Common use of Cybersecurity; Data Protection Clause in Contracts

Cybersecurity; Data Protection. The Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with the operation of the business of the Company and its subsidiaries as currently conducted, and to the best knowledge of the Company, free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company and its subsidiaries maintain commercially reasonable risk-based controls, policies, procedures, and safeguards to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”) processed and stored thereon, and to the knowledge of the Company, there have been no material breaches, incidents, violations, outages, compromises or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liability, nor any material incidents under internal review or investigations relating to the same. The Company and its subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification.

Cybersecurity; Data Protection. The Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are reasonably believed by the Company to be adequate for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with the operation of the business of the Company and its subsidiaries as currently conductedconducted and, and to the best knowledge of the Company’s knowledge, free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The To the knowledge of the Company, (i) there have been no breaches or violations of (or unauthorized access to) the Company or its subsidiaries’ IT Systems or any personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”) processed or stored by or on behalf of the Company or its subsidiaries, nor are there any pending internal investigations relating to the same, (ii) the Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, procedures and safeguards to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of all personal, personally identifiable, sensitive, confidential or regulated data (“including Personal Data”) processed and stored thereon, and to (iii) the knowledge of the Company, there have been no material breaches, incidents, violations, outages, compromises or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liability, nor any material incidents under internal review or investigations relating to the same. The Company and its subsidiaries are presently in compliance in all material compliance respects with all applicable laws or laws, statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and Data, in each case except as disclosed in the Registration Statement, the Prospectus or the General Disclosure Package or as would not reasonably be expected to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modificationhave a Material Adverse Effect.

Cybersecurity; Data Protection. The Except as would not, individually or in the aggregate, reasonably be expected to have a Material Adverse Effect, (i) the Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are adequate for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with the operation of the business of the Company and its subsidiaries as currently conductedconducted and, and to the best knowledge of the Company, are free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The ; (ii) the Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, and safeguards to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical its IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”)) processed and stored thereonused in connection with their businesses, and to the knowledge of the Company, there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liabilityliability or the duty to notify any other person, nor any material incidents under internal review or investigations relating to the same. The ; and (iii) the Company and its subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification.

Cybersecurity; Data Protection. The Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are reasonably believed by the Company to be adequate in all material respects for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with with, the operation of the business of the Company and its subsidiaries as currently conductedconducted and, and to the best knowledge of the Company’s knowledge, are free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, and safeguards to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”)) processed used in connection with the business of the Company and stored thereonits subsidiaries as currently conducted, and and, to the knowledge of the Company, there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liabilityliability or the duty to notify any other person, nor any material incidents under internal review or investigations relating to the same. The Company and its subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification, except for such failures as would not, individually or in the aggregate, reasonably be expected to have a Material Adverse Effect.

Cybersecurity; Data Protection. The Company Company’s and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are reasonably believed by the Company to be adequate in all material respects for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with with, the operation of the business of the Company and its subsidiaries as currently conductedconducted and, and to the best knowledge of the Company’s knowledge, are free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, and safeguards to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal IT Data”)) processed used in connection with the business of the Company and stored thereonits subsidiaries as currently conducted, and and, to the knowledge of the Company, there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liabilityliability or the duty to notify any other person, nor any material incidents under internal review or investigations relating to the same. The Company and its subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal IT Data and to the protection of such IT Systems and Personal IT Data from unauthorized use, access, misappropriation or modification, except for such failures as could not, individually or in the aggregate, reasonably be expected to have a Material Adverse Effect.

Cybersecurity; Data Protection. The Company and its subsidiariesMaterial Subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are adequate for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with the operation of the business of the Company and its subsidiaries Material Subsidiaries as currently conducted, and to the best knowledge of the Company, free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company and its subsidiaries maintain Material Subsidiaries have implemented and maintained commercially reasonable risk-based controls, policies, procedures, and safeguards designed to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”)) processed and stored thereon, and to the knowledge of used in connection with their businesses. To the Company’s knowledge, there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liability, nor any material incidents under internal review or investigations relating to the same. The Company and its subsidiaries Material Subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authorityauthority and external policies published by the Company, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data (“Data Security Obligation”) from unauthorized use, access, misappropriation or modification, except as would not, singly or in the aggregate, result in a Material Adverse Effect. There is no material action, suit or proceeding by or before any court or governmental agency, authority or body pending alleging material non-compliance with any Data Security Obligation.

Cybersecurity; Data Protection. The Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are adequate for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with the operation of the business of the Company and its subsidiaries as currently conducted, and to the best knowledge of the Company, free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not except in each case, as would not, individually or in the aggregate, reasonably be expected to have result in a Material Adverse Effect. The Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, and safeguards to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”)) processed and stored thereonused in connection with their businesses, and to in the knowledge of the Company, last three years there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liabilityliability or the duty to notify any other person, nor any material incidents under internal review or or, to the knowledge of the Company and its subsidiaries, investigations relating related to the same. The Company and its subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification, except in each case, as would not, individually or in the aggregate, reasonably be expected to result in a Material Adverse Effect.

