This Data Privacy Framework Policy (“Policy”) describes how Engage2Excel, and each of its affiliated entities E2E Holdings, The Tharpe Company Inc., Rideau Recognition Inc, Hinda Inc., The Robbins Company, Rideau Europe Limited, Rideau Recognition Solutions Inc, Vistance Technology Solutions Inc., Rideau Technology Services India Private Limited collects, uses, and discloses certain data about an identified or identifiable individual that we receive in the United States (“U.S.”) from the European Economic Area (“EEA Personal Data”), the United Kingdom and Gilbraltar (“UK Data”),and Switzerland (“Swiss Personal Data”). In this Policy, countries that are members of the European Economic Area are collectively referred to as the “EU”. This Policy supplements the Engage2Excel Privacy Policy located https://www.engage2excel.com/privacy_policy/, and unless specifically defined in this Policy, the terms in this Policy have the same meaning as in the Engage2Excel Privacy Policy.

Engage2Excel recognizes that the EU, the UK, and Switzerland have established strict protections regarding the handling of EU, UK and/or Swiss Personal Data, including requirements to provide adequate protection for EU, UK and/or Swiss Personal Data transferred outside of the EU and Switzerland. To provide adequate protection for certain EU and/or Swiss Personal Data relating to website visitors, customers, prospective customers, partners, vendors, third party suppliers and contractors that Engage2Excel receives in the U.S., Engage2Excel complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Engage2Excel has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Engage2Excel has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

DPFDPF Engage2Excel adheres to the DPF Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.

For purposes of enforcing compliance with the Data Privacy Framework, Engage2Excel is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.

Types of EU and/or Swiss Personal Data Collected
Engage2Excel collects EU, UK and/or Swiss Personal Data (i) from individuals who visit our website and voluntarily provide their information, and (ii) from our customers, vendors, contractors and agents, including the following specific types of information:

• Contact information, including name, address, email address and phone number
• Professional and employment information
• Financial information

Engage2Excel also collects certain data that may not specifically identify an individual but relate to an individual’s visit to our site, including information about equipment, browsing actions and usage patterns. This data is used for internal purposes only.

Purposes of EU, UK and/or Swiss Personal Data Collection and Use
Engage2Excel collects, uses and processes EU, UK and/or Swiss Personal Data for the purposes of:

• Providing information about our products, services and events
• Providing products, services and support to our customers
• Administrative purposes relating to processing transactions with our customers
• Communicating with business partners, vendors, agents and contractors about business matters
• Analysis of information in order to improve business practices, products and services
• Conducting related tasks for legitimate business purposes
• Other purposes disclosed at the time of collection
• Compliance with legal requirements and protection of rights and property

Engage2Excel will only process EU, UK and/or Swiss Personal Data in ways that are compatible with the purpose for which Engage2Excel collected the EU, UK and/or Swiss Personal Data, or for purposes that the individual or entity providing the EU, UK and/or Swiss Personal Data later authorizes. Before we use your EU, UK and/or Swiss Personal Data for a purpose that is materially different than the purpose for which it was collected or that you later authorized, we will provide you with the opportunity to opt out. Engage2Excel maintains reasonable procedures to help ensure that EU, UK and/or Swiss Personal Data is reliable for its intended use, accurate, complete, and current.

We may collect, or our customers may provide to us when using Engage2Excel services, certain EU, UK and/or Swiss Personal Data that is regarded as “sensitive”. When we directly collect sensitive EU, UK and/or Swiss Personal Data, we will obtain opt-in consent where the DPF requires, including if we disclose sensitive EU, UK and/or Swiss Personal Data to third parties, or before we use sensitive EU, UK and/or Swiss Personal Data for a different purpose than we collected it for or than the data subject later authorized.

In furtherance of the DPF principles, Engage2Excel will only use your personal data if we have a proper reason for doing so. We will take reasonable steps to ensure that personal data is reliable for its intended use, accurate, complete and current. We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information, and in most cases we use the purpose for which we collected the personal information to determine the length of time that we need to retain it. In some instances, such as when required by law or authorized by you, we may retain the information for a longer period. We will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to conclude that the purposes for which that information is in our possession are no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. We will take due care when destroying personal information so as to prevent unauthorized access to the information.

Engage2Excel may disclose your personal information to our service providers with whom we have a contract to process your personal information for a specific business purpose, such as to help us provide our services to you, to deliver to you the product that you selected, or to protect or improve our website. We contract with our service providers to use reasonable and appropriate security measures when processing your personal data.

Automated decision-making takes place when an electronic system uses personal data to make a decision relevant to you without human intervention. We may process automated decision-making in the following circumstances:

• Where we have notified an individual of the decision and given that individual 21 days to request a reconsideration;
• Where it is necessary to perform the contract with an individual and appropriate measures are in place to safeguard that individual’s rights; or
• In limited circumstances, with an individual’s explicit and informed consent and where appropriate measures are in place to safeguard that individual’s rights.

We will not make any decision that would significantly affect an individual based solely on processing by automated means, unless we have taken measures to protect the legitimate interests of that individual. If decisions are made by automated means, the individual has the right to know the logic involved in that decision-making.

Data Transfers to Third Parties
Third Party Agents or Service Providers. We may transfer EU, UK and/or Swiss Personal Data to our third party agents or service providers that perform functions on our behalf. Where required by the DPF, we enter into written agreements with those third party agents and service providers requiring them to provide the same level of protection that the DPF requires and limiting their use of the data to the specified services provided on our behalf. We take reasonable and appropriate steps (i) to ensure that third party agents and service providers process EU, UK and/or Swiss Personal Data in accordance with our DPF obligations and (ii) to stop and remediate any unauthorized processing. Under certain circumstances, we may remain liable for the acts of our third party agents or service providers that perform services on our behalf for their handling of EU, UK and/or Swiss Personal Data that we transfer to them.

