Notice of Data Collection and Privacy Policy

Last Updated: January 1, 2023

Ashley Furniture Industries, LLC, Ashley Distribution Services, Ltd., Ashley Global Retail, LLC, Ashley HomeStores, Ltd., Stoneledge Furniture, LLC, and their respective subsidiaries and affiliates (collectively referred to as “Ashley,” “we,” “us,” or “our”) want you to know how we collect, use, and disclose, your personal information.

Assistance for the Disabled

Alternative formats of this Notice of Data Collection and Privacy Policy (the “Privacy Policy”) are available to individuals with a disability. Please contact opinion@ashleyfurniture.com for assistance.

This Privacy Policy explains:

• The categories of personal information we collect about you
• The categories of sources from which we collect your personal information
• The purposes for which we use your personal information
• How we may disclose your personal information
• How long we keep your personal information
• Your privacy rights and how to exercise them
• Changes to this Privacy Policy

Scope:

This Privacy Policy applies to the personal information of:

• employees;
• job applicants;
• independent contractors, interns, and other individuals who perform work for us (collectively “Non-Employees”); and
• employees’ and Non-Employees’ dependents, emergency contacts, and beneficiaries (“Related Contacts”).

This Privacy Policy is intended to inform you about the categories of personal information we have collected about you in the preceding twelve months as well as the categories of personal information that we will collect about you in the future in connection with your role as an employee, Non-Employee, or Related Contact. For information regarding our privacy practices regarding personal information collected from customers and prospective customers, please read our privacy policy available at https://www.ashleyfurniture.com/privacy-policy/.

Except where the Privacy Policy specifically refers only to a specific category of individuals, such as employees, this Privacy Policy refers to all categories of individuals collectively.

“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

1)      THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT

 

1. Employees

• Identifiers, for example: real name, alias, telephone number, postal address, e-mail address, signature, bank account name and number for direct deposits, and photographs.
• Professional or Employment-Related Information, for example: educational institutions attended, degrees and certifications, licenses, work experience and previous employers, professional memberships and affiliations, seniority, training, employment start and ending dates, and job title.
• Compensation and Benefits Information for Employees, for example: salary, bonus and commission, equity compensation information, hours and overtime, leave information, bank details (for payroll and reimbursement purposes only), benefits in which you may be enrolled, and identifying information for dependents and beneficiaries.
• Non-public Educational Information, for example: academic transcripts.
• Commercial Information, for example: business travel and expense records.
• Internet Activity Information, for example: Internet browsing and search history while using our network, log in/out and activity on our electronic resources, interactions with our websites or apps, and publicly available social media activity.
• Mobile Device Information, for example: device model and serial number for Ashley-owned devices or personal devices enrolled in Microsoft Intune or similar mobile device management software.
• Sensory or Surveillance Data, for example: voicemails, recordings of meetings or video-conferences, and footage from video surveillance cameras.
• Other Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, such as insurance policy numbers.
• Preferences, for example, hobbies and leisure activities, membership in voluntary, charitable, or public organizations, and preferences regarding work tools, travel, hours, food for Ashley events, etc.
• Characteristics of Protected Classifications Under State or Federal Law for Employees, for example: race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations and to support diversity and inclusion programs; disability, medical condition, and pregnancy, childbirth, breastfeeding, and related medical conditions, as necessary to comply with federal and state law related to leaves of absence and accommodation; and marital and familial status as necessary to provide benefits to employees and for tax purposes.
• Sensitive Identifiers, for example: Social Security, driver's license, state identification card, or passport number.
• Biometric Information, for example, a fingerprint for a biometric timeclock.
• Geolocation Data, for example: GPS tracking on Ashley vehicles and locations of Ashley-owned mobile devices.
• Health Information, for example: information about an on-the-job injury collected for workers’ compensation purposes.
• Personal Communications: the contents of mail, email, or text messages on accounts or services not owned, or subscribed-to, by us as described in Ashley’s Acceptable Use Policy (published in AshleyNow) and, to the extent required by law, with your authorization.
• Login credentials, for example: login credentials to an online account owned or subscribed-to by Ashley or as necessary to review personal communications as described in the preceding bullet point.
• Religion, for example if volunteered by an employee in support of the employee’s request for a religious accommodation.
• Sex life: to the extent relevant and necessary for a legitimate Ashley investigation and only if permitted by law (e.g., as needed to investigate allegations of sexual harassment).
• Sexual orientation to the extent volunteered by you, for example, for our diversity and inclusion programs.

