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Data Protection Policy for Sellers

Effective Date: October 15, 2026 Version: 1.0 Applies to: All Sellers, and the personnel of a Seller, who receive Buyer personal information through the Platform.

Article 1: Introduction and Scope

1.1 This document states the duties of a Seller as a handler of Buyer personal information: the limitation on use of that information, the security duties that protect that information, the duty to give notice of a breach, and the duty to delete that information when the Seller relationship ends. This document is the Seller-facing statement of data protection for Seller handling. The data processing terms that the Seller accepts in the Seller Policy Center state the processing relationship between the Company and the Seller, and this document references those terms; the Privacy Policy governs personal information as the Company's statement to the individuals concerned.

1.2 If a provision of this document conflicts with the Terms of Use, this document controls for the subject it governs. If a provision of this document conflicts with the terms of a program in which the Seller participates, the program terms control for that program. Applicable privacy law controls over this document where the law gives greater protection. Policies and help pages explain this document; they do not amend it, and in any conflict this document prevails.

Article 2: Definitions

2.1 The definitions in the Selling Terms of Service are incorporated into this document by reference and apply to this document. This article defines only the additional terms used in this document, in alphabetical order.

2.2 Breach: suspected or confirmed unauthorized access to, acquisition of, or loss of Buyer Personal Information, including access through a lost device holding an Order export, a compromised service login, an exposed storage service of a provider to the Seller, and malicious software on a system holding Buyer Personal Information. Suspicion is sufficient to trigger the duties in Article 7.

2.3 Buyer Personal Information: information the Platform makes available to the Seller that relates to an identifiable Buyer, including name, shipping and billing addresses, telephone number, email address, Order contents, delivery instructions, and communications. Order data is Buyer Personal Information.

2.4 Service-Seller Information: the additional personal information a Seller of Services receives, including a home address, access instructions such as a gate code, a garage code, and a key location, pet details, and appointment contact information.

2.5 Sub-Processor: a third party the Seller uses that accesses Buyer Personal Information in the course of fulfillment or customer service, including shipping software, a helpdesk tool, an automated messaging agent, a label service, and an analytics service that receives an Order export.

Article 3: Purpose Limitation and Minimization

3.1 The Seller receives Buyer Personal Information solely to fulfill the Order and to provide the customer service contracted for that Order: to select, pack, ship, and deliver the Product, to answer the Buyer's questions about that Order, and to handle a return of that Order. That purpose is the boundary of permitted use. A prior purchase by a Buyer is not by itself a basis for another use.

3.2 The Seller shall not request personal information beyond the information the Order requires. Information required for a carrier label is required; information sought for a marketing program of the Seller is not required and shall not be solicited through Order communications.

3.3 Payment card information is never visible to the Seller and shall never be solicited by the Seller. Where a Buyer sends payment card details in a Message, the Seller shall direct the Buyer to the proper payment facility and shall delete the Message content containing the details from the Seller's own records.

3.4 The Seller shall not: (a) use Buyer Personal Information for marketing to a Buyer outside the Platform's own messaging; (b) sell or rent Buyer Personal Information; (c) enrich a Buyer profile with third-party data; (d) provide Buyer Personal Information as training data for a model or automated system of the Seller; or (e) retain Buyer Personal Information beyond the fulfillment need and a legal retention duty stated in Article 8. Use of Buyer Personal Information for solicitation outside the Platform is also a diversion violation under the Storefront and Identity Display Policy.

3.5 The Seller shall collect and retain the minimum information the purpose in clause 3.1 requires.

Article 4: Security Duties

4.1 The Seller shall maintain security for Buyer Personal Information that includes at least: (a) access limited to personnel who require the information for fulfillment or customer service; (b) no Buyer Personal Information in an unsecured spreadsheet, a personal email account, a messaging application, or a shared drive without access controls; (c) encrypted transmission where Buyer Personal Information moves between the Seller's systems and a Sub-Processor, and no transmission by unencrypted email or an unsecured file transfer method; and (d) prompt deletion when the retention need ends, under Article 8.

4.2 Access for personnel of the Seller with Seller Center access follows the principle of least privilege: customer service personnel receive access to Orders and not to disbursement records, and warehouse personnel receive access to packing information and not to Buyer email addresses. Until a permission facility that expresses that separation is available for an Account, the Seller shall achieve the separation through a separate login for each person and shall not share credentials.

4.3 Shared credentials are prohibited. Each person acting for the Seller shall use an individual login. When a person ceases to act for the Seller, the Seller shall revoke that person's access on the same day. The audit record for the Account records the identity of the actor; a shared login defeats that record, and the Seller bears the consequence of an attribution failure caused by a shared login.

