PSCC, Inc. Privacy Policy

Date Last Updated: July 14, 2023

The privacy and security of your information is very important to us. At PSCC, Inc., in California DBA PSCC Insurance Services Processing (“PSCC,” “us,” “we,” or “our”), we know that you care about how your information is collected, used, and shared, and we want to help you make knowledgeable choices about the information you provide to us. This Privacy Policy (the “Policy”) explains our information practices with regard to your Personal Information when you interact with our Orange Door Storage Insurance Program (the “Program”) directly, by phone, online, and through our customer support services. This Policy applies to current and former customers of PSCC who participate in the Program, as well as visitors to the orangedoor.spinudev.com website (the “Site”).

This Policy does not apply to other websites which may be operated by affiliates or business partners of PSCC, even if they are linked to the Site. By using our services and/or the Site, you agree that your Personal Information will be handled as described in this Policy. Your use of our Site, services, and any dispute over privacy is subject to this Policy and our Terms and Conditions.

Residents of certain states may have additional rights concerning their Personal Information under the laws of those states. If you are a resident of California, Colorado, Connecticut, or Virginia, please refer to the “Additional Privacy Information for Certain Jurisdictions” section below.

Please Note: Insurance through our Program is offered by STARR Indemnity & Liability Company – A Member of STARR Insurance Companies (the “insurance company”). You should review their privacy policy for more information about their data collection practices, as it may differ from ours.

Quick Reference Guide

1. What Personal Information We Collect and How We Use It
2. How We May Disclose Personal Information
3. Contact Preferences and Updating Your Personal Information
4. Additional Privacy Information for Certain Jurisdictions
5. Information Regarding Children
6. What Else You Should Know About Your Privacy
7. Changes to this Privacy Policy
8. Legal Disclaimer
9. External Links
10. Questions and Contacting PSCC

1. What Information We Collect and How We Use It

We collect information that you provide us that identifies, describes, or is reasonably capable of being associated with you (“Personal Information”). The following discusses the categories of Personal Information we collect, the sources we collect information from, and the business or commercial purposes we use your Personal Information. Personal Information does not include publicly available information as defined under applicable laws, de-identified information, or aggregated information.

1.1 When You Apply for and Purchase Insurance

When you complete an application for insurance, we may collect the following Personal Information from you or the insurance company. We might also receive Personal Information about you from our affiliates.

• Personal Identifiers. We may collect your first and last name, postal address, home and/or mobile phone numbers, email address, social security number, driver’s license number or identification, and any other information that you choose to provide that would allow us to identify you personally.
• Financial Information. We collect payment card information, insurance coverage information, and your account number.

We use this Personal Information to set up, maintain, and collect payment on your account with us. We also use this Personal Information to provide insurance services to you, for example to remit premiums or adjust any insurance claims, and otherwise run day-to-day operations. We may use this Personal Information to communicate with you and provide you with marketing and promotional information about products and services we believe are of interest to you. We may also use this Personal Information to strategically partner with advertisers and affiliates.

1.2 If You Make a Claim Under an Insurance Policy

If you make a claim under your insurance policy, we collect the following Personal Information from you and/or the claims management company.

• Personal Identifiers. We may collect your first and last name and contact information such as your postal address, home and/or mobile phone numbers, and email address.
• Commercial Information. We collect information about your storage unit, such as your unit number and the address and property number for the storage facility where your unit is located. We also collect information about the loss and the property damaged in the incident.
• Financial Information. We collect insurance coverage information and your account number.

We use this Personal Information to perform the service you requested. We may use this Personal Information to contact you about your request.

1.3 If You Contact Us

If you contact us directly with a question or concern or contact our customer service line, we may collect the following Personal Information directly from you.

• Personal Identifiers. We may collect your first and last name, postal address, home and/or mobile phone numbers, email address, social security number, driver’s license number or identification, and any other information that you choose to provide that would allow us to identify you personally.
• Financial Information. We collect payment card information, insurance coverage information, and your account number.

We use this Personal Information to respond to provide customer service and respond to your requests, comments, or concerns. We also take your feedback to heart and may use this information to improve our Program, as well as train our employees on how to better serve you.

