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Applicant and Employee Privacy Policy

Effective Upon: February 1, 2023

Last Updated: February 1, 2023

At SmartStop Storage Advisors, LLC (“SmartStop”, “us”, “our”, or “we”), we are strongly committed to transparency, and we want each of our employees, independent contractors, and applicants (“you” or “your”) to understand how we collect, use, disclose, and protect your information, as well as how you can manage the Personal Information we collect from you regarding your application for employment and employment, as applicable. For employees, this Privacy Policy does not cover other aspects of your employment.

We reserve the right to change our Privacy Policy from time to time. Please contact us immediately at [email protected] if you have any questions or concerns regarding this Privacy Policy.

  1. TYPES OF INFORMATION WE COLLECT
  2. HOW WE COLLECT INFORMATION
  3. HOW WE USE INFORMATION
  4. HOW WE DISCLOSE INFORMATION
  5. HOW WE PROTECT INFORMATION
  6. YOUR RIGHTS
  7. CONTACT US
  8. APPENDIX I

 


 

1.  TYPES OF INFORMATION WE COLLECT

We collect two basic types of information from you: Personal Information and Non-Personal Information.

Personal Information includes all information that relates to you personally and either identifies or may be used to identify, you personally (collectively, “Personal Information”). The Personal Information we collect depends on the reason it is sought, and may include:

  • Contact Information. Name, email address, postal address, phone number, business contact information, beneficiary and emergency contact information, and other contact information.
  • Demographic Information. Date of birth, gender, nationality, race, marital and dependent status.
  • Government Identification. Social Security number, driver’s license number, or other government identification numbers.
  • Financial Information. Compensation, benefits, tax information related to payroll, expenses, bank account information, bonus and pension information, and company credit card usage.
  • Employment Related Information. Information regarding performance, discipline, grievance, training, previous employment, work history, leave requests and absences, and background checks.
  • Company Equipment Information. Information regarding use of company IT systems including email, internet systems, computers, laptops (including via remote access) telephone systems and mobile devices; reviewing network traffic e-mails or other messages or data sent or received through our systems and inspecting data stored on individual file directories, hard drives or printed electronic media.
  • Letters about a pay raise or to your mortgage company confirming your salary.
  • Education Information. Education, certifications, and qualifications.
  • Physical or Mental Health Information. Health and attendance records, COVID-19 vaccination or testing records, medical records resulting from on-the-job injuries or accidents. All physical or mental health information, including COVID-19 vaccination or testing records are identified as strictly confidential, and maintained in physical and/or electronic files separate from your regular personnel file.
  • Biometric Information.  Photographs for identification cards (if applicable) and systems.
  • Photograph and other personal details included in a resume or cover letter, if applicable.

Non-Personal Information includes information that does not personally identify you (i.e., aggregated information) or information that has been anonymized (collectively, “Non-Personal Information”).

Please be aware, if you do not provide information when requested, we may be unable in some circumstances to comply with our obligations and we will inform you about the implications of that decision.

Information we collect and hold about Related Persons

As a result of certain individual’s relationship with you, such as family members, we may collect and process Personal Information about those individuals (“Related Persons”). We collect Personal Information about Related Persons in connection with emergency contacts and the benefits and services we provide, this information may include:

  • Contact information. Name, email, postal address, phone number, and emergency contact information.
  • Identification information. Photograph, Social Security number or other government identification number.
  • Benefits and Services information. Information necessary to extend the benefits and services that may be available to a related person as a family member or related person of our employees, including insurance-related information, claims-related information, disbursement-related information, and other protected characteristics such as race, sexual orientation, and health conditions.

Although we often collect the information described above directly from Related Persons, we also collect this information from employees and independent contractors related to these persons, as well as our benefit administrators. In addition, we may also collect this information through service providers and other third parties that collect it on our behalf, such as communications providers.

Special Category Information

Some of the data that we may collect as a result of providing employment checks (including background checks), employment identification, and Benefits and Services is particularly sensitive (e.g., biometric photo data, data revealing racial or ethnic origin, political opinions, sex life, sexual orientation, religion or other beliefs, data concerning health, criminal background or trade union membership).  We only collect this information as provided by or consented by you. 

Such sensitive data is only shared for the purpose of providing the services you request (e.g., health benefits) or as consented for (e.g., employment photograph) and will not be shared or used by us for any other purposes.

2.  HOW WE COLLECT INFORMATION

You may provide us with Personal Information in several ways, including, for example:

  • when you contact us and disclose Personal Information to us;
  • when you apply for employment with us;
  • during the interview process; and
  • during and after the course of employment with us.

We may collect Personal Information in several ways, including in person, in writing, over the phone, by email, online through social media platforms (e.g., LinkedIn), or our websites.

We will generally collect Personal Information about you from you directly. However, there may be occasions when we collect Personal Information about you from other sources (such as our third party service providers) to, among other things, enable us to verify or update information contained in our records.

