EU - U.S. PRIVACY SHIELD POLICY

NetRoadshow, Inc. and its group of affiliated companies, Financial Software and Services, Inc., Secure Share Network, LLC, and Apparity, LLC (collectively "NetRoadshow") value the trust and confidence of their customers, employees, and business partners and respect individual privacy. NetRoadshow strives to uphold the highest ethical standards in all of its business practices, and collects, uses, and discloses personal information in a manner consistent with the laws of the countries in which it does business. Capitalized terms not defined elsewhere in this Policy are defined in Section 13.

1. BACKGROUND

NetRoadshow provides global business to business services to investment banks, issuers of debt and equity securities, and corporations. Specifically, NetRoadshow, Inc., provides Electronic Roadshow Services, Wall Crossing Services, ResearchFN Services, and Document Delivery Services to investment banks and their issuer clients. Secure Share Network, LLC, provides Data Room Services and SEC Rule 17g-5 Services to issuers of debt and equity securities. Roadshow Services, Document Delivery Services, Wall Crossing Services, and 17g-5 Services are provided to assist NetRoadshow customers and business partners comply with certain provisions of the Securities Act of 1933 and the regulations promulgated thereunder and the Securities and Exchange Act of 1934 and the regulations promulgated thereunder. Apparity, LLC provides Spreadsheet Services. Roadshow Services, Document Delivery Services, Wall Crossing Services, Data Room Services, 17g-5 Services, and Spreadsheet Services are hereinafter collectively referred to as "Services".

The Services provided to NetRoadshow's customers may include the transfer to NetRoadshow of Personal Data of residents of the European Economic Area that is collected by, or transferred to, NetRoadshow's customers and business partners ("Customer Personal Data"). NetRoadshow's customers and business partners rely on Supplemental Principle 4 to collect and process Personal Data of residents of the European Economic Area ("EEA") without the knowledge or consent of the individual.

When NetRoadshow receives Customer Personal Data, NetRoadshow is acting as an agent for its customer or business partner and does not provide notice to individuals regarding the collection and use of their Personal Data. NetRoadshow's customers or business partners retain responsibility for providing notice, if and to the extent such notice is necessary under applicable EU law.

This Policy applies to the processing of (a) Personal Data that NetRoadshow collects through our websites www.netroadshow.com; www.structuredfn.com; www.reasearchfn.com; wallcrossing.netroadshow.com; www.om.netroadshow.com; and www.apparity.com (each a "NRS Website") from registered users of the Services offered by NetRoadshow that reside in the EEA ("Registered Users") and (b) Customer Personal Data transferred to NetRoadshow by its customers for specialized data processing services.

2. COMPLIANCE WITH EU-U.S. PRIVACY SHIELD PRINCIPLES

The European Community has established a data protection regime which applies to the EEA and restricts companies in the EEA in transferring Personal Data about individuals in the EEA to the United States, unless there is "adequate protection" for such personal data when it is received in the United States.

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles (the "EU-U.S. Privacy Shield Framework") to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EU to the United States. Compliance with the EU-U.S. Privacy Shield Framework with respect to Personal Data about individuals in the EEA provides adequate protection for Personal Data transferred from the EEA to the United States.

NetRoadshow complies with the EU-U.S. Privacy Shield Framework in NetRoadshow's collection, use, and retention of Personal Data collected from Registered Users and Customer Personal Data. In keeping with EU-U.S. Privacy Sheild principles, NetRoadshow has self-certified adherence to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.

This EU-U.S. Privacy Shield Policy (the "Policy") sets forth the privacy principles that NetRoadshow follows with respect to transfers of personal information from the EEA to the United States. If there is any conflict between the Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern the rights and obligations of NetRoadshow.

To learn more about the EU-U.S. Privacy Shield program, and to view NetRoadshow, Inc.'s certification, please visit www.privacyshield.gov/welcome.

3. RESPONSIBILITIES AND MANAGEMENT

NetRoadshow has designated its Chief Privacy Officer to oversee its information security program, including its compliance with the EU Privacy Shield program. The Chief Privacy Officer reviews and approve any material changes to this program as necessary. You may direct questions, concerns, or comments regarding this Policy to chiefprivacyofficer@netroadshow.com.

NetRoadshow will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects from Registered Users and Customer Personal Information transferred to NetRoadshow by our customers.

All of our employees and consultants have entered into agreements requiring that they maintain the confidentiality of Customer Personal Data.

