Privacy Policy


Thank you for visiting the website of ESR Group Limited (ESR, “we” “our” or “us”). By accessing this website (the “Site”), you agree to be bound by the terms set out in this Privacy Policy, which may be updated by us from time to time.

ESR is committed to safeguarding all confidential information. The following describes our current policies regarding collection, use and disclosure of your personal information which we receive in the course of you accessing our Site and any other services provided through this Site.

Collection of personal information may include information received solicited or unsolicited through the use of this Site. These may include and is not limited to, your name and contact details. The personal information may be used by ESR and/or any of its associates, including but not limited to any contractor, agent, business partners or service provider which provides administrative, data processing, financial, computer, telecommunications, payment or securities clearing, custodial or other services authorised by ESR when carrying out customer’s instructions and/or the business of ESR. Such information is only provided in accordance with the law and that our employees, agents and/or affiliates are required to treat the information confidentially and use it exclusively for the purpose for which it is provided. We do not share your personal information except where permitted by law or for lawful purposes.

This Privacy Policy concerns only the Site and does not concern any website to which the Site may link. Should you choose to visit these third-party sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your personal information. Similarly, this Privacy Policy does not concern your interaction with ESR in any matter other than your use of the Site. Finally, this Privacy Policy does not address our privacy practices with respect to any non-public personal information we may collect from you as an investor in us or in funds that we sponsor or manage; We address these practices in separate notices to investors or potential investors.

If you have any questions or comments about this Privacy Policy, you can contact us at

When you enter and browse the Site, we may collect information you provide to us and we may collect information on you through technology.

In order to obtain access to certain information or materials provided via the Site, you may have to provide information that we collect and store in a way that allows us to relate it to you personally, including but not limited to your name, e-mail address, mailing address, phone number, facsimile number. We refer to such information as personally identifiable information. Additionally, we may collect and retain a record of all communications with you.

We may collect information about you through technology. For example, we may collect your internet protocol (IP) address each time you request a page during a visit to the Site. At times, we may also use IP addresses to collect information regarding the frequency with which users browse various parts of the Site. The Site may also use cookies. The Site may also use other technical methods to track and analyse the traffic patterns on the Site, such as the frequency with which our users visit various parts of the Site. These technical methods may involve the transmission of information either directly to us or to another party authorised by us to collect information on our behalf. We may collect the information from use of these technical methods in a form that is personally identifiable.

We may also use software tools such as JavaScript to measure and collect session information, including page response times, download errors, length of visits to certain pages, page interaction information, and methods used to browse away from the page. We may use this information to measure site activity, to develop ideas for improving our websites and for any other purpose to the extent permitted by applicable law.

ESR does not disclose any non-public personally identifiable information to any non-affiliated third party, except where permitted by law.

To the extent permitted by any applicable Law, we may use your personally identifiable information in several ways. Although we do not sell your personal information to third parties, we may use or share certain personally identifiable information we collect about you when you visit and browse the Site as part of our normal business operations, or to send you administrative communications either about your interactions with us or about features of the Site, including any future changes to this Privacy Policy, to the extent permitted by law.

To the extent permitted by any applicable Law, we may also store your personally identifiable information and share it with our affiliates. We may use this information for marketing, research and other business purposes, and we may associate your personally identifiable information with other information we collect about you, such as details about your usage patterns and interests, in each case to the extent permitted by law.

We may also use service providers to facilitate our services or platform functions on our behalf. These companies and individuals may have access to your personally identifiable information, as permitted by law and as needed to perform their functions, but may not use it for another purpose.

We will disclose personal information when we believe that such disclosures are required by law, regulation, legal process or governmental request. We may also do so to help enforce our Terms of Use, protect your safety or security, including the safety and security of property that belongs to you, or protect the safety and security of our websites, databases or third parties, including the safety and security of tangible or intangible property that belongs to us or to third parties. Also, in the event that ESR, or substantially all of its assets, are acquired or merged with another entity, user information may be one of the transferred assets. You will receive a notice if such an event occurs. ESR, however, reserves the right to use any personal information in any manner permitted by law.

Non-personally identifiable information is information that does not personally identify you, including anonymous information and aggregate data. We may use this information to understand better how our visitors use the Site, research our visitors’ demographics, interest, and behaviour, improve the Site, provide visitors with customised services and information, and for other similar purposes. We may combine this information with personally identifiable information. We may share this information with others, such as investors, for information or promotional purposes to the extent permitted by law. ESR, however, reserves the right to use this information in any manner permitted by law.

We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personally identifiable information.

In the event of discrepancies of this policy between the English version and other language version(s), the English version shall prevail.

ESR, 2022