Data Privacy and Protection Policy Statement

Rubicon respects and is committed to protecting the privacy and confidentiality of Personal Information and proprietary information about its employees, customers, business partners and other identifiable individuals. “Personal Information” is information or data about an “identified” or “identifiable” individual (such as home address, social security number and other data points as recognized by applicable data protection laws). Personal Information and proprietary information does not include information that is anonymous, aggregated or in circumstances where the individual or customer is not readily identifiable.

Rubicon may utilize such information for purposes of better understanding our customers’ needs and improving the services we offer. Rubicon uses technical and physical safeguards to protect the security of personal information and proprietary information of third parties from unauthorized disclosure, and Rubicon’s Code of Conduct, Information Security Policy, Data Protection Policy, and Employee Handbook all support this commitment. Violation of this Statement by an employee or contractor of Rubicon will be considered a violation of these policies and will result in appropriate discipline up to and including termination.