Data Protection Notice
Your privacy is very important to us. This notice (“Privacy Notice”) is provided by the Lakemore Group (“Lakemore”, “we”, or “us”) and will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Lakemore Partners Ltd. is the group parent and is domiciled in the Cayman Islands. Lakemore Partners Management US LLC is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser (RIA Lakemore Partners (DIFC) Ltd. is authorized and regulated by the Dubai Financial Services Authority (“DFSA”). ). Lakemore Partners (UK) Ltd. is registered and domiciled in the United Kingdom. Lakemore Partners Management US LLC, Lakemore Partners (DIFC) Ltd. and Lakemore Partners (UK) Ltd. are wholly owned subsidiaries of Lakemore Partners Ltd. The various Lakemore entities listed above and any related entities that may exist in the future are, collectively, referred to herein as the “Lakemore Group”.
This website is not intended for minors, and we do not knowingly collect data relating to minors.
It is important that you read this Privacy Notice together with any other privacy notice or policy we may provide, from time to time, on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This Privacy Notice supplements other privacy notices and privacy policies and is not intended to override them.
1. Information We Collect
We may collect non-public personal information about you from the following sources:
Information you provide to us, including through subscription documents, investor questionnaires, onboarding forms, correspondence, meetings, telephone calls, emails, and other direct communications.
Information arising from your relationship with us, including records of investments, transactions, capital activity, distributions, account balances, payment instructions, communications preferences, and related administrative records.
Information from third parties, including placement agents, administrators, custodians, banks, professional advisers, screening providers, identity verification providers, public registers, regulatory databases, sanctions and politically exposed person screening tools, and other service providers.
Information collected through our website or electronic systems, including IP address, browser type, device information, usage data, cookies, log data, and similar technical information.
The types of information we may collect include but not limited to:
- name, address, email address, telephone number and other contact details;
- date of birth, nationality, tax identification number, passport or national ID details;
- employment, occupation, source of wealth and source of funds information;
- bank account, transaction and investment information;
- ownership, control, beneficial ownership and authorised signatory information;
- AML/KYC, sanctions, adverse media and investor eligibility information;
- communications records and preferences; and
- technical and website usage information.
We do not seek to collect sensitive personal information unless it is necessary or appropriate for legal, regulatory, AML/KYC, sanctions, tax, investor eligibility, or related compliance purposes.
2. How We Use Information
We may use your non-public personal information generally but not limited to the following purposes:
- to provide investment advisory, investor relations, fund administration support and related services;
- to process subscriptions, transfers, redemptions, distributions, capital activity and other investment-related transactions;
- to conduct AML/KYC, sanctions, politically exposed person, adverse media and other compliance checks;
- to assess investor eligibility, suitability where applicable, tax status and regulatory classification;
- to communicate with you and manage our relationship with you;
- to maintain books and records required under applicable law and regulation;
- to comply with SEC, tax, AML, sanctions, court, governmental, regulatory and law enforcement obligations;
- to manage legal, regulatory, operational, cybersecurity, fraud prevention and business continuity risks;
- to administer and protect our business, systems, website and records;
- to share information within the Lakemore group where necessary for legitimate business, operational, legal or compliance purposes; and
- to send relevant business communications, subject to applicable law and your communication preferences.
3. Information Sharing
We do not sell your non-public personal information.
We may disclose non-public personal information where permitted or required by law, including but not limited to:
- affiliates within the Lakemore group;
- fund administrators, custodians, banks, auditors, legal advisers, tax advisers, compliance consultants, IT providers, screening providers and other service providers;
- regulators, tax authorities, courts, law enforcement agencies, government bodies and self-regulatory organisations;
- counterparties or professional advisers in connection with corporate transactions, restructurings, audits, disputes, investigations or legal proceedings;
- persons acting in a fiduciary, representative or authorised capacity on your behalf; and
- other parties with your consent or as otherwise permitted by applicable law.
Where we share information with service providers, we expect them to use such information only for the purposes for which it was provided and to maintain appropriate confidentiality and security protections.
4. Safeguarding of Information
We maintain administrative, technical and physical safeguards reasonably designed to protect customer information against unauthorised access, use, disclosure, alteration or destruction.
These measures may include access controls, confidentiality obligations, cybersecurity controls, vendor oversight, secure recordkeeping, monitoring, incident response procedures and employee awareness measures.
The SEC has amended Regulation S-P to strengthen safeguarding, disposal, incident response and customer notification expectations for covered institutions.
5. Disposal of Information
We maintain procedures reasonably designed to ensure that non-public personal information and consumer report information are securely disposed of when no longer required, subject to applicable legal, regulatory, tax, accounting and recordkeeping obligations.
6. Data Retention
We retain non-public personal information for as long as reasonably necessary for the purposes for which it was collected, including to satisfy legal, regulatory, AML/KYC, tax, accounting, reporting, audit, dispute resolution and recordkeeping requirements.
We may retain information for longer periods where required or permitted by law, regulation, contractual obligation, litigation hold, regulatory inquiry or legitimate business need.
