Privacy Policy


Welcome to A-Storage Group Inc. and our website at www.astoragehub.com (our “website”). This Privacy Policy explains which Personal Data we collect from you via our website, what we use it for, when we delete it and how your data is protected.

www.astoragehub.com is operated and maintained by A-Storage Group Inc., 13744 Excelsior Dr, Santa Fe Springs, CA 90670 (“A-Storage Group”, “we”, “us”, “our”). If you want to contact us or if you have any questions, you can reach us by email using info@astoragehub.com, call +1 213 503 8766 or write to us at the above address.



WHY DO WE HAVE A PRIVACY POLICY?

We will only use your Personal Data in accordance with the applicable data protection laws, in particular the California Consumer Privacy Act (“CCPA”) including its subsequent amendments from the California Privacy Rights and Enforcement Act (“CPRA”) and the EU's General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.



WHAT IS PERSONAL DATA?

Personal Data is information that makes it possible to identify a natural person. This includes, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.



WHAT IS PROCESSING?

"Processing" means and covers virtually any handling of data.



WHEN CAN WE PROCESS YOUR PERSONAL DATA?

All Personal Data that we obtain from you will only be processed for the purposes described in more detail below. In particular, we collect Personal Data only if:


    ● you have given your consent;
    ● the data is necessary for the fulfillment of a contract / pre-contractual measures;
    ● the data is necessary for the fulfillment of a legal obligation; or
    ● the data is necessary to protect the legitimate interests of our company and business.

We process and store your Personal Data only for the period of time required to achieve the respective processing purpose or for as long as a legal retention period exists (in particular commercial and tax law in accordance with California’s Commercial Law and Revenue and Taxation Code and others for up to 4 years. Once the purpose has been achieved or the retention period has expired, the corresponding data is routinely deleted.



DATA TRANSFERS

In certain cases, it is necessary to transmit the processed Personal Data in the course of data processing. In this respect, there are different recipient bodies and categories of recipients.


    a) Internal

If necessary, we transfer your Personal Data within A-Storage Group. Of course, we comply with the associated legal framework and ensure that your data is processed properly. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job, e.g., to fulfill your order or to contact you in case of queries.


    b) External bodies

Personal Data is transferred to our service providers involved in the operation of our website and business and in the following instances:


    ● to use marketing services and to advertise our products online,
    ● to communicate with you,
    ● to provide our website and services, and
    ● to state authorities and institutions as far as this is required or necessary.

We usually do not transfer Personal Data to countries outside California or the USA. However, if we do, we ensure that the processing of your Personal Data is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection.



SECURITY OF YOUR DATA

Our website is hosted on servers in the USA. We employ appropriate security measures to help protect your Personal Data and guard against access by unauthorized persons. Data storage is on secure computers in a locked and certified data center and information is encrypted wherever possible. We undergo periodic reviews of our security policies and procedures to ensure that our systems are secure and protected. However, as the transmission of information via the Internet is not completely secure we cannot guarantee the security of your information transmitted to our websites.



YOUR RIGHTS AND PRIVILEGES

    a) Privacy rights

Under the CCPA and the CPRA amendment, you can exercise the following rights:

    ● Right to Know/Access
    ● Right to Delete
    ● Right to Opt-out of Sale
    ● Right to Non-Discrimination
    ● Right to Rectification
    ● Right to Limit Use and Disclosure of Sensitive Personal Information

Further, California’s “Shine the Light” law (Civil Code Section 1798.83) requires us to respond to requests from California asking about the business’s practices related to disclosing Personal Data to third parties for the third parties’ direct marketing purposes. You may make a request about our collection and disclosure of your Personal Data using the contact details provided.

Under the GDPR, you can exercise the following rights:

    ● Right to access;
    ● Right to rectification;
    ● Right to erasure;
    ● Right to restrict processing;
    ● Right to object to processing;
    ● Right to data portability;


    b) Updating your information, withdrawing your consent and objecting

If you believe that the information we hold about you is inaccurate or request its rectification, deletion, or object to its processing, please do so by contacting us.


    c) Access Request

In the event you want to make a Data Subject Access Request, please contact us. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days, we will tell you why and when we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we will tell you why.


    d) Complaint to a supervisory authority

You have the right to lodge a complaint about our processing of Personal Data with a supervisory authority responsible for data protection. In California this is the California Privacy Protection Agency, https://www.cppa.ca.gov. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.

    e) What we do not do     ● We do not request Personal Data from minors and children;
    ● We do not process Special Category Data without specific and expressly given consent;
    ● We do not use Automated decision-making including profiling;
    ● We do not sell your Personal Data.



