Notice at Collection and Privacy Policy
Effective: December 1, 2025
Revised: January 12, 2026
Last Reviewed: January 8, 2026
Anderson Merchandisers, LLC and its subsidiaries and affiliated companies (“Company”) takes your privacy seriously. We want you to know how we collect, use, and disclose your personal information. Anderson functions as a data controller as defined in AICPA Trust Services appendix A – the organization determines the purposes for and how personal data is processed. The Company stores your personal information on a protected server and allows access to personal information only to those individuals that have a legitimate business purpose for accessing such information and only to the extent required to achieve that legitimate business purpose.
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This Privacy Policy explains:
1. The categories of personal information we collect about you
2. The categories of sources from which we collect your personal information
3. The purposes for which we use your personal information
4. How we may disclose your personal information
5. How long we keep your personal information
6. Privacy rights for HR Individuals who are California residents
7. Changes to this Privacy Policy
Scope:
This Privacy Policy applies to the personal information of individuals who are (a) employees, (b) independent contractors, interns, volunteers, owners, board members, and other individuals who perform work for Company (collectively “Non-Employees”), and (c) employees’ and Non-Employees’ dependents, emergency contacts, and beneficiaries (“Related Contacts”), (all collectively, “HR Individuals”) in their role as HR Individuals. This Privacy Policy informs HR Individuals about the categories of personal information Company has collected about them in the preceding twelve months as well as the categories of personal information that the Company will collect about HR individuals in the future.
Except where the Privacy Policy specifically refers only to a specific category of HR Individuals, e.g., employees, this Privacy Policy refers to all categories of HR 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 a particular HR Individual or household.
1. THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT
A. Employees
The following categories of information will be collected for all employees and candidates, as required in order to complete the employment screening and onboarding processes*, as well as to monitor employment.
• Identifiers, for example: real name, alias, telephone number, postal address, e-mail address, signature, bank account name and number for direct deposits, Social Security number for example for tax purposes, driver’s license number, 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 Company’s network, log in/out and activity on Company's electronic resources, interactions with Company’s Internet web site, application, or advertisement, and publicly available social media activity.
• Sensory or Surveillance Data, for example: voice-mails, recordings of meetings or video-conferences, and footage from video surveillance cameras.
• § 1798.80 Information: personal information described under Cal. Civ. Code § 1798.80 to the extent not already included in other categories here, such as benefit information to administer short- and long-term disability benefits as well as other benefit plans or health information in a health emergency.
• Geolocation data, for example: GPS tracking on location of employee, store activity, and vehicle location.
*Candidates are entitled to withhold consent to providing the aforementioned categories of information. However, Candidates withholding consent to provide information necessary to complete employment screening, and the onboarding process may be considered no longer eligible for employment. Any questions regarding the information necessary for these processes and/or requests to withhold certain information may be directed to
The following categories of personal information may be collected from employees and/or candidates for employment, as necessary. If employees or employment candidates wish not to provide the following categories of personal information, or to keep such personal information strictly confidential, the employee or candidate must expressly inform the Company that the individual is opting out of providing such information to the Company, by contacting
• Preferences, for example, hobbies and leisure activities, membership in voluntary/charitable/public organizations, and preferences regarding work tools, travel, hours, food for company events, etc.
• Characteristics of Protected Classifications Under California 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 California law related to leaves of absence and accommodation; and marital and familial status as necessary to provide benefits to employees and for tax purposes.
B. Non-Employees
Company collects 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 California or federal law for employees; (c) health information, (d) sex life, and (e) sexual orientation.
In addition, Company collects the following personal information regarding Non-Employees:
• Compensation: Amounts paid to Non-Employees for services rendered.
C. Related Contacts
• Company only collects contact information about emergency contacts.
