If you are a California Resident (as defined below), please review the below section Additional Information for California Residents for additional disclosures and Notice at Collection and Use of Personal Information for a description of your rights under the California Consumer Privacy Act (with any implementing regulations, as amended by the California Privacy Rights Act (“CPRA”), and as may be amended from time to time, “CCPA”).
In the event that you have any questions or concerns about this Privacy Notice, if you object to our uses of your personal information, or if you wish to exercise your rights under applicable law, please contact us at atlas-sp.privacy@atlas-sp.com.
When you visit and browse the Site or communicate with us, you may directly provide us with information, including personal information, and we will collect certain information automatically or through other sources. When we use the term “personal information”, we mean any information that can help us directly or indirectly identify you and as otherwise defined under applicable law.
In order to access certain services provided via the Site or to request certain information from ATLAS via the Site, you may be required to provide certain personal information.
Depending on how you interact with us, including if you are vendor that we interact with, we may collect the following categories of personal information from or about you:
Please note that some of this information may be considered special category data, or sensitive data under applicable law.
You may also be required to provide a username and password to access certain features. If you choose to not provide us with information, you might not be able to gain access to certain information and services on the Site, which rely on such information (for example, you will not be able to register for e-mail updates if you do not provide us with an e-mail address, and if you choose not to provide a username and password, we will not be able to provide you with services available through an online account).
We also collect information about you automatically, which may include personal information.
For example, when you visit the Site, we collect your IP address, your browser type, your operating system, the pages you view on the Site, the duration of your visit, the pages you view immediately before and after you access the Site, and the search terms you enter on the Site.
We generally collect this information using cookies. For more information on our use of cookies and other technologies, please review Our Use of Cookies and Similar Technologies below. Other technical methods including web beacons may involve the transmission of information either directly to us or to another party authorized by us to collect information on our behalf. We may also use these technical methods in HTML e-mails that we send visitors to the Site to determine whether such visitors have opened those e-mails and/or clicked on links in those e-mails.
If you communicate with our employees and other staff members via email, telephone, or other electronic channels, our information technology systems record details of those communications, sometimes including their content, for compliance and record-keeping purposes.
We may collect personal information about you from other sources such as our service providers or other vendors that assist with our business. Additionally, some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.
The third-party partners from which we receive personal information include web hosting providers. We may receive information related to name, occupation, address, and contact information from such third-party partners. Our use of information received from such a third-party will be dictated by the third party’s privacy policy and not this Privacy Notice.
We will link the information that we collect automatically with the information you provide us, and we will combine the information we collect online with information we collect offline or that is collected by third-parties.
We use cookies, web beacons and other similar technologies for a variety of purposes such as to better understand, customize and improve the user experience of our Site, services and offerings, and market to you. Cookies are small files that a website sends to your computer or device while you are viewing the website, or other technical methods to track visitor usage, including web beacons, which are small pieces of data that are embedded in images on the pages of a website. For example, when you return to our Site after logging in, cookies provide information to the Site so that the Site will remember who you are. Cookies may also be used by our service providers or other business partners.
We collect such information through the following technologies (collectively “cookies”):
We use different types of cookies that provide various services, including:
You can control cookies in various ways, including:
Please note that if you turn cookies off, you may not have access to many features that may improve your browsing, like the features mentioned above, and some of our services may not function properly.
The Site may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites.
Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the Site). These links are provided to you for convenience purposes only, and you access them at your own risk.
How we use your personal information may vary depending on how you interact with us and which Site you are visiting. Generally, we use information we collect about you primarily to provide services to you in accordance with any contract with you, communicate with you, and manage and improve our services for you and our other counterparties, as permitted by applicable laws.
We may collect, use or process your personal information for the following business or commercial purposes, and the lawful bases for our processing include the following:
We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you. For example, we may prepare aggregated reports about how visitors tend to interact with the Site for research about the use of the Site and how the Site could be improved, from which your interactions with the Site cannot be singled out.
We may share information about you with third-parties when you engage in certain activities on the Site that are sponsored by third-parties. For example, you may choose to purchase products or services offered by a third-party or elect to receive information or communications from a third-party. If you engage in such third-party offerings, we may share information (e.g., your e-mail address) with third-parties in association with the offerings.
We may disclose this information to third-parties for the purposes and on the basis described above (see Section B), for example, to process your transactions and to respond to your requests for information or communications from third-parties.
