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Iron Mountain Web Site Privacy Notice





IRON MOUNTAIN WEB SITE PRIVACY NOTICE



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YOUR PRIVACY IS IMPORTANT TO IRON MOUNTAIN.

This notice is adopted by: Iron Mountain Incorporated, its participating
subsidiaries (including former Recall entities) 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 (each, an Affiliate, with Iron
Mountain and its Affiliates being collectively referred to as Iron Mountain).

Iron Mountain understands your concerns about the privacy of data you may submit
through this Iron Mountain Web site. This notice provides you information about
what type of information is gathered and tracked on the Web site, how the
information is used, and with whom the information is shared. You may also want
to review Iron Mountain's Privacy Principles which set forth the Company's
commitment to protecting our customers' and employees' privacy, online and
offline. In the event that any inconsistencies should arise with respect to this
notice and the Privacy Principles concerning online privacy, the terms of this
notice shall prevail.


COMPLIANCE WITH EUROPEAN PRIVACY PRINCIPLES

DATA ORIGINATING FROM THE EEA, SWITZERLAND AND THE UK

With respect to personal data that Iron Mountain receives either as a data
controller or data processor from the European Economic Area (EEA), Switzerland
and the United Kingdom (or accesses from the US in the EEA, Switzerland and the
United Kingdom) Iron Mountain uses approved Standard Contractual Clauses.
However, Iron Mountain often processes customer information as data processor,
without knowing the content or origin of such data.

EU-U.S. AND SWISS-U.S. PRIVACY SHIELDS

In addition to using the Standard Contractual Clauses, Iron Mountain
Incorporated and its United States subsidiaries - including former Recall
entities - which include, but are not limited to: Iron Mountain Global, LLC.,
Iron Mountain Information Management, LLC, Iron Mountain Intellectual Property
Management, Inc., Iron Mountain Data Centers, LLC, Iron Mountain Secure
Shredding, Inc., Iron Mountain Information Management Services, Inc., and
Crozier Fine Arts continues to comply with the EU-U.S. Privacy Shield Framework
and the Swiss – U.S. Privacy Shield Framework (“Privacy Shield”) as set forth by
the U.S. Department of Commerce regarding the collection, use, and retention of
personal information transferred from the European Union, the United Kingdom and
Switzerland to the United States, respectively in reliance on the Privacy
Shield. Iron Mountain Incorporated has certified to the Department of Commerce
that it adheres to the Privacy Shield Principles with respect to such
information. If there is any conflict between the terms in this privacy policy
and the Privacy Shield Principles, the Privacy Shield Principles shall govern.
To learn more about the Privacy Shield program, and to view our certification,
please visit https://www.privacyshield.gov/.

SCOPE

All personal data that Iron Mountain receives either as a data controller or
data processor from the EEA and Switzerland (or accesses from the US in the EEA
or Switzerland) will be processed pursuant to the applicable Privacy Shield
Principles. However, Iron Mountain often processes customer information as data
processor, without knowing the content or origin of such data.

For the types of personal data and the purposes for which such data is
transferred and processed, as well as the third parties with which such data may
be shared, please review Iron Mountain’s Privacy Shield certification statement
(https://www.privacyshield.gov/list).

ACCESS, RECOURSE (DISPUTE RESOLUTION), ENFORCEMENT AND LIABILITY

In compliance with the Privacy Shield Principles, Iron Mountain commits to
resolve complaints about our collection or use of your personal information.
European individuals with inquiries or complaints regarding our Private Shield
policy should first contact Iron Mountain at:

Privacy & Compliance Group
One Federal Street
Boston, MA 02110, USA
+1 617 (617) 535-4766
global.privacy@ironmountain.com

Iron Mountain has further committed to refer unresolved Privacy Shield
complaints to the American Arbitration Association, an alternative dispute
resolution provider located in the United States. If you do not receive timely
acknowledgment of your complaint from us, or if we have not addressed your
complaint to your satisfaction, please contact or visit the American Arbitration
Association (http://go.adr.org/privacyshield.html) for more information or to
file a complaint. The services of the American Arbitration Association are
provided at no cost to you.