3.  HOW WE USE INFORMATION

We use Personal Information to run the business and manage our relationship with you during the recruitment process, while you are working for us, when your employment ends, and after you have left. This includes using Personal Information to comply with the terms of your employment and protect your rights. We may also use Personal Information to comply with legal or regulatory obligations (e.g., complying with duties under applicable employment, social security, and tax regulations).

We may use your Personal Information for the following purposes:

  • employee/staff administration and operational functions (including payroll and benefits administration);
  • facilitating Human Resources functions, such as, recruitment, career development, training, talent management, performance management, appraisals, and disciplinary and grievance management;
  • business management and planning including internal administration;
  • processing employee work-related claims (for example, insurance and worker’s compensation claims);
  • accounting and auditing;
  • conducting performance reviews and determining performance requirements;
  • assessing qualifications for a particular job or task;
  • set up accounts in relation with management of expenses and professional travels;
  • detecting and preventing any inappropriate behaviour or breach of our policies, including securing and protecting our systems, resources, intellectual property, confidential information, and assets;
  • gathering evidence for disciplinary action or termination;
  • protecting against harm to the rights, property, or safety of us or our affiliates, our employees, contractors, customers, or the public, including, without limitation, instituting or defending against litigation;
  • health administration services, including administration of benefits relating to your spouse or dependents;
  • emergency contact purposes;
  • complying with health and safety obligations; and
  • complying with court orders and applicable law.

We may use Non-Personal Information for any legitimate business purpose.

As part of our ongoing compliance obligations, we as an employer may monitor company information, which may include Personal Information of our employees or independent contractors, and data usage to ensure reasonable and lawful use of our IT systems; maintain cost control, protect property and proprietary information; and ensure employees and contractors fulfil their duties and comply with company policies.

  • We reserve the right, at any time, to monitor and preserve any communications utilizing the company network and systems, including data or information access and usage.
  • Monitoring may include (i) hardware and software based IT security applications to prevent unauthorized access or activity relating to company systems used by the employee's device and (ii) in certain cases an inspection of the employee's device as part of an internal audit or investigation.
  • Information collected in connection with the use of devices to access and use our data or information may be accessed and reviewed by the following, each on a need-to-know basis:
    • Employee's supervisors and management;
    • Person acting for or on behalf of SmartStop;
    • HR department;
    • Legal department; and
    • IT department.

How we use Related Person information

We may use Personal Information we collect about Related Persons to:

  • Communicate with Related Persons about benefits and services they are eligible for, events or activities our personnel invite Related Persons to, or in the event of an emergency;
  • Administer the benefits and services Related Persons are eligible for;
  • Respond to requests and inquiries Related Persons may send to us;
  • Conduct internal investigations, audits, compliance, risk management, problem resolution and security operations;
  • Fulfil contractual obligations to Related Persons and other third parties; and
  • Comply with applicable law, rule, regulation, legal proceeding and government investigations, including relating to tax reporting and immigration.

4.  HOW WE DISCLOSE INFORMATION

Except as set forth in this Privacy Policy, or as required or permitted by law, we do not disclose your Personal Information other than where required by law, or to our employees, contractors, designated agents, or third-party service providers who require such information to assist us with administering our employment relationship with you. Third-party service providers include, but are not limited to, payroll processors and benefits administration providers. In no event will we sell or rent your Personal Information that was collected from the course of your employment or the application process with us for monetary value.

We may also disclose your Personal Information for the following additional purposes where permitted or required by applicable law:

  • to third parties to help us with the uses described in the How We Use Information section above;
  • to other affiliates for the purposes set out in this Privacy Policy and as necessary to perform our obligations with you as an employee, independent contractor, or applicant;
  • to other third parties where we are under a duty to disclose your Personal Information in order to comply with any applicable legal obligation including a regulatory process, subpoena, warrant, or a binding request by a regulatory body, government or judicial authority;
  • to assist during emergency situations or where necessary to protect the safety of persons;
  • to collect a debt that you owe to us;
  • in the event of a merger or acquisition, consolidation, change in control, transfer of assets, bankruptcy, reorganization, or liquidation; and
  • to comply with your directions or any additional consent you have provided us.

See Appendix I for all of the categories of Personal Information we may disclose.

We disclose Non-Personal Information to third parties as reasonably necessary to meet our business needs.

5.  HOW WE PROTECT INFORMATION

We implement and maintain reasonably appropriate measures designed to ensure the security and integrity of your Personal Information. We store Personal Information that we have collected in secure operating environments. We will only retain your Personal Information for the period of time reasonably required to fulfil the purposes for which it was collected, unless we have a legal requirement for retention.  Once you are no longer an employee, independent contractor, or applicant of SmartStop, we will retain for only as long as may be required by applicable Federal and State record retention laws and thereafter will securely destroy your Personal Information. We may retain Non-Personal Information for as long as we have a business need to do so.

