AVENTIX ANIMAL HEALTH

PRIVACY POLICY

Last Updated: July 7, 2026

Table of Contents

1. Who We Are

2. Information We Collect

3. How We Collect Information

4. Why We Collect and Use Information

5. Consent

6. Marketing and Email Communications

7. Cookies and Website Analytics

8. Sharing Information

9. International Transfers

10. Data Retention

11. Data Security

12. Your Privacy Rights

13. Quebec Privacy Rights (Law 25)

14. European Economic Area (EEA) Privacy Rights

15. United Kingdom Privacy Rights

16. Australia Privacy Rights

17. Governance & Privacy Office

18. Changes to This Policy

Appendix A - Records Retention Policy

Appendix B - Privacy Complaint Handling Procedure

Aventix Animal Health ("Aventix", "we", "our", or "us") is committed to protecting the privacy and security of personal information entrusted to us by our customers, veterinary professionals, veterinary clinics, distributors, wholesalers, business partners, website visitors, and other individuals with whom we interact.

This Privacy Policy explains how we collect, use, disclose, protect, retain, and otherwise process personal information in the course of our business activities. Aventix is committed to complying with applicable privacy and electronic communications laws, including Canada's Personal Information Protection and Electronic Documents Act (PIPEDA), Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25), Canada's Anti-Spam Legislation (CASL), the U.S. CAN-SPAM Act, European Economic Area (EEA) Privacy Rights, UK General Data Protection Regulation (UK GDPR), Australian Privacy Principles (APPs), and other applicable privacy and marketing laws.

1. Who We Are

Aventix Animal Health is a business-to-business (B2B) animal health company that works primarily with veterinary clinics, veterinary professionals, distributors, wholesalers, retailers, manufacturers, and other commercial partners worldwide. Aventix generally does not market products directly to consumers or collect personal information from pet owners except where necessary to support business operations, inquiries, events, or regulatory requirements.

Aventix does not market products directly to consumers or collect personal information from pet owners except where necessary to support business operations, inquiries, events, or regulatory requirements. For purposes of applicable privacy laws, Aventix is responsible for the personal information under its control.

For purposes of applicable privacy laws, Aventix Animal Health is responsible for the personal information under its control.

2. Information We Collect

Depending on the nature of our relationship with you, we may collect the following information:

Business Contact Information

· Name

· Job title

· Employer, clinic, or company name

· Business email address

· Business telephone number

· Business mailing address

Employment and Payroll Information

· Name

· Address

· Social Insurance Number (SIN)

· Banking information

· Tax forms

· Benefit information (including dependent and beneficiary details)

Age Restrictions: Our services, business operations, and websites are strictly intended for corporate business-to-business interactions and are not directed to minors. We do not knowingly collect, maintain, or process personal information from individuals under the age of 14 (or the legal age of majority in applicable jurisdictions) without verifiable parental or guardian consent. If we discover we have inadvertently collected information from a minor under 14, it will be securely destroyed immediately.

Relationship and Communication Information

· Customer inquiries and correspondence

· Product information requests

· Event registrations and attendance information

· Marketing and communication preferences

· Subscription status

· Records of consent and withdrawal of consent

· Customer relationship history

Website and Technical Information

· IP address

· Browser type and device information

· Website usage information

· Cookies and similar technologies

· Website analytics and interaction information

Email Engagement Information

When legally permitted, we may collect information relating to our communications, including:

· Email delivery status

· Email opens

· Link clicks

· Subscription preferences

· Unsubscribe requests

3. How We Collect Information

We may collect information:

· Directly from you;

· Through our Territory Managers and sales representatives;

· Through customer and supplier relationships;

· Through conferences, trade shows, and industry events;

· Through our website and online forms;

· Through email subscriptions;

· Through distributors and business partners where appropriate;

· Through publicly available professional sources where permitted by law; and

· Through technologies such as cookies and analytics tools.

4. Why We Collect and Use Information

We may use information for the following purposes:

· Managing customer and business relationships;

· Providing products, services, support, and educational resources;

· Responding to inquiries and requests;

· Processing orders and business transactions;

· Managing events and professional education programs;

· Communicating regarding products, services, and company updates;

· Conducting marketing and promotional activities where permitted by law;

· Improving our products, services, and website;

· Maintaining business records;

· Detecting fraud, misuse, or security incidents;

· Complying with legal, regulatory, contractual, and industry requirements; and

· Exercising or defending legal rights.

