, remember a request not to be counted in a browser where someone has made one, and remember a referral partner's link as described next.

When you follow a referral partner's link, the Service counts the visit by day: the number of visits, the number of different visitors (worked out with a one-way code that changes each day and is deleted at the end of that day), the website the visit came from, and whether it came from a paid search advertisement. It also sets one cookie on app.seraiq.io that holds the partner's link name and the time of the visit for thirty (30) days, so that an account opened within that time can be credited to the partner. Only SERA IQ reads that cookie, and it is never shared. The Service sets no such cookie for a visitor from the European Economic Area, the United Kingdom or Switzerland, for a visitor whose country it cannot determine, for a browser that sends a Global Privacy Control or Do Not Track signal, or where the link asks not to be tracked; those visitors are credited to a partner only if they enter the partner's code.

A2. How we use it

We use this information to provide, secure and bill for the Service; to apply usage limits and the Terms; to comply with sanctions and export-control laws, including by reviewing payments from a country or territory subject to comprehensive U.S. sanctions; to detect, prevent and investigate fraud, abuse, account sharing and unauthorized redistribution; to credit and pay referral partners, and to prevent self-referral and other abuse of the referral program; to send service, billing and account emails and the emails you choose to receive; to understand which parts of the Service are used, so we can improve it; to respond to you; and to comply with law and protect our rights.

The raises you describe or save, the firms and issuers you follow, your workspaces and the notes you write in them, and what you tell us in a demo request about what you are raising or researching, are used only to provide the Service to you and, for a demo request, to consider and set up your demo. Facto Global LLC and its affiliates do not use them for their own raising, investing or outreach, and we do not send them to any artificial intelligence provider.

A3. We do not sell your information

We do not sell, rent or trade subscriber information to anyone, and we do not share it for advertising. Subscriber information is kept for our own use in operating SERA IQ. We disclose it only:

(a) to service providers that process it for us under obligations of confidentiality, limited to providing their services: payment processing (Stripe), email delivery (Resend), network, security and content delivery (Cloudflare), server hosting (Hostinger), web analytics on our public pages (the providers described in Section A1), and internal operator alerting (Telegram), whose alerts identify an account by its number and not by its email address;

(b) when required by law, subpoena, court order or other legal process, or to respond to a lawful request of a public authority;

(c) when we believe in good faith that disclosure is needed to enforce the Terms, investigate misuse of the Service or of exported data, or protect the rights, property or safety of Facto, our subscribers or others;

(d) in connection with a merger, acquisition, financing, reorganization or sale of all or part of our business, in which case the information remains subject to this Policy; and

(e) to a referral partner whose link or code led to your account (Section A1(j)), only as counts of the accounts opened through its link or code, of those that paid and of those that were refunded or reversed, and the commission it earned on them. We never give a referral partner your name, your email address, your firm or anything else that identifies you. Because a partner may refer only a few accounts, a partner that already knows it referred you may be able to tell from these counts whether you paid or were refunded.

A4. How long we keep it

A5. Your choices

You can update your account details, turn emails off and close your account from the Account page. To ask that your account information be deleted, write to [email protected] from the address on the account. We will delete it, except information we are required or permitted to keep under this Policy or by law.

Information we delete or erase can remain in our encrypted backups for up to thirty (30) days, and in our hosting provider's server snapshots until they are replaced, after which it is gone. We do not restore deleted information from a backup except to recover the Service after a failure, and if we do, we delete it again.

A6. Security

We protect information with reasonable administrative, technical and physical measures. Your workspaces and their notes are shown only to your account; our staff may open them only to support you at your request, to secure the Service or as required by law. No system is completely secure, and we cannot guarantee the security of information transmitted to or stored by the Service.

A7. Where information is processed

SERA IQ is operated from the United States. Information is processed and stored in the United States and in other countries where our service providers operate. By using the Service, you consent to that processing.

A8. Business users only

The Service is offered to businesses and is not directed to children. We do not knowingly collect information from anyone under 18.

A9. Demo requests

(a) What we collect. When you ask for a demo of SERA IQ, we collect your name, your work email address, your firm, what you tell us you are raising or researching, and the time of the request. As with sign-ups, the IP address the request came from is kept with our sign-up records for the period in Section A4, to protect the form against abuse.

(b) Why. We use a demo request only to decide whether to offer a demo, to set up the demo and contact you about it, and to protect the request form against abuse. We do not add you to any mailing list because of a demo request.

