Effective Date: November 22, 2022

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OVERVIEW

This Candidate Privacy Notice (“Privacy Notice”) describes how Rise Healthcare Tech, Inc., doing business as both “Ostro” and “RxDefine” (along with our affiliates “Ostro”, “we” or “us”) collects, uses, and discloses information about individuals who are applicants for engagement with us as an employee, contractor, consultant, or other contingent worker (hereinafter “Applicants”).

This Privacy Notice does not apply to our handling of data gathered about Applicants arising from their role as a user of our products and services. When interacting with Ostro in that capacity, a different privacy policy associated with the relevant product or service applies as further described in connection with those products and services.

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DATA COLLECTION

We collect, store, and use various types of information, including personal information, through the application and recruitment process. We collect such information either directly from Applicants or (where applicable) from another person or entity, such as an employment or placement agency or consultancy, background check provider, or other referral sources.

The type of information we collect and maintain about Applicants may include, where applicable (collectively, “Applicant Information”):

• Identification and contact information and related identifiers, such as real name, alias, home postal address, home telephone number, personal email address, personal mobile number, online account name/screen name, or handle, and the same or similar information about an Applicant’s beneficiaries and/or emergency contacts.
• Recruitment, employment, or engagement information such as application forms and information included in a resume, cover letter, applicant questionnaire or examination, or otherwise provided through any application or engagement process.
• Personal Characteristics and Demographic Data, such as age or age range, race, or gender.
• Protected Classifications, such as information from a criminal background check.
• Government-Issued Identification Numbers, such as driver’s license, operator’s license, or other motor vehicle information, passport number, social security number, birth certificate number, and other state or federal issued IDs.
• Education Information, such as degrees or schooling, licenses and professional memberships, certifications, trainings, academic record, and other non-publicly available educational record information held by an education institution.
• Professional or employment-related information, such as job titles, work history, work dates and work locations, employment, service or engagement agreements, appraisal and performance information, information about skills, qualifications, experience, publications, speaking engagements, and preferences (e.g., mobility), absence and leave records, disciplinary and grievance information, and termination information.
• Other Information. That you volunteer to us or that we request from you as part of the application process.

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DATA USE

We collect, use, share, and store your Application Information for our operational purposes, as well as those of our service providers, in the recruitment and hiring process. This includes uses such as:

• processing applications
• tracking applications through the recruitment process
• contacting professional reference checks
• conducting background checks authorized by the Applicant
• evaluating Applicants for current and future job opportunities, including matching skills and interests to applicable job requirements
• communicating with Applicants throughout the hiring process
• making hiring decisions

We may also use Applicant Information for internal analysis purposes to understand the Applicants who apply and to improve our recruitment and interviewing process, including understanding and improving our diversity and inclusion efforts.

We may sometimes need to use Applicant Information for legal or compliance purposes, including for governmental reporting purposes or in connection with any challenges made to our hiring decisions.

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DATA SHARING

We may disclose Applicant Information to the following types of entities and/or in the following circumstances (where applicable):

• Internally: to our employees, workforce members, and others we work with who are involved in the recruiting and hiring process.
• Service Providers: to third parties with which we work, such as technology service providers, travel management providers, human resources suppliers, background check companies, recruitment consultants, providers of applicant tracking services, and employment or contractor agencies or recruiters, where applicable.
• Legal Compliance: when required to do so by law, regulation, or court order or in response to a request for assistance by the police or other law enforcement agency.
• Litigation Purposes: to seek legal advice from our outside counsel or other advisors or in connection with litigation with a third party.
• Business Transaction Purposes: in the event of a merger, sale of capital stock or assets, or similar transaction (or the due diligence in contemplation thereof).

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ADDITIONAL INFORMATION

Any questions about this Privacy Notice should be directed to privacy@ostrohealth.com.

Nothing in this Privacy Notice shall be construed as limiting or restricting Applicants from properly exercising any rights or entitlements under applicable federal, state, or local laws and regulations. To the extent anything in this Privacy Notice may conflict with any applicable law, such law will control.

Nothing in this Privacy Notice shall be construed as conferring any contractual right, either express or implied, to employment with us or any other party.

We reserve the right to modify, revise, discontinue, or terminate this Privacy Notice at any time with or without prior notice. Notwithstanding the foregoing, we may also provide Applicants with additional privacy notices regarding our collection, use, or disclosure of information in accordance with applicable law.

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