General Privacy Notice

Last updated: September 10, 2026

Introduction

Bayview Fund Management LLC and its affiliates (the “Investment Manager”) and the various investment funds and accounts sponsored by the Investment Manager (such investment funds and accounts, the “Bayview Funds,” and together with the Investment Manager, “Bayview,” “we” or “us”), respect privacy and are committed to protecting personal information.

This General Privacy Notice (“Privacy Notice”) explains how we collect, use, disclose, and otherwise process personal information in connection with:

  1. visitors to our website and other online properties;
  2. business contacts, vendors, service providers, counterparties, consultants, advisers, and other professional contacts; and
  3. individuals who communicate with us or attend our events.

Certain parts of this Privacy Notice apply only to particular individuals, jurisdictions, products, services, or relationships. For example, the “Supplemental Information for California Consumers” section applies to California residents. The “Supplemental Information for the United Kingdom, European Economic Area, Switzerland, and other International Jurisdictions” section applies to individuals in the European Economic Area, the United Kingdom, Switzerland, and other jurisdictions with similar Data Protection Laws.

Please note that this Privacy Notice does not apply to information that we collect in the context of providing financial services, such as investment advice, (e.g., to evaluate and establish investor, fund, account, and other business relationships, to conduct fund administration activities, to conduct investment and asset management and related business activities, and to perform regulatory compliance activities), which is instead described in our Investor Privacy Notice. Please contact us at compliance@bayview.com to request a copy.

Table of Contents

  • Who to Contact About This Privacy Notice
  • The Categories of Personal Data We May Hold
  • How We Collect Personal Data
  • How We May Use Personal Information
  • Cookies and Similar Technologies
  • How We May Share Personal Data
  • Retention Periods and Security Measures
  • Children
  • Questions/Changes
  • External Links
  • Supplemental Information for the United Kingdom, European Economic Area, Switzerland, and other International Jurisdictions
  • Supplemental Information for California Consumers

Who to Contact About This Privacy Notice

This Privacy Notice is being provided in accordance with the applicable requirements under the privacy and data protection laws that apply in the jurisdictions where we operate (collectively, the “Data Protection Laws”).

Bayview is considered to be a data controller in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that Bayview determines the purposes and the means of the processing of your personal information.

To contact us regarding this notice or the exercise of any privacy rights or complaints, you may contact us at:

Bayview Fund Management LLC
4425 Ponce de Leon Boulevard
Coral Gables, Florida 33146
Phone: 305-854-8880
Email: compliance@bayview.com

The Categories of Personal Data We May Hold

Depending on your relationship with us, we may collect the following categories of personal information:

Identifiers and contact information, such as name, business or residential address, email address, telephone number, account identifiers, signature, government identification numbers, passport number, driver’s license number, tax identification number, and similar identifiers.

Professional and business information, such as employer, title, business role, professional credentials, board or officer status, business contact details, and communications with us.

Internet, network, device, and cookie information, such as IP address, device identifiers, cookie identifiers, browser type, operating system, referring URL, pages viewed, time spent on pages, links clicked, approximate location derived from IP address, and interactions with our website, emails, advertisements, or digital content.

Communications information, such as records of emails, calls, meeting notes, inquiries, requests, feedback, and other communications with us.

Sensitive personal information, including application portal password and username for prospective employees and job applicants.

How We Collect Personal Data

We may collect personal information from:

  1. you directly;
  2. your representatives, advisers, agents, employer, affiliated entities, or other persons acting on your behalf;
  3. Bayview affiliates and related businesses;
  4. public sources, including public registers, corporate records, court records, professional directories, websites, and media sources; and
  5. website technologies, including cookies, pixels, tags, server logs, analytics tools, and similar technologies.

How We May Use Personal Information

We may use personal information for the following purposes:

  1. to communicate with you, respond to inquiries, provide information about Bayview, and send business, investor, marketing, or event communications, subject to applicable opt-out rights;
  2. to operate, secure, maintain, improve, and analyze our website, systems, network, facilities, and business operations;
  3. to use cookies and similar technologies as described in the “Cookies and Similar Technologies” section;
  4. to protect the rights, property, safety, and security of Bayview, our affiliates, funds, clients, investors, personnel, counterparties, service providers, website visitors, and others;
  5. to comply with applicable law, regulation, subpoena, court order, legal process, regulatory request, examination, investigation, or supervisory authority requirement; and
  6. to support corporate transactions, reorganizations, financing, audits, reporting, dispute resolution, litigation, enforcement of agreements, and other legitimate business purposes.

