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Privacy Policy

Last updated: March 13, 2026

Introduction

This privacy policy (“Privacy Policy”) describes the types of information Newfront Insurance Services (“Newfront” or “we”) may collect from you or that you may provide when you visit www.newfront.com and all pages within that domain (our "Website”) or other Newfront-managed webpages where this Privacy Policy is posted; information we receive from your employer, our client (“Client”) on your behalf as part of our provision of services to that Client; and information we collect from you or receive on your behalf from the Client in connection with our mobile application, Navigator™ platform, BenefitsU™ sites, Benji™, or other applications (collectively, the “Services”). This Privacy Policy details our practices for collecting, using, maintaining, protecting, and disclosing that information. For the purpose of this Privacy Policy, “Personal Information” means information that identifies or can identify you personally.

This Privacy Policy does not apply to the websites of our affiliates or to the practices of our clients or third parties, who maintain their own respective privacy policies.

Please read this Privacy Policy carefully to understand our practices regarding your Personal Information. By accessing or using the Services, you are giving Newfront your consent to collect, use, and disclose your information as described in this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

On January 27, 2026, the transaction between WTW and Newfront formally closed. While the transaction itself is now complete, we are actively working to align and integrate the operational, technological, legal, compliance, privacy, security, and other aspects of the respective organizations.

We want to assure our clients that this integration is being carried out in a structured and deliberate manner designed to support continued growth and innovation across both legacy entities, while ensuring ongoing compliance with applicable laws, regulatory requirements, and existing contractual obligations. During the integration period, each entity continues to operate in accordance with its existing policies, controls, and governance frameworks, as appropriate. At this time, there has been no material change to how client data is accessed, processed, or protected as a result of the transaction.

We anticipate achieving substantial integration by the end of 2026, which is expected to include, to the extent permitted by applicable laws and contractual commitments, the sharing of employee and client information across the integrated organization consistent with industry standard security and data privacy practices.

For more information about WTW and its privacy and security commitments, please review the WTW Global Website Privacy Notice available here: https://www.wtwco.com/en-us/notices/global-website-privacy-notice.

This statement includes forward-looking information regarding integration activities and anticipated outcomes. Such statements are based on current expectations and assumptions and are subject to risks and uncertainties that could cause actual outcomes to differ materially. No assurance can be given as to the timing, scope, or results of integration activities, and no obligation is undertaken to update this statement except as required by applicable law or contractual obligation.

How Do We Collect Your Personal Information?

We collect information from you and about users of our Website in the following ways:

1. Directly from you when you voluntarily provide it to us using this Website.
2. Through automated means as you navigate through the Website.

Information Voluntarily Provided Directly by You:

In the course of using this Website, you may choose to provide us with information to help us meet your needs. For example, you may enter your information on our “Contact” page with your name, e-mail address, telephone number, street address, and/or any other information you voluntarily enter in order to request information. In the alternative, you may also complete a registration for an event and provide us with your contact information, employment details and title, as well as communication preferences.

Information Collected Through Automated Means:

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including details of your visits to our Website, including the resources that you access and use on the Website as well as other communication data.

The data collection technologies we use include cookies and web beacons. Cookies are small pieces of text that a website places on your computer to help remember information about your visit. Web beacons are tiny graphics with a unique identifier that are embedded invisibly on the web pages.

We use information collected from cookies and web beacons to improve your experience and the overall quality of our services. We may also use cookies and web beacons to collect information from third parties (such as online search engines) to help advertise our products and services, to analyze the effectiveness of our marketing or the performance of this Website, and to determine whether you may be interested in other products or services.

Neither cookies nor web beacons can read data off your computer's hard drive or collect your personal information. You can refuse to accept and delete cookies by adjusting your browser settings. You can also opt-out of our use of certain cookies by adjusting your . To learn more, please refer to our Cookies notice.

How Do We Use the Personal Information We Collect?

