Anastasia Talent Group LLC

NATIONWIDE PRIVACY POLICY

Effective Date September 6 2026.

1. Scope

Anastasia Talent Group LLC (“ATG,” “we,” “us,” or “our”) respects privacy and is committed to handling personal information responsibly. This Privacy Policy describes how ATG collects, uses, discloses, retains, protects, and otherwise processes personal information in connection with its website, recruiting and executive-search activities, client relationships, business operations, marketing communications, and Candidate Mentorship Initiative.

This policy is intended to provide a nationwide baseline and to address applicable U.S. federal, state, and local privacy requirements. Particular rights may depend on the individual's state of residence, the nature of the information, the applicable law, and whether an exemption or threshold applies.

2. Information ATG Collects

• Identity and contact information, such as name, email address, telephone number, job title, company, and professional contact information.

• Professional and employment information, including resume/CV information, work history, education, skills, certifications, professional qualifications, compensation expectations, location, and career interests.

• Client and prospective-client information, including company information, hiring needs, role requirements, compensation ranges, search mandates, communications, and engagement information.

• Information submitted through ATG website forms, including Search Mandate and Contact forms.

• Information associated with agreements, invoices, communications, and other business records.

• Newsletter and marketing information, including email address, name, subscription status, preferences, and engagement information where applicable.

• Information voluntarily provided through ATG's Candidate Mentorship Initiative.

• Technical information made available through the website platform or embedded services, which may include IP address, browser/device information, and basic website interaction information.

3. Sources of Personal Information

ATG may receive personal information directly from individuals; from employers and prospective clients; from candidates and professionals; from referrals and business contacts; from publicly available professional sources; from recruiting and business systems; and from service providers operating technology used by ATG.

4. How ATG Uses Personal Information

• To provide executive search, direct-hire recruiting, targeted passive headhunting, and embedded/fractional talent advisory services.

• To evaluate and communicate with candidates and professionals in connection with recruiting opportunities.

• To understand and fulfill client search mandates and hiring requirements.

• To operate ATG's website, forms, communications, and business systems.

• To administer agreements, transactions, records, billing, and business relationships.

• To provide ATG Insights and other marketing communications when permitted and where individuals have subscribed or otherwise consented when required.

• To operate and administer the Candidate Mentorship Initiative.

• To maintain security, prevent fraud or misuse, protect legal rights, and comply with applicable law.

• To improve recruiting workflows, service quality, and internal operations.

5. Search Mandates and Client Information

When a company or other organization submits a search mandate or communicates with ATG about hiring, ATG may collect information concerning the organization, hiring requirements, position details, compensation, location, timing, organizational context, decision-makers, and related communications. ATG uses this information to evaluate the mandate, conduct discovery, develop a search strategy, perform recruiting services, communicate with the client, administer the engagement, and maintain appropriate business records.

6. Recruiting and Candidate Information

ATG may process professional information relating to candidates and prospective candidates for legitimate recruiting purposes, including identifying potential matches, communicating about opportunities, evaluating qualifications, presenting candidates to clients, coordinating interviews, and supporting placement activities.

Candidates and prospective candidates should avoid submitting unnecessary sensitive personal information unless specifically requested and legally appropriate.

7. AI-Assisted Resume Scanning

ATG uses Dover ATS, including AI-assisted resume scanning functionality, to assist with reviewing and organizing information contained in resumes submitted or otherwise processed through the recruiting workflow.

The AI-assisted resume-scanning functionality may extract, identify, organize, or surface information from resumes for recruiting workflow purposes. ATG does not represent that this technology independently makes final hiring or placement decisions. Human review and recruiting judgment remain part of ATG's candidate evaluation and placement process.

ATG does not currently use AI video interviewing, facial analysis or facial recognition, voice analysis or voiceprint technology, or biometric technology as part of its recruiting, candidate evaluation, or hiring-related processes.

8. Human Review, Fairness, and Accessibility

ATG uses human judgment in its recruiting and client-service processes. ATG does not intend for automated resume-processing technology to replace appropriate human evaluation. ATG seeks to conduct recruiting activities consistently with applicable equal-employment, anti-discrimination, accessibility, and privacy requirements.