 

2. Job Applicants

We collect from job applicants the categories of personal information listed in Section 1.A above, excluding the following categories: (a) compensation and benefits information for employees; (b) mobile device information; (c) characteristics of protected classifications under federal or state law for employees; (d) biometric information; (e) geolocation data; (f) health information, (g) sex life, and (h) sexual orientation.

 

3. Non-Employees

We collect from Non-Employees the categories of personal information listed in Section 1.A above, excluding the following categories: (a) compensation and benefits information for employees; (b) characteristics of protected classifications under federal or state law for employees; (c) health information, (d) sex life, and (e) sexual orientation.

In addition, we collect compensation information, namely amounts paid to Non-Employees for services rendered.

 

4. Related Contacts

We only collect contact information about emergency contacts.

We may collect the following categories of personal information about spouses or domestic partners, dependents, and beneficiaries: (a) Identifiers; (b) Commercial Information if, for example, we arrange travel for a dependent to attend an Ashley event; (c) Internet Activity Information if the individual uses Ashley electronic resources and websites; (d) Sensory or Surveillance Data if the individual enters Ashley facilities; (e) other personal information, such as insurance policy numbers if the individual is covered by Ashley insurance or a beneficiary; (f) Protected Categories of Personal Information, for example, childbirth to administer parental leave, marital status to pay taxes, and familial status to administer benefits; (g) Health Information, for example, infectious disease testing when a Related Contact attends an Ashley event or if needed to administer a leave of absence for you to care for a Related Contact; (h) sex life, for example, date of newborn delivery to administer parental or Family & Medical Leave Act; (i) Login Credentials to an Ashley benefits portal or site; and (j) Sensitive Identifiers, for example, Social Security numbers for beneficiary designations; personal communications if communicating with a workforce member.

Note on inferring characteristics: We do not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about you.

 

2)      THE CATEGORIES OF SOURCES FROM WHICH WE COLLECT YOUR PERSONAL INFORMATION

 

• You, for example, in your application, forms you fill out for us, assessments you complete, surveys you submit, and any information you provide during the course of your relationship with us.
• Your spouse or dependent with respect to their own personal information.
• Internally generated, for example, we may generate performance ratings, evaluations, hours worked, and other information about you.
• Vendors and service providers, for example, recruiters and law firms.
• Affiliated companies, for example, when an employee works on a cross-enterprise team.
• Third parties, for example, job references, business partners, professional employer organizations or staffing agencies, insurance companies.
• Public internet sources, for example, social media, job boards, public profiles, and other public online sources
• Public records, for example, court records, and credentialing and licensing organizations.
• Automated technologies on Ashley’s electronic resources, for example, to track logins and activity across our networks.
• Surveillance/recording technologies installed by us, for example, video surveillance in common areas of Ashley facilities, global positioning system (“GPS”) technologies, voicemail technologies, webcams, audio recording technologies, and Bluetooth® technologies, any of these with consent to the extent required by law.
• Government or administrative agencies, for example, law enforcement and public health authorities.
• Acquired company, if we acquired your employer, we might collect personal information from that employer.

Note: This Privacy Policy does not cover background screening conducted by third-party background check vendors subject to the federal Fair Credit Reporting Act. We provide separate notices for such screening.