Article 5: Sub-Processors and Seller Tooling

5.1 Software and a service that the Seller uses in fulfillment or customer service shall protect Buyer Personal Information to the same standard the Seller bears under this document. The Seller is responsible for a Sub-Processor under this document; a breach by a Sub-Processor is treated as a breach by the Seller for purposes of this document.

5.2 Before connecting a tool that accesses Buyer Personal Information, the Seller shall determine the data the tool receives, the place of storage, the retention period, and whether the tool trains a model on customer data. A tool whose terms permit training on the Seller's customer data shall not be connected to Buyer Personal Information. Duties for an automated agent are also stated in the Seller Automation Disclosure Policy.

5.3 The Seller shall keep a current list of Sub-Processors and shall produce the list within five (5) business days after the Company requests the list in connection with an investigation or a Buyer privacy request.

Article 6: Heightened Duties for a Seller of Services

6.1 A Seller that offers Services, including grooming, sitting, boarding, walking, training, and in-home installation, receives Service-Seller Information. The purpose limitation and minimization duties in Article 3 apply with heightened care to that information, because access information opens a residence.

6.2 In-home access information, including a gate code, a garage code, a key location, and alarm details, shall not be retained after the service need ends and shall not be shared beyond the personnel performing that specific Service. On completion of the appointment, the Seller shall delete the access information and shall not retain the information for a possible future booking or in a personal note of a member of personnel.

6.3 The Seller shall collect pet details only as the Service requires, shall use pet details only for that Service, and shall not build a retained pet health record beyond the need of the Service.

6.4 Personnel who perform a Service at a customer's residence are subject to the background-check duties in the Selling Services Addendum, which apply in significant part because of the information described in this article.

Article 7: Breach Notice and Cooperation

7.1 The Seller shall report a Breach involving Buyer Personal Information to the Company without undue delay, by notice to support@aapawz.com, and in any event within twenty-four (24) hours after discovery of the Breach. Where the report is a legal notice under this document, including a notice that the Company requires for a legally required notification, the Seller shall also send the notice to legal@aapawz.com. The report shall state the nature of the incident, the data involved, the number of Buyers affected as a best estimate at the time of the report, the containment measures taken, and a contact who can answer follow-up questions.

7.2 The Seller shall cooperate with investigation and notification as applicable law requires, including preservation of logs, identification of affected Buyers, and support for a legally required notification. The Seller shall not notify an affected Buyer unilaterally before coordination with the Company where coordination is required to state the facts accurately.

7.3 Failure to report a known Breach within the period in clause 7.1 is a separate violation from the Breach itself, and is treated as the more serious violation.

Article 8: Retention and Deletion

8.1 The Seller shall retain Buyer Personal Information only for as long as a fulfillment need or a legal retention duty requires, including the Order period, the return period, a tax record duty, and a hold for an open dispute or investigation. When the need ends, the Seller shall delete the information.

8.2 A legal retention duty does not authorize retention of all information. A tax record requires a transaction amount and a date, and does not require a gate code, a pet note, or a Buyer Message. The Seller shall retain the record the law requires and shall delete the information the law does not require.

8.3 Deletion means removal from live systems and removal from backups on the ordinary rotation of those backups.

8.4 On the end of the Seller relationship, for any reason, the Seller shall delete Buyer Personal Information held by the Seller except information subject to a legal retention duty, a litigation hold, or an open dispute or investigation, and shall confirm the deletion to the Company on request. A conflict between a deletion duty and a hold shall be raised with the Company and shall not be resolved by silent retention or silent deletion.

8.5 Where a Buyer exercises a privacy right through the Platform, including a right of access or deletion, the Seller shall cooperate within the period the Company states, including deletion of information the Seller holds beyond a legal retention need.

8.6 The Seller shall produce Buyer Personal Information to the Company, and not directly to a brand or a rights owner, in connection with an investigation by that brand or rights owner, unless the Company directs otherwise. A franchisee Seller is separately responsible for Buyer Personal Information that franchisee receives; a franchisor does not receive Buyer Personal Information from a franchisee's Orders by reason of the franchise relationship alone.

Article 9: Liability

9.1 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.

9.2 To the fullest extent permitted by law, the Company's total liability arising out of or relating to this document shall not exceed the greater of (a) the amounts the Seller paid to the Company under this document in the twelve months before the event giving rise to the claim, or (b) one hundred dollars ($100).

9.3 This article does not limit (a) a party's indemnification obligations under this document; (b) liability for fraud or willful misconduct; (c) amounts the Seller owes for Orders, fees, chargebacks, or refunds under this document; or (d) liability that cannot be limited under applicable law.