Third Party Data Controllers. In some cases, we may transfer EU, UK and/or Swiss Personal Data to unaffiliated third party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your EU, UK and/or Swiss Personal Data to third party data controllers for the following purposes:

• To facilitate provision of services to Engage2Excel customers, Engage2Excel may provide EU, UK and/or Swiss Personal Data to third party software and services companies whose products interact with Engage2Excel products and services in certain instances where an Engage2Excel customer is also a client of such third party.

We will only provide your EU, UK and/or Swiss Personal Data to third party data controllers where you have not opted-out of such disclosures. We enter into written contracts with any unaffiliated third party data controllers requiring them to provide the same level of protection for EU, UK and/or Swiss Personal Data that the DPF requires. We also limit their use of your EU, UK and/or Swiss Personal Data so that it is consistent with any consent you have provided and with the notices you have received. If we transfer your EU, UK and/or Swiss Personal Data to one of our affiliated entities within our corporate group, we will take steps to ensure that your EU, UK and/or Swiss Personal Data is protected with the same level of protection that the DPF requires.

Disclosures for National Security or Law Enforcement
Under certain circumstances, we may be required to disclose your EU, UK and/or Swiss Personal Data in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

Security
Engage2Excel maintains reasonable and appropriate security measures to protect EU, UK and/or Swiss Personal Data from loss, misuse, unauthorized access, disclosure, alteration, or destruction in accordance with the DPF.

Access Rights
You may have the right to access the EU, UK and/or Swiss Personal Data that we hold about you and to request that we correct, amend, or delete it if it is inaccurate or processed in violation of the DPF. These access rights may not apply in some cases, including where providing access is unreasonably burdensome or expensive under the circumstances or where it would violate the rights of someone other than the individual requesting access. If you would like to request access to, correction, amendment, or deletion of your EU, UK and/or Swiss Personal Data, you can submit a written request to the contact information provided below. We may request specific information from you to confirm your identity. In some circumstances we may charge a reasonable fee for access to your information. If your EU, UK and/or Swiss Personal Data was provided to us by an Engage2Excel customer, we may facilitate your access to such data by directing you to the customer that provided your data to us.

Questions or Complaints
You can direct any questions or complaints about the use or disclosure of your EU, UK and/or Swiss Personal Data to us as noted below (Contact Us). We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your EU, UK and/or Swiss Personal Data within 45 days of receiving your complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact the European Union Data Protection Authorities (“DPAs”), the UK Data Protection Authorities (the “UK DPA”), or the Swiss Federal Data Protection and Information Commissioner (“FDPIC”).

Dispute Resolution
If you believe that we may be processing data about you and wish to have access to that information, we can provide you with that data or at least an explanation of why we cannot do so in the particular context, such as if responding to the request would be unreasonably expensive.

Please also let us know if you have any questions, concerns, disputes, or issues. We are open to dialogue to resolve issues. If your concerns cannot be resolved, we can enter into appropriate third-party neutral dispute resolution. If you need to reach us about a privacy or data protection issue, please contact us using the contact information below.

In compliance with the DPF Principles, Engage2Excel commits to resolve DPF Principles-related complaints about our collection or use of your personal information. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, or the Swiss-U.S. DPF should first contact Engage2Excel at: us-privacy@Engage2Excel.com.

For personal data that is not human resources data, Engage2Excel has further committed to refer unresolved DPF complaints to:

VeraSafe US
100 M Street S.E., Suite 600
Washington D.C., 20003, USA
Phone: 1-888-376-1079

VeraSafe EU VeraSafe EU
Klimentská 46
Prague 1, 110 02, Czech Republic
Phone: +1-617-398-7067

VeraSafe Ireland
Unit 3D North Point House
North Point Business Park
New Mallow Road
Cork, T23AT2P, Ireland

VeraSafe is an alternative dispute resolution provider based in the United States, the European Union, the United Kingdom, and/or Switzerland (as applicable). If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/ for more information or to file a complaint. The services of VeraSafe are provided at no cost to you.

If neither Engage2Excel nor VeraSafe, as applicable, resolves your complaint, you may have the ability under certain circumstances to engage in binding arbitration through the DPF Panel. Additional information on the arbitration process is available on the DPF website at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

Engage2Excel has further committed to cooperate with the panel established by the EU and UK data protection authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved DPF complaints concerning data transferred from the EU and Switzerland which involves human resources personal information or information collected in the context of an employment relationship if that information is transferred from the EU, the UK or Switzerland (as applicable) to the US. If neither Engage2Excel nor DPAs or FDPIC, as applicable, resolves your complaint, you may have the ability to engage in binding arbitration through the DPF Panel. Additional information on the arbitration process is available on the , DPF website at https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

Contact Us
If you have any questions about this Policy or would like to request access to your EU, UK and/or Swiss Personal Data, please contact us as follows:

Engage2Excel
Attn: Data Compliance Department
115 Corporate Center Drive, Suite E,
Mooresville, North Carolina 28117 USA

us-privacy@Engage2Excel.com

Changes To This Policy
We reserve the right to amend this Policy from time to time consistent with the DPF’s requirements.

Effective Date: 6/20/2024