HD SUPPLY HOLDINGS, INC. PRIVACY NOTICE

Updated June 1, 2023

The privacy, confidentiality and security of your information is very important to HD Supply Holdings, Inc. and its subsidiaries and divisions (“HD Supply”).  We have prepared this Privacy Notice to let you know about the manner in which we collect, use, disclose, and otherwise manage the information we may collect about you through:  (a) interactions with any of our HD Supply sales associates (“Sales Associates”), our HD Supply Call Centers (the “Call Centers”), our websites and mobile applications (the “Sites”), our approved marketing partners (“Marketing Partners”), or our authorized service providers (“Service Providers”); (b) visiting our HD Supply Distribution Centers or other physical locations (the “Locations”); or by participating in other in‑person events (“Events”); or (c) any other circumstance in which you are provided with a copy of this Privacy Notice.

Information We Collect:

We may collect your information when you:

  • • Purchase, order, rent, return, exchange, or request certain information about our products and services;
  • • Contact a Call Center, Sales Associate, or other customer service desk, or interact with us via email or other forms of communication;
  • • Interact with us at an Event;
  • • Visit or register with our Sites;
  • • Apply for employment or other positions;
  • • Visit a Location; or
  • • Provide us with feedback, comments, or suggestions.

Information You Provide to Us:

We may collect information from you directly, including on our Sites, through our Sales Associates, through our Call Centers, or at Events.  This information may include your name, address, billing information, email address, telephone and facsimile numbers, social security number and other government identification, financial information, other information related to your business and your account with HD Supply, and any other information you provide in the course of interacting with us.

We may also collect information provided by you in the course of evaluating or engaging you for employment or other positions.  This information may include your first and last name, email address, CV, resume, cover letter and any other information provided by or about you, including information from references and background check providers.

Information We Collect through Automated Data Collection Technologies:

We may collect your information using automated data collection technologies as described in the “Additional Information about our Sites” section below.  Additionally, when you visit our Locations, we may collect video and audio recordings of your activity in our Locations through our use of CCTV and other similar recording equipment.

Information We Obtain from Third Parties:

We may obtain your information through third‑party sources such as lead generation companies, Marketing Partners, affiliates, and Service Providers.

How We Use Your Information:

We use your information:

  • • To fulfill or meet the reason you provided the information, such as fulfilling orders, deliveries, and returns, and responding to inquiries.
  • • To facilitate and improve the operation of our business, including to maintain the safety, security, and integrity of our Sites, products and services.
  • • To help us gain a better understanding of your preferences and interests so we can improve our products, services, and marketing to better serve your business, and/or our other customers.
  • • To inform your business about products and services, sales, and special offers that might benefit your business.
  • • To respond to your feedback, suggestions, survey information, and comments to monitor and/or improve the ways in which we serve you.
  • • To register you for Events and other meetings you sign up for.
  • • For internal legal compliance purposes.
  • • To provide the information to Service Providers and other third parties as described in the “Sharing Your Information” section below.
  • • For other purposes consistent with the context of the collection of your information, or as otherwise disclosed to you prior to the use of your information.

Call Centers:

When you call one of our Call Centers about a product, delivery, installation, billing question, or customer service, you may be asked for information that identifies your business along with additional information we need to help us promptly answer your question, such as your name and address or a telephone number where we might contact you or another person in your business.  We may retain this information to assist your business in the future.

Online Registration:

Registration is an optional service provided by some of our Sites.  You do not have to register your business to browse online.  When you register, you may be asked for information such as your name, business name, address, telephone number, email address, a password, and business interests.  This registration information may be used to help make your online shopping quicker and easier by, for example, pre‑populating certain parts of your shopping information.

Promotional Email Opt‑out:

You may choose to receive promotional email communications.  If you have opted in or otherwise qualify to receive these forms of communication, and no longer wish to receive promotional communications by email, you may opt‑out or unsubscribe by following the instructions that are included on each email.

Sharing Your Information:

In the course of our business, we may disclose your information to third parties in the following circumstances:

Service Providers and other Companies That Work with or on Behalf of HD Supply:

We share your information with Service Providers for operations, technology, payment, marketing, and other purposes.  Some of our operations, such as our Call Centers, may be managed by unaffiliated partner companies.  In addition, if you purchase special products or services from HD Supply, these products or services may not be provided by HD Supply affiliates, but rather by reputable local or national companies with which we contract to provide such products or services.  Other third parties provide technology we use on our website to optimize your shopping experience and to market relevant products and services to you on our Sites and in email communications that you agree to receive.  These companies may have access to your information to the extent necessary to perform their respective functions.

