California Privacy Notice
Effective Date: January 1, 2023
WillScot is committed to protecting the privacy and security of your Personal Information. This Notice describes how WillScot collects, uses and retains your Personal Information, the instances where WillScot may disclose your Personal Information to third parties, and your privacy rights and choices under California law. “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Please be advised that “Personal Information” does not include information which is publicly available, anonymized or aggregated, as well as other information which is excluded from the CCPA/CPRA’s scope (e.g., information covered by other privacy laws such as the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act or California Financial Information Privacy Act, and the Driver’s Privacy Protection Act).
This Notice does not apply to Personal Information that we collect when: you are acting as a job applicant to or employee or independent contractor of WillScot; you have been designated as an emergency contact for a job applicant or employee and your information has been collected for use solely within that context; we need your Personal Information to administer benefits obtained through an employee.
We reserve the right to amend this Notice at our discretion, at any time and without sending notice to you. When we make changes to this Notice, we will post the updated Notice on this web page and update the effective date. This Notice is not a contract and does not create any contractual rights or obligations.
Collection and Retention of Personal Information
Through our website and products and services, we collect and process certain categories of Personal Information about you. As permitted by law, we collect, and within the last twelve (12) months have collected, the following categories of Personal Information:
- Identifiers, such as name, postal or email address, phone number, Internet Protocol (IP) address, and account number.
- Information described under the California Customer Records statute (California Civil Code § 1798.80(e)) such as contact information, financial information, insurance information and signature.
- 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 device location and IP location.
- Audio, electronic or similar sensory data, such as call recordings.
- Professional or employment-related information, such as job title and position and employer information.
- Inferences drawn from other Personal Information.
- Sensitive Personal Information, limited to the government identifiers such as tax identification number and in some instances social security number.
We do not collect biometric information, non-public education information, or the following categories of Sensitive Personal Information: complete account access credentials; precise geolocation data; racial or ethnic origin; religious or philosophical beliefs; union memberships; genetic data; mail, email or text message content not directed to us; unique identifying biometric information; or health, sex life or sexual orientation information.
We generally keep all categories of Personal Information and Sensitive Personal Information described above for as long as needed or permitted considering the purpose(s) for which the Personal Information or Sensitive Personal Information was obtained, such as to provide services or products to you, complete our transaction with you, to enable us to communicate with you about our products and services, for our research, evaluation of use, or troubleshooting purposes, for our analysis to improve quality of our products and services, or to satisfy our legal, regulatory, insurance or contractual obligations. We maintain Personal Information and Sensitive Personal Information in accordance with our record retention policies which are informed by business needs and our legal and contractual obligations. The criteria that we use to determine our retention periods include: (1) for as long as we have an ongoing relationship with you; (2) as required by a legal obligation to which we are subject to; or (3) as advisable in light of our legal position (such as in regard of applicable statutes of limitations, litigation, or regulatory investigations). If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
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.
Sources of Personal 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.
Purposes for Collection and Processing Personal Information
We may collect, use or disclose the above categories of Personal Information and Sensitive 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.
- As described to you when collecting your Personal Information or subsequently agreed to by you, and as otherwise permitted under the CCPA/CPRA.
We will not collect additional categories of Personal Information or Sensitive Personal Information or use the Personal Information or Sensitive Personal Information we collected for materially different, unrelated or incompatible purposes without providing you notice. We only use Sensitive Personal Information collected (e.g., government identifiers) for purposes expressly permitted under the CPRA.
Disclosure of Personal Information
WillScot does not sell, trade or rent your Personal Information to unaffiliated third parties, such as sellers of goods or services, for their own business or commercial purposes. WillScot will only disclose or share your Personal Information to our affiliates and certain trusted parties—specifically:
- Affiliates (including Mobile Mini Inc.) and subsidiaries, when permissible under relevant laws and regulations, for various purposes, such as to improve our existing suite of products and services across all our related brands and businesses;
- 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;
- Governmental authorities or other entities as required by law or regulation.
