The Home Depot, Inc. Associate Privacy Statement

The Home Depot values and respects the privacy of its associates and former associates (collectively, “Associates” or “you”), as well as candidates. While operating our business and interacting with you, we collect, use, and share personal information. We collect and use personal information about Associates, candidates, and their respective beneficiaries and dependents to communicate with such individuals; support workforce management; conduct workforce analytics; monitor use of technology; administer employment-related plans and programs; comply with applicable laws and regulations, protect the security and integrity of our systems, processes and our business; help prevent fraud, recruit, manage employment relationships, and for the other purposes disclosed in this Associate Privacy Statement.

This Associate Privacy Statement provides you with information about how we collect, use, and share personal information, and describes choices and rights available regarding your personal information. If you have any questions, please contact us via the channels listed below.

This Associate Privacy Statement describes the privacy practices of The Home Depot, Inc. and its subsidiaries, divisions, affiliates, brands, and other The Home Depot companies, located in the United States or its territories, that link to this Associate Privacy Statement (collectively, “The Home Depot,” “our,” “us,” “we,” or “Company”). It applies to the information we collect in association with your interactions with us, including, but not limited to:

• Use of our websites, including mobile websites
• Activities in our stores or at our events
• Use of our information technology resources, including but not limited to networks, devices, communications tools, and applications
• Phone and email communications
• Interactions with customers and other Associates
• Interactions with authorized service providers

It also applies to personal information that we receive from business partners and other third parties, such as recruiters, background check providers, customers, other Associates, and references.  You can find out more information about our collection of personal information below.

This Associate Privacy Statement does not apply to the practices of The Home Depot Canada or The Home Depot Mexico, Associates located outside of the United States or its territories, or to the information we collect from individuals interacting with us in a consumer, rather than an employment, capacity.  Please see The Home Depot Privacy & Security Statement for information about our consumer data practices.  Also, this Associate Privacy Statement does not apply to third-party websites accessible through our websites. Other The Home Depot companies may provide different privacy and security statements or policies for their business operations that may differ from this Associate Privacy Statement.

We do not disclose the personal information we collect from Associates, candidates, or individuals under 16 years of age for valuable consideration (i.e., we do not “sell” such information as that term is defined under certain laws), and we do not disclose such information for targeted advertising purposes (i.e., we do not “share” such information as that term is defined under certain laws).

We retain the personal information we collect regarding Associates and candidates for as long as reasonably necessary to assess employability, manage ongoing employment relationships, and achieve the purposes disclosed above, unless a shorter retention period is required by law.  We may retain personal information after employment relationships end or after employment decisions are made. The length of retention may vary depending upon factors such as:

• The existence of an ongoing relationship between you or your dependents and us;
• Recordkeeping or legal compliance requirements;
• The need to resolve inquiries or complaints;
• Identifying other employment opportunities for you; and
• Protecting the rights or safety of you, us, or others.

When imaging or copying Company information stored on Company-issued devices, personal information the device user has stored on such device, including personal information collected by apps installed on such device by you, us, or pre-installed by the device manufacturer, may be inadvertently collected if we are unable to distinguish or otherwise separate it from Company information. This may include sensitive personal information.

Biometric Data

The Company may collect and retain biometric information concerning a limited number of our associates, contractors, and authorized third parties, and we would like to provide more information on this type of data processing. The term “biometric information” means any information, regardless of how it is captured, converted, stored, or shared, based on an individual’s biometric identifier that is used to identify an individual. That could include a retina or iris scan, fingerprint, voiceprint, or scan of hand or face geometry.

We collect and retain biometric information (facial scans) from a limited number of our associates, contractors, and authorized third parties to verify or authenticate their identity for purposes of accessing restricted areas on The Home Depot premises. We use a service provider to gather this biometric information. It may be collected via biometric access control software, which is a computer-based system that scans an individual’s face for purposes of identification. We may share or disclose biometric information to our third-party service providers to assist in satisfying the purposes for which the data was gathered or collected and to other third parties when permitted, or otherwise required by law (e.g., complying with judicial or law enforcement demands).

The Company will retain such biometric information for no longer than is permitted by law, but and generally in no event longer than three (3) years after the applicable individual’s last interaction with the Company. In some cases, we may retain your biometric information for a longer period where required by applicable law.

We collect information directly from you.

For example, we collect information when you:

• Complete an application for employment, job opening, transfer, or rehire
• Select, register, or participate in Company benefit plans and programs
• Complete forms required by local, state, and federal governments
• Submit to background checks or drug screenings
• Provide beneficiary information and emergency contacts
• Provide financial information to facilitate payment of wages, bonuses, reimbursement, or other rewards
• Work in our stores or other facilities, including parking lots
• Communicate with coworkers, management, customers, and others
• Participate in career development or training activities
• Complete work tasks and manage other associates
• Use company technology such as computers, systems, and applications
• Participate in performance appraisals, disciplinary actions, or other evaluations of work performance
• Participate in promotion and succession planning activities
• Time tracking activities for hours, PTO, leave, or other relevant time related details
• Complete a survey or provide a rating
• Use an online forum, submit a question, or answer to our internal information sharing platforms
• Upload or share a photo, submit a request, submit information, or post other digital content through one of our internal websites, applications or information sharing platforms
• Participate in Associate focused sweepstakes, contests, promotions, programs, clinics, or workshops
• Use certain company resources for which we record usage information
• Conduct transactions with customers where logging of transaction details is retained
• Use company provided resources for travel arrangements
• Request expense reimbursements
• Perform other work-related activities that require submission of your personal information to complete, fulfill, or otherwise perform the Company’s business objective(s)

We collect information from you passively.

We use cameras and other technologies in our stores, in parking lots and at other facilities for fraud prevention, security, and asset protection. We monitor use of technology to detect and measure security and fraud threats, as well as to monitor compliance with company policies. We also may conduct workforce related analytics that include your personal information, such as collecting information regarding how Associates use information resources. We may also share this information when complying with laws and regulations, and cooperating with law enforcement as we deem reasonably necessary to comply with laws, support investigations, and protect the rights and property of you, us, and others.

We collect information from Affiliates of The Home Depot.

We collect information from third parties.

In the course of serving you and operating our business, we collect information from a variety of third parties. For example, we collect information from:

• Recruiters
• Consultants and advisors
• References
• Social media
• Customers
• Former associates
• Service Providers who assist us in completing our business activities and objectives
• Your coworkers, supervisor, and business contacts
• Providers of internal communication platforms
• Public records resources
• Companies that help us process payments, benefits, and associate programs
• Security and fraud prevention providers
• Agencies, courts, or municipalities for orders we must comply with

We collect and use personal information about Associates, candidates, and/or their beneficiaries and dependents to support workforce management; recruit Associates; manage and improve employment relationships; conduct workforce analytics; communicate with Associates, candidates, and others; monitor use of technology; support customer care and software-based customer care analysis, enable certain features and experiences in AI tools, administer Associate-related plans and programs; comply with applicable laws and regulations, cooperating with law enforcement as we deem reasonably necessary to comply with laws, support investigations, and protect the rights and property of you, us, and others; protect the security and integrity of our systems, processes, and business; promote workplace safety; fulfill our obligations to Associates and others; and to otherwise support our business operations.

Here are some examples of how we use the information we collect:

Our workforce management activities include managing work activities and personnel, recruitment, appraisals, performance management, promotions and succession planning, transfers, rehiring, administering salary, compensation administration and reviews, wages, bonuses, and other awards, equity plan (such as stock options, stock grants, and stock purchase plan) participation and administration, processing accounts payable and receivable for associates and contractors, healthcare benefits, retirement savings plans, training, leave, managing disability and sickness leave and accommodations, honoring other contractual benefits, providing employment confirmations, loans, performing associate surveys, performing background checks, managing disciplinary matters, grievances and terminations, reviewing employment decisions, making business travel arrangements, planning and monitoring of training requirements and career development activities and skills, and creating and maintaining one or more internal associate directories.

Our workforce analytics activities include supporting the workforce management activities referenced above, data security, and other operational activities.

Our communications activities include facilitating communication with Associates, ensuring business continuity, property management (e.g. laptops and mobile phones), providing employment confirmations, protecting the health and safety of associates and others, identifying and providing reasonable accommodations, safeguarding IT infrastructure, office equipment and other property, and communicating with your nominated contacts in an emergency.