Cookies and Similar Technologies

We may use cookies and similar technologies, such as pixels, tags, scripts, SDKs, local storage, and server logs, to operate our website, remember your preferences, understand how visitors use our website, improve our content, and maintain security.

You may be able to manage certain cookie choices through our Cookie Preferences center. Some cookies are required for the website to function and cannot be disabled through our Cookie Preferences center. You may also be able to control cookies through your browser settings. If you block or delete cookies, some website features may not function properly.

Required Cookies

Required Cookies are necessary for our website to operate, maintain security, load pages, remember your privacy choices, balance network traffic, and provide functionality you request. These cookies do not require consent where they are strictly necessary to provide the website or service you request.

Examples may include cookies used to:

  1. remember your cookie preferences;
  2. maintain website security;
  3. prevent fraud or abuse;
  4. enable page navigation;
  5. balance website traffic; and
  6. support accessibility or core website functionality.

Functional Cookies

Functional Cookies help us provide enhanced functionality and remember choices you make, such as region, language, display preferences, or similar settings. If you do not allow Functional Cookies, some features may not work as intended.

These cookies may also help us understand how visitors interact with our website, including which pages are visited, how long visitors remain on pages, and how visitors navigate the website. We use this information to measure performance, troubleshoot issues, and improve our website.

Advertising Cookies

Advertising Cookies may be set by us or by third-party advertising, analytics, or social media partners. These cookies may be used to measure advertising effectiveness, understand interactions with our content, build or infer interests, limit ad frequency, or deliver advertising that may be more relevant to you on other websites or services.

Where required by law, we will not set non-essential cookies, including Functional or Advertising Cookies, unless you consent. You may withdraw or change your consent at any time through the Cookie Preferences center.

How We May Share Personal Data

We may disclose personal information to the following categories of recipients:

  1. Bayview affiliates and related entities;
  2. advertising, analytics, and digital technology providers, subject to applicable cookie choices and opt-out rights;
  3. persons or entities to whom you direct or authorize us to disclose information; and
  4. successors or potential successors in connection with a merger, acquisition, reorganization, financing, transfer, sale, or other corporate transaction.

We do not sell personal information for money. However, depending on the cookies and similar technologies used on our website, we may disclose internet, network, device, cookie, and interaction information to advertising, analytics, or social media partners in a way that may be considered a “sale,” “sharing,” or processing for “targeted advertising” under certain U.S. state privacy laws.

As a reminder, where required by applicable law, you may opt out of such activities by using our Cookie Preferences center or a legally recognized opt-out preference signal. We do not disclose personal information except as permitted or required by applicable law, contract, regulation, legal process, or your instructions.

Retention Periods and Security Measures

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Notice, including to maintain our relationship with you, provide services, administer investments, operate our business, maintain security, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and establish, exercise, or defend legal claims.

Retention periods vary depending on the type of information, the purpose for which it is processed, the jurisdiction, and applicable legal, regulatory, tax, accounting, and recordkeeping requirements. For example, investor and compliance records may be retained for the duration of the relevant relationship and for a period thereafter consistent with applicable investment adviser, fund, anti-money laundering, tax, corporate, litigation, and regulatory recordkeeping obligations.

When personal information is no longer needed, we will delete, de-identify, aggregate, or otherwise dispose of it in accordance with applicable law and our records management practices.

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, acquisition, use, disclosure, alteration, or destruction. These safeguards may include access controls, authentication controls, secure systems, vendor oversight, employee training, incident response procedures, and physical security measures.

No system or transmission of information is completely secure. We maintain procedures designed to identify, assess, respond to, and, where required, provide notification regarding certain incidents involving personal information in accordance with applicable law, including applicable financial privacy and data protection requirements.

Children

Our website and services are not directed to children under 16, and we do not knowingly collect personal information from children under 16. If you believe a child has provided personal information to us, please contact us using the contact information above.

Questions/Changes

We may update this Privacy Notice from time to time. The “Last Updated” date above indicates when this Privacy Notice was last revised. Any changes will become effective when we post the revised Privacy Notice, unless otherwise stated.

External Links

Our website may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.

Supplemental Information for the United Kingdom, European Economic Area, Switzerland, and other International Jurisdictions

International transfers

Bayview operates globally, including through locations or relationships in the United States, the United Kingdom, the European Economic Area, Switzerland, and other jurisdictions including, but not limited to, Hong Kong. We may transfer personal information to, or process personal information in, countries that may not provide the same level of data protection as the country where you are located.

Where required by applicable law, we use appropriate safeguards for cross-border transfers, which may include contractual protections, standard contractual clauses or similar transfer mechanisms, adequacy decisions, regulatory approvals, or other safeguards permitted by law. You may contact us for more information about the safeguards we use for international transfers, where applicable.

