Effective Date: June 1, 2026

FW Cook, Inc. (“FW Cook”, “we”, “us”, “our”) takes the protection of your personal information very seriously. Whether you are one of our clients, one of the employees of our clients, or a visitor to our website, this Privacy Notice (this “Notice”) describes how we collect and use your personal information.

Scope

FW Cook provides expert, independent advice regarding executive compensation. We help our clients navigate the changing norms around compensation to ensure their renumeration strategy supports their long-term goals. When the personal information we process is given to us by our clients in order to provide our consulting services, we serve as a “processor” under certain data protection laws. In these cases, we do not decide why or how data is collected, and we only process it at the direction of our clients. We typically have no direct relationship with the individuals whose personal information we receive from our clients.

Additionally, this Notice covers the information we collect when you visit this website or otherwise provide information directly to us, including when you apply for a job with us, or when we collect publicly available information in order to provide our expert consulting services (when we act as a “controller” under certain data protection laws).

This Notice is meant to help you understand how and why we collect, use, or share personal information, and your rights under the privacy and data protection laws in the areas in which we or our clients operate.

Your Privacy Rights

Requests we receive when we act as a processor:
When FW Cook collects or receives your personal information by or on behalf of one of our clients (usually by virtue of being employed or prospectively employed by them), we process your personal information based on the documented instructions of our clients. In these cases, our client’s privacy notice, rather than this Notice, will apply to our processing of your personal information. If you have a direct relationship with one of our clients, please contact them to exercise your privacy rights. If you are unsure whether FW Cook has any of your personal information, and you believe your employer may have provided it to us, please first contact them and they will communicate any requests through to us. If you are unable or unwilling to contact them, you may also contact us directly and please provide the name of the FW Cook client who submitted your personal information to us. We will forward your request to that client and provide any needed assistance as they respond to your request.

Requests we receive when we act as a controller:
When FW Cook acts as a controller (e.g. for data you provide directly to us or we collect directly), you may always contact us at [email protected] to exercise any of the privacy rights available to you. Under certain circumstances, by applicable law, those rights may include:

• access to your personal information (commonly known as a “data subject access request”) and receive a copy of it;
• that we update or correct your personal information;
• erasure of your personal information;
• that we stop processing your personal information where we process it, relying on a legitimate interest;
• that we suspend the processing of your Personal information when you have asked us to check its accuracy and in other cases;
• to export a copy of your personal information in a format that allows you to reuse your data;
• to withdraw your consent of processing your data at any time (if applicable) which will apply to any further processing, not data that has already been processed;
• to lodge a complaint with the data protection authority. If you have a concern about our privacy practices, including the way we handled your personal information, you can report it to the data protection authority that is authorized to hear those concerns.

Personal Information We Hold About You

In the context of this Notice, we may collect or receive your Personal information only from the following sources:

• your employer or prospective employer provides it to us when they engage us to provide our consulting services;
• you provide it directly to us when you engage or consider engaging us for our services;
• you provide it to us directly by virtue of your use of this website; engaging with our distributions lists, publications or marketing efforts; fill in our webforms or contact us directly or by other means;
• you provide it to us directly when you apply for a job with us or otherwise provide us with your resume;
• we collect it from publicly available sources (e.g. SEC filings);

When providing our consulting services, FW Cook will have access to the following types of data:

• Identifying information (name, age, email address, physical address, etc.)
• Professional and educational background (including information you’ve shared in your resume)
• Compensation information (salary, other forms of remuneration)
• Please note: FW Cook does not seek to process any sensitive data (e.g. race, ethnicity, health status, trade union membership or political party affiliation, for example) however occasionally we may incidentally have access to it if you elect or your employer elect to share it with us (in, for example, a resume). Consent for such collection and sharing would be obtained through your employer.

When you use this website or provide data to us by additional means, FW Cook may also process:

• Technical data (IP address, device type and coarse location, etc.)
• Any other data you choose to share with us.

Additionally, FW Cook may collect and use information that is publicly available (for example, in SEC filings) in order to provide our consulting services.

Cookies

What is a cookie?
A “cookie” is a small file stored on your device that contains information about your device (computer, phone, tablet, etc.), about your browser and online activity. This information often consists of a string of numbers and letters that uniquely identifies your device.

How do we use cookies on our website?
We use session and persistent cookies. Session cookies are deleted when you close your browser. Persistent cookies may remain even after you close your browser, but always have an expiration date. Most of the cookies placed on your device through our website are first-party cookies which are placed directly by us. Other parties, such as Google, may also set their own (third-party) cookies through our website. In other words, when you visit our website, certain third parties may place cookies on your device to collect information about your online activities over time and across different Internet websites or online services. Please refer to the policies of these third parties to learn more about the way in which they collect and process information about you.