All NetRoadshow employees and consultants who handle Personal Data from the EEA are required to comply with the Privacy Shield Principles stated in this Policy. Any employee or consultant that NetRoadshow determines is in violation of these policies will be subject to discipline, up to and including termination of employment and/or criminal prosecution.

4. BUSINESS PURPOSES FOR THE COLLECTION AND USE OF PERSONAL DATA

NetRoadshow primarily receives business-related information from the EEA, this information consists of (a) information about Registered Users that reside in the EEA who access Services by means of a NRS Website, (b) user generated content input into our Services by Registered Users, and (c) Customer Personal Data transferred to NetRoadshow by NetRoadshow's customers and business partners.

Registered Users are individuals that represent businesses with whom NetRoadshow or NetRoadshow's customers and business partners have a business relationship. NetRoadshow collects identifying information from Registered Users including names, addresses, work phone numbers, work email addresses, IP address, browser type, etc. The information that NetRoadshow collects from Registered Users is used for validation of identity, managing transactions, reporting, other operations related to providing the Services to NetRoadshow's customers and business partners. NetRoadshow only uses the Personal Data of Registered Users for providing the Services and communicating with Registered Users in response to support questions, and other matters related to the Services. NetRoadshow does not use Personal Data of Registered Users for marketing or promotional purposes.

In connection with Document Delivery Services and Data Room Services, Registered Users have the ability to add comments and annotations to documents which are stored and processed by NetRoadshow, and up load files and due diligence information which could include Personal Data. NetRoadshow has no control over the Personal Data which NetRoadshow customers and business partners upload into the Services. In its capacity as a service provider, NetRoadshow receives, stores, and processes Customer Personal Data and is acting as a data processor on behalf of, and subject to, contractual agreements between NetRoadshow and its customers. NetRoadshow does not use Customer Personal Data, for any other purpose other than the purposes for which NetRoadshow's customers provide such information to NetRoadshow.

NetRoadshow does not review, share, distribute, print, or reference the Personal Data of Registered Users or Customer Personal Data except when requested to provide assistance in resolving a technical problem or support issue, or as may be required by law.

When Registered Users access Services NetRoadshow logs certain information. NetRoadshow uses this information to diagnose technical problems, administer the Services and NRS Websites, and prepare reports for NetRoadshow Customers. NetRoadshow may also track and analyze non-identifying and aggregate usage and volume statistical information from Registered Users, and we may provide such information to third parties that assist us for these purposes. NetRoadshow may collect analytics data, or use third-party analytics tools and services, to measure traffic and usage of the Services. These tools collect information sent by the browser or mobile device or a Registered User, including the pages visited and other information that assists NetRoadshow in administering and improving the Services.

5. HOW WE PROTECT YOUR INFORMATION

NetRoadshow uses commercially reasonable and appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of Personal Data of Registered Users and Customer Personal Data. All Personal Data of Registered Users and Customer Personal Data collected, stored, and processed by NetRoadshow for Wall Crossing Services, ResearchFN Services, Document Delivery Services, Data Room Services, and Rule 17g-5 Services is stored and processed in encrypted computer databases and servers. NetRoadshow uses Secure Socket Layer (SSL) technology to protect Personal Data of Registered Users and Customer Personal Data using both server authentication and data encryption during transmission.

6. DISCLOSURE OF PERSONAL INFORMATION

Except as otherwise stated in this Policy, NetRoadshow does not disclose or share Personal Data of Registered Users or Customer Personal Data with third parties. NetRoadshow does not sell, rent, or otherwise provide Personal Data of Registered Users or Customer Personal Data to any third parties for marketing or promotional purposes.

In the event NetRoadshow undergoes a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, Personal Data of Registered Users or Customer Personal Data would likely be among the assets transferred.

NetRoadshow retains the right to disclose Personal Data of Registered Users and Customer Personal Data as required by law, such as to comply with a subpoena or similar legal process to the extent provided in the agreements with NetRoadshow and its customers or to respond to a government request. NetRoadshow may also may be required to disclose Personal Data in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

The United States Federal Trade Commission has jurisdiction to investigate and to bring enforcement actions for claims against NetRoadshow regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy, including the EU-US Privacy Shield.

