Iron Mountain

Iron Mountain Web Site Privacy Policy

YOUR PRIVACY IS IMPORTANT TO IRON MOUNTAIN.

This Policy Adopted By: Iron Mountain, its participating subsidiaries 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 Privacy Policy 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 policy and the Privacy Principles concerning online privacy, the terms of this policy shall prevail.

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 policy, Iron Mountain does not collect Personal Information in connection with your use of this Web 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.

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].

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 policy.

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 policy.

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 policy.

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.

Your right to reject use of cookies.

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 [and our service will still work if you choose to do so]. However, this may restrict the services that you can access at the Web site.

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, COMAC, 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 Privacy Policy);
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 purpose 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.

Links and third-party websites.

This policy 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.

How to opt out or request changes.

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.

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 webmaster@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.

If you do not receive acknowledgement of your inquiry from the webmaster@ironmountain.com, or your inquiry has not been satisfactorily addressed, you should first contact Iron Mountain's Director of Privacy at global.privacy@ironmountain.com. 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.

Notification of changes.

Iron Mountain may, in its sole discretion, update this policy at any time and from time to time, by posting the amended policy on this Web site. If we make material changes to this policy that affect our treatment of your Personal Information, we will provide you with e-mail or postal mail notice and a choice to opt in under the terms of the revised policy. After the changes take effect, all newly collected Personal Information will be subject to the terms of the revised policy and all previously collected Personal Information will be handled in accordance with your response to our opt-in notice (in accordance with the revised policy if you opt in and in accordance with the previous policy if you do not opt in). If no material changes have been made to this policy that affect our treatment of your Personal Information, the amended policy shall be effective upon posting, and your access to or use of the site following an update shall be deemed consent to the revised policy. If you have asked to receive marketing and other materials, and you regularly receive electronic communications from us, amendments to this policy may be sent to you via e-mail. We urge you to refer back to this page regularly and especially prior to providing any Personal Information via this Web site. This policy may not be otherwise amended without the written consent of Iron Mountain. This Policy was last updated August 1, 2005.

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. In addition, Iron Mountain has certified its compliance with the Safe Harbor framework designed to satisfy the "adequacy" requirement under the European Directive on Data Protection.

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 policy.

Questions regarding this policy.

If you have questions concerning this Policy, please contact our Director of Privacy at 1-800-935-6966, ext. 4932 (if calling from within the USA) or 1-617-535-4932 (if calling from outside the USA) or via e-mail at global.privacy@ironmountain.com or by writing to Director of Privacy, Iron Mountain, 745 Atlantic Avenue, Boston, MA 02111, 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 requirement. We keep our customers informed as to what information we are 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 fulfill 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 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.
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 policy, please contact our Director of Privacy at 1-800-935-6966, ext. 4932 (if calling from within the USA) or 617 535 4932 (if calling from outside the USA) or via e-mail at global.privacy@ironmountain.com or by writing to Director of Privacy, Iron Mountain, 745 Atlantic Avenue, Boston, MA 02111, USA.