This Privacy Policy describes how Verenva Group LLC, a South Carolina limited liability company

(“Verenva,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards personal information in connection with our website located at www.verenva.com, including any related portals, tools, or electronic platforms accessible through the Website (the “Website”).

1. SCOPE AND APPLICABILITY

This Privacy Policy governs the collection, use, and disclosure of personal information through the Website and general online interactions with Verenva.

Staffing and Engagement Agreements Exception.

Verenva is a healthcare staffing agency that recruits and places licensed healthcare professionals (“Professionals”) with healthcare facilities and organizations (“Facilities”). Any engagement between Verenva and a Professional, and any engagement between Verenva and a Facility, is governed by a separate written agreement (collectively, “Engagement Agreements”). The collection, use, and handling of personal information provided in connection with, or arising out of, those Engagement Agreements, including information collected during the staffing, credentialing, onboarding, or placement process, is governed by the applicable Engagement Agreement, which shall control in the event of any conflict with this Privacy Policy.

HIPAA and Protected Health Information.

Verenva is a staffing agency and does not, by virtue of operating the Website or providing staffing services, act as a “Business Associate” or “Covered Entity” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) in connection with this Website or these general staffing services. Professionals placed by Verenva may have access to Protected Health Information (“PHI”) in the course of performing their clinical duties at Facilities; however, such access and any associated obligations arise under the Professionals’ own professional obligations, the Facility’s own HIPAA policies, and any applicable terms in the Engagement Agreement, not through this Privacy Policy. To the extent a Business Associate Agreement (“BAA”) is separately executed between Verenva and a Facility in connection with a specific engagement, the terms of that BAA shall govern the processing of PHI as described therein.

Supplemental Notices.

In certain circumstances, Verenva may provide supplemental privacy notices for specific activities, promotions, or partnerships. To the extent any supplemental notice conflicts with this Privacy Policy, the supplemental notice will control for that specific activity.

Your use of the Website is also governed by our Terms and Conditions, which are incorporated herein by reference.

2. WHO THIS PRIVACY POLICY APPLIES TO

This Privacy Policy applies to the following categories of individuals who interact with the Website:

• Website visitors who browse the Website without submitting an application or registration;

• Healthcare Professionals who submit an application, inquiry, or profile through the Website;

• Representatives of healthcare facilities or organizations who inquire about or request staffing services through the Website; and

• Any other individual or entity that contacts or communicates with Verenva through the Website.

This Privacy Policy does not apply to information collected solely in the context of Engagement Agreements or to information about Verenva’s own employees acting in their capacity as Employees.

3. PERSONAL INFORMATION WE COLLECT

We collect personal information in three primary ways: information you provide to us directly, information we collect automatically when you use the Website, and information we receive from third-party sources.

3.1 Information You Provide Directly

Contact and Identification Information. When you contact us, submit an inquiry, or register through the Website, we may collect your full name, email address, telephone number, mailing or business address, and any other identifying information you voluntarily provide.

Professional Application and Credentialing Information.

Healthcare Professionals who apply for placement through the Website may submit resumes or CVs, professional license numbers, certifications, and NPI numbers, education and employment history, clinical specializations and skills, professional references, and continuing education records. This information is used to evaluate Professionals.

Compliance and Screening Information. In connection with professional applications, we may collect or facilitate the collection of immunization records, drug screening results, exclusion list screening results, and criminal background check results, and related information, including government-issued identification numbers.

Work Authorization Information. We may collect documentation and employment eligibility verification information, and, where applicable, visa or immigration status information necessary to confirm a Professional’s eligibility to work in the United States.

Financial Information. We may collect financial account information, including bank account details, routing numbers, and related payment information, from Professionals in connection with compensation and payroll processing, and from Facilities in connection with billing and invoicing for staffing services.

Facility Information. Representatives of healthcare Facilities who interact with us through the Website may provide their name, business contact information, organizational affiliation, and Privacy Policy general staffing needs. Detailed facility onboarding information, credentialing requirements, and contractual terms are addressed through Engagement Agreements.

Communications and Correspondence. We process the content of communications you submit through the Website, including contact form submissions, emails, and any attached documents or materials. This helps us respond to inquiries and maintain records of our interactions. We may also collect audio and video recordings, such as recorded interviews, video applications, or virtual meeting recordings, where permitted by applicable law and with appropriate notice to participants.

