Privacy Policy

Last Updated September 1, 2025

Olaro Group Inc. and its wholly and majority-owned entities (collectively, “OLARO GROUP INC”), respect your concerns about privacy. References in this Privacy Policy to “OLARO GROUP INC”, “we”, “us”, and “our” are references to the entity responsible for the processing of your personal information, which generally is the entity that obtains your personal information.

This Privacy Policy applies to the personal information we obtain through the OLARO GROUP INC properties, including websites, mobile applications and social media pages that reference this Privacy Policy (“Online Channels”); offline collection in connection with sales, marketing, partner and supplier engagement (“Offline Channels”); and third-party sources, including ad networks and lead brokers (collectively, the “Channels”). This Privacy Policy does not apply to personal information obtained through products and services that post separate privacy policies.

This Privacy Policy describes the types of personal information we obtain through the Channels, how we may use that personal information, with whom we may share it, and how you may exercise your rights regarding our processing of the information. The Privacy Policy also describes the measures we take to safeguard the personal information we obtain and how you can contact us about our privacy practices.

The Online Channels may provide links to other third-party websites and features, or contain third-party cookies, that are not owned or controlled by the OLARO GROUP INC. Please review the privacy policies of these third parties to familiarize yourself with their practices.

Personal Information We Obtain

We may obtain personal information through the Channels. The types of personal information we may obtain include:

contact information (such as name, phone and fax number, email and postal address) for you or for others (e.g., principals in your business);
information used to create your online account (such as username, password and security question and answer);
biographical and demographic information (such as date of birth, age, gender, job title/position, marital status and dependent, spousal and other family information);
purchase and customer service history;
financial information (such as payment information, including name, billing address and payment card details (i.e., card number, expiration date and security code); bank account information; financial statements; income; and credit score);
location data (such as data derived from your IP address, country and zip code) and the precise geolocation of your mobile device where we have provided notice and choice, as appropriate;
audio, electronic, or visual information;
contact information you provide about friends or other people you would like us to contact;
inferences about you, including about your preferences;
clickstream data and other information about your online activities (such as information about your devices, browsing actions and usage patterns), including across the Online Channels and third-party websites, that we obtain through the use of cookies, web beacons and similar technologies and other personal information contained in content you submit to us.

In addition, we may obtain government-issued ID numbers and Tax ID numbers, such as US Social Security numbers.

We use third-party web analytics services in connection with the Online Channels, including Google Analytics, Adobe Analytics and Market, which use cookies and similar technologies to collect data (such as IP addresses) to evaluate use of and interaction with the Online Channels.

Please note that providing personal information to us is voluntary on your part. If you choose not to provide us certain information, we may not be able to offer you certain products and services, and you may not be able to access certain features of the Online Channels.

Cookies and Similar Technologies

Like most companies, OLARO GROUP INC uses cookies and similar technologies (“cookies”) on our websites to personalize and enhance your experience on our sites.

How We Use Cookies

Cookies contain small amounts of information which are downloaded to your device when you visit our website. Cookies are sent back to our website to allow us to recognize your device.

Essential Cookies allow us to recognize your device to help you navigate efficiently to obtain the information and services you have requested.

Analytical and Customization Cookies allow our site to remember your preferences such as language selection, and help you to view information that is most relevant to your interests; these cookies also help us to maintain and improve our websites by providing information on how visitors find and use the sites, and how well the sites are performing.

Advertising Cookies may be used in some cases to make advertising messages more relevant to you.

Making Cookie Choices

You may see the list of OLARO GROUP INC and selected partner cookies on our website and make choices about those cookies. Most browsers allow you to manage cookie preferences. If you decide to disable cookies on our site, you may not be able to take full advantage of all our website features once you have done so. Except for cookies that are essential to the operation of this website (Essential Cookies), you may make choices about the cookies on this website. Please note that if you choose to manage cookies on our websites, the Tool will place a cookie on your device to allow your choices to be honored.

Sharing Tools

To enhance your experience on our websites, we sometimes embed content and sharing tools from other third-party sites, such as “like” buttons from social networking sites; these third-party sites may also place and access cookies on your device. OLARO GROUP INC does not control the placement or access of these third-party cookies. Please review the privacy policies of these third parties to familiarize yourself with their practices.

