Lowe’s Associate Privacy Statement

What Information We Collect
What Are the Sources of Your Information
Why We Collect Your Information
How We Share Your Information
Your Privacy Rights and Choices
How We Protect Your Information
How We Retain Your Information
Scope
How to Contact Us
Updates
California Residents Only: Privacy Requests

Effective 8/31/23

This Privacy Statement is also available in Español.

Lowe’s U.S. Associate Privacy Statement (the “Privacy Statement”) describes how Lowe’s Companies, Inc. and its U.S. operating subsidiaries and affiliates (“Lowe’s”, “we”, “our”, “us”) collect, use, share, and protect personal information: (a) related to current and former associates (collectively, “Associate(s)”) in an employment context, and (b) personal information about current and former associates’ family members and other individuals that is made available to Lowe’s as a result of the relationships those individuals have with those associates (collectively, “related persons”). It also contains other important privacy disclosures, such as choices you can make with regard to your personal information, how we may update the Privacy Statement and how you can contact us. It is the responsibility of our associates to make this Privacy Statement available to their related persons.

THIS PRIVACY STATEMENT IS NOT A CONTRACT AND DOES NOT CREATE ANY LEGAL RIGHTS OR OBLIGATIONS. This Privacy Statement also is not intended to replace other notices or disclosures we may provide to an individual in connection with their role in our organization, which will supersede any conflicting disclosures contained in this Privacy Statement.

A. Associates

We collect the following categories of information in order to identify you, communicate with you, evaluate and respond to your requests, inquiries, and applications, manage all aspects of your application and employment relationship, comply with applicable laws, and administer company programs and promote company culture and image:

• Identification information that can be used to identify you, such as name, address, telephone number, email address, driver’s license number, date of birth, and Social Security number or similar government identifiers.
  
• Protected class information under state or federal laws, such as your immigration status, ability to work legally in the U.S., gender, race, and ethnic background.
  
• Commercial information, such as information related to your participation in company benefits and engagement programs or booking information for company travel. 
  When you use your associate discount card to purchase products and services at Lowe’s, we may use your associate ID and other identification information to identify you as a customer and to apply the associate discount. Personal information collected, used and shared when you are acting in Lowe’s customer capacity will be governed by the Lowe’s Privacy Statement for customers available at the footer of the Lowe’s commercial websites.
• Online activities information, such as device usage history, Internet Protocol (IP) address, browse and search history, interactions with our websites, applications, clickstreams, or other information about your online interactions when you use Lowe’s owned or operated IT or communications systems (e.g., computers and phones). We, and our authorized service providers, may also use analytics tools to collect information about your keystroke activity and rhythms, mouse movements, scrolling, and clicks when you use our websites or mobile applications.
  
• Geolocation information, including precise geolocation data when you drive certain types of company vehicle at work, such as a Lowe’s delivery truck, or when you use certain types of company-owned in-store customer services devices, such as Zebra.
  
• Audio, electronic, video or image information, such as photographs or video recordings taken during your participation in company events, records related your physical access (e.g., entry/exit/location) to Lowe’s facilities, audio recordings when you contact us, and video recording at Lowe’s facilities for security purposes.
  
• Professional or employment-related information, such as employment history, performance evaluations and reviews, hours and days worked, working arrangement, work restrictions or accommodations, candidate identification number, employee identification number, licenses, and certifications, attendance, career goals, performance reviews, disciplinary records, information needed to establish eligibility to work for us, including visa information and other information provided to HR throughout the employment relationship.
  
• Education information, such as your degree and education background information.
• Inferences or preferences we learn or infer about you, such as information related to any assessment you may take as part of the interview screening process during your tenure for promotional opportunities.
  

• Sensitive personal information. We may also collect personal information elements about our Associates that may be classified as “sensitive personal information” under certain privacy laws. This may include information such as precise geolocation when you use company vehicle or device, government issued ID and bank account information to identify you and process your compensation, race and ethnicity information for diversity, inclusion and compliance purposes, and login credentials when you use company-issued devices or company systems. We may also collect health related information for purposes of processing workers’ compensation claims and to comply with the Americans with Disabilities Act (ADA).
  
