Global Privacy Principles

GLOBAL PRIVACY PRINCIPLES

Daniel J. Edelman Holdings, Inc. and its family of companies, which includes Daniel J. Edelman, Inc., StrategyOne, Inc. d/b/a Edelman Intelligence, Zeno Group, Assembly Media, Matter, Inc., United Entertainment Group Holdings, LLC (UEG), The K Group Public Relations Company, d/b/a Krispr Communications, Edible, Inc., Edelman Miami Latin America Corp., The H & W Group, d/b/a Salutem, The R Group Public Relations Company, d/b/a Revere, First & 42nd, Inc., and all operating companies under the Edelman family of companies (collectively referred to as “the Company”) understands the importance of fair information privacy practices in individual privacy. The Company helps its clients maintain and grow their relationships with stakeholders, and a key part of a brand’s relationship with its stakeholders involves a stakeholder’s confidence in the privacy practices associated with the brand. Privacy is good corporate citizenship, and the Company has adopted privacy principles consistent with its leadership position in the industry and applicable laws and regulations. The Company conducts its business (and assists its clients in conducting their businesses) according to the following privacy principles with regard to the collection, use, storage and other processing of personal information, which are designed to identify the personal information that is being processed and ensure that the processing is taking place in a fair and proper manner in accordance with applicable laws and these principles.

Notice

The Company recognizes that individuals should be clearly and reasonably informed as to how personal information is collected, used and/or otherwise processed.

Choice

The Company recognizes that individuals should have the ability to make an informed decision regarding how personal information about them is used/processed, understanding that the collection, use and/or processing of personal information is often a necessary aspect to provide individuals with goods, services and opportunities.

Access, Accuracy, Integrity, and Quality

The Company recognizes that individuals should have the reasonable ability to access the personal information that has been collected from or about them and to correct inaccuracies. The Company should, to the extent practicable, ensure that personal information is accurate, relevant, timely, and complete.

The Company processes personal data for itself and for its clients.   Individuals can contact the Company at compliance@djeholdings.com to request access to the personal data processed by the Company about them.  We may ask for authentication of the request and will take a reasonable amount of time to respond to the request consistent with applicable law.   Please note, however, that certain personal information may be exempt from such access, modification or deletion rights pursuant to applicable data protection laws.

Collection and Processing of Personal Information

The Company strives to collect and process only personal information that is necessary for the purpose for which it is collected.

Security

The Company has adopted and will maintain technical, physical and organizational measures designed to protect personal information in its possession consistent with industry standards and applicable laws and regulations.

Retention of Personal Information

The Company strives to retain personal information for a period of time that is reasonably necessary in order to conduct its business and comply with applicable laws and regulations.

Ethics

The Company will conduct its privacy practices in an ethical and professional manner.

Client Service

As part of its client service, the Company is committed to helping to educate its clients regarding fair information privacy practices generally, and its global privacy principles in particular, and will seek to implement these principles in connection with the work that the Company does for its clients.

Responsibility

All Company employees are responsible for ensuring that the Company follows these principles, and that clients act in a consistent fashion when processing data in connection with Company projects.   The Company’s Global Privacy Officer, the Company’s Global Privacy Steering Committee and any member of the Data Security and Privacy Group may be contacted with questions regarding these principles.

Legal Compliance

The Company will make reasonable efforts to stay informed of applicable privacy and data protection laws and regulations as they continue to evolve in order to maintain legal compliance.

MAY 2018