7. International Transfers
Because Lakemore operates internationally, your information may be processed, stored or transferred in jurisdictions outside your country of residence, including the United States, the United Arab Emirates, the Cayman Islands and other jurisdictions where Lakemore group entities or service providers operate.
Where information is transferred internationally, we take steps designed to ensure that it is handled in accordance with applicable legal and confidentiality requirements.
8. Website and Cookies
Our website may use cookies, analytics tools, server logs and similar technologies to collect technical and usage information. This may include IP address, browser type, device information, pages visited, time spent on the website and other usage data.
You may be able to manage cookies through your browser settings. Disabling cookies may affect the functionality of certain website features.
9. Marketing Communications
We may use your contact details to send business updates, investor communications or other information that may be relevant to your relationship with us.
You may request that we stop sending marketing communications by contacting us using the details below. Please note that we may continue to send administrative, regulatory, legal, transactional or relationship-related communications where appropriate.
10. Your Choices and Rights
Depending on your jurisdiction and relationship with us, you may have rights regarding your personal information, including rights to request access, correction, deletion, restriction, portability or objection to certain processing.
These rights may be limited by applicable legal, regulatory, AML/KYC, tax, accounting, litigation, recordkeeping or other obligations.
To submit a request, please contact us using the details below.
11. Contact Details
Lakemore Partners Management US LLC is responsible for this Privacy Notice.
For questions regarding this Privacy Notice or our privacy practices, please contact:
Contact Person: Mehmet Baris Timur
Email: mehmet@lakemore.com
Telephone: +971 4 430 9911
Address: 1611, Level 16, Index Tower, DIFC, PO Box 507071, Dubai, UAE
12. Updates to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our business, legal or regulatory requirements, technology, service providers or privacy practices.
The most current version of this Privacy Notice will apply from the date it is published or otherwise made available.
Data Protection Notice
Your privacy is very important to us. This notice (“Privacy Notice”) is provided by the Lakemore Group (“Lakemore”, “we”, or “us”) and will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Lakemore Partners Ltd. is the group parent and is domiciled in the Cayman Islands. Lakemore Partners Management US LLC is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser (RIA Lakemore Partners (DIFC) Ltd. is authorized and regulated by the Dubai Financial Services Authority (“DFSA”). ). Lakemore Partners (UK) Ltd. is registered and domiciled in the United Kingdom. Lakemore Partners Management US LLC, Lakemore Partners (DIFC) Ltd. and Lakemore Partners (UK) Ltd. are wholly owned subsidiaries of Lakemore Partners Ltd. The various Lakemore entities listed above and any related entities that may exist in the future are, collectively, referred to herein as the “Lakemore Group”.
This website is not intended for minors, and we do not knowingly collect data relating to minors.
It is important that you read this Privacy Notice together with any other privacy notice or policy we may provide, from time to time, on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This Privacy Notice supplements other privacy notices and privacy policies and is not intended to override them.
1. Information We Collect
We may collect non-public personal information about you from the following sources:
Information you provide to us, including through subscription documents, investor questionnaires, onboarding forms, correspondence, meetings, telephone calls, emails, and other direct communications.
Information arising from your relationship with us, including records of investments, transactions, capital activity, distributions, account balances, payment instructions, communications preferences, and related administrative records.
Information from third parties, including placement agents, administrators, custodians, banks, professional advisers, screening providers, identity verification providers, public registers, regulatory databases, sanctions and politically exposed person screening tools, and other service providers.
Information collected through our website or electronic systems, including IP address, browser type, device information, usage data, cookies, log data, and similar technical information.
The types of information we may collect include but not limited to:
- name, address, email address, telephone number and other contact details;
- date of birth, nationality, tax identification number, passport or national ID details;
- employment, occupation, source of wealth and source of funds information;
- bank account, transaction and investment information;
- ownership, control, beneficial ownership and authorised signatory information;
- AML/KYC, sanctions, adverse media and investor eligibility information;
- communications records and preferences; and
- technical and website usage information.
We do not seek to collect sensitive personal information unless it is necessary or appropriate for legal, regulatory, AML/KYC, sanctions, tax, investor eligibility, or related compliance purposes.
2. How We Use Information
We may use your non-public personal information generally but not limited to the following purposes:
- to provide investment advisory, investor relations, fund administration support and related services;
- to process subscriptions, transfers, redemptions, distributions, capital activity and other investment-related transactions;
- to conduct AML/KYC, sanctions, politically exposed person, adverse media and other compliance checks;
- to assess investor eligibility, suitability where applicable, tax status and regulatory classification;
- to communicate with you and manage our relationship with you;
- to maintain books and records required under applicable law and regulation;
- to comply with SEC, tax, AML, sanctions, court, governmental, regulatory and law enforcement obligations;
- to manage legal, regulatory, operational, cybersecurity, fraud prevention and business continuity risks;
- to administer and protect our business, systems, website and records;
- to share information within the Lakemore group where necessary for legitimate business, operational, legal or compliance purposes; and
- to send relevant business communications, subject to applicable law and your communication preferences.