• Other personal information you may choose to share with us or make publicly available, or that we receive from a third party in connection with your work for us, such as personal or family employment affiliation with Lowe’s or criminal record.

B. Related Persons

At times, we receive identifiers and other personal information about our Associate’s family members and other related persons in connection with emergency contacts and the benefits and services we provide. These identifiers and other personal information include:

• Contact information, such as full name, email address, home address, business address, telephone number and emergency contact information.
  
• Audio, electronic, video or image information, such as photographs or video recordings taken or submitted if the Associate chooses to participate in company events or programs.
  
• Benefits and services information, such as personal information necessary to extend benefits and benefit-related services, including insurance-related information, claims-related information, and disbursement-related information.

We do not knowingly collect personal information from children under the age of 16 without parental or guardian consent. If a child under the age of 16 has provided us with personally identifiable information, we ask that a parent or guardian contact us so that the information can be deleted.

For more information about how we retain personal information, please see the “How We Retain Your Information” section below.

A. Associates

We collect different types of information about you from a number of sources, including personal information you provide to us, personal information we automatically collect, information we obtain from other sources (specified below), and information we derive or infer about you.

Information You Provide

You may provide identification information, protected class information under state or federal laws, commercial information, professional or employment-related information education information, sensitive personal information, inferences or preferences, and other personal information described under “What Information We Collect” section during job application, onboarding process and throughout your employment with Lowe’s.

Information We Collect by Automated Means

We collect audio, electronic, video or image information, Online Activities information and geolocation information described under “What Information We Collect” section by automated means online and offline. 

Each Associate’s use of or connection to Lowe’s IT systems, whether through company-provided devices or personal devices (e.g., connecting a personally owned device to a Lowe’s operated Wi-Fi network), is governed by Lowe’s Information Technology and Information Security policies available on LowesNet and is subject to monitoring. ACCORDINGLY, THERE CAN BE NO EXPECTATION OF PRIVACY WITH RESPECT TO THE USE OF SUCH SYSTEMS.

Information We Collect from Other Sources

We may obtain certain information about you from other businesses, such as background checks. We also may collect information directly from our benefit administrators. We may also obtain information from public sources, such as information you submit in a public forum. We may also obtain information about you from Lowe’s affiliates. We may also obtain potential job applicant information from public sources or recruitment business partners.

Information We Generate, Derive, or Infer

We may generate personal information about you, such as assigning an associate ID or job applicant ID to you. We may also derive or infer information about you, such as information related to any assessment you may take as part of the interview screening process upon hire or during your tenure for promotional opportunities.

B. Related Persons

Although we often collect the personal information described above directly from our Associates, we also may collect this information directly from the related person, and from our benefit administrators. In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers.

A. Associates

We use the personal information we collect from you for a range of business purposes, including to:

• Identify you and maintain records related to your employment;
• Communicate with you;
• Evaluate and respond to employment related requests, inquiries, and applications;
• Manage all aspects of your current or former job applicant and employment relationship, including, but not limited to, recruitment and hiring, payroll, benefits, corporate travel and other reimbursable expenses, development and training, absence monitoring, performance evaluation and career management, disciplinary and grievance processes and other general company, administrative and human resource related processes;
  
• Conduct business analysis, research and development for purposes such as operational improvement;
• Comply with applicable laws (e.g. health and safety), including judicial or administrative orders regarding individuals (e.g., garnishments, child support payments);
• Protect the security and integrity of data, systems, processes and our business, and help prevent fraud.
• Administer company programs and promote company culture and image; and
• Offer various associate benefits programs, including associate discount cards.

Associate Benefit Programs:

A summary of different benefits programs and material terms available to Lowe’s Associates is provided in the My Benefits page. In order to participate in some of these programs, you may be asked to provide personal information, such as identification information (e.g., name, email address, phone number and mailing address). You may adjust your benefits participation and preference in My Benefits page.