Sometimes we engage companies that process information for us or act on our behalf in association with the operation of the Site and our services. For example, such companies may deliver products or services, improve the functionality of the Site, collect information about you, communicate with you, or store information for us. In some cases, these companies may need to access information about you.
We may also disclose your information to service providers that provide products or services to us or to facilitate our business operations, including marketing, advertising and related services.
Except as otherwise disclosed in this Privacy Notice or as otherwise communicated to you, ATLAS takes reasonable steps to require these companies to collect, store, and use information about you only on our behalf and in accordance with this Privacy Notice. We share personal information with service providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business.
We may engage analytics providers to help us understand how users engage with the Site. These providers may use cookies and similar technologies to collect information about your use of the Site as well as information about your use of other websites over time.
The services we use include, but may not be limited to: Google Analytics and Adobe, which may provide you with choices about how they collect and use information. As described above, we share personal information with analytics providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business. To find out more about how Google Analytics collects and processes data, please click here. Google Analytics has its own cookies that it uses to track and aggregate this information. You can prevent the use of Google Analytics relating to your use of our Site by downloading and installing the browser plugin available here.
We may share your information with our affiliates and subsidiaries, or with our attorneys, banks, auditors, securities brokers and other service providers in connection with the purposes described above. We may also partner with other organizations or companies to provide co-sponsored or co-branded promotions, services, or events, and we will share your information with our co-sponsor(s) and partners to the extent necessary for the partnership to function.
We may disclose information when we believe in good faith that such disclosures:
We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.
The above-described disclosures are provided on the basis that they are either necessary to comply with our legal obligations or they are necessary to meet our legitimate interests in managing our business efficiently and for developing future business.
Additionally, we reserve the right to share with third-parties, information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.
We do not sell your personal information and have not done so in the last 12 months from the effective date of this policy.
Please note that for purposes of this Section E, “sharing” does not include “sharing” as defined under the CCPA. For additional disclosures and information on our CCPA practices, please review Additional Information for California Residents below.
We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
You may update your contact information and/or modify your communication preferences by sending us an e-mail at atlas-sp.privacy@atlas-sp.com. Additionally, we may provide tools on the Site that facilitate such updates or modifications.
The Site is intended for use by those over 18, and minors under the age of 13 may not use the Site.
We do not knowingly solicit or collect personal information on the Site from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Site, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).
Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.
Third-parties, such as our analytics providers, may collect data that relates to you on the Site, across time, and over other websites. We cannot control third-parties’ responses to do-not-track signals or other such mechanisms. Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies.
If you no longer wish to receive marketing materials from us, you can let us know by contacting us at atlas-sp.privacy@atlas-sp.com or using other unsubscribe features that we provide in our marketing communications.
Subject to local law, you may have certain additional rights regarding your personal information. These may include the following rights to: (i) access your personal information; (ii) rectify the information we hold about you; (iii) erase your personal information; (iv) restrict our use of your personal information; (v) object to the processing of your Personal Information in certain circumstances, including where we process Personal Information for direct marketing purposes or where we have processed such data on the basis of our legitimate interests; (vi) withdraw your consent to the processing of your Personal Information (where applicable); (vii) receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability); and (viii) lodge a complaint with your local data protection authority, and withdraw any consent you have given to uses of your personal information.
If you are a California Resident, please review Additional Information for California Residents below for a description of your California-specific rights regarding your Personal Information.
How to Exercise Your Rights
If you would like to discuss or exercise the rights you may have, contact us at atlas-sp.privacy@atlas-sp.com or call us toll-free at 833-381-5803. We will review your request and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.
We will process your request within the time provided by applicable law.
Our activities and the jurisdictions in which we are established are such that we process information collected via the Site in and subject to the laws of the United States and other countries, which may not provide the same level of protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.
In some cases, your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union or other applicable laws. However, we will seek to ensure that a similar degree of protection is afforded to your personal information by ensuring that, where possible, we have put in place appropriate safeguards (such as standard contractual clauses approved by the European Commission) in accordance with applicable legal requirements, or otherwise transfer personal information in accordance with applicable laws, such as, where the transfer is necessary for the performance of a contract between you and us or between us and a third party in your interest, where the transfer is necessary to establish, exercise or defend legal claims, or where the transfer is made for important reasons of public interest. For more information on the appropriate safeguards in place or to obtain a copy, please contact us at atlas-sp.privacy@atlas-sp.com.
We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.
When deciding how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.