We may also share your information with businesses such as advertising partners, data sellers, and similar companies, in accordance with the “Additional Information about our Sites” Section below and other sections of this Privacy Policy.

Sale of Business:

HD Supply may transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets to a third party as part of a merger, acquisition, bankruptcy proceeding, or other restructuring.

Legal Purposes:

We may provide your information if we have a good faith belief that the law requires it, such as in response to a search warrant, subpoena, or other legally valid inquiry, order, or process, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law.  We may also disclose information to assist us in collecting a debt, or as necessary to exercise our legal rights or defend claims brought against us.

With Your Consent:

We may share your personal data where you have provided your consent to us sharing or transferring your personal data (e.g., where you provide us with marketing consents or opt‑in to optional additional services or functionality).

Additional Information About Our Sites:

Visiting our Sites:

In general, you can visit our Sites without telling us who you are or providing us with your business information.  However, we collect the IP (Internet protocol) addresses of all visitors to our Sites and other related information such as page requests, browser type, operating system, and average time spent on our Sites.  We use this information to monitor and improve our Sites.

Cookies:

Our Sites use a technology called “cookies”.  A cookie is a tiny element of data that our Sites and our third‑party technology providers can send to your browser, which may then be stored on your hard drive so we can recognize you when you return.  All pages on our Sites where you are prompted to log in or that are customizable require that you accept cookies.  If you have registered with our Sites, these cookies:  (1) may let us know who you are, (2) are necessary to access your account information (stored on our computers) in order to deliver products and personalized services, and (3) will provide us and our service providers with information that we will use to personalize our Sites in accordance with your preferences.  Cookies are also required to optimize your shopping experience in that they allow you to add multiple items to your shopping basket before checking out and help us to recommend relevant products to you.  We also use cookies set by third‑party partners to deliver you targeted advertisements across the Internet.  You may set your web browser to notify you when you receive a cookie.  However, should you decide not to accept cookies from our Sites, you will limit the functionality we can provide when you visit our Sites.

Third‑Party Links:

Our Sites may include links to the websites of our business partners, vendors, and advertisers.  HD Supply provides links to third‑party websites as a convenience to the user.  The inclusion of any link does not imply HD Supply’s endorsement of any other company, its websites, or its products and/or services.  These linked websites have separate and independent terms of use and privacy policies, which we recommend you read carefully.  We have no control over such websites and therefore have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, or disclose and otherwise treat your information.

Tracer Tags:

Our Sites may also use a technology called “tracer tags”.  These may also be referred to as “clear GIFs” or “web beacons”.  This technology allows us and our third‑party technology providers to understand which pages you visit on our Sites.  These tracer tags are used to help us optimize and tailor our Sites for you and other future website visitors.

Google Analytics™:

We use automated technologies and applications, such as Google Analytics, to evaluate usage of our Sites.  We also may use other analytic means to evaluate our Sites and services.  We use these tools to help us improve the Sites, performance, and user experiences.  These entities may use cookies and other tracking technologies to perform their services.  To learn how Google Analytics collects and processes data, please visit:  http://www.google.com/analytics/learn/privacy.html.

How We Respond to Do Not Track (DNT) Settings:

Some web browsers (including Safari®, Internet Explorer®, Firefox® and Chrome®) incorporate a “Do Not Track” (“DNT”) or similar feature.  At the present time, the Sites do not respond to DNT signals.

Data Retention:

We retain your information as long as reasonably necessary for the respective purpose.  In determining the criteria by which to retain or dispose of your information, we consider the type, sensitivity, context, and purpose of collecting the information.  HD Supply may additionally delete your information in response to a valid data subject request, as described below.

Security of Your Information:

We maintain administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of your information in our custody and control.  No data, on the Internet or otherwise, can be guaranteed to be 100% secure.  While we strive to protect your information from unauthorized access, use, or disclosure, HD Supply cannot and does not ensure or warrant the security of your information.

Children’s Privacy:

HD Supply does not knowingly collect personal information from children under the age of 6.

California Residents:

If you are a California resident, your information may be covered by the California Consumer Privacy Act (“CCPA”).  The below disclosures apply to the extent the CCPA applies to your data, subject to any applicable exemptions.

