This Privacy Policy (the “Policy”) describes how Aurora Bridge Capital and its affiliates (including its European affiliate Aurora Bridge Capital (“Aurora,” “we,” or “our”) collect personal information (as defined below) and how we process personal information when you visit our website www.aurorabridgecapital.com (the “Website”) or otherwise interact with us (collectively, our “Services”).

We are a limited liability company incorporated in the United States with our registered office at 1521 Blake St Ste 47009, Denver, CO 80202. We are the data controller under the General Data Protection Regulation (“GDPR”). By accessing our website or using our services, you agree that we will process your personal information in accordance with the manner described in this policy. Your use of our website or services, and any disputes relating to privacy, are governed by this policy and our Terms of Use (including applicable limitations on damages and dispute resolution provisions therein). Our Terms of Use are incorporated into this policy by reference. If you do not agree to all or any part of this policy, please do not access this website. Please read this policy carefully to understand your rights regarding personal information and how we collect, use, and process your personal information. If you are a resident of California, please see Section 12 of this policy for more information about your privacy rights. Please note that if information is protected under the Graeme-Ritchie-Billilay Act (“GLBA”), please see the GLBA notice in Section 10 of this policy.

As stated above, this policy details how Aurora collects personal information and how we process it when you visit our website or otherwise interact with us. Regarding Aurora's privacy framework, [further details are available upon request]. Information on how personal data from other data subjects (e.g., candidates, employees, investors) is provided to the respective data subjects in the form of a separate privacy statement or privacy notice, which is typically tailored to the specific requirements of the data subject's jurisdiction.

1. Personal Information We Collect

We collect information that is relevant to or describes you (“Personal Information”). Personal Information does not include:

• Public information as defined under applicable law.
• De-identified or aggregated information.

Aurora will collect Personal Information directly from you and automatically through our website.

Personal Information We Collect Directly from You

The Personal Information we collect depends on how you interact with our services, but generally includes the following. Contact Information. For example, you may provide your name, organization name, address, city, state/province, postal code, country/region, email address, telephone number, and fax number.

Communication Information. When you contact us, we may also collect other information you choose to provide in the subject and body of your emails.

Investor Portal

We collect other personal information from registered investors and their representatives. Our processing of such personal information is governed by the Investor Privacy Statement.

Investors can access our Investor Portal, a private part of our website, through the following providers. These providers are third parties, and their collection and use of your login information and any other data related to your use of the Investor Portal are governed by separate privacy policies, which can be viewed after you register and log in.

News Briefs

If you register to receive email notifications on our website, we will send you information you request to receive (including information on company events, press releases, presentations, and company documents). You can opt out of receiving such information at any time using the contact information described in Section 14 below.

Personal Information We Automatically Collect

Like most website operators, we use cookies on our website... This information may be collected using technologies such as [unspecified technology]. Depending on your browser and settings, this may include the following personal information:

• Domain name
• Country or region information
• Browser type
• Pages viewed and activities performed
• Clicked links
• IP address
• Session duration
• Website referrer URL
• Ad ID
• Language information
• Operating system name and version.

2. Cookies

We also use cookies to collect your personal information, such as whether you have visited this website and when you last visited. For more information about the types of personal information we collect using these technologies, please see the "Personal Information We Collect" section above. For resources and instructions on how to disable tracking technologies, please see the "Tracking and Advertising Choices" section below.

What is a Cookie?

A cookie is a piece of information that a website stores on a user's computer. Each time a user submits a query to the website using their browser, the browser provides this information to the website. When you visit our website, we place cookies on your computer. Some cookies make it easier for you to browse our website, while others are used to speed up the login process or help us track your activity on our website. Cookies come in two types: session cookies and persistent cookies.

Session Cookies

Session cookies exist only during your online visit. They disappear from your device when you close your browser or turn off your device. We use session cookies to enable our systems to uniquely identify you during your visit to the website or after you log in. This allows us to process your online transactions and requests and verify your identity when you browse the website after logging in.

Persistent Cookies

Persistent cookies remain on your device even after you close your browser or turn off your device.

3. How We Use Personal Information

We collect personal information and use it for the following purposes:

Operating Services and Providing Support

To provide and operate our services, communicate with you about your use of the services, verify your eligibility to access restricted areas of our website, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments and claims, communicate with you regarding the services, and for similar service and support purposes.