We use the Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. For example, if your employer provided your name to receive medical benefits, we will use that information as part of a submission to an insurance carrier.

• To provide you with information, products or Services that you or your employer request from us.

• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you or to host corporate events on behalf of Newfront.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.

• To improve our Website and present its contents to you, including to gather your feedback or survey responses.

• For testing, research, analysis and product development.

• As necessary or appropriate to protect the rights, property or safety of us, our Clients or others.

• To maintain network security and performance and protect against cyber incidents.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations

• As otherwise described to you at the point of collection or pursuant to your consent.

• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

Newfront is a technology and data-driven company, and we use data to develop innovative products and deliver cutting-edge services. Newfront takes steps designed to ensure that your data is protected through the use of aggregated or otherwise de-identified data. Newfront will retain Personal Information in accordance with our data retention policies, legal, and regulatory obligations.

Personal Information We Collect

The categories of Personal Information we collect, the business purposes (from the list above) for which the information may be used and the categories of third parties to whom we have disclosed information to include:

With Whom Do We Share Your Personal Information?

We will not disclose, share, sell, or otherwise use your Personal Information without your consent, except to the extent required by law, in accordance with your instructions, or as identified in this Privacy Notice. We may share your Personal Information with:

Client Companies: We may share the Personal Information of our Clients’ employees or information derived from that Personal Information with the Clients as part of the Services provided to the Client. This information includes employee utilization and other measurements of adoption or performance of the Services.

Insurance and Financial Services Entities: In order to deliver some of our Services, we are required to receive and transmit certain Personal Information to Insurance and financial services entities, such as to obtain quotes for employee benefits programs.

Marketing Service Providers: We may use marketing agencies for ad network purposes or for communication and client engagement. For example, Personal Information input into an event registration form on our Website may be shared with our marketing service providers.

Platform- or Infrastructure-as-a-Service and other Service Providers: We sometimes contract with other companies and individuals to perform functions or services for us or on our behalf, such as hosting this Website, providing the infrastructure that powers our platforms and applications, sending e-mail messages, providing back-office support, and handling phone calls. They may have access to Personal Information (as set forth above) needed to perform their functions, but are bound by contractual confidentiality obligations and are restricted from using Personal Information for any reason other than those defined in our contract.

Business Transfers: To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us is among the assets transferred.

Legal Matters: We may preserve, and have the right to disclose any information about you or your use of this Website, without your prior permission if we have a good faith belief that such action is necessary to: (a) protect and defend the rights, property, or safety of Newfront or its affiliates, other users of this Website, or the public; (b) enforce the terms and conditions that apply to use of this Website; (c) respond to claims that any content violates the rights of third parties; (d) respond to claims of suspected or actual illegal activity; (e) respond to an audit or investigate a complaint or security threat; or (f) comply with applicable law, regulation, legal process, or governmental requests.

What Do We Do to Protect Your Personal Information?

Newfront has taken reasonable steps to implement physical, administrative, and technical safeguards designed to protect your Personal Information from unauthorized access, use, or disclosure. For more information about Newfront’s security controls, access our Trust Center.

Third Party Sites

The Services may include links to other sites operated by third party organizations. If you access another organization’s site using a link provided, the other organization may collect information from you. Once you have left this Website or any Newfront application through a third party link, you should refer to those sites' policies and terms of use. Newfront is not responsible for the content or privacy practices of linked sites.

Personal Information of Minors

This Website and Newfront’s applications are not intended for use by children, and we do not knowingly collect, use, or disclose information of children under the age of sixteen (16) without the consent of their parents or legal guardians. For employees of our Clients who enroll dependents in insurance, Newfront will collect Personal Information that you provide about your dependents solely for the purpose of obtaining benefits.