Individuals who need an accommodation or who believe that information has been inaccurately processed may contact ATG using the privacy contact method provided below.

9. Third-Party Providers and Business Systems

ATG uses third-party technology and service providers to operate its business. Depending on the activity, these may include:

• Tally — website forms and form submissions.

• HubSpot — client and prospective-client relationship management.

• Kit — ATG Insights/newsletter marketing and subscriber management.

• Dover — recruiting applicant-tracking and resume-scanning workflow.

• Microsoft — internal business files and productivity infrastructure.

• RabbitSign — electronic execution and administration of agreements.

• Google Sites — website hosting/platform functionality.

• biBerk — business insurance and related risk-management administration.

These providers may process information on ATG's behalf subject to their applicable terms, privacy practices, contracts, and security controls. ATG does not sell personal information to these providers for their independent advertising purposes.

10. Website Cookies, Analytics, and Tracking

ATG's public website is operated using Google Sites. The website or embedded third-party services may use cookies, similar technologies, and technical information for site functionality, security, performance, and basic usage purposes.

Based on ATG's current website configuration, ATG does not represent that it operates a separate advertising-pixel or behavioral-advertising program on the website. ATG will update this Privacy Policy and implement applicable consent or opt-out mechanisms if it later adds analytics, advertising pixels, tracking technologies, or other non-essential technologies requiring disclosure or consent.

Because platform-level cookies and embedded services can change over time, this policy should be read together with any applicable cookie or privacy controls presented through the website.

11. Information Sharing

• With clients as reasonably necessary to perform recruiting and search services, including presenting candidate qualifications.

• With candidates or professionals as reasonably necessary to communicate about opportunities or recruiting processes.

• With service providers that perform functions on ATG's behalf.

• With professional advisers, insurers, auditors, legal counsel, or other business partners where reasonably necessary for ATG's operations.

• When required by law, legal process, court order, or governmental request.

• When reasonably necessary to protect ATG, its clients, candidates, personnel, systems, or legal rights.

• In connection with a business transaction such as a merger, acquisition, restructuring, financing, or sale of assets, subject to applicable law.

ATG does not sell personal information for monetary consideration as a business practice.

12. Data Minimization and Sensitive Information

ATG seeks to collect and retain information reasonably necessary for legitimate recruiting, client-service, business, legal, security, and compliance purposes. Individuals should not provide sensitive personal information unless it is relevant and appropriate to the particular interaction.

Where applicable law imposes heightened requirements on sensitive personal information, ATG will process such information in accordance with those requirements.

13. Biometrics

ATG does not currently collect or process biometric identifiers or biometric information through facial recognition, voiceprints, biometric screening, or similar technologies as part of its recruiting or hiring workflow. If ATG's practices materially change, ATG will update its privacy disclosures and implement legally required safeguards before using such technology.

14. ATG Insights and Marketing

ATG may offer ATG Insights — The Talent Intelligence Brief and other marketing communications. Newsletter subscribers may be managed through Kit or another designated marketing platform. ATG may use subscription information to send requested communications, manage preferences, measure basic engagement where configured, and comply with applicable marketing laws.

Recipients may unsubscribe from marketing communications using the unsubscribe mechanism provided in the communication or by contacting ATG.

15. Candidate Mentorship Initiative

ATG's Candidate Mentorship Initiative is a free, community-oriented and volunteer initiative separate from ATG's commercial recruiting services. Information submitted for participation may be used to coordinate mentorship, provide career guidance, support networking and job-search readiness, and administer the initiative.

Participation in the Candidate Mentorship Initiative does not create a paid recruiting engagement or contractual obligation.

16. Data Retention and Deletion

ATG maintains an internal process governing retention, review, deletion, and disposal of personal information. Retention periods vary based on the purpose for which information was collected, recruiting and client-service needs, contractual obligations, legal requirements, dispute resolution, insurance requirements, security needs, and legitimate business requirements.

