HOME DEPOT OF CANADA INC. ASSOCIATE PRIVACY STATEMENT

The Home Depot values and respects the privacy of its associates and former associates (collectively, “Associates”), as well as candidates for associate status (collectively with Associates, “you”).

While operating our business and interacting with you, we collect, use, and disclose personal information. We collect, use, and disclose 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 and benefits-related plans and programs; comply with applicable laws and regulations; protect the security and integrity of our systems, processes and business; protect the rights and interests of other members of the Home Depot team, our customers and the public; help prevent fraud; recruit; establish, manage, improve and terminate employment relationships; promote workplace safety; fulfill our obligations to Associates and others; otherwise support our business operations; and for the other purposes disclosed in this Associate Privacy Statement or through other means of communicating with you.

This Associate Privacy Statement provides you with information about how we collect, use, and disclose personal information, the governance policies and practices we have in place to protect this information, and the choices and rights available regarding your personal information. If you have any questions, please contact us at privacycanada@homedepot.com.

ABOUT THIS STATEMENT

This Associate Privacy Statement describes the privacy practices of Home Depot of Canada Inc. and its subsidiaries, divisions, affiliates, brands, and other The Home Depot companies, located in Canada, 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:

• Your performance of duties for us
• 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

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 U.S.A., Inc. or The Home Depot Mexico, Associates located outside of Canada, 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 [change link to the Canadian Privacy and 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. As always, please read any such privacy statements with care.

WHAT INFORMATION DO WE COLLECT?

Below we describe the categories of information we collect regarding Associates and candidates. You can find information about our sources of information from, our purposes for using the information, and the types of recipients that may receive the information from us in the “How Do We Collect Information?”, “How Do We Use Information?”, and “Information Disclosures” sections that follow.

Categories of Information:

1. General Information. This information includes name, address, telephone number, associate ID, unique personal number such as social insurance, insurance policy, bank account, credit card and driver’s license numbers, license plate number for access to facilities, passport data, signature, or other similar identifiers.
2. Internet & Networking Activity. This includes Internet or other similar network activity associated with use of our equipment, networks, or other resources, including but not limited to incoming and outgoing electronic communications, browsing history, search history, interactions with websites or applications, login credentials, electronic records and files, IP addresses and other information associated with network activities, and logs of application access and use.
3. Education Information. This includes transcripts, certifications, skills and proficiencies, and training attended.
4. Demographic Information. This includes demographics as permitted by law, such as age, race, ethnicity, ethnic origin, colour, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, reproductive health, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status.
5. Location Information. This includes rough or exact location based on IP address or mobile device location information.
6. Employment Information. This includes professional or employment-related information, such as application information, employment history, demographic information, performance evaluations, work schedule, salary and other compensation information, benefits and allowances, tenure, hours worked, terms of employment, records of any disciplinary proceedings or investigations, job responsibilities, background check information, business and travel expenses, and any documentation relating to your candidacy or work eligibility.
7. Video and Audio Recordings: This information includes in-store CCTV and customer care calls. We may capture your image via closed circuit television cameras deployed in our stores, vehicles, parking lots, warehouses and other facilities. We may capture video or audio recordings when you interact with our customers or other Associates or otherwise use our communications equipment.

HOW DO WE COLLECT INFORMATION?

We collect information directly from you and from other sources.

For example, we collect information directly from you 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, provincial, and federal governments
• Submit to background checks
• 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
• 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, paid time off, 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. For example, 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 information, such as collecting information regarding how Associates use technological resources.

We collect information from affiliates and subsidiaries of The Home Depot.

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 and other members of the public
• Former Associates
• Service Providers who assist us in completing our business activities and objectives
• Your co-workers, supervisors, 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

HOW DO WE USE INFORMATION?

We use personal information about Associates, candidates, and their beneficiaries and dependents to support workforce management; recruit and hire Associates; establish, manage, improve and terminate employment relationships; support workforce management; conduct workforce analytics; communicate with Associates, candidates, and others; monitor use of technology; administer Associate-related plans and programs; comply with applicable laws and regulations; protect the security and integrity of our systems, processes, and business; protect the rights and interests of other members of the Home Depot team, our customers and the public; promote workplace safety; fulfill our obligations to Associates and others; and to otherwise support our business operations; and for the other uses disclosed in this Associate Privacy Statement or through other means of communicating with you.

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 and 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, terminations, reviewing employment decisions.
• Making business travel arrangements.
• Planning and monitoring of training requirements and career development activities and skills.
• 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 and associated benefit plans and programs.

TRANSFERS TO SERVICE PROVIDERS

We may transfer your information Canadian, US and foreign affiliates and other service providers who provide services on our behalf to carry out the purposes described in this Associate Privacy Statement, including to operate and manage our business and risks, to improve and market our products and services, to comply with our legal or regulatory obligations, and as required or permitted by law.

