Triton International Limited
privacy policy

This Privacy Notice covers all personal information collected and used by us in relation to your use of our websites that are designed for clients and potential clients of the Triton family of companies, as well as other business partners and intermediaries, such as depots, transportation service providers and equipment manufacturers, and in other ways you (or a person on your behalf) interact with us, such as when we are supplied with your business contact details. In this Privacy Notice, "personal data" or "personal information" means information that (either in isolation or in combination with other information) enables you to be identified as an individual or recognised directly or indirectly. This may include your name, company name, postal address, email address, phone number, where you are based or obtaining our products or services from, details of the preferences you express to us, your comments and questions, and technical information from the devices you use to access our websites.

We (and our service providers) may collect personal information (such as your name, postal and email address, telephone and fax number, company, preferences, comments and questions) from you when you:

• obtain or lease equipment from us, typically in your capacity as a representative of your company;
• submit any information through our websites;
• create an account with us, register for use of one of our websites or otherwise sign up for a service;
• opt in or consent to receive marketing or communications from us, including through one of our third-party partners;
• communicate with us via social media websites;
• contact us, correspond with us, or otherwise provide information to us; or
• have your information supplied to us, typically in your capacity as a representative of your company.

In some cases, you may provide personal information to us about another person. In such cases, you should only do so if you have the authorisation of such person to provide us with this information and for us to use this information as explained in this Privacy Notice.

When you are registering to access a website for the first time with an email address that you have previously provided to us in another circumstance (e.g., when signing up for a subscription-based service), we may recognise that email address and, once you have completed the online registration process, you may be able to see some of your personal information already included in your new website registration profile. This typically happens because we recognise your email address and, for your convenience, add your information to your online registration. You can always change this information by signing into your online account.

We also work closely with third parties (such as business partners, sub-contractors, analytics providers, search information providers, and industry bodies), and may receive demographic and other personal information about you from those third parties, which we may combine with the information you have provided to us. We process all data we obtain from such other sources in accordance with this Privacy Notice.

When you visit our websites, we (and our service providers) may use cookies and other technologies to automatically collect the following information:

• Technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors;
• information about your visit, including the websites you visit before our websites and products or services you viewed or searched for;
• number of visits, length of visits to certain pages, pages viewed, page interaction information (such as scrolling, clicks and mouse overs) and methods used to browse away from the page; and

To learn more about how we use cookies and how to accept and control which cookies are used, please see our Cookies Policy.

We use the personal information we collect from and about you for a variety of purposes and based on one or more legal justifications, as set out below:

The provision of your personal data is necessary when data is needed for the purposes of entering into or servicing a contract that a company has with us or to receive the products or services or information you or your company request, or to comply with applicable laws and regulations. Refusal to provide your information would make it impossible for us to provide the products, services or information requested and to fulfill our contract obligations.

The provision of your personal data is voluntary for any marketing and profiling activities. Marketing will be performed through email and telephone. You may object to receiving of marketing communications at any time through all or only some of the communications methods mentioned above. If you do not wish to provide your personal data to us for these purposes, this will have no consequences.

Your personal information is intended for Triton and may be shared with its affiliates and subsidiaries and third parties in certain circumstances.

Our websites may, from time to time, contain links to and from the websites of our partners, or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we have no control over how they may use your personal information. You should check the privacy notices of third party websites before you submit any personal information to them.

We may share your personal information with the following third party organisations:

• Triton's family of companies. We may share your personal information among our family of companies, including our subsidiaries and affiliates, in order to administer our services and products and provide you with customer support. With your consent, which is optional, we may share data to understand your preferences, send you information about products and services that may be of interest to you, and conduct the other activities described in this Privacy Notice.
• External Auditors.
• Our service providers. We use other companies or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of Triton products or services to you. We may share personal information with the following categories of Service Provider:
  • Infrastructure and IT service providers;
  • Marketing, advertising, analysis, research, event and communications providers.
  In the course of providing such services, these Service Providers may have access to your personal information. However, we will only provide our Service Providers with the information that is necessary for them to perform the services, they will act under our instructions and we ask them not to use your personal information for any other purpose. We will always use our best efforts to ensure that all the Service Providers we work with will keep your personal information secure.
• Third parties permitted by law. In certain circumstances, we may be required to disclose or share your personal information in order to comply with a legal or regulatory obligation (for example, we may be required to disclose personal information to the police, regulators, government agencies or to judicial or administrative authorities). We may also disclose your personal information to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our agreements or protect your rights or those of the public.
• Your company and other third parties connected with your company or its account.We may transfer your personal information to your company, such as when you are included on an email with others or to confirm your details or role with your company. We also may transfer your information to third parties connected with your company or its account, such as hauliers, engineers and depots. We take these actions as needed in light of your role as a representative of your company.
• Third parties connected with business transfers. We may transfer your personal information to third parties (including existing or newly-formed companies in the Triton family of companies) in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your personal information in a manner consistent with this Privacy Notice.