Analysis and Improvement

To better understand how users access and use our services and our other products and services, and for other research and analysis purposes, such as evaluating and improving our services and business operations, developing services and features, and for internal quality control and training purposes.

Customization and Personalization

To customize the content we may send or display in the services, including providing location customization, personalized help and instructions, and otherwise personalizing your experience.

Marketing and Advertising

For marketing and advertising purposes. For example, to send you information about our services, such as offers, promotions, newsletters and other marketing content, and any other information you register to receive. We may also use certain information collected to manage and improve our advertising campaigns so that we can better deliver relevant content to users.

Security and Rights Protection

To protect the services and our business operations; to protect the rights of ourselves or our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other abuses; to conduct risk and security controls and monitoring; and, where we deem it necessary, to investigate, prevent, or take action against illegal activities, suspected fraud, situations involving potential threats to the safety or legitimate rights of any individual or third party, or violations of our Terms of Use. To maintain our facilities and infrastructure and to implement quality and security assurance measures.

Compliance and Legal Processes

To comply with laws and our legal obligations, and to respond to legal processes and related legal proceedings.

General Business and Operational Support

To consider and implement mergers, acquisitions, reorganizations, insolvency, and other business transactions, such as financing, and matters relating to our general business administration, accounting, auditing, compliance, records keeping, and legal functions.

Business Transfers

To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and, where necessary, to manage our general business, accounting, records keeping, and legal functions.

4. How We Disclose Personal Information

We collect personal information and use it for the following purposes:

Our Service Providers

To provide and operate our services, communicate with you regarding your use of the services, verify your eligibility to access restricted areas of our website, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments and claims, communicate with you regarding the services, and for similar service and support purposes.

Subsidiaries and Affiliates

We may disclose the personal information we collect to our subsidiaries or affiliates.

Government or Public Agencies/Departments

We may disclose personal information if: (a) we believe disclosure is reasonably necessary to comply with any applicable laws, regulations, legal processes, or governmental requirements; (b) to enforce our agreements, policies, and terms of use; (c) to protect the security or integrity of our website or services; (d) to protect the property, rights, and safety of Aurora, our users, or the public from harm or illegal activities; (e) to respond to an emergency in which we believe in good faith that disclosure is necessary to help prevent death or serious personal injury to any person; or (f) to investigate and respond to any third-party claims or allegations.

Third-party advertising networks

We may disclose personal information to third-party advertising network providers, sponsors, and/or traffic monitoring service providers. These third parties may use cookies and other tracking technologies to measure the effectiveness of their advertising and to provide you with personalized advertising content. These third-party cookies and other technologies are governed by their respective privacy policies, not this privacy policy. To choose whether to receive third-party advertising, please see Section 5 below.

Third-party analytics service providers

We may disclose personal information to marketing analytics service providers, such as Google Analytics.

We may disclose personal information to the above parties for the following purposes:

• Operating our websites and services. We may disclose personal information to provide and operate our websites and services.
• Marketing and communications. We may disclose personal information to third-party advertising networks to place advertisements on our websites, third-party websites, or other media. This enables us and these third parties to serve you advertisements for products and services based on your interests.
• Fraud prevention. We may disclose user information when we believe it is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activities; to protect the safety, rights, or property of the company, its users, or others; or to exercise or protect legal rights or to defend against legal proceedings.
• Law enforcement and litigation. To the extent permitted by law, we may disclose any information collected through this website or related to the use of this website to government agencies or third parties as required by law or regulation, subpoena, or other legal process. We may also use or disclose your information to the extent permitted by law to protect the rights or property of Aurora, our customers, this website, its users, or third parties, or when we believe in good faith that the law requires us to do so.
• Business Transfer. If Aurora undergoes a change of control, such as being sold to or merged with other entities, or if all or part of its assets are sold, Aurora reserves the right to transfer your personal information to the new controlling party or asset acquirer. As part of the business transfer process, we may share some of your personal information with lenders, auditors, and third-party advisors (including lawyers and consultants).

5. Advertising and Tracking Cookies

If you wish to prevent cookies or third-party advertisers from tracking your activity on our website or your visits across websites, you can use some tools to disable cookies and opt out of interest-based advertising. Using the following resources does not mean you will no longer receive any advertising through our websites, services, or other websites. For example, you may still receive ads based on the specific website you are browsing (i.e., context-sensitive ads). If your browser is set to refuse cookies, your opt-out settings may not work.