1.4 Cookies and Other Information We Collect Automatically

PSCC and our affiliates may automatically collect certain types of Personal Information whenever you use the Site. If we collect this information, it will be done passively through the use of certain electronic technologies, such as cookies, web beacons, pixels, clear GIFs, and similar technologies. The Personal Information we may automatically collect includes:

• Device and Browsing Information. When you visit our Site, we may collect IP address, browser type, domain names, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and similar device and browsing information.
• Activities and Usage. We also collect activity information related to your use of the Site, such as information about the links clicked, searches, features used, items viewed, time spent, your interactions with the Site, and other activity and usage information.
• Location Information. We may also collect or derive location information about you, such as through your IP address.

We use cookies, pixel tags, and other similar tracking mechanisms to automatically collect Personal Information to analyze and understand how you access, use, and interact with our Site; identify and resolve bugs and errors; assess, secure, protect, optimize, and improve the performance of our Site; and to personalize content on our Site. We may also aggregate such information to analyze trends and gather broad demographic information for aggregate uses

Cookies. “Cookies” are alphanumeric identifiers we transfer to your device’s hard drive through your web browser for tracking purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process, support the security and performance of the Site, or allow us to track activity and usage data within the Site.

Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these to, among other things, track the activities of users, and help us manage content and compile usage statistics.

Third Party Analytics. We use third party tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Site. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect usage data about our Site to provide us with reports and metrics that help us evaluate usage, improve our Site, and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Your Choices. To prevent cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.

Do Not Track. Currently, our Site and Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed below (e.g., by disabling cookies).

2. How We May Disclose Information

We may disclose your Personal Information with selected recipients. These categories of recipients include:

• Our Service Providers. We may disclose Personal Information we collect with our service providers who perform functions on our behalf, such as to collect payment, complete a task that you have asked us to do, to adjust insurance claims, or provide your Personal Information to a delivery service so that they can assist us in fulfilling your request for service. We require that these service providers do not sell, transfer, or use your Personal Information use the Personal Information we gathered on this website other than in accordance with our policies.
• Business Partners and Affiliates. We may disclose the Personal Information we collect to our corporate affiliates and subsidiaries. We also partner with other businesses to offer our products and services, and we may disclose Personal Information to those business partners.
• Customers and Clients. In some circumstances, we may disclose the Personal Information we collect to our customers and clients to administer our services.
• Third-Party Analytics Providers. We may also disclose your Personal Information, such as device and browsing, and activities and usage information, to data analytics providers who provide analytics services on our behalf.
• Government or Public Authority/Agency. We may disclose Personal Information if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process, or governmental request, (b) to enforce our agreements, policies, and terms of use, (c) to protect the security or integrity of our Website or Services, (d) to protect the property, rights, and safety of PSCC, our users or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person, or (f) to investigate and defend ourselves against any third-party claims or allegations.

We may disclose Personal Information to the parties listed above for the following purposes:

• Operating Our Site and Services. We may disclose Personal Information to provide and operate our Site and services.
• In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the Personal Information we have collected from you with or to the other company. We may also disclose certain Personal Information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. To comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
• Security and Protection of Rights. Where we believe doing so is necessary to protect our rights and property, or the rights, property, and safety of others. For example, we may disclose Personal Information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms and Conditions. We may also disclose Personal Information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.

3. Contact Preferences and Updating Your Personal Information

You have certain choices when it comes to how PSCC uses your Personal Information. You may choose not to receive information about new services and special promotional offers from us by direct mail and/or email. If you elect not to receive such marketing information by direct mail or email, PSCC may continue to contact you as necessary to service your account. You can change your contact preferences by emailing us at privacy@orangedoorstorageinsurance.com or by writing to us at the physical address set forth further below.

Keeping your account information accurate and up to date is very important so we can provide you with excellent service. If your account information is incomplete, inaccurate, or not current, please contact PSCC customer service. You can obtain information about how to contact PSCC customer service at orangedoor.spinudev.com/contact.

