Global Employee Privacy Notice

‍EFFECTIVE DATE: November 14th, 2025

This Employee Privacy Notice (the “Notice”) describes how Particle Health (“Particle Health,” “we” or “us”)collects, uses, and discloses personal information of current and former employees, officers, and directors (each an “Employee” and collectively,“Employees,” “you,” and “your”). As used in this Notice, “personal information” means information that identifies, relates to, or could reasonably be linked to an Employee.

I. Scope

This Notice applies only to the personal information that Particle Health collects related to Employees, including personal information about emergency contacts, dependents and beneficiaries of Employees. We may provide additional notices to Employees in some circumstances.

This Notice does not address or apply to our collection of personal information of applicants, contractors, and customers, which is subject to other notices. This notice also does not apply to personal information collected about an Employee(1) who interacts with us in their capacity as a user of our services and notin their capacity as an Employee, or (2) who ceases to be an Employee, becomes an applicant or contractor, and interacts with us in their capacity as an applicant or contractor.

II. Collection use disclosure and retention of personal information

We collect, use, disclose, and retain personal information about Employees as described herein. Please note that our collection, use, disclosure, and retention of personal information may vary depending upon the circumstances, such as an Employee’s role and responsibilities with Particle Health.

Categories of Personal Information and How We Disclose Personal Information. The table below identifies, generally, the categories of personal information we collect about Employees, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose (subject to applicable laws).

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Categories of Personal Information

Third Parties to Whom We Disclose This Personal Information

Contact information/identifiers: such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number or other similar identifiers. We also collect identifiers about your emergency contact(s), dependent(s) and beneficiary(ies), if provided.

•   Service providers
•   Advisors and agents
•   Benefits providers
•   Recruiters
•   Regulators, government entities and law enforcement
•   Affiliates and subsidiaries
•   Internet service providers, operating systems and third-party platforms
•   Others as required by law
•   Others in the event of a business transaction (e.g.,sale or merger of our company)
•   With your consent or at your direction

Sensitive Information/ Characteristics of classifications protected under certain applicable laws:such as race, color, sex, sexual orientation, gender identity, age, religion, national origin, disability, citizenship status, military/veteran status, trade union membership; marital status, medical/health condition or disability information (e.g., as necessary to provide reasonable accommodations), social security numbers or other government identifiers, financial account information, or other characteristics of protected classifications under certain laws (e.g., California or Canadian law). (Note: generally, this information is collected on a voluntary basis and is used where necessary to provide accommodations to you, in support of our equal opportunity and diversity and inclusion efforts and reporting obligations, or where otherwise required bylaw.)

•   Service providers
•   Advisors and agents
•   Benefits providers
•   Regulators, government entities and law enforcement
•   Affiliates and subsidiaries
•   Others as required by law
•   Others in the event of a business transaction (e.g.,sale or merger of our company)
•   With your consent or at your direction

Internet or network activity information: such as browsing history, search history, and information regarding interactions with an internet website, application, or advertisement, as well as physical and network access logs and other network activity information related to your use of any Particle Health device, network or other information resource.

•    Service providers
•    Advisors and agents
•    Benefits providers
•    Regulators, government entities and law enforcement
•    Affiliates and subsidiaries
•    Internet service providers, operating systems and third-party platforms
•    Others as required by law
•    Others in the event of a business transaction (e.g., sale or merger of our company)
‍•    With your consent or at your direction

Geolocation data: location information about a particular individual or device.

Audio, video and other electronic data: audio, electronic, visual, thermal, olfactory, or similar information, such as, CCTV footage, photographs, and call recordings and other audio recordings (e.g., recorded meetings and webinars).

•    Service providers
•    Advisors and agents
•    Benefits providers
•    Regulators, government entities and law enforcement
•    Affiliates and subsidiaries
•    Others as required by law
•    Others in the event of a business transaction (e.g., sale or merger of our company)
‍•    With your consent or at your direction

Professional Information: professional or employment-related information, such as information related to your employment history during the recruitment process.

•    Service providers
•    Advisors and agents
•    Benefits providers
•    Recruiters
•    Regulators, government entities and law enforcement
•    Affiliates and subsidiaries
•    Others as required by law
•    Others in the event of a business transaction (e.g., sale or merger of our company)
‍•    With your consent or at your direction

Education information: information about education history or background.

•    Service providers
•    Advisors and agents
•    Benefits providers
•    Recruiters
•    Regulators, government entities and law enforcement
•    Affiliates and subsidiaries
•    Others as required by law
‍•    Others in the event of a business transaction (e.g., sale or merger of our company)
•    With your consent or at your direction

Inferences: inferences drawn from any of the information identified above to create a profile about Employees reflecting their preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

•   Service providers
•   Advisors and agents
•   Benefits providers
•   Recruiters
•   Regulators, government entities and law enforcement
•   Affiliates and subsidiaries
•   Others as required by law
•   Others in the event of a business transaction (e.g.,sale or merger of our company)
•    With your consent or at your direction

Sources of Personal Information. In general, Particle Health may collect the categories of personal information identified in the table above from the following categories of sources:

• The Employee;

• Recruiters;

• Other Particle Health employees;

• Publicly available information and sources;

• Benefits providers; and

• Our service providers, representatives and agents.

Retention. The personal information we collect from Particle Health Employees will be retained until we determine it is no longer necessary to satisfy the purposes for which it was collected and our legal obligations. As described above, these purposes include our business operations and complying with reporting, legal and accounting obligations. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes in other ways, the applicable legal requirements, and our legitimate interests.

