Vista Credit BDC Management, L.P. and our affiliates (together, “our”, “we”, “company” or “Vista”) are committed to respecting the privacy of all users of our website (the “Site”). We have established and implemented this Privacy Policy to inform you, the user of the Site, of the type of information collected by us and how we use and protect such information. Please read this Privacy Policy carefully.
Except where EU laws apply to the processing of your personal information, by providing your personally identifiable information to us, you signify your acceptance of this Privacy Policy and agree that we may collect, use and disclose your personally identifiable information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not provide your personal details to us.
This Privacy Policy is incorporated into, and part of, the Terms of Use, which govern your use of the Site in general.
Vista reserves the right to amend this Privacy Policy in its sole discretion from time to time. Vista will post any changes to this Privacy Policy on the Site so our users are always aware of what information we collect, how we use it and under what circumstances, if any, we disclose it, and such changes shall be effective immediately upon posting. If at any point we decide to collect personal information or use any collected information in a manner different from that stated at the time it was collected, we will notify applicable users. Except where EU laws apply to the processing of your personal information, your provision of personally identifiable information after any such changes constitutes your acceptance of the new terms and conditions.
We will use information only in accordance with the Privacy Policy under which the information was collected.
For the purposes of applicable EU laws, Vista Credit BDC Management, L.P. will be a data controller of any personal data collected by us. If you have any questions regarding our use of your personal data, or this Privacy Policy, please contact Vista at +1 (415) 756.6500 or at [email protected].
Table of Contents
- Information We Collect
- How We Use Information Collected
- Marketing
- With Whom Do We Share the Information We Collect?
- CCPA Consumer Rights
- Transfers of Personal Information Outside the EEA
- Security
- Capacity
- Cookies
- Your EU Rights
Information We Collect
Information you provide to us
In general, you can visit the Site without telling us who you are or revealing any information about yourself.
We collect your personal information when you decide to interact with us and which you submit using the contact options provided on this Site. You can also provide us with personal information via email, post and telephone. This may include your name, email address, address, title, job title, position, telephone number and IP address. We may collect additional personal information about you, including special categories of personal information, when you apply for a job with Vista or an affiliate or enter into an agreement with Vista. See below for further information on ‘How We Use Information Collected’.
Information provided by third parties or publicly available sources
We collect personal information about you from third parties including from our affiliates, our portfolio companies, job posting websites and recruiting firms, and companies that we are evaluating in connection with a potential investment or business opportunity.
Information provided under a legal obligation
If we require your personal information due to a legal requirement or obligation or in order to perform a contract with you, we will make you aware of this at the time we collect your personal data, and the possible consequences of you failing to provide this personal data (e.g., we may require your passport details to verify your identity for the purposes of anti-money laundering regulations). Failure to provide this information may mean that we cannot provide our services or products to you. In this case, we may have to cancel the service you have with us, but we will notify you if this is the case at the time.
How We Use Information Collected
To the extent that you provide us with any personal information, through or in connection with this Site (i.e., via telephone, email or post), we may use such information for the following purposes:
PURPOSE |
LEGAL BASIS |
| To provide you with the services or financial products you have requested, e.g., responding to any inquiry. | Contractual necessity |
| For our administration, research, database development and business operation purposes. | Legitimate interest |
| To keep a record of your relationship with us. | Legitimate interest |
| To verify your identity. | Legal requirement and legitimate interest |
| To process your inquiries about employment opportunities at Vista | Legitimate interest or pre-contractual necessity |
| To conduct due diligence activities in connection with an actual or prospective corporate transaction or investment with respect to which we are party to. | Legitimate interest |
| Fraud and abuse prevention. | Legal requirement and legitimate interest |
| Litigation management and conducting internal audits and investigations. | Legal requirement and legitimate interest |
| To administer and protect our business and this website. | Legitimate interest |
| To make suggestions and recommendations to you about goods or services that may be of interest to you. | Legitimate interest |
Note that we may process your personal data on more than one legal basis depending on the specific purpose for which we are using your personal information.
Marketing
We will send you direct marketing communications where we have obtained your prior consent to keep you informed of our services in which you might be interested, or based on our legitimate business interests where we have an existing relationship with you and we wish to contact you about similar products or services in which you may be interested. You may opt out of certain kinds of marketing communications by clicking the “opt out” link provided in such emails or by contacting [email protected].
With Whom Do We Share the Information We Collect?
Your personal information will be shared with and processed by:
- our affiliates;
- certain service providers as necessary to fulfill the purposes set out in this Privacy Policy, including professional advisors, recruitment firms, consultants and data hosting providers
We use our best efforts to ensure anyone who provides a service to, or for us, enters into an agreement with us and meets our standards for data security.
We reserve the right to disclose your personal information to third parties in order to comply with law, to law enforcement or other governmental agencies, or when we believe that disclosure is necessary to enforce or protect our rights in or otherwise with respect to, or the safety of, our Site, or to protect the safety or rights of other users of our Site and/or comply with a judicial proceeding, court order, request from a regulator, national security, for the purposes of public importance or any other legal or investigatory process involving us. Should we, or any of our affiliated entities, be the subject of a takeover, divestment or acquisition we may disclose your personal information to the new owner of the relevant business and their advisors.