Our affiliates and service providers may have access to your information on a confidential basis to the extent necessary to perform their functions. We might also authorize our service providers to collect information on our behalf.

More particularly, we transfer your information to our service providers for the following purposes:

• To support business operations and streamline internal processes
• To conduct analytics and improve our products and services
• To offer products and services that are jointly developed or provided

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)
• 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
• Legal and accounting service providers
• Other service providers as may be deemed necessary by the Company in order to conduct its business

INFORMATION DISCLOSURES

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

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. Your information will be shared in accordance with applicable law and will only include information that is relevant and necessary to facilitate or complete the transaction.

When necessary to comply with our legal and regulatory obligations. By way of example only, we may disclose your information:

• in response to a search warrant, court order, or other legally valid inquiry or order
• if a government agency or investigatory body requests it in accordance with its legal authority
• to fulfil reporting requirements regarding financial compensation and tax issues
• to establish, exercise or defend our legal interests
• as otherwise required or permitted by law

With our business partners for their purposes or a joint purpose.

• For example, we might disclose information to one of our affiliates or subsidiaries 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
• Statistical aggregations (i.e., files which may include information regarding your employment, but stripped of identifying fields such as name, social insurance 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

Data Retention

We retain the personal information we collect regarding Associates and candidates and their respective beneficiaries and dependants for as long as reasonably necessary to assess employability, manage ongoing employment relationships, and achieve the purposes disclosed in this Associate Privacy Statement, 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
• Protecting the rights or safety of you, us, or others

If we no longer require your personal information for any of these purposes, we will securely delete or anonymize it in accordance with applicable law, unless we are required or permitted by law to keep it for a longer period.

Cross-Border Transfers

Home Depot of Canada Inc. is based in Canada, but some of our affiliates, subsidiaries and service providers may process or store personal information on our behalf in other regions or countries, including the United States. For Quebec residents, please note that it is possible that this information could be communicated outside Quebec. This means that your personal information may be subject to the laws of those jurisdictions, which may include laws that permit or require disclosure of personal information to government agencies, courts and law enforcement. We take reasonable steps to ensure that our affiliates, subsidiaries and service providers comply with applicable laws and maintain appropriate safeguards for your personal information wherever it is used or stored.

How We Protect, Store and Transfer Your Information

We use a combination of physical, technical, and organizational safeguards to protect your personal information. These measures are adapted to the volume and sensitivity of the information, the purposes for which it is used, and the format in which it is stored, and include the following:

• A privacy framework governing the protection of personal information throughout its lifecycle. This framework defines the roles and responsibilities of our personnel, provides a process for dealing with complaints regarding the protection of the information, and addresses the retention and destruction of personal information.
• Internal policies and procedures that outline the roles and responsibilities of our Associates throughout the information life cycle and, where appropriate, limit their access to such information on a “need-to-know” basis.
• Technical safeguards to protect information transmitted over the internet.
• A designated Privacy Officer to oversee our compliance with applicable privacy laws.
• Employee privacy and data security training.

While we use appropriate means to protect our systems, no technology is 100% secure. The measures we use are appropriate for the type of information we collect. We cannot promise that your use of our technologies will be completely safe. We encourage you to use caution when using the Internet or other technologies.

Accessing and Correcting Your Personal Information

To the extent required or permitted by applicable law, you have the right to access your personal information in our records and to correct it if it is inaccurate, incomplete or no longer up to date. You may exercise these rights by contacting your Human Resources partner or by contacting us at privacycanada@homedepot.com.

Withdrawal of Consent

Under applicable law, you may be able to withdraw consent to the communication, use or disclosure of the personal information collected. Please contact privacycanada@homedepot.com with any such request.

LINKS

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.

CONTACT US

If you have additional questions or concerns about how we handle your personal information, or have questions about how to exercise your rights, you can reach our Privacy Officer at:

Privacy Officer & General Counsel
Home Depot of Canada Inc.
Attention: Privacy Office
400-1 Concorde Gate
Toronto, Ontario
M3C 4H9

Email: privacycanada@homedepot.com

CHANGES TO THIS ASSOCIATE PRIVACY STATEMENT

From time to time we may update our privacy policies, including this Associate Privacy Statement, to reflect changes in our information handling practices, to comply with applicable laws and regulations, or to improve the clarity and transparency of our policies. If we make any material changes to our Associate Privacy Statement, we will notify you by posting an updated copy on our website or by any other means permitted or required by applicable law, such as by sending you an email, posting a notice in a prominent location on our websites or by providing notice through other communication channels that are reasonably likely to reach you. Please check our website periodically for updates.

Date of first posting: August 31, 2023