Revised June 22 , 2003

Our commitment to you: User data and contact information obtained by TigerRock Capital Research will never be shared for commercial purposes.

If you have any questions concerning TigerRock Capital Research's Privacy Policy, please send us an email to: Cs@tigerockcapital.com

Introduction

TigerRock Capital Research provides investment management services to institutions and individuals worldwide. As a world-class organization, we are committed to providing the highest quality of service to all of our customers. We also have a responsibility to our customers, the public, and our profession to deliver our services in a professional manner, with uncompromising values and standards. As such, the firm must and will in all respects comply with all relevant Federal and State laws, regulations and requirements.

TigerRock Capita is committed to providing you with a clear explanation of its Privacy Policy. This Privacy Policy covers privacy issues as they relate to US, Canada, and UK online marketing initiatives.

General

TigerRock Capita collects contact information and other relevant data from prospective clients so that we can provide them with the information they've requested - either directly from TigerRock Capital Research or through one of our marketing partners. Please note that this information comes from people who specifically request information through TigerRock Capital Research' website or from clearly labeled advertising.

All personal information submitted to us will be held confidential and will not be shared for any commercial purposes.

Email

TigerRock Capital Research sponsors third party email content. In order to receive TigerRock Capital Research' email content through a third party, an individual would have had to previously subscribed to a particular service or "opted-in" to receive relevant promotional content from advertising partners. As advertisers, we do not gain access to users' contact information—this information is kept confidential by the content owner—nor does TigerRock Capital Research supply additional users from our own internal database. Rather, the respective online publisher distributes content on our behalf.

If you have received TigerRock Capital Research' email content through a third party, you must unsubscribe or "opt-out" through the respective publisher. The only way to avoid receiving future promotional offers (from TigerRock Capital Research or other companies) is by going directly to the respective publisher and unsubscribing from their list.

TigerRock Capital Research does, however, maintain a suppression file of email addresses in compliance with the CAN SPAM Act of 2003 (S.877). This list is updated daily and provided to publishers with instructions to exclude the respective email addresses from TigerRock Capital Research sponsored email campaigns. For instructions on adding your name to TigerRock Capital Research' email suppression file, see the section called "Removal from the TigerRock Capital Research Database."

Online Advertising

TigerRock Capital Research' online advertising is in full compliance with Internet, advertising and finance industry standards and regulations. Our advertising content is integrated and delivered with online publisher's primary content in a variety of different formats; some in graphical format (e.g. banner) and others in text format.

The delivery of our online advertisements (and frequency thereof) is ultimately controlled by the respective online publisher. Unfortunately, we are unable to suppress or restrict the delivery of our online advertisements to individual users. Many publishers offer "frequency capping" to limit the number of advertisements a user will receive on a periodic basis. However, this functionality will NOT work if you have disabled "cookies" in your browser. For example, if you are experiencing a high volume of online advertisements in general (like pop-up ads), then it might be an issue with your Internet browser's ability to accept "cookies". It is important that you have "cookies" enabled in your browser settings.

TigerRock Capital Research collects aggregate performance data on its online advertising. This information is anonymous and not personally identifiable. It does not contain your name, address, telephone number, or email address. In addition, service providers and the media owners themselves may track behavior of users visiting their web sites, such as domain type, IP address, and clickstream data. Please note that this information is not individually identifiable.

Cookies

What is a "cookie"? A cookie is a small data file containing information, such as a link that a user clicked on, which is written to the user's hard drive by a web server and used to track the pages visited. With cookies, the information is anonymous and not personally identifiable. It does not contain personal information such as name, address, telephone number, or email address. It also does not contain user passwords. The individual information gathered in this manner is used for internal purposes only, such as looking at unique page views and customizing content. We also use the information on an aggregate basis, to track the usage of our website and to analyze traffic patterns.

You can control your browser's settings regarding cookies by selecting "Internet Options" or "Preferences" in the menu bar of your browser. This will allow you to prevent your browser from accepting new cookies, have your browser notify you when you receive a new cookie, or disable cookies altogether. However, because cookies provide benefits like streamlining the website so visitors can find the information they are looking for more easily, we recommend that you leave them turned on.

Partners

Certain partner organizations have limited access to online performance data (e.g. cookie data) in order to help TigerRock Capital Research get a better understanding of the users visiting its website. The data they maintain for TigerRock Capital Research helps us optimize the use of our website. Note: Personal data obtained by TigerRock Capital Research will not be shared for commercial purposes.

General Privacy Notice for TigerRock Capital Research' Clients

TigerRock Capital Research collects nonpublic information about users from the following sources:

• Information received on applications or other forms
• Information provided orally
• Information about transactions or online behavior with TigerRock Capital Research or other publishers

TigerRock Capital Research does not disclose any nonpublic personal information about its clients or non-clients without explicit authorization from the respective party, except as permitted by law or in response to inquires from governmental authorities.

TigerRock Capital Research restricts access to personal and account information to those personnel who need to know that information to conduct business. TigerRock Capital Research may also disclose that information to unaffiliated third parties (such as to brokers or custodians) only as permitted by law and only as needed for TigerRock Capital Research to provide agreed services to clients. TigerRock Capital Research maintains physical, electronic and procedural safeguards to guard nonpublic personal information.

Privacy Policy Updates

From time to time, TigerRock Capital Research may use data for new, unanticipated uses not previously disclosed in our privacy notice. If its information practices change at some time in the future TigerRock Capital Research will post the policy changes to its website to notify users of these changes. If users are concerned about how information is used, they should check back to this location periodically.

Updating or Correcting Personal Information

Upon request, TigerRock Capital Research will provide site visitors with access to respective contact information (e.g., name, address, phone number) that is maintained about them. To access this information, please email Cs@tigerockcapital.com. Upon request, TigerRock Capital Research will also offer visitors the ability to have inaccuracies corrected in the database. Users can have this information corrected by sending email to Cs@tigerockcapital.com

Removal from the TigerRock Capital Research Database

If contact information is willingly provided to TigerRock Capital Research by mail, phone, email, online, or otherwise, in response to our marketing activities, individuals may receive subsequent periodic information from TigerRock Capital Research on new products and services or upcoming events. If individuals don't wish to receive such information, please let TigerRock Capital Research know by sending an email to Cs@tigerrockcapital.com, or by writing to the following address:

TigerRock Capital Research
ATTN: Marketing Department
501 N. Orlando Ave, Ste 313
Winter Park, FL 32789

Please provide TigerRock Capital Research with the exact name and address as it was originally provided. We will be happy to remove your name from our database and will do everything possible to honor your request for removal.

To unsubscribe from TigerRock Capital Research's email communications, send an email to Cs@tigerockcapital.com. Please put "UNSUBSCRIBE" in the subject field and include the email address where you received the content, along with any additional email addresses you would like suppressed. We will do our best to prevent you from receiving our email content in the future.

Security

TigerRock Capital Research has appropriate security measures in place at its physical facilities to protect against the loss, misuse or alteration of private information collected from users. If users feel that this website is not following its stated privacy policy, they are encouraged to contact TigerRock Capital Research at Cs@tigerockcapital.com.