Privacy Policy

2 Who We Are

For a particular engagement, the specific legal entity responsible for processing personal information may be identified in the applicable agreement, proposal, SOW, MSA, or other contractual document.

Where required by applicable privacy law, Atlancia may identify a separate data controller, processor, representative, or Data Protection Officer ("DPO") for particular processing activities.

Data Protection Contact: [INSERT PRIVACY CONTACT / DPO DETAILS IF APPLICABLE]

3 Scope of This Privacy Policy

This Privacy Policy applies to personal information processed by Atlancia through our website, contact forms, enquiry forms, email communications, business communications, sales and consultation processes, client engagements, project delivery, support and maintenance, technology services, digital platforms operated by Atlancia, recruitment processes (where applicable), and other interactions with Atlancia.

This Privacy Policy does not necessarily apply to third-party websites, applications, platforms, or services that Atlancia does not control.

4 What is Personal Information?

"Personal information" or "personal data" generally means information that identifies, relates to, describes, or can reasonably be associated with an identifiable individual.

Depending on the circumstances and applicable law, this may include information such as:

The precise categories of information collected depend on how you interact with Atlancia.

6 Information Collected Automatically

When you visit our website or use certain digital Services, certain technical information may be collected automatically, depending on the technologies implemented on the relevant website or platform.

This may include: IP address, browser type, device type, operating system, language preferences, approximate geographic region, referring website, pages viewed, date and time of access, website interaction information, technical logs, and similar technical information.

The actual information collected will depend on the technologies and services implemented on the relevant website or platform.

7 Cookies and Similar Technologies

Atlancia may use cookies, pixels, local storage, analytics technologies, or similar technologies to operate, secure, analyze, and improve our website and Services. Cookies may be used for purposes such as website functionality, security, remembering preferences, understanding website usage, performance measurement, analytics, improving user experience, and other purposes disclosed at the time of collection.

Where required by applicable law, we will request appropriate consent before using non-essential cookies or similar technologies. You may be able to control cookies through your browser settings and, where available, our cookie-management tools.

Cookie Policy: [INSERT COOKIE POLICY URL, IF SEPARATE]

8 How We Use Personal Information

We may use personal information for legitimate business and operational purposes, including to:

9 Legal Bases for Processing

Where laws such as the EU General Data Protection Regulation ("GDPR") or UK GDPR apply, Atlancia will process personal information on an appropriate lawful basis. Depending on the circumstances, the lawful basis may include:

• Contractual Necessity: Processing may be necessary to enter into or perform a contract with you.
• Legitimate Interests: Processing may be necessary for legitimate business interests, such as operating and improving our Services, managing Client relationships, securing our systems, preventing fraud, communicating with business contacts, or managing our business operations. Where relying on legitimate interests, Atlancia will consider applicable legal requirements and individual rights.
• Consent: We may rely on your consent where applicable law requires or permits consent as the legal basis for processing. You may withdraw consent where applicable. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
• Legal Obligations: We may process personal information where necessary to comply with applicable legal or regulatory obligations.
• Vital Interests or Other Lawful Bases: Where recognized by applicable law, we may rely on other lawful bases where appropriate.

The availability and application of a particular legal basis depends on the relevant jurisdiction and circumstances.

11 AI-Generated Outputs and Personal Information

Where an Atlancia Service generates AI outputs based on personal information, the processing will be subject to the applicable privacy and contractual requirements.

AI-generated outputs may contain errors or inaccuracies. Atlancia does not represent that AI-generated information is always accurate, complete, or suitable for a particular purpose.

Where AI is used in a context involving significant decisions about individuals, appropriate human review and applicable legal safeguards should be considered.

12 Client Data

Where Atlancia provides Services to a business or enterprise Client, the Client may provide information or data to Atlancia for processing. Depending on the nature of the Project, the Client may remain the data controller while Atlancia acts as a data processor or service provider.

The applicable roles and responsibilities will depend on: The nature of the Services, applicable privacy laws, the Project architecture, the applicable agreement, and the instructions provided by the Client.

Where required, Atlancia and the Client may enter into a separate Data Processing Agreement ("DPA").

13 Client Responsibility for Data

Clients are responsible for ensuring that information they provide to Atlancia is collected and shared lawfully. Clients must ensure that they have appropriate rights, permissions, notices, consents, authorizations, and other lawful bases required to provide personal information to Atlancia for the applicable Services.

