Privacy Policy

Last Updated: 15. March 2026

Effective Date: 15. March 2026

This Privacy Policy explains how Vistera Partners (“we,” “us,” or “our”) collects, uses, and protects personal information when
you interact with our website at https://www.visterapartners.com, our products, or any related services (collectively, the
“Services”). We are committed to safeguarding your information and handling it responsibly in accordance with applicable data
protection laws.

Our business is located at 58 Route de Lodève, 34080 Montpellier, FRANCE.

If you have questions about this Privacy Policy or the way we process personal information, you can contact us at
contact@visterapartners.com or via post to the address indicated below.

Our Role in Data Processing

Depending on the context, we act as both a data controller and a data processor.

As a data controller, we determine how and why personal information is processed when we operate our website, manage user
accounts, provide customer support, or carry out other core activities related to offering our Services.

As a data processor, we may process personal information on behalf of other organizations and according to their instructions when
our Services are used to store, manage, or handle data that belongs to those organizations.

Table of Contents

Information We Collect
How We Collect Information
How We Use Your Information
How We Process Your Information
Automated Decision-Making and Profiling
Cookies & Tracking Technologies
How We Share Information
International Transfers
How Long We Retain Information
How We Keep Information Safe
Your Rights
Children’s Privacy
Updates to This Policy
How to Contact Us
INFORMATION WE COLLECT

We collect personal information that you provide directly, information generated automatically when you use our Services, and
information obtained from third-party tools that support our operations. The specific personal information we collect depends on
how you interact with our Services, the features you use, and the choices you make.

Personal information we receive directly from you or collect automatically includes:

IDENTIFIERS

Name
Email address
Phone number

ACCOUNT AND TRANSACTION DATA

Account or profile information

TECHNICAL AND DEVICE DATA

Device identifiers
Browser type and operating system

USAGE DATA

Pages visited

ANALYTICS AND TRACKING DATA

Cookie data
Analytics events

COMMUNICATION DATA

Messages or information provided through forms or support

PREFERENCES AND LOCALIZATION DATA

Time zone
City-level location (if available)

Some features of our Services require specific personal information to function.

All personal information you provide must be accurate, complete, and up to date. You are responsible for notifying us if any of
your information changes so we can maintain accurate records.

HOW WE COLLECT INFORMATION

We collect personal information through a combination of information you provide directly, information gathered automatically when
you use our Services, and information supplied by third-party providers that support our operations.

Information You Provide Directly

We collect personal information that you choose to provide when you interact with our Services. This includes information
submitted when you:

create an account or update profile details
complete forms, make purchases, or engage with customer support
respond to surveys, request information, or communicate with us

This information typically includes identifiers (such as name, email, phone number), account details, and any other information
you voluntarily provide as part of your use of the Services.

Information Collected Automatically

When you visit our website or use the Services, we automatically collect certain technical and usage information. This data does
not usually reveal your identity but may include:

IP address and device identifiers
browser type, operating system, and device characteristics
language settings and time zone
pages viewed, links clicked, and navigation patterns
error logs, performance data, and diagnostic information
cookie data, analytics events, and usage logs

This information helps us operate, secure, and optimize the Services, and supports internal analytics, reporting, and service
improvement.

HOW WE USE YOUR INFORMATION

We only process personal information when we have a valid legal basis under applicable data protection laws. This means we process
data when it is necessary to provide our Services, fulfill our contractual obligations, comply with legal requirements, protect
important interests, or pursue legitimate business purposes that do not override your rights.

Legal Bases We Rely On

We may rely on the following legal bases to process personal information:

Contract – when processing is necessary to provide the Services or take steps at your request.
Consent – when you voluntarily provide information for a specific purpose; you may withdraw consent at any time.
Legitimate interests – when processing is necessary for our business operations and does not override your rights.
Legal obligation – when we must process data to comply with applicable laws.
Vital interests – when necessary to protect the safety or vital interests of an individual.

Purposes for Which We Process Personal Information

We use personal information to provide customer support, answer inquiries, and resolve issues. Legal basis: based on our legitimate interests (e.g., Service Improvement) Our legitimate interests include service improvement.
We may send newsletters, updates, or promotional content. Users can opt out at any time. Legal basis: with your consent
We analyze usage data to understand how our Services are used and to improve functionality, performance, and user experience. Legal basis: based on our legitimate interests (e.g., Service Improvement) Our legitimate interests include service improvement.
We may process personal information as required by applicable laws, regulations, or legal processes. Legal basis: with your consent

HOW WE PROCESS YOUR INFORMATION

We process personal information in ways that are appropriate to the nature of the data and the purposes for which it is collected.
This includes storing, organizing, using, transmitting, and deleting information when it is no longer required. We apply
principles of data minimization, purpose limitation, and accuracy to ensure that personal information is processed only when
necessary and for clearly defined purposes.

