American Tower Corporation and each of its wholly-owned affiliates and subsidiaries (collectively, "American Tower") pays particular attention to the protection of your personal data, and treats the collection and processing of such personal data in accordance with applicable law. Personal data refers to any information that identifies you, directly or indirectly, by reference to one or more elements that are unique to you, or by cross-checking information and this notice sets forth the general framework for American Tower’s handling of personal data.

The commitment of American Tower

As a controller, American Tower may collect and handle the personal data of its employees, landlords, and certain other parties, as applicable, and shall do so in a fair and transparent manner. American Tower is committed to ensuring the security and confidentiality of the personal data entrusted to it.

Scope of this policy

This notice is intended for all landlords, employees, and other natural persons from whom American Tower receives personal data. It applies only to those activities for which American Tower is a controller or processor, in accordance with applicable law.

What is the applicable law?

American Tower is subject to the rules of the various jurisdictions in which it handles personal data including, but not limited to, the Massachusetts Data Privacy Act and the General Regulation on the Protection of Personal Data 2016/679 of April 27, 2016 (directly applicable from May 25, 2018) (“GDPR”), and the California Consumer Protection Act (“CCPA”).

What data is collected?

The data collected by American Tower is limited to the data necessary for the purposes pursued as described below. These data may include, but are not limited to: identification and contact data (surname, first name, professional and / or personal address, date of birth, telephone number, e-mail address and other contact details available by the persons concerned, data relating to the monitoring of the commercial relationship, the financial and economic status, transactions and means of payment, the payment of invoices, your opinions on American Tower’s products and services, and data resulting from the exercise of your rights.

What are the legal purposes and grounds for the processing of personal data?

In general, personal data are processed by American Tower in the context of the management of the administrative or commercial operations related to the relations with its landlords or employees.

The processing carried out by American Tower is either (i) necessary for the execution of a contract or in order to take steps at a data subject’s request prior to entering into a contract, (ii) based on your prior consent, or (iii) necessary for the compliance with legal obligation to which American Tower is subject. In the absence of such treatment, the actions referred to above could not be properly implemented by American Tower.

Recipients of the data

Only the recipients duly authorized by American Tower by reason of their job requirements will be able to access the personal data concerning you, without prejudice of their possible transmission to the bodies in charge of a control mission or inspection in accordance with the applicable regulation.

Is personal data shared internationally?

Due to American Tower’s global reach, some personal data processed are shared outside of its country of origin including, for data from the European Economic Area, with the United States. This sharing is carried out within the limits necessary for the accomplishment of the aforementioned purposes, and in compliance with the regulations in force.

Non-disclosure of data

American Tower does not sell, rent, share or otherwise distribute personal data to third parties, including providers or other partners, unless the applicable law so requires; provided, however that these data may occasionally be transmitted to third parties in accordance with the purposes for which they were collected. Where the disclosure of personal data to third parties is necessary for such purposes, American Tower shall ensure, as controller, that such third parties guarantee to the data concerned the same level of protection as that offered to them by American Tower, and requires contractual guarantees so that, in particular, the data are exclusively processed for the purposes previously authorized by you, with all the confidentiality and security required.

Is personal data stored securely?

We put in place technical and organizational measures to ensure that your personal data is kept as secure as possible for the time necessary to fulfill the purposes pursued in accordance with the applicable law.

Exercising your rights regarding your personal data

Under certain applicable laws, you may have, under certain conditions and without limitation, a right of access, opposition, and withdrawal of your consent to the processing of personal data, in addition to rights of limitation, rectification, portability and erasure which you can exercise at any time by sending an email to privacy.officer@americantower.com.

American Tower will do its best to respond to your request as soon as possible and in any event within thirty (30) days of receipt of your request. If necessary, this period may be extended, given the complexity and the number of requests.

In addition, under the applicable regulations, you have the right to lodge a complaint with the applicable supervisory authority.

Applicable law and competent court

In the event of a dispute and in the event that an amicable agreement cannot be reached with respect to the subject matter set forth herein, the competent court will be the one determined according to the applicable rules of procedure.

