Privacy Policy Last updated: 24/02/2024

At Atlas AI, we are committed to protecting your privacy and safeguarding your personal data. This Privacy Policy outlines how we collect, store, use, and share your information when you interact with our website and services.

We strive for transparency in all data-related operations and follow globally recognized standards, including those applicable under Australian law.

This policy applies to the website Atlas AI (the “Website”) and the services provided through it.

Our key privacy principles:

• Transparency and informed consent:

We ensure that you are fully aware of how your personal data is collected and used. You will always receive clear and timely information when interacting with our platform or any third-party investment tools we may connect you with.

• Purpose limitation:

We only process your data to deliver services, improve functionality, ensure security, and comply with relevant legal and regulatory obligations. Your data may also help us better tailor content and user experience.

• User rights and access:

You may contact us at any time to review, correct, delete, restrict, or export your personal data. We take these requests seriously and respond in accordance with privacy regulations.

• Data security:

While no system is immune to risk, we employ strict technical and organizational safeguards to help protect your information from unauthorized access, misuse, or loss.

Full Policy Overview

1. Scope

This Policy describes the categories of personal data we collect, how we use and share it, how we protect it, and your choices about our data practices.

“Personal Data” means any information that identifies or could reasonably identify you — directly or indirectly — when combined with other data we hold.

“Processing” includes actions such as collecting, storing, accessing, altering, using, disclosing, or deleting personal data.

Our services are intended for users aged 18 and older. We do not knowingly collect data from children, and we remove such information upon discovery.

2. When Do We Collect Your Data?

We collect personal data when you use the Atlas AI website, access services, submit forms, or interact with our partners. This includes both data you provide directly and data gathered from your activity and device.

3. Is Providing Data Mandatory?

You are not obligated to share your personal data. However, without it, certain services may not be available or function properly.

4. What Data Do We Collect?

- **Usage data**: IP address, access time, device type, browser info, error logs, page views. - **Voluntary data**: Information you submit through forms or third-party integrations (e.g., name, email, phone number). - **Transactional data**: Information submitted for investment-related purposes via third-party platforms.

5. The Objectives for Processing Personal Data and Their Legal Foundations

Atlas AI handles your Personal Data for one or more of the purposes detailed in this section, each backed by the appropriate legal grounds in Australia.

Atlas AI will not process your Personal Data unless there is a legitimate legal basis for such actions. The legal bases on which Atlas AI may handle your Personal Data include:

  • You have provided consent for the processing of your Personal Data for specific purposes. This applies when you deliberately share your information through the Website, allowing us to submit it to a third-party trading platform.
  • Processing is required to serve the legitimate interests pursued by Atlas AI or a third party. For example, this may include enhancing our Services or managing legal claims.
  • Processing is necessary to fulfill a legal obligation to which Atlas AI is subject.

If you need further clarification on how processing your Personal Data serves the legitimate interests of Atlas AI or another party, please don't hesitate to contact us via email at any time.

Below, we outline the reasons why we may process your Personal Data, along with the legal justifications for these activities:

6. Cookies and Third Party Services

We might utilize certain third-party services, like analytics companies or advertisement providers on our Website, which may also employ cookies or other technologies. These practices and providers are governed by their own policies and may comply with relevant Australian privacy laws.

A cookie, which is a small text file, is installed on the device you use to visit or access the Website. These cookies enable the collection of information about you and your behavior, to

enhance your user experience by remembering your preferences and settings, and by tailoring products and services that may capture your interest. Cookies might also be employed to gather statistics and perform analytics.

Some cookies we may use are session cookies, which are temporarily downloaded to your device and remain active until you close your web browser. Others are persistent cookies, which stay on your device after you stop browsing the Website, aiding the Website in recognizing you as a returning visitor.

Types of cookies:

The cookies we may utilize are categorized based on their functionality as follows:

Type of Cookie Purpose Additional Information
Strictly Necessary Cookies

These cookies are indispensable for enabling you to navigate the Website and access features you have requested. They ensure delivery of our content, products, and services you seek.

Such cookies are crucial for your device to download or stream information, allowing seamless navigation through the Website, utilization of its features, and revisiting previously accessed pages.

These cookies collect personal data about you, such as your username and last login date, and confirm your login status on the Website.

These cookies are automatically removed once you close your web browser (session cookies).

Functionality Cookies These cookies help us recognize you when you revisit the Website, enabling us to remember your selections and preferences. These cookies remain active even after your browser is closed, lasting until they reach their set expiration time.
Performance Cookies These cookies are essential for gathering aggregated statistics about the Website's performance, aiding in its testing and enhancement to deliver a superior user experience. They also allow us to perform analytical functions on the Website.

These cookies gather anonymized data that cannot be traced back to any identified or identifiable individual.

The validity of these cookies varies; some are erased when you close your browser, while others persist indefinitely.

