Non-Affiliated Individual Privacy Notice

Northrop Grumman Corporation (“Northrop Grumman”) and its U.S-based affiliates listed at http://www.northropgrumman.com/Pages/PrivacyPolicyEntities.aspx respects your concerns about privacy. Northrop Grumman participates in the EU-U.S. Privacy Shield (“Privacy Shield”) framework issued by the U.S. Department of Commerce. Northrop Grumman commits to comply with the Privacy Shield Principles with respect to EU Personal Data of non-EU Employees the company receives from the EU in reliance on the Privacy Shield. This Notice describes how Northrop Grumman implements the Privacy Shield Principles for Non-affiliated EU Individual Personal Data.

For purposes of this Notice:

“Non-Affiliated EU Individual” means any natural person who is located in the EU, but excludes any individual acting in his or her capacity as an Employee.

“Controller” means a person or organization which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“EU Customer” means any entity that purchases or otherwise obtains products or services from Northrop Grumman.

“EU Employee” means any current, former or prospective employee or contractor of Northrop Grumman or any of its European affiliates or any related individual whose Personal Data Northrop Grumman processes in connection with an employment relationship, who is located in the EU. For purposes of this Manual, “Employee” includes any temporary worker, intern, or other non-permanent employee of the company.

“EU” means the European Union and Iceland, Liechtenstein and Norway.

“EU Personal Data” means any information, including EU Sensitive Data, that is (i) about an identified or identifiable individual, (ii) received by Northrop Grumman in the U.S. from the EU, and (iii) recorded in any form.

“Privacy Shield Principles” means the Principles and Supplemental Principles of the Privacy Shield.

“Processor” means any natural or legal person, public authority, agency or other body that processes EU Personal Data on behalf of a Controller.

“EU Sensitive Data” means EU Personal Data specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, the commission or alleged commission of any offense, any proceedings for any offense committed or alleged to have been committed by the individual or the disposal of such proceedings, or the sentence of any court in such proceedings.

Northrop Grumman’s Privacy Shield certification can be found at www.privacyshield.gov/list. For more information about the Privacy Shield Principles, please visit www.privacyshield.gov. For more information about Northrop Grumman’s processing of Non-affiliated EU Individual Personal Data with respect to information collected on its websites, please visit Northrop Grumman’s Online Privacy Notice or other privacy notices published by the company.

Types of Personal Data Northrop Grumman Collects

Northrop Grumman obtains EU Personal Data, such as contact information, in connection with maintaining its Customer relationships and providing products and services to Customers. Northrop Grumman also obtains EU Personal Data of its suppliers’ representatives, such as contact information, financial statements and reputational data. Northrop Grumman uses this information to manage its relationships with its suppliers and comply with applicable law or legal requirements.

In addition, Northrop Grumman collects EU Personal Data directly from Non-affiliated EU Individuals. This collection occurs, for example, when the individual visits Northrop Grumman’s websites and provides EU Personal Data to the company. The company may use this information to:

• Provide products and services; • send promotional materials or other communications; • communicate with Customers about, and administer their participation in, special events, programs, offers, surveys and market research; • respond to Customer inquiries; • perform data analyses (including anonymization and aggregation of EU Personal Data); • operate, evaluate and improve the company’s business (including developing new products and services; enhancing and improving the company’s products and services; managing the company’s communications; analyzing the company’s products, services and communications; and performing accounting, auditing and other internal functions); • management of customer services including management of negotiations, contracts, transactions, and customer accounts, budgeting, accounting, maintaining records related to customers financials analysis; • protect against, identify and prevent cybersecurity and other security events, espionage, fraud and other unlawful activity, claims and other liabilities; and • comply with and enforce applicable legal requirements, relevant industry standards and the company’s policies.

Northrop Grumman also may use the information in other ways for which the company provides specific notice at the time of collection. The types of Personal Data Northrop Grumman collects in connection with these activities includes: • contact information (such as name, postal address, telephone number and email address); • login credentials for the company’s websites; • photograph, electronic signature, and acknowledgements of company policy; • other personal information submitted by current or prospective suppliers and subcontractors, such as Social Security number, , federal tax ID number, and civil and criminal court history; and • bank account and financial details; • other EU Personal Data found in content that Non-affiliated Individuals provide. Northrop Grumman’s privacy practices regarding the processing of Non-affiliated EU Individual Personal Data comply with the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.