 

3)      THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION

 

1. All Individuals other than Job Applicants

 

1. Managing Personnel (not applicable to Related Contacts), including:

• Administration, including:
  • To manage personnel and workforce matters
  • To communicate with the workforce
  • To plan and arrange work supplies and workspaces
  • To fulfill recordkeeping and reporting responsibilities
  • For recruitment of new personnel
  • To resolve internal grievances and disciplinary issues
  • To make business travel arrangements
  • To manage workforce-related emergencies, including health emergencies
• Workforce development, including:
  • To screen workforce for risks to Ashley and continued suitability in their positions
  • To conduct surveys
• Team-building, including:
  • To maintain an internal workforce directory and for purposes of identification
  • To facilitate communication, interaction, and collaboration
  • To arrange meetings and manage Ashley-sponsored events and public service activities
  • To promote Ashley as a place to work
  • Workforce reporting and data analytics/trend analysis
  • For workforce satisfaction

 

2. Monitoring, Security, and Compliance, including:

• To monitor use of our information systems and other electronic resources or information systems
• To conduct internal audits
• To conduct internal investigations
• To administer Ashley’s whistleblower hotline
• To protect the safety and security of our facilities, including preventing illicit activity
• To report suspected criminal conduct to law enforcement and cooperate in investigations
• To control access to secure facilities
• To monitor compliance with Ashley’s policies
• To exercise our rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel

 

3. Conducting Our Business (not applicable to Related Contacts), including:

• To engage in marketing, advertising, and promotion
• For communications with prospective, current, and former customers
• To provide a directory and contact information for prospective and current customers and business partners
• For customer service purposes
• To enable us to comply with contractual obligations
• To manage and fulfill orders
• To manage business expenses and reimbursements
• To engage in project management
• To conduct product and service training
• To conduct research and development
• To conduct quality assurance and improvement
• For event planning

4. Miscellaneous Other Purposes, including:

• To manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning;
• To manage litigation involving Ashley, and other legal disputes and inquiries and to meet legal and regulatory requirements;
• In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Ashley;
• To manage licenses, permits, and authorizations applicable to our business operations; and
• To protect the rights, property, or safety of Ashley, personnel, customers or others.

 

2. Employees

 

1. Generally Applicable Purposes. Unless stated otherwise in Section 1.B.2 below, we may use employees’ personal information for the following purposes:

• Managing employees, including:
  • Administration, including:
    • To set up and manage a personnel file
    • To manage performance
    • To administer compensation, bonuses, other forms of compensation, and benefits (as permitted by law)
    • To manage vacation, sick leave, and other leaves of absence
    • To track hours and attendance
    • To monitor compliance with our policies and administer discipline
• Employee development, including:
  • To provide, evaluate, and manage training
  • To evaluate job performance and consider employees for other internal positions or promotions
  • To assist with professional licensing
  • To develop a talent pool and plan for succession
  • Career development activities
• Team-building, including:
  • For diversity and inclusion programs
  • To arrange team-building and other morale-related activities
  • To design employee retention programs

 

2. Purposes Specific To Certain Categories Of Employees’ Personal Information. We may use the categories of employees’ personal information listed in this Section 1.B.2 for the purposes stated below:

• Purposes For Using Employees’ Biometric Information:
  • For security purposes to verify the identity of an individual entering certain Ashley facilities
  • Using biometric timeclocks to help track hours worked by non-exempt employees
• Purposes For Using Geolocation Data:
  • While we do not track employees’ locations, we track the locations of Ashley-owned vehicles (e.g., trucks and trailers) and Ashley-owned mobile devices (e.g., smart phones and tablets) used by employees.
• Purposes For Using Employees’ Health Information:
  • To the extent necessary to comply with our legal obligations, such as to accommodate disabilities
  • To conduct a direct threat analysis in accordance with the Americans with Disabilities Act and state law
  • For workers’ compensation purposes
  • For occupational health surveillance
  • For occupational health and safety compliance and record-keeping
  • To conduct fitness-for-duty examinations
  • To administer leaves of absence and sick time
  • To provide a wellness program
  • To respond to an employee’s medical emergency

Note: This Privacy Policy does not cover health information governed by the Health Insurance Portability and Accountability Act (HIPAA), the Health Information Technology for Economic and Clinical Health Act (HITECH Act), or similar state laws.

