Global Privacy Policy

Your Privacy Is Important To JDF Capital
In the course of serving you as an individual client or as someone associated with a corporate or institutional client, JDF Capital may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.

This Policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information, and the steps that we take to safeguard the information to protect your privacy. As used throughout this Policy, the term JDF Capital refers to JDF Capital Advisors, LLC.

The Sources of Information
JDF Capital facilitates mergers and acquisitions, business valuations and private placements. Due to the nature of our business, we do not hold funds or securities for customers, trade on behalf of customers, or provide investment advice. In the hypothetical event that we do hold and trade customer funds, personal information would be collected from account applications or other forms and materials you submit to us.

The personal information we do collect about you comes primarily from materials you submit to JDF Capital as part of due diligence information packages at the beginning of the engagement and other materials submitted throughout the course of the engagement. We may also collect information about your transactions and experiences with JDF Capital relating to the products and services JDF Capital provides. In addition, depending on the products or services you require, JDF Capital may obtain additional information about you, such as your credit history, from consumer reporting agencies.

Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly during the normal conduct of business (e.g., e-mails and telephone conversations). In these circumstances, the information is not accessed for any purpose other than normal conduct of business and it may be used for compliance or security purposes.

The Information We Have About You
If you deal with JDF Capital as an owner or principal of a company, the typical information we collect about you would include:

• Your name, address and other contact details;
• Your age, occupation and marital status;
• Extensive financial information, including source of wealth, investment experience and objectives and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources;
• A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc.

If you are an employee/officer/director/principal, etc. of one of our corporate or institutional clients, the typical information we collect about you personally would include:

• Your name and contact details;
• Your role/position/title and area of responsibility; and

Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to provide services to you. While we make every effort to ensure that all information we hold about you is accurate, complete, and up to date, you can help us considerably in this regard by promptly notifying us if there are any changes to your personal information.

Our Use of Your Personal Information
We may use your personal information to:

• Administer, operate, facilitate and manage your relationship with JDF Capital. This may include sharing such information internally as well as disclosing it to third parties, as described in the following two sections, respectively;
• Contact you or, if applicable, your designated representative(s) by post, telephone, electronic mail, facsimile, etc., in connection with your relationship and/or account;
• Provide you with information (such as investment research), recommendations, or advice concerning products and services offered by JDF Capital; and
• Facilitate our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.

If your relationship with JDF Capital ends, JDF Capital will continue to treat your personal information, to the extent we retain it, as described in this Policy.

Disclosures of Your Personal Information Within JD Ford Holdings Company, LLC
JDF Capital is a subsidiary of JD Ford Holdings Company, LLC. In order to provide efficient and reliable services, and to improve product and service options available to you, your personal information may be disclosed to and/or from JD Ford Holdings Company, LLC and its affiliates. For example, JD Ford Holdings Company, LLC might share your information with JDF Capital in order to facilitate settlement of your transactions. When so sharing your personal information, we adhere to applicable legal and industry standards regarding the protection of personal information. Additional information on how your personal information is protected while within JDF Capital is provided below under Information Security: How We Protect Your Privacy.

Disclosures of Your Personal Information to Third Parties
JDF Capital does not disclose your personal information to third parties, except as described in this Policy. Third party disclosures may include sharing such information with non-affiliated companies that perform support services for your account or facilitate your transactions with JDF Capital, including those that provide professional, legal, or accounting advice to JDF Capital. Non-affiliated companies that assist JDF Capital in providing services to you are required to maintain the confidentiality of such information to the extent they receive it, and to use your personal information only in the course of providing such services and only for the purposes that JDF Capital dictates.

We may also disclose your personal information to fulfill your instructions, to protect our rights and interests and those of our business partners, or pursuant to your express consent. Finally, under limited circumstances, your personal information may be disclosed to third parties as permitted by, or to comply with, applicable laws and regulations, for instance, when responding to a subpoena or similar legal process, to protect against fraud, and to otherwise cooperate with law enforcement or regulatory authorities, or with organizations such as exchanges and clearinghouses.

You should know that JDF Capital will not sell your personal information.

Information Security: How We Protect Your Privacy
JDF Capital is committed to protecting the privacy and confidentiality of your personal information. We limit access to your personal information to authorized JDF Capital employees or agents and, as described above in Disclosures of Your Personal Information to Third Parties, our service providers are held to stringent standards of privacy. We also maintain physical, electronic, and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure. Some of the other central features of our information security program are:

• The use of specialized technology such as firewalls;
• Testing of the security and operability of products and services before they are introduced to the Internet;
• Internal and external reviews of our Internet sites and services;
• Monitoring of our systems infrastructure to detect weaknesses and potential intrusions;
• Protecting information during transmission through various means including, where appropriate, encryption; and
• Providing JDF Capital personnel with relevant training and continually updating our security practices in light of new risks and developments in technology.

Other Privacy Policies or Statements; Changes to Policy; Your Access to Our Records
This Policy provides a general statement of the ways in which JDF Capital protects your personal information. This Policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised Policy will be effective immediately upon posting to our Web site. This version of the Policy is effective January 1, 2008.

You are entitled to access any personal data about you held by JDF Capital by sending a written request to the addressed listed below. You may be required to supply a valid means of identification as a security precaution to assist us in preventing the unauthorized disclosure of your personal information. We will process your request within the time provided by applicable law. You are also entitled to have JDF Capital modify or delete any information that you believe is incorrect or out of date.

If you require further information regarding our privacy policies and practices, use the following address:

JDF Capital Advisors, LLC
650 S. Cherry Street, Suite 1200
Denver, Colorado 80246