You may contact American Tower for any purpose concerning this Privacy Notice by emailing the Privacy Department at privacy@americantower.com or contacting the Privacy Department at +1-617-375-7500, in the United States toll-free at 1-877-282-7483 or 116 Huntington Avenue, 11th Floor, Boston, MA 02116.

Privacy Policy

American Tower offers on this web site a variety of materials, information, and online services targeted to wireless communications carriers, broadcasters, vendors, customer, and partners. American Tower values your privacy and any information it collects is considered private and is not shared with other organizations. American Tower uses the information to improve the quality of information and services contained in this web site, or to communicate with you directly about specific industry information or special announcements. This policy statement explains American Tower’s use and care of any personal information received from you the users of this web site.

Collection and Use of Personal Information

You have a right to use this web site without identifying yourself unless you choose to do so. American Tower may solicit information from you in several areas of this web site including the log-in areas, service-specific features, the adding and editing of tower site listings, e-mail forms, and any surveys or contests that American Tower may hold. American Tower will assume that you have the right to give us the information about yourself or others that you choose to provide in response to American Tower’s solicitation.

American Tower may track the IP address of your computer or place a "cookie" in the browser files of your computer. Collected information helps American Tower better understand its web site users’ needs and improve product and service offerings. E-mail addresses are used to communicate periodic announcements and for other notification purposes. Personal information may be used to contact you for the purpose of research, product development, marketing, or customer service. You may be removed from any e-mail or direct mail list at your request by contacting the web site administrator by e-mail at privacy.officer@americantower.com. IP address and cookie log data is regularly analyzed to generate information pertaining to user trends and feature usage. This information is used to plan web site enhancements, and to measure overall site effectiveness.

Security of Personal Information

Your personal information deserves to be treated with the utmost respect. Personal information collected on this web site may be stored and processed in the United States or any other country in which American Tower or its service providers keep an office. American Tower will take commercially reasonable precautions to secure your personal information within its or its service providers’ computer systems and physical premises and to hold it as confidential and proprietary. American Tower will not release personal information to third parties other than as may be required by law.

Confidentiality Statement

Unless explicitly stated to the contrary on this web site, American Tower uses all collected information only for internal purposes and does not share, sell, rent or lease identifiable user information to any third party. American Tower may, from time to time, reveal general, aggregated or statistical information about its web site’s services, users or clients, such as the total number of users and clients and what site features are used, but will not make reference to any user or client by name or address or any other specific identifier without prior written permission. American Tower disclaims responsibility for the privacy practices of third party web sites that may be found by following links from this web site. For further information concerning access to web sites of third parties via the American Tower web site, please see the “Click Through Web Sites” section of American Tower’s Terms of Use Notice.

Cookies

A “cookie” is a small file or part of a file which American Tower creates and stores on your computer for a period of time. The cookies contain information about the things you do on this web site (such as a user identification code, customized preferences, or a record of pages visited) which is used by American Tower to provide you with automated features and/or customized materials or services. Most internet browsers allow you to refuse to accept cookies if you wish to do so. Please refer to your browser’s help function for more information. Be aware that at least some of the functionality of the American Tower web site will not be available if you set your browser to refuse cookies.

Online Advertising

American Tower does not allow third party advertising on its web site. Unless otherwise explicitly stated to the contrary on the web site, no information collected on this web site will be used for the purpose of targeting third party advertising, nor will any such information be provided to any third party advertising firm.

Change Notice

American Tower reserves the right to change this Privacy Notice at any time. The most current version of the Privacy Notice is always the version that is published on this web site.

The Terms of Use Notice

Please also refer to the Terms of Use Notice elsewhere on this web site. That notice governs your usage of this web site.

American Tower is committed to protecting the confidentiality, integrity, and availability of information, and meeting legal and regulatory security requirements. Our information security management system is the engine for continually assuring the protection of information and meeting our security objectives in accordance with the controls in the scope of our ISO 27001 certification.

• An information security management system defines and manages the security controls to protect the confidentiality, integrity, and availability of assets from threats and vulnerabilities.

• If you would like more information about the American Tower information security management system, its scope, and the statement of applicability, please contact information.security@americantower.com