For employment and payroll information, we collect and use personal information relating to employees, contractors, and job applicants for employment-related purposes, including recruitment, onboarding, payroll processing, compensation administration, benefits administration, tax reporting, workforce management, legal compliance, and maintaining employment records.

We will only collect, use, and disclose personal information for purposes that a reasonable person would consider appropriate under the circumstances.

Automated Decision-Making: Aventix does not use personal information or technological profiles to render decisions based exclusively on automated processing that produce legal or significant effects concerning individuals. If automated tools are deployed in the future to evaluate parameters such as credit terms or purchasing profiles, this policy will be updated, and individuals will be informed of the underlying logic and their right to submit observations.

5. Consent

Where required by applicable law, Aventix obtains consent for the collection, use, and disclosure of personal information.

Consent may be obtained:

· Expressly, such as through forms, event registrations, website opt-in mechanisms, or written communications; or

· Implicitly, where permitted by law and based on an existing business relationship or other lawful basis.

Technology-Based Consent Restrictions: Notwithstanding the above, for website tracking, behavioural profiling, geolocational analysis, or the deployment of non-essential cookies on our digital platforms, Aventix relies strictly on explicit opt-in consent. These tracking and profiling technologies are deactivated by default for users in jurisdictions requiring opt-in consent (such as Quebec and the European Economic Area (EEA)) until affirmative consent is given.

You may withdraw your consent at any time, subject to legal, regulatory, or contractual restrictions and reasonable notice.

Withdrawal of consent may affect our ability to provide certain information, services, products, or communications.

6. Marketing and Email Communications

Aventix may send commercial electronic messages, product updates, educational information, event invitations, newsletters, promotional communications, and other business-related messages where permitted by applicable law.

In accordance with CASL, CAN-SPAM, and other applicable laws, Aventix:

· Obtains appropriate consent where required;

· Maintains records relating to consent and communication preferences;

· Clearly identifies Aventix as the sender;

· Provides current contact information;

· Includes a clear and functioning unsubscribe mechanism in marketing communications;

· Honors unsubscribe requests within 10 business days; and

· Maintains records of subscription and opt-out preferences.

Marketing emails may include information regarding engagement, including email opens, clicks, and other interaction data, to improve communications and maintain customer relationship records.

You may unsubscribe from marketing communications at any time using the unsubscribe link included in our communications or by contacting us directly.

Even if you opt out of marketing communications, Aventix may continue to send transactional, service-related, safety-related, regulatory, legal, or account-related communications where permitted by law.

7. Cookies and Website Analytics

Our website may use cookies, web beacons, analytics tools, and similar technologies to:

· Improve website functionality;

· Analyze website performance;

· Understand visitor interactions;

· Enhance user experience; and

· Support marketing and business operations.

You may manage cookie preferences through your browser settings or other tools made available on our website.

Where required by applicable law, we will obtain consent before placing non-essential cookies on your device.

8. Sharing Information

Aventix does not sell personal information.

We may disclose information to trusted service providers and business partners that support our operations, including:

· Customer relationship management providers;

· Marketing and communication platforms;

· Event management providers;

· Website hosting providers;

· Cloud service providers;

· Analytics providers;

· Information technology and cybersecurity providers; and

· Professional advisors, including legal, accounting, and consulting firms.

These organizations are permitted to access information only as necessary to perform services on our behalf and are expected to maintain appropriate confidentiality and security safeguards.

Internal Personal Access Limits: Internally, access to your personal information is strictly restricted on a "need-to-know" basis. Only authorized Aventix personnel who require the data to fulfill their specific professional duties—such as our Territory Managers, sales representatives, customer service teams, and IT/billing support staff—are granted access to personal records.

We may also disclose information:

· To comply with legal obligations;

· To respond to lawful requests from government authorities;

· To protect our rights, safety, property, or interests;

· In connection with corporate transactions such as mergers, acquisitions, reorganizations, or asset sales; or

· Where otherwise required or permitted by applicable law.

9. International Transfers

As an international organization, Aventix may transfer, store, or process personal information outside your province, territory, state, or country of residence, including in Canada, the United States, and other jurisdictions where Aventix or its service providers operate.

Information transferred to another jurisdiction may be subject to the laws of that jurisdiction and may be accessible to local governments, courts, regulators, or law enforcement authorities in accordance with applicable laws.