Feedback and Evaluations. We may collect feedback, ratings, evaluations, and related

comments submitted about or by Professionals or Facilities, including performance feedback

provided in connection with a placement or engagement. Such feedback may include personal

information about the individual being evaluated and is used to inform future placement decisions and improve our services.

3.2 Information Collected Automatically

When you access or browse the Website, we may automatically collect the following categories

of information through cookies, web beacons, pixels, and similar technologies:

• Device and Connection Information: IP address, device type, browser type and version, operating system, and unique device identifiers.

• Usage and Behavioral Information: Pages viewed, links clicked, time and date of visit, duration of page visits, and navigation paths through the Website.

• Referral Information: The source from which you arrived at the Website (e.g., search engine queries, referring website).

• Technical Configuration: Screen resolution, language preferences, and similar technical details that help ensure the Website functions properly.

For additional information regarding cookies and how to manage them, please see Section 8 (Cookies and Tracking Technologies) below.

3.3 Information from Third-Party Sources

We may receive personal information about you from third-party sources, including:

• Licensing boards and credentialing verification services, to confirm the status of professional licenses and certifications;

• Background check and drug screening providers, as authorized by you;
• Exclusion list screening services;
• Identity verification services;
• Referral sources or staffing platforms; and
• Publicly available sources, including government databases and professional registries.

3.4 Inferences

We may derive inferences from the personal information we collect to create profiles reflecting your preferences, characteristics, aptitudes, and other attributes. Such inferences may be used Privacy Policy for a variety of purposes, including improving our services, informing placement and business development activities, and supporting advertising and analytics efforts, consistent with this Privacy Policy.

4. SENSITIVE PERSONAL INFORMATION

Certain information we collect may constitute “Sensitive Personal Information” or a similar category of heightened-protection data under applicable law, including:

• Social Security Numbers and other government-issued identification;
• Gender, marital status, ethnicity, veteran status, and disability status;
• Criminal background check information;
• Drug screening results;
• Immigration or work authorization status;
• Health-related documentation; and
• Biometric identifiers, to the extent collected as part of identity or employment eligibility verification.

We process Sensitive Personal Information, including via service providers, only to the extent necessary to fulfill the purposes for which it was collected, primarily credentialing, compliance screening, and employment eligibility verification, and in accordance with applicable federal and state law.

5. HOW WE USE PERSONAL INFORMATION

We use the personal information we collect for the following purposes:

• To evaluate Professional applications, verify credentials and licensure, and facilitate placement with Facilities;

• To conduct or facilitate background checks, drug screening, exclusion list checks, and other compliance screening, as authorized and required;

• To make and receive payments, including processing compensation to Professionals and billing Facilities for staffing services;

• To process and use feedback and evaluations, which may include personal information, to assess the quality of placements, inform future matching decisions, and improve our services;

• To respond to inquiries, contact form submissions, and other communications submitted through the Website;

• To provide, operate, maintain, and improve the Website and its features;
• To communicate with you about your application, placement, or inquiry status;
• To develop new products, services, features, and functionality;
• To facilitate targeted advertising and to perform data analytics;
• To send you marketing and promotional materials;
• To comply with applicable federal, state, and local legal and regulatory requirements, including employment eligibility verification;

• To detect, prevent, and address fraud, security incidents, and other unlawful or harmful activity;

• To enforce our Terms and Conditions and other applicable agreements; and
• For other purposes consistent with the context in which the information was collected and as disclosed at the time of collection.

Automated Decision-Making and Profiling

To the extent we employ automated decision-making tools or profiling in connection with our services, we do so in accordance with applicable law. We do not make decisions that produce legal or similarly significant effects on you based solely on automated processing without human review. Where required by applicable law, we will seek your consent prior to engaging in automated decision-making with respect to your personal information. You may have the right to obtain information about the logic involved in any such automated processing and to request human review of decisions made using automated means. See Section 11 for information on how to exercise applicable rights.

6. HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information to the following categories of recipients, for the purposes described below:

Healthcare Facilities. We share Professional credentials, qualifications, and screening results with Facilities for purposes of evaluating, onboarding, and placing Professionals.