Cookies Notice

Updated: July 7, 2025

We use different types of cookies to optimize your experience on our Website. Cookies are pieces of information shared between your web browser and a website. Some cookies are necessary for making the website work. Some help us assess and improve its performance. We also use cookies to help provide relevant content, products and services to you. A cookie cannot read data from your computer's hard drive.

Different Kinds of Cookies We May Use:

• Session cookies: these cookies are only stored on your computer during your web session. They are automatically deleted when the browser is closed. They usually store an anonymous session ID allowing you to browse a website without having to log in to each page. They do not collect any information from your computer

• Persistent cookies: these cookies are stored as a file on your computer and remain there when you close your web browser. These cookies allow the party that set them to recognize your computer when it visits our Website or when it visits certain other sites

• First-party cookies: these cookies are created by our Company. They are stored and sent between our servers and your computer’s hard drive. These cookies may be either Session or Persistent cookies

• Third-party cookies: these cookies are created by one of our third-party partners. They are stored and sent between the third-party’s server and your computer’s hard drive. These cookies are usually Persistent cookies and enable third party features or functionality to be provided on or through the Website (e.g., advertising, interactive content, or analytics).

Different Purposes of Cookies:

Depending on the page, we may use cookies for the following purposes:

• Where Strictly Necessary: These essential cookies are necessary to enable you to use our Website’s features. Without these cookies, services you have asked for, such as obtaining a quote or logging into your account, cannot be provided. These cookies do not gather information about you that could be used for marketing purposes or recording where you have been on the internet.

• Performance and Functionality Cookies: These cookies allow our Website to remember choices you make and provide enhanced features, such as auto-logon. They may also be used to provide services you have requested such as receiving updates or information from a query. The information these cookies collect is usually de-identified. They do not gather any information about you that could be used for advertising or remember where you have been on the internet.

• Analytics: These cookies collect information about how many visitors use our Website, how they use the Website, whether there are any inefficiencies in the site structure, or whether there are web page error messages. This information is used to improve the way that our Website works.

• Advertising Cookies: These cookies are used for the purpose of displaying advertisements that will be relevant to you and for managing the performance of advertisements. Advertising cookies are generally third-party cookies and may be present even if there are no visible advertisements on the Website.

How to Control Cookies and Other Tracking Technologies

• Cookies: You can update your preferences to restrict collection of certain cookies at this link.

• Browser: You may also restrict cookies using your web browser controls, which vary by browser. Visit your browser’s help menu for additional information.

• Web beacons: In most instances, web beacons are dependent on cookies. By adjusting your cookies preferences to restrict cookies, you will also restrict web beacons with dependency on those cookies.

Changes to Our Cookies Notice

We reserve the right to amend this cookies policy at our discretion and at any time. When we make changes to this policy, we will update this notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Website and update the notice's effective date. Your continued use of the Services following the posting of changes constitutes your acceptance of such changes.

Applicability of This Privacy Policy to International Users

This Privacy Policy is crafted and provided in accordance with and subject to U.S. law. If you access the Services from a location outside of the United States, you agree that your use of the Services is subject to the terms of this Privacy Policy. You also agree and accept that your Personal Information will be transferred to and processed in the U.S. in accordance with U.S. law, and not the specific laws of the country where you reside.

Privacy Policy for California Residents

This Privacy Policy for California Residents supplements the information contained in our Privacy Policy and applies to all visitors, users, and others who reside in the State of California ("consumers" or "you").

In particular, our Website has collected the following categories of Personal Information from consumers within the last twelve (12) months:

Categories of information collected from you:

For details about the categories of your Personal Information we collect, the business purposes for such collection, and the categories of third parties who may access that information, click here.

What Are Sources of Personal Information?

We may receive Personal Information from you from you, your employer (our Client), or from the following sources:

• From you, through direct interactions, including forms.
• Internet websites, through passive collection of information about your interactions, including page clicks, time spent, or other automatically collected metadata.
• Internet cookies. For more information, see our Cookies Notice.
• Advertising networks.
• Internet service providers.
• Data analytics providers.
• Operating systems and platforms.
• Search terms.
• Data brokers or resellers.
• Social media services, like Instagram or Facebook.
• Government databases.