 

• Purposes For Using Employees’ Personal Communications:
  • For purposes of legitimate Ashley investigations and, to the extent required by law, with your authorization.
• Purposes For Using Employees’ Religion:
  • We may use employees’ religion to respond to, and manage, an employee’s request for an accommodation on the basis of religion.
• Purposes For Using Sex Life:
  • We may use information about an employee’s sex life only to the extent relevant and necessary for a legitimate Ashley investigation and only if permitted by law (e.g., as needed to investigate allegations of sexual harassment).
• Purposes For Using Employees’ Sexual Orientation:
  • We will use an employee’s sexual orientation only if voluntarily provided by an employee in connection with our diversity and inclusion program.
• Purposes For Using Employees’ Protected Categories Of Information:
  • We collect information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including, for example, the reporting requirements of the federal Equal Employment Opportunity Act.
  • We collect information about disability status to the extent an employee may need special assistance from us or first responders during emergencies.
  • We collect the following characteristics (in addition to those listed above) for our diversity and inclusion programs (including analytics): (a) religion, (b) sex, (c) gender, (d) pregnancy, (e) childbirth, (f) breastfeeding, or related medical conditions, (g) sexual orientation, (h) disability, (i) gender identity, (j) gender expression, (k) marital status, (l) age, (m) familial status, or (n) ancestry.
  • With respect to disability, medical condition, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions, we use the information as necessary to comply with federal and state law related to leaves of absence and accommodation.
  • With respect to military and veteran status, we use the information as necessary to comply with leave requirements under applicable law and for tax purposes.
  • With respect to age, we use the information incidentally to the use of birth date for birthday celebrations and identity verification.
  • With respect to religion and pregnancy, childbirth, breastfeeding, and related medical conditions, we use the information as necessary for accommodations under applicable law.
  • With respect to protected classifications, such as national origin, we use the information to the extent contained in documents that you provide in I-9 documentation.
  • With respect to marital status and familial status, we use the information for Ashley events and as necessary to provide benefits and for tax purposes.

 

We collect personal information about membership in protected categories on a purely voluntary basis, except where required by law. We use the information only in compliance with applicable laws and regulations.

 

3. Job Applicants

 

1. Generally Applicable Purposes. Unless stated otherwise in Section 1.C.5 below, we may use job applicants’ personal information for the following purposes:

• Recruiting, including:
  • To evaluate job applicants’ qualifications or suitability for employment with Ashley
  • To communicate with job applicants
  • To conduct a pre-employment or criminal history background check
  • For identification purposes
  • For diversity and inclusion purposes
  • To arrange and manage Ashley-sponsored events
  • To create a talent pool for future job openings
  • For recordkeeping purposes
  • To demonstrate job applicants’ agreement to, or acceptance of, documents presented to them (e.g., acknowledgement of employment application, offer letter)
  • To evaluate and improve the recruiting process
  • To promote Ashley as a place to work

 

2. Monitoring, Security, and Compliance, including:

• To monitor use of our information systems and other electronic resources or information systems
• To conduct internal audits
• To conduct internal investigations
• To protect the safety and security of our facilities, including preventing illicit activity
• To report suspected criminal conduct to law enforcement and cooperate in investigations
• To control access to secure facilities
• To monitor compliance with Ashley’s policies
• To exercise our rights under applicable law and to support any claim, defense, or declaration in a case or before a jurisdictional and/or administrative authority, arbitration, or mediation panel

 

3. Conducting Our Business, including:

• For training purposes or quality assurance with respect to Ashley employees conducting interviews or otherwise assisting with the recruiting and hiring process
• For travel and event planning and manage travel reimbursement

 

4. Miscellaneous Other Purposes, including:

• To manage and operate information technology and communications systems, risk management and insurance functions, budgeting, financial management and reporting, and strategic planning;
• To manage litigation involving Ashley, and other legal disputes and inquiries and to meet legal and regulatory requirements;
• In connection with a corporate transaction, sale, or assignment of assets, merger, divestiture, or other changes of control or financial status of Ashley; and
• To protect the rights, property, or safety of Ashley, personnel, customers or others.

