CPSG Partners Safe Harbor Privacy Policy CPSG Partners LLC (“CPSG”) respects individual privacy and values the confidence of its customers, employees, business partners and others. Not only does CPSG strive to comply with the laws of the countries in which it does business when it collects, uses and discloses personal information, but it also is committed to upholding the highest ethical standards in its business practices. This Safe Harbor Privacy Policy (the “Policy”) sets forth the privacy principles CPSG follows with respect to transfers of personal information from the European Economic Area (EEA) (which includes the twenty-seven member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland to the United States.

CPSG complies with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries and Switzerland. CPSG has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view CPSG’s certification, please visit
http://www.export.gov/safeharbor/

SAFE HARBOR

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “U.S.-EU Safe Harbor”). The EEA also has recognized the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45, 15.2.2001, p.47). The United States Department of Commerce and the Federal Data Protection and Information Commissioner (FDPIC) of Switzerland have agreed on a similar set of principles and frequently asked questions to enable U.S. companies to satisfy the requirement under Swiss law that adequate protection be given to personal information transferred from Switzerland to the United States (the “U.S.-Swiss Safe Harbor”). Consistent with its commitment to protect personal privacy, CPSG adheres to the principles set forth in the U.S.-EU Safe Harbor and the U.S.-Swiss Safe Harbor (the “Safe Harbor Principles”).

To learn more about the Safe Harbor program and to view CPSG’s certification, please visit http://www.export.gov/safeharbor.

SCOPE

This Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by CPSG in the United States from the EEA and from Switzerland, in any format, including electronic, paper or verbal.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, CPSG or to which CPSG discloses personal information for use on CPSG’s behalf.

“CPSG” means CPSG Partners LLC, its predecessors, successors, subsidiaries, divisions and groups in the United States.

“Personal information” means any information or set of information that identifies or could be used by or on behalf of CPSG to identify an individual. Personal information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information.

“Sensitive personal information” means personal information that reveals race, age, ethnic origin, political opinions, wages or salaries, employment benefits with your current or past employer, religious or philosophical beliefs, trade union membership, views or activities, that concerns health or sex life, information about social security benefits, or information on criminal or administrative proceedings and sanctions other than in the context of pending proceedings. In addition, CPSG will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE: Where CPSG collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non–agent third parties to which CPSG discloses that information, if any, the choices and means CPSG offers individuals for limiting the use and disclosure of personal information about them, and how to contact CPSG. Notice will be provided in clear and conspicuous language if and when individuals are asked to provide personal information to CPSG, or as soon as practicable thereafter, and in any event before CPSG uses or discloses the information for a purpose other than that for which it was originally collected.

If CPSG receives personal information from subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.

CHOICE: CPSG will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

For sensitive personal information, CPSG will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.

CPSG will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY: CPSG will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. CPSG will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS: CPSG will obtain assurances from its agents that they will safeguard personal information consistently with this Policy. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), being subject to Swiss Federal Act on Data Protection, Safe Harbor certification by the agent, or being subject to another European Commission or Swiss FDPIC adequacy finding (e.g., companies located in Canada). Where

CPSG has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, CPSG will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION: Upon request, CPSG will grant individuals reasonable access to personal information that it holds about them. In addition, CPSG will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY: CPSG will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

ENFORCEMENT: CPSG will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that CPSG determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the CPSG Privacy Office at the address given below. CPSG will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Policy. For complaints that cannot be resolved between CPSG and the complainant, CPSG has agreed to participate in the following dispute resolution procedures in the investigation and resolution of complaints to resolve disputes pursuant to the Safe Harbor Principles:

1. for disputes involving all personal information received by CPSG from Switzerland, CPSG has agreed and to cooperate with the Swiss FDPIC;

2. for disputes involving employment-related personal information received by CPSG from the EEA, CPSG has agreed to cooperate with the data protection authorities in the EEA and to participate in the dispute resolution procedures of the panel established by the European data protection authorities;

3. for disputes involving all other personal information received by CPSG from the EEA, CPSG has agreed to dispute resolution using INTERNATIONAL CENTRE FOR DISPUTE RESOLUTION. Individuals who submit a question or concern to CPSG and who do not receive acknowledgment from CPSG of the inquiry or who think their question or concern has not been satisfactorily addressed should then contact the INTERNATIONAL CENTRE FOR DISPUTE RESOLUTION Safe Harbor Dispute Resolution Program on the Internet, by mail or by fax.

Inquiries by mail or fax should identify CPSG as the company to which a concern or question has been submitted, and include a description of the privacy concern, the name of the individual submitting the inquiry, and whether the INTERNATIONAL CENTRE FOR DISPUTE RESOLUTION may share the details of the inquiry with CPSG. The INTERNATIONAL CENTRE FOR DISPUTE RESOLUTION will act as a liaison to CPSG to resolve these disputes.

a. Online (http://go.adr.org/safeharbor)

b. Fax: 877-304-8457 (USA) | 212-484-4178 (Outside USA)

c. Mail:

International Centre for Dispute Resolution
Case Filing Services
1101 Laurel Oak Road, Suite 100
Vorhees, NJ 08043

For information about INTERNATIONAL CENTRE FOR DISPUTE RESOLUTION or the operation of ICDR/AAA’s dispute resolution process, visit INTERNATIONAL CENTRE FOR DISPUTE RESOLUTION on the Internet (http://go.adr.org/safeharbor) or request this information from the INTERNATIONAL CENTRE FOR DISPUTE RESOLUTION by mail or fax using the contact information listed above. The INTERNATIONAL CENTRE FOR DISPUTE RESOLUTION dispute resolution process shall be conducted in English.

LIMITATION ON APPLICATION OF PRINCIPLES

Adherence by CPSG to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION

Questions or comments regarding this Policy should be submitted to the CPSG Privacy Office by mail to:

CPSG Privacy Officer
CPSG Partners LLC
5001 Spring Valley Rd #1155E
Dallas, Tx 75244

Or by e-mail to the CPSG Privacy Officer (privacy@cpsgpartners.com)
CHANGES TO THIS SAFE HARBOR PRIVACY POLICY

This Policy may be amended from time to time, consistent with the requirements of the Safe Harbor Principles. A notice will be posted on the CPSG web page (www.cpsgpartners.com) for 60 days whenever this Safe Harbor Privacy Policy is changed in a material way.

EFFECTIVE DATE: March 28th, 2014