Privacy Notice

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Privacy Notice – Vistia Capital  

June 2026  

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  oƯer 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 information to regulators and governmental authorities as required by law. 

What Sources We Obtain Your Information From  

We collect nonpublic personal information about our customers 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 nonpublic personal information about our customers or former  customers to nonaƯiliated third parties except as permitted or required by law. Moreover,  we will not release information about our customers or former customers unless one of  the following conditions is met:  

• 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 affected individuals as soon as  practicable, and as soon as practicable, consistent with applicable regulatory requirements,  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 as soon as practicable, and no later than 72 hours after becoming aware  of any unauthorized access to or use of customer information.  
• 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 customers, 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. We provide initial and annual privacy notices to customers as required  by Regulation S-P. 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. We limit sharing of nonpublic personal information to  circumstances permitted by law that generally do not require an opt-out. 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.  

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 affiliates 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 customer 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, your browser settings  will determine how cookies are handled 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. 06.2026