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Data Access and Least Privilege Policy

Effective Date: October 15, 2026 Version: 1.0 Applies to: All Company employees.

Article 1: Introduction and Scope

1.1 This document states the principle on which access to Company Systems and Company data is granted: an Employee receives the least access the Employee's duties require, and no more. This document states how access is requested, granted, reviewed, changed, and ended, and what an Employee shall and shall not do with access the Employee holds.

1.2 This document governs access to every Company System, including the module grants described in Article 3, and the data held in those Systems, for every Employee. The same principle applies to the access a franchised business grants its own staff, as the Franchise Agreement Policy provides for that relationship.

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 Access Level: the level of a Grant: Read, Write, or Full access, as Article 3 states.

2.3 Grant: a permission record, assigned to an individual Employee for a stated Module at a stated Access Level, that permits the Employee to use that Module.

2.4 Module: one of the business areas of the Platform administered through the admin portal: Customers, Appointments, Payments, Invoices, Deposits, Refunds and Disputes, Gift Cards and Credits, Inventory, Products and Services, Purchasing, Communications, and Reports.

Article 3: Least Privilege and the Grant Model

3.1 Access is granted on a least-privilege basis. An Employee is granted a Module only where the Employee's current duties require it, and at the lowest Access Level that permits those duties: Read permits the Employee to view the Module and its records; Write permits the Employee to view and to change records in the Module; Full access permits the Employee to view, change, and administer the Module, including actions that move money, export records, or alter the records of other persons.

3.2 The grant model is additive. An Employee holds the Modules listed in the Employee's grants, at the Access Levels stated, and holds no other access. A Module that is not granted is absent from the Employee's access; there is no general or default access to a Module, and no access arises from seniority, from a prior role, or from access held by a coworker in the same role.

3.3 An Employee's own station work: the Employee's appointments, shifts, time clock, and employment record: is available to the Employee by virtue of employment and is not a Grant. Station work shows the Employee the Employee's own assignments and records only; access to the records of customers, of other Employees, and of the business beyond those assignments requires a Grant.

3.4 A Grant is personal to the Employee to whom it is assigned. A Grant is checked against the Employee's identity on each use of the Module, in accordance with the Authentication Controls Policy. A Grant does not transfer to another person and does not survive the end of employment.

Article 4: Requesting, Granting, and Changing Access

4.1 An Employee who needs access the Employee does not hold shall request the access from the Employee's Manager, in writing, stating the Module, the Access Level requested, and the duty that requires it. A request for access to every Module, or for a level higher than the duty requires, does not satisfy this clause.

4.2 A Grant is made, changed, and withdrawn only by a person the Company has authorized to grant access, and only on a stated justification recorded with the Grant. Granting access is itself a controlled act: a Manager who cannot grant the access requested shall refer the request to the person who holds that authority and shall not direct the Employee to work through another person's access in the meantime.

4.3 Temporary access, granted for a stated task such as covering a shift or completing a project, shall state the task and shall be withdrawn when the task ends. The person who grants temporary access is responsible for its withdrawal.

4.4 Where an Employee's role changes, the Employee's Manager shall review the Employee's Grants against the new duties on the day the change takes effect, shall withdraw every Grant the new duties do not require, and shall grant only the access the new duties require. An Employee who holds a Grant the Employee's current duties do not require shall report the excess access to the Manager promptly; holding excess access without reporting it violates this document, because an unexplained loss in a Module falls first on the persons who hold access to it.

4.5 The Company shall review Grants periodically and shall withdraw a Grant that no current duty supports. A Manager shall certify, on each review the Company conducts, that the Grants of the Manager's reports match their current duties.

Article 5: Duties of an Employee Who Holds Access

5.1 The Employee shall access a Module and the data in it only for the duties the Grant supports, and only to the extent the task requires. The Employee shall not access a Module, a record, or a report out of curiosity, for a personal purpose, or for a person who lacks a Grant.

5.2 The Employee shall not use the Employee's access to obtain access for another person: the Employee shall not act on another person's behalf under the Employee's own Grant, shall not permit another person to act under the Employee's session, and shall not seek to defeat a permission check by any means, including the use of another person's credentials, which the Authentication Controls Policy prohibits.

5.3 The Employee shall not export, copy, or remove data from a Module except as the task requires, the Access Level permits, and the Confidentiality and Non-Disclosure Policy allows. An export of customer, payment, or personnel records is made only through a function the Module provides for that purpose and is recorded in the audit log under the Record Keeping and Audit Policy.

5.4 Every act taken under a Grant is recorded against the Employee's identity in the audit log. The Employee is accountable for every act recorded under the Employee's Grants and session, in accordance with the Employee Code of Conduct.

Article 6: End of Access

6.1 Access ends when the employment ends, on the terms the Termination and Offboarding Policy states, and access to a Module ends when the Grant is withdrawn, whichever occurs first. No Grant, session, or credential survives separation.

6.2 The Company may suspend or withdraw a Grant at any time, with or without notice, where the Company determines that the access is no longer required, that this document has been violated, or that a risk to data or to the business requires it. Withdrawal of a Grant is an administrative act and is not, without more, a disciplinary measure.

Article 7: Liability

7.1 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.

7.2 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.

7.3 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.

7.4 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 8: Indemnification

8.1 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.

8.2 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 access to a Module or a record that no Grant permitted.

8.3 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.

8.4 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 9: Enforcement and Appeals

9.1 The Company may investigate any suspected violation of this document, including by review of the audit log. The Employee shall cooperate with an investigation and shall produce the records this document requires the Employee to keep.

9.2 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.

9.3 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 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. Access obtained or used beyond a Grant, and access used for a personal purpose, are serious violations for the purposes of this article.

9.4 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 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. An Employee who disputes a Grant decision, as distinct from a disciplinary measure, raises the dispute with the Manager in writing, stating the duty that requires the access.

9.5 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 10: Term and Termination

10.1 This document applies from the commencement of employment until the employment ends for any reason. A Grant held at the end of employment terminates with the employment, without further act.

10.2 On the end of employment, Articles 7, 8, 9 (for measures taken before the employment ended), 11, and 12 survive. The end of employment and of access is governed by the Termination and Offboarding Policy.

Article 11: Dispute Resolution

11.1 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.

11.2 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.

Article 12: General Provisions

12.1 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.

12.2 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.

12.3 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.

12.4 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.

12.5 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.

12.6 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.

12.7 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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