(c) How long we keep it. If we invite you and you open an account, the request is kept with your account while it is open and deleted when the account is erased. Otherwise, we delete the request within one hundred eighty (180) days after it is received. We keep a one-way code of the email address of each demo request, made with a secret key, for two (2) years after the latest request from that address, and use it only so that an account later opened by a demo requester is not credited to a referral partner (Section A1(j)).

(d) Deleting it. To ask that your demo request be deleted sooner, write to [email protected] from the address you gave. We will delete it, except information we are required or permitted to keep under this Policy or by law.

(e) Raise information. What you tell us about what you are raising or researching is used only as stated in Section A2. Facto Global LLC and its affiliates do not use it for their own raising, investing or outreach.

A10. Research drafting

SERA IQ's weekly and monthly analyses, including the view of the economic cycles shown with them, are drafted with the help of artificial intelligence providers that Facto selects, from aggregate market figures. No subscriber information and no information about any person named in a filing is sent to them.

Part B. People Named in Public Filings

B1. What SERA IQ shows. Form D filings with the U.S. Securities and Exchange Commission name people: an issuer's executive officers, directors and promoters, people paid in connection with selling an offering, and the person who signed. SERA IQ shows them on each filing's own page, and finds filings by a name typed into its name search, including the person search of its Records search page, which searches Form D filings only, exactly as filed in the SEC's public records: name, title and other details as the filer entered them, except as this Part states (addresses, for example, as Section B1(a) states). An investment adviser's Form ADV, also filed with the SEC, lists the individuals who lead it, and SERA IQ may show some of them with that adviser alone, as Section B1(c) states. SERA IQ takes every fact it shows about a person from these government records only. It adds nothing to them, infers or scores nothing about any person (beyond deciding, so as to withhold more, whether a name is a person's), does not match or combine them with other sources, and does not build a profile of any person. Subscribers may follow a firm, or an issuer that is not a person, to hear when it files again; SERA IQ does not let anyone follow a person named in a filing. A subscriber who follows an issuer is also reminded, in the follows email, shortly before the first anniversary of the latest Form D of each of its offerings under Rule 504 or 506 (the date Rule 503 refers to); the reminder is worked out from the filings' dates alone and names no person.

(a) Addresses and telephone numbers. SERA IQ shows a person named in a filing with the city and state of the address the filing gives, never the street, ZIP code or telephone number of a natural person. Where a filing names a person as its issuer, the issuer's address is shown the same way, with no telephone number.

(b) Firms' offices. An investment adviser's street address, and a placement firm's address from the SEC's list of active broker-dealers, are shown only in the firm's contact details, which a subscriber opens with a click. SERA IQ shows the street and telephone number of an investment adviser's main office only where its Form ADV says that office is not a private residence; where Form ADV marks the main office as a private residence, or does not say, SERA IQ shows neither. For a placement firm that files no Form ADV, SERA IQ may show the business address that the SEC's public list of active broker-dealers gives for it, with no telephone number, and withholds that address where an investment adviser that is the same firm marks its main office as a private residence or does not say. Where a placement firm is not found on that list, SERA IQ may show, with the date of the newest such filing, the city and state, or the city and country, that Form D filings naming the firm itself as paid to sell give for it, never a street, ZIP code or telephone number, and shows none where it withholds that firm's address under this paragraph or Section B3. SERA IQ shows no street address and no telephone number for an investment adviser or placement firm whose name is a person's.

(c) A firm's leaders. Where SERA IQ shows an investment adviser's contact details, which a subscriber opens with a click in the profile or page of the adviser, of a fund it manages or of a placement firm that is the same firm, it may also show the individuals the adviser lists in Schedule A of its newest Form ADV with a leadership title, such as chief executive officer, president, director, managing member or chief compliance officer, while the adviser is registered on the SEC's current roster. Each is shown by name and title as filed, dated to that Form ADV. Individuals listed only as owners, members, shareholders, limited partners or trustees are not shown. An individual listed as a partner, with no other title, is shown only where that Form ADV marks the individual as a control person; SERA IQ reads that mark only to decide which titles show, and does not keep or show it. No one is shown for an adviser whose name is a person's or whose Form ADV names a sole proprietor. They are shown with no address, telephone number, email address, individual registration (CRD) number, ownership or control information, and with nothing inferred about them; they cannot be found by searching a person's name, including on the Records search page; they are not included in any export, email or report; and they are not matched to the people named in Form D filings or combined with any other source, except that the name given in a removal request is looked for among both so that it can be hidden. A person shown there may ask for removal as Section B3 states.

(d) Demo Access. An account on Demo Access, as the Terms of Service describe it, is not shown the name of any person this Part describes, and has no name search, including the person search of the Records search page.