With regard to human resources data transferred from the EEA in the context of
the employment relationship, Iron Mountain commits to cooperate with EU data
protection authorities (DPAs) and comply with the advice given by such
authorities. With regard to human resources data transferred from Switzerland,
Iron Mountain commits to cooperate with the Swiss Federal Data Protection and
Information Commissioner’s office and comply with the advice given by such
office.

Finally, under certain conditions, more fully described on the Privacy Shield
website, you may be entitled to invoke binding arbitration when other dispute
resolution procedures have been exhausted.

With respect to Personal Information received or transferred pursuant to the
Privacy Shield Framework, Iron Mountain is subject to the regulatory enforcement
powers of the U.S. Federal Trade Commission.

If a third party service provider providing services on Iron Mountain’s behalf
processes personal data from the EEA or Switzerland in a manner inconsistent
with the Privacy Shield Principles, Iron Mountain will be liable unless we can
prove that we are not responsible for the event giving rise to the damages.

To access Iron Mountain’s list of GLOBAL Personal Data Subprocessors List, click
here. (Note that this list applies to Iron Mountain’s customers and not the
public.)

REQUIRED DISCLOSURE

Iron Mountain may disclose personal data in special cases to conform to legal
requirements or to respond to lawful requests by public authorities, including
meeting national security or law enforcement requirements or to protect and
defend our rights or property.

THE INFORMATION WE COLLECT.

Iron Mountain collects two types of information about users of this Web site;
"Personal Information" (including, but not limited to, your name, address,
telephone number and e-mail address) and non-personally identifiable and
anonymous "Aggregate Information" (such as information about how many users log
onto our Web site). Unless you provide it to us voluntarily or the information
is collected via cookies in the manner described in this notice, Iron Mountain
does not collect Personal Information in connection with your use of this Web
site.

Please read this notice 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.

In order to accommodate your information request, we ask you to submit your
name, title, company affiliation (if any), mailing address, telephone number and
e-mail address. At your option, you may also provide us with the best time at
which to contact you, the annual revenues of the company with which you are
affiliated, the number of employees of the company you are affiliated with, and
other relevant comments [if a comment field exists for the information you have
requested]. By providing your personal information to Iron Mountain via its
website, you agree to the terms of this notice and to receive communications
from Iron Mountain.

HOW WE USE THE INFORMATION WE COLLECT.

We will use the information you submit (a) to answer your specific inquiry; (b)
at your option, to send you additional materials relating to Iron Mountain and
services that may be of interest to you; (c) in the administration of the Web
site; and (d) as otherwise described in this notice.

Iron Mountain may, from time to time, share your Personal Information with
marketing consultants, in which case, the consultants shall be prohibited from
using your Personal Information except with respect to assisting Iron Mountain
in the sale of its services and products, and the consultants shall also be
required to comply with the terms of this notice.

HOW WE USE COOKIES AND OTHER TECHNOLOGIES.

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 behavior, 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, Iron Mountain may track your response to Iron Mountain's
advertisements, e-mails and site content, determine your ability to receive
HTML-based e-mail messages, learn how many users open an e-mail and allow our
service providers to compile aggregated statistics about an e-mail campaign for
Iron Mountain. 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. The collection of such information, whether by us or by data
aggregators, is subject to the terms set forth in this notice. Data obtained
through the SMS short code program will not be shared with any third-party for
their own marketing purposes.

Transparent GIF Files - In addition to our own cookies, we use pixels, or
transparent GIF files, on our sites to help manage our online advertising and
e-mail 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 e-mails bring you to our website and how you use the site.

