Effective Date: October 15, 2026 Version: 1.0 Applies to: All Company employees.
Article 1: Introduction and Scope
1.1 This document states what information of the Company, of customers, and of Employees is confidential, what an Employee shall and shall not do with that information, and what happens when the duty of confidence is broken. This document governs the handling of confidential information in every form: spoken, written, printed, photographed, and recorded in a Company System.
1.2 This document binds every Employee who receives, creates, or gains access to confidential information in the course of employment, whether the information was marked confidential or not. The Employee Code of Conduct states the daily conduct duties under this document.
1.3 If a provision of this document conflicts with the Terms of Use, this document controls for the subject it governs. If a provision conflicts with the terms of a program in which the Employee participates, the program terms control for that program. Help pages explain this document; they do not amend it.
Article 2: Definitions
2.1 The definitions in the Employee Code of Conduct are incorporated into this document by reference. This article defines only the additional terms used in this document, in alphabetical order.
2.2 Confidential Information: information of the Company, of a customer, of a Seller, or of an Employee that is not public, that an Employee receives or creates in the course of employment, and that falls within Article 3.
2.3 Customer Information: information that identifies or relates to a customer or a customer's pet, including contact details, addresses, order and appointment history, payment references, notes, and photographs.
2.4 Personnel Information: information in an employment record, including compensation, evaluations, disciplinary records, manager notes, medical and leave information, and identification documents.
Article 3: Information That Is Confidential
3.1 Each of the following is Confidential Information, whether or not marked as confidential (a) Customer Information, including customer and pet information recorded in appointment notes, handling notes, and before-and-after photographs;
(b) Personnel Information, including the compensation, rate, and pay details of any Employee;
(c) Company business information that is not public, including pricing structures, margins, supplier terms, sales and performance figures, plans, and the contents of internal reports;
(d) credentials, access records, security arrangements, and the contents of audit logs;
(e) information received from a Seller, a supplier, or another business under an obligation of confidence; and
(f) the contents of a report made under the Whistleblower and Internal Reporting Policy and of an investigation under the Incident Response Policy, except as those documents provide.
3.2 Information is not Confidential Information where the Company has published the information for general use, or where the information is the Employee's own Personnel Information and the Employee deals with it as Article 6 provides.
Article 4: Duties of Non-Disclosure and Use
4.1 The Employee shall not disclose Confidential Information to any person, inside or outside the Company, except to a person who is authorized to receive it and who needs it for the work the Employee is performing.
4.2 The Employee shall use Confidential Information only for the duties of the Employee's employment. The Employee shall not use Confidential Information for personal benefit, for another business, or for any purpose after the employment ends.
4.3 The Employee shall not copy, photograph, download, forward, or remove Confidential Information from a Company System or from Company premises, except as the Employee's duties require and a Company System designated for the purpose permits. The Employee shall not keep Confidential Information in a personal account, a personal application, or on a personal device, except where the Data Access and Least Privilege Policy expressly permits the device and the use.
4.4 The Employee shall not discuss Confidential Information where a customer, a member of the public, or an unauthorized Employee can hear or read the discussion, and shall not leave printed Confidential Information unattended. On a shared device, the Employee shall sign out as the Authentication Controls Policy requires, so that Confidential Information is not exposed to the next user.
4.5 Where an Employee is unsure whether information is confidential, or whether a person is authorized to receive it, the Employee shall treat the information as confidential and shall ask the Employee's Manager before disclosing it.
Article 5: Compensation and Personnel Information
5.1 Compensation information is Confidential Information. The Employee shall not photograph, copy, or remove a pay screen or a pay record, and shall not disclose another Employee's compensation, commission rate, or pay details to any person who is not authorized to receive Personnel Information for payroll or management purposes.
5.2 A Manager and an Employee who handles payroll shall disclose Personnel Information only to the Employee the information concerns, to a person whose duties require it, and as applicable law requires. Write-ups, disciplinary records, and manager notes are Personnel Information and are kept on the manager side of the employment record; the Employee shall not seek access to such records of another Employee except through a duty that requires it.
