Effective: January 1, 2020
In most instances, we process, collect and use personal information provided to us by our Customers’ employees within the context of us providing our Services to our Customers (the “B2B Information”). In rare instances, while rendering our Services, we may collect personal information of or about Individuals that is not B2B Information. In such instances, we are the business, as defined in the CCPA.
YOUR PERSONAL INFORMATION
“Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties.
We have collected the following categories of data personal data from you within the last twelve (12) months:
|A. Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||YES|
|C. Protected classification characteristics under California or federal law.||YES|
|D. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||NO|
|E. Biometric information.||NO|
|F. Internet or other similar network activity, including, but not limited to, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||YES|
|H. Audio, electronic, visual, thermal, olfactory, or similar information||NO|
|I. Professional or employment-related information.||YES|
|J. Education information, defined as information that is not publically available personally identifiable information as defined in the Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||NO|
|K. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Specifically, we collect the following information from you:
Personal information that you provide to us
We collect personal information that you provide to us directly, such as:
- Personal Identification Information: A real name, alias, postal address, online identifier (social media handles), Internet Protocol address, email address, account name, phone number, birth date. If you are an employee of Atlas, a job applicant, or a contractor, we may already have or require you to provide us, as applicable, with information related to your education and employment history.
- Government Issued Identification: If you are applying for a job, under the applicable laws, we may be required to collect copies of your government-issued identification.
- Correspondence: If you choose to correspond with us through email, we may retain the content of your email messages together with your email address and our responses, unless it is a request for deletion, in which case we will delete all your personal information in your request after completion of the same.
Personal information that we collect automatically when you use our websites
Similar to applications on other commercial website, our application utilizes a standard technology called “cookies” (see explanation below, “What Are Cookies?”), IP addresses and web server logs to collect information about how our Services are used. Information gathered through cookies and web server logs may include the date and time of visits, the pages viewed, time spent at our website, and the websites visited just before and just after our website.
Personal information we collect from our partners and other sources
In providing our Services to our Customers, as a processor, we may be given personal information about Individuals from our Customer.
HOW YOUR PERSONAL INFORMATION IS USED
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our services.
We may use the information that you provide us in the following ways:
- To process the transaction. We use the information that you provide for processing the transaction.
- To provide Customer service. We process your personal information when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. Without processing your personal information for such purposes, we cannot respond to your requests about our services.
- To ensure quality control. We process your personal information for quality control and for staff training to make sure that we continue to provide you with quality service. If we do not process your personal information for quality control purposes, your issues with the service, if any, as communicated to us, may not get resolved.
- To provide communication. We may send administrative or account-related information to you, on behalf of the Customer, to keep you updated about the transaction and our services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account and the applicable transactions. You may not opt-out of receiving critical service communications, such as emails sent for legal or security purposes.
- To engage in marketing activities. Based on your communication preferences, we may send you marketing communications (e.g. emails) to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers. Our marketing will be conducted in accordance with your advertising marketing preferences and as permitted by applicable law.
- For research and development purposes. We process your personal information to better understand the way you use and interact with our services. In addition, we use such information to customize, measure, and improve our products and services. Without such processing, we cannot ensure your continued enjoyment of our products and services.
- To facilitate corporate acquisitions, mergers, or transactions. We may process any information regarding your account and use of our services as is necessary in the context of corporate acquisitions, mergers, or other corporate transactions. You may contact us at email@example.com, if you do not want us to use your information for this purpose.
- For recruitment and/or engaging third-party contractors. We process your personal information when you apply for a job, become an employee of Atlas, or become our third-party contractor.
- For any purpose that you have consented to. We may disclose your personal information for any purpose you consent to.
WHAT ARE COOKIES?
A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.
How Do We Use Information We Collect From Cookies?
Can You Opt-Out Of Cookies?
You may only opt-out of the cookies if you disable cookies in your browser and clear your browser history each time you visit the website. Please follow your browser’s documentation for instructions on how to disable cookies.