Background Check and Screening Vendors. We work with third-party vendors to conduct or facilitate background checks, drug testing, exclusion list screening, and employment eligibility verification. These vendors process personal information, including Sensitive Personal Information, subject to their own privacy practices and applicable law.

Credentialing and Licensing Verification Services. We may share Professional information with services that verify licensure, certifications, and professional standing with state licensing boards and other relevant authorities.

Technology and Service Providers. We engage third-party vendors and service providers to assist with operating and improving the Website, including hosting, targeted advertising, analytics, communications, and data security.

Legal and Regulatory Disclosures.

We may disclose personal information when required or permitted by applicable law, including in response to valid legal process (such as subpoenas or court orders), regulatory inquiries, or to protect the rights, safety, or property of Verenva, our users, or the public.

Business Transfers. In connection with a merger, acquisition, reorganization, sale of assets, or similar transaction, personal information may be disclosed or transferred to a successor entity. We will provide notice of any such transfer as required by applicable law.

Sale and Sharing of Personal Information

We do not sell your personal information to third parties for monetary consideration. However, we may disclose personal information to, and permit certain third-party analytics and advertising service providers to collect data directly from your device via cookies, pixels, and similar tracking technologies when you visit the Website. To the extent we use such technologies for purposes of Website analytics and targeted advertising, including, for example, to measure the effectiveness of recruitment or business development campaigns or to serve relevant advertising through platforms such as Google, Meta, LinkedIn, or similar networks, such disclosures may constitute “sharing” of personal information for cross-context behavioral advertising under certain state privacy laws, even where no monetary consideration is exchanged.

To the extent applicable law affords you the right to opt out of the sale or sharing of personal information, you may exercise your rights by submitting a request as described in Section 11 of this Privacy Policy.

7. DATA RETENTION

We retain personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, to resolve disputes, and to enforce our agreements.

8. COOKIES, TRACKING, CHATBOTS, AND MONITORING

The Website uses cookies and similar tracking technologies to enhance your browsing experience, analyze Website traffic, support advertising, including targeted advertising, and support the functionality of the Website. Cookies are small data files placed on your device when you visit a website.

8.1 Types of Cookies and Tracking Technologies

We use the following types of cookies and similar technologies:

• Strictly Necessary Cookies: Required for the Website to function properly, including security features, account authentication, and session management.

• Analytics and Performance Cookies: Used to understand how visitors interact with the Website, including pages visited, time spent, and errors encountered. This information is used to improve the Website and user experience.

• Functional Cookies: Used to remember your preferences and settings to improve your experience on return visits.

• Marketing and Targeting Cookies: Marketing cookies are used to track visitors across websites and deliver and analyze advertisements. These cookies may be set by us or by third parties, including advertising networks.

You may control cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the Website.

8.2 Session Recording and Website Monitoring

To the extent we deploy session recording, screen capture, or similar monitoring technologies, which may record mouse movements, clicks, scrolling behavior, keystrokes, and other interactions with the Website, such recording may be conducted by us or by third-party service providers acting on our behalf, to the fullest extent permitted by applicable law. Information collected through such technologies may be used to analyze and improve Website functionality and user experience, to investigate security incidents or unauthorized activity, and to support compliance and quality assurance efforts. We may disclose information obtained through such monitoring to our service providers and, where required or permitted by law, to law enforcement or regulatory authorities.

8.3 Interactive Features and Chatbot Communications

The Website may offer interactive features, including chatbots or other communication features

(“Interactive Features”). If you use Interactive Features, the content of your communications, including any personal information you voluntarily provide, may be collected, processed, and retained by us and by third-party service providers who operate or support such features on our behalf. Communications submitted through Interactive Features are not confidential and should not include sensitive personal information. We may use the content of such communications for customer service, quality assurance, product improvement, and other purposes consistent with this Privacy Policy.

8.4 Do Not Track and Universal Opt-Out Signals

Some browsers and browser extensions transmit “Do Not Track” (DNT) signals or universal opt- out signals, including the Global Privacy Control (GPC). As of the date of this Privacy Policy, the Website does not respond to DNT signals, and we make no representation that GPC signals are currently recognized. To the extent applicable law requires us to recognize GPC signals or similar universal opt-out mechanisms as valid opt-out requests; we will update our practices accordingly.

