PURPOSE

To provide notice to Associates regarding PetSmart’s policy for the collection, use, and disclosure of Associate personal information.

SCOPE

This Policy applies to PetSmart and PetSmart Charities (“PetSmart,” “we,” “us,” or “our”). For the purposes of this Policy, “Associate” means any current PetSmart employee, former employee, or employee applicant, or current PetSmart contractor, former contractor, or contractor applicant (“you” or “your”). “Personal information” means information that identifies or could reasonably be linked to a particular Associate. This Policy applies to our collection, use, and disclosure of Associates’ personal information and does not apply to information that is not personal information under applicable laws.

Where we refer to “employment” in this Policy, we do so for convenience only, and this should in no way be interpreted as purporting to confer employment status on non- employees to whom this Policy also applies. This Policy does not form part of any contract of employment, does not confer any employment status or contractual right on any Associate, and does not place any contractual obligation on us.

This Policy does not cover our processing of personal information collected from you as a PetSmart customer or visitor of our websites or mobile app. To learn more about our privacy practices in those cases, please see the PetSmart Privacy Policy.

In some cases, you may provide personal information to third parties that we work with, such as when you voluntarily sign up for certain services or benefits programs provided by third parties to our Associates. By participating in these services or benefits programs, you understand that the information you provide to the third parties is not under our control and is not subject to this Policy. Please refer to the privacy policies of those third parties before providing them with your personal information.

POLICY

Categories of Personal Information Collected

PetSmart collects, and has collected in the preceding 12 months, personal information about our Associates to establish, manage, and conclude the employment relationship. For example, we may collect the following types of information:

• Identifiers, such as name, alias, home and other personal contact information, signature, unique personal identifier, email address, next of kin, emergency contact information, Social Security Number, Social Insurance Number, driver’s license number, passport number, date of birth, citizenship, and other similar identifiers;
• Information related to benefits, such as the application for, changes to, and enrollment in employee health and welfare benefits, life insurance, and retirement accounts, details on such benefits such as contribution and deferral levels, the names and other legally required information of beneficiaries, information about your spouse, partner, and dependents, and emergency contact information;
• Financial information, such as banking and direct deposit information, salary, expense reimbursement records, information required for tax and other withholdings and, where applicable, information relating to charitable donations;
• Characteristics of protected classifications under state or federal law, such as age, gender, marital status, race, ethnicity, sexual orientation, veteran status, and disability status;
• Commercial information, such as information collected for any Associate discount programs or benefits;
• Internet or other electronic network activity information, such as log and usage data collected from use of PetSmart systems and devices including browsing history, search history, information regarding your interaction with our websites, applications, and platform, and other information collected via cookies, web beacons and similar technologies;
• Central Bark information, such as content submitted to Central Bark, profile information, and usage activity.
• Audio, electronic, visual, or similar information, such as photographs, clothing size, CCTV footage or other information gathered from security and workplace monitoring systems, or provided by you;
• Geolocation data when you use certain PetSmart-issued devices on PetSmart properties;
• Professional or employment-related information, such as work experience; information in an employment application, on a resume, files you choose to share with us, cover letters, information provided to us during an interview, or provided by references or included in background checks (where applicable); compensation; job title and description, picture, and employee number; performance appraisals and disciplinary reports and customer comments; and workplace investigations; and other work-related documents such as records, forms, logs, and agreements;
• Education information, such as educational background and information on a resume;
• Medical information, such as information related to symptoms of, or risk of exposure to, certain illnesses (e.g., contact with others who may be sick or relevant travel history);
• Inferences, such as notes regarding your performance; and
• Other information as may be permitted or required by law.

Monitoring: We reserve the right to monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources. In the event monitoring occurs, it may result in the collection of personal information about you. Some PetSmart facilities are equipped with surveillance equipment, such as cameras and CCTV, which may capture your image or information about your movements and which may be used to protect the safety of PetSmart staff, visitors, and property, to monitor and troubleshoot issues with equipment or technology, or otherwise for any lawful purpose. In addition, all telephone conversations or transmissions, electronic mail or transmissions, or internet access or usage by Associates by any electronic device or system, including but not limited to the use of a computer, telephone, wire, radio, or electromagnetic, photoelectronic, or photo-optical systems may be monitored at any time by any lawful means. This is not meant to suggest that PetSmart will in fact monitor all Associates, but to alert you that, when using PetSmart equipment and resources, you should not have any expectations of privacy related to your use of PetSmart equipment or resources. We will treat any personal information generated by this monitoring in accordance with this Policy.

Sensitive Personal Information: In some cases, we may collect sensitive personal information about you, which requires a higher level of protection. Please note that, where permitted by law, we may collect, store, and use sensitive personal information about you, including race, ethnicity, veteran status, sexual orientation, sex, gender, age, marital status, disability status, and health and medical conditions. We collect this information for specific purposes, such as to accommodate a disability or illness, comply with legal obligations such as anti- discrimination or diversity regulations (where applicable), protect the health and safety of our employees, and facilitate internal programs and initiatives relating to diversity, equity, inclusion, and anti-discrimination. We only use sensitive personal information for the purposes set out in this Policy, or as otherwise described to you at the time the information is collected, and in accordance with applicable law.

