U.S. ASSOCIATE PRIVACY NOTICE

Effective Date: January 1, 2020

This Privacy Notice explains how Williams-Sonoma, Inc. (“WSI”) collects, uses, discloses, and otherwise processes personal information about our U.S.-based associates, officers, directors, contractors, freelancers, contingent workers, consultants and other outsourced and temporary workers (collectively, “personnel”), and their family members or other individuals about whom we process personal information as a result of the relationships those individuals have with personnel (collectively, “related persons”). Personnel are required to provide a copy of this Privacy Notice to all related persons to whom this Privacy Notice applies.

This Privacy Notice is not a contract and does not create any legal rights or obligations. This Privacy Notice also is not intended to replace other notices or disclosures we may provide to you in connection with your role in our organization, which will supersede any conflicting disclosures contained in this Privacy Notice.

What is Personal Information?

When we use the term “personal information” in this Privacy Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you within the context of your role as a member of our personnel or a related person. It does not include aggregated or anonymized information that is maintained in a form that is not capable of being associated with or reasonably linked to you. For information about your rights and collection of personal information as a customer of Williams-Sonoma, Inc. and its family of brands, please refer to the privacy policy located on the homepage of each brand.

Our Collection and Use of Personal Information

The types of personal information we collect, the way we collect it and how we use it will depend on the relationship you have with us.

Personnel

Collection of Personal Information

In connection with your role as a member of our personnel, we collect certain personal information about you, which may include:

  • Contact Information: such as your full name, email address (personal and work), home address, business address, telephone number and emergency contact information.
  • Identification Materials: such as your image, social security number or other national identification number, passport number, driver’s license number or vehicle license plate number.
  • Professional Information: such as your hire date, employment location, business unit, department, supervisor, job title, position/grade, hours and days worked, working arrangement, work restrictions or accommodations, employee identification number, licenses and certifications, attendance, career goals, performance reviews, disciplinary records and information needed to establish your eligibility to work for us, including visa information.
  • Education & Training Information: such as your highest level of education, the schools you attended and when you were in attendance, degrees, certificates or other educational qualifications you earned.
  • Financial Information: such as your salary, bonus, benefits, expenses, stock or equity grants, bank account and routing information and corporate credit card number.
  • Benefits Information: such as your eligibility for benefits, information about your family members and other related persons under your benefits, and claims relating to your benefits.
  • Equal Opportunity Information: such as age, race, ethnicity, national origin, citizenship, sex, gender identity, sexual orientation, religion, disability or accommodation request, or marital or veteran status when you choose to provide it, but it will not be used in employment-related decisions unless specifically permitted by law.
  • Security Information: such as your work-related accounts and passwords, technical details about your use of work-related devices, your access to physical and electronic work-related locations, and photographs, videos and other visual images of you.
  • Other Work-Related Information: We also collect any personal information you choose to share with us or we receive from a third party in connection with your work for us, a grievance you are involved in, an agreement you enter into with us or additional roles you take on as a part of our organization.

Although we often collect the personal information described above directly from you, we also collect this information from supervisors, colleagues, customers, vendors, publicly available sources and other third parties you may interact with as a member of our personnel. 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, payroll providers and benefits providers.

Use of Personal Information

We use the personal information we collect about our personnel to:

  • Conduct organizational planning and development, including budget planning and administration;
  • Analyze and monitor compliance with our personnel and compliance policies and practices;
  • Administer recruiting, onboarding, staffing, leave, personnel evaluations, promotions, performance management, training, discipline, participation in available activities or programs and any other processing in connection with work-related purposes;
  • Authorize, grant, administer, monitor (including by video surveillance) and terminate access to or use of company systems, facilities, records, property and infrastructure;
  • Communicate with and between personnel, as well as with designated emergency contacts;
  • Support and manage personnel, including providing resources needed for personnel to perform their roles with us;
  • Facilitate personnel compensation, payroll, and benefit planning and administration (e.g., salary, tax withholding, insurance);
  • Conduct performance reviews and evaluations, as well as make decisions about promotions and job mobility;
  • Manage business travel (e.g., car service/rentals, flights, hotels) and personnel expenses (e.g., reimbursement, corporate credit card).
  • Operate our business, including marketing our personnel to customers, facilitating the work of our personnel and providing the products and services made available to our customers;
  • Investigate, document and report work-related injuries, illness or grievances;
  • Conduct internal investigations, audits, compliance, risk management, problem resolution and security operations;
  • Fulfill contractual obligations to you and other third parties;
  • Comply with applicable law, rule, regulation, legal proceeding and government investigations, including relating to tax reporting and immigration.

Related Persons

Collection of Personal Information

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

  • Contact Information: such as your full name, email address, home address, business address, telephone number and emergency contact information.
  • Identification Materials: such as your image, social security number or other national identification number, passport number, driver’s license number or vehicle license plate number.
  • Benefits and Services Information: We also collect personal information necessary to extend the benefits and services that may be available to you as a family member or related person of our personnel, including insurance-related information, claims-related information, and disbursement-related information.

Although we often collect the personal information described above directly from you, we also collect this information from the personnel related to you, as well as 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.

Use of Personal Information

We use the personal information we collect about related persons to:

  • Communicate with you about benefits and services you are eligible for, events or activities our personnel invite you to, or in the event of an emergency;
  • Administer the benefits and services you are eligible for;
  • Respond to requests and inquiries you may send to us;
  • Conduct internal investigations, audits, compliance, risk management, problem resolution and security operations;
  • Conduct internal investigations, audits, compliance, risk management, problem resolution and security operations;
  • Fulfill contractual obligations to you and other third parties;
  • Comply with applicable law, rule, regulation, legal proceeding and government investigations, including relating to tax reporting and immigration.

Our Disclosure of Personal Information

We may share your personal information with the following third parties for the purposes described below:

  • Within WSI: We share personal information relating to personnel and related persons within our family of companies for internal administrative purposes and uses that are consistent with this Privacy Notice. For example, the WSI entity responsible for payroll may receive personal information about personnel employed by another WSI entity in order to determine the proper compensation to be provided.
  • Benefit Administrators: In order to provide our personnel and related persons benefits and services available to them, we share personal information with the third parties we engage to offer and administer the benefits and services on our behalf. These third parties may also collect additional personal information from you in connection with these benefits and services, which will be subject to the relevant third party’s own privacy policies and notices.
  • Payroll and Tax Providers: We share personal information with third parties who assist us in processing our payroll and other compensation-related obligations, including our tax withholding and reporting obligations.
  • Other Service Providers: In addition to the third parties identified above, we engage other third parties to perform certain functions on our behalf in connection with the uses of personal information described in the Our Collection and Use of Personal Information section above, including assisting us with our personnel management, benefits and services offerings and other related business operations. Depending on the function the third party serves, the service provider may process personal information on our behalf or have access to personal information while performing functions on our behalf.
  • Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
  • Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws and regulations or to respond to lawful requests and legal process;
  • to protect our rights and property and the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use;
  • to detect, suppress, or prevent fraud;
  • to reduce credit risk and collect debts owed to us;
  • to protect the health and safety of us, our customers, or any person; or
  • as otherwise required by applicable law.
  • Consent: We may disclose personal information about you to certain other third parties with your consent.

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to Legal@wsgc.com.