California Privacy Notice
Effective Date: January 1, 2020
Your privacy is important to Williams Scotsman, Inc. and its subsidiaries (“WillScot,” “we” or “us”). This California Privacy Notice explains how WillScot collects, shares, uses and protects personal information relating to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”) over the past twelve (12) months. Any terms defined in the CCPA have the same meaning when used in this Notice.
This California Privacy Notice supplements WillScot’s general and online privacy policies. We may provide supplemental or updated privacy notices on specific occasions when we are collecting or processing your personal information. Such supplemental privacy notices should be read together with this California Privacy Notice. When we make material changes to this Notice, we will post the updated Notice on our web page and update the effective date.
Under the CCPA, “personal information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal information” does not include information which is publicly available, anonymized or aggregated, as well as other information which is excluded from the CCPA’s scope (e.g., information covered by other privacy laws such as the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, or the California Financial Information Privacy Act and Driver’s Privacy Protection Act). The specific personal information we collect, use and share relating to a California resident covered by the CCPA will vary based on our relationship or interaction with that individual. We do not knowingly collect personal information from children under age sixteen (16).
Keeping personal information secure is of the utmost importance to us. Consistent with our obligations under applicable laws and regulations, we maintain physical, technical, electronic, procedural and organizational safeguards and security measures that are designed to protect personal data against accidental, unlawful or unauthorized destruction, loss, alteration, disclosure or access, whether it is processed by us or elsewhere.
Collection of Information
In the past twelve (12) months, we have collected the following categories of personal information relating to California residents:
- Identifiers, such as name, postal or electronic address, account number, and government-issued identifiers (e.g., taxpayer identification number);
- Personal information as defined under the California Customer Records statute (California Civil Code § 1798.80(e)) such as contact information, financial information and insurance information;
- Characteristics of protected classifications under California or federal law, such as age and gender;
- Commercial information, such as transaction information and purchase history;
- Internet or network activity information, such as browsing history and interactions with our website;
- Geolocation data, such as leased equipment location, device location and Internet Protocol (IP) location;
- Audio, electronic or similar information, such as call recordings;
- Professional or employment-related information, such as job title and position and employer information;
We also may associate the information listed above with other information we obtain.
Sources of Information
- From third parties that interact with us in connection with the services we perform, e.g., from third-party applications when we evaluate creditworthiness in connection with rendering credit decisions;
- From marketing partners and commercially available third-party sources, such as lead generation companies and credit reporting agencies; and
- From publicly available databases, e.g., from the Secretary of State when we verify the legal status of an entity that has engaged us for services.
Use of Information
We may use or share personal information to operate, manage and maintain our business, to provide our products and services and to accomplish our business and commercial purposes and objectives, including the following:
- To fulfill or meet the reason you provided the information;
- To perform services, including maintaining or servicing accounts, generating quotes and invoices, processing or fulfilling orders and transactions, verifying customer information, processing payments, extending credit, advertising and marketing our services, collecting payments owed to us or repossessing leased equipment;
- To provide, support, personalize and develop our website, products and services;
- To detect security incidents and to prevent fraud in connection with performance of our services or processing requests, transactions and payments;
- To perform auditing functions, including performing advertising analytics, and legal and regulatory compliance;
- To debug, including to identify and repair technical errors that impair intended functionalities;
- To provide customer support and to respond to inquiries, including to investigate and address customer concerns and monitor and improve our responses and services;
- To perform testing, research, analysis, and service development, including to develop and improve our website and services;
- To perform security functions, including detecting security breaches, protecting against fraud and malicious activities, and taking action against wrongdoers;
- To protect the rights, property or safety of us, our clients or others, as necessary or appropriate;
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of WillScot assets, whether as a going concern or as part of bankruptcy, liquidation, or similar processing;
- To respond to governmental authorities, including law enforcement requests, and as required by applicable law, court order, or regulations; and
- As described to you when collecting your personal information or subsequently agreed to by you, and as otherwise permitted under the CCPA.
Sharing of Information
We may share your personal information with our affiliates and certain trusted third parties. For example, we may share your information with:
- Affiliates and subsidiaries in an effort to bring improved products and services across our family of products and services, when permissible under relevant laws and regulations;
- Service providers and vendors to perform functions and provide services, such as website and database hosting and maintenance, data analytics, payment processing, order fulfillment, debt collection and property repossession, and other activities relating to customer relationships, call monitoring, email delivery and related communication infrastructure, marketing and marketing research, error monitoring, debugging, and information technology and related infrastructure;
- Other third parties to whom you or your authorized agent authorize us to share personal information in connection with products or services provided by us; and
- Governmental authorities or other entities as required by law or regulation.
We share personal information to the extent necessary to perform these functions and provide these services, and we require these third parties to maintain the privacy and security of the personal information they access and process on our behalf. We do not sell or rent your personal information to unaffiliated third parties, such as sellers of goods or services, for their own business or commercial purposes. We may share anonymous or aggregated information with third parties to help deliver products, services and content and for other purposes.
Rights Under the CCPA
If you are a California resident, you have the right to:
- Request that we disclose to you the following information covering the 12 months preceding your request:
- the categories of personal information that we have collected about you;
- the categories of sources from which the personal information was collected;
- the purpose for collecting your personal information;
- the categories of third parties to whom we disclosed your personal information, the categories of personal information that we disclosed (if applicable) and the purpose for disclosing your personal information; and
- the specific pieces of personal information we collected about you (also referred to as a “data portability” request);
- Request that we delete personal information we collected from you, unless the CCPA recognizes an exception; and
- Be free from unlawful discrimination for exercising your rights under the CCPA.
How to Exercise Rights
If you are a California resident, you may submit a request by:
- Calling toll-free at 1-866-713-7492
- Submitting an online request via email to CaliforniaPrivacy@willscot.com
Only you, or a person legally authorized to act on your behalf, may make a request related to your personal information. You may also make a request on behalf of your minor child. You may only make a request for access or data portability twice within a 12-month period.
Your request must (1) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, and (2) describe your request with sufficient detail that allows us to properly understand, evaluate and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identify or authority to make the request and confirm the requested personal information relates to you. Making a request does not require you to create an account with us. We will only use personal information provided in a request to verify the requester’s identity or authority to make the request.
Any disclosures we provide will only cover the 12-month period preceding our receipt of the request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you have any questions or concerns about this Notice, the ways in which WillScot collects and uses your information described above, or your choices and rights regarding such use, please do not hesitate to contact us at:
Samantha Bishop Esq.
Deputy General Counsel
Williams Scotsman, Inc.
901 S. Bond Street
Baltimore, MD 21231