How Do We Use the Personal Information We Collect and With Whom Do We Share It?

Click here for an explanation of how we use Personal Information.

Click here for an explanation of who may have access to your Personal Information.

Your Rights as a California Resident

Under California law, some California residents have specific rights regarding their Personal Information, described below. When required and for any information provided directly to us by you, we will respond to most requests within 45 days, unless it is reasonably necessary for us to extend our response time. However, for any Personal Information provided to us by our Client on your behalf, or at the Client’s direction on your behalf, you will need to direct your request to your employer.

Right to Know and Data Portability

You have the right to request that We disclose to you any of the information below, provided that you submit a valid and verifiable request:

• The categories of Personal Information we have collected about you in the last 12 months (also called a data portability request).
• The categories of sources for the Personal Information we have collected about you in the last 12 months.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information we collected about you.
• If we sold your Personal Information for a business purpose, a list of the Personal Information types that each category of recipient purchased.
• If we disclosed your Personal Information to a third party for a business purpose, a list of the Personal Information types that each category of recipient received.

Right to Delete Personal Information

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. If you submit a valid and verifiable request and we can confirm your identity and/or authority to make the request, we will determine if retaining the information is necessary for us or our service providers to:

• Complete a transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

• Debug products to identify and repair errors that impair existing intended functionality.

• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;

• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

• Comply with a legal obligation; and/or

• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If none of the above retention conditions apply, we will delete your Personal Information from our records to the extent we are able in accordance with our legal and regulatory compliance obligations and direct any applicable service providers to do the same.

Right to Correct

If you believe any Personal Information collected by this Website is inaccurate, you have the right to submit a verifiable request that the Company correct the information.

Right to Limit Use

As a California resident, you also have the right to restrict sensitive Personal Information use and disclosure for the same. We do not collect “protected classification characteristics” of Personal Information as defined under California law using this Website.

How to Exercise These Rights

To exercise your rights described above, please submit a verifiable consumer request to us as follows:

• Email: privacy@newfront.com

A “verifiable consumer request” means a request that provides sufficient information to enable us to reasonably verify you and fulfill your request. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Examples of information necessary include:

• Confirmation of certain pieces of information about you, such as phone number and address;
• Proof of identity;
• Detail to allow us to understand, evaluate, and respond to your request.

Only you or a person legally authorized to act on your behalf may make a verifiable consumer request related to your Personal Information. You may make a verifiable consumer request for access or deletion no more than twice within a 12-month period. You will not be required to create an account with us in order to submit a verifiable request, though we may communicate with you about your request via a pre-established account if applicable.

Do Not Sell My Personal Information

Although we do not sell your Personal Information, you have the right to opt-out of sharing Personal Information for cross-context behavioral advertising purposes, also known as “targeted advertising.” Personal Information related to targeted advertising is generally collected through the use of third party cookies. To opt-out of sharing your personal information for cross-context behavioral advertising purposes, you can adjust your Website preferences. For more information about cookies, see our Cookies notice.

Non-Discrimination

We will not discriminate against you for exercising any of your rights under California law. Unless permitted by law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Notice at Collection

By completing a “Schedule a Consultation” request form, you acknowledge that Newfront is collecting your Personal Information to support its business operations, including to contact you at your request. We will not share or sell this contact information and will retain such information in accordance with our data retention policies and regulatory obligations.

Privacy Policy for EU Citizens

This Privacy Policy for European Union citizens supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who are citizens of the EU, regardless of physical location ("consumers" or "you").

How Do We Use the Personal Information We Collect and With Whom Do We Share It?

Click here for an explanation of how we use Personal Information.

Click here for an explanation of who may have access to your Personal Information.