Where required, Aventix implements appropriate contractual, organizational, and technical safeguards for cross-border data transfers.

10. Data Retention

Aventix retains personal information only for as long as necessary to:

· Fulfill the purposes for which it was collected;

· Maintain accurate business and consent records;

· Meet operational needs;

· Satisfy legal, regulatory, accounting, and contractual obligations; and

· Resolve disputes or enforce agreements.

When information is no longer required, it will be securely deleted, anonymized, or destroyed in accordance with our records retention practices (Appendix A)

11. Data Security

Aventix maintains reasonable administrative, technical, and physical safeguards designed to protect personal information against:

· Unauthorized access;

· Unauthorized disclosure;

· Loss;

· Misuse;

· Alteration; and

· Destruction.

While no security measure can guarantee absolute security, Aventix regularly evaluates and updates its safeguards to address evolving risks.

12. Your Privacy Rights

Depending on your jurisdiction and applicable law, you may have the right to:

· Access your personal information;

· Request correction of inaccurate information;

· Withdraw consent;

· Request deletion of information where permitted by law;

· Request information regarding the use or disclosure of your information;

· Request explanation regarding automated decision-making where applicable;

· Lodge a complaint with a privacy regulator; and

· Manage communication preferences.

Request Data Portability: Where personal information has been collected in an electronic format, you have the right to request that your computerized personal information be provided to you in a structured, commonly used, and technological format, or transferred directly to another organization designated by you, provided such transfer is technologically feasible.

Requests may be submitted through our privacy request process or by contacting us.

13. Quebec Privacy Rights (Law 25)

For individuals located in Quebec, Aventix is committed to complying with Quebec's Act Respecting the Protection of Personal Information in the Private Sector (Law 25).

Where applicable, individuals may request:

· Access to personal information;

· Correction of inaccurate information;

· Withdrawal of consent;

· Information regarding the processing of personal information;

· De-indexation or cessation of dissemination where legally applicable; and

· Information regarding cross-border processing activities.

Aventix will implement privacy impact assessments and appropriate safeguards when required under applicable Quebec privacy legislation.

14. European Economic Area (EEA) Privacy Rights

For individuals located in the European Economic Area (EEA), Aventix processes personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (GDPR).

Legal Bases for Processing

Where required by law, Aventix processes personal data on one or more of the following legal bases:

· Your consent;

· Performance of a contract;

· Compliance with legal obligations;

· Protection of vital interests;

· Performance of tasks carried out in the public interest; or

· Legitimate business interests that are not overridden by your rights and freedoms.

GDPR Rights

Subject to applicable law, you may have the right to:

· Access your personal data;

· Correct inaccurate personal data;

· Request deletion of personal data ("right to be forgotten");

· Restrict processing of personal data;

· Object to processing based on legitimate interests;

· Withdraw consent where processing is based on consent;

· Request data portability; and

· Lodge a complaint with a supervisory authority.

International Transfers

Where personal data is transferred outside the EEA, Aventix will implement appropriate safeguards as required by applicable law, including contractual protections or other lawful transfer mechanisms.

15. United Kingdom Privacy Rights

For individuals located in the United Kingdom, Aventix processes personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the UK Data Protection Act 2018.

Individuals in the United Kingdom may exercise rights similar to those available under the GDPR, including rights to:

· Access personal data;

· Correct inaccurate information;

· Request deletion of personal data;

· Restrict or object to processing;

· Withdraw consent where applicable;

· Request portability of personal data; and

· Submit complaints to the Information Commissioner's Office (ICO).

Where personal data is transferred outside the United Kingdom, Aventix will implement appropriate safeguards as required under applicable UK data protection laws.

16. Australia Privacy Rights

For individuals located in Australia, Aventix is committed to handling personal information in accordance with the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs).

Collection and Use

Aventix collects, uses, and discloses personal information only where reasonably necessary for our business activities and in accordance with applicable Australian privacy requirements.

Access and Correction

Individuals may request access to personal information held by Aventix and request correction of inaccurate, incomplete, or outdated information, subject to applicable legal exceptions.

Overseas Disclosure

Where personal information is disclosed outside Australia, Aventix will take reasonable steps to ensure recipients handle personal information in a manner consistent with applicable privacy obligations.

Complaints

Individuals who have concerns regarding our handling of personal information may contact Aventix using the details below. If concerns are not resolved, complaints may be directed to the Office of the Australian Information Commissioner (OAIC).