Browser Solutions

You can decide whether and how to accept cookies by configuring your browser preferences, following the instructions provided in your browser. However, if you choose to refuse cookies, some functionality of this website may be affected.

6. Third-Party Website Links

Our websites and services may contain links to third-party websites and applications. Access to and use of such links are not governed by this policy but by the relevant third-party privacy policies. If you provide information directly to a third party, that third party is not obligated to comply with this policy. We are not responsible for how these third-party websites process information. Therefore, before accessing a third-party website and providing any personal or other information to any third party, users should understand the website operator's privacy policies and practices (if any) and take necessary measures to protect their own privacy.

7. Security

We have taken precautions to protect the personal information we collect from loss, misuse, unauthorized access, disclosure, alteration, and destruction. Please note that while we have made every effort, no data security measure can guarantee absolute security.

You should take steps to protect your passwords, mobile phone, and computer from unauthorized access, such as logging out of your account after using a shared computer, setting strong passwords that are unknown or difficult for others to guess, and keeping your login name and password safe. We are not responsible for any lost, stolen, or disclosed passwords, or for account activity resulting from unauthorized password activity.

8. Information for EU Residents Regarding International Data Transfers

Please note that this website is hosted in the United States and other countries mentioned above, and some of the Aurora companies and contractors that process your personal information are also located in these countries. The levels of information protection offered in these countries may differ from the requirements of the EU General Data Protection Regulation (GDPR). In this case, your personal information will be transferred through one of the following mechanisms:

• Sample Terms: Aurora will take steps to ensure that appropriate safeguards are in place to protect personal information transferred to the United States or other jurisdictions where data protection levels do not meet European Commission standards, including the use of standard contractual terms approved by the European Commission and the UK Parliament. You can request a copy of the sample terms. You can make a request to us at [email protected].
• Adequacy Decision: Your personal information will be transferred to and stored/processed in Canada. Canada is considered to have an adequate level of protection for personal data, pursuant to European Commission Decision 20/2/EC of 20 December 2001.

9. Retention of Personal Information

We retain personal information only as necessary and in accordance with our data retention policy. We may retain information to comply with applicable laws, fulfill contractual obligations, respond to litigation or legal matters, or for other reasonable purposes necessary to provide our services. For example, we will retain your information as follows:

• If you provide us with your personal information through the “Contact Us” page, we will store your data in the Aurora Exchange email system in accordance with our data retention policy and practices.
• Personal information collected using Google Analytics cookies will be retained for two (2) years. Information collected using other cookies will be retained for 24 hours.

10. GLBA Notice

Aurora Bridge Capital (“Aurora”) and your personal information

Financial companies can choose how they share your personal information. Federal law gives you the right to restrict some (but not all) information sharing. Federal law also requires us to inform you how we collect, share, and protect your personal information. Please read this notice carefully to understand our practices.

The types of personal information we collect and share depend on the products or services you receive from us. This information may include, but is not limited to:

• Your name, address, email address, and phone number
• Transaction history and assets
• Investment experience and wire transfer instructions
• Any other personally identifiable information, including information on your driver's license, passport, or other identification documents.
• Information collected through "cookies" on our website, data room, and/or investor portal

Even if you are no longer an Aurora customer, we will continue to share your information as described in this notice.

All financial companies need to share customers' personal information to conduct their day-to-day business. The following sections list the reasons why financial companies may share customers' personal information; whether Aurora chooses to share it; and whether you can restrict this sharing.

Personal Information Sharing Practices

Who We Are

Who issues this notice?
Aurora or its affiliates (as defined below).

What We Do

How Does Aurora Protect My Personal Information?

To protect your personal information from unauthorized access and use, we take security measures that comply with federal law. These measures include computer security and the security of documents and buildings.

How Does Aurora Collect My Personal Information?

We collect your personal information, for example, when you:

• Provide income information or your contact details
• Provide account information or make wire transfers
• Please tell us where the money is going.

Why can't I limit all sharing?

Federal law gives you the right to limit only the following:

• Sharing your credit information for the ordinary business purposes of your partners
• Preventing affiliate partners from using your information to market to you
• Sharing with non-affiliate marketers to market to you

State laws and individual company rules may grant you additional rights to limit information sharing.

There is no common ownership or control relationship between these companies. They can be financial companies or non-financial companies.

Aurora does not share information with unaffiliated companies so they can market to you.