You will receive an associate discount card once you meet the eligibility requirements and we monitor the use of the card to maintain the integrity of the program.

B. Related Persons

• Communicate about eligibility benefits and services, events or activities that are happening, or in the event of an emergency;
  
• Administer benefits and services;
  
• Respond to requests and inquiries;
• Conduct internal investigations, audits, compliance, risk management, problem resolution, and security operations;
• Fulfill contractual obligations;
• Comply with applicable law, rule, regulation, legal proceeding, and government investigations, including relating to tax reporting and immigration.
  

We disclose personal information of Associates and related persons outlined above for business purposes to service providers or, to other third parties at your direction for the purposes described below:

Within Lowe’s

We share personal information relating to Associates and related persons within our family of companies for internal administrative purposes and uses that are consistent with this Privacy Statement. For example, the Lowe’s entity responsible for payroll may receive personal information about Associates employed by another Lowe’s entity in order to determine the proper compensation to be provided.

Benefits Administrators

In order to provide our Associates and related persons with benefits and services available to them, we share personal information with the third parties we engage to offer and administer benefits and services on our behalf. These third parties may also collect additional personal information directly from our Associates and their related persons in connection with these benefits and services, which will be subject to the relevant third party’s own privacy policies, notices and terms.

Other Service Providers

In addition to the third parties identified above, we may disclose your personal information to companies or agents that provide services to us, such as associate engagement vendors, workforce management and analytics vendors, information technology vendors, training and development vendors, vendors providing hosting, support, payroll, actuarial services, and vendors that help us manage employment or application processes. These providers may need access to information about you in order to perform their functions.

In addition, as part of an associate’s job function, we share your work contact information with prospective and current service providers that you deal with in connection with the vendor relationship establish, maintenance and termination processes.

Customers

As part of an associate’s job function, we share your work contact information with prospective and actual customers in connection with the marketing, negotiation, sale, delivery, and provision of the products and services we make available. For example, we may share the images and work contact information for the team of Associates who will be responsible for handling a specific customer’s account.

Public Disclosure

We may disclose certain personal information about our Associates, such as name, job title, work-related contact information and experience, publicly in connection with our recruiting and business operations.

Legal, Enforcement, Security, and Investigation

We may disclose personal information about you (1) if we believe we are required to do so by law, regulation or legal process, such as a court order or subpoena; (2) as we deem appropriate or necessary in response to requests by government agencies, such as law enforcement authorities or tax authorities; (3) when we believe disclosure is appropriate or necessary to protect the rights, property, or safety of Lowe’s, our customers, or others, including to prevent physical, financial or other harm, injury or loss, or to collect debts you owe; or (4) in connection with an investigation of suspected or actual unlawful activity.

Sale or Transfer of Business or Assets

We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including, without limitation, in the event of a reorganization, dissolution, or liquidation).

Privacy Rights for Residents of California

If you are a California resident, you may be able to exercise the right to know, access, delete, or correct your personal information, or opt-out from or limit certain types of processing activities (subject to certain limitations at law). Below are additional details about the privacy rights above:

• Right to know and access your personal information. You may request to access a copy of your personal information that we have collected about you in a format that is easily understandable to the average consumer, and to the extent technically feasible, in a structured, commonly used, machine-readable format, which also may be transmitted to another entity at your request without hindrance. You also have the right to confirm whether we are processing personal data about you and to obtain certain personalized details about the personal information we have collected about you, including the categories and specific pieces of personal information we collect about you, the purposes for which the personal information was collected, the categories of sources from which personal information is collected, the categories of personal information disclosed to third parties (if any), the categories of entities with whom we disclose the personal information, the categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information was disclosed for those purposes, and the categories of personal information sold (if any), and the categories of third parties to whom the personal information was sold. The information may be delivered by mail or electronically at your request.
• Delete your personal information. You may request Lowe’s to delete your personal information we maintain about you. Please note that we need to keep certain information when permitted by law to comply with laws and regulations, and for other solely internal and lawful purposes.
• Correct your personal information. You may request Lowe’s to correct inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.
• No discrimination. You have the right not to receive discriminatory treatment by Lowe’s for the exercise of your privacy rights.