In addition to the partners listed above, we may transfer certain Personal Information across geographical borders to Newfront partners through the Worldwide Broker Network (WBN), authorized service providers or business partners in other countries working on our behalf in accordance with applicable law. Our affiliates and third parties may be based locally, or they may be overseas some of which have not been determined by the European Commission to have an adequate level of data protection.

When we do, we use a variety of legal mechanisms to help ensure your rights and protections travel with your data:

• We seek to cover applicable data transfers with agreements based on the EU Commission’s standard contractual clauses, which contractually oblige each member to ensure that Personal Information receives an adequate and consistent level of protection wherever it resides within Newfront;
• where we transfer your Personal Information outside Newfront or to third parties who help provide our products and services, we seek to obtain contractual commitments from them to protect your Personal Information. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Information transferred from within the EU to the United States, or the standard contractual clauses; or
• where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Information are disclosed.

If you would like further information about whether your information will be disclosed to overseas recipients, please contact us as noted below. You also have a right to contact us for more information about the safeguards we have put in place (including a copy of relevant contractual commitments, which may be redacted for reasons of commercial confidentiality) to ensure the adequate protection of your Personal Information when this is transferred as mentioned above.

Your Rights Under GDPR

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your Personal Information.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

You can exercise your rights by contacting us. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfill your request.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

• Right to Access: You have right to access Personal Information which Newfront holds about you. If you have created a profile, you can access that information by visiting Newfront Connect.

• Right to Rectification: You have a right to request us to correct your Personal Information where it is inaccurate or out of date.

• Right to be Forgotten (Right to Erasure): You have the right under certain circumstances to have your Personal Information erased. Your information can only be erased if your data is no longer necessary for the purpose for which it was collected, and we have no other legal ground for processing the data.

• Right to Restrict Processing: You have the right to restrict the processing of your Personal Information, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or

• the processing is unlawful, but you do not want it erased; or

• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or

• you have exercised the right to object, and verification of overriding grounds is pending.

• Right to Data Portability: You have the right to data portability, which requires us to provide Personal Information to you or another controller in a commonly used, machine readable format, but only where the processing of that information is based on (i) consent; or (ii) the performance of a contract to which you are a party.

• Right to Object to Processing: You have the right to object to the processing of your Personal Information at any time, but only where that processing has our legitimate interests as its legal basis. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

• Right to Decline Automated Decision Making: You have the right to not be subject to decisions based solely on automated decision making, which produce legal or significant effects for you, except where these are (i) necessary for a contract to which you are a party; (ii) authorized by law; (iii) based on your explicit consent.

Privacy Notice to Candidates Applying to Newfront

Updated July 9, 2025

Notice to Candidates

If you’re interested in applying to Newfront, please read this notice (“Candidate Notice”). Newfront is obligated under certain data privacy laws, including California Civil Code Sec. 1798.100 et seq. and Sec. 1798.145(m)(3) (CCPA), to provide candidates for employment (“Candidates,” “you,” “yours,” or “your”) with notice about how we collect and use your personal information, as well as how you can access and correct certain information that we may collect. This Notice applies to information obtained by Newfront or disclosed to Newfront in connection with the online application process, correspondence with Newfront or its agents, and through other personal communications with Newfront or its agents, including but not limited to interviews. This Notice does not constitute or form part of an offer of employment or a contract for employment with Newfront.

Categories of Personal Information We Collect

Newfront may collect the personal information categories detailed below, as permitted under applicable law and in connection with your candidacy. To the extent you decide to withhold certain personal information, note that insufficient personal information may hinder Newfront’s ability to thoroughly evaluate and consider your candidacy.

Sources of Personal Information

We collect personal information from you during the application process, along with other sources available to us. This may include the following sources of information: (i) pre-employment screening and recruiting services, such as recruiters or placement agencies; (ii) prior employers that provide employment verification or history; (iii) references that you authorize us to contact on your behalf; (iv) third-party job posting and recruiting websites; (v) your university or other educational institution; (vi) publicly available online information about you such as on social media or the internet; (vii) your online activity on this Website; and (viii) Newfront or Newfront’s agents with whom you may communicate during the recruiting process.

