www.bluelakesadvisors.com
Last updated: 1 July 2026

1. Introduction

This Privacy Policy explains how Blue Lakes Advisors SA (“Blue Lakes”, “we”, “our”, or “us”) collects, uses, and protects personal data when you visit www.bluelakesadvisors.com (the “Site”).

The Site is a showcase website providing general information on Blue Lakes and its fund distribution business. No client onboarding, account registration, financial transactions, or product subscriptions take place on this Site.

We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR) and any other data protection laws applicable in your jurisdiction. By using the Site, you agree to this Privacy Policy.

2. What Data We Collect

Given the nature of this Site as a showcase website, we collect only the following limited categories of personal data:

• Website usage data (e.g., IP address, browser type, pages visited, time spent on the Site), collected automatically when you access the Site;
• Contact and identification data that you voluntarily provide when submitting an enquiry through the Site’s contact form, specifically: your full name, email address, and phone number; your capacity as either a Fund Manager or a Qualified Investor, as selected by you; and any information you choose to provide in the free-text field describing your project or enquiry. Where you opt-in at the point of submission, your name and email address will also be added to our mailing list for the purpose of sending you updates and communications about Blue Lakes and its services. You are not obligated to complete the contact form, and any information you provide is given voluntarily; and
• Cookie and analytics data, as described in Section 7 below.

We do not collect financial, transactional, or KYC/AML data through this Site.

3. Purpose of Data Processing

We use the personal data collected through this Site solely for the following purposes:

• Operating and improving the Site (website functionality, analytics, and user experience);
• Responding to enquiries submitted through the Site’s contact form or by email;
• Understanding the nature and context of your enquiry, including your capacity as a Fund Manager or Qualified Investor, in order to direct your enquiry to the appropriate team and provide a relevant response;
• Sending marketing or promotional communications about Blue Lakes and its services, where you have consented to receive such communication (with the option to unsubscribe at any time); and
• Complying with applicable legal obligations.

4. Legal Basis for Processing

Our processing of your personal data through this Site is based on:

• Your consent, where you have provided it (e.g., for marketing communications or non-essential cookies);
• Our legitimate interests in operating and improving the Site and responding to enquiries; and
• Compliance with applicable legal obligations.

We do not process personal data on the basis of performance of a contract through this Site, as no contracts are formed or services delivered through it.

The collection of your professional capacity (Fund Manager or Qualified Investor) through the contact form is processed on the basis of our legitimate interest in responding appropriately to enquiries and ensuring that communications are directed to the right team. This information is used solely for the purpose of handling your enquiry and is not used for any profiling or automated decision-making.

The addition of your contact details to our mailing list is processed on the basis of your consent, given at the point of submission of the contact form. You may withdraw that consent at any time by unsubscribing from our communications. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to the withdrawal.

5. Data Sharing and Disclosure

We may share personal data collected through this Site with:

• Third-party service providers who assist us in operating the Site (e.g., website hosting, analytics, and IT support providers), each of whom is bound by confidentiality and data protection obligations; and
• Regulatory or legal authorities where we are required to disclose information by law.

We do not share personal data collected through this Site with financial product issuers, fund managers, or distribution partners, as no client relationships are established through this Site. We do not sell your personal data to any third party.

6. Data Retention

We retain personal data as long as necessary for the purposes described above or as required by Swiss financial regulations.

Mailing list data (your name and email address) is retained until you unsubscribe or withdraw your consent, at which point your details will be removed from our active mailing list within a reasonable period and no further marketing communications will be sent. Basic records of your consent and unsubscribe request may be retained for a short period thereafter for compliance purposes.

7. Cookies and Tracking

This Site uses cookies and similar tracking technologies for the following purposes:

• Essential cookies, which are necessary for the Site to function correctly and cannot be disabled;
• Analytics cookies, which help us understand how visitors use the Site and allow us to improve its functionality and content; and
• Marketing cookies, where applicable, which may be used to deliver relevant communications about Blue Lakes.

You can manage your cookie preferences through your browser settings or our cookie consent tool when you first visit the Site. Disabling non-essential cookies will not affect your ability to browse the Site.

8. Data Security

We apply industry-standard security measures to protect personal data from unauthorized access, disclosure, alteration, or destruction.

9. International Transfers

As this Site is accessible globally, personal data submitted through it may be processed in Switzerland or in other countries where our service providers operate. Where personal data is transferred outside of Switzerland or the EU/EEA, we ensure adequate protection by applying standard contractual clauses or other recognized safeguards in accordance with applicable law.

Visitors accessing this Site from jurisdictions with their own data protection requirements — including Singapore (Personal Data Protection Act) and Hong Kong (Personal Data (Privacy) Ordinance) — should be aware that their data may be transferred to and processed in Switzerland. We will handle such data in accordance with the applicable requirements of their jurisdiction to the extent required by law.

10. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you;
• Request rectification of inaccurate or incomplete data;
• Request erasure of your personal data (where applicable);
• Object to or request restriction of certain types of processing;
• Withdraw your consent at any time where processing is based on consent; and
• Lodge a complaint with your local data protection authority, including the Swiss Federal Data Protection and Information Commissioner (FDPIC) for Swiss residents, or the relevant supervisory authority in your jurisdiction.

To exercise any of these rights, please contact us using the details in Section 12 below.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The revised version will be posted on our website with an updated effective date.

12. Contact

For questions or requests regarding your personal data:

Blue Lakes Advisors SA, Swiss Company Limited by Shares, CHE-136.285.148
Galerie Jean Malbuisson 15, 1204 Geneva, Switzerland

Phone: +41 22 552 09 10
Email: compliance@bluelakesadvisors.com