CCPA Consumer Rights
California: Your Privacy Rights
If you are a California resident, you may have the right to (1) request access to certain personal information we have collected about you, (2) request that we delete certain personal information we have collected from you and (3) opt-out of the sale of your personal information.
To view our California Consumer Privacy Statement, click here.
Transfers of Personal Information Outside the EEA
Your personal information will be hosted in the U.S. and will therefore be transferred and stored outside of the European Economic Area (“EEA”), where collected in the EU. For the purpose of applicable EU laws, such third countries (including the U.S.) may not offer the same level of data protection as your country of residence. Such transfers will be made in accordance with applicable EU data privacy laws. For further information about the safeguards used, please contact [email protected].
Security
We are committed to protecting the personal information you entrust to us. We implement appropriate security measures and technologies to seek to ensure the security of your personal information on our systems and to ensure that it is protected to the extent possible from unauthorized access and improper use. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Notwithstanding our efforts to protect your information, no security system is completely impenetrable, so we cannot guarantee the absolute security of our databases, nor can we guarantee that information you supply to us will not be intercepted while in transit to us over the Internet. Any transmission of information or data by you to or through this Site is at your sole risk.
We will keep your personal information only for as long as is reasonably necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required by law. We will not keep more information than we need for those purposes. For further information about how long we will keep your personal information, please contact [email protected].
Capacity
This site is only intended for individuals who are at least 13 years of age. We do not knowingly encourage or solicit visitors to this site who are under the age of 13 or knowingly collect personal information from anyone under the age of 13 without parental consent. If we learn we have collected or received personal information from an individual under the age of 13, we will delete that information.
Cookies
Strictly Necessary Cookies
These cookies are essential for the website to function properly and cannot be disabled. They are used to enable basic features such as page navigation and access to secure areas of the website.
Performance Cookies
These cookies collect information about how visitors use the website, such as which pages they visit most often and whether they receive error messages. This helps us to improve the performance and usability of the website.
Functionality Cookies
These cookies enable the website to remember your preferences and choices, such as your language and region. They can also be used to provide certain features, such as personalized content and social media integration.
Analytics Cookies
These cookies are used to collect information about how visitors use the website, such as which pages they visit and how long they stay on the site. We use this information to analyze user behavior and improve the website.
Marketing Cookies
These cookies are used to track your browsing activity across different websites and to show you targeted advertising based on your interests. If you do not allow these cookies, you will experience advertising less relevant to your interests.
Global Privacy Control (GPC)
This website recognizes and respects the Global Privacy Control (GPC) standard, which allows users to communicate their privacy preferences to websites that may process their personal information. If you have enabled a GPC signal on your browser or device, we will process it for your browser, but it will not apply outside of that browser to your device, account, or offline sales or sharing. After using the GPC, if you clear your cookies in your browser, you will need to use the GPC again for us to process your opt-out request for that browser. For more information about the GPC, please visit https://globalprivacycontrol.org.
Google Analytics: Our websites use cookies for Google Analytics. You can learn more about how Google uses the information it collects by visiting https://www.google.com/policies/privacy/partners/.
Your EU Rights
To the extent that EU data protection laws apply to the processing of your personal information, or to the extent that you are a resident of the UK, the EU or the EEA, you have certain rights with respect to your personal information, as outlined below.
You have the right to access the personal information we hold about you, and there are a number of ways you can control the way in which and what information we store and process about you. To exercise these rights and controls, please contact [email protected].
- Access: You have the right to ask for a copy of the personal information that we hold about you free of charge, however we may charge a ‘reasonable fee’, if we think that your request is excessive, to help us cover the costs of locating the information you have requested.
- Correction: You may notify us of changes to such your personal information if it is inaccurate or it needs to be updated.
- Deletion: If you think that we shouldn’t be holding or processing your personal information anymore, you may request that we delete it. Please note that this may not always be possible due to legal obligations.
- Restrictions on use: You may request that we stop processing your personal information (other than storing it), if: (i) you contest the accuracy of it (until the accuracy is verified); (ii) you believe the processing is against the law; (iii) you believe that we no longer need your data for the purposes for which it was collected, but you still need your data to establish or defend a legal claim; or (iv) you object to the processing, and we are verifying whether our legitimate grounds to process your personal information, override your own rights.
- Object: You have the right to object to processing, including: (i) for direct marketing; (ii) for research or statistical purposes; or (iii) where processing is based on legitimate interests.
- Portability: If you wish to transfer your personal information to another organization (and certain conditions are satisfied), you may ask us to do so, and we will send it directly if we have the technical means.
- Withdrawal of consent: If you previously gave us your consent (by a clear affirmative action) to allow us to process your personal information for a particular purpose, but you no longer wish to consent to us doing so, you can contact us to let us know that you withdraw that consent.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Should you wish to lodge a complaint with regards to how your personal information has been processed by us, please contact your local supervisory authority. In the UK, this is the Information Commissioner’s Office. You can find details for your relevant EU national data protection authority here.
Question and Comments
If you have any comments or questions about our privacy practices or your experience with the Site, please do not hesitate to contact Vista at +1 (415) 765.6500 or [email protected].