4. Additional Privacy Information for Certain Jurisdictions

Residents of certain jurisdictions have additional rights under applicable privacy laws, as described in this section.

• 1. Colorado, Connecticut, and Virginia

Residents of Colorado, Connecticut, and Virginia have rights under applicable privacy laws, subject to certain limitations, which may include:

• Access. To confirm whether we are processing your Personal Information and to obtain a copy of your Personal Information in a portable and, to the extent technically feasible, readily usable format.
• Deletion. To delete your Personal Information provided to or obtained by us.
• Correction. The right to correct inaccuracies in your Personal Information, taking into account the nature and purposes of the processing of the Personal Information.
• Opt-Out. To opt out of certain types of processing, including:
  • to opt out of the “sale” of your Personal Information;
  • to opt out of targeted advertising by us; and
  • to opt out of any processing of Personal Information for purposes of making decisions that produce legal or similarly significant effects.

Note that we do not “sell” Personal Information, process Personal Information for purposes of targeted advertising, or process Personal Information for purposes of making decisions that produce legal or similarly significant effects.

How to Exercise Your Privacy Rights. To submit a request to exercise these rights you may use one of the following three methods:

• Webform powered by OneTrust
• Phone: (877) 878-6730
• Mail: PSCC, Inc. Privacy Officer in California DBA: PSCC Insurance Services Processing (CA Insurance License #0E14626), P.O. Box 25097 Glendale, CA 91221-5097

For all requests, please clearly state that the request is related to “Your [State] Privacy Rights,” indicate which type of request you are making. Please provide us with the following information: (1) first and last name; (2) email address; and (3) zip code. We will take steps to verify your request by matching the information provided by you with the information we have in our records. If we are unable to adequately verify a request, we will notify the requestor.

We may deny your request if (1) we are not reasonably capable of associating your request with the Personal Information or it would be unreasonably burdensome for us to associate your request with the Personal Information; (2) we do not use the Personal Information to recognize or respond to you specifically or associate the Personal Information with other Personal Information about you; and (3) we do not sell the Personal Information to any third party or otherwise voluntarily disclose the Personal Information to any third party other than a processor, except as otherwise permitted under applicable law.

If we decline to take action regarding your request, you have the right to appeal. We will notify you providing our reasons and instructions for how you can appeal the decision. If the appeal is denied, we will provide a way for you contact your state’s Attorney General to submit a complaint.

• 1. California

This section of the Policy provides additional information for California residents and describes our information practices pursuant to the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020, and its implementing regulations (the “CCPA”). This section applies to “Personal Information” as defined in the CCPA, whether collected online or offline. This section does not apply to information that is exempt from CCPA, such as information protected under the federal financial privacy laws. The CCPA recognizes that such financial information is already protected by federal privacy law, so the CCPA does not apply to this information. The majority of information we collect, process, or disclose is for insurance purposes and is governed by the federal Gramm-Leach-Bliley Act (“GLBA”). For more information, please see the insurance company’s policy. To the extent you are an insured and we have received your information for insurance purposes, these privacy rights do not apply to you. Your insurance company may be required to provide you with certain privacy rights under federal and state law. If you would like a copy of your privacy rights under such laws, please contact the insurance company directly.

Retention of Personal Information. We retain your Personal Information for as long as needed, or permitted, based on the reason we obtained it (consistent with applicable law). When deciding how long to keep your Personal Information, we consider whether we are subject to any legal obligations (e.g., any laws that require us to keep records for a certain period of time before we can delete them) or whether we have taken any legal positions (e.g., issued any legal holds or otherwise need to preserve the information). In accordance with our retention policies, rather than delete your Personal Information we may also deidentify your Personal Information in compliance with CCPA. If we collect or use deidentified information, we will not attempt to reidentify it.

Your California Privacy Rights. The CCPA provides California residents with certain rights regarding their Personal Information. In general, California residents, including our business clients’ employees who reside in California, have the following rights with respect to their Personal Information, subject to certain exceptions:

The Right to Know/Access. With respect to the Personal Information we have collected about you, you have the right to request from us (subject to certain exemptions):

• The categories of Personal Information we collected;
• The categories of sources from which we collected that information;
• Our business or commercial purpose for collecting that information;
• The categories of third parties with whom we shared that information; and
• The specific pieces of Personal Information we collected about you.