How We Use Personal Information

We may use the personal information we obtain to:

provide and administer our products and services;
process and fulfill orders and keep you informed about the status of your order;
communicate about and administer our products, services, events, programs and promotions (such as by sending alerts, promotional materials, newsletters and other marketing communications);
conduct and facilitate surveys, sweepstakes, contests, focus groups and market research initiatives;
perform data analytics (such as market research, trend analysis, financial analysis and customer segmentation);
engage in ad retargeting and evaluate the effectiveness of our marketing efforts (including through our participation in ad networks);
provide customer support;
process, evaluate and respond to requests, inquiries and applications;
create, administer and communicate with you about your account (including any purchases and payments);
administer and register participants in our courses;
provide investor services;
conduct marketing and sales activities (including generating leads, pursuing marketing prospects, performing market research, determining and managing the effectiveness of our advertising and marketing campaigns and managing our brand);
operate, evaluate and improve our business (such as by administering, enhancing and improving our products and services; developing new products, services and Online Channels; managing our communications and customer relationships; and performing accounting, auditing, billing, reconciliation and collection activities);
verify your identity and protect against and prevent fraud and other unlawful activity, unauthorized transactions, claims and other liabilities, and manage risk exposure and quality;
conduct investigations and comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our policies and terms (such as this Privacy Policy and other Online Channels terms of use); and
maintain and enhance the safety and security of our products, services, Online Channels, network services, information resources and employees.

We may combine personal information we obtain through Online Channels with information we obtain through Offline Channels, as well as other information, for the purposes described above. We may anonymize or aggregate personal information and use it for the purposes described above and for other purposes to the extent permitted by applicable law. We also may use personal information for additional purposes that we identify at the time of collection. We will obtain your consent for these additional uses to the extent required by applicable law.

Where required by applicable law, we will obtain your consent for the processing of your personal information for direct marketing purposes.

The legal basis for OLARO GROUP INC processing your personal information as described above will typically be one of the following:

Your consent;
Performance of a contract with you or a relevant party;
Our legitimate business interests; or
Compliance with our legal obligations.

Personal Information Sharing

We do not sell or otherwise disclose personal information about you except as described here or at the time of collection.

We may share personal information within OLARO GROUP INC for the purposes described in this Privacy Policy.
We may share personal information with service providers we have retained to perform services on our behalf (such as payment processing, order fulfillment, customer support and data analytics). These service providers are contractually required to safeguard the information provided to them and are restricted from using or disclosing such information except as necessary to perform services on our behalf or to comply with legal requirements.
We may share personal information with our joint marketing partners and other business partners for the purposes described in this Privacy Policy, or in the case of processing that is specific to a particular OLARO GROUP INC entity.
We may disclose personal information about you (1) if we are required or permitted to do so by applicable law or legal process (such as a court order or subpoena), (2) to law enforcement authorities or other government officials to comply with a legitimate legal request, (3) when we believe disclosure is necessary to prevent physical harm or financial loss, (4) to establish, exercise or defend our legal rights, (5) in connection with an investigation of suspected or actual fraud or illegal activity or (6) otherwise with your consent.
We reserve the right to transfer to relevant third-parties any information we have about you in the event of a potential or actual sale or transfer of all or a portion of our business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation) or other business combination. In such case, we will require the relevant third parties to provide comparable levels of protection as OLARO GROUP INC provides with respect to the information we share.

Data Transfers

We may transfer the personal information we collect through the Channels to, and store such data in, other countries, including the U.S.A., which may have different data protection laws than the country in which the information was provided. If we do so, we will transfer the personal information only for the purposes described in this Privacy Policy. To the extent required by applicable law, when we transfer your personal information to recipients in other countries, we will take measures to protect that information.

Your Choices

We offer you certain choices in connection with the personal information we obtain about you. To update your preferences, or limit the communications you receive from us, please contact us as specified in the How To Contact Us section of this Privacy Policy.

You also may exercise choice over how information about your interests is used by ad networks to deliver you relevant advertising. To learn how to opt out of ad network interest-based advertising in the United States, please visit Digital Advertising Alliance, and the Network Advertising Initiative. In the European Union, please visit European Interactive Digital Advertising Alliance. The Online Channels are not designed to respond to “do not track” signals received from web browsers.

To the extent provided by the law of your jurisdiction, you may have the right to (1) access certain personal information we process about you and request details of that processing; (2) request that we update, correct, amend, erase, or restrict your personal information or; (3) exercise your right to data portability. Where provided by law, you may withdraw consent you previously provided to us or object at any time to the processing of your personal information on legitimate grounds relating to your particular situation, and we will apply your preferences going forward as appropriate. To request to exercise these rights, please contact us by clicking here. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. To the extent permitted by applicable law, a charge may apply before we provide you with a copy of any of your personal information that we maintain. Depending on your location, you may have the right to file a complaint with a government regulator if you are not satisfied with our response. OLARO GROUP INC endeavors to respond to complaints within thirty days of receipt.