17. Governance & Privacy Officer

Aventix maintains a data privacy program that protects personal information throughout its lifecycle through defined responsibilities, employee training, incident reporting and assessment procedures, and a structured process for addressing privacy complaints (Appendix B).

Aventix has designated an individual responsible for privacy compliance and personal information management.

Privacy Officer
Aventix Animal Health
data.privacy@aventix.ca
905-332-4744

18. Changes to This Policy

Aventix may update this Privacy Policy from time to time to reflect changes in our business practices, legal obligations, technologies, or services.

Any updates will be posted on this page, and the "Last Updated" date will be revised accordingly.

Material changes may be communicated through additional channels where required by law.

Contact Us

If you have questions or concerns about this Privacy Policy or our privacy practices, please contact the Privacy Officer using the contact details above.

Appendix A - Records Retention Policy

Purpose

Aventix Animal Health ("Aventix") is committed to retaining personal information and business records only for as long as reasonably necessary to fulfill legitimate business, legal, regulatory, contractual, and operational requirements.

Scope

This policy applies to all employees, contractors, consultants, and third-party service providers who create, access, manage, store, or dispose of company records.

Retention Principles

Aventix will:

Retain records only for legitimate business and legal purposes.
Limit retention of personal information to the period necessary to fulfill identified purposes.
Maintain records in a secure manner throughout their lifecycle.
Securely destroy, anonymize, or delete records when no longer required.
Suspend destruction where records may be required for litigation, audits, investigations, or regulatory matters.

Standard Retention Periods

Record Type

Retention Period

Customer and Distributor Records

7 years after end of relationship

Sales and Transaction Records

7 years from transaction date

Marketing Consent Records

3 years after consent withdrawal or expiry

Employee Personnel Files

7 years after employment ends

Payroll and Tax Records

7 years from end of relevant tax year

Recruitment Records (Unsuccessful Applicants)

2 years after hiring decision

Contracts and Agreements

7 years after expiration or termination

Privacy Complaints and Investigations

7 years after closure

Website Analytics Data

Up to 26 months

Supplier Records

7 years after relationship ends

Exceptions

Records may be retained beyond the periods specified above where required by law, regulatory requirements, contractual obligations, or where litigation, audits, investigations, or other legal proceedings are ongoing or reasonably anticipated.

Secure Disposal

When records are no longer required, Aventix will:

Permanently delete electronic records.
Securely shred paper records.
Anonymize information where appropriate.
Maintain destruction methods appropriate to the sensitivity of the information.

Responsibility

All Aventix employees are responsible for complying with this policy. The Privacy Officer is responsible for overseeing records retention and disposal practices.

Appendix B - Privacy Complaint Handling Procedure

Purpose

Aventix is committed to addressing privacy concerns promptly, fairly, and transparently.

How to Submit a Complaint

Individuals may submit privacy complaints by contacting:

Privacy Officer
Aventix Animal Health
4350 Mainway
Burlington, ON L7L 5R7

Email: data.privacy@aventix.ca
Phone: 905-332-4744

Information Requested

Where possible, the complainant should provide:

Name and contact information
Description of the concern
Relevant dates
Supporting documents or correspondence
Desired resolution

Complaint Review Process

Step 1: Acknowledgement

Aventix will acknowledge receipt of the complaint within 5 business days.

Step 2: Investigation

The Privacy Officer will review the complaint.
Relevant records, correspondence, systems, and business processes may be examined.
Employees and service providers may be consulted where necessary.

Step 3: Response

Aventix will provide a written response within 30 days, where reasonably possible.
If additional time is required, the complainant will be informed of the reason and expected timeline.

Step 4: Corrective Action

Where a complaint is substantiated, Aventix may:

Correct inaccurate information.
Modify internal procedures.
Provide additional employee training.
Strengthen privacy safeguards.
Update records as appropriate.

Escalation Rights

If a complainant is not satisfied with Aventix's response, they may contact the applicable privacy regulator, including:

Office of the Privacy Commissioner of Canada
Commission d'accès à l'information du Québec
Relevant provincial, state, national, or international privacy regulator

Record Keeping

Aventix will maintain records of:

Privacy complaints received
Investigations conducted
Findings and outcomes
Corrective actions implemented

Complaint records will be retained in accordance with Aventix's Records Retention Policy