• Company may collect the following categories of personal information about spouses or domestic partners, dependents, and beneficiaries: (a) Identifiers; (b) Commercial Information if, for example, Company arranges travel for a dependent to attend a Company event; (c) Internet Activity Information if the individual uses Company electronic resources and web sites; (d) Sensory or Surveillance Data if the individual enters Company facilities;
(e) § 1798.80 personal information, such as insurance policy numbers if the individual is covered by Company insurance or health information, for example, infectious disease testing when a Related Contact attends a Company event; and (f) Protected Categories of Personal Information, for example, childbirth to administer parental leave, marital status to pay taxes, and familial status to administer benefits.
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.
• Vendors and service providers, for example, 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 Company’s electronic resources, for example, to track logins and activity across Company network.
• Surveillance/recording technologies installed by Company, for example, video surveillance in common areas of Company facilities, global positioning system (“GPS”) technologies, voicemail technologies, webcams, audio recording technologies, and blue-tooth technologies, any of these with consent to the extent required by law.
• Labor processes, for example, HR and arbitration processes.
• Government or administrative agencies, for example, law enforcement, public health authorities, California Department of Industrial Relations, Employment Development Department.
• Acquired company, if Company acquired your employer, Company 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. Company provides separate notices for such screening.
3. THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION
A. All HR Individuals Managing Personnel, including:
(Not applicable to Related Contacts)
• Administration, including:
o To manage personnel and workforce matters
o To communicate with the workforce
o To plan and arrange work supplies and workspaces
o To fulfill recordkeeping and reporting responsibilities
o For recruitment of new HR Individuals
o To resolve internal grievances and disciplinary issues
o To make business travel arrangements
o To manage workforce-related emergencies, including health emergencies
• Workforce development, including:
o To screen workforce for risks to Company and continued suitability in their positions
o To conduct surveys
• Team-building, including:
o To maintain an internal workforce directory and for purposes of identification
o To facilitate communication, interaction, and collaboration among HR Individuals
o To arrange meetings and manage Company-sponsored events and public service activities
o To promote Company as a place to work
o Workforce reporting and data analytics/trend analysis
o For workforce satisfaction
Monitoring, Security, and Compliance, including:
• To monitor access to, and use of, Company facilities and information systems
• To ensure compliance with applicable laws and Company policies
• To conduct internal audits and investigations
• To administer Company’s whistleblower hotline
• To protect the safety and security of Company’s facilities, including preventing illicit activity
• To report suspected criminal conduct to law enforcement and cooperate in investigations
• To exercise Company’s 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
Conducting Our Business, including:
(Not applicable to Related Contacts)
• 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 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
• To engage in crisis management
Miscellaneous Other Purposes:
• 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 Company, 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 Company or any of its subsidiaries or affiliates;
• To manage licenses, permits, and authorizations applicable to Company’s business operations; and
• To protect the rights, property, or safety of Company, HR Individuals, customers or others.
B. Employees
1. Generally Applicable Purposes
Unless stated otherwise in section 3.B.2, below, we may use employees’ personal information for the following purposes:
Managing Employees, including:
• Administration, including:
o To set up and manage a personnel file
o To manage performance
o To administer compensation, bonuses, other forms of compensation, and benefits (as permitted by law)
o To manage vacation, sick leave, and other leaves of absence
o To track hours and attendance
• Employee development, including:
o To provide, evaluate, and manage training and career development
o To evaluate job performance and consider employees for other internal positions or promotions
o To assist with professional licensing
o To develop a talent pool and plan for succession
• Team-building, including:
o For diversity and inclusion programs
o To arrange team-building and other morale-related activities
o 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 3.B.2 for the purposes stated below:
Purposes For Using Employees’ Geolocation Data:
• Field personnel may be required to provide geolocation data in order to access work sites. Certain corporate employees may be issued cards which collect geolocation data related to the corporate office.
• Company requires field associates to download a location tracking application (“app”) to allow Company and customers to see these employees’ location only during working time.
Purposes For Using Employees’ Health Information:
• To the extent necessary to comply with Company’s 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 California’s Confidentiality of Medical Information Act (CMIA) because these laws have their own disclosure requirements. Any
information covered under such laws will be and are governed by such statutes or regulations.
