Employer Benefits Program Terms

These Gen Employer Benefits Program Terms (Terms), with the Gen Benefits Group Application (Application), form the Agreement. This Agreement relates to the Gen Employer Benefits Program (Program). It is between the Gen Digital entity specified in section 10 below (Gen) and the employer (Employer) identified on the Application. If the Services include any Norton Money Workplace offering, the terms set out in Exhibit 1 will also apply.

The Services. The Gen services are detailed in the Application (Services). Employer will market the Services to individuals eligible under its Employer benefits plans (Eligible Person). When the Eligible Person is enrolled into the Services and their account is activated (End User), their relationship with Gen is governed by Gen’s end user license agreement and global privacy statement (End User Terms) as agreed by the Eligible Person on enrollment and prior to Service activation. Gen will enable the Services to End Users on behalf of the Employer for the Term specified in the Application and will notify End Users of any changes to the Services in accordance with the End User Terms.
Employer’s Rights and Restrictions. During the Term, Gen may provide Employer with Gen owned documentation including but not limited to marketing materials, websites or other materials (Documents). Employer is only permitted to use such Documents to market the Services to Eligible Persons and will comply at all times with Gen’s trademark usage guidelines at https://www.gendigital.com/us/en/legal/. Employer will not alter the Documents without Gen’s prior written consent, or represent Gen as an insurance company, or as providing any insurance or credit repair services to End Users. Neither party will reference the other for marketing or publicity purposes.
Enrollment Requirements. For the Employer’s End Users to be able to enroll in or access Services, Gen must receive the required enrollment information (Enrollment Information). Gen may either reduce or cancel the Services to End Users without any liability, for: (a) incomplete or inaccurate Enrollment Information, (b) failure by an End User to fully activate the Services or, (c) where the End User is unable to be verified for the particular Service.
Confidentiality. If a party receives the other’s designated confidential or proprietary information, it may only be used for the Program and to fulfill this Agreement. Sharing it with third parties is not allowed except when the Employer needs to share it with their broker or as legally required.
Personal Data and Information Security. Employer shall provide Gen the Enrollment Information and shall ensure that all necessary consents and agreement to End User Terms have been obtained before providing any information relating to an identified or identifiable natural person (Personal Data) to Gen. Once enrolled the processing of End User’s Personal Data will be carried out by Gen, and it becomes the responsibility of Gen as sole data controller. If a Data Processing Agreement (DPA) is required the applicable DPA is here: https://www.gendigital.com/us/en/privacy/data-protection-agreements (or any successor website). Gen will comply with the information security standards as further detailed below: Gen Information Security Standards
Gen AI Use: Gen shall comply with all applicable laws when using artificial intelligence (AI), large language models, or solutions from Sub-processors that may utilize AI or large language models in the context of this Agreement and shall implement and maintain appropriate security measures to protect such data. Gen shall comply with (and ensure Sub-processor’s compliance with) AI use requirements as follows. Specifically, Gen shall i) keep Employer data used/uploaded in AI tools secure in line with the terms of the Agreement; and ii) not use Employer data for training the Gen AI tools. Employer data shall be used in Gen AI tools only for the purpose of providing services to Employer as per terms of this Agreement; and iii) not use generative AI technologies without implementing appropriate protections and contractual obligations.
Disclaimers. Gen makes no express or implied warranties or representations of any kind to Employer or any other party.
Liabilities. Employer shall be solely liable for any employee-related costs and taxes associated with the procurement of the Services for its employees. To the extent allowed by applicable law, neither party shall be liable for any indirect, special or consequential damages and Gen’s total liability under or in connection with the Agreement is limited to net revenue received by Gen for the relevant Services in the 12 months before the dispute.
General. When this Agreement or an End User’s relationship with Employer terminates, the End User will continue to receive the Services procured by the Employer on their behalf through the end of their paid term. All notices must be sent to the addresses specified in the Application with a copy to Legal.Department@GenDigital.com. This Agreement may not be assigned without prior written consent, except to a party’s affiliates or successors in a merger, acquisition or asset sale. A party’s waiver or failure to exercise any right or require performance under the Agreement is not a waiver of any further failure. The Agreement is governed exclusively by the laws specified below without regard to principles of conflicts of law. If Company is based in EMEA: The laws of Ireland. Venue for legal action will be the Irish courts, Dublin; If Company is based in Japan: The laws of Japan. Venue for legal action will be the Japanese courts; If Company is based in the Asia Pacific region: The laws of Singapore. Venue for legal action will be the courts of Singapore. If Company is based in the Americas: The laws of California. Venue for legal action will be the courts of Santa Clara County, California. Company waives any right to have this Agreement officially written in the language of the applicable Territory where applicable. In the event of translation, the English version shall prevail. Without limiting Section 2 (Employer’s Rights and Restrictions), each party is not an agent or subcontractor of the other and has no right to represent or create any obligation on behalf of the other. Not all Services or Service features may be available in all jurisdictions. This is the entire agreement between the parties for the Services and changes to these Terms must be made in writing and be signed by both parties, but the parties may modify the Application as mutually agreed in writing by their authorized representatives. Each party will comply with all applicable laws and regulations, including export compliance, anti-money laundering and anticorruption laws.
Applicable Gen Entity: For purposes of this Agreement, the Gen entity is based on your location specified here: https://www.gendigital.com/us/en/legal/gen-contacting-entity/ (“Company”). Please note the Gen contract entity and billing entity issuing invoices may differ, depending on your location.