How We Protect Personal Information Transmission

We maintain administrative, technical and physical safeguards, consistent with legal requirements where the personal information was obtained, designed to protect against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal information provided to us through the Channels.

Retention of Personal Information

To the extent permitted by applicable law, we retain personal information we obtain about you as long as (1) it is needed for the purposes for which we obtained it, in accordance with the provisions of this Privacy Policy or (2) we have another lawful basis, stated in this Privacy Policy or at the point of collection, for retaining that information beyond the period for which it is necessary to serve the original purpose for obtaining the personal information.

Children’s Personal Information

The Online Channels are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through the Online Channels. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us by clicking here.

Changes to Our Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices. We will indicate at the top of this Privacy Policy when it was most recently updated.

How to Contact Us

If you have any questions or comments about this Privacy Policy or if you would like us to update information we have about you or your preferences, please contact us at (404) 736-6807 or write to us at:

1725 Windward Concourse
Suite 100, Alpharetta,
GA 30005

Candidate Privacy Notice

Introduction

This notice (Notice) describes how Olaro Group Inc. and its subsidiaries and related companies (collectively, OLARO GROUP INC) handle and protect data to which OLARO GROUP INC is provided access in connection with the recruiting process.

By making available your Candidate Data, as defined below, you confirm that:

You have reviewed this Notice and agree that OLARO GROUP INC may process your Candidate Data in accordance with this Notice;
You have provided any notices and obtained any consents needed to provide information concerning others (e.g., information about employment references or information on third parties’ experience with working for the government); and
Your Candidate Data may be transferred and processed worldwide, including the USA and other countries that may not be deemed to provide the same level of data protection as your home country, for the purposes and in the manner specified in this Notice.

OLARO GROUP INC will process Candidate Data in accordance with this Notice, unless in conflict with requirements of applicable law, in which case applicable law will prevail.

Your consent to the provisions of this Notice is required in order to submit or make available Candidate Data. If you decline to submit or make available your Candidate Data, it may affect your ability to apply for or receive an offer of employment.

This Notice does not form part of any contract of employment offered to candidates hired by OLARO GROUP INC.

Definitions

Candidate Data is identifiable information that an individual makes available to OLARO GROUP INC either directly or indirectly in connection with the recruiting process, or sharing your work experience or interests. OLARO GROUP INC may collect Candidate Data directly from a job candidate or from third parties, for example, in connection with a background or employment check or employment reference, subject to your consent where required by law. Candidate Data may include a variety of information, such as candidate status, work history/job data, education, compensation, employer feedback, questionnaire results, contact information, previous addresses or names, additional information provided by the candidate (e.g., a cover letter), expertise or project work publicly shared, driver’s license number as required for certain positions, references, and criminal history where permitted by law, 3rd party information that might be required to determine any potential conflict of interest that may affect to your application when certain regulatory conditions are met.

Processing refers to any action performed on Candidate Data, such as collecting, recording, organizing, storing, transferring, modifying, using, disclosing, or deleting.

Sensitive Candidate Data is Candidate Data concerning nationality or citizenship, race or ethnic origin, criminal history, or trade union membership. OLARO GROUP INC does not request or consider information concerning religion, sex life or political opinions in connection with recruiting.

OLARO GROUP INC Companies includes ASTA Solutions, Inc.; Premier Healthcare Professionals, Inc.; Autumn Enterprises, LLC and Adevia Health USA Inc.

Collection

You may use various electronic and paper methods to submit Candidate Data to OLARO GROUP INC. You agree that, in addition to collecting Candidate Data directly from you, OLARO GROUP INC may collect Candidate Data from third parties, for example, from recruiters, in connection with a background or employment check or an employment reference (subject to your consent where required by law) or, to the extent permitted by law, from a recruiting or other web site where you may have provided information about your work experience or interests.

Processing and Retention

OLARO GROUP INC processes Candidate Data for human resources and business management purposes. These include identifying and evaluating candidates for OLARO GROUP INC positions; record-keeping related to hiring processes; analyzing the hiring process and outcomes; and conducting background checks, where permitted by law. Furthermore, to evaluate conflicts of interest, OLARO GROUP INC asks for past work experience. This refers to both, you as the applicant yourself, as well as third parties like business partners or relatives. Please make sure, that the concerned data subjects are informed about you providing the data as well as their rights. In addition, Candidate Data may be used to comply with OLARO GROUP INC’s legal, regulatory and corporate governance requirements. If a candidate is hired, Candidate Data may be used in connection with his/her employment consistent with OLARO GROUP INC’s employment data protection policies.

