This Policy Adopted By:
Iron Mountain UK Limited of Third Floor, Cottons Centre, Tooley Street, London SE1 2TT Registered in England with Company Number: 1478540 (“Iron Mountain”, “we” or “us”) and our participating subsidiaries, holding companies and joint venture partners which are part of the Iron Mountain service system, and other entities which directly or indirectly are controlled by Iron Mountain UK Limited (each an “Affiliate”).
The information we collect.
Iron Mountain collects two types of information about users of this Site; “Personal Information” (including, but not limited to, your name, address, telephone number and email address) and non-personally identifiable and anonymous “Aggregate Information” (such as information about how many users log onto our Site). Unless you provide it to us voluntarily or the information is collected via cookies in the manner described in this policy, Iron Mountain does not collect Personal Information in connection with your use of this Site.
Please read this policy carefully to learn how you can verify the accuracy of any Personal Information we have concerning you and how you can request that Iron Mountain delete or update your Personal Information. You can also change your contact or marketing preferences at any time by contacting us as set out in this policy.
How we use the information we collect.
We will use the information you supply (a) to answer your specific inquiry; (b) at your option, to send you additional materials relating to Iron Mountain; (c) in the administration of the Site; and (d) as otherwise described in this policy.
In order to provide you with a better service, we would like to use your Personal Information to send you information about products and services which we think may be of interest to you.
We may send you mailings by post or call you unless you have told us that you do not want to be contacted in this way.
We will only send you emails, SMS’ and faxes where you have given us your prior express consent to receive such communications.
If you opted to receive any communications from us and any of our Affiliates at the time you registered on this Site, but subsequently change your mind, you may opt out by sending an e-mail to www.ironmountain.co.uk/optout or by writing to us at the address below.
General - When you visit this Site, information about your browser type, operating system, IP address, and the domain name from which you access this Site (e.g., yahoo.com) is collected. In addition, we may collect information about your browsing behaviour, such as the number of times you have visited the Site, the date you visited the Site, and the amount of time you spent viewing the Site. In addition, we may track your response to our advertisements, emails and Site content, determine your ability to receive HTML-based e-mail messages, learn how many users open an email and allow our service providers to compile aggregated statistics about an e-mail campaign for us. This information is used solely for our internal purposes in managing the site and improving its functionality, as well as to assist us in better targeting interactive advertising, thereby enhancing customer support and site usability. Transparent GIF Files - In addition to our own cookies, we use pixels, or transparent GIF files, on our Site to help manage our online advertising and email marketing. These GIF files are provided by one or more third-party service providers, based on our specification as to where they are used. The files enable our service providers to recognize a unique cookie in your web browser, which, in turn, enables us and our service providers to learn which advertisements and emails bring you to our Site and how you use the Site.
Examples of the ways in which we and our third-party service providers use GIF files include:
- Tracking customer response to our advertisements, emails and Site content.
- Determining your ability to receive HTML-based email messages. This capability helps us or our service providers send you email in a format you can read.
- Knowing how many users open an email, thereby enabling our service providers to compile aggregate statistics about an email campaign for us.
- Allowing us to better target interactive advertising; enhancing customer support and site usability; and providing offers and promotions that we believe would be of interest to you, if you have given us permission to do so by opting-in to receive them.
To conduct these or other activities, we or our service providers sometimes may link Personal Information you previously provided us (such as, for example, your name and email address) to the information the GIF files provide about how you arrive at, navigate through and leave our Site.
The information we disclose.
We will at all time comply with the Data Protection Act 1998. We and our service providers (as defined below) disclose and share your Personal Information:
- Among Iron Mountain and our Affiliates;
- To unaffiliated third party service providers that are under contract to perform services for or on behalf of us (“Service Providers”) and such Service Providers are required to uphold and maintain policies with respect to privacy and the treatment of your Personal Information (e.g., vendors hosting the investor relations, courier companies for delivery of products, COMAC, Iron Mountain Digital Services, or Iron Mountain Intellectual Property Management aspects of this Site or other vendors providing services in connection with our Site and services and goods);
- For credit card payments we employ WorldPay to process these payments on our behalf. WorldPay will only have access to the Personal Information which you provide directly to them when you make a credit card payment. They are required under their contract with us to process this Personal Information securely and in accordance with all relevant Data Protection laws. We will not collect or store any credit card details. When you pay for any goods, you will be taken to a link to WorldPay’s website in order to conclude the sale. The data you provide to WorldPay will be processed in accordance with the terms and conditions on its website.
- To a third party in connection with a proposed or actual sale, merger, or transfer of all or a portion of a business or division; and
- To other persons as permitted or required by applicable law or regulation.
Any access to such information will be limited to the purpose for which such information was provided to us or our Service Providers. Iron Mountain’s Affiliates and Service Providers are located throughout the world. Accordingly, your Personal Information may be sent to countries which have a different level of privacy protection than England or your country of residence. For instance, if you inquire about services we provide in France and in Brazil, we will forward your inquiry to our office in such countries. We will, at your request, provide you with details of companies and countries to which your information has been sent.
Links and third-party websites.