 

5. Purposes Specific To Certain Categories Of Job Applicants’ Personal Information. We may use the categories of job applicants’ personal information listed in this Section 1.C.5 for the purposes stated below:

• Purposes For Using Employees’ Health Information:
  • To the extent necessary to comply with our legal obligations, such as to accommodate disabilities
  • For occupational health and safety compliance and record-keeping
  • To respond to a job applicant’s medical emergency

Note: This Privacy Policy does not cover health information governed by the Health Insurance Portability and Accountability Act (HIPAA), the Health Information Technology for Economic and Clinical Health Act (HITECH Act), or similar state laws.

 

• Purposes For Using Job Applicants’ Protected Categories Of Information:
  • We collect information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including, for example, the reporting requirements of the federal Equal Employment Opportunity Act.
  • We collect information about disability and/or medical condition as necessary to comply with federal and state laws related to accomodation.
  • With respect to age, we use the information incidentally to the use of birth date for identity verification.

We collect personal information about membership in protected categories on a purely voluntary basis, except where required by law. We use the information only in compliance with applicable laws and regulations.

 

4. Contingent Workforce

We may use personal information of our Contingent Workforce (e.g., temporary workers, independent contractors, and consultants), to:

• Evaluate the individual’s qualifications for engagements, including licensure and certifications
• Negotiate and execute the agreement with the individual
• Provide orientation and familiarization with our working environment
• Administer the contractual relationship, including payments
• Evaluate your deliverables or performance of the contract
• Manage absences

 

5. Related Contacts

 

1. Spouse and Dependents/Beneficiaries. We may use the personal information of your spouse and dependents/beneficiaries to:

• Manage and administer benefits
• Communicate with the individual
• Arrange travel to, and manage participation in, Ashley events
  2. Emergency Contacts. We may use the personal information of your emergency contacts to communicate in the event of an emergency involving you.

 

6. Deidentified Information

We may convert personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”). We will maintain Deidentified Information in a deidentified form.

4)      HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION

We generally maintain information related to employees, job applicants, Non-Employees, and Related Contacts as confidential. However, from time to time, we may have a legitimate business need to disclose personal information for one of the purposes listed in Section 3 above, to one or more of the categories of recipients listed below. In that event, we disclose your personal information and/or sensitive personal information only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by applicable laws.

 

1. Service Providers and Contractors. We disclose your personal information to service providers and contractors to assist us in meeting our business needs and contractual and legal obligations. We disclose your personal information to service providers and contractors only subject to written contracts in compliance with applicable law. Service providers and contractors include auditors, administrative service providers, law firms, travel agencies, benefits providers, and any other entity providing services to Ashley.

 

2. Affiliated Companies. We disclose your personal information to other companies within the Ashley family of companies.

 

3. Customers and Vendors. We may disclose your personal information to customers and vendors (e.g., disclosing a sales representative’s contact information with customers and potential customers).

 

4. Government or Administrative Agencies. We may disclose your personal information to government or administrative agencies (e.g., to pay taxes, respond to unemployment or state disability insurance claims, to report work-related health and safety issues, to respond to employment charges, and to resolve workers’ compensation claims.

 

5. Public. We may disclose your personal information to the public as part of a press release, for example, to announce promotions or awards. If you do not want your personal information in press releases, please contact our Human Resources department at (888) 757-4036 or opinion@ashleyfurniture.com. We do not disclose sensitive personal information to the public.