Blocking and Removing Cookies

You can adjust your browser settings to block and eliminate some or all cookies. Below are links with instructions for doing this in some of the most widely-used web browsers:

  • Firefox
  • Microsoft Edge
  • Google Chrome
  • Safari

Please be aware that if you proceed, certain features and functionalities of the Website might not operate as expected.

ONLINE TRACKING NOTICE

AT THIS TIME, THIS SERVICE DOES NOT SUPPORT DO-NOT-TRACK SIGNALS.

7. Retention Of Personal Data About You

Atlas AI will retain your Personal Data as long as necessary to fulfill the purposes outlined in this Policy or as required by applicable laws, regulations, policies, and orders.

We will share your information with third-party trading platforms for a 12-month period and, subject to your consent, may extend this for an additional 12 months.

To ensure that your Personal Data is not held longer than necessary, we regularly review the data we retain to determine if any can be deleted.

8. Transfers of Personal Data To A Third Country Or An International Organization

Your Personal Data may be transferred to a third country or to international organizations. In such cases, Atlas AI will implement appropriate safeguards to ensure the protection of your Personal Data and provide enforceable data subject rights and effective legal remedies.

If you reside in the EEA (European Economic Area), please note that these protections and safeguards will be in place if any of the following conditions are met:

  • The transfer is directed to a third country or an international organization recognized by the EU Commission as offering an adequate level of protection for Personal Data, in accordance with Article 45(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council dated 27 April 2016 (commonly known as the "GDPR").
  • The transfer is executed under a legally binding and enforceable agreement between public authorities or bodies as outlined in Article 46(2)(a) of the GDPR; or
  • The transfer complies with standard data protection clauses adopted by the EU Commission in line with Article 46(2)(c) of the GDPR. You can view these clauses at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

If you're interested in learning about the safeguards we employ to protect the Personal Data transferred to a third country or an international organization, please reach out to us via email at: [email protected]

9. Protection Of Your Personal Data

We take the implementation of appropriate technical and organizational measures seriously to ensure a high level of security for Personal Data, considering the risks associated with processing, especially from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access to Personal Data that is transmitted, stored, or otherwise processed.

While we strive for perfection, we cannot promise error-free performance regarding the privacy of your Personal Data. We disclaim any liability for indirect, incidental, consequential, or punitive damages related to the use or release of your Personal Data, including but not limited to, disclosure of Personal Data due to transmission errors, unauthorized third-party access, or other causes beyond our reasonable control.

In some cases, legal or other obligations beyond our control may require us to transfer your Personal Data to third parties, entities like public authorities. In these scenarios, our control over the protection level offered to your Personal Data by such third parties is limited.

The transfer of Personal Data over the internet cannot be completely safeguarded. Consequently, Atlas AI cannot guarantee the security of your Personal Data when it is transmitted over the internet to us.

10. Links to Third-Party Websites

The Website might contain links to websites and/or applications operated by third parties. Atlas AI does not oversee these websites and applications, nor the gathering and/or processing of your Personal Data by them. We hold no responsibility for these websites and applications or their privacy and data protection policies and practices. This Policy does not govern any activities conducted through such websites and/or applications.

Whenever you visit these third-party websites and/or applications, we advise you to thoroughly examine their privacy policies before using them and before sharing any of your Personal Data.

11. Your Rights Regarding Your Personal Data

In general, you have the right to request that we confirm whether we are collecting Personal Data about you, to review this data, to correct any inaccuracies, and to delete Personal Data no longer needed by us. You can also limit your consent to specific processing of your Personal Information.

If you are a resident of the EEA, please review this section:

You have the following rights concerning your Personal Data. To exercise these rights, you may send a request to exercise your rights to the following email address:

Right of Access

You have the right to obtain from Atlas AI confirmation as to whether your Personal Data is being processed and, if so, to access the Personal Data along with the following details: (1) the objectives of processing; (2) the types of Personal Data involved; (3) the recipients or groups of recipients to whom the Personal Data has been or will be shared, particularly those in countries outside the European Economic Area (EEA) or with international organizations; (4) if feasible, the planned duration for storing the Personal Data, or if not feasible, the criteria used to determine that duration; (5) the existence of the right to request from Atlas AI the correction or deletion of Personal Data or the limitation of its processing, or to object to such processing; (6) the right to file a complaint with a supervisory authority; (7) if the Personal Data was not collected directly from you, any available information regarding its origin; (8) the existence of profiling; and (9) if Personal Data is transferred to a third country outside the EEA or to an international organization, the appropriate safeguards regarding the transfer.

Atlas AI will provide a copy of the Personal Data undergoing processing and may impose a reasonable fee for any additional copies you request. If your request is made electronically, and unless you specify otherwise, the information will be provided in a commonly used electronic format.

