We at Bogle & Chang, LLC ("B & C") respect and are committed to protecting your privacy. That is why we have adopted this Privacy Policy. This Privacy Policy lets you know how and for what purposes your personal information is
being collected, processed and used. We pledge that we will take reasonable steps to ensure that your personal information will only be used in ways that are in compliance with this Privacy Policy. This Privacy Policy is only in effect
for any Web pages, e-mail lists, collective non user-specific information and collective personal information collected on and/or provided through Bogle & Chang's Web Sites, including but not limited to the www.boglechang.com,
www.boslegal.com Web Sites, as well as any online features, services and/or programs offered by B & C and its affiliates (collectively, the “Web Site”).

At B & C, we recognize that the privacy and security of your personal financial information is an important concern. We have established and implemented policies and procedures to protect this information. This Privacy Policy
describes how we maintain the confidentiality and accuracy of your nonpublic personal information that we may collect, and how we use and may disclose such information in the future. This Privacy Policy explains your legal rights
with respect to your nonpublic personal information that we collect.

Categories of Nonpublic Personal Information We May Collect and Disclose
Nonpublic personal information means personally identifiable financial information that relates specifically to you and that is not readily available from a public source. We receive various kinds of nonpublic personal information from
you. This information may include identification, contact and financial information. The nonpublic personal information that we may collect about you and disclose to third parties comes from the following sources:

Information that we receive from you, such as your name, birth date, address, telephone number, social security number, employment history, income, assets and liabilities; Information that we receive from others whom you authorize
us to contact in our representation of you or otherwise; and Information that may be disclosed in a discussion forum or submitted in a question or comment by a user, including our response to such a question or comment.  We use
your personal information only for the purpose of providing legal services to you, maintaining and operating any features, services and programs on the Web Site and in compliance with all applicable laws and regulations. We may,
however, disclose any of the information that we collect to non-affiliated third parties as described below.

We use reasonable precautions to keep the information that is disclosed to us secure. We reserve the right to transfer information in connection with the sale or other disposition of all or part of the Fox Rothschild business and/or assets.
Furthermore, we cannot and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the information that is disclosed to us. The Web Site also links to a wide variety
of other Web sites and the Web Site may contain advertisements of third parties. We are not and cannot be responsible for the privacy policies of those Web sites of third parties or how they treat information about their users. Any
information that you post on the Web Site may be viewed by any third party and we are not responsible for the content and/or the accuracy thereof.

Disclosure to Nonaffiliated Third Parties
Nonaffiliated third parties are those companies that are not owned or controlled by B & C, do not own or control Bogle & Chang, or are not under common control with B & C. Our policy is that we do not disclose your nonpublic
personal information to nonaffiliated third parties except as permitted by law. We may provide your nonpublic personal information to our employees and, in limited circumstances, to nonaffiliated third parties who need such
information to assist us in providing legal services to you. Before we would disclose your information to a non-affiliated third party, we would require such third party to comply with our measures and standards of security and
confidentiality. Additionally, we may disclose nonpublic personal information to non=affiliated third parties as required by law or as part of a sale or merger of all or part of Bogle & Chang.

r Policies and Practices With Respect To Your Nonpublic Personal Information
Your privacy is considered in all aspects of our business. We maintain physical, electronic and procedural safeguards that comply with our professional standards and procedures. We only allow access to your nonpublic personal
information by a select group of employees and contractors; specifically, those who need to access your information to provide legal services to you.

Information From Children
The Web Site is not intended or designed to attract children under the age of thirteen (13). We do not collect personally identifiable data from any person that we know to be under the age of thirteen (13).

Parents should be aware that Fox Rothschild’s Privacy Policy will govern our use of personal data, but also that information that is voluntarily given by children – or others – in chat sessions, e-mail exchanges, bulletin boards or the like
may be used by other parties to generate unsolicited communications. Fox Rothschild encourages all parents to instruct their children in the safe and responsible use of their personal data while using the Internet.

