Privacy Policy

Last updated: August 2026

1. Grounds and General Provisions

1.1 Framework

This Privacy Policy (the “Policy”) explains how Bright Blue Partners Sàrl (“Bright Blue Partners”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal data in connection with its business activities and the operation of its website.

Bright Blue Partners is a company incorporated in Switzerland and processes personal data principally in accordance with the Swiss Federal Act on Data Protection (“FADP”), the associated ordinances and other applicable Swiss data protection legislation.

Where our activities involve individuals located in the European Economic Area or United Kingdom and the relevant legislation applies, we will also process personal data in accordance with the EU General Data Protection Regulation (“GDPR”), the UK GDPR, and other applicable data protection legislation.

1.2 Purpose

The purpose of this Policy is to explain:

  • what personal data we may collect;
  • why and how we process that data;
  • how we protect and retain personal data;
  • when personal data may be shared with third parties;
  • how we use cookies and similar technologies; and
  • the rights available to individuals in relation to their personal data.

1.3 Scope

This Policy applies to personal data processed by Bright Blue Partners in connection with:

  • visitors to our website;
  • clients and prospective clients;
  • suppliers and service providers;
  • professional advisers and business partners;
  • individuals who contact or communicate with us;
  • applicants for employment or engagement; and
  • other individuals with whom we interact in the course of our business.

2. Processing and Protection of Personal Data

2.1 Personal Data We Collect

“Personal data” means information relating to an identified or identifiable individual.

Depending on the nature of our relationship with you, we may collect and process information including:

  • name, title and contact details;
  • business address and organisation;
  • telephone number and email address;
  • professional position and employment information;
  • correspondence and other communications with us;
  • information contained in contracts, proposals or other business documentation;
  • billing, payment and transaction information;
  • information required for legal, regulatory, compliance or due diligence purposes;
  • recruitment information, including CVs, professional experience and qualifications;
  • information voluntarily provided through our website or when contacting us; and
  • technical information relating to your use of our website, including IP address, browser type, device information and website usage information.

We seek to collect only personal data that is reasonably necessary for the purposes for which it is processed.

2.2 Data Controller

Unless otherwise indicated, the entity responsible for the processing of personal data under this Policy is:

Bright Blue Partners Sàrl
Rue de Chantepoulet 10
1201 Geneva
Switzerland

UID: CHE-145.284.455

For questions concerning this Policy or the processing of your personal data, please contact us using the contact details provided on our website or at:

contact@brightblue.ch

2.3 How We Collect Personal Data

We may collect personal data:

  • directly from you;
  • through correspondence, meetings and other interactions with you;
  • when you submit an enquiry or otherwise communicate with us through our website;
  • through contractual or commercial relationships;
  • from your employer, organisation or professional representatives;
  • from publicly available sources;
  • from professional databases and business information providers;
  • from service providers acting on our behalf; and
  • automatically when you visit our website through cookies, server logs and similar technologies.

2.4 Principles Applying to Our Processing

Bright Blue Partners processes personal data in accordance with applicable data protection principles.

We seek to ensure that personal data is:

  • processed lawfully, fairly and transparently;
  • collected for specified and legitimate purposes;
  • proportionate and limited to what is necessary;
  • accurate and, where appropriate, kept up to date;
  • retained only for as long as reasonably necessary; and
  • appropriately protected against unauthorised or unlawful processing, accidental loss, destruction or damage.

3. Purposes for Which We Process Personal Data

We may process personal data for purposes including:

3.1 Business and Client Relationships

  • establishing and managing relationships with clients and prospective clients;
  • providing advisory, administrative, management or other professional services;
  • preparing proposals, presentations and other commercial materials;
  • negotiating and administering contracts;
  • communicating with clients and business contacts;
  • managing projects and engagements; and
  • maintaining appropriate business records.

3.2 Business Administration

  • invoicing and payment administration;
  • accounting and financial management;
  • supplier and service-provider management;
  • internal administration and record keeping;
  • corporate governance; and
  • managing our professional advisers and other service providers.

3.3 Legal, Regulatory and Compliance Purposes

We may process personal data where necessary to:

  • comply with applicable legal or regulatory obligations;
  • conduct appropriate due diligence;
  • prevent, identify or investigate fraud or other unlawful activity;
  • establish, exercise or defend legal claims;
  • respond to lawful requests from courts, regulators or public authorities; and
  • protect our business, employees, clients and other stakeholders.

3.4 Communications and Business Development

Where permitted by applicable law, we may process business contact information to:

  • communicate with existing and prospective clients;
  • provide information regarding Bright Blue Partners and its services;
  • invite contacts to meetings or events; and
  • maintain and develop professional relationships.

You may ask us to stop sending marketing or business-development communications at any time.

3.5 Website Operation

We may process technical and usage information in order to:

  • operate and maintain our website;
  • ensure the security and integrity of the website;
  • understand how visitors use the website;
  • diagnose technical issues;
  • improve the website and user experience; and
  • compile aggregated website statistics.

3.6 Recruitment

Where individuals apply for positions with Bright Blue Partners, we may process personal data for purposes including:

  • assessing applications;
  • conducting interviews;
  • verifying professional information;
  • communicating with applicants; and
  • taking steps necessary to enter into an employment or consulting relationship.