 

6. Required Disclosures. We may be required to disclose personal information in a court proceeding; in response to a court order, subpoena, civil discovery request, other legal process; or as otherwise required by law.

 

7. Legal Compliance and Protections. We may disclose personal information when we believe disclosure is necessary to comply with the law or to protect the rights, property, or safety of Ashley, our personnel, our customers, or others.

 

We do not sell your personal information. We do not “share” your personal information (i.e., disclose your personal information for cross-context behavioral advertising).

5)      HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We keep your personal information no longer than necessary for the purposes described in Section 3 above and in accordance with our record retention schedule. To learn more about our record retention schedule for personal information, please contact our Human Resources department at (888) 757-4036 or opinion@ashleyfurniture.com.

6)      YOUR PRIVACY RIGHTS AND HOW TO EXERCISE THEM

 

1. Subject to applicable law, you have the following rights:

 

1. Right to Know. You have the right to submit a verifiable request for copies of specific pieces of your personal information collected in the preceding 12 months and for information about our collection, use, and disclosure of your personal information during that same 12-month time period. Please note that your right to obtain copies does not grant a right to the whole of any document that contains personal information, but only to copies of “specific pieces” of personal information. Moreover, you have a right to know categories of sources of personal information and categories of external recipients to which personal information is disclosed, but not the individual sources or recipients.

 

2. Right to Delete. You have the right to submit a verifiable request for the deletion of personal information that you have provided to Ashley.

 

3. Right to Correct. You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Ashley, taking into account the nature of the personal information and the purposes of processing the personal information.

 

2. How to Exercise Your Rights. We will respond to requests know, delete, and correct in accordance with applicable law if we can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:

• Call (888) 757-4036
• Email opinion@ashleyfurniture.com

 

3. How We Will Verify Your Request.

 

1. Requests To Know Categories Or Purposes. We will match at least two data points that you provide with your request, or in response to your verification request, against information about you that we already have in our records and that we have determined to be reliable for purposes of verifying your identity. Examples of relevant data points include your mobile phone number, your zip code, or your employee identification number.

 

2. Requests To Know Specific Pieces Of Personal Information: We will match at least three data points that you provide with your request, or in response to our request for verification information, against information that we already have about you in our records and that we have determined to be reliable for purposes of verifying your identity. In addition, we may require you to sign a declaration under penalty of perjury that you are the individual whose personal information is the subject of the request.

 

3. Requests To Correct or Delete Personal Information. Our process for verifying your identity will depend on the sensitivity (as determined by Ashley) of the personal information that you ask us to correct or delete. For less sensitive personal information, we will require a match of two data points as described in Section 6.C.1 above. For more sensitive personal information, we will require a match of three data points and a signed declaration as described in Section 6.C.2 above.

Additionally:

• If we cannot verify your identity based on the processes described above, we may ask you for additional verification information. If we do so, we will not use that information for any purpose other than verification.
• If we cannot verify your identity to a sufficient level of certainty to respond to your request, we will let you know promptly and explain why we cannot verify your identity.

 

4. Authorized Agents. If an authorized agent submits on your behalf a request to know, correct or delete, the authorized agent must submit with the request either a power of attorney, signed by you, that is valid under applicable state law; or another document signed by you that authorizes the authorized agent to submit the request on your behalf. In addition, we may ask you or your authorized agent to follow the applicable process described above for verifying your identity.

 

5. Non-Discrimination And Non-Retaliation Policy. We will not unlawfully discriminate or retaliate against you for exercising your rights under the California Privacy Rights Act, to the extent applicable to you.

7)      CHANGES TO THIS PRIVACY POLICY

If we change this Privacy Policy, we will post those changes on this page and update the Privacy Policy modification date above. If we materially change this Privacy Policy in a way that affects how we use or disclose your personal information, we will provide a prominent notice of such changes and the effective date of the changes before making them.

For More Information

For questions or concerns about Ashley’s privacy policies and practices, please contact us at opinion@ashleyfurniture.com.