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Telemedicine Data Handling Policy

Effective Date: October 15, 2026 Version: 1.0 Applies to: All Veterinarians who provide services through the Platform, and to the Company's handling of telemedicine data.

Article 1: Introduction and Scope

1.1 This Policy governs telemedicine data on the Platform: the categories of clinical data the service creates, who may access each category, the Company's position as custodian and not owner of the medical record, the security standard that applies, breach notice, and retention.

1.2 Telemedicine on the Platform is meeting-room-only. The Platform provides the consultation room, the booking flow, and the payment path. The Platform does not build a medical-record repository, a pet health database, or a clinical data asset. The boundary is deliberate: every category of data the Platform holds is a category the Platform must protect, produce, retain correctly, and delete. If a provision of this Policy conflicts with the Terms of Use, this Policy controls for the subject it governs. If a provision of this Policy conflicts with the terms of a program in which a party participates, the program terms control for that program.

1.3 The Privacy Policy governs personal data generally. This Policy governs telemedicine data specifically, and no provision of the Privacy Policy expands the telemedicine collection this Policy states. The practice of veterinary medicine is governed by the law of the state in which the patient is located.

Article 2: Definitions

2.1 Account: the account a person or business establishes with the Company to use the Platform.

2.2 Client: a pet owner or caretaker who uses the Platform's veterinary services.

2.3 Clinical Data: the data within Article 3 created by or for a consultation, a triage session, or a prescription through the Platform.

2.4 Company: All About Pawz, LLC, a Tennessee limited liability company.

2.5 Medical Record: the clinical documentation of a consultation, including the clinical note, created and maintained under the Clinical Documentation Policy.

2.6 Patient: the animal that is the subject of a consultation, a triage session, or a prescription.

2.7 Pharmacy of Record: the licensed pharmacy partner that dispenses a prescription for the Patient, under the Pharmacy Partner Standards.

2.8 Platform: the websites, applications, and services the Company operates under the name All About Pawz, including aapawz.com.

2.9 Veterinarian: a veterinarian licensed in the state in which the patient is located, whom the Company has accepted to provide veterinary services through the Platform.

Article 3: Categories of Clinical Data; the Collection Boundary

3.1 The Platform collects and holds, for telemedicine, the following categories only: (a) contact and routing data: the Client's name, email address, telephone number, and postal code; the Patient's name, species, and breed; the urgency classification; a summary of the described signs; and the consent records; and (b) session-scoped clinical documentation under Article 4. Booking and intake collect the categories in clause (a); the intake shape is stated in the Consult Booking and Scheduling.

3.2 Booking and intake flows shall not request, and the Platform shall not hold as Platform-owned data, a Patient's medical history, prior veterinary records, laboratory results, or imaging. A feature that passes a Client-supplied record to the treating Veterinarian for the session only, without holding the record, requires an amendment to this Policy before the feature operates; the feature is not an interpretation of this Policy.

3.3 The signs text in a triage session and in a referral record is routing information, retained for quality review and escalation under the Teletriage Standards Policy and the Triage Escalation Policy. Routing information shall not be presented, sold, or used as a pet health history, and shall not be used for marketing or product recommendations.

Article 4: The Medical Record; Custodian, Not Owner

4.1 The clinical note exists to satisfy the Veterinarian's own professional record-keeping duty and the Platform's payout-verification need under the Vet Fees and Payouts Policy. The note is the Veterinarian's record. The Company holds the note as custodian for the Veterinarian and the Client; the Company does not own the Medical Record, and custodianship confers no right to use the record for any purpose outside this Policy.

4.2 The Medical Record shall not be used for marketing, for product recommendations, for any secondary purpose, or as material for an automated tool. The Medical Record is not available to a Veterinarian other than the treating Veterinarian and a designated clinical reviewer acting under Article 5, and is not available to analytics functions.

4.3 Access to the Medical Record is limited to: (a) the treating Veterinarian; (b) a designated clinical reviewer, for quality review and incident investigation; (c) the Pharmacy of Record, for the prescription information the dispensing requires; and (d) the Client, for the Client's portions of the record, including the assessment and the plan. Access controls enforce this Article at the data level: a Client accesses the Client's own sessions; a Veterinarian accesses the Veterinarian's assigned sessions; Company operations access is limited to the access the operations function requires. No application function may be more permissive than this Article.

4.4 Incident records that contain clinical information receive the highest access class in the telemedicine data, as the Clinical Incident Reporting Policy provides.

Article 5: Security

5.1 Telemedicine data is protected to the standard stated in the Information Security Policy, which governs the Company's security controls, access management, and monitoring for all Platform data. This Policy adds the telemedicine-specific access limits in Articles 4.3 and 4.4; in any conflict between a general access practice and those Articles, those Articles control for telemedicine data.

5.2 Misuse of telemedicine data by a member of the Company's workforce: access to session notes without a work need, or export of triage data: is a conduct matter of the same severity as a clinical violation, and is handled under the applicable conduct document for the person concerned.

Article 6: Breach Notice

6.1 A breach or misuse of telemedicine data follows the Company's incident process under the Information Security Policy. A breach that involves session content is in addition reported as a clinical incident under the Clinical Incident Reporting Policy, because exposed clinical content is both a data breach and a patient-privacy event, and the event receives both investigations.

6.2 The Company shall give notice of a breach of telemedicine data to each affected Client and to each affected Veterinarian, and to each regulator, within the period and in the form the applicable law requires. Where no period is prescribed, notice is given without unreasonable delay after the scope of the breach is established. The notice states the categories of data involved, the date or period of the breach as known, and the steps the Company has taken.