Data Controller: Unless otherwise specified the Investment Manager is responsible for the processing of your personal data as the controller.

Legal Bases for Processing: We process personal data in reliance on the following legal bases:

Processing Purposes Legal Bases
To deliver our services
  • Performance of a contract to which you are a party or to take steps at your request prior to entering a contract.
  • Legitimate interests as set out in the “How We May Use Personal Information” section above.
  • Your consent, when appropriate.
For recruiting, position advertising, talent management, and employment purposes
  • Performance of a contract to which you are a party or to take steps at your request prior to entering a contract.
  • Legitimate interests as set out in the “How We May Use Personal Information” section above.
  • Compliance with a legal or statutory obligation to which we are subject.
  • Your consent, when appropriate.
To market to you and send you information
  • Legitimate interests as set out in the “How We May Use Personal Information” section above.
  • Your consent, when appropriate.
To contact you when necessary
  • Legitimate interests as set out in the “How We May Use Personal Information” section above.
  • Compliance with a legal or statutory obligation to which we are subject.
  • Your consent, when appropriate.
For our internal business purposes
  • Performance of a contract to which you are a party or to take steps at your request prior to entering a contract.
  • Compliance with a legal or statutory obligation to which we are subject.
  • Legitimate interests as set out in the “How We May Use Personal Information” section above.
  • Your consent, when appropriate.
For our internal research and improvement purposes
  • Legitimate interests as set out in the “How We May Use Personal Information” section above.
  • Your consent, when appropriate.
To protect the security or integrity of our business
  • Performance of a contract to which you are a party or to take steps at your request prior to entering a contract.
  • Compliance with a legal or statutory obligation to which we are subject.
  • Legitimate interests as set out in the “How We May Use Personal Information” section above.
  • Establishment, exercise, or defense of legal claims.
  • Protection of vital interests.
  • Your consent, when appropriate.
For legal reasons
  • Performance of a contract to which you are a party or to take steps at your request prior to entering a contract.
  • Compliance with a legal or statutory obligation to which we are subject.
  • Legitimate interests as set out in the “How We May Use Personal Information” section above.
  • Establishment, exercise, or defense of legal claims.
  • Protection of vital interests.
  • Your consent, when appropriate.
In connection with a corporate transaction
  • Legitimate interests as set out in the “How We May Use Personal Information” section above.

You are not required to provide us with your Personal Information. However, if you elect not to provide your Personal Information, we may be unable to provide you with some or all of our services.

Your Data Protection Rights. You may exercise certain rights regarding your personal information.

  • Right to Access. You may have the right to obtain confirmation from us whether we are processing your personal information and a copy of your personal information.
  • Right to Data Portability. You may have the right to your personal information be provided to you in a structured, commonly used, and machine-readable format.
  • Right to Rectification. You may have the right to request that we rectify inaccurate personal information and complete incomplete data.
  • Right to Objection. You may have the right to object to the processing of your personal information in certain cases.
  • Right to Restrict Processing. You may request that we restrict the processing of your personal information in certain cases.
  • Right to Erasure. You may request that we erase your personal information in certain cases.
  • Right to Refuse or Withdraw Consent. In case we ask for your consent to process your personal information, you are free to refuse to give it. If you have given your consent, you may withdraw it at any time without any adverse consequences. The withdrawal of your consent will not affect the lawfulness of any processing of your personal information that occurred prior to your withdrawal.
  • Right to Not Be Subject to Automated Decision-making. You have the right not to be subject to a decision based solely on automated processing and to be given more information about why any such decision was made.

You may exercise these rights by contacting us using the information described under the “Who to Contact About This Privacy Notice” section above. If you are not satisfied with our response, you have the right to lodge a complaint with a supervisory authority in the country where you reside or where the conduct that is the subject of the complaint occurred.

Data Protection Officer. You may contact our Compliance Department at compliance@bayview.com.

Supplemental Information for California Consumers

This notice contains additional disclosures required by the California Consumer Privacy Act (“CCPA”). Terms defined in the CCPA have the same meaning when used in this notice. This notice is only relevant to California residents (“consumers” or “you”) and supplements the other sections of this Privacy Notice.