5.3 Nothing in this article limits an Employee's discussion of the Employee's own wages, hours, or working conditions where applicable law protects that discussion. The duty in this article attaches to information held in Company records and Systems and to the information of other persons.
Article 6: Exceptions and Compelled Disclosure
6.1 The duty in this document does not prohibit a disclosure that (a) applicable law requires; (b) the Whistleblower and Internal Reporting Policy protects; (c) a government agency requires in a proceeding in which the Employee participates as the law permits; or (d) the Privacy Policy provides for in the handling of personal information.
6.2 Where an Employee receives a subpoena, a court order, or another legal demand for Confidential Information, the Employee shall not disclose the information in response to the demand and shall deliver the demand to legal@aapawz.com immediately, so that the Company may respond through its legal process. The Employee shall disclose the demand itself only as this clause directs.
6.3 An Employee who discloses Confidential Information by accident, or who discovers that Confidential Information has been disclosed or exposed, shall report the event immediately in accordance with the Incident Response Policy. A prompt report of an accidental disclosure is a mitigating fact in any enforcement under this document; concealment of a disclosure is an independent violation.
Article 7: End of Employment
7.1 On the end of employment, for any reason, the Employee shall return or, as the Company directs in writing, delete every record and copy of Confidential Information in the Employee's possession, in accordance with the Termination and Offboarding Policy. The Employee shall not retain Confidential Information after the employment ends.
7.2 The duties in this document survive the end of employment without limit of time for trade secrets and for so long as the information remains confidential for every other category of Confidential Information.
Article 8: Liability
8.1 The Employee is responsible for the Employee's own conduct and shall bear the loss that the Employee's violation of this document causes, to the extent permitted by applicable law. Nothing in this document makes the Company responsible for a loss caused by an act taken in violation of this document or outside the scope of employment.
8.2 To the fullest extent permitted by law, neither party is liable to the other for indirect, incidental, special, punitive, or consequential damages, or for lost profits, lost revenue, or loss of goodwill, arising out of or relating to this document, even if the party has been advised of the possibility of those damages.
8.3 To the fullest extent permitted by law, the Company's total liability arising out of or relating to this document shall not exceed one hundred dollars ($100). This clause does not limit (a) wages, commissions, benefits, or other compensation owed under applicable law or a written agreement; (b) indemnification obligations under this document; (c) liability for fraud or willful misconduct; or (d) liability that cannot be limited under applicable law.
8.4 The parties agree that this article allocates risk between them, that it is an essential part of the basis of their bargain, and that it applies even if a limited remedy fails of its essential purpose.
Article 9: Indemnification
9.1 The Company shall indemnify, defend, and hold harmless the Employee from and against a claim, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) brought by a third party and arising out of an act the Employee took within the scope of employment and in compliance with this document and applicable law.
9.2 The Company does not indemnify an Employee for the Employee's own unlawful acts. No indemnification is owed under this article for a claim arising out of (a) the Employee's willful misconduct or fraud; (b) an act outside the scope of employment; or (c) an act taken in violation of this document, including a disclosure this document prohibits.
9.3 The Employee shall indemnify, defend, and hold harmless the Company and its members, managers, employees, and agents from and against every claim, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) arising out of (a) the Employee's breach of this document; (b) the Employee's violation of any law or of the rights of any person; and (c) an act outside the scope of employment.
9.4 The party seeking indemnification shall give prompt written notice of a claim under this article. The indemnifying party shall control the defense with counsel reasonably acceptable to the other party; the indemnified party may participate at its own expense. The indemnifying party shall not settle a claim in a manner that imposes an obligation on the other party, or that does not release the other party fully, without the other party's prior written consent. This article survives the end of employment.
Article 10: Enforcement and Appeals
10.1 The Company may investigate any suspected violation of this document. The Employee shall cooperate with an investigation and shall produce the records this document requires the Employee to keep.
10.2 If the Company determines that the Employee has violated this document, the Company shall give written notice stating the provision violated and the facts relied on, except where notice would compromise an investigation of fraud, a safety risk, or a legal obligation. The Employee may submit a written response within ten (10) business days, and the person deciding the matter shall consider the response before a measure is imposed. Where a violation is capable of cure, the Employee has ten (10) business days from notice to cure it and to confirm the cure in writing; no cure period applies to fraud, a safety risk, unlawful conduct, or a violation that cannot be cured.