The personal information that we collect from you may be transferred to, and stored at, a destination outside the jurisdiction in which you are located.

If you are located in the European Economic Area ("EEA") or the United Kingdom (“UK”), this means the personal information may be transferred to, and stored at, a destination outside the EEA or UK, including to Triton Container International, Incorporated of North America in New York, USA. It may also be processed by staff operating outside the EEA or UK and who work for us, an affiliate or for one of our Service Providers. If you are located outside the EEA or UK, in addition to the above, this means that personal information may be transferred to, and stored at, a destination in the EEA or UK.

For transfers outside the EEA or UK, Triton will be bound by the EU Standard Data Protection Clauses which the European Commission has assessed as providing an adequate level of protection for personal data (or other appropriate safeguards under EU or UK data protection laws as appropriate), to ensure that your data is protected adequately.

You can ask for a copy of such appropriate safeguards by contacting us as set out below (Contact Us).

You have various rights in connection with our processing of your personal information, each of which is explained below. If you wish to exercise one or more of the below rights, please contact us with your request at privacy@trtn.com and include your name, email and postal address, as well as your specific request and any other information we may need in order to provide or otherwise process your request.

• Access. You may have the right to confirm with us whether your personal data is processed, and if it is, to request access to that personal data including the categories of personal data processed, the purpose of the processing and the recipients or categories of recipients. We do have to take into account the interests of others though, so this is not an absolute right, and if you want to request more than one copy we may charge a fee.
• Rectification. You may have the right to rectify inaccurate or incomplete personal data concerning you.
• Deletion. You may have the right to ask us to erase personal data concerning you, except we are not obligated to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
• Restriction. In limited circumstances, you may have the right to request that we restrict processing of your personal data. This may apply where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it. In such case, we would mark stored personal information with the aim of limiting particular processing for particular purposes in accordance with your request, or otherwise restrict its processing.
• Portability. You may have the right to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity.
• Objection. Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data, including profiling, by us and we can be required to no longer process your personal data. This may include requesting human intervention in relation to an automated decision so that you can express your view and to contest the decision.
• Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time. If you would like to withdraw consent, including if you would like to opt out of receiving marketing correspondence from us, please contact us at privacy@trtn.com or for marketing follow the opt out instructions located in the email or the unsubscribe instructions on the website you used to subscribe to specific content (as relevant). Please understand that if you opt out of or unsubscribe from receiving promotional correspondence from us, we may still contact you in connection with an account, relationship, activities, and communications with us. Additionally, if you do request that we stop sharing your personal information with third parties for their direct marketing purposes, it is also prudent you opt out from or contact that third party directly.
• Make a Complaint. You have the right to lodge a complaint with the local data protection authority if you believe that we have not complied with applicable data protection laws.

If you are based in, or the issue relates to, the UK, the Information Commissioner’s Office can be contacted as follows:

Telephone: +44 0303 123 1113
Email: casework@ico.org.uk
Website: www.ico.org.uk
Web-form: www.ico.org.uk/concerns/
Address: Water Lane, Wycliffe House, Wilmslow, Cheshire, SK9 5AF

If you are based in, or the issue you would like to complain about took place elsewhere in the European Economic Area (EEA) or Switzerland, please click here for a list of local data protection authorities in the countries within the EEA in which we operate.

Note that the rights outlined above only extend to personal information.

We will only retain your personal data for as long as it is necessary for the purpose for which that data was collected and to the extent permitted by applicable laws. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to promptly anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject). Personal data contained in contracts, communications, and business letters may be subject to statutory retention requirements, which may require retention of up to 10 years. Other personal data will in principle be deleted 7 years after the termination of the contract relationship.

We have implemented technical and organisational security measures in an effort to safeguard personal information in our custody and control. Such measures we have implemented include, limiting access to personal information only to employees, contractors and authorised Service Providers who need to know such information for the purposes described in this Privacy Notice, training for our employees and contractors, as well as other technical, administrative and physical safeguards.

While we endeavour to always protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.

To access some content on our websites, you are required to register and establish a username and password. You are responsible for maintaining the confidentiality of your online credentials, and we strongly recommend that you do not disclose your username or password to anyone. We will never ask you for your password in any unsolicited communication. Please notify us immediately (see Contact Us section below) of any unauthorised use of your online credentials or any other suspected breach of security.

This Privacy Notice is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.

We reserve the right to change our Privacy Notice from time to time. If we decide to make a material change to our Privacy Notice, we will endeavour to make you aware of that fact by, for example, notifying you of these changes via email and/or posting an alert on the home page of a relevant website and/or take any further action as required by applicable law.