Categories of Sources From Which Personal Information is Collected

We collect personal information from a variety of sources, including:

• Directly from you
• Previous and current employers
• Service providers (e.g., time entry, payroll, and expense reimbursement services)
• Insurance and benefits providers
• Background check services (where applicable and permitted by law)
• Online sources including public social networks and personal webpages
• Open government databases and other public sources

We may also receive information about Associates through authorized medical assessments, legal bodies, and third-party recruitment job posting sources.

Purposes for Collecting, Using, and Disclosing Personal Information

We may, at any time, collect, use, and disclose Associate personal information for purposes related to establishing, maintaining, and concluding the employment relationship, including for the following example purposes of:

• To manage our Associates, such as communicating with an Associate; evaluating and hiring prospective Associates (including by conducting background checks); for determining an Associate’s suitability for advancement, transfer, or promotion to another position; retaining Associates; advancing diversity, equity, inclusion, and anti-discrimination initiatives; training Associates; making compensation determinations; responding to your requests, inquiries, and comment; and for disciplinary and grievance investigations, and considering those decisions in subsequent relevant employment and business decisions up to terminating the employment relationship;
• For operational purposes, such as paying compensation and administering tax and other withholding obligations and company benefits; updating Associate files; conducting audits and training; reimbursing business expenses; providing IT support; facilitating participation in voluntary employee programs and platforms; and managing shifts, working hours, and attendance;
• For benefits administration purposes, such as administering and maintaining group health insurance benefits and wellness programs, retirement plans, life insurance, disability insurance, leave programs, and processing claims for benefits or for workplace injury or workers’ compensation claims;
• For marketing purposes, such as using Associate photos, videos, social media posts, and other content for internal and external marketing activities; sharing associate- focused marketing with you if you share any associate information(e.g., associate ID) in connection with your Treats customer profile;
• For statistical and analytical purposes to understand and improve worker satisfaction, engagement, and performance;
• To administer our applications, software, and systems, including to ensure the security of our workforce, guests, property, and assets, and to monitor and audit network traffic and information in our applications, software, and systems;
• For legal and compliance purposes, such as to implement internal policies, detect, investigate, or resolve any disputes, suspected fraud, security incidents, or any other activity that is illegal or violates our policies, exercise a legal claim, cooperate with law enforcement investigations, and comply with applicable laws, regulations, legal processes, or governmental requests;
• Administering charitable campaigns and donations in which the Associate chooses to participate;
• To protect the health, safety, and vital interests of PetSmart, Associates, or of another natural person, such as during an emergency where the health or security of Associates is in danger, to prevent physical harm or financial loss, including maintaining the security of and appropriate use of our premises, computer systems, network, email, and internet access through monitoring the use of PetSmart facilities and equipment, or through use of video cameras, and communicating with an Associate or an emergency contact;
• To comply with our legal obligations and internal policies relating to initiatives relating to diversity, equity, inclusion, and anti-discrimination;
• As necessary and appropriate to provide reasonable accommodations;
• As necessary for the performance of a contract or to take steps at the request of our Associates before entering a contract (if you do not provide certain information when requested, we may not be able to perform the contract we entered with you, such as paying you or providing a benefit); and
• As otherwise may be permitted or required by law.

Categories of Third Parties to Which Personal Information is Disclosed

We may disclose or transfer Associate personal information internally to PetSmart Associates and affiliates who need to know the information, including human resources, payroll, and information technology departments.

We may also disclose your personal information to service providers retained to administer or provide products, services, or information on our behalf. Any measures we may use to protect Associates’ personal information are subject to the legal requirements of any foreign jurisdictions where the personal information may be transferred or disclosed, for example the United States or Canada. Examples of the third parties to whom personal information may be disclosed include:

• Our parent company, its subsidiary companies, or affiliated companies;
• Payroll, benefits, tax, and garnishment providers and administrators;
• Application tracking systems, and background and employment verification providers;
• Business travel agents and PetSmart-issued credit card providers;
• Employment record retention providers;
• Information technology contractors, risk management providers, communication platform providers, security companies, and investigators;
• Professional advisors, including accountants, auditors, bankers, brokers, consultants, insurers, and lawyers for specified purposes and in accordance with our instructions and the provisions of this Policy and applicable law;
• Government authorities, regulators, and similar third parties, if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
• Third parties connected to : (a) comply with our obligations, including to protect the rights and property of PetSmart, our customers and the public, to cooperate with law enforcement investigations and to detect and respond to suspected illegal activity and threats to the health or safety or any person or of our systems or services; (b) in connection with, or during negotiations of the contemplated or actual financing, insuring, sale, merger, transfer, or assignment of all or part of our business or assets; and (c) with your consent and at your direction.
• Customers, potential customers, and other third parties may be provided work contact details, only as necessary and where the disclosure is required by role.
• Other third parties as may be permitted or required by law.