PURPOSES OF USE OF PERSONAL DATA AND LEGAL BASIS
    a) Hosting

The hosting service used by us for the purpose of operating our website is Hostchain. In doing so Hostchain, processes inventory data, contact data, content data, contract data, usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests in an efficient and secure provision of the website and services in conjunction with the provision of contractual services.


    b) Collection of access data and log files

We, or rather Hostchain, collect data on every access to our website on the basis of our legitimate interest. The access data includes the name of the website accessed, file, date and time of access, amount of data transferred, notification of successful access, browser type and version, the user's operating system, referrer URL (the previously visited page), IP address and the requesting provider. Log file information is stored for security reasons (e.g., for the clarification of abuse or fraud) for a few days only and then deleted. Data whose further storage is necessary for evidentiary purposes is exempt from deletion until the respective incident is finally clarified.


    c) Cookies

For the processing of personal data using cookies and similar technologies on our website, please refer to our Cookie Policy. The legal basis for the use of cookies is our legitimate interest or your consent when you agree to the use of technically non-essential cookies as further explained in our cookie policy.


    d) Cookie consent

As set out in the CCPA/CPRA and the EU’s Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of technically non-essential cookies. For this purpose, we use a cookie consent tool, to obtain your consent to the storage of cookies and to document this consent. When you enter our website, the following Personal Data is transferred to us via our cookie consent tool: i) Your consent(s) or revocation of your consent(s); ii) Your IP address; iii) Information about your browser; iv) Information about your device; v) Time of your visit to our website. The basis for processing is our legitimate interest and your consent.


     e) Analytics

For business reasons, we analyze the data we have on web and server traffic patterns, website interactions, browsing behavior etc. The analyses serve us alone and are not disclosed externally and processed using anonymous analyses with summarized and or anonymized values. For this purpose, we use Google Analytics. The legal basis is our legitimate interest and your consent. For further information, please refer to our Cookie Policy.


    f) Fonts

We use Google Fonts by Google LLC on our website to display external fonts. To enable the display of certain fonts on our website, a connection to a Google server is established when our website is accessed. The connection to Google established when you visit our website enables Google to determine which website sent your request and to which IP address the display of the font is to be transmitted. This represents a legitimate interest.


    g) reCAPTCHA

We also use Google's reCAPTCHA from Google to check whether data input is made by a human being or by an automated program. For this purpose, reCAPTCHA analyzes the behavior of the website visitor on the basis of various characteristics. This analysis begins automatically as soon as the website visitor enters the website. The legal basis for using reCAPTCHA is our legitimate interest.


    h) Google Tag Manager

We also use Google Tag Manager. Google Tag Manager is a solution enabling us to administer website tags via an interface. Google Tag Manager itself, which implements the tags, is a cookie-free domain and does not record any personal data. However, the tool triggers other tags that may record your Personal Data. Google Tag Manager itself does not access this data. If you refuse Analytical/Performance and/ or Marketing & Social Media Cookies, Google Tag Manager remains in place. The legal basis for the processing is our legitimate interest.


    i) Contact options

We process and store the Personal Data provided in the contact enquiry solely for the purpose of processing and responding to your enquiry and contacting you. If you contact us, we will process the data you provide to respond to you and answer your questions and requests. In doing so, the principle of data economy and data avoidance is observed in that you only have to provide the data that we absolutely need from you in order to contact you. These are usually your first and last name, your email address, the topic selection and the message field itself. In addition, your IP address is processed out of technical necessity and for legal protection. The legal basis for processing is our legitimate interest, the provision or initiation of a contractual service and your consent.


    j) Using our services

We process the Personal Data involved in your use of our warehouse, shipping, receiving and storage services in order to be able to provide our contractual services. The Personal Data obtained from or provided by you depends on how you are using our services and your particular requirements and may include your contact details, contract details, payment information and data relating to your preferences. This includes in particular our support, correspondence with you, invoicing, fulfillment of our contractual obligations. Accordingly, the data is processed on the basis of fulfilling our contractual obligations and our legal obligations and in individual cases, your consent.


    k) User account

It is also possible for you to register for an account. For this purpose, you can choose a password together with your email address/ username, both of which will enable you to log in more easily without having to enter your data again when you make a future purchase or to access your order history. We will hold your data for further orders as long as you are using our services.


    l) Data of your Clients/Customers

If you wish to use our warehouse, shipping, receiving and storage services, we process the data you or your clients/customers provide. This may include Personal Data such as full name and delivery address or email address and telephone number, and other details you or your clients/customers voluntarily provide (“Service Data”). We recognize that you own your Service Data and provide you with complete control of your Service Data by providing you the ability to (i) access your Service Data, (ii) share your Service Data through supported third-party integrations, and (iii) request export or deletion of your Service Data.

When we process Service Data, we become your Data Processor or in other words, we will process the Service Data involved in your use of our services in accordance with your instructions and shall use it only for the purposes agreed between you and us. We ensure that access by our employees to your data is only available on a need-to-know basis, restricted to specific individuals, and is logged and audited. We communicate our privacy and security guidelines to our employees and enforce privacy and protection safeguards strictly.

Some jurisdictions may require you to disclose your use of our services as your processor in your privacy policy and/or data processing agreement as applicable. For this purpose, all Service Data processed by us will be processed using a dedicated Hostchain server and take appropriate legal precautions and corresponding technical and organizational measures to ensure the protection of your Service Data.

We and you agree that the 2021 Standard contractual clauses for international transfers will apply to personal data that is transferred to us from the UK, European Economic Area or Switzerland, either directly or via onward transfer.