4. Basis for Processing

Depending on the circumstances and applicable law, we may process personal data where:

  • processing is necessary to enter into or perform a contract;
  • processing is necessary to comply with a legal obligation;
  • processing is necessary for our legitimate business interests or those of a third party;
  • you have provided consent;
  • processing is necessary for the establishment, exercise or defence of legal claims; or
  • another basis permitted by applicable law applies.

Where processing is based on consent, you may generally withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

5. Disclosure of Personal Data

Bright Blue Partners does not sell personal data.

We may disclose personal data where reasonably necessary to:

  • companies, consultants or individuals working with Bright Blue Partners;
  • technology and IT service providers;
  • website hosting and infrastructure providers;
  • cloud and data-storage providers;
  • accountants, auditors, lawyers and other professional advisers;
  • banks and payment providers;
  • insurers;
  • prospective purchasers, investors or counterparties in connection with a corporate transaction;
  • public authorities, courts or regulators where required or permitted by law; and
  • other third parties where disclosure is necessary for the operation of our business or performance of our services.

Where third parties process personal data on our behalf, we seek to ensure that appropriate contractual, confidentiality and data-protection arrangements are in place.

6. International Transfers

Bright Blue Partners operates and maintains professional relationships internationally. As a result, personal data may in certain circumstances be transferred to or accessed from countries outside Switzerland.

Where personal data is transferred to a country that does not provide a level of data protection recognised as adequate under applicable Swiss law, Bright Blue Partners will implement appropriate safeguards where required.

Such safeguards may include recognised contractual provisions, including applicable standard contractual clauses, or another mechanism permitted under applicable law.

Where the GDPR or UK GDPR applies, any international transfers will also be managed in accordance with the relevant requirements of those laws.

7. Data Retention

Bright Blue Partners retains personal data for as long as reasonably necessary for the purposes for which it was collected.

Retention periods may depend upon:

  • the nature of the information;
  • the duration of our relationship with the relevant individual or organisation;
  • contractual requirements;
  • applicable legal or regulatory obligations;
  • statutory limitation periods;
  • accounting and tax requirements; and
  • whether information may be required in connection with an actual or potential legal dispute.

When personal data is no longer reasonably required, it will be deleted, anonymised or otherwise securely disposed of in accordance with applicable requirements.

8. Data Security

Bright Blue Partners takes reasonable organisational and technical measures designed to protect personal data against:

  • unauthorised access;
  • misuse;
  • accidental loss;
  • alteration;
  • disclosure;
  • destruction; and
  • other unlawful processing.

While we take appropriate steps to protect information under our control, no method of transmission or electronic storage can be guaranteed to be completely secure.

9. Cookies and Similar Technologies

Our website may use cookies and similar technologies.

Cookies are small data files stored on a user’s device when visiting a website. They may be used to:

  • enable essential website functionality;
  • remember website preferences;
  • understand how visitors use the website;
  • measure website performance; and
  • improve website content and functionality.

Some cookies may be provided by third-party services used on our website.

Where required under applicable law, non-essential cookies or similar technologies will only be used with the appropriate consent.

You may also control or delete cookies through your browser settings. Disabling certain cookies may affect the functionality or performance of the website.

Where our website uses a dedicated cookie-management tool, visitors may also use that tool to manage their preferences.

10. Third-Party Websites and Services

Our website may contain links to websites or services operated by third parties.

Bright Blue Partners is not responsible for the privacy practices, content or security of third-party websites. We recommend reviewing the applicable privacy policies of third-party websites before providing personal data to them.

11. Rights of Individuals

Subject to applicable law and any relevant exceptions, you may have rights in relation to your personal data including the right to:

  • obtain information regarding the processing of your personal data;
  • request access to personal data held about you;
  • request correction of inaccurate or incomplete personal data;
  • request deletion of personal data where applicable;
  • object to or request restriction of certain processing;
  • withdraw consent where processing is based on consent;
  • request the provision or transfer of certain personal data in a commonly used electronic format where applicable; and
  • exercise other rights provided under applicable data protection legislation.

We may need to verify your identity before responding to a request.

Certain rights are subject to exceptions and limitations under applicable law, and we may therefore be permitted or required to retain or continue processing certain information despite a request.

Requests regarding your personal data should be sent to:

contact@brightblue.ch

or by post to:

Bright Blue Partners Sàrl
c/o Calliopée Sàrl
Rue de Chantepoulet 10
1201 Geneva
Switzerland

12. Complaints

If you have concerns about how Bright Blue Partners processes your personal data, we encourage you to contact us in the first instance.

You may also have the right to contact the competent data protection supervisory authority.

In Switzerland, the relevant federal supervisory authority is the Federal Data Protection and Information Commissioner (FDPIC).

Where another country’s data protection legislation applies to the processing of your information, you may also have the right to contact the relevant supervisory authority in that jurisdiction.

13. Children’s Data

Our website and services are intended for professional and business audiences and are not directed towards children.

We do not knowingly seek to collect personal data relating to children through our website.

14. Changes to this Privacy Policy

Bright Blue Partners may amend this Policy periodically to reflect:

  • changes to our business or services;
  • developments in technology;
  • changes in the manner in which personal data is processed; or
  • changes in applicable laws or regulatory guidance.

The latest version will be made available on our website and the date of the most recent update will be shown at the beginning of the Policy.

15. Contact

Questions about this Privacy Policy or the processing of personal data by Bright Blue Partners should be addressed to:

Bright Blue Partners Sàrl
Rue de Chantepoulet 10
1201 Geneva
Switzerland

UID: CHE-145.284.455

Email: contact@brightblue.ch