ULMER & BERNE LLP WEBSITE PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THIS WEBSITE.

ULMER & BERNE LLP, an Ohio limited liability partnership (the “Company” or “we”), recognizes that privacy is an important issue, so we operate ourselves in a manner consistent with the protection of your privacy. We developed this Privacy Policy pursuant to applicable law regarding the collection and use of Personally Identifying Information (defined below) in those jurisdictions where we do business. This Privacy Policy outlines the types of Personally Identifying Information we gather when you use this website (the “Website”), how we use that information, as well as some of the steps we take to safeguard it. We urge you to read the Privacy Policy in its entirety and hope it will help you make an informed decision about sharing your Personally Identifying Information with us.

The Company reserves the right to change this policy at any time. Please check this page periodically for changes. Your continued use of the Company’s Website following the posting of changes to these terms will mean you accept these changes. The Company will take reasonable measures to notify you if there is a material change in our privacy practices with respect to use of the information you have provided to The Company. The Company will conspicuously post these changes in our Privacy Policy and on our Website. These postings will occur on this Website at least 30 days prior to any material change. If you have any questions about this privacy statement, the Company’s practices, or feel that your privacy has been compromised, please contact us at mmarrero@ulmer.com.

As part of the operation of this Website, certain pieces of information are gathered about the users (individually, a “User” and collectively, “Users”). This privacy policy contains explanations regarding the types of information we, directly or through an affiliate, collect through the Website, what is done with such information, and how to correct or change the information.

GENERAL PRIVACY PRINCIPLES

Accountability:

The Company is responsible for your Personally Identifying Information under its control. The Company has appointed an officer who is accountable for the Company’s compliance with this privacy policy. Michael A. Marrero has been designated the Company’s privacy officer in connection with this privacy policy. Michael A. Marrero can be reached by telephone at 513-698-5078, by e-mail at mmarrero@ulmer.com or by regular mail at 600 Vine Street, Suite 2800, Cincinnati, Ohio 45202-2409.

Identifying Purposes:

“Personally Identifying Information” is information that individually identifies you, such as your name, company name, physical address, phone numbers, e-mail address and any other information that would allow someone to identify or contact you. The Company may ask for your Personally Identifying Information so that we can send you correspondence or legal updates in the future. Of course, you may choose not to provide the Company with Personally Identifying Information. However, this choice may prevent the Company from providing you with legal updates or responding to any of your inquiries. Our server does not automatically record Personally Identifying Information. Such information can become known to the Company via this Website only when you voluntarily submit it.

Consent:

Your knowledge and consent are required for the collection, use, or disclosure of your Personally Identifying Information. No information is collected without your express consent. By submitting Personally Identifying Information to the Company, you hereby consent to the Company’s collection, use and disclosure of the Personally identifying Information that you disclose to the Company.

Limiting Collection:

The Company only collects the information that it needs in order to respond to your inquiries or provide you with legal updates.

Limiting Use, Disclosure and Retention:

The Company does not use or disclose your Personally Identifying Information for purposes other than those for which it was collected, as set forth in this Privacy Policy, or as required by law. Your Personally Identifying Information is retained only as long as necessary for the fulfillment of those purposes or as required by law.

Accuracy:

Your Personally Identifying Information is kept as accurately and completely as is necessary for the purposes for which it is to be used. You have the right to update, modify, amend or correct errors in your Personally Identifying Information by contacting The Company.

Safeguards:

The Company protects your Personally Identifying Information by using safeguards that are appropriate to the sensitivity of the information. Each of our employees who has access to your Personally Identifying Information is informed about our Privacy Policy and procedures for protecting Personally Identifying Information.

The Company undertakes substantial efforts to protect the confidentiality of the identity, preferences and other information it has collected about individual Users and, except as otherwise set forth in this Privacy Policy, will not knowingly allow access to this information to anyone outside the Company as described below under the heading Limits of Confidentiality.

Unfortunately, neither the Company’s network nor data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect User’s information, The Company cannot ensure or warrant the security of member information. Thus, any information a User transmits to us is done so at the User’s own risk.

Openness:

The Company will make its complete policies and practices relating to the management of your Personally Identifying Information readily available to you.

Access:

Upon request in writing, either by e-mail or letter, you will be informed of the existence, use or disclosure of your Personally Identifying Information and you will be given access to that information. The Company will assist any customer who informs us that they need assistance in preparing a request concerning Personally Identifying Information. You may also challenge, in writing either by e-mail or letter, the accuracy and completeness of the information and have it amended as appropriate, or request that the Company delete or correct any Personally Identifying Information contained in your file.

Challenging Compliance:

You may address any challenge concerning our compliance with this privacy policy to Michael A. Marrero at mmarrero@ulmer.com, or by regular mail at 600 Vine Street, Suite 2800, Cincinnati, Ohio 45202-2409.

SPECIFIC PRIVACY POLICY

Scope:

Our privacy policy applies to all websites owned and operated by the Company and to any Personally Identifying Information collected by the Company. It is designed to inform you of when, why, how and for what purpose the Company collects Personally Identifying Information from visitors to its websites. It is also designed to inform you about the types of information that is collected about you at this Website. Finally, it is designed to inform you about our use of Personally Identifying Information collected at the Company websites and to whom access to such Personally Identifying Information may be given. Our privacy policy is also designed to inform you about how you may access, amend, or delete Personally Identifying Information collected by the Company and how you may limit the Company’s use of your Personally Identifying Information.