Purposes For Using Employees’ Protected Categories of Information:
Company collects information about race, age, national origin, disability, sex, and veteran status as necessary to comply with legal obligations, including the reporting requirements of the federal Equal Employment Opportunity Act, the federal Office of Contracting Compliance Programs (applicable to government contractors), and state laws, where applicable, such as the California’s Fair Employment and Housing Act. Company also collects information about disability status to the extent an employee may need special assistance during emergencies from Company or from first responders.
Company may also collect the following characteristics (in addition to those listed above) for its diversity, inclusion, and accommodation programs and process (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.
Company also uses this personal information for purposes including:
• with respect to disability, medical condition, familial status, marital status, and pregnancy, childbirth, breastfeeding, and related medical conditions: as necessary to comply with Federal and California law related to leaves of absence and accommodation;
• with respect to military and veteran status: as necessary to comply with leave requirements under applicable law and for tax purposes;
• with respect to age: 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: as necessary for accommodations under applicable law;
• with respect to protected classifications, such as national origin: to the extent this information is contained in documents that you provide in I-9 documentation; and
• with respect to marital status and familial status: for Company events and as necessary to provide benefits and for tax purposes.
Company collects personal information about membership in protected categories on a purely voluntary basis, except where required by law, and uses the information only in compliance with applicable laws and regulations.
If you object to the Company using any or all of your “protected categories” of personal information for the purposes listed above, please contact
C. Board Members
• To administer the relationship
• To administer compensation, bonuses, equity grants, other forms of compensation, and benefits (as permitted by law).
D. Related Contacts
Spouse and Dependents/Beneficiaries
• To manage and administer benefits
• To communicate with the individual and manage the relationship
• To arrange travel to, and manage participation in, Company events
Emergency Contacts
• To communicate in the event of an emergency involving the individual who provided the emergency contact’s information.
4. HOW WE MAY DISCLOSE YOUR PERSONAL INFORMATION
Company generally maintains information related to its personnel as confidential. However, from time to time, Company may have a legitimate business need to disclose personnel 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, Company discloses your personal information only to the minimum extent necessary to achieve the purpose of the disclosure and only if the disclosure is permitted by the CPRA and other applicable laws.
• Your direction: We may disclose your personal information to third parties at your direction.
• Service providers and contractors: Company discloses your personal information to service providers and contractors to assist us in meeting our business needs and contractual and legal obligations.
o Company discloses your personal information to service providers and contractors only subject to written contracts in compliance with the CPRA and any other applicable law.
o Service providers and contractors include auditors, administrative service providers, law firms, travel agencies, benefits providers, and any other entity providing services to Company.
• Affiliated companies: Other companies within the Anderson Merchandisers family of companies.
• Clients and customers: This may include, for example, disclosing a field representative’s contact information to our clients. .
• Business partners: For example, Company might disclose your business contact information to a co-developer of a new product or service with which you will be working.
• Government or administrative agencies: These may include, for example:
o Internal Revenue Service to pay taxes;
o State unemployment insurance departments as required for state payroll taxes and to respond to unemployment or state disability insurance claims;
o OSHA as required to report work-related death or serious injury or illness;
o Department of Fair Employment and Housing as required to respond to employment charges; and
o California Department of Industrial Relations as required to resolve workers’ compensation claims.
• Public: Company 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
• Required Disclosures: We may be required to disclose personal information (a) in a court proceeding, (b) in response to a court order, subpoena, civil discovery request, other legal process, or (c) as otherwise required by law.
• 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 Company, our users, or others.
If, for any reason, Company intends to or is required to disclose your personal information for any reason not listed above, Company will provide you with written notice and, where applicable, an opportunity to approve or decline such disclosure.