B2. Source. This information comes from public government records: filings with the SEC and, for a placement firm's address, the SEC's public list of active broker-dealers. The filing remains public on the SEC's own website whatever SERA IQ shows.

B3. Removal requests. To ask that a record about you be removed from SERA IQ, use the removal request form at app.seraiq.io/privacy/removal, or write to [email protected], naming the filing (its accession number or link) and the entry or, for a person shown among a firm's leaders (Section B1(c)), the firm (its name, its CRD number or the link to its page in SERA IQ) instead of a filing. A request may also name a firm's page in SERA IQ, by its link; that firm's street address and telephone number are then withheld, and its city and state stay shown. When a request reaches SERA IQ, SERA IQ hides at once the record about a person that the request identifies clearly enough under SERA IQ's matching rules, and Facto then reviews the request; a request sent by email or post reaches SERA IQ when we record it. For a person shown among a firm's leaders, a request that names a firm SERA IQ can identify hides at once every leader there whose name holds the first and last name given, and a request that names no firm hides at once only where one name as filed, and no other, matches the name given. Any other request, including one whose record SERA IQ cannot identify at once, goes to Facto's staff, who find the record by hand. If Facto refuses a request on review, what the request hid is shown again. We act on a request made under the federal Daniel Anderl Judicial Security and Privacy Act, the law of New Jersey commonly known as Daniel's Law, Texas Government Code chapter 92 or a similar law within the time that law requires, counted from when we receive the request, and on other requests within ten (10) business days. A removed record stays hidden after every reload of the data, including, for a person shown among a firm's leaders, in that firm's later Form ADV filings, and we ask subscribers who exported it to delete it.

B4. Records of removal requests. We keep each removal request, the information given in it and what we did about it, for as long as the removal stays in force and as long as needed to show that we acted on the request. We use that information only to act on the request, to keep the record hidden and to answer you.

B5. Sanctions lists and SEC orders. SERA IQ keeps the sanctions lists that the U.S. Treasury's Office of Foreign Assets Control (OFAC) publishes, its Specially Designated Nationals and Blocked Persons List and its Consolidated Sanctions List, for entities only, as OFAC publishes them. It keeps no entry for an individual, a vessel or an aircraft, and from OFAC's daily file of changes it keeps only each entry's number, the lists it names and the kind of change. SERA IQ compares those entities only with the names of the firms it shows, never with a firm whose name is a person's and never with a name typed into a search. SERA IQ also reads the SEC's administrative proceedings and litigation releases to find the firms they name by CIK number. It keeps no document's text and no list of the people a document names: for each document it reads, it keeps the link, release numbers, date, proceeding file number and the kind of document it is, and for a document that names a firm beside its CIK number, also the document's title and that firm's name and CIK number as printed. SERA IQ shows these records about firms only. For each link between a firm and an OFAC entry that SERA IQ's rule finds, Facto keeps the firm, the entry, the facts that agreed, whether the link was approved by the rule or by Facto's staff and who approved it, when, and any refusal or withdrawal and its reason, for as long as the link is shown and afterwards as the record of the decision. A pair that only nearly meets the rule is kept only to test the rule and is never shown.

Part C. The SERA IQ Capital Brief

C1. What we collect. When you ask for the SERA IQ Capital Brief, our free weekly email, we keep your email address, your name if you give it, the words you agreed to and when (the consent record), whether and when you confirmed the address, each issue we sent you and when, and when and how you unsubscribed. As with sign-ups, the IP address a request came from is kept with our sign-up records for the period in Section A4, to protect the form against abuse. Subscribers to the SERA Market Briefing, which the Capital Brief replaces, were moved to it with the date and the way they originally signed up. If you ask for the Capital Brief through a referral partner's link, we also keep that partner's link name with your request and subscription, so that a SERA IQ account opened with the same address within ninety (90) days after you confirm it can be credited to the partner (Section A1(j)). Subscribers moved from the SERA Market Briefing are never credited to a partner.

C2. Why. We use this information only to send you the Capital Brief, to confirm your address, to honor an unsubscribe, to keep the list free of addresses that bounce or complain, and, where you asked for it through a referral partner's link, to credit that partner as stated in Section C1. The Capital Brief is a separate consent from a SERA IQ account: closing or erasing an account does not end a Capital Brief subscription, and unsubscribing from the Capital Brief does not change an account.

C3. How we send it. The Capital Brief is sent through the email delivery provider named in Section A3. It carries no tracking pixel and no click tracking: we do not record whether you open it or which links you follow. Every issue says why you receive it, carries a one-click unsubscribe link and states our mailing address.

