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Privacy Policy

Privacy Notice

Last Updated and Effective December 2025

Introduction

Your privacy is very important to us. This notice (this “Privacy Notice”) is provided by Diameter Capital Partners LP (“we” or “us”), and sets forth our policies for the collection, use, storage, sharing, disclosure (collectively, “processing”) and protection of personal information relating to current, prospective and former investors in the Funds, as applicable.

References to “you” or an “investor” in this Privacy Notice mean any investor who is an individual, or any individual connected with an investor who is a legal person, as applicable.

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”). The Fund and the Adviser are considered to be data controllers in respect of any personal information we hold about you for the purposes of certain Data Protection Laws. This means that the Fund and the Adviser (alone or jointly, as applicable) determines the purposes and the means of the processing of your personal information.

Please contact our Head of Investor Relations at [email protected] or call (833) 891-0802 with any questions about this Privacy Notice or requests with regards to the personal information we hold.

Please note that the Administrator, the Distributor, the Custodian and other service providers work under a range of professional and legal obligations that require them to process personal information (e.g., anti-money laundering legislation). In order to meet the requirements of such obligations, they, from time to time, would not be acting on our instructions but instead in accordance with their own respective professional or legal obligations and therefore as data controllers in their own right with respect to such processing. For more specific information or requests in relation to the processing of personal information by the Administrator, the Distributor, the Custodian or any other service provider of the Fund, you may also contact the relevant service provider directly at the address specified in this registration statement or by visiting their websites.

The Types of Personal Information We May Collect

“Personal information” means any information relating to an identifiable individual who can be identified from such information, either alone or in combination with other information, including the terms “nonpublic personal information” as defined under the Gramm-Leach-Bliley Act (“GLBA”) or “personal information,” “personal data,” or similar terms as defined by applicable Data Protection Laws. The categories of personal information we may collect include names, residential or business addresses, or other contact details, signature, nationality, tax identification or passport number, social security number, date of birth, place of birth, photographs, copies of identification documents, bank account details, information about assets or net worth, credit history, information on investment activities, or other personal information, such as certain special categories of personal information (including, where relevant, information on political affiliations, ethnic origin, and personal information relating to criminal convictions and offences), as specified under the applicable Data Protection Laws, that may be contained in your relevant materials or documents obtained through background searches.

How We Collect Personal Information

We may collect personal information about you through: (i) information provided directly to us by you, or another person on your behalf; (ii) information that we obtain in relation to any transactions between you and us; and (iii) the monitoring of telephone conversations with you.

We also may receive your personal information from third parties or other sources, such as our affiliates, the Administrator, publicly accessible databases or registers, tax authorities, governmental agencies and supervisory authorities, credit agencies and other background check providers, transaction counterparties, service providers, law enforcement, other investors, fraud prevention and detection agencies, or other publicly accessible sources, such as the Internet.

How We May Use Personal Information

We will use one of the lawful bases under the applicable Data Protection Laws to process your personal information. Such grounds include, for example, circumstances where:

  • processing is necessary to perform our obligations under the Declaration of Trust, Bylaws, Investment Advisory Agreement and Services Agreement or any other contract we have with you;
  • we are required to comply with a legal or regulatory obligation applicable to us;
  • or processing is necessary for the purpose of our or a third party's legitimate interests.

Specific purposes for which we may use your personal information as described above, and the lawful bases we rely on to do so, are set out in the table below.

Lawful Basis Purposes of Use
Where it is necessary to perform our contract with you or to take steps at your request to enter into the contract
  • To consider and make decisions about your subscription to the Fund.
  • To admit you to the Fund (including undertaking client and investor due diligence).
  • To administer and manage your investment, including to report on the performance and governance of the Funds; to make payments or distributions; to provide requested investment services and related support services; and to perform any other obligations in or relating to your subscription.
  • To enter into, administer or perform any other contract or agreement we have with you.
Where it is necessary for compliance with a legal or regulatory obligation to which we are subject
  • To perform appropriate client and investor due diligence in accordance with our legal obligations.
  • To ensure the protection of personal information and other information, property and assets in our possession.
  • To cooperate with competent regulators and other public authorities, including by responding to their requests for information, undertaking internal investigations, and complying with our reporting, filing and other regulatory obligations.
  • To comply with our legal and regulatory record-keeping requirements.
  • For the prevention and detection of fraud and other unlawful acts.
  • For compliance with our anti-money laundering, tax reporting and sanctions obligations.
Where it is necessary for the purposes of our or another party's legitimate business interests, except where these are overridden by your interests, rights or freedoms
  • To comply with any other obligations to which we are subject under applicable rules and laws.
  • To provide and improve our services and business offerings.
  • To manage and administer the Fund and related accounts, and to open, maintain or close accounts in connection with an investment.
  • To manage financing arrangements.
  • To market our products and services.
  • To ensure compliance with our internal policies and procedures.
  • For IT system problem diagnosis, security and business continuity purposes.
  • To manage operational, commercial, financial and investment risks.
  • To prepare and maintain books, reports and records and ensure appropriate governance of the Adviser.
  • To manage insurances, complaints, potential and actual claims.
  • To verify information you have provided and perform appropriate client and investor due diligence.
  • To carry out surveys.
  • For the prevention and detection of fraud and other unlawful acts.
  • To provide support and communicate with you.
  • To assist transaction counterparties in complying with their regulatory and legal obligations.
  • To exercise, establish, protect or defend legal rights, property, and safety, including to enforce our agreements and policies and to respond to suspected illegal activity and threats to our systems and services.
  • To provide information to a potential purchaser of all or a part of our business.
  • For any other legitimate purpose communicated to you.
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Consent

Subject to local laws, we typically do not rely on consent in order to process your personal information as described above. If we do ask you for consent, we will provide you with details of the activities we are requesting consent for.

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