Further, and if you are providing us with Personal Data relating to a third party, you agree a) that you have in place all necessary appropriate consents and b) that such third party has read this Privacy Policy. You agree to indemnify us in relation to all and any liabilities, penalties, fines, awards, or costs arising from your non-compliance with these requirements.

The legal basis for the processing of your Service Data is our obligation to fulfill the contract we have with you.


    m) Administration, financial accounting, office organization, contact management

We process data in the context of administrative tasks as well as organization of our business, and compliance with legal obligations, such as archiving and invoicing using the services of QuickBooks (Intuit Inc.). In this regard, we process the same data that we process in the course of providing our contractual services. The processing bases are our legal obligations and our legitimate interest.


    n) Promotional use of your data

We use your data within the legally permissible scope for marketing purposes, e.g., to draw your attention to special promotions and discount offers. In addition, we may draw your attention to comparable offers by email, e.g., we may inform you about exclusive sales, promotions, or special events. The legal basis for processing is our legitimate interest.


    o) Advertising

We may work together with advertising partners who help us to make our internet offer more interesting for you. For this purpose, cookies from partner companies are also stored on your hard drive when you visit our website (third-party cookies). In terms of advertising, we adhere to the Digital Advertising Alliance’s AdChoices program principles. For further details and opt-out options, please refer to our Cookie Policy.



SOCIAL MEDIA
    a) General

We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The Personal Data collected when contacting us is to handle your request and the bases are both your consent and our legitimate interest.


    b) Market research and advertising

In addition, your data may be processed for market research and advertising purposes. For example, usage profiles can be created from your usage behavior and the resulting interests. This allows, for example, advertisements to be placed within and outside the platforms that presumably correspond to your interests. The legal basis is our legitimate interest.


    c) When you visit our profiles and interact with us and others

When you visit our social media profiles, we, as the operator of the profile, process your actions and interactions with our profile (e.g., the content of your messages, enquiries, posts or comments that you send to us or leave on our profile or when you like or share our posts) as well as your publicly viewable profile data (e.g., your name and profile picture). Which Personal Data from your profile is publicly viewable depends on your profile settings, which you can adjust yourself in the settings of your social media account. The legal basis is our legitimate interest and your consent.

OTHER USA SPECIFIC PROVISIONS

The following applies to users located in other parts of the United States. While we understand and appreciate that privacy and consumer data protection laws differ as they are subject to each state's legislature and that no data protection framework similar to the CCPA/CPRA or GDPR exists on a federal level, we are committed to follow and apply the for your state relevant privacy rules and regulations.

As of the day of drafting, the following states had enacted privacy and consumer data protection laws:

    ● Colorado Privacy Act (“CPA”);
    ● Connecticut Data Privacy Act (“CTDPA”);
    ● Delaware Personal Data Privacy Act (“DPDPA”);
    ● Indiana Consumer Data Protection Act (“ICDPA”);
    ● Iowa Consumer Data Protection Act (“ICDPA”);
    ● Montana Consumer Data Privacy Act (“MCDPA”);
    ● Oregon Consumer Privacy Act (“OCPA”);
    ● Tennessee Information Protection Act (“TIPA”);
    ● Texas Data Privacy and Security Act (“TDPSA”)
    ● Utah Consumer Privacy Act (“UCPA”); and
    ● Virginia Consumer Data Protection Act (“VCDPA”).

Further and under consideration of the similarities of the above provisions, no conflict should arise pursuing a uniform approach in granting all users in the USA the same rights and privileges as set out above. However, should ambiguity occur the most stringent provision is chosen to ensure the most comprehensive approach when it comes to protecting your Personal Data.

Further, the following also apply

    i) COPPA (Children Online Privacy Protection Act)

When it comes to the collection of Personal Data from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under the age of 13 years old.

    ii) CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. To be in accordance with CAN SPAM, we agree to the following: If at any time you would like to unsubscribe from receiving future emails, you can email us, and we will promptly remove you from ALL correspondence.

    iii) Telephone Consumer Protection Act (TCPA)

If we process your Personal Data for the purpose of sending you SMS marketing communications, you may manage your receipt of marketing and non-transactional communications from us by replying or texting ‘STOP’ if you receive our SMS communications. In this respect, the data processing is carried out solely on the basis of our consent in personalized direct advertising per SMS.

    iv) Controls For Do-Not-Track Features

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, our website does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Notice.

    v) Right to complain

Finally, and in regard to the right to complain to a supervisory authority. You have the right to lodge a complaint about our processing of Personal Data with a supervisory authority responsible for data protection. Users based in the above-mentioned States may lodge a complaint with the relevant district attorney or attorney general office. However, we would appreciate the opportunity to address your concerns before you contact any supervisory authority.



HOW DO WE MAKE CHANGES TO THIS POLICY?

We may change our Privacy Policy from time to time. When we change our Privacy Policy, we will publish the updated policy on our website. Please check this Privacy Policy regularly. Subject to applicable law, all changes will take effect as soon as we publish the new Privacy Policy, but where we have already collected information about you and/or where legally required to do so, we may take additional steps to inform you of any material changes to our Privacy Policy and may request that you agree to these changes.



EFFECTIVE DATE

Thursday, June 6th, 2024