European Users
Because BOS Legal operates globally, the information that we collect may be made available to our affiliates, partners and subsidiaries worldwide. For those users visiting us from the European Economic Area, please note that B & C
may transfer your personally identifiable data outside the European Economic Area for use for any of the purposes described above. By using the Web Site and providing B & C with your personal data, you consent to such transfer of
your personal data.

How Information is Collected
IP Address
Every computer connected to the Internet is given a domain name and a set of numbers that serve as that computer’s “Internet Protocol”, or IP, address. When a user requests a Web page from the Web Site, our Web servers
automatically recognize that user’s domain name and IP address. The domain name and IP address reveal nothing personal about the user other than the IP address from which the user has accessed the Web Site. We may use this
information to examine our traffic in the aggregate, but do not collect and evaluate this information for individuals. Our Web servers do not automatically record e-mail addresses of users.

From time to time, we and/or our affiliates or advertisers may send a “cookie” to your computer. A cookie is a small piece of data that is sent to your Internet browser from a Web server and stored on your computer’s hard drive. A cookie,
by itself, cannot read data from your hard disk or read cookie files created by other Web sites. A cookie, by itself, does not damage your system. We may use cookies to identify and keep track of those areas of the Web Site that you
have visited in the past in order to enhance your next visit to the Web Site. Our advertisers may also use cookies to ascertain how many times that you have seen an advertisement. We and our advertisers may use this information to
better personalize the content, banners and promotions that you see on the Web Site. You can choose whether or not to accept cookies by changing the settings of your Internet browser. If you choose not to accept cookies, your
experience on the Web Site may be diminished and some features may not be available or may not work as intended.

Member Account, Password And Security
For certain features available through the Web Site, we require the use of encryption technologies provided for your protection and/or your use of a UserID and password after setting up a User Account. We use reasonable precautions
to protect the privacy of your UserID, password and User Account information by utilizing a Secure Socket Layer (“SSL”) connection. Accordingly, your UserID, password and User Account information are encrypted using an SSL
connection and are not expected to be read in an intelligible form as they travel to the Web Site. You, however, are ultimately responsible for protecting your UserID, password and User Account information from disclosure to third
parties, and you are not permitted to circumvent the use of required encryption technologies. You agree to: (a) immediately notify Fox Rothschild of any unauthorized use of your UserID, password and/or User Account, and/or any other
breach of security, and (b) ensure that you exit from your User Account at the end of each session. While we provide certain encryption technologies and use other reasonable precautions to protect your confidential information and
provide suitable security, we do not and cannot guarantee or warrant that information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.

Privacy Outside the Web Site
The Web Site contains various links to other Web sites, including links to various third party service providers. B & C is not and cannot be responsible for the privacy practices or the content of any of those other Web sites. Other than
under agreements with certain reputable organizations and companies, and except for third party service providers whose services you voluntarily elect to utilize, we do not share any of the personal information that you provide to us
with any of the Web sites to which the Web Site links, although we may share aggregate, non-personally identifiable data with those other Web sites. Please check with those Web sites in order to determine their privacy policies and
your rights under them.

Your Consent To This Privacy Policy
By using the Web Site, you consent to the collection and use of information by us as specified above or as we otherwise see fit unless you inform us otherwise by means of the procedure identified below. If we decide to change this
Privacy Policy, we will make an effort to post those changes on this Web page so that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose
that information to others. We may use comments, information or feedback that you may submit in any manner that we may choose without notice or compensation to you.

If you have additional questions or comments of any kind, if you see anything on the Web Site that you think is inappropriate or if you would like to have any or all of your personal information withheld from third party organizations
and companies and/or from third party service providers, please let us know by sending your comments or requests to:

Ten Post Office Square, 8th Floor
Boston, MA  02109
Attn: Web Site – Privacy Issues

Effective Date: January 1, 2005
Last Updated: March 22, 2010
Privacy Policy
Copyright © 2010 Bogle & Chang, LLC.  All Rights Reserved.