If you suspect an unauthorized use or disclosure of your Personal Information, please contact us at [email protected] as soon as possible.

6.  YOUR RIGHTS

You have certain rights under the California Consumer Privacy Act, as amended from time to time, in connection with your Personal Information. You have the right to not receive discriminatory treatment for exercising your rights. To do so, you may submit the webform located in Section 9.9 of this website (https://smartstopselfstorage.com/privacy-policy) or contact us at [email protected], or at the following:

SmartStop Self Storage

10 Terrace Road

Ladera Ranch, California 92694

Attention: Compliance Department (Privacy Policy)

(855) 924-1444

Access to your Personal Information

You have the right to request that we provide you access to the Personal Information that we collect directly from you, use, and disclose about you.

Correcting your Personal Information

You have the right to rectify inaccurate or obsolete Personal Information by contacting [email protected].

Deleting your Personal Information

You may have the right to request that we delete your Personal Information, subject to some exceptions. Once we have received and confirmed your request, we will delete (and direct our business partners and service providers to delete) your Personal Information, unless an exception applies – for example, if we are required by applicable Federal or State law to retain such information for a certain period of time prior to deletion. You have the right to not receive discriminatory treatment for exercising your deletion right.

Opting out of the Sale/Sharing of Personal Information

You have the right to opt out of the sale or sharing of Personal Information.  However, we do not sell or share your Personal Information.

Limiting the Disclosure of Sensitive Personal Information

You may have the right to request to limit the use and disclosure of their sensitive Personal Information for specific secondary purposes.  However, we do not disclose sensitive Personal Information outside of those allowed under applicable laws.

Access and Opt Out of Automated Decision-Making

You may have the right to access and opt out of automated decision-making technology and processes involving your Personal Information.  However, we do not use automated decision-making with regards to your Personal Information.

To submit a request to exercise the above rights related to your Personal Information or designate an authorized agent to make a request to access your Personal Information, please contact us at [email protected].

Our security procedures and our obligations under applicable law mean that we may request proof of identity before we disclose your Personal Information to you.

7.  CONTACT US

If you have questions, concerns, or would like to update/change your Personal Information, you can always contact us in the following ways:

Email

[email protected]

Toll-free phone

(855) 924-1444

 

8.  APPENDIX I

To learn more about the categories of Personal Information we collect, how we collect it, why it is collected, and with whom we share the information, please see the chart below.

Category

What we collect

How we collect it

Why we collect it

With whom we share it

Identifiers

Name, mailing address, email address, phone number, and other contact information.

For more information please see the Types of Information We Collect section above.

Collected online or offline when you directly provide it to us or through internal or external sources.

We collect this information for the purposes listed in the How We Use Information section above.

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

(Some information included in this category may overlap with other categories)

Name, mailing address, phone number, government identification numbers, education and employment history, financial information, and medical and health insurance information.

For more information please see the Types of Information We Collect section above.

Collected online or offline when you directly provide it to us or through internal or external sources.

We collect this information for the purposes listed in the How We Use Information section above.

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

Protected classification characteristics under California or federal law

Age, gender, race, nationality, physical or mental disability, and veteran or military status.

For more information please see the Types of Information We Collect section above.

Collected online or offline when you directly provide it to us or through internal or external sources.

We collect this information for the purposes listed in the How We Use Information section above.

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

Commercial information

Not collected

N/A

N/A

N/A

Biometric information

Photograph

Collected when you directly provide it to us

Employment identification

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

Internet or other similar network activity

Information regarding use of company IT and telephone systems.

For more information please see the Types of Information We Collect section above.

Collected online when you directly provide it to us or through internal or external sources.

We collect this information for the purposes listed in the How We Use Information section above.

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

Geolocation data

Collected via IP address while using company IT systems.

For more information please see the Types of Information We Collect section above.

Collected online when you directly provide it to us or through internal or external sources.

We collect this information for the purposes listed in the How We Use Information section above.

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

Sensory data

Audio and visual information collected via security camera or when otherwise provided.

For more information please see the Types of Information We Collect section above.

Collected when you directly provide it to us or through internal or external sources.

We collect this information for the purposes listed in the How We Use Information section above.

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

Professional or employment-related information

Employment history.

For more information please see the Types of Information We Collect section above.

Collected online or offline when you directly provide it to us or through internal or external sources.

We collect this information for the purposes listed in the How We Use Information section above.

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

Non-public education information

Education history and information.

For more information please see the Types of Information We Collect section above

Collected online or offline when you directly provide it to us or through internal or external sources.

We collect this information for the purposes listed in the How We Use Information section above.

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

Inferences drawn from other Personal Information

Information generated during your employment reflecting your characteristics, preferences, trends, attitude, abilities, and aptitudes.

Collected online or offline when you directly provide it to us or through internal or external sources.

We collect this information for the purposes listed in the How We Use Information section above.

Shared with our affiliates, partners, vendors, and service providers as described in the How We Share Information section above.

 

 

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