Purposes for Processing Personal Information. Subject to applicable legal restrictions, generally, we collect, use, disclose and otherwise process Employee personal information for the following business and commercial purposes:

Compensation and benefits administration: relating to our administration of compensation and benefits, including:

• Administering employee payroll, salary and compensation;

• Administering employee pensions, IRAs and retirement plans, health insurance, medical plans, and other employee benefits administration (which may include the collection of personal information about others such as beneficiaries, where necessary to administer such benefits);

• Reviewing, assessing and administering employee salary and compensation increases and bonuses;

• Calculating deductions, issuing tax return-related documents and forms to employees;

• Reviewing timecards and reported time worked; and

• Monitoring and managing personal time off, holiday, and other leaves of absences.

Management of employment relationships: to manage our relationship with Employees, including related to:

• Hiring, terminations, relocation, transfers, promotions and disciplinary actions;

• Reviewing performance;

• Conducting Employee performance reviews, compensation and bonus reviews, and headcount and salary reviews;

• Administering and monitoring compliance with our policies and procedures;

• Maintaining records of emergency contact information for use in the event of an emergency;

• Administering or performing employment contracts where applicable;

• Conducting pre-employment and employment screening;

• For professional development and training purposes;

• Verification and management of applicable Employee credentials, licensing and other qualifications;

• Facilitating employee communication and collaboration, such as through the corporate directory, employee bios and other similar; and

• In support of our equal opportunity employment policy and diversity and inclusion program.

Business operations and client services: relating to the organization and operation of our business and our performance of services to clients, including related to:

• Auditing and assessing business operations, including client services and associated activities;

• Performance, training and quality control;

• Supporting business developing, marketing, sales and customer support activities;

• Satisfying client reporting and auditing obligations;

• Facilitating business development opportunities, as relevant; and

• Facilitating communications in furtherance of the foregoing.

Security and monitoring: to monitor and secure our resources, network, premises and assets, including:

• Detecting, preventing and investigating suspected or alleged misconduct or violations of work rules;

• Detecting, preventing, investigating, mitigating and responding to security and privacy incidents;

• Implementing and managing physical and technical access controls;

• Monitoring activities, access and use to ensure the security and functioning of our systems and assets; and

• Securing our offices, premises and physical assets, including through the use of electronic access systems and video monitoring.

Health and safety: for health and safety purposes, such as contact tracing or conducting appropriate screenings of individuals entering or accessing certain physical locations or premises.

Auditing, accounting and corporate governance: relating to financial, tax and accounting audits, and audits and assessments of our business operations, security controls, financial controls, or compliance with legal obligations, and for other internal business purposes such as administration of our records retention program.

M&A and other business transactions: for planning, due diligence and implementation of commercial transactions, for example mergers, acquisitions, asset sales or transfers, bankruptcy or reorganization or other similar business transactions.

Defending and protecting rights: to protect and defend our rights and interests and those of third parties, including to manage and respond to legal claims or disputes (including employee claims and disputes), and to otherwise establish, defend or protect our rights or interests, or the rights, interests, health or safety of others, including in the context of anticipated or actual litigation with third parties.

Complying with legal obligations: relating to compliance with applicable legal obligations (such as hiring eligibility, responding to subpoenas and court orders) as well as assessments, reviews and reporting relating to such legal obligations, including under employment and labor laws and regulations, Social Security and tax laws, environmental regulations, workplace safety laws and regulations, and other applicable laws, regulations, opinions and guidance.

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We may also use personal information for any other legally permitted purpose (subject to your consent, where legally required).

III. Personal information Rights

Depending on your jurisdiction of residence, you may have certain rights regarding your personal information. As provided in applicable law, these rights may include the right to:

• Request deletion or removal of certain personal information.

• Request access certain of your personal information, including the right to obtain confirmation of whether we are processing your personal information, obtain a copy of that information, and know certain information about our processing of your personal information, such as our processing purposes.

• Request correction of certain personal information we have about you that is inaccurate.

• Object to or request restriction of certain processing activities.

Exceptions. There are certain exceptions to the above rights. For instance, we may retain your personal information if it is reasonably necessary for us or our service providers to provide a service that you have requested, to comply with law, or to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity or prosecute those responsible for that activity. In addition, we reserve the right not to process requests that are manifestly unfounded or excessive, as provided inapplicable law, or that we are not legally obligated to process.

Submitting Requests. Employees may exercise their rights by emailing privacy@particlehealth.com. We will take steps to verify your request, such as by (i) sending you a confirmation email to your Particle Health email address (which you must take action to confirm), and/or (ii) matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. If permitted under applicable law, authorized agents may also initiate a request on behalf of another individual via email; authorized agents will be required to provide proof of their authorization and we may also require that the relevant Employee directly verify their identity and the authority of the authorized agent. We will not discriminate against you for exercising your rights.

California Disclosures.

· We do not ‘sell’ or ‘share’ for ‘cross-context behavioral advertising purposes (as defined by the California Consumer Privacy Act (“CCPA”)) any personal information covered by thisNotice and have not done so in the twelve months prior to the effective date of this Notice.

· Please note that to the extent we collect sensitive/protected classification information, we do not process such information for purposes subject to the “right to limit” under California law. Accordingly, we only use and disclose such sensitive information aboutCalifornia Applicants as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; and(v) for compliance with our legal obligations.

IV. Contacting Us About This Notice

If you have questions or concerns regarding this Notice or the handling of your personal information by ParticleHealth, please contact us at privacy@particlehealth.com.

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Global Employee Privacy Notice

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