Article 7: Retention and Deletion

7.1 Contact and routing data is retained for the life of the Client relationship plus the legal retention period, and is then deleted.

7.2 The Medical Record follows the Veterinarian's record-retention obligations under the law of the state in which the patient is located: typically three (3) to seven (7) years, depending on the state: because the note is the Veterinarian's professional record first. The general retention schedule is stated in the Regulatory Record Retention Policy, and the period in that schedule applies where state law does not prescribe a period for the record.

7.3 Triage sessions are retained for quality review under the Teletriage Standards Policy, and are then anonymized or deleted. Anonymized triage data, with identifiers removed, may inform growth of the reference content under the Clinical Reference Content Policy; identified triage data shall not be repurposed.

7.4 Deletion at the end of a retention period is actual deletion, not a status flag. The Company keeps no archive of medical encounters beyond the periods this Article states, except records under a litigation hold under the Clinical Incident Reporting Policy.

Article 8: Liability

8.1 Data risk. The Company, as custodian, bears responsibility for the security of telemedicine data in the Company's custody and for access given in breach of this Policy. The Veterinarian bears responsibility for the accuracy and completeness of the Medical Record the Veterinarian creates. Nothing in this Article limits liability for personal injury or injury to an animal caused by negligence, where applicable law does not permit the limitation.

8.2 Exclusion of certain damages. 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 Policy, even if the party has been advised of the possibility of those damages.

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

8.4 Carve-outs. This Article does not limit (a) a party's indemnification obligations under this Policy; (b) liability for fraud or willful misconduct; (c) amounts owed for Orders, fees, chargebacks, or refunds under the Company's documents; or (d) liability that cannot be limited under applicable law.

8.5 Essential purpose. 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 Duty. The Veterinarian 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 Veterinarian's breach of this Policy; (b) the Veterinarian's services or content; (c) the Veterinarian's violation of any law or of the rights of any person; and (d) taxes for which the Veterinarian is responsible under the Company's documents.

9.2 Procedure. The Company shall give prompt written notice of a claim under this Article. The Veterinarian shall control the defense with counsel reasonably acceptable to the Company. The Company may participate in the defense at its own expense. The Veterinarian 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.

9.3 Survival. This Article survives the termination of this Policy.

Article 10: Enforcement and Appeals

10.1 Investigation. The Company may investigate any suspected violation of this Policy. The Veterinarian shall cooperate with an investigation and shall produce the records this Policy requires the Veterinarian to keep.

10.2 Notice. If the Company determines that the Veterinarian has violated this Policy, 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.

10.3 Opportunity to cure. Where a violation is capable of cure, the Veterinarian has ten (10) business days from notice to cure it and to confirm the cure in writing. No cure period applies to fraud, a risk to the safety of a person or an animal, unlawful conduct, or a violation that by its nature cannot be cured.

10.4 Measures. 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; (b) remove or suppress content; (c) suspend the Account or program participation, in whole or in part; (d) terminate this Policy and the Account; and (e) exercise any other right or remedy available under the Company's documents or at law. The Company may suspend a Veterinarian's participation immediately where a license has lapsed or a safety risk arises.

10.5 Appeal. The Veterinarian 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.

10.6 No waiver by delay. 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 Term. This Policy takes effect when the Veterinarian is accepted into the veterinary program and continues until terminated under this Article.

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

11.3 Termination by the Veterinarian. The Veterinarian may terminate this Policy on thirty (30) days' written notice to support@aapawz.com, provided the Veterinarian has no consultation or investigation outstanding.

11.4 Effect of termination. On termination: (a) the rights granted under this Policy end; (b) obligations that arose before termination: including record-keeping, retention, and indemnification obligations: survive until satisfied; and (c) the Company shall disburse amounts owed, less amounts the Company may set off under the Company's documents, within thirty (30) days, except amounts held in connection with an open investigation or dispute. Termination does not shorten a retention period in Article 7, and the Company's custodianship of the Medical Record continues until the record is transferred to the Veterinarian or the retention period ends, whichever occurs first.

11.5 Survival. The Definitions, Liability, Indemnification, Enforcement and Appeals (for measures taken before termination), Dispute Resolution, and General Provisions Articles survive termination.

Article 12: Dispute Resolution

12.1 Any dispute arising out of or relating to this Policy, or to the relationship it governs, is governed by the Dispute Resolution Policy, which is incorporated into this Policy by reference.

Article 13: General Provisions

13.1 Amendments. The Company may amend this Policy by posting the amended Policy in the Document Center and giving notice to the Veterinarian at the email address in the Account. An amendment that materially increases the Veterinarian's 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. A Veterinarian who does not accept an amendment may terminate under Article 11 before the amendment takes effect.

13.2 Notices. Legal notices under this Policy 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 Veterinarian 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 Veterinarian shall keep the email address in the Account current.

13.3 Governing law. This Policy 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 Policy shall be brought in the state or federal courts located in Shelby County, Tennessee, and the parties consent to personal jurisdiction there. The practice of veterinary medicine under this Policy is governed by the law of the state in which the patient is located.

13.4 Severability. If any provision of this Policy is held unenforceable, the provision shall be enforced to the fullest extent permitted, and the remaining provisions continue in full effect.

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

13.6 Assignment. The Veterinarian shall not assign this Policy 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 Policy to an affiliate or in connection with a sale of all or part of its business, on notice to the Veterinarian.

13.7 Waiver. A waiver of any provision of this Policy is effective only in writing and only for the instance stated. No waiver is a waiver of any other provision or instance.

13.8 Interpretation. Headings are for convenience only. "Including" means "including without limitation." This Policy shall not be construed against a party as its drafter. The English-language text controls over any translation.

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