This California Privacy Notice explains how Triton Container International Incorporated collects and processes personal information about California residents who are customers, clients or potential clients, potential investors, and other business partners and intermediaries who visit Triton Web sites, mobile apps, or digital applications (collectively, our “Site(s)”) that display or link to this California Privacy Notice.

California Personal Information. Depending on your online and offline interactions with us, Triton may collect and process the following categories of personal information ("California Personal Information"):

• Contact Details, including name, postal address, telephone number, fax number, email address;
• Professional information, including organization information and company name, where you are based or obtaining our products or services from;
• Internet or other electronic network activity information, including your interactions with our Sites, login information, IP address, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times and download errors;
• Inferences drawn from the information collected.

Triton does not collect Sensitive Personal Information, as this term is defined under California law.

Sources. Triton generally sources the categories of California Personal Information identified above directly from you (for instance, when you provide information as part of a business transaction or otherwise) or from third parties, such as business partners and analytics providers.

We do not knowingly share the California Personal Information of individuals under 16 years of age, in a manner that constitutes a "sale" under California law.

Purposes of use. Triton uses California Personal Information for:

• Business purposes, including:
• Managing Triton accounts and records;
• Operating the Triton website, including the use of analytics software;
• Facilitating the security of Triton sites, websites and other assets;
• Legal and regulatory compliance and internal control evaluations and audits;
• Obtaining legal advice, including for legal proceedings and litigation and also in connection with the sale, purchase or merger of a business;
• To provide the products, information and services you request;
• For security, credit or fraud prevention purposes;
• To provide you with effective customer service;
• To contact you as you have requested;
• To improve the content, functionality and usability of our Sites;
• To understand your preferences and provide you with a more personalized experience;
• To notify you about changes to our services;
• To improve our products and services; and
• For any other purpose identified in an applicable Privacy Notice or other agreement between Triton and you.
• Commercial purposes, including:
• Advertising and marketing (including direct marketing);
• To display personalized advertising when you visit our Sites or a third party website;
• To contact you with special offers and other information we believe will be of interest to you;
• To invite you to participate in surveys and provide feedback to us;
• To better understand your needs and interests; and
• To improve our marketing and promotional efforts.

Disclosure of California Personal Information.

• We may disclose the categories of California Personal Information described above for the business purposes described above to:
• Triton subsidiaries and affiliates in order to administer our services and products and provide you with customer support;
• Third party service providers that perform data processing activities on our behalf, and subject to appropriate privacy and security obligations;
• Third parties connected with your company or its account, such as engineers and depots;
• External auditors;
• Government and other authorities as required by law;
• Potential purchasers and other parties in connection with the sale, purchase or merger of a business; and
• Others to the extent necessary to comply with applicable law and as otherwise permitted under California Privacy Law.
• We may disclose Identifiers and Internet or other electronic network activity information for the commercial purposes described above to:
• Third party service providers;
• Social media and ad networks.

Retention of California Personal Information. Triton retains your California Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained. Triton establishes policies and procedures for the retention of records for an appropriate duration, including retention schedules for categories of records. Retention categories may include records which contain California Personal Information, including identifiers, customer records information, commercial information, professional information. The length of time California Personal Information is retained will vary depending on the retention period of the category in which such Personal Information is contained.

Your Rights. Subject to certain exceptions detailed in California Privacy Law, as a California resident, you have the right to request: (i) deletion of your California Personal Information; (ii) correction of inaccurate California Personal Information; (iii) the right to know/ access the categories of California Personal Information that we collect about you, including the specific pieces of California Personal Information; (iv) the categories of California Personal Information disclosed for a business purpose; and (v) information about the categories of California Personal Information about you that we have shared (as such term is defined under California Privacy Law) and the categories of third parties to whom the California Personal Information was shared.

Exercising Your Rights. If you are a California resident and wish to request the exercise of these rights as detailed above or have questions regarding the California Personal Information collected or shared with third parties, please see the “Contact Us” section below if you have questions, click Privacy@trtn.com or call us toll free at [+1-888-512-2667]. When submitting your request, please include the specific nature of your request, referencing "Your California Privacy Rights," as well as your first and last name, email address, and zip code or mailing address. Triton may apply any exceptions or other conditions available under law when responding to correction, deletion, or other requests.

Do Not Sell or Share My Information. In addition to the above, California residents have the right to opt-out of the selling or sharing of their California Personal Information, as such terms are defined under California Privacy Law. To exercise this right, please contact us as described below. We do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to one of our Sites. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request.

Authorized Agents. To the extent that you elect to designate an authorized agent to make a request on your behalf, they must provide appropriate documentation including written signed permission from you, proof of your identity, and verification of their identity; or a valid, designated power of attorney as defined under the California Probate Code.

CA Shine the Light. Triton does not provide products for personal, family, or household use.

If you have any questions about this Privacy Notice and/or about the privacy policies and practices of our service providers, please contact us via email at privacy@trtn.com.

This Privacy Notice was updated May 2022.