“Personal Information” We Collect:

The categories of “personal information,” as defined in the CCPA, that we collect include:

  • • Identifiers
  • • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
  • • Commercial information
  • • Internet or other electronic network activity information
  • • Audio, electronic, and visual information
  • • Professional or employment‑related information
  • • Inferences drawn from other personal information

 

HD Supply may obtain, use, and share these data categories as detailed in the “Information We Collect,” “How We Use Your Information,” and “Sharing Your Information” sections of this Privacy Notice, above.

Some of the personal information we collect and process may qualify as “sensitive information” under the CCPA.  Where we collect your sensitive information, we only process this information for limited purposes consistent with Cal. Civ. Code § 1798.121(a).

“Sales” and “Sharing” of Personal Information:

We may share personal information with third parties for targeted advertising purposes.  Under the CCPA, these practices may be considered “sales” or “sharing” of data and you have the opportunity to opt out of these practices by selecting that option on our website (hdsupplysolutions.com) by clicking on the link in the footer entitled “Do Not Sell or Share My Personal Information” and following the instructions to opt‑out.

Your California Privacy Rights:

You may have the following rights with respect to your personal information under the CCPA:

(i) Right to Know About Personal Information Collected, Disclosed, or Sold:  You may have the right to request that we provide certain information to you about our collection and use of your personal information over the past twelve (12) months.  Specifically, you may have the right to request disclosure of:

  • • The specific pieces of personal information we collected about you;
  • • The categories of personal information we collected about you;
  • • The categories of sources from which personal information was collected;
  • • Our business or commercial purpose for collecting or disclosing personal information; and
  • • The categories of third parties with whom we shared personal information.

 

(ii) Right to Request Deletion of Personal Information:  You may also have the right to request that we delete any of your personal information that we collected or maintain about you, subject to certain exceptions.

(iii) Right to Correct Inaccurate Personal Information:  You may also have the right to request that we correct inaccurate personal information we maintain.

(iv) Right to Non‑Discrimination for the Exercise of a Consumer’s Privacy Rights:  We will not unlawfully discriminate against you for exercising any of your applicable privacy rights.

(v) Exercising Your California Privacy Rights:  To request to exercise your CCPA rights described above, please submit a verifiable consumer request to us by using the information in the “Contact Us” section below.  Only you or your “authorized agent,” as defined in the CCPA, may make a verifiable consumer request related to your personal information.

Your verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.  We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  We will use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  Making a verifiable consumer request does not require you to create an account with us.

(vi) Response Timing and Format:  We will make our best effort to respond to a verifiable consumer request within forty‑five (45) days of its receipt.  If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing.  Within ten (10) days of receiving the request, we will confirm receipt and provide information about its verification and processing of the request.  HD Supply will maintain records of consumer requests made pursuant to the CCPA as well as our response to said requests for a period of at least twenty‑four (24) months.

(vii) Your Rights Under “Shine the Light”:  In addition to your rights under the CCPA, California Civil Code Section 1798.83 permits California residents to request information regarding our disclosure, if any, of their personal information to third parties for their direct marketing purposes.  If this applies, you may obtain the categories of personal information shared and the names and addresses of all third parties that received personal information for their direct marketing purposes during the immediately prior calendar year.  You may submit this request using the information in the “Contact Us” section below.

Contact Us:

Please feel free to contact us at any time if you have any questions or comments about this Privacy Notice.

For general inquiries not related to the California Consumer Privacy Act (“CCPA”), you can contact us or otherwise communicate your privacy concerns by:

  • • Calling us at 1‑877‑694‑4932
  • • Emailing us at [email protected]
  • • Accessing your registration information on our Sites
  • • Writing us at the address below (please include your email address and telephone number with your correspondence along with the information needed to support your request):

HD Supply
Attn:  Legal Department
3400 Cumberland Blvd., SE
Atlanta, GA 30339‑4435

 

To exercise your rights under the California Consumer Privacy Act (“CCPA”), you can contact us by:

  • • Calling us at: 1‑833‑906‑1281
  • • Emailing us at:  [email protected]
  • • Writing us at the address below (please include your email address and telephone number with your correspondence along with the information needed to support your request):

HD Supply
Attn:  Legal Department
3400 Cumberland Blvd., SE
Atlanta, GA 30339‑4435

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