Privacy Policy

• as part of a press check or background check, including; verification of educational or professional credentials;

• to help support and improve our business operations (e.g. interview transcription (if applicable), audit procedures, security processes, document storage, maintenance of our systems and infrastructure, data analytics, benchmarking, statistics, creating knowledge pieces, determining the effectiveness of our services);

• to share marketing and promotional materials (e.g., intellectual capital, thought leadership pieces, etc.);

• to invite you to an industry and/or role-specific event (e.g., forum, charity event, etc.);

• to work with partners, sponsors and vendors, including third-party travel agencies;

• maintaining business records, including those related to our services;

• to exercise our legal rights, protect your interests, or as required by applicable law;

We strive to ensure that your personal data is accurate, complete, and current. Your data will only be used in a way that is compatible with its intended use and will not be processed in any way that is contrary to what is outlined in this policy. We will not sell your personal data.

Newpath’s legal basis for processing your personal data in the context of providing its services will depend on the personal information and processing activity involved and the specific context in which it was obtained. This can be:

• our legitimate business interest, provided the processing of such information is not overridden by your own interests or your fundamental rights and freedoms. For example: managing, operating or promoting our business, building and maintaining relationships with you, our clients and vendors, analyzing and improving our services, and managing

our IT systems (including audits);

• your consent, where required by applicable law. For example: for background checks, for any potentially sensitive information that may come to light during interviews, for employment diversity requirements, for recorded interview sessions; or

• our compliance with legal and regulatory requirements under applicable laws such as: keeping records for tax purposes or for accounting, or providing information to public authorities.

Personal information is held on NewPath’s database. In order to guarantee that the appropriate and suitable safeguards for the protection of your personal data are in place, in addition to the privacy practices set out in this policy, NewPath has a set of binding corporate rules. These binding corporate rules are a commitment by NewPath to adequately protect personal information of data subjects, regardless of where the data resides.

NewPath may, in the course of our business, transfer your information to clients, partners, or approved third-party providers (such as background check providers, or travel/ catering related service providers) in the context of the activities outlined in this policy.

We may disclose personal information where required by law or in connection with any legal claims, subpoenas, warrants or other governmental/regulatory/judicial requests. If NewPath receives a lawful access request from a third-country authority, our best efforts will be made to use all legal, technical, organizational, and supplementary measures available to limit the data that can be accessed in order to support the protection of your rights. We may disclose data where necessary to exercise, establish, or defend our legal rights, or to protect your vital interests or those of any other person.

NewPath has implemented appropriate measures to safeguard personal information collected, ensure its proper use and prevent against accidental loss, unauthorized access, or unlawful processing. These measures are periodically reviewed and updated to remain aligned with legal and technological developments. Such measures include but are not limited to contractual provisions, encryption, logical separation, and access security.

NewPath will retain your personal data for as long as the data is needed in connection with the purposes for which it is being processed and depending on the nature of our relationship with you.

Specifically, we will retain personal data for as long as we have your consent or a legitimate interest to do so. We may also be required to retain certain personal information (i) for our business records (ii) to show that we have fulfilled our obligations towards relevant parties such as our clients and candidates, or to continue meeting any of our obligations once we have completed an assignment in which you may have been involved in, (iii) for us to be able to establish, exercise or defend our legal rights, or (iv) to otherwise comply with our legal obligations.

Once the need to retain your data has expired, we will delete or anonymize it in accordance with data minimization principles. If this is not possible at the time, (for example, because your personal information has been stored in backup archives) then we will securely store your personal information and isolate it from any further processing until deletion is possible.

You have the right to access, erase, correct, update, or complete your personal data, or to request no further contact from NewPath. Additionally, to the extent allowed under applicable laws, you have the right to request the transfer of your personal data to a third party, to object to our use of your personal information, or to object to certain types of processing of your personal information. You can also withdraw your consent at any time; however, such withdrawal will not affect any processing performed prior to your withdrawal, nor will it affect processing on the basis of other lawful grounds. Should you request that we delete your personal information, please note that we may keep a minimal amount of data for record keeping purposes (for example, to record your wish for your data to be deleted). If you wish to exercise any of these rights, you may contact support@newpathhealthcare.com. Additionally, you may bring a complaint to the relevant data protection authority about our processing of your personal information If you are a California resident, you have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”). Specifically, you may request the categories of personal data we have collected, the sources of such personal information, and the specific pieces of personal data we have collected about you. If applicable, you may also request the business or commercial purpose we have for collecting your personal data, the categories (outlined above) of your personal data we have shared or disclosed, and the categories of third parties to whom we have shared or disclosed such personal data. You also have the right to request the deletion of your personal data. To exercise any of your rights, you may contact support@newpathhealthcare.com, or you may call us at 747-609-7300. We will not discriminate against you for exercising any of your rights pertaining to your personal data.

We may occasionally update this policy. Any material changes made will be posted on this page and the appropriate measures will be taken to keep you informed. Please visit this page on a regular basis to ensure that you remain up to date with our policy. If you have any questions about this Privacy Policy, please e-mail us at support@newpathhealthcare.com.