10.3 If a violation is established, the Company may, proportionate to the violation: (a) issue a written warning; (b) require retraining; (c) restrict or withdraw access or a module grant; (d) place the Employee on a written improvement plan; (e) suspend the Employee's employment; (f) terminate the Employee's employment; and (g) exercise any other right or remedy available at law. A disclosure of Confidential Information made deliberately, or for personal benefit, is a serious violation for the purposes of this article.
10.4 The Employee may appeal a measure under this article by written notice to the Employee's Manager within thirty (30) days of the measure, stating the grounds and attaching the records relied on. Where the measure arises out of a legal demand or a disclosure to a government agency, the appeal is made in writing to legal@aapawz.com. Where the Manager made the decision appealed from, the appeal is made to the Manager's manager. The appeal is decided by a person who did not make the original decision, and the Company's decision on appeal is final. A measure remains in effect during an appeal unless the Company directs otherwise in writing.
10.5 No measure under this article may be imposed in retaliation for a report made in good faith under the Whistleblower and Internal Reporting Policy or for the exercise of a right protected by applicable law. The Company's delay in acting on a violation is not a waiver of the violation or of any later violation of the same kind.
Article 11: Term and Termination
11.1 This document applies from the commencement of employment until the employment ends for any reason, and thereafter as clause 11.2 states.
11.2 On the end of employment, the duties of non-disclosure and non-use, the duty to return or delete Confidential Information, and Articles 8, 9, 10 (for measures taken before the employment ended), 12, and 13 survive, for the periods Article 7 states. The end of employment and of access is governed by the Termination and Offboarding Policy.
Article 12: Dispute Resolution
12.1 Any dispute arising out of or relating to this document, or to the relationship it governs, is governed by the Dispute Resolution Policy, which is incorporated into this document by reference.
12.2 Nothing in this document limits an Employee's right to file a charge or complaint with a government agency, to participate in an agency proceeding, or to engage in concerted activity protected by applicable law, and no provision of this document requires the Employee to give notice of, or to obtain consent to, the exercise of such a right. Nothing in this document prohibits a disclosure to a government agency that applicable law protects.
Article 13: General Provisions
13.1 The Company may amend this document by posting the amended document in the Document Center and giving notice to the Employee at the email address in the Employee's employment record. An amendment that materially increases the Employee's obligations takes effect thirty (30) days after notice; other amendments take effect on posting.
13.2 Legal notices under this document shall be sent to legal@aapawz.com; operational notices and all other communications shall be sent to support@aapawz.com. A notice to the Company is effective when the Company acknowledges receipt or, for email, one business day after sending, whichever is earlier. Notices to the Employee are effective when sent to the email address in the Employee's employment record or posted in the employee portal, whichever occurs first. The Employee shall keep that email address current. Notices under the DMCA and Copyright Policy are given as provided in that policy, to the designated agent at legal@aapawz.com.
13.3 This document is governed by the laws of the State of Tennessee, without regard to its conflict-of-laws rules. Subject to the Dispute Resolution Policy, any proceeding arising out of this document shall be brought in the state or federal courts located in Shelby County, Tennessee, and the parties consent to personal jurisdiction there.
13.4 If any provision of this document is held unenforceable, the provision shall be enforced to the fullest extent permitted, and the remaining provisions continue in full effect.
13.5 This document, together with the documents it incorporates by reference, is the entire agreement between the Company and the Employee for the subject it governs and supersedes every prior statement or agreement on that subject. This clause does not supersede an offer letter or a written employment agreement signed by the Company.
13.6 The Employee shall not assign this document or any right or obligation under it, and an assignment without the Company's prior written consent is void. The Company may assign this document to an affiliate or in connection with a sale of all or part of its business, on notice to the Employee. A waiver of any provision of this document is effective only in writing and only for the instance stated; no waiver is a waiver of any other provision or instance.
13.7 Headings are for convenience only. "Including" means "including without limitation." This document shall not be construed against a party on the ground that the party prepared this document. The English-language text controls over any translation.
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