9.4 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 10: Indemnification

10.1 The Seller shall indemnify, defend, and hold harmless the Company and its members, managers, employees, and agents from and against every claim, demand, action, loss, liability, judgment, settlement, cost, and expense (including reasonable attorneys' fees) arising out of or relating to: (a) the Seller's breach of this document; (b) the Seller's Products, Services, listings, or User Content; (c) the Seller's violation of any law or of the rights of any person; and (d) taxes for which the Seller is responsible under this document.

10.2 The Company shall give prompt written notice of a claim under this article. The Seller shall control the defense with counsel reasonably acceptable to the Company. The Company may participate in the defense at its own expense. The Seller shall not settle a claim in a manner that imposes any obligation or restriction on the Company, or that does not release the Company fully, without the Company's prior written consent.

10.3 This article survives the termination of this document.

Article 11: Enforcement and Appeals

11.1 The Company may investigate any suspected violation of this document. The Seller shall cooperate with an investigation and shall produce the records this document requires the Seller to keep.

11.2 If the Company determines that the Seller 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.

11.3 Where a violation is capable of cure, the Seller has ten (10) business days from notice to cure it and to confirm the cure in writing. No cure period applies to fraud, counterfeiting, a risk to the safety of a person or an animal, unlawful conduct, or a violation that by its nature cannot be cured. No cure period applies to willful misuse of Buyer Personal Information, including sale of Buyer Personal Information and retention of in-home access information after a warning.

11.4 If a violation is established and is not cured within the period allowed, the Company may, proportionate to the violation: (a) issue a written warning, with an improvement plan for negligent handling that is promptly corrected; (b) remove or suppress a listing or content; (c) suspend selling until the Company verifies that a mishandling practice is corrected, where mishandling continues or a Breach has affected Buyers; (d) suspend the Account or a program participation, in whole or in part, for willful misuse; (e) terminate this document and the Account; and (f) exercise any other right or remedy available under this document or at law. A data protection finding carries a repeat period of three hundred sixty-five (365) days.

11.5 The Company may hold disbursements to the Seller while an investigation under this article is pending, and shall release amounts not required to satisfy the Seller's obligations when the investigation closes.

11.6 The Seller may appeal a measure under this article by written notice to legal@aapawz.com within thirty (30) days of the measure, stating the grounds and attaching the records relied on. The appeal is decided by a person who did not make the original decision. The Company's decision on appeal is final. A measure remains in effect during an appeal unless the Company directs otherwise in writing.

11.7 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 12: Term and Termination

12.1 This document takes effect when the Seller accepts it and continues until terminated under this article.

12.2 The Company may terminate this document and the Account on thirty (30) days' written notice for any reason, and immediately on written notice if the Seller materially breaches this document, engages in fraud, or becomes ineligible to participate.

12.3 The Seller may terminate this document on thirty (30) days' written notice to support@aapawz.com, provided the Seller has no Order, booking, or investigation outstanding.

12.4 On termination: (a) the rights granted under this document end; (b) obligations that arose before termination: including payment, refund, chargeback, record-keeping, and indemnification obligations: survive until satisfied; (c) the deletion duty in Article 8 applies to Buyer Personal Information held at termination; and (d) the Company shall disburse amounts owed, less amounts the Company may set off under this document, within thirty (30) days, except amounts held in connection with an open investigation or dispute.

12.5 The Definitions, Fees (for accrued amounts), Liability, Indemnification, Enforcement and Appeals (for measures taken before termination), Dispute Resolution, and General Provisions articles survive termination.

Article 13: Dispute Resolution

13.1 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.

Article 14: General Provisions

14.1 The Company may amend this document by posting the amended document in the Document Center and giving notice to the Seller at the email address in the Account. An amendment that materially increases the Seller's fees or obligations takes effect thirty (30) days after notice; other amendments take effect on posting. Continued use of the Platform after the effective date of an amendment is acceptance of it. If the Seller does not accept an amendment, the Seller's remedy is to terminate under the Term and Termination article before the amendment takes effect.

14.2 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 Seller are effective when sent to the email address in the Account or posted to the Account's notice facility in the portal, whichever occurs first. The Seller shall keep the email address in the Account current. Notices under the DMCA and Copyright Policy are given as provided in that policy, to the designated agent at legal@aapawz.com.

14.3 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.

14.4 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.

14.5 This document, together with the documents it incorporates by reference, is the entire agreement between the Company and the Seller for the subject it governs and supersedes every prior or contemporaneous statement, communication, or agreement on that subject, whether written or oral.

14.6 The Seller shall not assign this document or any right or obligation under it without the Company's prior written consent, and an assignment without 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 Seller.

14.7 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.

14.8 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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