Purpose of Our Data Collection

As permissible under applicable laws, we may collect data on Candidates for the following business purposes

• Recruiting, including through the Website, communicating available positions, interviewing and evaluating candidates, conducting background checks and pre-employment screening;

• Evaluating compliance with employment laws related to recruiting and hiring, including laws pertaining to the accommodation of candidates’ health and disability requirements, as well as compliance with Newfront’s internal recruiting policies where applicable;

• Analyzing and improving the recruitment and application processes as well as related human resources and employment business operations;

• Fulfillment of legal obligations from government entities and agencies; and

• Proactively addressing security, privacy and other rights and safety considerations of Newfront or individual.

Disclosure of Your Personal Information

As permissible under applicable laws, we may share your personal information with the following:

• Internally: within Newfront, solely for the purpose of recruitment and hiring, but your SMS opt-in and phone number(s) will not be shared for marketing purposes.

• Agents and Service Providers: We sometimes contract with other companies and individuals to perform functions or services for us or on our behalf, such as hosting this Website, sending e-mail or text messages, making phone calls, or those who provide other recruiting and interviewing process-related services, such as testing, screening, relocation services, law firms, or immigration advisors. They may have access to personal information, such as email addresses, needed to perform their functions, but are bound by contractual confidentiality obligations and are restricted from using personal information for any reason other than those defined in our contract. Besides the limited purposes outlined within this section, your SMS opt-in information and phone number(s) will not be shared with third parties for unrelated marketing purposes.

• Business Transfers: To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

• Legal Matters: The Company may preserve, and has the right to disclose any information about you or your use of this Website without your prior permission if the Company has a good faith belief that such action is necessary to: (a) protect and defend the rights, property, or safety of the Company or its affiliates, other users of this Website, or the public; (b) enforce the terms and conditions that apply to use of this Website; (c) respond to claims that any content violates the rights of third parties; (d) respond to claims of suspected or actual illegal activity; (e) respond to an audit or investigate a complaint or security threat; or (f) comply with applicable law, regulation, legal process, or governmental requests.

De-identified Data; Exclusions

We may also aggregate, anonymize, or otherwise de-identify your data to use and disclose for our business operations. Where we use, disclose or process de-identified data we will maintain and use the data in de-identified form and shall not attempt to re-identify the data, except as permitted by applicable privacy laws. Notwithstanding anything to the contrary, we may collect, use, retain and disclose your personal information as required or permitted by applicable law and this may override your privacy rights. In addition, we need not honor any of your requests to the extent that doing so would infringe upon our or any other person or party’s rights or conflict with applicable law.

How We Share Your Personal Information

In the last twelve (12) months, we have shared information in the following categories: Identifiers, Contact Information, Job Application Data, Professional Qualifications, Biographical Information, Employment History, Background Check Information, Information to Assess Disability and Status of Health Condition and Other Information with company subsidiaries and affiliates, service providers, and government agencies.

Candidate Privacy Rights

You have the right to exercise these rights via an authorized agent who meets the agency requirements of under applicable law, and any request you submit to us is subject to an identification and residency verification process. Provided that we are able to verify your qualification under applicable law, a description of your rights afforded to you is available here.

Privacy of Minors

Newfront’s recruitment and application processes, as well as this website, is not intended for those under the age of eighteen (18) years old.

Changes to Our Privacy Notice to Candidates Applying to Newfront

We reserve the right to amend this Candidate Notice at our discretion and at any time. When we make changes to this Candidate Notice, we will post the updated notice on the Website and update the notice's effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.

Contact Us

To exercise your rights described above, please contact us:

• Email: privacy@newfront.com

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