Effective as of January 1, 2020
Last Updated August 1, 2023
We collect personal data from you through your use of the Site and Services. Personal data is information that is linked or reasonably linkable to an identified or identifiable individual. We collect the following types of personal data:
Personal Data You Provide
Depending on how you interact with our Site and Services, we will collect the following personal data that you voluntarily provide to us for the following purposes:
- Account. To create a Limited Partner Resources account, you will provide your first and last name, email address, and password. You also may choose to provide your company name, if applicable. When you log-in to your Limited Partner Resources account, you will provide your email address along with your password.
- Information Request/Email Alerts. When you submit an information request or sign up to receive our news alerts, you will provide your name and email address. To unsubscribe from our marketing emails, please click the unsubscribe link included in the footer of our emails. You also may submit a request to us at firstname.lastname@example.org.
- Contact Us. To contact us through the Site, we may collect your name, email address, and telephone number along with any additional information you voluntarily provide.
- Listening to Earnings Calls. To listen to our earnings calls (live or through webcasts), we use a third party, through our Site vendor, to complete this request. In such event, you will be asked to provide your first and last name, email address, and professional or employment related information (including your company name).
Personal Data as You Navigate Our Site
- Usage Information. For example, the pages on the Site you access, the frequency of access, and what you click on while on the Site.
- Device Information. For example, hardware model, operating system, application version number, and browser.
- Mobile Device Information. Aggregated information about whether the Site is accessed via a mobile device or tablet, the device type, and the carrier.
- Location Information. Location information from Site visitors on a city-regional basis.
For more information on our cookie usage, see our “Cookies and Other Tracking Technologies” section below.
Personal Data We Collect About You From Other Sources
In some cases, we may receive personal data about you from other sources. This includes internet service providers, data analytics providers, and operating systems and platforms.
We may share the personal data that we collect about you in the following ways:
- With vendors who perform data or Site-related services on our behalf (e.g., email, hosting, maintenance, backup, analysis, etc.);
- To the extent that we are required to do so by law;
- With vendors who perform services on our behalf relating to the management and operation of our business, including without limitation, with respect to tax matters and filings and shareholder and limited partner administration;
- With vendors who perform services on our behalf relating to our prospective employees;
- In connection with any legal proceedings or prospective legal proceedings;
- To establish, exercise, or defend our or a third party’s legal rights, including providing information to others for the purposes of fraud prevention or detection and investigation of whistleblower claims;
- With any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal data where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal data;
- With any other person or entity as part of any business or asset sale, equity transaction, merger, acquisition, bankruptcy, liquidation, or similar proceeding, or in preparation for any of these events;
- With any other person or entity where you consent to the disclosure; and
- For any other purpose disclosed by us when you provide the personal data or for any other purpose we deem necessary, including to protect the health or safety of others.
- Estimate audience size and usage patterns;
- Understand and save your preferences for future visits, allowing us to customize the Site and Services to your individual needs;
- Compile aggregate data about site traffic and site interactions to resolve issues and offer better site experiences and tools in the future; and
- Recognize when you return to the Site.
How You Can Opt Out of Cookies
You can block Cookies by changing your Internet browser settings to refuse all or some Cookies. If you choose to block all Cookies (including essential Cookies) you may not be able to access all or parts of the Site.
You can opt out of Cookies set by specific entities by following the instructions found at these links:
- Google: https://adssettings.google.com
Advertising Industry Resources
You can understand which entities have currently enabled Cookies for your browser or mobile device and how to opt out of some of those Cookies by accessing the Network Advertising Initiative’s website or the Digital Advertising Alliance’s website. For more information on mobile specific opt-out choices, visit the Network Advertising Initiative’s Mobile Choices website.
Please note these opt-out mechanisms are specific to the device or browser on which they are exercised. Therefore, you will need to opt out on every browser and device that you use.
We do not engage in “sales” or “shares” as those terms are defined under applicable laws and therefore our Site does not recognize the Global Privacy Control (“GPC”) signal. For more information and to download and use a browser supporting the GPC browser signal, click here: https://globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
Some internet browsers incorporate a “Do Not Track” feature that signals to websites you visit that you do not want to have your online activity tracked. Given that there is not a uniform way that browsers communicate the “Do Not Track” signal, the Site does not currently interpret, respond to, or alter its practices when it receives “Do Not Track” signals.