We do not sell the personal information of Associates or related persons and have not sold your personal information in the preceding 12 months. We do not share the personal information of Associates or related persons for targeted advertising and have not done so in the preceding 12 months. We do not use or disclose sensitive personal information for purposes other than those purposes allowed under the California Privacy Rights Act and its implementing regulations and we have not used or disclosed your sensitive personal information except for those purposes in the preceding 12 months. Examples of the permitted purposes include using the sensitive personal information reasonably expected by an average employee for employment related purposes, such as to administer diversity initiatives and benefits programs, to protect security, integrity and safety, and to prevent fraud, malicious and illegal actions.

How to Submit Privacy Request(s)

• Right to access, know, delete, or correct personal information. To exercise your right to access, know, delete, or correct your personal information, please enter the California Resident ONLY: Privacy Request Portal or call 1-844-HR-LOWES. We need your contact information, such as name, address, phone number and email, to submit your request and verify your identity for access, deletion, or correction requests.
  For your information security and privacy, we verify requestor identity. If you are a current associate, we will ask you to log into Lowe’s associate account via single sign on. If you are a former associate, we will verify your identity using information we have on file.
• Agent. You may designate an agent to submit privacy requests on your behalf, but for your protection, we may need to verify your identity directly with you before fulfilling certain requests, and we will deliver your personal information directly to you (if requested). We need your agent’s contact information, and your agent needs to have your information ready when submitting the request.

We maintain administrative, technical, and physical safeguards designed and intended to protect personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. Despite these safeguards, due to inherent uncertainty in the use of the internet and information systems and the potential for unlawful attacks by third parties, we cannot guarantee that the use of our systems, websites, or applications will be completely safe or secure.

You play a critical role in personal information protection, too! Each Lowe’s associate is responsible for protecting all individuals’ personal information to which they have access. Lowe’s associates shall comply with all applicable security and data policies, and shall ensure that they use appropriate safeguards to protect personal information. Examples include:

• Paper and other hard copies containing personal information should be secured in a locked location when not in use and unauthorized copies of such documents should not be made or distributed.
  

• When no longer necessary for business purposes, paper and hard copies containing personal information should be immediately destroyed or discarded using paper shredders or other approved devices or receptacles.

• Computers and other access points to Lowe’s systems containing personal information should be secured when not in use by logging out or locking.

• Usernames and passwords should be guarded and not shared.

• Electronic files containing personal information should only be stored on secured computers and not copied or otherwise communicated to unauthorized individuals within or outside of Lowe’s.

We will retain information we collect from you for as long as necessary or appropriate to carry out the purposes described in this Privacy Statement, or any other notice provided at the time of data collection. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax, and accounting requirements set by a legislature, regulator, or other government authority.

To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.

Where required, we will dispose of or deidentify the information we collect when we no longer need it for the purposes set forth in this Privacy Statement or any other notice provided at the time of data collection, in accordance with Lowe’s retention policies and procedures, or, if this is not possible (for example, because personal information has been stored in backup archives), then we will protect the personal information until deletion or deidentification is possible.

When we use the term “personal information” in this Privacy Statement, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual within the context of the individual’s role as a member of our Associates or a related person. It does not include aggregated or deidentified information that is maintained in a form that cannot reasonably be used to infer information about, or otherwise be linked to, a particular individual. Where we maintain de-identified data, we will maintain and use the data in de-identified form and not attempt to re-identify the data except as required or permitted by law.

The Privacy Statement covers the privacy practice of Lowe’s Companies, Inc. and its U.S. operating subsidiaries and affiliates (“Lowe’s”), except as outlined below. It applies to personal information related to (a) current and former associates (collectively, “Associates”) in an employment context, and (b) personal information about current and former associates’ family members and other individuals that is made available to Lowe’s as a result of the relationships those individuals have with those associates (collectively, “related persons”).