Our administration of Associate-related plans includes both: (1) daily activities between managers and Associates, including the fair implementation of associate evaluation procedures and financial reward incentives, and (2) the efficient and responsible management of associate services, access to Company resources, associate and family-related health care, retirement/401(k) and associated benefit plans and programs.

We may share your information for our business purposes and as legally required or permitted by law. Please see below for examples of circumstances in which we share information.

With third parties who perform services on our behalf.

• Providing products, services, and other benefits to associates (these service providers may have their own privacy policies. We encourage you to review each third-party’s privacy statement)
• Service providers, such as our suppliers, vendors, and other service providers who need your contact information
• Providers of security and payment services, such as to pay your wages, bonuses, and expense reimbursements
• Third parties that help us communicate with you
• Data storage providers
• Communications services
• Payroll providers
• Other service providers as may be deemed necessary by the Company in order to conduct its business

With any successor to all or part of our business.

• For example, if all or part of our business is sold or otherwise acquired, we may sell or disclose our associate lists and other personal information we collect in preparation for or as part of that transaction

If we think we have to in order to comply with the law or cooperate with legal requests.

• We will provide it in response to a search warrant or other legally valid inquiry or order
• To an investigative body in the case of a breach of an agreement or contravention of law
• Reporting requirements regarding financial compensation and tax consequences

With our business partners.

• For example, we might disclose information to one of our Affiliates or a business partner who is working on a joint business objective(s)

For security, safety, and fraud prevention.

• We will disclose information to detect, prevent, and investigate fraud or unlawful activities
• We may also disclose information to collect unpaid debts or company assets not returned
• Criminal or civil investigations into suspected or alleged Associate or Company misdeeds
• Cooperating with law enforcement as we deem reasonably necessary to comply with law, support investigations, and protect the rights and property of you
• Statistical aggregations (i.e., files which may include information regarding your employment, but stripped of identifying fields such as name, social security number, country identification number, Associate number, etc.) which may be required to monitor our Company-wide compliance with laws throughout the world

At your direction.

• For example, if you ask us to provide your information to a third-party to participate in a benefit, perk, or other activity offered by The Home Depot

The California Consumer Privacy Act (“CCPA”) provides California residents with the following privacy rights regarding the information we process about Associates and candidates:

• Right to Know: the right to request information about the personal information that we collect, use, and disclose
• Right to Delete: the right to request the deletion of personal information that we have collected from individuals, though we may be permitted to retain personal information for certain purposes
• Right to Correct: the right to request that we correct inaccurate personal information
• Non-Discrimination: We may not discriminate against you for exercising your rights under the CCPA. We may, however, provide a different level of service if the difference is reasonably related to the value of your information

We have compiled information about the number of California privacy rights requests we received in the previous calendar year and how we responded to them. Please view the California Privacy Rights & Report  for the report.

If you are a California resident who is a current or former Associate and would like to exercise one of these rights, you can click here or call us at:  1-866 myTHDHR (1.866.698.4347) and select option 4 and then select Privacy Questions.  Candidates may exercise such rights by going to https://www.homedepot.com/privacy/Exercise-My-Privacy-Rights .

We require that you provide the following information to submit a request:

• State of residence
• First and last name
• Email address and confirmation that the request is submitted by a natural person
• Phone number
• Postal address

The information that you provide will be analyzed to determine whether we can reasonably verify your identity. We may need to obtain additional information from you to process your request. For example, if we determine that the information provided is not sufficient for verification, you may be prompted to answer a few questions.

There may be circumstances where we may not completely fulfill your request, as permitted under the CCPA. For example, if you submit a request to delete your personal information, we may need to retain certain personal information to complete a transaction, detect fraud, or comply with our legal obligations.

If you are an authorized agent acting on behalf of a California resident, please send your request to myinfo@homedepot.com and include the following information about you and the person on whose behalf you are submitting the request: full name, mailing address, email address, and phone number. You should also provide proof of your authorization to act on the other person’s behalf. We will contact you for additional information once your request has been received.

Our websites contain links to third-party websites. If you click on one of those links, you will be taken to websites we do not control. This Associate Privacy Statement does not apply to the information practices of those websites.