5. HOW LONG WE KEEP YOUR PERSONAL INFORMATION
Company keeps your personal information no longer than necessary for the purposes described in Section 3 above and in accordance with our Company data and document retention schedule. Further, personal information may, at times be deidentified in the manner set forth herein below. A copy of the Company’s data and document retention schedule may be obtained by contacting the Company at
6. ADDITIONAL PRIVACY RIGHTS FOR HR INDIVIDUALS
A. Pursuant to the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”), California residents receive certain rights with respect to their personal information, as described below in this Section 6. These rights are not absolute and are subject to certain execptions more fully set forth in the CCPA. California residents have the right to not receive discriminatory treatment from us for the exercise of the privacy rights conferred by the CCPA. While HR individuals who do not reside in California may not be statutorily afforded the following rights, the Company will honor reasonable requests made by non-California HR Individuals in accordance with this Section 6. Your Additional California Privacy Rights
Subject to applicable law, HR Individuals have the following rights:
• Right to Know: You have the right to submit a verifiable request for copies of specific pieces of your personal information obtained from you and for information about the Company’s collection, use, and disclosure of your personal information. Please note that the CPRA’s 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, HR Individuals have a right to know categories of sources of personal information and categories of third parties to which personal information is disclosed, but not the individual sources or third parties. Company does not always track individualized sources or recipients.
• Right to Delete: You have the right to submit a verifiable request for the deletion of personal information that you have provided to Company.
• Right to Correct: You have the right to submit a verifiable request for the correction of inaccurate personal information maintained by Company, taking into account the nature of the personal information and the purposes of processing the personal information. If any of your personal information is corrected, we will share that information with any third parties with whom you have previously directed Company to share your personal information.
• Note on inferring characteristics: Company does not collect or process sensitive personal information or characteristics of protected classifications for the purpose of inferring characteristics about the HR Individual.
No sales and no “sharing”, i.e., disclosure for cross-context behavioral advertising:
Company does not sell the personal information of any HR Individuals nor disclose their personal information for cross- context behavioral advertising.
Note on Deidentified Information
At times, Company converts personal information into deidentified information using reasonable measures to ensure that the deidentified information cannot be associated with the individual (“Deidentified Information”). Company maintains Deidentified Information in a deidentified form and does not attempt to reidentify it, except that Company may attempt to reidentify the information solely for the purpose of determining whether its deidentification processes ensure that the information cannot be associated with the individual. Company prohibits vendors, by contract, from attempting to reidentify Company’s Deidentified Information.
B. How to Exercise Your Rights
Company will respond to requests to know, delete, and correct in accordance with applicable law if it can verify the identity of the individual submitting the request. You can exercise these rights in the following ways:
• Call 855-379-8111
C. Email
The processes that we follow to verify your identity when you make a request to know, correct, or delete are described below. The relevant process depends on how and why the request is submitted.
If you submit a request by any means other than through a password-protected account that you created before the date of your request, the verification process that we follow will depend on the nature of your request as described below:
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 risk level (as determined by Company) associated with the personal information that you ask us to correct or delete. For low-risk personal information, we will require a match of two data points as described in Point No. 1, above. For higher risk personal information, we will require a match of three data points and a signed declaration as described in Point No. 2, above.
We have implemented the following additional procedures when verifying the identity of requestors:
1. 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.
2. 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.
D. Authorized Agents
E. 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) a power of attorney, signed by you, that is valid under California law; or (b) 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. You can obtain “Authorized Agent Designation” form by contacting us at
Company will not unlawfully discriminate or retaliate against you for exercising your rights under the California Privacy Rights Act.
7. CHANGES TO THIS PRIVACY POLICY
If we change this Privacy Policy, the updated policy will be communicated and distributed through Workday and/or uploaded to Company’s website prior to implementation. You must review and acknowledge the policy within 7 calendar days. 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.
Anderson will review this Privacy Policy at least annually.
For More Information
A copy of any previous privacy policies that you received and acknowledged at any time during your employment with Anderson will be accessible on your personal workspace on Workday (or any successor platform). For any further questions or concerns about Company’s privacy policies and practices, please contact us at: