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INFORM Act Compliance Policy

Effective Date: October 15, 2026 Version: 1.0 Applies to: All Sellers who offer products or services through the Platform.

Article 1: Introduction and Scope

1.1 This document states the Seller's duties under the Integrity, Notification, and Fairness in Online Retail Marketplaces for Consumers Act, 15 U.S.C. § 45f (the INFORM Act): information collection, verification, annual certification, disclosure, change notification, and cooperation with suspicious activity reporting. The statutory duties of the Company as an online marketplace are stated in the INFORM Act Seller Verification Policy and the related disclosure statement in Regulatory; this document states the Seller's obligations that support compliance with that law.

1.2 The INFORM Act controls over this document where the two conflict. This document states compliance duties; this document is not legal advice.

1.3 If a provision of this document conflicts with the Terms of Use, this document controls for the subject it governs, subject to Clause 1.2.

Article 2: Definitions

2.1 The definitions in the Terms of Use and the Selling Terms of Service are incorporated into this document. The following additional definitions apply (a) High-Volume Seller: a Seller with 200 or more discrete sales or transactions in any continuous 12-month period resulting in $5,000 or more in gross revenues. Both conditions shall be met.

(b) Disclosure Threshold: $20,000 or more in annual gross revenues, at or above which the disclosure duties in Article 5 apply.

(c) Verification Information: the information listed in Clause 3.1.

Article 3: Information Collection and Verification

3.1 Every Seller shall provide the following at onboarding, so that the Company can monitor the thresholds in Article 2 without a further collection after a threshold is crossed: (a) full legal name, confirmed against registration documents; (b) a government-issued photo identification for an individual, or business registration documents for an entity; (c) tax identity, with the legal name as on the tax return, matching Internal Revenue Service records; (d) bank account information, with holder name, routing number, and account number, verified before disbursement; (e) a working email address and telephone number, confirmed deliverable; and (f) business address: street, city, state, and ZIP code: verified against postal records and proof of address.

3.2 Verification of Verification Information is governed by the Business Verification Policy, which states the evidence standard and the verification decisions. Completion of onboarding satisfies the collection duty in Clause 3.1; verification is complete only when each item in Clause 3.1 is verified under that policy.

3.3 Where Verification Information cannot be verified, the Seller shall not sell until verification is complete.

3.4 Annual certification. The Company shall notify a High-Volume Seller annually to keep Verification Information current and shall require electronic certification that the information is current. The Seller shall certify within 30 days after notice, after first updating any item that has changed. Failure to certify within that period suspends the Seller's listings until certification is complete. Suspension under this Clause is a compliance freeze, lifts on certification, and is not by itself a conduct finding.

3.5 On crossing into High-Volume Seller status, the Company shall re-check Verification Information for currency. The crossing is a re-verification event. If an item is stale, the Seller shall cure within the certification period in Clause 3.4; selling continues during cure unless the staleness indicates fraud, in which case Article 8 applies as serious conduct.

Article 4: Sellers Below the Threshold

4.1 A Seller below the High-Volume Seller threshold is verified once at onboarding under the Business Verification Policy. No scheduled re-verification applies to such a Seller under the INFORM Act alone; the change notification duty in Article 6 and the re-verification events in the Business Verification Policy continue to apply.

4.2 Verification duties that attach on crossing the threshold do not cease on a decline in volume within the same continuous 12-month period.

Article 5: Disclosure to Buyers

5.1 For a Seller at or above the Disclosure Threshold, the Company shall disclose to Buyers: the Seller's full legal name and business address; whether the Seller uses a different name or address for manufacturing, shipping, or returns; contact information, consisting of a working email address and telephone number; and the Seller's identity verification status. The Seller shall provide accurate information for each disclosure item and shall keep each item current under Article 6.

5.2 Disclosure appears on the Seller's storefront page and at the point of sale, in accordance with the Storefront and Identity Display Policy.

5.3 Partial disclosure: a legal name without a full street address: is permitted only where the INFORM Act permits that form: where the Seller has no physical address in the United States and provides an alternative contact method meeting the statutory conditions, or where the Seller answers the questions prescribed by the Act in the manner that permits partial disclosure. Preference alone is not a ground for partial disclosure. The Company applies the statutory test; the Seller shall not self-certify into partial disclosure.

5.4 Where a Seller falls below the Disclosure Threshold, the Company applies a period of one full quarter before removing disclosure, so that a Buyer who purchased during the disclosed period continues to see consistent seller information on order history.

Article 6: Change Notification

6.1 The Seller shall notify the Company of a change to any item in Clause 3.1 within 10 business days after the change, in accordance with the Business Verification Policy. For a High-Volume Seller, that duty is a duty under the INFORM Act as well as under this document.

6.2 A material change: a new legal entity, a new tax identity, or a new disbursement account in a different name: requires re-verification before the change takes effect for disbursement or disclosure. The Seller shall update the record, the Company shall verify the update, and only after verification shall storefront disclosure show the new information. Unverified new information shall not be displayed as verified business information.

Article 7: Suspicious Activity Reporting

7.1 The Company maintains a mechanism for a Buyer to report suspicious marketplace activity, including counterfeit goods, stolen goods, fraud, and evasion of verification. The mechanism appears on the storefront page and on the order detail page.

7.2 A report is directed to the trust and safety function and is not directed to the Seller reported. A substantiated report may result in a finding under the Seller Enforcement Policy. An unsubstantiated report is closed without action against the Seller and without notice to the Seller of the report.

7.3 A Seller that contends a report was filed in bad faith, including serial reports by a competitor to suppress listings, may appeal an enforcement measure resulting from such a report under the Appeals Policy. Bad-faith reporting is itself a ground for enforcement against the reporting party where that party is a Seller.

Article 8: Liability

8.1 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 document, even if the party has been advised of the possibility of those damages.

8.2 Cap. 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).

8.3 Carve-outs. 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.

8.4 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 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, including product liability claims; (c) infringement or alleged infringement of intellectual property or other rights by the Seller's Products, listings, or User Content; (d) a product recall of the Seller's Products, including recall costs; (e) the Seller's violation of any law or of the rights of any person; and (f) taxes for which the Seller is responsible under this document.

9.2 Procedure. 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.

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

Article 10: Enforcement and Appeals

10.1 Investigation. 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.

10.2 Notice. 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.

10.3 Opportunity to cure. 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.

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 a listing or content; (c) cancel an Order or a booking; (d) suspend the Account or a program participation, in whole or in part; (e) terminate the Selling Terms of Service and the Account; and (f) exercise any other right or remedy available under this document or at law. 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.

10.5 Appeal. 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.

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 document takes effect when the Seller is accepted to sell through the Platform and continues until terminated under this Article.

11.2 Termination by the Company. 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.

11.3 Termination by the Seller. 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.

11.4 Effect of termination. 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; and (c) the Company shall disburse amounts owed, less amounts the Company may set off under the Selling Terms of Service, within thirty (30) days, except amounts held in connection with an open investigation or dispute.

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 document, or to the relationship it governs, is governed by the Dispute Resolution Policy, which is incorporated into this document by reference.

Article 13: General Provisions

13.1 Amendments. 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 Article 11 before the amendment takes effect.

13.2 Notices. 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. DMCA notices are given as provided in the DMCA and Copyright Policy, to the designated agent at legal@aapawz.com.

13.3 Governing law. 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 Severability. 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 Entire agreement. 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.

13.6 Assignment. 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.

13.7 Waiver. 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.

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

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