In some cases, we may provide additional details about privacy practices specific to a particular operation or location. Any such additional terms supplement or amend this statement, but only with respect to the matters governed by such separate disclosures.

This Statement does not apply to:

• Personal information collected when you interact with Lowe’s as a customer. Such personal information is governed by the Lowe's Privacy Statement available at the footer of the Lowe’s commercial websites.
• Personal information that qualifies as Protected Healthcare Information collected and held by or on behalf of Lowe’s Welfare Plans (such as the Group Medical Plan, the Vision Care Plan, the Dental Plan, etc.). Such personal information is governed by the Lowe’s HIPAA Privacy Policy and HIPAA Privacy Notice published on Lowe’s Benefit Site.
• Your interactions with third parties or their websites that are linked to or accessible from Lowe’s websites or that are operated by unaffiliated parties, even though the website may contain references to Lowe’s. The information collection, use and sharing practices are governed by the respective privacy notices at the bottom of the sites.

If you have questions or comments about this Privacy Statement or if you would like us to update information we have about you, please contact us as indicated below.

Privacy Office
1000 Lowe’s Boulevard, NB6LG
Mooresville, NC 28117
privacy@lowes.com

If you suspect or observe an incident that may deviate from this Statement such as a potential loss of personal information, you may also contact the Lowe’s Compliance by phone (1-800-309-5859), by email (compliance@lowes.com), or to NAVEX Global, which is an independent third party responsible for field compliance-related complaints. Complaints submitted to NAVEX Global may be made anonymously. NAVEX Global can be reached through one of the following methods:

a. Via the Internet: www.ethicspoint.com
b. Via the Telephone: 800-784-9592 for the U.S. and Canada; 10-800-120-1239 for Southern China; 10-800-712-1239 for Northern China; 800-964214 for Hong Kong; 001-8008407907 or 001-866-737-6850 for Mexico; 00801-13-7956 for Taiwan; 1-800-80-8641 for Malaysia; 001-803-011-3570 or 007-803-011-0160 for Indonesia; 120-11067 for Vietnam; 001-800-12-0665204 for Thailand; 000-800-100-1071 or 000-800-001-6112 for India; 01800-9-155860 for Colombia; 0800-8911667 for Brazil or 503-619-1883 for use internationally.

We will not permit retaliation, whether direct or indirect, against Associates for reporting, in good faith, suspected violations.

This Privacy Statement may be updated periodically and without prior notice to you to reflect changes in our information practices or relevant laws. We will post a notice on Corporate Privacy Resource Center and other websites that point to this Privacy Statement to notify you of any substantive changes to the way we collect and use information. We will indicate the date the Privacy Statement was last updated at the top of the Privacy Statement.

By opting into one or more text message programs, you expressly consent to receive automated text messages from Lowe’s or others texting on its behalf to your phone number(s). Your consent to such messages is not required as a condition to purchase goods or services from Lowe’s. The number of messages per month will vary based on the subscription list you’ve enrolled in. Consent is not required to purchase goods or services. Message and data rates may apply. You may discontinue the receipt of these text messages at any time by texting STOP to the short code for the text messaging program from which you no longer wish to receive messages (i.e., the short code number from which its text messages are being sent). We may send you an SMS message to confirm that you have been unsubscribed. Similarly, for additional help, text HELP to the short code for the text messaging program about which you have questions, or contact HR at hrservicecenter@lowes.com.

HR Program: 839847

Lowe’s will use reasonable commercial efforts to deliver the automated marketing or nonmarketing text messages to the number you provide through compatible wireless carriers. Carriers are not liable for delayed or undelivered messages.

Lowe’s will not share phone numbers on the opt-in lists with third parties for their independent marketing purposes irrelevant to Lowe’s services and products in exchange for money.

Compatible wireless carriers may be subject to change without notice but currently include AT&T, Verizon Wireless, Sprint, T-Mobile, MetroPCS, U.S. Cellular, Boost Mobile and Virgin Mobile, among others.