The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, and which Site you are visiting, we may collect the categories of personal information listed above in The Types of Information We Collect and How We Collect It.
Our Use and Collection of Information
We may collect and use personal information from you for the purposes described above in How We Use the Information We Collect.
Sale or Sharing of Personal Information
We do not “sell” your personal information under the CCPA, meaning we do not rent, release, disclose, transfer, make available, or otherwise communicate personal information to another business or third party for monetary or other valuable consideration. We also do not “share” your personal information, as defined under the CCPA to mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
How Long We Keep Information
We retain your personal information as described above in the section How Long Is Information Retained?
For more information about our privacy practices, please review our entire Privacy Notice.
Our Collection, Use, and Disclosure of Personal Information and Sensitive Personal Information
What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting the Information
In the preceding 12 months, depending on how you interact with us and which Site you are visiting, we may have collected the categories of personal information from the categories of sources listed above in the section, The Types of Information We Collect and How We Collect It. We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section How We Use the Information We Collect.
Our Disclosure of Personal Information
We do not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell or share the personal information of California Residents under 16 years old. In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information (described in more detail in The Types of Information We Collect and How We Collect It above) to the following categories of third parties, as describe in the below chart:
| Category of Third Parties | Categories of Personal Information | Business or Commercial Purpose for Disclosure |
|---|---|---|
| Our affiliates | Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Internet or Electronic Network Activity Information; Audio (e.g., voicemail), electronic, visual or similar information; Professional or Employment Related Information; Inferences | Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); Internal research for technological development and demonstration; Activities to verify, maintain, or improve the quality of our services; Business development and marketing initiatives. |
| Counterparties and intermediaries (e.g., broker-dealers) | Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Professional or Employment Related Information; Inferences | Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); and Activities to verify, maintain, or improve the quality of our services. |
| Third parties as needed to complete a transaction, including financial institutions or advisors, or entities that assist with fraud prevention | Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Professional or Employment Related Information; Inferences | Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); and Activities to verify, maintain, or improve the quality of our services. |
| Professional services organizations, such as auditors and law firms | Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Characteristics of protected classifications under certain federal or state laws; Commercial information; Education information; Internet or Electronic Network Activity Information; Audio (e.g., voicemail), electronic, visual or similar information; Professional or Employment Related Information; Inferences | Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); Internal research for technological development and demonstration; and Activities to verify, maintain, or improve the quality of our services. |
| Prospective lenders to or creditors of an entity or company in which we have or are considering investing | Identifiers; Additional information subject to Cal. Civ. Code § 1798.80(e); Commercial information; Education information; Professional or Employment Related Information; Inferences | Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); and Activities to verify, maintain, or improve the quality of our services |
In addition, we may disclose and in the preceding 12 months, may have disclosed for all of the categories of personal information identified in The Types of Information We Collect and How We Collect It above to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose the categories of personal information identified in The Types of Information We Collect and How We Collect It for the business or commercial purposes identified above in How We Use the Information We Collect. Additionally, we may disclose your personal information to third parties upon your request, at your direction, or with your consent.
We may also disclose your personal information or otherwise make it available to our service providers such as our IT and/or CRM providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.
Use and Disclosure of Sensitive Personal Information
As noted in The Types of Information We Collect and How We Collect It, we may collect certain special category data or sensitive personal data under certain laws. We do not currently collect “sensitive personal information” (as defined under the CCPA) from our website visitors. We may collect “sensitive personal information” from our service providers or job applicants, as explained in separate notices such as our employee or candidate privacy notices.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected, and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit); (vii) correct inaccurate personal information (“Request to Correct”); and (viii) request that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months (“Request to Know”).
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the GLBA. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
How to Submit a Request Under the CCPA
You may submit a Request to Know, Request to Correct or Request to Delete (“Consumer Rights Request”), as described above, through the following toll-free telephone number 833-381-5803 or email us at atlas-sp.privacy@atlas-sp.com.
When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
If you would like to use an authorized agent to submit a request, we may request proof that that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
We may change this Privacy Notice from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Notice to review any changes. Your continued use of the Site after the effective date of any modification to the Privacy Notice will be deemed to be your agreement to the changed terms.
This Notice was last updated February 2023.
This Privacy Notice is available in alternative formats upon request. If you have any questions regarding this policy or our privacy or data protection practices, or to request this Privacy Notice in an alternative format, please feel free to contact us at atlas-sp.privacy@atlas-sp.com.