When information is no longer required to be retained, ATG's procedures are designed to provide for appropriate deletion, destruction, de-identification, or other disposition, subject to legal holds and other lawful retention obligations.

17. Security

ATG maintains administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, loss, or destruction. No method of transmission or storage is completely secure, and ATG cannot guarantee absolute security.

ATG uses business technology and service providers that maintain their own security measures and contractual/privacy obligations. ATG also maintains business insurance that includes errors and omissions, general liability, and cyber coverage.

18. Nationwide Privacy Rights

Depending on applicable law, individuals may have rights that include access to personal information, correction, deletion, portability, objection or opt-out of certain processing, restriction of certain processing, and the right to appeal a privacy-rights decision.

Some state laws also provide rights concerning targeted advertising, sale or sharing of personal information, profiling, sensitive personal information, universal opt-out signals, and nondiscrimination. These rights are subject to applicable statutory thresholds, exemptions, verification requirements, and other limitations.

19. State-Specific Privacy Requirements

ATG maintains this policy as a nationwide baseline and will provide additional rights and disclosures where required by applicable state or local law.

As of the effective date of this policy, comprehensive state privacy laws are in effect in California, Virginia, Colorado, Connecticut, Utah, Oregon, Montana, Texas, Florida, Delaware, Iowa, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, and Rhode Island.

Additional comprehensive privacy laws enacted but scheduled to become effective later include Oklahoma (January 1, 2027), Alabama (May 1, 2027), and Vermont (January 1, 2028). ATG will review and update its practices as applicable laws become effective.

Other states may impose separate requirements involving data security, breach notification, biometrics, health information, employment information, communications, consumer protection, or other categories of personal information. ATG will comply with applicable requirements.

20. California Privacy Notice

California residents may have rights under the California Consumer Privacy Act, as amended, including rights to know/access, correct, delete, opt out of sale or sharing where applicable, limit certain uses of sensitive personal information where applicable, and receive equal treatment for exercising privacy rights.

ATG does not sell personal information for monetary consideration as a business practice. If ATG engages in processing that constitutes a sale or sharing under applicable California law, ATG will provide the disclosures and opt-out mechanisms required by law.

California residents may submit privacy requests through the contact method below. ATG may verify requests as required by law before completing them.

21. Universal Opt-Out Signals

Where required by applicable law, ATG will recognize and process legally valid universal opt-out preference signals for applicable processing activities. The scope and effect of such signals may depend on the applicable law and the type of processing involved.

22. Privacy Requests, Verification, and Appeals

ATG maintains an internal process for handling privacy requests, including requests for access, correction, deletion, portability, restriction or objection where applicable, and other rights provided by law.

ATG may request information reasonably necessary to verify the identity and authority of the person making a request. Verification requirements are intended to protect individuals from unauthorized disclosure or deletion of information.

ATG also maintains a process for reviewing and responding to privacy-rights appeals where an applicable law provides an appeal right. Requests and appeals will be handled within applicable statutory time periods, subject to lawful extensions and permitted exceptions.

23. Children

ATG's website and commercial services are not directed to children under 13. ATG does not knowingly collect personal information from children under 13 through its website. If ATG learns that it has received such information in circumstances where collection is not permitted, it will take appropriate steps consistent with applicable law.

24. Third-Party Websites and Services

ATG may provide links or access to third-party websites, platforms, or services. Their privacy practices are governed by their own policies. ATG is not responsible for the privacy, security, or content practices of independent third parties.

25. Changes to This Privacy Policy

ATG may update this Privacy Policy from time to time to reflect changes in its business practices, technology, legal requirements, or services. The updated version will be posted on ATG's website with a revised effective date where appropriate.

26. Privacy Contact

Privacy requests, questions, or appeals may be submitted to Anastasia Talent Group LLC through the privacy contact method designated on ATG's website.

General business contact: info@anastasiatalentgroup.com

Telephone: (888) 916-HIRE

Location: Westmont, Illinois

ATG may establish or designate a dedicated privacy email address in the future and will update this policy and website contact information accordingly.