We use the following cookie categories on our website:
“Necessary” cookies to enable the basic features of the website. These cookies play a critical role in the operation of the website and cannot be turned off.

“Analytics” cookies which go beyond technical performance, recording visitor interactions with our website. They gather data, such as which pages are visited most frequently, how long visitors stay on each page, and which links they click. This information guides us and third parties in making informed decisions to enhance our website’s functionality and content.

How to opt out and change your cookie preferences?
You have the right to opt out of the use of non-essential cookies. When you first visit our website, you will be presented with a cookie consent pop-up window through which you can make your cookie choices. To opt out, please close the pop-up window.

For more information about how to manage and delete cookies in your browser, please visit https://www.aboutcookies.org/how-to-manage-and-delete-cookies.

Please note, however, that if you reject certain cookies, you may not be able to access and use all of the features on our website.

If you have any questions about the use of cookies on our website, please contact [email protected].

How We Use Personal Information

We will use personal information provided to us or collected by us to:

• Provide our consulting services (that is, to analyze and advise companies on how best to compensate their teams);
• Provide and customize this website;
• Sell and market our services;
• Hire and evaluate prospective FW Cook team members;
• Respond to your inquiries regarding our services;
• Manage our relationship with our clients;
• Collect payments or engage in financial transactions with our clients;
• Enforce our legal rights and to comply with all laws, regulations, guidance, or professional obligations applicable to FW Cook;
• Measure and improve our consulting products, marketing initiatives, and website performance, and to personalize your visit and use of our website and to assist you while using our services;
• To contact you (unless you opt out of such communications) regarding developments in executive compensation that may be of interest to you, or to otherwise market our consulting services. If you change your mind and do not want to receive publications, or details of events or webinars we believe could be interesting to you, you may unsubscribe from these communications by clicking on the “unsubscribe” link in the relevant communication.

When we act as a controller, we may process your personal information on the basis of:

• your consent;
• our legitimate interests, such as our interest in performing the contract we entered into with your employer, or marketing and selling our services;
• our obligation to comply with applicable law; or
• any other ground, as required or permitted by applicable law.

Where we process your Personal information based on your consent, you may withdraw your consent at any time. However, this will not affect the lawfulness of our processing before you withdrew your consent. It will also not affect our processing performed on other lawful grounds.

When we act as a processor, please refer to the privacy notice of the controller – usually our clients, and your employers or prospective employers – to understand the legal bases for processing your data and sharing it with us.

Data Retention

We may retain information provided by you, including personal information, for as long as necessary to comply with our legal obligations, or to achieve the purposes for which the information was originally collected and for the purposes described in the Notice and in our applicable policies.

Data Sharing

It has always been FW Cook’s policy to exercise the utmost discretion regarding the information our clients entrust to us. Data is shared from FW Cook to third parties only in limited circumstances.

Service Providers

We may share your Personal information with limited, vetted, services providers like cloud-based software providers, customer relationship management platforms, file transfer and hosting software providers; word processing, analytics and office support providers, and website hosting providers.

We require that all of these service providers protect your Personal information, including through the adoption of adequate security measures, and use the data solely to provide the services to us.

Other FW Cook Clients

If you or your employer elect to participate in the FW Cook Executive Compensation Survey, we will share pseudonymized data among participants as described in the documents for the Survey. In no other circumstances will data from one FW Cook client be shared with another.

Other Third Parties

We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business, or to relevant third parties such as auditors, lawyers or professional advisors, or our insurers.

We may also disclose your personal information to comply with a subpoena, bankruptcy proceedings, or similar legal process, or in response to lawful requests by public authorities, or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, or those of you or third parties, or the public at large.

Data Transfers

FW Cook is located in the United States, as are most of our service providers and partners. The United States may have data protection laws less stringent than or otherwise different from the laws in effect in the country in which you are located. When data is transferred to FW Cook in the United States, it will be for the same purposes as described in this Notice. When we act as controller, we will always ensure there are appropriate safeguards in place, and will cooperate with our clients when they act as controllers to assist them in ensuring the same. Where required, these safeguards include the use of the European Commission-approved Standard Contractual Clauses or other mechanisms required by the local data protection authority. We will also take steps to ensure that your personal information receives an adequate level of security protection wherever it is processed.

Data Security

We have put in place and have contractually required our service providers, contractors, and any other third parties with access to your data to put in place reasonable and appropriate security measures intended to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered, or disclosed. While protecting the confidentiality of the data entrusted to us is of the utmost importance, we cannot guarantee that these safeguards will always be effective.

Questions

If you have any questions about this Notice or our processing of your Personal information, please contact [email protected]. Our team will respond to you as soon as possible but no later than four (4) weeks after you contact us.

Changes To This Privacy Notice

We may update this Privacy Notice at any time, and we will either provide you with a new privacy notice or update the web page you read it on. We will also update the “Effective” date at the top of this Notice.