Access to personal information is limited to authorized personnel who require it to perform their job duties and who are bound by
confidentiality obligations. We implement technical and organizational measures designed to protect personal information against
unauthorized access, disclosure, alteration, or misuse. These measures may include access controls, authentication procedures,
logging, encryption in transit and at rest (where appropriate), monitoring, and routine security assessments.

We may combine information collected from different sources when this is necessary to operate the Services or when required to
meet a lawful purpose, such as preventing fraud or maintaining the security of our platform.

We retain personal information only for as long as needed for the purposes described in this Privacy Policy, unless a longer
retention period is required or permitted by law. For more details, see the “How Long We Retain Information” section.

Where required by applicable laws, we provide users with the ability to access, update, delete, restrict, or withdraw consent to
the processing of their personal information. Additional rights may apply depending on your location; see the “Your Rights”
section for more information.

AUTOMATED DECISION-MAKING AND PROFILING

We do not use automated decision-making or profiling in a way that produces legal or similarly significant effects. If this
changes in the future, we will update this Policy and provide any required notices or options.

COOKIES & TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies (such as web beacons, tags, and pixels) to operate our website, understand how it
is used, improve performance, and enhance your experience. These technologies help us maintain platform security, remember your
preferences, prevent errors, and support essential site features.

We may use the following categories of cookies:

Necessary / Essential Cookies: Required for the website to function properly and to provide services explicitly requested by
the user.
Analytics / Performance Cookies: Collect aggregated or behavioral data to help website owners understand usage and improve
performance.

Some cookies are set directly by us (“first-party cookies”), while others may be placed by third-party providers that support our
operations (“third-party cookies”), such as analytics, advertising, or customer support tools.

Where required by law, we display a cookie banner or notice to obtain consent and to give users control over cookie settings.

Necessary/Essential cookies are always active, while Analytics/Performance, Advertising/Marketing, and Functional/Preference
cookies are used only with consent where required by law. You can manage your preferences at any time through the Cookie Banner or
settings page.

HOW WE SHARE YOUR INFORMATION

We do not share personal information with third parties, except when required by law or to protect our legal rights.

INTERNATIONAL TRANSFERS

We do not share personal information with third parties, except when required by law or to protect our legal rights.

HOW LONG WE RETAIN INFORMATION

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal
and regulatory requirements, resolve disputes, and enforce our agreements. We do not keep personal information longer than needed,
and retention periods may vary depending on the type of data and the reason it was collected.

When we no longer have a legitimate business need to process personal information, we will delete or anonymize it. If deletion is
not immediately possible (for example, due to technical constraints or backup systems), we will securely store the information and
isolate it from further processing until deletion is feasible.

We retain personal information for the following periods:

Account information: Until users delete their account.
Profile and preferences: Until users terminate their accounts.
Usage logs and activity data: 1 year.
Cookies and tracking data: 1 year.
Customer support records: 1 year after resolution.
Marketing communications: 90 days after user unsubscribes.

With regard to cookies and tracking data, we retain personal information according to the durations listed in the Cookie Policy.
If no specific retention period applies, we delete or anonymize personal information once it is no longer necessary for the
purpose collected.

HOW WE KEEP YOUR INFORMATION SAFE

We implement appropriate technical and organizational measures to protect personal information from unauthorized access,
disclosure, alteration, or destruction. These measures are designed to provide a level of security appropriate to the risks
associated with processing personal information.

Our safeguards may include:

Encryption of data in transit and at rest
Access controls to limit who can view or handle information
Monitoring and logging of system activity to detect potential issues
Regular security assessments and updates to our systems
Secure data storage and transmission practices
Employee training on data protection and security

While we take reasonable steps to safeguard personal information, no system or method of transmission over the internet is
completely secure. Because of this, we cannot guarantee absolute security.

If we identify a data breach that affects your personal information, we will notify you and any applicable supervisory authorities
when required by law.

YOUR RIGHTS

Individuals have certain rights regarding their personal information. These rights vary depending on where they live, but we aim
to provide clear and accessible options for all users.

Rights for Users in the European Union (EU/EEA)

If you are located in the EU/EEA, you have the following rights under the GDPR:

Right of access: Request a copy of the personal information we hold about you.
Right to correction: Request that we correct inaccurate or incomplete information.
Right to deletion: Request deletion of your personal information in certain circumstances.
Right to restrict processing: Request that we limit how your data is used.
Right to object: Object to processing based on legitimate interests or direct marketing.
Right to data portability: Request your information in a structured, commonly used format.
Right to withdraw consent: Withdraw consent at any time when processing is based on consent.