EXHIBIT 1:
NORTON MONEY WORKPLACE

COMMON TERMS FOR NORTON MONEY ACCESS AND NORTON MONEY ADVANTAGE: The Services do not include, and Gen does not provide, any financial or investment related advice or recommendations of any kind and no statements or actions by Gen shall be relied on as providing such advice. Any investment advisory services available through the Services are provided solely by the applicable licensed third-party provider under that provider's own regulatory obligations and agreements with end users. Employer’s marketing and related documentation shall not include any statements to the contrary.
NORTON MONEY ADVANTAGE: Norton Money Advantage comprises the following features: Norton Money Access, Norton Money Workplace Retirement Planning and Norton Money Workplace College Fund Planning features.
2.1 Enrollment Information. Employer will only provide Enrollment Information and any Personal Data needed for Norton Money Workplace Retirement Planning and Norton Money Workplace College Fund Planning as applicable and in accordance with applicable law and will ensure any required notices and consents have been provided or obtained. Employer will notify Gen without undue delay of any event affecting an End User’s eligibility (including employment termination or benefit cancellation) so that the End User’s access can be deactivated.
2.2 End User Terms with Third Party Providers. Norton Money Workplace College Fund Planning and Norton Money Workplace Retirement Planning as applicable, include services provided by a third party provider, which Gen may update or replace from time to time at it’s sole discretion. To access Norton Money Workplace College Fund Planning, and Norton Money Workplace Retirement Planning as applicable, an Eligible Person or End User must accept the relevant provider’s user terms of service and privacy statement, together with any additional terms, policies, or third-party terms incorporated therein. Those terms are between the End User and the relevant provider.
2.3 Privacy, Security and Confidentiality. Employer will reasonably cooperate with Gen in relation to privacy requests, complaints, investigations, or Security Incidents relating to Norton Money Advantage offerings. Any non-public information about Norton Money Advantage Offerings or the relevant provider forms part of Gen’s Confidential Information. Employer may not use the name, logo, or marks of the relevant provider except with Gen’s prior written consent for each specific use.
2.4 Changes and Availability. The Norton Money Advantage offering (or features thereof) may be changed, suspended, or discontinued from time to time. Gen will use reasonable efforts to give Employer prior notice where practicable.
Norton Money Workplace Retirement Planning: The following applies in addition to Section 2 above
3.1. Use Restrictions. Employer will not, and will not permit any third party to, copy, modify, reverse engineer, resell, rent, timeshare, or misuse Norton Money Workplace Retirement Planning, except as allowed by applicable law. Employer will not remove any proprietary notices from any Documents. Employer will promptly notify Gen of any unauthorized use of, or breach of security relating to, Norton Money Workplace Retirement Planning of which it becomes aware.
3.2. End of Services. If Norton Money Workplace Retirement Planning is removed from the Services or this Agreement ends, an End User may be offered the option to continue directly with the relevant provider under that provider’s terms. Employer will notify Gen without undue delay of any event affecting an End User’s eligibility (including employment termination or benefit cancellation), so that the End User’s access can be deactivated.
Norton Money Workplace College Fund Planning: The following applies in addition to Section 2 above.
4.1. Use Restrictions. Employer will not, and will not permit or assist any third party to, (i) decompile, disassemble, or reverse engineer the Norton Money Workplace College Fund Planning; (ii) distribute, resell, rent, lease, subcontract, or otherwise make the Norton Money Workplace College Fund Planning, available to any third party other than as contemplated herein; (iii) circumvent or otherwise interfere with any authentication or security measures associated with or needed for access to the Norton Money Workplace College Fund Planning (iv) remove, conceal, or alter any identification, copyright, or other proprietary rights notices or labels relating to the Norton Money Workplace College Fund Planning. Educational and knowledge base content made available within Norton Money Workplace College Fund Planning may not be modified, redistributed, or sublicensed outside the Services. Employer will promptly notify Gen of any unauthorized use of, or breach of security relating to, Norton Money Workplace College Fund Planning of which it becomes aware.
4.2. Aggregated Reporting. Any reporting made available to Employer regarding Norton Money Workplace College Fund Planning will be aggregated or de-identified. Employer will not attempt to re-identify any individual from such reporting, will use it only to administer its benefits program, and will impose the same obligations on any permitted recipient of such reporting.
4.3. End of Services. If Norton Money Workplace College Fund Planning is removed from the Services, this Agreement ends, or an End User ceases to be an Eligible Person, the End User’s access to Norton Money Workplace College Fund Planning will be deactivated, and neither Gen nor the relevant provider is obliged to maintain, extend, or restore such access.

September 2026