Examples of the ways in which Iron Mountain and our third-party service
providers use GIF files include:

 * Tracking customer response to our advertisements, e-mails and site content.
 * Determining your ability to receive HTML-based e-mail messages. This
   capability helps us or our service providers send you e-mail in a format you
   can read.
 * Knowing how many users open an e-mail, thereby enabling our service providers
   to compile aggregate statistics about an e-mail 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 e-mail address) to the information the GIF files provide about how you
arrive at, navigate through and leave our sites.

DO NOT TRACK

Do Not Track (DNT) is a privacy preference that users can set in some web
browsers, allowing users to opt out of tracking by websites and online services.
At the present time, the World Wide Web Consortium (W3C) has not yet established
universal standards for recognizable DNT signals and therefore, Crozier and the
Website do not recognize DNT.

THE INFORMATION WE DISCLOSE.

Subject to applicable law, we and our service providers (as defined below)
disclose and share your personal information:

 * Among Iron Mountain and its Affiliates;
 * To unaffiliated third parties that are under contract to perform services for
   or on behalf of Iron Mountain (Service Providers), and 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, Iron
   Mountain Fulfillment Services, Iron Mountain Digital Services, or Iron
   Mountain Intellectual Property Management aspects of this web site or other
   vendors providing services of the nature referred to in this notice);
 * If a customer gives us written permission to do so, we may share
   de-identified data, which is deidentified using the HIPAA safe-harbor method,
   with third party partners;
 * 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.
 * For credit card payments, we employ third parties to process these payments
   on our behalf. These third-party credit card processing parties 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 Iron Mountain to process this personal information securely and in
   accordance with the relevant privacy or data protection laws.

Any access to such information will be limited to the purposes for which such
information was provided to us or our Service Providers. Iron Mountain, its
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 the United States of America (USA) or your country of
residence. For instance, if you inquire about services Iron Mountain provides in
France and in Brazil, Iron Mountain will forward your inquiry to the Iron
Mountain location in such countries. Iron Mountain will, at your request,
provide you with details of companies and countries to which your information
has been sent. Iron Mountain does not and will not sell your personal
information.

LINKS AND THIRD-PARTY WEBSITES.

This notice applies only to this Web 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 Web site. Although some of the
entities controlling these sites are under contract with Iron Mountain, we urge
you to familiarize yourself with the individual privacy and other terms for each
linked Web site prior to submitting your personally identifiable information

YOUR RIGHTS.

You are entitled to request that Iron Mountain:

 * provide you with a copy of your Personal Information that it holds;
 * cease processing your Personal Information, in whole or in part, as you
   direct us, for the purposes of direct marketing;
 * correct any errors in that Personal Information; and
 * update that Personal Information as required.

You will be given the opportunity to accept or reject the use of cookies on the
Web site in a pop-up box when you first access the Web site. You may choose not
to accept the cookies, however, this may restrict the services that you can
access at the Web site. If you would like to receive a copy of the Personal
Information we have about you as submitted to us via this Web site, or if you
wish to opt out of receiving marketing related communications from us, please
send a request to www.ironmountain.com/optout. If this information is incorrect
or incomplete, please let us know by sending a request to
global.privacy@ironmountain.com, and we will make every reasonable effort to
correct or update it promptly (unless we require further information from you in
order to fulfill 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 honor your request promptly, subject to
legal and other permissible considerations.

You may have additional rights under law, such as those granted by some U.S.
states. To inquire about these rights or to make a request pursuant to these
rights, please contact global.privacy@ironmountain.com.

If you do not receive acknowledgement of your inquiry from the
global.privacy@ironmountain.com, or your inquiry has not been satisfactorily
addressed, you should first contact Iron Mountain's Director of Privacy at
1-800-935-6966, ext. 8332 (if calling from within the USA) or 1-617-535-8332 (if
calling from outside the USA) or by writing to the Director of Privacy, Iron
Mountain, 1 Federal Street, Boston, MA 02110, U.S.A. or our Chief Compliance
Officer at 1-800-935-6966, ext. 8477 (if calling from within the USA) or
1-617-535-8477 (if calling from outside the USA) or by writing to the Chief
Compliance Officer, Iron Mountain, 1 Federal Street, Boston, MA 02110, U.S.A. If
you continue to have questions thereafter, then you may file a request for
mediation of an online privacy issue with the American Arbitration Association
at 335 Madison Avenue, 10th Floor, New York, New York 10017-4605, USA;
telephone: 212-716-5800; fax: 212-716-5905 and e-mail: websitemail@adr.org. Any
mediation shall take place at a location mutually agreed to as being convenient
to both parties; if mutual agreement cannot be achieved, then it shall take
place at a location convenient to the party which did not initiate the mediation
request.