If you believe your personal data is being processed unlawfully, you have the right to lodge a complaint with a data protection
authority. You can usually contact the authority in your country of residence, place of work, or where you believe a violation has
occurred.

Rights for Users in the United Kingdom

If you are located in the United Kingdom, you have the following rights under the UK GDPR:

Access
Correction
Deletion
Restriction of processing
Objection
Data portability
Withdraw consent

If you believe we are processing your personal information unlawfully, you have the right to lodge a complaint with the
Information Commissioner’s Office (ICO).

Rights for Users in Switzerland

If you are located in Switzerland, you have the following rights under the Swiss Federal Act on Data Protection. This section
supersedes any other possibly divergent or conflicting information contained in this Privacy Policy. Further details regarding the
categories of data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention
period and further information about personal data can be found in the relevant sections within this document.

You may exercise certain rights regarding your personal information within the limits of the Swiss Federal Act on Data Protection,
including the following:

right of access to personal data;
right to object to the processing of your personal data (which also allows you to demand that processing of personal data be
restricted, personal data be deleted or destroyed, specific disclosures of personal data to third parties be prohibited);
right to receive your personal data and have it transferred to another controller (data portability);
right to ask for incorrect personal data to be corrected.

How to exercise these rights

Any requests to exercise user rights can be directed to us through the contact details provided in this document. Such requests
are free of charge and will be answered by us as early as possible, providing you with the information required by law.

Rights for Users in Brazil

This section integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by us
and, if the case may be, our parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as
“we”, “us”, “our”).

This section applies to all users in Brazil (Users are referred to below, simply as “you”, “your”, “yours”), according to the “Lei
Geral de Proteção de Dados“ (the “LGPD“), and for such Users, it supersedes any other possibly divergent or conflicting
information contained in the Privacy Policy. This part of the document uses the term “personal information“ as it is defined in
the LGPD.

The grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

your consent to the relevant processing activities;
your consent to the relevant processing activities;
compliance with a legal or regulatory obligation that lies with us;
the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal
instruments;
studies conducted by research entities, preferably carried out on anonymized personal information;
the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
the exercising of our rights in judicial, administrative or arbitration procedures; protection or physical safety of yourself
or a third party;
the protection of health – in procedures carried out by health entities or professionals;
our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out what categories of your personal information are processed, you can read the relevant section within this document.

Why we process your personal information

To find out why we process your personal information, you can read the relevant sections within this document.

Your Brazilian privacy rights, how to file a request and our response to your requests

Your Brazilian privacy rights

You have the right to:

obtain confirmation of the existence of processing activities on your personal information;
access to your personal information;
have incomplete, inaccurate or outdated personal information rectified;
obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that
is not being processed in compliance with the LGPD;
obtain information on the possibility to provide or deny your consent and the consequences thereof;
obtain information about the third parties with whom we share your personal information;
obtain, upon your express request, the portability of your personal information (except for anonymized information) to another
service or product provider, provided that our commercial and industrial secrets are safeguarded;
obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or
more exceptions provided for in art. 16 of the LGPD apply;
revoke your consent at any time;
lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer
protection bodies;
oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
request clear and adequate information regarding the criteria and procedures used for an automated decision;
request the review of decisions made solely on the basis of the automated processing of your personal information, which affect
your interests, including decisions defining personal, professional, consumer, and credit profiles or aspects of your
personality.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided
in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to
communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests.
In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you
should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify
whether you’d like your personal information to be delivered in electronic or printed form.

You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a
simplified fashion, or if you need a complete disclosure instead.

In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the
origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the
purposes of the processing, while safeguarding our commercial and industrial secrets.

In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to
immediately communicate your request to other parties with whom we have shared your personal information in order to enable such
third parties to also comply with your request – except in cases where such communication is proven impossible or involves
disproportionate effort on our side.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution
bodies, according to the legal means provided by the international law;
when the transfer is necessary to protect your life or physical security or those of a third party;
when the transfer is authorized by the ANPD;
when the transfer results from a commitment undertaken in an international cooperation agreement;
when the transfer is necessary for the execution of a public policy or legal attribution of public service; when the transfer
is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures
related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Rights for Users in the United States

Your privacy rights under US state laws

You may exercise certain rights regarding your personal information. In particular, to the extent permitted by applicable law, you
have:

the right to access personal information: the right to know. You have the right to request that we confirm whether or not we
are processing your personal information. You also have the right to access such personal information;
the right to correct inaccurate personal information. You have the right to request that we correct any inaccurate personal
information we maintain about you;
the right to request the deletion of your personal information. You have the right to request that we delete any of your
personal information;
the right to obtain a copy of your personal information. We will provide your personal information in a portable and usable
format that allows you to transfer data easily to another entity – provided that this is technically feasible;
the right to opt out from the sale of your personal information;
the right to non-discrimination; We will not discriminate against you for exercising your privacy rights.

