Privacy Practices and Cookies Policy (May 2026)

EWM Global ( "We," "Us"), provides deferred compensation plan administration services to your employer ("Plan Sponsor"). In doing so we may process certain Personal Data strictly as a Data Processor acting on the Plan Sponsor's instructions. This privacy notice (the "Notice") explains how that Personal Data is collected, used, disclosed, and protected when you access the EWM Global online platform (the "EWM System").

Roles and Responsibilities

The Plan Sponsor is the Data Controller: it determines the purposes and means of processing your Personal Data.

EWM Global acts solely as a Data Processor within the meaning of applicable data protection laws, including:

• The EU General Data Protection Regulation (GDPR)
• The UK General Data Protection Regulation (UK GDPR)
• The Swiss Federal Act on Data Protection (nFADP), and
• Applicable U.S. federal and state privacy laws (as relevant).

And processes your data only in accordance with the Plan Sponsor's documented instructions.

By accessing and using the EWM System, as a Data Subject, you are considered a "User" and a "Plan Participant" under the terms of your deferred compensation plan(s) as prescribed by the Plan Sponsor.

Personal Data processed and purpose of processing

In providing the services, EWM Global may process certain data points relating to you and your employment, such as:

• Identification and contact details (e.g., name, e-mail address, date of birth).
• Employment and plan-related information (e.g., employee ID, business unit, job title, award allocations, vesting schedules).
• Information you voluntarily submit through the System depending upon the plan rules (e.g., award allocation preferences, bank account details, beneficiary information).

For the Mobile App only: unique device identifier, when enabled (to allow push notifications)

Some of these data points may qualify as Personal Data - that is, information relating to an identified or identifiable natural person, as defined under the relevant privacy frameworks noted above.

EWM Global does not determine the purposes or means of data collection and does not engage in any independent or discretionary data processing outside of the service scope defined by the Plan Sponsor. EWM Global does not process Personal Data for marketing, profiling, or any purpose unrelated to the services described above.

Sources of Data

All Personal Data processed within the EWM System is either:

• (a) provided by the Data Controller (your Plan Sponsor) who is responsible for collecting consent from the data subjects, or
• (b) in limited cases, collected directly by EWM Global on behalf of the Data Controller - for example, when a Plan Participant updates their own contact details (such as an email address) within the platform. Such collection is always carried out solely under the instructions of the Data Controller, and only to the extent necessary to fulfill the contractual obligations.

Retention and Disclosure to Third Parties

We retain Personal Data only for as long as necessary to:

• Deliver the contracted services; and
• Comply with applicable legal or contractual obligations.

After the relevant retention period, and in accordance with the Plan Sponsor's instructions, Personal Data is securely irreversibly pseudonymized.

Personal Data is not shared to external third parties unless specifically requested by your Plan Sponsor of by you through your Plan Sponsor (e.g, tax advisors).

Security Measures

We employ appropriate technical and organisational safeguards, including:

• Encryption of data in transit and at rest
• Role-based access controls and multi-factor authentication
• Continuous monitoring, vulnerability management, and regular security reviews

Data Subject Rights

The Plan Sponsor, in its role of Data Controller, shall be the recipient of all requests related to the exercise of Data-Subject rights. EWM Global shall assist the Plan Sponsor in responding in a timely manner.
Please note that certain Personal Data are required for proper administration of the deferred compensation plan. Failure to provide such data may limit or prevent your ability to access or benefit from plan features.

If you believe that any Personal Data displayed in the EWM System is incorrect or if you wish to exercise any rights in relation to your Personal Data, please contact your Plan Sponsor directly. You may contact EWM Global for general inquiries at privacy@ewmglobal.com , but please be aware that we are legally obligated to refer any such requests to the relevant Data Controller before taking any action.

DPO Contact Details:
Luca Cristalli
Talacker 41, 8001, Zurich, Switzerland
privacy@ewmglobal.com
+41 44 913 19 00

Update to this Notice

This Notice is reviewed periodically and may be amended over time. Material changes will be duly communicated to the Plan Sponsor and/or to the Data Subjects prior to taking effect.