C4. How long we keep it. A sign-up that is never confirmed, and each request made through the form or a link, is deleted thirty (30) days after it is received. Your subscription is kept while you are subscribed, and the record of each issue sent to you is kept for four hundred (400) days. After you unsubscribe, or if your address bounces or a complaint is received, we keep the address and why it was removed, so that it is never mailed again.

C5. Deleting it. To ask that your Capital Brief information be deleted, write to [email protected] from the subscribed address. We delete your address, name, consent record and any referral partner's link name kept with them, and keep only a one-way code of the address, so that it is never mailed again.

Part D. General

D1. Changes. We reserve the right, in our sole discretion, to change this Policy at any time. We will post the updated Policy with a new "Last updated" date and, for a material change, notify subscribers and, for a change to Part E, referral partners, by email or in the Service. Continued use after a change takes effect is acceptance of it.

D2. Contact. Facto Global LLC, 4613 N University Dr PMB 244, Coral Springs, FL 33067. Privacy: [email protected].

Part E. Referral Partners

E1. Who this Part covers. This Part covers the people and businesses that take part in SERA IQ's referral program under a Marketing Partner Agreement with Facto ("referral partners"), and the people who act for them.

E2. What we collect. We keep:
(a) the partner's name, firm, address and email address, and the sign-in records of its partner account, as Section A1(c) describes for subscribers;
(b) each acceptance of the Marketing Partner Agreement, with the version accepted, the time and how it was accepted, and a one-way code, made with a secret key, of the network address it was accepted from; the partner's own terms, which we set for each partner and may change for accounts credited after a change: its commission percent and the months it is paid for, its client benefit, and its code and link, with each change and when it took effect; and what the partner tells us about its regulatory status, such as the firms it is registered with or associated with and the notices it gave them;
(c) whether the partner is in the United States; whether and when we received its IRS Form W-9 and the kind of taxpayer number it gives, never the number itself; and the date and result of each sanctions screening;
(d) for payouts through Stripe, the identifier of the Stripe Express account we open for the partner, which only receives payouts from us, and whether it can receive them; for any other payout, its amount, method, reference and date;
(e) the partner's program records: daily visits through its link, monthly counts of the accounts it referred that joined, paid, and were refunded or reversed, its commission records, statements and payouts, and any review of its referrals and how it ended; and
(f) the emails we send the partner about the program, and the messages it sends us, including copies of its promotions and the records of its email campaigns that it gives us under the Marketing Partner Agreement.

E3. Tax forms and bank details. The partner's Form W-9 itself, with its taxpayer number, is kept by Facto outside SERA IQ's systems, with Facto's tax records, and is used only for tax reporting, any withholding the law requires, and as the law otherwise requires. For payouts through Stripe, Stripe collects the partner's identity, bank and tax details directly, under Stripe's own terms and privacy policy, and SERA IQ never receives the partner's bank account details. For a payout by wire, Wise transfer or check, the payment details the partner gives are kept by Facto outside SERA IQ's systems and used only to make its payouts.

E4. How we use it. We use this information to run the referral program: to decide which accounts are credited to a partner, to calculate, hold and pay commissions, to send statements and program emails, to file tax information returns, to screen against sanctions lists, to prevent and investigate self-referral, fraud and other abuse, to enforce the Marketing Partner Agreement, and to comply with law.

E5. Who receives it. We do not sell, rent or trade referral partners' information. We disclose it only to Stripe, the partner's name and email address to open its Stripe Express account, and its payouts made through it; to Facto's licensors, copies of the partner's promotions and of the materials it uses in them, so that they can check the use of the SERA IQ name and logo; to the bank, Wise or postal service that carries a payout; to tax authorities, including on IRS Form 1099-NEC, as the law requires; to Facto's accountants and legal advisers, under duties of confidentiality; to the service providers named in Section A3(a), as they process it for us; and as Sections A3(b) to (d) state.

E6. How long we keep it. We keep a partner's information while it takes part in the referral program and, after it ends, for as long as it has a balance, commissions still held, or a refund request, payment dispute or review open, and then for seven (7) years for tax and accounting records. After that, we remove the partner's name and email address, and keep its commission and payout records by partner number only, with our billing and payment records. Records of acceptances of the Marketing Partner Agreement are kept as the record of the agreement. Sign-in records are kept for the period in Section A4.

E7. A partner's own subscription. If a referral partner also subscribes to SERA IQ, Part A covers that subscription, and that subscription earns no commission.

E8. Your choices. A referral partner may ask us to correct its information, or to delete it, by writing to [email protected] from the email address it gave us. We will do so, except for information we are required or permitted to keep under this Policy, the Marketing Partner Agreement or law.