In addition to using Candidate Data for the position for which you have applied, OLARO GROUP INC may retain and use your Candidate Data to consider you for other positions. If you do not want to be considered for other positions or would like to have your Candidate Data removed, you may contact OLARO GROUP INC as specified under Inquiries, Complaints, Objections and Restrictions below. Unless required for tax or other legal purposes or in connection with employment as specified above, Candidate Data will be retained for a maximum of three years (or less where required by law) except in the US.

Sharing with other OLARO GROUP INC Companies and Third Parties

OLARO GROUP INC may process Candidate Data jointly with another OLARO GROUP INC Company when the candidate applies during the transition period.

OLARO GROUP INC may transfer Candidate Data to external third-party providers performing certain services for OLARO GROUP INC. Such third-party providers have access to Candidate Data solely for the purposes of performing the services specified in the applicable service contract, and OLARO GROUP INC requires the providers to undertake security measures consistent with the protections specified in this Notice.

OLARO GROUP INC may be required to disclose certain Candidate Data to other third parties (1) as required by law; (2) to protect OLARO GROUP INC’s legal rights to the extent authorized or permitted by law; or (3) in an emergency where the health or safety of a candidate or other individual may be endangered. In addition, in the event of a re-organization, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of OLARO GROUP INC’s business, OLARO GROUP INC may transfer Candidate Data to successor entities or parties. OLARO GROUP INC does not share OLARO GROUP INC Candidate Data with the Separated business entities once the transition period expires.

International Data Transfers

OLARO GROUP INC operates globally different countries. Accordingly, Candidate Data may be transferred to and processed in the US and other countries that may not be deemed to provide the same level of data protection as your home country. OLARO GROUP INC maintains and applies employment data protection standards consistent with those specified in this Notice to its operations globally.

Sensitive Candidate Data

OLARO GROUP INC may perform background and criminal checks where permitted by law, and may process other Sensitive Candidate Data, such as citizenship or nationality information or health information, when relevant for a position and permitted by law. If OLARO GROUP INC intends to collect Sensitive Personal Data from third parties, you will be provided notice and the opportunity to consent. If you have a disability and would like OLARO GROUP INC to consider an accommodation, you may provide that information during the recruiting process. To the extent you make Sensitive Candidate Data available to OLARO GROUP INC, you consent to OLARO GROUP INC processing such Data in accordance with this Notice.

Security and Confidentiality

OLARO GROUP INC employs technical and organizational measures designed to protect the integrity, confidentiality, security and availability of Candidate Data, and to comply with applicable legal requirements for information security. OLARO GROUP INC limits access to internal systems that hold Candidate Data to individuals who need access for a legitimate business purpose.

Candidate Rights

You may exercise the following rights in relation to your Candidate Data:

Access, Correction, Deletion and Portability: OLARO GROUP INC will provide you access to your Candidate Data that OLARO GROUP INC holds, as well as a means to make that data portable, to the extent required by law in your home country, regardless of the location of the Candidate Data processing. You may request correction or deletion of that Candidate Data, except where retention is required by your contractual relationship with OLARO GROUP INC, in the context of a legal dispute, or as otherwise required by law. If access, correction, deletion or portability is denied, the reason for the denial will be communicated to you.

To initiate any request for OLARO GROUP INC, click here.

Automated Decisions: OLARO GROUP INC generally does not make recruiting or hiring decisions based solely on automated decision-making within the meaning of the EU General Data Protection Regulation. In the event that OLARO GROUP INC relies solely on automated decision-making that could have a significant impact on you, OLARO GROUP INC will provide you an opportunity to express your views and will provide any other safeguards required by law.

Inquiries, Complaints, Objections and Restrictions: You may withdraw consent to the processing of your Candidate Data or submit inquiries, complaints, objections and/or requests to restrict processing to the processing of your Candidate Data by sending a request by clicking here.

This option is also available to third parties (business partners or relatives) whose data has been submitted to OLARO GROUP INC as part of the past experience in working for a government query. The processes described in this Notice supplement any other remedies and dispute resolution processes provided by OLARO GROUP INC and/or available under applicable law.

Direct Marketing

OLARO GROUP INC will not use Candidate Data to offer you any products or services for personal or family consumption (“direct marketing”) or provide Candidate Data to third parties for their direct marketing. These restrictions do not apply to contact or other personal data obtained in the context of a customer, consumer or other non-employment relationship with OLARO GROUP INC.

Changes to this Notice

OLARO GROUP INC reserves the right to modify this Notice by posting changes to relevant OLARO GROUP INC websites. If you submit additional Candidate Data or request to be considered for a OLARO GROUP INC position following the effective date of a modified Notice, your Candidate Data will be handled in accordance with the Notice in effect at that time.

Effective Date: September 2025.