PRIVACY POLICY

78 Ventures, Inc.

Effective 7/27/2026 · Last updated 7/27/2026

TEXT MESSAGING AT A GLANCE

• No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent are never shared with any third party.

• Message frequency varies. You may receive up to 15 messages per month.

• Message and data rates may apply.

• Reply STOP to any message to opt out. Reply HELP for assistance, or contact us at titus.c@seventyeightventures.com.

1. WHO WE ARE

78 Ventures, Inc. ("78 Ventures," "we," "us," or "our") is a New York corporation providing nurse staffing services to long-term care and skilled nursing facilities. This policy explains what personal information we collect, how we use it, and the choices you have.

This policy applies to our website, our text messaging program, and the information we collect from nurses and other clinicians who apply to work with us and from the facilities we serve.

2. INFORMATION WE COLLECT

From clinicians and applicants:

• Name, mobile phone number, email address, and mailing address

• Professional license and certification numbers, expiration dates, and issuing state

• Work history, availability, shift preferences, and rate expectations

• Credentialing records such as immunization status, background check results, and required health screenings

• Government identification and tax information where required to place you on assignment and process payroll

From facility clients:

• Business contact names, titles, phone numbers, and email addresses

• Staffing requirements, scheduling details, and billing information

Automatically from our website:

• Standard log information such as browser type, device type, and pages visited

3. HOW WE USE YOUR INFORMATION

• To evaluate applications, verify credentials, and match clinicians to open shifts

• To send shift offers, schedule confirmations, credentialing reminders, and assignment updates

• To process payroll, invoicing, and tax reporting

• To meet licensing, regulatory, and client contract requirements

• To respond to your questions and provide support

4. TEXT MESSAGING

If you provide your mobile number and consent to receive text messages, we may text you about open shifts, schedule changes, credentialing deadlines, and assignment details.

Consent is not a condition of employment or placement. You may decline text messages and still apply, be credentialed, and be placed on assignment.

We do not sell, rent, or share mobile phone numbers with third parties or affiliates for marketing or promotional purposes. Your opt-in consent and the mobile number associated with it are excluded from every category of sharing described in Section 5 and are not disclosed to any third party under any circumstances.

Message frequency varies based on your availability and the shifts we have open. You may receive up to 15 messages per month. Message and data rates may apply depending on your mobile plan.

To stop receiving messages, reply STOP to any message from us. You will receive one confirmation message and no further texts. To resume, reply START. For help, reply HELP or email titus.c@seventyeightventures.com.

5. WHEN WE SHARE INFORMATION

We share personal information only as described below, and only to the extent needed:

• Client facilities. When we present you for an assignment, we share the credentialing and qualification information the facility requires.

• Service providers. Payroll processors, background screening vendors, credentialing platforms, and scheduling software that work on our behalf under contract.

• Legal and regulatory. When required by law, subpoena, audit, or to protect our rights and the safety of others.

• Business transfer. In connection with a merger, acquisition, or sale of assets, subject to this policy.

We do not sell your personal information. As stated in Section 4, mobile numbers and text messaging consent are never included in any sharing described above.

6. HOW WE PROTECT YOUR INFORMATION

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, or disclosure, consistent with the New York SHIELD Act. Access is limited to personnel who need it to do their jobs. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

7. HOW LONG WE KEEP IT

We retain personal information for as long as needed to provide our services and to meet legal, tax, payroll, and credentialing recordkeeping obligations. Retention periods for employment and payroll records are generally set by federal and New York State law.

8. YOUR CHOICES

• Text messages. Reply STOP at any time.

• Email. Use the unsubscribe link in any marketing email, or contact us directly.

• Access and correction. Email us to request a copy of the information we hold about you, or to correct anything inaccurate.

• Deletion. Email us to request deletion. We may need to retain certain records to meet legal obligations.

9. CHILDREN

Our services are directed to licensed and certified healthcare professionals aged 18 and over. We do not knowingly collect personal information from anyone under 18.

10. CHANGES TO THIS POLICY

We may update this policy from time to time. When we do, we will revise the "Last updated" date above. Material changes to how we handle text messaging consent will be communicated directly.

11. CONTACT US

78 Ventures, Inc.

400 Rella Blvd Ste 207-549

Montebello, NY 10901

titus.c@seventyeightventures.com

8452763050