- 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.
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.
In the last twelve months, we have disclosed the following categories of Personal Information to our affiliates and/or service providers for the business purposes described above: (1) identifiers; (2) information described in California Civil Code § 1798.80(e); (3) commercial information; (4) internet or other similar network activity; (5) sensory data (e.g., call recordings); (6) inferences drawn from other Personal Information; and (7) Sensitive Personal Information limited to government identifiers. (We do not disclose Sensitive Personal Information for purposes other than what the CPRA specifically permits.)
We also may share certain categories of Personal Information, excluding Sensitive Personal Information, with third parties such as marketing/advertising platforms for cross-context behavioral advertising purposes, to improve the quality of your website experience, evaluate performance of our marketing/advertisements, facilitate engagement with you and display relevant information to you. In the last twelve months, we have shared the following categories of Personal Information for these purposes: (1) identifiers (e.g., your name, contact information and IP address); (2) internet or other similar network activity; and (3) commercial information.
Your Privacy and Rights Choices
If you are a California resident, you have the following rights and choices:
1. Right to Know. You have the right to request that we disclose to you the following information covering the 12 months preceding your request:a. the categories of Personal Information and Sensitive Personal Information that we have collected about you;
b. the categories of sources from which the Personal Information or Sensitive Personal Information was collected;
c. the purpose for collecting your Personal Information and Sensitive Personal Information;
d. the categories of third parties to whom we disclosed your Personal Information and Sensitive Personal Information, the categories of Personal Information and Sensitive Personal Information that we disclosed (if applicable) and the purpose for disclosing your Personal Information and Sensitive Personal Information; and
e. the specific pieces of Personal Information and Sensitive Personal Information we collected about you (also referred to as a “data portability” request); and
f. if we shared/disclosed your Personal Information or Sensitive Personal Information for a business purpose, a list identifying the personal information categories that each category of recipient obtained.
2. Right to Delete. You have the right to request that we delete Personal Information we collected about you (note that any deletion request may be rejected or limited by WillScot’s rights and legal obligations under the CCPA, CPRA and/or other applicable federal and/or state law).
3. Right to Correct. You have the right to request that we correct any inaccuracies in the Personal Information we collected about you.
4. Restrict Use or Disclosure/Sharing of Personal Information for Advertising & Marketing. We may use, or disclose/share to our service providers and marketing providers, Personal Information about you for our own advertising and marketing purposes. You have the right, at any time, to request that we not use or disclose/share your Personal Information for advertising and marketing purposes. Once we receive and verify your request, we will no longer use or share your Personal Information for advertising or marketing purposes. We also will recognize browser-based opt-out signals as provided under law. If we receive an opt-out signal and are able to identify the consumer to whom the signal relates, we will treat the signal as a request to opt out related to all Personal Information we have on file for the consumer. If we receive an opt-out signal and are not able to identify the consumer to whom the signal relates, we will treat the signal as a request to opt out limited to the Personal Information we collect from the consumer during the online session during which the signal is present.
To exercise the rights described above, please submit a verifiable consumer request to us either by:
- Calling toll-free at 1-888-995-0672
- 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 verifiable request related to your Personal Information. You may also make a verifiable 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 verifiable 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.
We will not discriminate against you for exercising any of your rights under California law. Unless permitted by applicable law, we will not deny you goods or services, charge you different rates for goods or services, provide you with a different level or quality of goods or services, or suggest that you may receive a different rate for goods or services or a different level or quality of goods or services. However, we may offer you certain financial incentives permitted under California law that can result in different prices, rates, or quality levels. Any legally-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
If you have any questions or concerns about this Notice or need to access this Notice in an alternative format due to having a disability, please contact us at:
Williams Scotsman, Inc.
901 S. Bond Street Suite 600
Baltimore, MD 21231