Sharing Information With Third Parties
We may share your personal information may be processed with or stored on the following third-party service providers.
- Cloud storage
- Customer support
- Data analytics
- Document repository services
- Internet (e.g. ISPs)
- Network infrastructure
We may also share your personal information in the following circumstances:
- With companies or other entities that we plan to merge with or be acquired by. You will receive prior notice of any change in applicable policies.
- With companies or other entities that purchase Atlas’ assets pursuant to a court-approved sale or where we are required to share your information pursuant to insolvency law in any applicable jurisdiction.
- With our professional advisors who provide banking, legal, compliance, insurance, accounting, or other consulting services in order to complete third party financial, technical, compliance and legal audits of our operations or otherwise comply with our legal obligations.
- With law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of any other applicable policies.
ANONYMIZED AND AGGREGATED DATA
Anonymization is a data processing technique that removes or modifies personal information so that it cannot be associated with a specific individual. We may use anonymized or aggregate Individuals’ data and Customers’ data for any business purpose, such as to better understand the needs and behaviors of our Customers, improve our Services, conduct business intelligence and marketing, and detect security threats. We may perform our analytics on anonymized data or enable analytics provided by third-parties.
PROTECTING YOUR INFORMATION
We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
We may disclose your personal information if required to do so by law or subpoena or if we believe that such action is necessary to (a) conform to the law or comply with legal process served on us or affiliated parties; (b) protect and defend our rights and property, the website, and our Services; and (c) act under circumstances to protect the safety of users of the website, our Services, or third parties.
What About Other Website Through Which Our Services Are Available?
We are not responsible for the practices employed by any other website that may/may not link or provide access to our Services.
We do not knowingly collect any personal information from children under the age of 13. Our Services and websites are directed to people who are at least 13 years old or older.
CALIFORNIA Residents’ rights and choices
The CCPA provides California residents, except for the employees, contractors, and job applicants of the business who are California residents, with specific rights regarding their personal information. This section describes the rights of California residents and explains how to exercise those rights. In this section, “you” refers only to California residents, as described above. Under the CCPA, businesses are required to give California employees, contractors, and job applicants a notice about the categories of data collected and its purpose, which we have provided in the following sections above – YOUR PERSONAL INFORMATION, and HOW YOUR PERSONAL INFORMATION IS USED.
- Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm that you are the one who made the verifiable consumer request, as defined in the CCPA, (“VCR”), we will disclose to you the following:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
We do not provide these access and data portability rights for B2B Information.
- Deletion request
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your VCR, we will delete your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with Consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We do not provide these deletion rights for B2B Information.
- Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a VCR to us by either:
Emailing us at firstname.lastname@example.org
Calling us at (833) 286-6446
Writing to us at: 13215 Bee Cave Parkway, Building A, Suite 230, Austin, TX 78738
All requests must contain your full and complete legal name and any alias or other names or nicknames that you use; your contact information, including mailing address, email and phone number; and the description of your request.
Only you, or someone legally authorized to act on your behalf, may make a VCR related to your personal information. You may also make a VCR on behalf of your minor child.
You may designate an authorized agent to make a request to access or a request to delete on your behalf. A response will be furnished to your authorized agent’s request if they submit proof that they are registered with the California Secretary of State to be able to act on your behalf, or submit evidence you have provided them with power of attorney pursuant to California Probate Code section 4000 to 4465. Authorized agents may not be provided with the response pertaining to the request if the authorized agents fail to submit a proof of authorization or are unable to verify their identity.
You may only make a VCR for access or data portability twice within a 12-month period.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a VCR does not require you to create an account with us.
We will only use personal information provided in a VCR to verify the requestor’s identity or authority to make the request.
- Response Timing and Format
We endeavor to respond to a VCR within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the VCR’s request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your VCR.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
OTHER CALIFORNIA RESIDENTS RIGHTS
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of such data, the names and addresses of those businesses with which we shared for the immediately prior calendar year. To request a notice, please email your request to email@example.com. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. Please also note that we do not share your personal information with any other business for that business’s marketing use.