We maintain commercially reasonable security measures to protect the personal data we collect and store from loss, misuse, destruction, or unauthorized access. However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal data, we cannot guarantee absolute security.
The Site may contain links that will let you leave the Site and access another website. Linked websites are not under our control. We accept no responsibility or liability for these other websites.
The Site and Services are not intended for children under 13 years of age. We do not knowingly collect, use, or disclose personal data from children under 13.
Depending on the state in which you reside, you may have certain privacy rights regarding your personal data. If you are a California resident, please see our “Notice to California Residents” Section below. For other state residents, your privacy rights may include (if applicable):
- The right to confirm whether or not we are processing your personal data and to access such personal data;
- The right to obtain a copy of your personal data that we collected from and/or about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another controller without hindrance, where the processing is carried out by automated means;
- The right to delete personal data that we collected from and/or about you, subject to certain exceptions;
- The right to correct inaccurate personal data that we maintain about you, subject to certain exceptions;
- The right, if applicable, to opt out of the processing of your personal data for purposes of (1) targeted advertising; (2) the “sale” of your personal data (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- If we are required by applicable law to obtain your consent to process sensitive personal data, the right to withdraw your consent; and
- The right not to receive discriminatory treatment by us for the exercise of your privacy rights.
We do not “sell” personal data to third parties or process personal data for targeted advertising as those terms are defined under applicable privacy laws. We also do not use personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals.
To exercise your rights, please submit a request through our interactive webform available here or by calling us at 1-855-966-1392. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision by emailing us at email@example.com.
The CCPA defines “personal information” to mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. Personal information does not include publicly available, deidentified or aggregated information or lawfully obtained, truthful information that is a matter of public concern. For purposes of this “Notice to California Residents” section we will refer to this information as “Personal Information.”
If you are California resident and a current or former employee, job applicant, or independent contractor of ours, please see our privacy notice available here for more information on our collection and use of your Personal Information in that capacity.
Notice at Collection of Personal Information
- Identifiers (name, alias, postal address, Internet Protocol address, email address, and Social Security or employer identification number)
- Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology)
- Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (signature and initials, telephone number, banking information (including account number), other financial information (such as the information provided in our accredited investor questionnaire), as well as the categories listed in the “Identifiers” category above)
- California corporation number or California Secretary of State file number
- Characteristics of protected classifications under California or federal law (race, color, sex/gender (including pregnancy, childbirth, breastfeeding and/or related medical conditions), sexual orientation, gender identity/expression, age (40 and older), religion (including religious dress and grooming practices), national origin, ancestry, disability (mental and physical including HIV/AIDS, cancer, and genetic characteristics), citizenship status, genetic information, marital status, medical condition (genetic characteristics, cancer or a record or history of cancer), military or veteran status, political affiliations or activities, status as a victim of domestic violence, assault or stalking, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and retaliation for reporting patient abuse in tax-supported institutions)
- Audio information (recordings of phone calls or voice mail messages)
- Any information in the consumer’s whistleblower claims history, including appeals records, if information is linked or reasonably linkable to consumer
- Professional or employment-related information (including employment history)
- Sensitive Personal Information (consumer’s account log-in and password)
In addition, if we engage in acquisition due diligence with a potential seller or business partner, we may collect renter names (from rent rolls) of California residents from the seller or business partner. We also may collect the following categories of Personal Information about the seller or business partner for purpose of the transaction:
- Identifiers (name, postal address, phone number, email address, Social Security number or federal employer identification number)
- Personal information described in California’s Customer Records statute (California Civil Code § 1798.80(e)) (signature and initials, financial information (including income and expense statements, bank statements, real estate tax bills and information on any mortgages or loans the seller or business partner may have outstanding, income tax returns, certificates of insurance, insurance loss runs (showing insurance claims history), affidavits confirming that the seller or business partner is not a foreign person, as well as the categories listed in the “Identifiers” category above)
- Audio information (recordings of phone calls or voice mail messages)
We collect Personal Information directly from California residents and from internet service providers, data analytics providers, and operating systems and platforms. We do not collect all categories of Personal Information from each source.