Information We Collect. In the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information:

Category Examples Collected Disclosed for Business Purpose
A. Identifiers A real name, alias, email address, postal address, Internet Protocol (IP) address, account name, Social Security number, driver’s license number, passport number, or other similar personal identifiers. YES YES
B. Other personal information categories, as listed in the California Customer Records Statute A signature, physical characteristics or description, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. YES YES
C. Protected classification characteristics under California or federal law Age (40 years or older), race, citizenship, marital status, sex, veteran or military status. NO NO
D. Commercial information Account activity, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. NO NO
E. Biometric information Fingerprints, faceprints, voiceprints, and iris or retina scans. NO NO
F. Internet or other similar network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. YES YES
G. Geolocation data Physical location or movements. YES YES
H. Sensory data Audio, electronic, visual, thermal, olfactory, or similar information. NO NO
I. Professional or employment-related information Current or past job history or performance evaluations. YES YES
J. Non-public education information (per the Family Educational Rights and Privacy Act) Education records directly related to a student maintained by an educational institution or party acting on its behalf. NO NO
K. Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. NO NO
L. Sensitive personal information A consumer’s SS, driver’s license, state ID card, or passport number; account log-in or debit/credit card number in combination with any access code, password, or account credentials; precise geolocation; racial/ethnic origin, religious/philosophical beliefs, or union membership; contents of mail, email, and text messages; genetic data; biometric information; health information; or sex life or sexual orientation. YES YES

We do not knowingly collect, solicit or sell personal information from anyone under the age of 16 without the prior consent of a parent or guardian.

Purpose for Collection and Use of Personal Information. We may collect or use personal information for one or more of the following purposes:

  • Providing you with information about our products and services;
  • Providing you with performance and other updates;
  • One or more of the following business purposes:
    • Performing services (for us or our service provider or contractor) such as account servicing, processing orders and payments, and analytics;
    • Legal compliance;
    • Detecting and protecting against security incidents, fraud, and illegal activity;
    • Debugging;
    • Internal research for technological improvement;
    • Internal operations;
    • Activities to maintain and improve our services; and
    • Short-term, transient use, such that the personal information is not disclosed to another third party and is not used to build a profile about you.

Sharing Personal Information. We may disclose personal information to:

  • Service providers, including but not limited to: administrators, lenders, banks, brokers, auditors, law firms, consultants, placement agents, credit bureaus;
  • Affiliates;
  • Business partners;
  • Legal or government regulatory authorities as required by applicable law;
  • In connection with a potential business transfer; and
  • Third parties to whom you or your agents authorize us to disclose such information in connection with services we provide to you.

In the past 12 months, we have not sold personal information to third parties.

Cookies and Similar Technology. Certain Advertising Cookies and similar technologies may constitute “sharing” of personal information for cross-context behavioral advertising. You may opt out of this sharing by using the “Cookie Preferences” to make your “Do Not Sell or Share My Personal Information” opt-out election, as applicable. We also process legally recognized opt-out preference signals, such as Global Privacy Control, as required by applicable law.

Length of Time. Please refer to the “Retention Periods and Security Measures” section above.

Rights of California Consumers. The CCPA provides a California consumer the following rights, subject to certain exceptions and limitations:

  • The right to request: (a) the categories and specific pieces of personal information we collect about you; (b) the categories of sources from which we collect your personal information; (c) our business or commercial purposes for collecting, selling or sharing your personal information; (d) the categories of personal information disclosed for a business purpose and the categories of persons to whom it was disclosed; (e) the categories of your personal information (if any) that we have either sold, shared, or disclosed.
  • The right to request that we delete your personal information, subject to certain exceptions.
  • The right to opt out of our sale(s) or sharing for the purposes of cross-context behavioral advertising of your personal information.
  • The right to request we correct any inaccurate personal information maintained about you.
  • The right to limit our use of your sensitive personal information to only use that is necessary to perform the services expected or provide the goods reasonably expected.
  • The right not to receive discriminatory treatment for exercising your CCPA rights.

You may submit requests relating to your exercise of CCPA rights to us via:

By Telephone: 305-854-8880; or
By Email: compliance@bayview.com

You may only make a verifiable request for access or data portability twice within a 12-month period. All verifiable requests must provide (1) enough information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and (2) sufficient detail that allows us to properly evaluate and respond to it.

We endeavor to respond to a verifiable request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.

You may also exercise your right to opt out through a browser setting or extension to communicate your preference to automatically opt out of selling and sharing of your personal information. We honor your right to opt out of the sale and sharing of your personal information as signaled by a universal opt-out signal or Global Privacy Control (“GPC”). To enable GPC, you can visit the Global Privacy Control page at https://globalprivacycontrol.org. If you download a supported browser or extension and exercise your privacy rights with GPC, we will turn off certain third-party cookies on the applicable site after the site detects a GPC signal.

Shine the Light

California residents may request that we provide certain information regarding our disclosure of your personal information to third parties for their direct marketing purposes. You can opt out of these disclosures by emailing compliance@bayview.com with the subject line “CA Shine the Light”.