Privacy Notice

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December 2025

Privacy Notice
Vistia Capital, LLC respects your right to privacy and recognizes our responsibility for protecting the privacy and security of the personal information we receive from you. We have always been committed to securing the confidentiality and integrity of your personal information. We are proud of our privacy practices and want our current and prospective
customers to understand what information we collect and how we use it.

Why We Collect Your Information
We gather information about you so that we can (i) know who you are and thereby prevent unauthorized access to your information, (ii) design and improve the services we
offer and (iii) comply with the laws and regulations that govern us.

What Information We Collect
We may collect the following types of ‘nonpublic personal information’ about you: Personally Identifiable Information (PII):

• Information about your identity, such as your name, address and social security number;
• Information about your transactions;
• Information about your personal financial profile, such as your risk tolerance levels, goals and objectives, assets, liabilities, savings and investments.

Non-Personally Identifiable Information (Non-PII):

• Browser type, device ID, and IP address

How We Use Your Information

We may use your information to:

• Verify investor eligibility.
• Facilitate transactions and fulfill service requests.
• Respond to inquiries and customer service requests.
• Deliver communications and regulatory updates.
• Maintain regulatory records.
• Improve site experience and compliance.
• Provide good faith disclosures to regulators who have regulatory authority over us.

What Sources We Obtain Your Information From

We collect nonpublic personal information about our clients such as you from the following
sources:

• Information we receive from you on contracts or other forms; such as risk tolerance questionnaires and/or investment policy statements.
• Information about your transactions with our affiliates, or others.
• If you visit our website, information we collect via a web server is often referred to as a cookie. Cookies indicate where a site visitor has been online and what has been viewed.

What Information We Disclose
We do not disclose any non-public personal information about our customers or former customers to anyone, except to affiliates, as permitted or required by law, or for regulatory
compliance. Moreover, we will not release information about our customers or former customers unless one of the following conditions is met:

• We receive your prior written consent.
• We believe the recipient to be you or your authorized representative.
• We are required by law to release information to the recipient.

Regulation S-P Procedures

Information Security and Incident Response. We maintain written policies and procedures designed to protect the security and confidentiality of nonpublic personal information. Our program includes measures to:

• Identify and assess risks of unauthorized access or use.
• Implement and monitor safeguards appropriate to our business model.
• Detect, respond to, and recover from security incidents affecting customer information.

If we determine that nonpublic personal information has been, or is reasonably likely to have been, accessed or used without authorization, we will notify aƯected individuals as soon as practicable, and no later than 30 days after that determination, except where a delay is requested by law enforcement.

Service Provider Oversight. We require third-party service providers with access to nonpublic personal information to:

• Maintain appropriate protections.
• Notify us promptly of any unauthorized access or use.
• Cooperate in incident response and mitigation efforts.

Additionally, we conduct ongoing due diligence and monitoring of service providers consistent with regulatory requirements.

Scope of Individuals Covered. These protections apply to current and former clients, as well as to individuals who provide information to us in connection with a potential advisory or brokerage relationship, even if no account is opened or no contract is signed.

Privacy Notice Delivery under Regulation SP. We will provide initial privacy notices consistent with Regulation S-P. Consumers will receive notice before any non-public personal information is shared with third parties, and customers will receive notice before a customer relationship is established. When a relationship is initiated by telephone and providing notice beforehand materially delays a transaction, the notice may be delivered within the Customer Agreement Form, provided you consent. Annual privacy notices will be provided to all active customer accounts unless the privacy policy remains unchanged.

Opt-Out Provisions
We have taken steps to assure that all third-party vendors have confidentiality clauses to protect your information. Should we not have such written agreements in place, then you have the option to “opt-out” of the sharing of this information. If you desire to opt out of receiving marketing material from us or those instances that we do not have the confidentiality clause, you should provide us with written instructions forwarded to Chief Compliance Officer at the address set out below. Additionally, the law allows you to “opt out” of only certain kinds of information sharing with third parties. As mentioned above, we do not share personal information about you with any third parties that trigger this opt-out right. This means you are already opted out of those sharing situations.

California Privacy Rights
California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. That notice will identify the categories of information shared and will include a list of the third parties and aƯiliates with which it was shared, along with their names and addresses. If you are a California resident and would like to make such a request, please submit your request in writing at the address information below.

Confidentiality and Security
We maintain physical, electronic and procedural safeguards to guard your personal information. We also restrict access to your personal and financial data to our authorized associates who have a need for these records. We require all nonaffiliated organizations and vendors to keep client data confidential and use appropriate security measures to protect it. They must also be contractually obligated to keep the information provided confidential and used as requested. Furthermore, we will continue to adhere to the privacy
policies and practices described in this notice even after your account is closed or becomes inactive.

Cookies and Other Tracking Technologies
We may track users by IP address, by cookies (e.g., pieces of code or text placed on your computer by us or third parties when you browse our websites), by web beacons and other data collection methods for broad demographic data, as well as to help make sure that we are delivering the information you want. Our website sends cookies to your web browser (if your browser’s preferences allow it) to collect data when you browse our website(s). Cookie settings can be controlled in your Internet browser to automatically reject some forms of cookies. If you view our website without changing your cookie settings, you are indicating your consent to receive all cookies from our website(s). If you do not allow cookies, some features and functionality of our website(s) may not operate as expected. In addition to cookies, we place technological tools (and allow certain third parties to place technological tools) such as tags and beacons (e.g., code scripts that are primarily used to track visitors’ activities on our website(s) by web analytics software), Internet Protocol (IP) addresses, and other tools, to collect your data for the purposes listed in this Privacy Policy. “Do Not Track” signals are options available on your browser to tell operators of websites that you do not wish to have your online activity tracked. Our websites operate no differently if these “Do Not Track” signals are enabled or disabled.

To Contact Us
If you have questions regarding our privacy policy, please contact us at 720.738.1740 or [email protected].

Rev. 12.2025