This policy applies only to this Site. This Site includes links to both our affiliated web sites and to non-affiliated web sites, including access to content, products and services of such affiliated and non-affiliated sites. In some cases, these other sites are made available via “seamless experience” technology, and may appear to be part of our Site. Although some of the entities controlling these sites are under contract with us, not all of them are, we advise you to familiarise yourself with the individual privacy and other terms for each linked web site prior to submitting your personally identifiable information as we are not responsible for the policies or do we accept any liability in respect of the content of such web sites.
We may use third party advertisements on our Site. Cookies may be associated with these advertisements to enable the advertiser to track the number of anonymous users responding to the campaign. We do not have access to or control of cookies placed by third parties.
How to opt out or request changes.
You are entitled to request that we:
- provide you with a copy of your Personal Information that we hold;
- cease processing your Personal Information, in whole or in part, as you direct us, for the purposes of direct marketing;
- change the manner in which we contact you for marketing purposes;
- correct any errors in that Personal Information; and
- update that Personal Information as required.
If you would like to receive a copy of the Personal Information we have about you as submitted to us via this Site, or if you wish to opt out of receiving marketing related communications from us, please send a request to firstname.lastname@example.org.
If any of your Personal Information is incorrect or incomplete, please let us know, and we will make every reasonable effort to correct or update it promptly (unless we require further information from you in order to fulfil your request). You may also ask us to remove your name and other Personal Information from our databases. In each of the foregoing cases, we will make all reasonable efforts to honour your request promptly, subject to legal and other permissible considerations.
If you have submitted an inquiry to us and you do not receive acknowledgement of your inquiry from the email@example.com or our response to your inquiry is not satisfactory, you should first contact Iron Mountain’s Director of Privacy at firstname.lastname@example.org or write to the Director of Privacy at Third Floor, Cottons Centre, Tooley Street, London SE1 2TT.
Notification of changes.
We recommend that you check this policy every time you visit our Site as we may update this policy from time to time, by posting the amended policy on this Site. Any changes will be effective when posting and your continued use of the Site will indicate your acceptance of any changes.
How we protect and store your information.
We take the security of the information we collect seriously. We have implemented technology and security policies and procedures intended to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the data concerned.
Personal Information collected via this Site is stored on servers in the UK and USA. You should be aware that your Personal Information once collected will be transferred to our servers, and the USA currently does not have uniform data protection laws, however we certify our compliance with the Safe Harbour framework designed to satisfy the “adequacy” requirements under the European Directive on Data Protection.
We are concerned about the safety of children when they use the internet, and will never knowingly collect Personal Information from minors (children under 13 years of age, or any other age defined under applicable law). If we become aware that a minor is attempting to or has submitted Personal Information via this Site, we will notify the user that we may not accept his or her Personal Information. We will then remove any such Personal Information from our records.
Questions regarding this policy.
If you have questions concerning this Policy, or your Personal Information, please contact us at email@example.com or write to the Director of Privacy, Third Floor, Cottons Centre, Tooley Street, London SE1 2TT
Iron Mountain’s Privacy Principles
Iron Mountain commits to the following:
- Iron Mountain only collects information that is needed. From its valued customers, Iron Mountain collects information that will enable it to administer customer accounts, to provide marketing information about Iron Mountain’s services and products, to provide “white papers” containing articles that may be useful to customers, to obtain information that may be helpful to Iron Mountain in administering and enhancing its Site, and to fulfil any regulatory or legal requirement. Iron Mountain keeps its customers informed as to what information it is collecting and how that information will be used.
From its valued employees, Iron Mountain collects information that will enable it to manage employee benefits and related benefit plan administration, for human resources management purposes and staff training and for immigration purposes, as well as to fulfil any regulatory or legal requirement.
- Customers must “opt in” prior to Iron Mountain using Customer information online. You have the option of determining whether to supply Iron Mountain with information that it may use for purposes of sending you information, whether it is sent through online marketing efforts, by telephone, by fax, by email or by mail. At any time, you may “opt out”, and Iron Mountain will use its best efforts to promptly cease processing the Personal Information you previously supplied. In connection with the offline activities of Iron Mountain, you may simply notify Iron Mountain that you wish to cease receiving additional information from Iron Mountain (“opt out”), and Iron Mountain will use its best efforts to promptly honour any such request.
- Iron Mountain uses security procedures and safeguards that it considers appropriate for the level of Personal Information our customers or employees are providing to Iron Mountain. Iron Mountain’s goal is to prevent unauthorized access, maintain data accuracy, ensure the appropriate use of information and use professional industry standards to protect against the loss, misuse or alteration of information under Iron Mountain’s control in connection with its information management services.
- Release of Information. In addition to using customer or employee information to fulfil requests received from its respective customers or employees, Iron Mountain discloses information provided to it when required to do so by law or by a regulatory agency. In addition, Iron Mountain may share, as appropriate, with its Affiliates, with unaffiliated third parties that are under contract to perform services for or on behalf of Iron Mountain (who are required to uphold and maintain policies with respect to privacy and the treatment of your Person Information) and/or to a third party in connection with a proposed or actual sale, merger or transfer of all or a portion of a business or division.
- Iron Mountain’s expectations for its Service Providers. Iron Mountain expects its Service Providers, who may have access to Personal Information furnished to us by our customers or employees for purposes of providing services to Iron Mountain, to honour the privacy principles set forth herein, whether such Service Providers are accessing customer or employee information and considers a Service Provider’s commitment to privacy and security as part of its decision-making process as to which Service Providers it selects as its business partners.