Notice

Northrop Grumman provides information in this Notice and the company’s Online Privacy Notice about its Non-Affiliated EU Individual Personal Data practices, including the types of EU Personal Data Northrop Grumman collects, the types of third parties to which Northrop Grumman discloses the EU Personal Data and the purposes for doing so, the rights and choices Non-affiliated EU Individuals have for limiting the use and disclosure of their EU Personal Data, and how to contact Northrop Grumman about its practices concerning EU Personal Data. Privacy notices pertaining to specific data processing activities also may contain relevant information.

Choice

Northrop Grumman generally offers Non-affiliated EU Individuals the opportunity to choose whether their EU Personal Data may be (i) disclosed to third-party Controllers or (ii) used for a purpose that is materially different from the purposes for which the information was originally collected or subsequently authorized by the relevant Non-affiliated EU Individual. To the extent required by the Privacy Shield Principles, Northrop Grumman obtains opt-in consent for certain uses and disclosures of Sensitive Data. Non-affiliated EU Individuals may contact Northrop Grumman as indicated below regarding the company’s use or disclosure of their EU Personal Data. Unless Northrop Grumman offers Non-affiliated EU Individuals an appropriate choice, the company uses EU Personal Data only for purposes that are materially the same as those indicated in this Notice or the company’s Online Privacy Notice.

Northrop Grumman may disclose Non-affiliated EU Individual Personal Data without offering an opportunity to opt out, and may be required to disclose the EU Personal Data, (i) to third-party Processors the company has retained to perform services on its behalf and pursuant to its instructions, (ii) if it is required to do so by law or legal process, or (iii) in response to lawful requests from public authorities, including to meet national security, public interest or law enforcement requirements. Northrop Grumman also reserves the right to transfer EU Personal Data in the event of an audit or if the company sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, dissolution or liquidation).

Accountability for Onward Transfer of Personal Data

This Notice and Northrop Grumman’s Online Privacy Notice describe Northrop Grumman’s sharing of Non-affiliated EU Individual Personal Data.

Except as permitted or required by applicable law, Northrop Grumman provides Non-affiliated EU Individual with an opportunity to opt out of sharing their EU Personal Data with third-party Controllers. Northrop Grumman requires third-party Controllers to whom it discloses Non-affiliated EU Individual Personal Data to contractually agree to (i) only process the EU Personal Data for limited and specified purposes consistent with the consent provided by the relevant Non-affiliated EU Individual , (ii) provide the same level of protection for EU Personal Data as is required by the Privacy Shield Principles, and (iii) notify Northrop Grumman and cease processing EU Personal Data (or take other reasonable and appropriate remedial steps) if the third-party Controller determines that it cannot meet its obligation to provide the same level of protection for EU Personal Data as is required by the Privacy Shield Principles.

With respect to transfers of Non-affiliated EU Individual Personal Data to third-party Processors, Northrop Grumman (i) enters into a contract with each relevant Processor, (ii) transfers EU Personal Data to each such Processor only for limited and specified purposes, (iii) ascertains that the Processor is obligated to provide the EU Personal Data with at least the same level of privacy protection as is required by the Privacy Shield Principles, (iv) takes reasonable and appropriate steps to ensure that the Processor effectively processes the EU Personal Data in a manner consistent with Northrop Grumman’s obligations under the Privacy Shield Principles, (v) requires the Processor to notify Northrop Grumman if the Processor determines that it can no longer meet its obligation to provide the same level of protection as is required by the Privacy Shield Principles, (vi) upon notice, including under (v) above, takes reasonable and appropriate steps to stop and remediate unauthorized processing of the EU Personal Data by the Processor, and (vii) provides a summary or representative copy of the relevant privacy provisions of the Processor contract to the Department of Commerce, upon request. Northrop Grumman remains liable under the Privacy Shield Principles if the company’s third-party Processor onward transfer recipients process relevant EU Personal Data in a manner inconsistent with the Privacy Shield Principles, unless Northrop Grumman proves that it is not responsible for the event giving rise to the damage.

