Last Updated: March 19, 2025

Vistina Structured Credit Privacy Policy

Vistina Structured Credit LLC (“Vistina,” “we,” “us,” “our”) is committed to respecting and protecting the privacy of the personal information it collects. Please read this privacy policy (“Policy”) carefully to understand what information we may collect when you visit and use our website, and how we use and when we disclose that information to others.

What Personal Information Do We Collect?

Note that, when we say “personal information” in this Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal information does not include information that is aggregated or information that cannot be reasonably linked to you.

We and third parties working on our behalf collect personal information that you provide directly to us. The specific information you provide is typically a function of the context in which you provide it; for example, we collect information from you when you use features on the website to email us questions or other information.

The personal information we collect may include, but is not limited to:

• Contact information and other identifiers you may provide (for example, name, address, phone number, e-mail address, social media identifier, name of your employer, your position or title, other professional information about you and your career, and other data you may provide us so that we can contact you).

• Internet activity information (for example, “cookies,” web server logs, web beacons, and other electronic tools to collect statistical information about your use of this website and other websites). For more information about how we collect and process such information, please see our “Cookie Policy” below.

• Other personal information you may provide.

How Do We Use and Disclose Your Personal Information and Other Information?

We and third parties working on our behalf use the information we have about you for internal business purposes, such as overseeing our business and client relationships, communicating with you, responding to your requests, enhancing our services, compiling aggregate statistics, and improving this website. To assist us with these activities, information covered by this Policy, including information about your use of this website, may be combined with or enhanced by other information that we have from other online or offline sources.

Finally, we may disclose your information with third parties as permitted or required by law, including:

• With service providers that assist us in operating our business;
• To comply with the law or in response to a subpoena, court order, government request, or other legal process;
• To produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings;
• To protect our or others’ interests, rights, safety, or property;
• To enforce any terms of service or other legal disclosures on or related to this website;
• In connection with a sale or other transfer of all or some of our assets and/or in connection with a sale or merger;
• To provide you with the services or products requested by you, and to perform other activities related to such services and products;
• To operate our systems properly; or
• Any other sharing, with your consent.

Note that this Policy does not apply to, and we are not responsible for, the treatment of the information by third parties or on third party websites. If you follow a link on our website to a third party’s site, you should review the privacy policy on that site.

We do not sell your personal information to third parties.

What Are Our Lawful Bases for Processing?

Some jurisdictions require that organizations have a “lawful basis” for processing or sharing any personal information. We have several lawful bases for using and sharing the information we collect for the purposes outlined above. Specifically:

• We have a legitimate business interest in ensuring that our website continues to function efficiently and effectively, and to enhance the functionality of the website in response to how visitors use the website.
• When you submit contact information, we use that data to fulfill your request or otherwise respond to your questions.
• We may need to perform such processing for compliance with applicable legal requirements or to assert legal rights or defenses.

To the extent that certain processing activities, or the processing of certain data, requires us to seek your consent, we will do so.

Cookies

As described above, we, third parties working on our behalf, and our partners, including social networking sites, may also place, view, and/or use cookies, web server logs, web beacons, and other electronic tools to collect statistical information about your use of this website. The information collected via these tools may include your device’s IP address, browser type, operating system, computer platform, web pages viewed, the date and time of your visit, the links you click within this website, the websites used prior to visiting this website, and whether you have been to this website before. As previously discussed, this information may be used research and analysis, to enhance your experience with this website, to provide you with certain functions on this website, or to create aggregate and anonymize information about usage of this website.

The collection, use, and disclosure of the information by third parties is governed by their own privacy policies. For example, we use Google Analytics to help us understand how website visitors use our websites. For more information about how Google uses cookies, visit here.

If you have deleted and disabled cookies, our ability to use these services, and some features of the website, will be hindered. Most web browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. The help function on most browsers contains instructions on how to set your browser to notify you before accepting cookies, disable cookies entirely, or how to disable the collection of geo-location data. You need to set each browser, on each device you use to surf the Web. Similarly, if you connect to the Web from multiple devices (e.g., work and home), you need to set each browser on each device. You may also opt out of our third-party partners’ cookies by following the instructions provided by DAA AdChoices – https://optout.aboutads.info. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of this website will not function properly.

In addition, you may manage the cookies that are installed via our website on our cookie management tool. Click on "Manage Cookies" to call up that tool and see what kinds of cookies you are currently allowing and which you may turn off.

Security

To protect your personal information from unauthorized access and use, we use reasonable administrative, technical, personnel, and physical measures. These measures include computer safeguards and secured files and buildings. However, there is no guarantee that information shared over the Internet will remain secure, so please use caution, particularly before sending any sensitive information like government identification numbers, financial information, or similar.

Data Retention

We will retain your personal information for as long as needed for the purposes described herein, or as otherwise required by law.

Accessing and Updating Your Personal Information

Some jurisdictions require companies like ours to give you the right to access, review, rectify, or delete the personal information we may have collected about you. If you reside in one of these jurisdictions and would like to exercise those rights, please submit a request. Please include the following information in all requests: first name, last name, and e-mail address. We will make reasonable efforts to fulfill your request, but we also reserve the right to impose certain restrictions and requirements on such access requests, if allowed or required by applicable laws.

Transferring Personal Information to Other Countries

We primarily store and process the information described above in the United States. You should only submit information if you are comfortable that your data will be stored in the United States as part of our effort to fulfill your request.

How We Respond to Do Not Track Signals

Some web browsers may give you the option to request that a website operator not track your information across its website or other websites using the browsers’ “Do Not Track” settings. At this time, we do not respond to “Do Not Track” browser settings or requests, and we will only use your information in a manner consistent with this Policy.

Modifications to This Privacy Policy

We reserve the right to modify this Policy at any time by posting the revised version on this website and updating the effective date above. Such changes will be effective upon posting. We encourage you to check this website frequently to see the current Policy in effect and any changes that have been made to it.

Questions Regarding This Privacy Policy

If you have additional questions regarding this Policy, please contact us.