Cybersecurity; Data Protection. The Company and its subsidiaries’ Company’s information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are adequate for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with the operation of the business of the Company and its subsidiaries as currently conducted, and to the best knowledge of the Company, free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company has implemented and its subsidiaries maintain maintained commercially reasonable risk-based controls, policies, procedures, and safeguards to maintain and protect their its material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”) processed and stored thereonused in connection with its business, and to the knowledge of the Company, there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liabilityliability or the duty to notify any other person, nor any material incidents under internal review or investigations relating to the same. The Company and its subsidiaries are is presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, 1 Note to JPM: removed “no undisclosed liabilities” rep covered by “related party transactions” rep in (zz). rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification, except where the failure to be in compliance would not, individually or in the aggregate, have a Material Adverse Effect.

Cybersecurity; Data Protection. The Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are adequate in all material respects for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with the operation of the business of the Company and its subsidiaries as currently conducted, and to the best knowledge of the Company, free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, and safeguards to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”)) processed and stored thereonused in connection with their businesses, and to the knowledge of the Company, there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liabilityliability or the duty to notify any other person, nor any material incidents under internal review or investigations relating to the same. The Company and its subsidiaries are presently in material compliance with all applicable laws or statutes (including the European Union General Data Protection Regulation) and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification, except as would not reasonably be expected to have a Material Adverse Effect.

Cybersecurity; Data Protection. The Except as would not, individually or in the aggregate, reasonably be expected to have a Material Adverse Effect, the Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are adequate for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with the operation of the business of the Company and its subsidiaries as currently conducted, and to the best knowledge of the Company, free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, and safeguards to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”)) processed and stored thereonused in connection with their businesses, and and, to the knowledge best of the Company’s knowledge, there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to sameany Personal Data, except for those that have been remedied without material cost or liabilityliability or the duty to notify any other person, nor any material incidents under internal review or investigations relating to the samePersonal Data. The Company and its subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification, except in each case as would not, individually or in the aggregate, reasonably be expected to have a Material Adverse Effect.

Cybersecurity; Data Protection. The Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are adequate for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with with, the operation of the business of the Company and its subsidiaries as currently conducted, and to the best knowledge of the Company, free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, procedures and safeguards to maintain and protect their material confidential information and Personal Data (defined below) and the integrity, continuous operation, redundancy integrity and security of all mission critical material IT Systems and the integrity redundancy and risk-based security of Systems. As used herein, “Personal Data” shall refer to all personal, personally identifiable, sensitive, confidential personal or regulated data (“Personal Data”) processed that relates to an identified or identifiable natural person according to applicable law that is maintained by the Company or any of its subsidiaries and stored thereon, and to used in connection with the Company or its subsidiaries’ respective businesses. To the knowledge of the Company, there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses access to samePersonal Data, except for those that have been remedied without material cost or liability, nor any material related incidents under internal review investigation by a governmental or investigations relating to regulatory authority. To the same. The knowledge of the Company, the Company and its subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgmentslaws, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification, and there is no pending, or to the knowledge of the Company, threatened, action, suit or proceeding by or before any court or governmental agency, authority or body alleging non-compliance with any applicable laws, internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of IT Systems and Personal Data from unauthorized use, access, misappropriation or modification.

Cybersecurity; Data Protection. The Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are reasonably believed by the Company to be adequate in all material respects for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with with, the operation of the business of the Company and its subsidiaries as currently conducted, and and, to the best knowledge of the Company, are free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, and safeguards that are reasonably consistent with industry standards and practices, or as required by applicable regulatory standards, to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”)) processed and stored thereonused in connection with their businesses, and and, to the knowledge of the Company, there have been no material breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liability. Except as would not reasonably be expected to have a Material Adverse Effect, nor any material incidents under internal review or investigations relating to the same. The Company and its subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification.

Cybersecurity; Data Protection. The Company and its subsidiaries’ information technology assets and equipment, computers, systems, networks, hardware, software, websites, applications, and databases (collectively, “IT Systems”) are adequate for, and operate and perform in all material respects in conformance with their specifications or contracted requirements as required in connection with the operation of the business of the Company and its subsidiaries as currently conducted, and are, to the best knowledge of the CompanyCompany and its subsidiaries, free and clear of all material bugs, errors, defects, Trojan horses, time bombs, malware and other corruptants, other than those not reasonably expected to have a Material Adverse Effect. The Company and its subsidiaries maintain have implemented and maintained commercially reasonable risk-based controls, policies, procedures, and safeguards to maintain and protect their material confidential information and the integrity, continuous operation, redundancy and security of all mission critical IT Systems and the integrity redundancy and risk-based security of data (including all personal, personally identifiable, sensitive, confidential or regulated data (“Personal Data”)) processed and stored thereonused in connection with their businesses, and to neither the Company nor its subsidiaries have been notified of, and each of them have no knowledge of the Companyany event or condition that could result in, there have been no material any breaches, incidents, violations, outages, compromises outages or unauthorized uses of or accesses to same, except for those that have been remedied without material cost or liabilityliability or the duty to notify any other person, nor any material incidents under internal review or investigations relating to the same. The Company and its subsidiaries are presently in material compliance with all applicable laws or statutes and all applicable judgments, orders, rules and regulations of any court or arbitrator or governmental or regulatory authority, material internal policies and contractual obligations relating to the privacy and security of IT Systems and Personal Data and to the protection of such IT Systems and Personal Data from unauthorized use, access, misappropriation or modification.