Security

Northrop Grumman takes reasonable and appropriate measures to protect Non-affiliated EU Individual Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the EU Personal Data.

Data Integrity and Purpose Limitation

Northrop Grumman limits the Non-affiliated EU Individual Personal Data it processes to that which is relevant for the purposes of the particular processing. Northrop Grumman does not process Non-affiliated EU Individual Personal Data in ways that are incompatible with the purposes for which the information was collected or subsequently authorized by the relevant Non-affiliated EU Individual. In addition, to the extent necessary for these purposes, Northrop Grumman takes reasonable steps to ensure that the EU Personal Data the company processes is (i) reliable for its intended use, and (ii) accurate, complete and current. In this regard, Northrop Grumman relies on on-affiliated EU Individuals to update and correct the relevant EU Personal Data to the extent necessary for the purposes for which the information was collected or subsequently authorized. Non-affiliated EU Individuals may contact Northrop Grumman as indicated below to request that Northrop Grumman update or correct relevant EU Personal Data.

Subject to applicable law, Northrop Grumman retains Non-affiliated EU Individual Personal Data in a form that identifies or renders identifiable the relevant Non-affiliated EU Individual only for as long as it serves a purpose that is compatible with the purposes for which the EU Personal Data was collected or subsequently authorized by the Non-affiliated EU Individual, as appropriate.

Access

Non-affiliated EU Individuals generally have the right to access their EU Personal Data. Accordingly, where appropriate, Northrop Grumman provides Non-affiliated EU Individuals with reasonable access to the EU Personal Data Northrop Grumman maintains about them. Northrop Grumman also provides a reasonable opportunity for those Non-affiliated EU Individuals to correct, amend or delete the information where it is inaccurate or has been processed in violation of the Privacy Shield Principles, as appropriate. Northrop Grumman may limit or deny access to EU Personal Data where the burden or expense of providing access would be disproportionate to the risks to the Non-affiliated EU Individual’s privacy in the case in question, or where the rights of persons other than the Non-affiliated EU Individual would be violated. Non-affiliated EU Individuals may request access to their EU Personal Data by contacting Northrop Grumman as indicated below.

Recourse, Enforcement and Liability

Northrop Grumman has mechanisms in place designed to help assure compliance with the Privacy Shield Principles. Northrop Grumman conducts an annual self-assessment of its Non-affiliated EU Individual Personal Data practices to verify that the attestations and assertions the company makes about its Privacy Shield privacy practices are true and that the company’s privacy practices have been implemented as represented and in accordance with the Privacy Shield Principles.

Non-affiliated EU Individuals may file a complaint concerning Northrop Grumman’s processing of their EU Personal Data. Northrop Grumman will take steps to remedy issues arising out of its alleged failure to comply with the Privacy Shield Principles. Non-affiliated EU Individuals may contact Northrop Grumman as specified below about complaints regarding the company’s Non-affiliated EU Individual Personal Data practices.

If a Non-affiliated EU Individual’s complaint cannot be resolved through Northrop Grumman’s internal processes, Northrop Grumman will cooperate with JAMS pursuant to the JAMS International Mediation Rules, available on the JAMS website at www.jamsadr.com/international-mediation-rules. JAMS mediation may be commenced as provided for in the relevant JAMS rules. The mediator may propose any appropriate remedy, such as deletion of the relevant EU Personal Data, publicity for findings of noncompliance, payment of compensation for losses incurred as a result of noncompliance, or cessation of processing of the EU Personal Data of the Non-affiliated EU Individual who brought the complaint. The mediator or the Non-affiliated EU Individual also may refer the matter to the U.S. Federal Trade Commission, which has Privacy Shield investigatory and enforcement powers over Northrop Grumman. Under certain circumstances, Non-affiliated EU Individual also may be able to invoke binding arbitration to address complaints about Northrop Grumman’s compliance with the Privacy Shield Principles.

How to Contact Northrop Grumman

To contact Northrop Grumman with questions or concerns about this Notice or Northrop Grumman’s Non-affiliated EU Individual Personal Data practices write to:

Corporate Privacy Executive
Northrop Grumman Corporation
2980 Fairview Park Drive
Falls Church, VA 22042

or Email: privacy@euro.ngc.com