In addition to the purposes stated above in the Section “How We Use Your Personal Data” we currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:
- Auditing related to counting unique visitors to our website
- Helping to ensure security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes
- Debugging to identify and repair errors that impair existing intended functionality
- Performing services, including customer service to our shareholders and limited partners
- Acquiring and selling self storage facilities and related properties, including identifying and conducting due diligence on such facilities and properties and negotiating transaction agreements
Disclosure of Personal Information
|Category of Personal Information||Categories of Recipients|
Identifiers (name, email address, and postal address); telephone number
Vendors to allow us to provide our Site and Services to you (e.g., website hosting and related vendors)
Vendors to allow us to conduct, administer and manage our business, including tax, accounting and legal advisors, human resources providers, transfer agent, and consultants and providers utilized in connection with purchasing and selling self storage facilities and related properties
Social Security number or employer identification number; signature and initials; banking information, including bank account number; other financial information such as the information provided on our accredited investor questionnaire; California corporation number of California Secretary of State file number; audio information (recordings of phone calls or voice mail messages); any information in the consumer’s whistleblower claims history, including appeals records, if information is linked or reasonably linkable to consumer; characteristics of protected classifications under California or federal law (race, color, sex/gender (including pregnancy, childbirth, breastfeeding and/or related medical conditions), sexual orientation, gender identity/expression, age (40 and older), religion (including religious dress and grooming practices), national origin, ancestry, disability (mental and physical including HIV/AIDS, cancer, and genetic characteristics), citizenship status, genetic information, marital status, medical condition (genetic characteristics, cancer or a record or history of cancer), military or veteran status, political affiliations or activities, status as a victim of domestic violence, assault or stalking, request for family care leave, request for leave for an employee’s own serious health condition, request for pregnancy disability leave, and retaliation for reporting patient abuse in tax-supported institutions)
Vendors to allow us to conduct, administer and manage our business, including tax, accounting and legal advisors, human resources providers, transfer agent and other consultants and providers utilized in connection with purchasing and selling self storage facilities and related properties
Professional or employment-related information (including employment history)
Vendors providing us with human resource related services
Vendors to allow us to provide our Site and Services to you (e.g., website hosting and related vendors)
Unique personal identifiers (device identifier; cookies, beacons, pixel tags, mobile ad identifiers, or other similar technology); Internet Protocol address
Data analytics providers
Retention of Personal Information
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collect it, such as to provide you with the service you have requested, and for the purpose of satisfying any legal, accounting, contractual, or reporting requirements that apply to us.
If you are a California resident, you have the following rights with respect to your Personal Information:
- The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing Personal Information (if applicable), the categories of third parties to whom we disclose Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
- The right to delete Personal Information that we collected from you, subject to certain exceptions;
- The right to correct inaccurate Personal Information that we maintain about you;
- If we sell or share Personal Information, the right to opt out of the sale or sharing;
- If we use or disclose sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure; and
- The right not to receive discriminatory treatment by us for the exercise of privacy rights the CCPA confers.
How to Submit a Request to Know, Delete, and/or Correct
You may submit a request to know, delete, and/or correct through our interactive webform available here or by calling us at 1-855-966-1392.
If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed above. After submitting the request, we will require additional information to verify your authority to act on behalf of the California resident.
Our Process for Verifying a Request to Know, Delete, and/or Correct
We will comply with your request upon verification of your identity and, to the extent applicable, the identity of the California resident on whose behalf you are making such request. We will verify your identity either to a “reasonable degree of certainty” or a “reasonably high degree of certainty” depending on the sensitivity of the Personal Information and the risk of harm to you by unauthorized disclosure, deletion, or correction as applicable. To do so, we will ask you to verify data points based on information we have in our records concerning you.
Shine the Light Law
We do not disclose personal information obtained through our Site or Services to third parties for their direct marketing purposes. Accordingly, we have no obligations under California Civil Code § 1798.83.