In addition to the rights listed above common to all users in the United States, as a user residing in Virginia, Colorado,
Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Montana, Indiana,
Kentucky and Rhode Island, you have

the right to opt out of the processing of your personal information for targeted advertising or profiling in furtherance of
decisions that produce legal or similarly significant effects concerning you;
the right to freely give, deny or withdraw your consent for the processing of your sensitive personal information. Please note
that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of
sensitive personal information is necessary for the provision of a product or service specifically requested by you.

In Minnesota, users also have the right to obtain a list of the specific third parties to which the controller has disclosed the
consumer’s personal data.

Note that in some states like Minnesota, in addition to the rights listed above common to all users in the United States, you have
the following specific rights connected to profiling:

the right to question the results of the profiling;
the right to be informed of the reason that the profiling resulted in the decision; if feasible;
the right to be informed of what actions you might have taken to secure a different decision and the actions that you might
take to secure a different decision in the future;
the right to review your personal data used in the profiling;
if inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all users in the United States, as a resident of Utah or Iowa, you have the
following additional rights under the Utah Consumer Privacy Act (UCPA) or the Iowa Consumer Privacy Act (ICPA):

the right to opt out of the processing of your personal information for targeted advertising;
the right to opt out of the processing of your sensitive personal information. Please note that certain exceptions outlined in
the law may apply, such as, but not limited to, when the collection and processing of sensitive personal information is
necessary for the provision of a product or service specifically requested by you.

Additional Rights for California Residents

If you are a resident of California, in addition to the rights listed above common to all users in the United States, you have the
following rights under the CCPA/CPRA:

Right to know the categories of personal information we collect and how it is used.
Right to access specific pieces of information we hold.
Right to deletion of your personal information, with certain exceptions.
Right to correct inaccurate information.
Right to opt out of the sale or sharing of personal information.
Right to limit the use and disclosure of sensitive personal information.
Right to non-discrimination for exercising your rights.

We do not use sensitive personal information for inferring characteristics or for purposes other than those that are reasonably
necessary to provide the requested services. Sensitive personal information is not sold or shared for cross-context behavioral
advertising.

In addition, California residents may exercise their rights through the following clearly-labeled links provided on this website:

“Do Not Sell or Share My Personal Information”“Limit the Use of My Sensitive Personal Information”

These links allow users to opt out of cross-context behavioral advertising, targeted advertising, or the use of sensitive personal
information.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request according to the details in the “How To Contact Us”
section of this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your
identity and therefore confirm the personal information in our possession relates to you. You are not required to create an
account with us to submit your request. We will use any personal information collected from you in connection with the
verification of your request solely for verification and shall not further disclose the personal information, retain it longer
than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of sale or sharing and targeted advertising you can also
use the cookie banner, consent management options or privacy choices link provided on this website.

If you want to submit requests to opt out of sale or sharing and targeted advertising activities via a user-enabled global privacy
control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a
technically frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we
need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial. Afterwards, you may at your option then contact
the relevant regulatory authority to submit a complaint.

We will not charge a fee to process or respond to your request unless such request is manifestly unfounded or unduly excessive and
in all other cases where it is permitted by the applicable law. In such cases, at our discretion, we may charge a reasonable fee
or refuse to act on the request. In either case, we will communicate our choices to you and explain the reasons behind them.

Rights for All Users

Regardless of where you live, we provide all users with the ability to:

Request access to the personal information we hold.
Request corrections or updates.
Request deletion where appropriate.
Withdraw consent where processing is based on consent.

You can submit a request to exercise your rights by contacting us using the details provided in the “How To Contact Us” section.
Users in jurisdictions requiring consent for cookies and tracking (e.g., EU/EEA) may withdraw consent at any time via the cookie
banner, privacy settings page, or by contacting us. Withdrawal does not affect the lawfulness of processing performed before
withdrawal. We may need to verify your identity before processing your request.

CHILDREN’S PRIVACY

Our Services are not intended for children under 16, and we do not knowingly collect personal information from individuals under
this age. If we become aware that we have collected personal information from a child under 16, we will delete it as soon as
reasonably possible.

If you believe that a child has provided personal information to us, please contact us using the details in the “How To Contact
Us” section.

UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, operational needs, or applicable laws.
When we make changes, we will update the “Last Updated” date at the top of this Policy.

We use the following method(s) to notify users of significant changes to this Privacy Policy:

Posting a notice on our website

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal
information.

HOW TO CONTACT US

If you have questions, concerns, or requests related to this Privacy Policy or our handling of personal information, you may
contact us using the details below:

Vistera Partners
contact@visterapartners.com
58 Route de Lodève
34080 Montpellier
FRANCE