Joint Marketing

Formal agreements between unaffiliated financial companies that jointly market financial products or services to you.

11. Notice to European Residents

Where the General Data Protection Regulation (GDPR) applies, you have the following rights regarding your personal information:

Data Rights

In certain circumstances, you have the right to access and obtain a copy of the information we hold about you, to correct any inaccurate personal information, and to request the deletion of the personal information we hold about you. Any subsequent access requests after the initial request may be subject to a reasonable fee to cover the costs we incurred in providing you with the relevant information. You can exercise your right by emailing [email protected].

Marketing

You have the right to request that we cease using your personal information for marketing purposes. You can exercise your right to block such processing at any time by contacting us at [email protected].

Complaints

If you wish to file a complaint regarding how we process your personal information, please first contact us at [email protected], and we will endeavor to process your request as quickly as possible. This does not affect your right to file a complaint with a regulatory authority.

With respect to the GDPR, we are the data controller.

12. Notice to California Residents

Under the California Consumer Privacy Act (CPA), as amended by the California Privacy Rights Act (“CCPA”), California residents are entitled to certain disclosures relating to our processing of “personal information” (as defined in the CCPA). If you are a California resident and we collect personal information subject to the CCPA, the following terms apply.

Please note that this section does not apply to information exempted by the CCPA, such as information protected under federal financial privacy laws. The CCPA acknowledges that such financial information is already protected under federal privacy laws, therefore the CCPA does not apply to such information. For more information, please see the Graeme-Ritchie-Billilay Act (GLBA) notice below.

CCPA Right to Know Disclosure

While our information processing methods may vary depending on our relationship and interactions with you, the table below describes the categories of personal information we collect (as listed in the California Consumer Privacy Act (CCPA), the categories of third parties to whom we disclose each category of personal information, and the categories of third parties to whom we sell or share personal information if we "sell" or "share" it as defined by the CCPA. For more information on how we collect, use, and disclose personal information, please see Sections 1–4 and 9 above.

Your California Privacy Rights

If you are a California resident, you may have the following rights regarding your personal information:

• Right to Access: You have the right to request, up to twice a year, subject to certain exceptions, any personal information we have collected about you in the past 12 months regarding: (i) the categories of personal information we have collected about you; (ii) the sources from which we collected this personal information; (iii) the commercial or business purposes for which we collect, sell, or disclose this personal information; (iv) the categories of third parties to whom we have disclosed this personal information; and (v) a copy of any specific personal information we have collected about you.
• Right to Correction: You have the right to request that we correct any inaccuracies in your personal information.
• Right to Erasure: You have the right to request the erasure of any personal information we have collected about you, subject to certain conditions and exceptions.
• Right to Opt Out of Sale/Sharing: You have the right to opt out of the “sale” or “sharing” of your personal information. To opt out of the sharing or sale of the above information, please contact us at [email protected]. We currently have no record of selling or sharing the personal information of consumers under the age of 16.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of the rights described in this section.
• Authorized Agent: You may designate someone as your authorized agent to submit requests and act on your behalf. To do this, you must provide us with written authorization allowing that authorized agent to act on your behalf.

To exercise the above rights, please contact us by emailing [email protected]. Please indicate that you are making a request under the California Privacy Rights. You must provide the following information: (1) your name; (2) your date of birth; (3) your email address; and (4) your residential or mailing address. We will verify your request by comparing the information you provide with information in our records. In some cases, we may request additional information from you to verify your request or to process your request as necessary. If we are unable to verify your request, we will notify the requester. California residents have the right to request the following information from the business in writing: (i) a list of categories of personal information disclosed by the business to third parties (including independent affiliated companies as separate legal entities) for direct marketing purposes during the previous calendar year, such as name, address, email address, and type of services provided; and (ii) the names and addresses of all such third parties. Please contact [email protected] to submit your request.

13. Children

This website is not intended for users under the age of 16. We do not knowingly collect any personal information from children under the age of 16. If we discover that an individual who submitted information is under the age of 16, we will remove that information as soon as possible.

14. Changes to this Privacy Policy

We reserve the right to modify, change, or update this policy at any time in our sole discretion, and you agree to be bound by such modifications, changes, or updates. We will notify you of any material changes to this Privacy Policy by posting the revised policy and its revision date on this page. We recommend that you review this Privacy Policy periodically to stay informed of any changes.

15. How to Contact Us