9. DATA SECURITY

Verenva maintains reasonable and appropriate safeguards designed to protect personal information. No method of electronic transmission or storage is completely secure, however, and we cannot guarantee the absolute security of your personal information. You are responsible for maintaining the confidentiality of any account credentials and for promptly notifying us if you suspect unauthorized access to your account.

10. CHILDREN’S PRIVACY

The Website is not directed to individuals under the age of 18. We do not knowingly collect personal information from individuals under 18 through the Website. If we become aware that we have inadvertently collected personal information from a minor under 18, we will take steps to delete such information. If you believe we have collected personal information from a minor, please contact us using the contact information included at the end of this Privacy Policy.

11. YOUR PRIVACY RIGHTS

Depending on your state of residence and whether Verenva is within the scope of a specific privacy law, you may have certain rights with respect to your personal information. We may need to verify your identity prior to processing your request. Verification may require you to provide certain identifying information that we can match against our records. We will not use information collected solely for verification to fulfill any other purpose.

We describe below the rights that may be available to you under applicable law.

11.1 California Residents (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA/CPRA”), may afford you the

following rights:

• Right to Know: The right to request disclosure of the categories and specific pieces of personal information we have collected about you, the categories of sources from which personal information was collected, the business or commercial purposes for collecting personal information, and the categories of third parties with whom we share personal information.

• Right to Access: The right to obtain a copy of the specific pieces of personal information we have collected about you.

• Right to Delete: The right to request deletion of personal information we have collected from you, subject to certain exceptions.

• Right to Correct: The right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: We do not sell your personal information for monetary consideration. However, we may “share” personal information, as that term is defined under law, with third-party advertising and analytics partners for cross-context behavioral advertising purposes, including through the use of cookies and similar tracking technologies on the Website. You have the right to opt out of such sharing.

• Right to Limit Use of Sensitive Personal Information: You have the right to direct us to limit our use and disclosure of your Sensitive Personal Information to uses that are reasonably necessary and proportionate to the purposes for which it was collected.

• Right to Opt Out of / Request Human Review of Automated Decision-Making: To the extent applicable, you may have rights with respect to automated decision-making and profiling. See Section 11.3.

• Right to Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

California Statutory Disclosure (Under-16). As required by the California Consumer Privacy

Act, we state that we do not sell or share the personal information of consumers we have actual knowledge are under the age of 16.

To exercise your California privacy rights, please submit a request through the contact information included at the end of this Privacy Policy. We may need to verify your identity before processing your request. We will respond to requests within the timeframes required by applicable law.

11.2 Other State Privacy Rights

Residents of certain other states may also have privacy rights under applicable state law, including rights to know, access, correct, delete, or opt out of certain uses of personal information, as well as opt out of certain processing, and non-discrimination. To the extent such rights apply to information collected through this Website, you may submit a request using the contact information included at the end of this Privacy Policy.

For Residents of Nevada

We do not sell your personal information as per the definition of “sale” under Nevada’s Revised Statutes Chapter 603A.

11.3 Automated Decision-Making

To the extent applicable law affords you the right to opt out of, or to request human review of, decisions made through automated processing of your personal information, you may submit such a request using the contact information at the end of this Privacy Policy. We will respond in accordance with applicable law.

12. THIRD-PARTY WEBSITES AND LINKS

The Website may contain links to third-party websites, services, or resources that are not owned or controlled by Verenva. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites or services. We encourage you to review the privacy policies of any third-party websites you visit. This Privacy Policy applies only to information collected through the Website and does not govern the practices of third parties.

13. UPDATES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, applicable law, or other operational considerations. When changes are made, we will update the “Last Updated” date at the top of this Policy. If we make a material change to this Policy, we may provide notice by posting an announcement on the Website or by sending an email to individuals who have provided contact information.

Your continued use of the Website following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy. We encourage you to review this Privacy Policy periodically.

14. CONTACT INFORMATION

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Verenva Group LLC 213 East Butler Road Suite A1 Mauldin, South Carolina 29662

Email: info@verenva.com