Right to Correct. You have the right to request that we correct inaccuracies in your Personal Information.

Right to Delete. Subject to certain exceptions, you have the right to request we delete Personal Information we have collected from you.

Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your Personal Information, as those terms are defined under the CCPA. We do not “sell” or “share” Personal Information under CCPA. We do not sell or share sensitive Personal Information, nor do we sell or share any Personal Information about individuals who we know are under sixteen (16) years old.

Right to Limit Use of Sensitive Personal Information. We do not engage in uses or disclosures of “sensitive Personal Information” that would trigger the right to limit use of sensitive Personal Information under the CCPA.

Right to Non-Discrimination. We will not discriminate against you for exercising any of the rights described in this section.

Exercising Your Rights. If you are a California resident and would like to exercise any of these rights, you may contact us at:

• Webform powered by OneTrust
• Phone: (877) 878-6730
• Mail: PSCC, Inc. Privacy Officer in California DBA: PSCC Insurance Services Processing (CA Insurance License #0E14626), P.O. Box 25097, Glendale, CA 91221-5097

Before responding to your request, we must first verify your identity using your first and last name, phone number, email address, government issued ID, and Public Storage account. If we cannot verify your request, we will contact you for more information. If we cannot verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

Designating an Authorized Agent. You may designate someone to submit requests and act on your behalf (an “Authorized Agent”). Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

5. Information Regarding Children

Our Site is intended for users who are 13 years or older and we do not knowingly collect information from children under 13 years old. If we become aware that we have collected information from a child under 13 years old, we will delete such information from our records. If you are a parent or legal guardian and believe your child has given us information and you did not provide consent, please email us at privacy@orangedoorstorageinsurance.com for assistance.

6. What Else You Should Know About Your Privacy

You should be careful to maintain the secrecy of your user ID and password and/or account information and be responsible for protecting your Personal Information and identity, both online and offline. You can refer to the Federal Trade Commission’s website at http://www.ftc.gov/bcp/menus/consumer/data.shtm for information on how to protect yourself from identity theft.

7. Changes to This Privacy Policy

Our Privacy Policy will change over time as we seek to improve the services we provide. We will post the revised Policy on the Site and we will update the Last Updated Date at the top of the Policy. We encourage you to refer to the Policy from time to time to stay informed about our most current practices. We also encourage you to periodically review this Policy to stay informed about our collection, use, and disclosure of your information. We will not use or share your Personal Information for materially different purposes without first taking reasonable steps to provide you notice, such as by posting prominent notice on our Site.

8. Legal Disclaimer

Nothing in this Policy restricts our ability to:

• Comply with federal, state, or local laws;
• Comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities;
• Cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local law;
• Exercise or defend legal claims;
• Detect security incidents and protect against fraudulent or illegal activity and prosecute those responsible for such activity; or
• Transfer Personal Information as part of a merger or acquisition, dissolution, bankruptcy, or any other transaction in which a third party assumes control of all or part of our business. It is our practice to seek appropriate protection for Personal Information disclosed or received in these types of transactions. We cannot, however, guarantee that PSCC’s Privacy Policy will remain unchanged in the unlikely circumstance that PSCC is sold or if it merges with another company.

9. External Links

The Site may contain links to third-party websites. Please be aware, however, that PSCC is not responsible for and cannot control the privacy policies of these other websites or their practices. We encourage you to read the privacy policies for these other websites, as they may differ from ours. Please read the privacy policy on these sites for applicable privacy practices relating to Personal Information collected via those sites because they may differ from PSCC’s privacy practices.

10. Questions and Contacting PSCC

If you have any questions, comments, or concerns about this Policy, please call us at (877) 878-6730, or write to us at:

PSCC, Inc. Privacy Officer in California DBA: PSCC Insurance Services Processing (CA Insurance License #0E14626)
P.O. Box 25097
Glendale, CA 91221-5097