DebtX European Union Privacy Policy

Effective March 31, 2006

The Debt Exchange, Inc. (collectively,"DebtX" or the "Company") adheres to the Safe Harbor Agreement concerning the transfer of personal data from the European Union to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce ("Principles") with respect to all such data. This statement outlines our general policy and practices for implementing the Principles, including the types of information DebtX is in contact with, how we use it, and the choices affected individuals have regarding our use of, and their ability to correct, that information. If there is any conflict between the policies in this statement and the Principles, the Principles will govern.

The Principles apply to information that pertains to an identifiable individual residing in the European Union ("EU Personal Data") which DebtX receives either directly from such individuals or pursuant to its performance of services for its clients situated in the European Union ("EU Clients"). The Principles do not apply to: (a) data collected and used by DebtX which is not EU Personal Data; (b) or the subsidiaries of DebtX who do not receive EU Personal Data.

DebtX acquires EU Personal Data in the following ways:

• Directly from inviduals at institutions that are interested in registering as sellers of assets on the DebtX platform ("Sellers");
• Directly from individuals at institutions that are interested in buying assets via the DebtX platform ("Buyers");
• Debt-related data is sent to DebtX for processing directly from EU Clients or from their agents which may contain EU Personal Data ("Client Data")

With regards to data gathered regarding Sellers and Buyers, we notify individuals about the personal information we collect from them, how we use it, and how to contact us with privacy concerns. This information is set out in our privacy policy, available on our website at http://www.debtx.com/Corporate/Security/Privacy.asp. We collect personal information from individuals only as permitted by the Principles or with the consent of the individual affected. Consent for personal information to be collected, used, and/or disclosed in certain ways may be required in order for an individual to obtain or use our services. To the extent permitted by the Safe Harbor Agreement, we reserve the right to process personal information in the course of providing professional services to our clients without the knowledge of individuals involved.

With regards Client Data, DebtX is acting in accordance with instructions from its EU Clients as set out in its agreements with such clients. Under these agreements, the EU Client is responsible for providing notice to its customers as to what data will be collected and for what purpose the data will be used. The EU Client is also responsible for receiving consent, if required, based on such notice.

DebtX uses Seller and Buyer data for the following purposes:

• Buyers – to identify institutions that may be interested in reviewing specified assets
• Sellers – to allow individuals access to the platform to review their own data.

With regards to Client Data, DebtX uses this data to perform its obligations under its EU Client agreements:

• The negotiation of the sale of debt assets to qualified buyers
• The processing of due diligence material related to asset sales.

To provide the above services, DebtX will disclose Client Data to Buyers, but only if authorized to do so in the EU Client agreement and only where Buyers are within the scope of the agreement with the EU Client. Before disclosing Client Data to a Buyer, DebtX assures itself that it is: (a) a Safe Harbor certified company; (b) situated in the EU or a jurisdiction which is recognized by an adequacy finding of the EU data protection authorities; or (c) bound by a written agreement with DebtX regarding data privacy protection.

As a result of legal requirements, DebtX may be required to provide personally identifiable information to authorized organizations in order to comply with legally mandated reporting or process requirements.

DebtX is committed to ensuring that EU Personal Data received from its EU Buyers, EU Sellers, and EU Clients is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction while it is under the control of DebtX, its affiliates or agents.

DebtX's processing technologies and operations employ a wide range of security measures including: physical, electronic, and procedural safeguards; sophisticated security monitoring tools; documented security policies; use of encryption and/or private leased lines for transmissions of EU Personal Data to and from EU Clients; restricted access of personally identifiable information only to those of its employees that need to know the information; and, periodic security audits by internal audit group and third party security experts.

Buyers and Sellers can contact DebtX to view and correct their data either on-line, by phone or in writing.

An individual who's data is included in Client Data, and who wishes to access any of his or her EU Personal Data that is in DebtX' possession may contact the EU Client to which he or she submitted the data and request access. On receipt of an access request from the EU Client, DebtX will provide access except where the burden or expense of providing the access would be disproportionate to the risks to the individual's privacy or where the rights of a person other than the individual would be violated by such access.

If the EU Client advises DebtX that the information pertaining to an individual is found to be inaccurate, DebtX will correct, amend or delete it as directed by the EU Client.

DebtX has an internal audit group which audits the Company's compliance with this policy and its Safe Harbor commitment.

An individual who's data is included in Client Data, and who has a complaint or dispute should contact the EU Client who provided the data to DebtX. If after contacting the EU Client, the individual's complaint or dispute has not been resolved, s/he can contact the International Centre for Dispute Resolution of the American Arbitration Association at www.adr.org. This organization will provide independent dispute resolution and, should it determine it appropriate, it can also assess sanctions, including damages, for violation of the Principles.

A Buyer or Seller who has a complaint or dispute should contact DebtX. If after contacting DebtX, the individual's complaint or dispute has not been resolved, s/he can contact the International Centre for Dispute Resolution of the American Arbitration Association at www.adr.org. This organization will provide independent dispute resolution and, should it determine it appropriate, it can also assess sanctions, including damages, for violation of the Principles.

If you have any questions about the Principles or the Safe Harbor practices of DebtX, please contact us at +1-617-531-3400, or write to:

The Debt Exchange, Inc.
Attention: General Counsel
133 Federal Street, 10th Floor
Boston, MA 02110
U.S.A.