The right to obtain a copy of the Personal Data must not infringe on the rights and freedoms of others. Therefore, if the request compromises the rights and freedoms of others, Atlas AI may choose not to fulfill your request or to do so in a restricted manner.

Right to rectification

You are entitled to have Atlas AI correct any inaccurate Personal Data about you. Considering the purposes of processing, you have the right to have incomplete Personal Data about you completed, possibly by providing a supplementary statement.

Right to erasure

The following grounds apply: (a) the Personal Data is no longer needed for the purpose it was collected or otherwise processed; (b) you withdraw your consent on which the processing is based and there is no other legal basis for the processing; (c) you object at any time, on grounds relating to your specific situation, to the processing of Personal Data about you that is based on the legitimate interests pursued by us or by a third party, and there are no overriding legitimate grounds for the processing; (d) you object to the processing of Personal Data about you for direct marketing purposes; (e) the Personal Data has been processed unlawfully; or (f) the Personal Data concerning you must be deleted to comply with a legal obligation under European Union or Member State law applicable to the Company.

This right does not apply if the processing is necessary (a) to comply with a legal obligation requiring processing under European Union or Member State law to which the Company is subject; or (b) for establishing, exercising, or defending legal claims.

Right to Restrict Processing

You have the right to request that the Company restricts the processing of your Personal Data under the following circumstances: (a) if you dispute the accuracy of the Personal Data, for a period that allows the Company to verify its accuracy; (b) if the processing is unlawful and you oppose erasure, opting instead to restrict its use; (c) if the Company no longer requires your Personal Data for processing purposes, but you need it to establish, exercise, or defend legal claims; (d) if the processing is necessary for the legitimate interests pursued by the Company or a third party, unless we can demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, or for establishing, exercising, or defending legal claims; or (e) if your Personal Data is processed for direct marketing purposes, including profiling, to the extent related to such marketing.

Should the processing of your Personal Data be restricted at your request, such data, apart from storage, will only be processed with your consent or for establishing, exercising, or defending legal claims, protecting the rights of another natural or legal person, or for significant public interest reasons of the European Union or a Member State.

Right to Data Portability

You are entitled to receive your Personal Data, which you have provided to the Company, in a structured, commonly used, and machine-readable format. Additionally, you have the right to transfer this data to another entity if the processing is based on your consent or a contract to which you are a party, and the processing is carried out by automated means.

When you exercise your right to data portability, it's possible to have your Personal Data transferred directly from the Company to another organization, provided it can be done technically. This right doesn't interfere with your or the Company's rights to data deletion. Moreover, exercising this right should not adversely impact the rights and freedoms of others.

Right to Withdraw Consent

You have the ability to withdraw your consent for us to process your Personal Data at any time, without affecting the legality of any processing carried out before the withdrawal.

Right to Object

You may object to the processing of your Personal Data at any time, especially if it pertains to your particular situation, and when the processing is based on the legitimate interests of the Company or a third party. This includes any profiling conducted on these grounds. Once you object, we will cease processing your Personal Data unless we can demonstrate compelling legitimate reasons for the processing that override your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

Additionally, you can object to the processing of your Personal Data for direct marketing purposes at any time, including any related profiling.

Right to lodge a complaint with a supervisory authority

You are entitled to file a complaint with a supervisory authority established by a Member State to safeguard the fundamental rights and freedoms of individuals concerning the processing of Personal Data within the European Union.

If you are located in Australia, and you believe your privacy rights under the Australian Privacy Act 1988 have been violated, you can also contact the Office of the Australian Information Commissioner (OAIC) via: https://www.oaic.gov.au.

Your rights concerning your Personal Data as detailed in this section 13 may be limited by European Union, Member State, or applicable Australian law to which the Company is subject.

We will provide you with the requested information as per your rights detailed in this section 13 promptly and within one month of receiving the request. This period may be extended by two additional months if necessary, considering the complexity and number of requests. We will inform you of any such extension within one month of receiving your request, along with the reasons for the delay.

The information requested according to your rights detailed in this section 13 will be provided at no charge, unless specified otherwise in this section 13. If a request is considered unreasonable or excessive, particularly due to its repetitive nature, we may either (a) impose a reasonable fee, reflecting the administrative expenses incurred to provide the information, communication, or action requested; or (b) decline to fulfill the request.

Atlas AI might ask you to provide additional details necessary to verify your identity to process your request as per your rights outlined in this section 13, especially if there are reasonable doubts regarding the identity of the individual making the request.

12. Updates To This Policy

We reserve the right to modify this Policy periodically. Whenever changes are made, we will inform you by posting the revised Policy on the Website. Moreover, for significant updates, we will endeavor to notify you through communication methods deemed reasonably effective to inform you of such changes, and by posting a notice on the Website. Unless otherwise specified, all modifications will become effective once the updated Policy is published on our Website.