Last updated: 7 September 2026

This Privacy Policy explains how personal data is processed in connection with the Blue Oceans Advisors website at www.blueoceansadvisors.com (the "Website"). It applies to visitors of the Website and to anyone who contacts Blue Oceans Advisors through the Website. It does not cover personal data processed in the context of a subsequent client engagement, which is addressed in the relevant engagement documentation.

Blue Oceans Advisors is operated by Jerome Vecchi, Principal, in Basel, Switzerland ("Blue Oceans Advisors", "we", "us"). Blue Oceans Advisors is the controller responsible for the processing of personal data described in this Privacy Policy. Our contact details are set out in Section 11 below.

(a) When you visit the Website

When you access the Website, certain technical data may be processed automatically in connection with delivering and securing the Website. This processing may be carried out by our website hosting/infrastructure provider and may include your IP address, the date and time of access, the pages requested, and information about your browser or device ("access data" or "server logs"). This processing is used to display the Website, keep it operating reliably and securely, and detect or prevent misuse.

We do not ourselves analyse this data for statistical, marketing or profiling purposes, and we do not combine it with any other information about you.

IONOS SE provides the Website hosting/infrastructure services and processes personal data in connection with those services on our behalf as a processor. According to IONOS, the data is stored entirely in IONOS data centres located in Germany.

(b) When you contact us by email

If you contact Blue Oceans Advisors by email — for example, to make a business enquiry — we process the personal data you choose to share, such as your name, email address, employer, and the content of your message, together with any personal data of third parties you may include. We use this information to respond to you and to conduct any resulting business discussions. If a client engagement is subsequently entered into, personal-data processing relating to that engagement is addressed separately in the applicable client documentation.

We do not use web forms, newsletter tools, or other automated means designed to collect personal data directly from visitors through the Website.

Blue Oceans Advisors does not intentionally deploy cookies or third-party analytics or marketing technologies designed to track Website visitors. IONOS SiteAnalytics is provided as part of the Website hosting service and is activated by default. According to IONOS, SiteAnalytics collects data through a pixel or log file and does not use cookies. The data processed includes the referrer, requested website or file, browser type and version, operating system, device type, time of access and an IP address that is anonymised directly after transmission. IONOS states that this data is processed for statistical evaluation and technical optimisation of the Website. Apart from IONOS SiteAnalytics described above, the Website does not use any additional cookies, similar technologies or externally loaded third-party resources.

Personal data may be disclosed to service providers that support the operation and security of the Website or the handling of email enquiries, including IONOS SE, our website hosting/infrastructure provider, and Google, which provides our Google Workspace email service, to the extent necessary for those services. IONOS and Google process personal data in connection with the respective services on our behalf as processors under their applicable data-processing terms.

We do not sell personal data and do not share it with third parties for their own marketing purposes.

According to IONOS, data stored in connection with the Website hosting is stored entirely in IONOS data centres located in Germany. Germany provides an adequate level of data protection for the purposes of Article 16 paragraph 1 FADP. Personal data contained in email communications may be processed by Google and its subprocessors outside Switzerland. Google provides contractual mechanisms for international transfers under its applicable data-processing terms, including recognised adequacy mechanisms where available and contractual safeguards where required. Where personal data is otherwise disclosed to recipients outside Switzerland, we ensure that the disclosure complies with Articles 16 and 17 FADP, including, as applicable, through an adequate level of protection, appropriate safeguards or a statutory exception.

Server/access logs are retained only for as long as necessary to operate and secure the Website. IONOS retains access logs for eight weeks. According to IONOS, the access logs stored during that period contain only anonymised IPv4 and IPv6 addresses.

Correspondence arising from an email enquiry is retained for as long as necessary to respond to you and pursue any resulting business relationship, and for longer where required by applicable statutory retention obligations, including where correspondence relates to a concluded engagement.

We take appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, misuse or alteration. No method of electronic storage or transmission can be guaranteed to be completely secure.

Under the FADP, you have the right to request confirmation of whether we process personal data about you and, if so, to obtain that data and related information (Art. 25 FADP); to request correction of inaccurate data; and, subject to the applicable statutory conditions, to request deletion or destruction of personal data and to object to specific processing or disclosure. Where the conditions of Article 28 FADP are met, you may also request that personal data you have provided be delivered to you in a commonly used electronic format or transferred to another controller. To exercise any of these rights, contact us at contact@blueoceansadvisors.com. If you believe that your data-protection rights have not been respected, you may also file a report with the Federal Data Protection and Information Commissioner (FDPIC).

We may update this Privacy Policy from time to time, for example to reflect changes to the Website or to applicable law. The version published on the Website is the version currently in effect.

Blue Oceans Advisors
Jerome Vecchi, Principal
4053 Basel, Switzerland