NOTICE TO CALIFORNIA RESIDENTS.

If you are a resident of the State of California, the California Consumer
Privacy Act (CCPA) may grant you certain additional rights. Please visit the
following page for more information: Your California Privacy Rights.

CORONAVIRUS / COVID-19 UPDATE.

To protect you, your fellow visitors, and our employees and their families, Iron
Mountain may collect limited health information to grant or deny access to our
facilities, and/or to inform stakeholders of exposure to or positive testing for
Covid-19. Information collected will be handled, as applicable, in accordance
with this Privacy Notice.

CHANGES.

Iron Mountain may, in its sole discretion, update this notice at any time and
from time to time, by posting the amended notice on this Web site. We urge you
to refer back to this page regularly and especially prior to providing any
Personal Information via this Web site. You can determine if this notice has
been revised since your last visit by referring to the "last updated" legend at
the bottom of this page. This notice may not be otherwise amended without the
written consent of Iron Mountain.

As we provide more services on our websites and as privacy laws and regulations
evolve, it may be necessary to revise or update our Privacy notice. You can
determine if this Privacy notice has been revised since your last visit by
referring to the "last updated" legend at the bottom of this page.

HOW WE PROTECT AND STORE YOUR INFORMATION.

Iron Mountain takes seriously the security of the information it collects. Iron
Mountain has therefore 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 Web site is stored on servers in the
USA, and these servers are subject to Iron Mountain's IT security policies and
procedures. If you are located in another jurisdiction, 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.

CHILDREN.

Iron Mountain is 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)
[without prior verifiable parental consent]. If we become aware that a minor is
attempting to or has submitted Personal Information via this Web 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.

IRON MOUNTAIN'S BUSINESS ETHICS PROGRAM.

Disclosures made pursuant to Iron Mountain's Business Ethics Program are covered
by Iron Mountain's Code of Ethics and Business Conduct in lieu of this privacy
notice.

QUESTIONS REGARDING THIS NOTICE.

If you have questions concerning this notice, please contact our Chief
Compliance Officer at 1-800-935-6966, ext. 8477 (if calling from within the USA)
or 1-617-535-8477 (if calling from outside the USA) or via e-mail at
global.privacy@ironmountain.com or by writing to the Chief Compliance Officer,
Iron Mountain, 1 Federal Street, Boston, MA 02110, U.S.A.

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 Web site, and to
   fulfill any regulatory or legal requirements, including protecting our
   visitors' safety and wellbeing. We keep our customers informed as to what
   information we are collecting and how that information will be used. From its
   valued employees (including prospective and former 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 fulfill any
   regulatory or legal requirements, including protecting our employees’ and
   their families’ safety and wellbeing.
 * 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 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, the
   Customer may simply notify Iron Mountain in writing that it wishes to cease
   receiving additional information from Iron Mountain ("opt out"), and Iron
   Mountain will use its best efforts to promptly honor any such request./li>
 * 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 fulfill 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 (Service
   Providers) (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 honor 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.

If you have any questions about our privacy notice, please contact our Chief
Compliance Officer at 1-800-935-6966, ext. 8477 (if calling from within the USA)
or 617 535 8477 (if calling from outside the USA) or via e-mail at
global.privacy@ironmountain.com or by writing to the Director of Privacy, Iron
Mountain, 1 Federal Street, Boston, MA 02110, USA.

This notice was last updated July, 2021.


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