On occasion, the Company’s websites are connected by “hyperlinks” to other companies’ websites. Please note that the Company is not responsible in any way for the privacy practices of other websites and suggests that you review the privacy policies of those other companies’ websites before using them.

What Types of Personally Identifying Information Does the Company Collect?

On Each Visit to this Website:

The Company collects certain limited non-personally identifying information your browser makes available whenever you visit this Website. This log information includes your Internet Protocol address, browser type, browser language, as well as the date and time of your visit. We use this information to operate, develop, and improve our Website. This information does not include your Personally Identifying Information. Our server does not automatically record Personally Identifying Information. Such information can become known to the Company via this Website only when you voluntarily submit it.

How Does the Company Use Your Personally Identifying Information?

Confidentiality:

Except as set forth under the “Limits of Confidentiality” section below, or otherwise in this Privacy Policy, the Company will not provide Personally Identifying Information about a User to third parties. By requesting additional information or communicating directly with the Company after visiting the Website, a User is choosing to provide the Company with Personally Identifying Information in such User’s sole discretion.

How We Protect Your Information:

The Company may store and process Personally Identifying Information collected on our site on our own servers or on the servers of our Business Partners (defined below). Paper copies containing all or part of the Personally Identifying Information you supply to us may be made and kept in file cabinets as part of the course of normal business activity. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online. We take security measures which we believe to be appropriate to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. We restrict access to your Personally Identifying Information to employees who need to know that information in order to perform their jobs and provide service to you.

Limits of Confidentiality:

If you choose to share your Personally Identifying Information with us we may use it for the purposes of sending you requested information as well as occasional announcements, bulletins and other similar purposes. We also will not give, rent, loan, or otherwise make available your Personally Identifying Information to third parties except in the limited circumstances described in this “Limits of Confidentiality” section, or with your consent.

We may share such information in any of the following limited circumstances:

(i) Transactions with the Company. We may provide your Personally Identifying Information to trusted businesses or persons (“Business Partners”) for the sole purpose of processing or storing personally identifying information on our behalf. These Business Partners include Website developers, internet service providers, as well as other third parties we use to assist us in managing the Website. When we do disclose your information to others, it is subject to agreements that require those parties to process such information only on our instructions, in compliance with this Privacy Policy, and in an appropriate confidential and secure manner.

(ii) Legal Obligation. The Company may disclose aggregate level and/or Personally Identifying Information if such disclosure is required by any legal obligation, whether by law or judicial or regulatory decree.

(iii) Sale or Transfer of Business. We may sell or otherwise transfer such information to a successor of the Company, or any subsidiary or division of the Company in connection with an asset sale, acquisition, merger, consolidation, divestiture, stock sale, purchase of part or all of the assets of the business, or other corporate transaction, or by way of assignment (whether by operation of law or otherwise) in connection with any such or similar transaction or in connection with the administration of a bankruptcy estate. In the case of such event, the Personally Identifying Information will become the property of the successor and will be subject to the successor’s Privacy Policy should they have one.

What about cookies?

A “cookie” is a small file containing a string of characters that is sent to your browser from a web server and stored on your computer hard drive when you visit some websites. We reserve the right to use cookies in connection with this Website. By using this Website, you are providing consent to the Company, or any third party at the direction of the Company, to place cookies on your computer.

Opting-out:

Even after you have granted the Company your consent to collect Personally Identifying Information, you may optout of having your Personally Identifying Information collected by contacting us by e-mail or regular mail. Please note that in order to fulfill certain obligations, we may need to continue sending you notices or other important information. If you wish not to receive targeted legal updates via e-mail from the Company and wish not to have your information shared with third parties as set forth in this policy, you may send an e-mail message to mmarrero@ulmer.com.

Accessing Your Personally Identifying Information Once Given:

You have the right to request information about the existence, use and disclosure of your Personally Identifying Information and to challenge the accuracy and completeness of your Personally Identifying Information, and to have your Personally Identifying Information amended where inaccurate or deleted from the Company’s database. To do so, simply e-mail the Company at theggen@ulmer.com, or write to the Company at 1660 West 2nd Street, Suite 1100, Cleveland, OH 44113-1448. On each e-mail you receive from the Company, you will be given the opportunity to unsubscribe from further e-mails, thereby removing your e-mail address permanently from our mailing list.

Changes to this Policy:

Please note this Privacy Policy is subject to change from time to time without specific notice. We expect most such changes to be minor, but there may be changes that are more significant. Regardless, we will post those changes on this page and, if the changes are significant, we will also provide a more prominent notice. Each version will be noted at the top of the page. Prior versions of this Privacy Policy will be kept in an archive for you to view for a reasonable period of time.

Contact Information:

If you have any additional questions about this privacy policy, feel that information we have collected about you is incorrect, or wish to opt-out of future e-mails, please feel free to contact us at any time.

Date of last update: August 23, 2013 2025219.1