7. ACCOUNTABILITY OF ONWARD TRANSFER

NetRoadshow does not transfer Personal Data of Registered Users or Customer Personal Data to unrelated third parties, unless directed by a NetRoadshow customer, or in certain limited or exceptional circumstances in accordance with the EU-U.S. Privacy Shield Framework. For example, such circumstances would include disclosures of Personal Data of Registered Users or Customer Personal Data required by law or legal process, or disclosures made in the vital interest of an identifiable person such as those involving life, health, or safety. In addition, NetRoadshow in cases of onward transfer to third parties requested by our customers, NetRoadshow will not transfer any Personal Data to a third-party without first ensuring that such party is either subject to the EU-U.S. Privacy Shield Agreement, subject to similar laws providing an adequate and equivalent level of privacy protection, or will enter into a written agreement with the third party requiring them to provide protections consistent with the EU-U.S. Privacy Shield Framework and NetRoadshow's Policy.

8. ANNUAL ASSESSMENT

NetRoadshow assures compliance with this Policy and the EU-U.S. Privacy Shield Framework by utilizing the self-assessment approach as specified by the U.S. Department of Commerce. The assessment is conducted on an annual basis to ensure that all of NetRoadshow's relevant privacy practices are being followed in conformance with this Policy and the EU-U.S. Privacy Shield Framework.

9. APPLICABILITY

NetRoadshow is subject to the investigatory and enforcement powers of the Federal Trade Commission ("FTC").

NetRoadshow also assures compliance with this Policy and the EU-U.S. Privacy Shield Framework by fully investigating and attempting to resolve any complaint or dispute regarding the use and disclosure of personal data in violation of this Policy.

10. POLICY UPDATES

This Policy may occasionally be updated. When material updates are made, the date of the last revision will be reflected at the end of the page. This page may be bookmarked to facilitate periodic review of this Policy and to note recent updates. Neither this Policy nor any update to it will affect or modify any contract between NetRoadshow and its customers.

11. ACCESS, REVIEW & UPDATE

If you are a Registered User, you may request access to, and the opportunity to update, correct, or delete, your Personal Data by contacting our Chief Privacy Officer, for assistance.

If you are a resident of the EEA about whom NetRoadshow holds Personal Data on behalf of one of our customers or business partners, you may request access to, and the opportunity to update, correct, or delete, such Personal Data from our customer. You may also contact our Chief Privacy Officer, for assistance, however, NetRoadshow does not have any authority to permit you to access, update, correct, or delete, your Personal Data, but we are able to assist you to contact our customer who may have that power.

12. EU-U.S. PRIVACY SHIELD CONTACT

In compliance with the EU-U.S. Privacy Shield, NetRoadshow, Inc. commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact NetRoadshow's Chief Privacy Officer, e-mail: chiefprivacyofficer@netroadshow.com. Or you may call us at: +1 (404) 400-7392 NetRoadshow will promptly investigate and attempt to resolve complaints and disputes in a manner that complies with the principles described in this Policy.

If you are not satisfied with our response, or if contacting us does not resolve your complaint, you can contact, JAMS, an independent dispute resolution provider located in the United States by calling +1 (404) 588-0900 or visiting https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.

There is the possibility, under certain limited conditions, for individuals to invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

13. DEFINITIONS

"17g-5 Services" means a secure on-line repository for sharing ratings-related information for certain structured financial products in compliance with Rule 17g-5 of the Exchange Act of 1934 by means of NetRoadshow's proprietary platform.

"Data Room Services" means a secure on-line repository for offering and due-diligence materials for debt offerings, equity offerings, and private transactions made by or for the account of a NetRoadshow customer.

"Directive" means Directive 95/46/EC.

"Document Delivery Services" means the electronic delivery of securities transaction related materials, such as preliminary, amended, and final, offering memoranda and prospectuses to Registered Users.

"Electronic Roadshow Services" means the recording, processing, and broadcasting of video, audio, and slides only roadshows, by means of NetRoadshow's proprietary platform.

"Personal Data" means data about an identified or identifiable individual that are within the scope of the Directive received by NetRoadshow from the European Union and recorded in any form.

"ResearchFN Services" means delivery of research material by means of NetRoadshow's proprietary platform.

"Roadshow Services" means the recording, processing, and delivery of electronic roadshow presentations by means of NetRoadshow's proprietary platform.

"Spreadsheet Services" means software and services that enable spreadsheet management, auditing, and control.

"Wall Crossing Services" means a secure on-line repository to organize, track, and archive all aspects of the wall crossing process.