We may also disclose aggregated or de-identified information, which cannot reasonably be used to identify you.

Data Retention

We retain personal information according to the PetSmart Privacy Policy PetSmart's Enterprise Records Retention Schedule for business, tax, and legal reasons. For example, we retain personal information in accordance with our obligations under applicable labor and employment law and as necessary to administer and carry out the employment relationship and our post- employment obligations, including complying with our legal obligations, resolving disputes, and as necessary for our legitimate interests.

Your Consent

PetSmart collects, uses, and discloses Associate personal information as described in this Policy or, to the extent that consent is required by applicable laws, with Associate consent. Consent may be express or implied depending on the circumstances and the sensitivity of the personal information. Your acceptance or continuation of employment with PetSmart will, in most cases, constitute consent for collection, use, and disclosure of certain personal information as described above. When you provide us with personal information, we will assume that you consent to the collection, use and disclosure of your personal information for the purposes identified in this Policy, if applicable, or otherwise at the time of collection.

Your Responsibilities

During your employment, you may acquire certain confidential information about, without limitation, Associates, our customers, PetSmart systems, financial data, vendors, suppliers, marketing programs or strategies, training programs, or merchandising programs (collectively “confidential information”), and some of that confidential information may be personal information.

Confidential information and personal information may be protected by laws that prohibit the unauthorized collection, use, or disclosure of the information. You agree that, as a condition of employment with PetSmart, you will maintain the confidentiality of all confidential information and personal information and will not disclose it to others except to perform your duties for PetSmart and in accordance with applicable laws. Any breach of your responsibilities may result in disciplinary measures, up to and including the termination of employment.

If, during your employment, you do not understand or are uncertain about your responsibilities, you may speak with your leader, Human Resources, or any of the resources listed in the Open Door Policy.

Security and Accuracy of Personal Information

We employ information security practices, including physical measures (such as locked offices and filing cabinets), organizational measures (such as restricted access and security clearances), and technological measures (such as computer passwords) to protect personal information from unauthorized access. It is important to keep personal information accurate and up-to-date, particularly information required to process payroll and benefits. Associates should promptly update any change in personal information (address, phone number, email address, family status, etc.) through the HR Connect Employee Self-Service.

California Privacy Rights

PetSmart does not “sell” or “share” your personal information, as those terms are defined under privacy laws, and has not done so in the past 12 months.

California residents may have the following rights:

Access. You may have the right to request access to the specific pieces of personal information we have collected about you.

Correction. You may have the right to request that we correct inaccurate information that we maintain about you. As always, you can see and update certain inaccurate personal information at any time through HR Connect Employee Self-Service.

Deletion. You may have the right to request deletion of your personal information we have collected about you (subject to exceptions). After honoring your deletion request, we may retain personal information that is necessary for us to fulfill our legal obligations or that is not otherwise subject to deletion under applicable law. For example, we may keep personal information that is necessary to provide employment or contractor services, detect security problems, or to comply with laws.

Appeal. You may have the right to appeal a denial of your request to access, correct, or delete your personal information.

Limit use and disclosure of sensitive personal information. YWe do not use or disclose sensitive personal information to infer characteristics.

Authorized Agent. You may designate, through a power of attorney or in writing, an authorized agent to access and control your personal information. Authorized agents may contact us through one of the methods listed below to request to access and control your personal information. Before accepting such a request from an agent, we will need you to verify your identity directly with us, and we require the agent to provide proof you have authorized it to act on your behalf via a valid power of attorney or other documentation demonstrating the agent’s authority to access and control your personal information. This can be a letter or other documentation signed by you authorizing the agent to access and control your personal information.

Nondiscrimination. PetSmart never discriminates against anyone for making privacy requests.

Exercising Your Rights. You may make a rights request by calling HR Shared Services at 1- 866-263-8411 or emailing HRSharedServices@PetSmart.com. We may deny your request for any reason permitted or required by law. Questions, requests, or complaints about our personal information practices may also be directed to your leader, Human Resources, or any of the resources listed in the Open Door Policy.

To respect your privacy and security, we must verify your identity before we can give you access to, correct, or delete, your personal data.

To verify your identity, we will need information from you, like your email address and phone number. You may have to share your U.S. driver’s license, state ID, or passport, along with a current digital photo of your face so we can ensure the photo ID truly belongs to you. We may also request additional personal data to validate your employment. Please follow the instructions provided when you submit your rights request.

Reporting

All knowledge of attempted or actual data theft or loss of Associates’ personal information, or violations of this policy, must be reported immediately through a Speak Up resource as outlined in our Code of Ethics and Integrity.

Changes to this Policy

PetSmart may, in its sole discretion, modify, add to, or discontinue portions of this Policy at any time, subject to applicable law.