3. Information Sharing
We do not sell your non-public personal information.
We may disclose non-public personal information where permitted or required by law, including but not limited to:
- affiliates within the Lakemore group;
- fund administrators, custodians, banks, auditors, legal advisers, tax advisers, compliance consultants, IT providers, screening providers and other service providers;
- regulators, tax authorities, courts, law enforcement agencies, government bodies and self-regulatory organisations;
- counterparties or professional advisers in connection with corporate transactions, restructurings, audits, disputes, investigations or legal proceedings;
- persons acting in a fiduciary, representative or authorised capacity on your behalf; and
- other parties with your consent or as otherwise permitted by applicable law.
Where we share information with service providers, we expect them to use such information only for the purposes for which it was provided and to maintain appropriate confidentiality and security protections.
4. Safeguarding of Information
We maintain administrative, technical and physical safeguards reasonably designed to protect customer information against unauthorised access, use, disclosure, alteration or destruction.
These measures may include access controls, confidentiality obligations, cybersecurity controls, vendor oversight, secure recordkeeping, monitoring, incident response procedures and employee awareness measures.
The SEC has amended Regulation S-P to strengthen safeguarding, disposal, incident response and customer notification expectations for covered institutions.
5. Disposal of Information
We maintain procedures reasonably designed to ensure that non-public personal information and consumer report information are securely disposed of when no longer required, subject to applicable legal, regulatory, tax, accounting and recordkeeping obligations.
6. Data Retention
We retain non-public personal information for as long as reasonably necessary for the purposes for which it was collected, including to satisfy legal, regulatory, AML/KYC, tax, accounting, reporting, audit, dispute resolution and recordkeeping requirements.
We may retain information for longer periods where required or permitted by law, regulation, contractual obligation, litigation hold, regulatory inquiry or legitimate business need.
7. International Transfers
Because Lakemore operates internationally, your information may be processed, stored or transferred in jurisdictions outside your country of residence, including the United States, the United Arab Emirates, the Cayman Islands and other jurisdictions where Lakemore group entities or service providers operate.
Where information is transferred internationally, we take steps designed to ensure that it is handled in accordance with applicable legal and confidentiality requirements.
8. Website and Cookies
Our website may use cookies, analytics tools, server logs and similar technologies to collect technical and usage information. This may include IP address, browser type, device information, pages visited, time spent on the website and other usage data.
You may be able to manage cookies through your browser settings. Disabling cookies may affect the functionality of certain website features.
9. Marketing Communications
We may use your contact details to send business updates, investor communications or other information that may be relevant to your relationship with us.
You may request that we stop sending marketing communications by contacting us using the details below. Please note that we may continue to send administrative, regulatory, legal, transactional or relationship-related communications where appropriate.
10. Your Choices and Rights
Depending on your jurisdiction and relationship with us, you may have rights regarding your personal information, including rights to request access, correction, deletion, restriction, portability or objection to certain processing.
These rights may be limited by applicable legal, regulatory, AML/KYC, tax, accounting, litigation, recordkeeping or other obligations.
To submit a request, please contact us using the details below.
11. Contact Details
Lakemore Partners Management US LLC is responsible for this Privacy Notice.
For questions regarding this Privacy Notice or our privacy practices, please contact:
Contact Person: Mehmet Baris Timur
Email: mehmet@lakemore.com
Telephone: +971 4 430 9911
Address: 1611, Level 16, Index Tower, DIFC, PO Box 507071, Dubai, UAE
12. Updates to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our business, legal or regulatory requirements, technology, service providers or privacy practices.
The most current version of this Privacy Notice will apply from the date it is published or otherwise made available.
These Terms of Use govern your access to and use of this website. By using the site, you agree to these terms. If you do not agree, please do not use the site.
No Offer or Solicitation
The content of this website is for informational purposes only and does not constitute an offer to sell, or a solicitation of an offer to buy, any security, fund interest or investment product, nor does it constitute investment, legal, tax or other advice. Any such offer would be made only through definitive offering documents and to eligible investors in permitted jurisdictions.
Regulatory Status
Lakemore Partners Management US LLC is registered with the U.S. Securities and Exchange Commission as an investment adviser. Lakemore Partners (DIFC) Ltd. is regulated by the Dubai Financial Services Authority. Registration does not imply any particular level of skill or training.
Forward-Looking Statements
Certain information on this site may contain forward-looking statements that involve risks and uncertainties. Past performance is not indicative of future results, and no representation is made that any investment will or is likely to achieve results comparable to those shown.
Intellectual Property
All content on this site, including text, graphics, logos and marks, is the property of Lakemore Partners or its licensors and is protected by applicable intellectual-property laws. You may not reproduce or distribute it without our prior written consent.
Limitation of Liability
The site is provided “as is” without warranties of any kind. To the fullest extent permitted by law, Lakemore Partners disclaims liability for any loss arising from use of, or reliance on, the site or its content.