Clients should not provide Atlancia with information that they are legally prohibited from sharing or processing.

14 Information Sharing

Atlancia does not sell personal information merely as part of providing its ordinary technology Services. We may share personal information where reasonably necessary with:

• Service Providers: We may use trusted service providers to support our operations, such as providers of cloud infrastructure, hosting, software, communications, analytics, security, customer relationship management, payment processing, email delivery, IT services, and other business services.
• Professional Advisors: We may disclose information to professional advisors such as lawyers, accountants, auditors, consultants, and other professional service providers where reasonably necessary.
• Legal and Regulatory Authorities: We may disclose information where required or permitted by law, including in response to court orders, legal processes, government requests, regulatory requirements, or law-enforcement requests.
• Business Transfers: If Atlancia is involved in a merger, acquisition, restructuring, financing, sale of assets, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable legal requirements.

16 International Data Transfers

Because Atlancia serves Clients globally, personal information may be processed or accessed in countries other than the country in which it was originally collected. Depending on the Project, information may be processed by Atlancia, its service providers, or technology providers in different jurisdictions.

Where applicable law imposes requirements on international transfers of personal information, Atlancia will use appropriate mechanisms and safeguards required by applicable law. For individuals protected by GDPR or UK GDPR, international transfers may involve legally recognized safeguards such as adequacy decisions, standard contractual clauses, or other lawful transfer mechanisms where applicable.

17 Data Retention

Atlancia retains personal information only for as long as reasonably necessary for the purposes for which it was collected, including providing Services, maintaining business records, managing Client relationships, meeting contractual obligations, complying with legal obligations, resolving disputes, enforcing agreements, and protecting legitimate business interests.

The specific retention period depends on the type of information, the purpose of processing, the nature of the relationship, contractual requirements, legal requirements, and applicable limitation periods. Where a specific retention period is required by applicable law, Atlancia will comply with that requirement.

Specific retention schedule: [INSERT IF ATLANCIA HAS A FORMAL RETENTION SCHEDULE]

18 Data Security

Atlancia takes reasonable technical and organizational measures designed to protect personal information against unauthorized access, loss, misuse, alteration, disclosure, or destruction. Security measures may include, where appropriate: access controls, authentication mechanisms, encryption, secure infrastructure, monitoring, logging, backup procedures, security controls, personnel access restrictions, and other appropriate technical and organizational safeguards.

However, no method of electronic transmission, storage, or processing can be guaranteed to be completely secure.

19 Data Breaches and Security Incidents

If Atlancia becomes aware of a security incident involving personal information, we will assess and respond to the incident in accordance with applicable law and contractual obligations.

Where legally required, Atlancia may notify affected individuals, Clients, regulators, or other relevant parties. For Client engagements governed by a separate Data Processing Agreement or security agreement, the notification requirements contained in that agreement will apply.

21 How to Exercise Your Rights

To submit a privacy request, contact: contact@atlanciaworldwide.com

Please include: Your full name, contact information, the nature of your request, information that helps us identify your relationship with Atlancia, and any other information reasonably necessary to process the request.

We may need to verify your identity before fulfilling certain requests. This verification is intended to protect personal information from unauthorized disclosure. We will respond to valid requests within the timeframe required by applicable law.

22 California Privacy Rights

If applicable California privacy laws apply to your personal information, you may have additional rights depending on your circumstances and the nature of Atlancia's processing activities. These rights may include rights to: know or access personal information, correct personal information, delete personal information, opt out of certain sales or sharing activities, limit certain uses of sensitive personal information where applicable, and receive information about the categories of personal information collected, used, and disclosed.

At this time, Atlancia's policy is not to sell personal information as defined by applicable law, unless this Privacy Policy is subsequently updated to state otherwise. California privacy rights and applicable obligations depend on factors including the nature of the business, individuals concerned, data processed, and applicable legal thresholds.

California Privacy Request Contact: contact@atlanciaworldwide.com

23 Marketing Communications

Where permitted by applicable law, Atlancia may send business communications regarding Services, technology solutions, company announcements, events, research, product or service updates, and relevant business information.

You may opt out of marketing communications at any time by clicking the unsubscribe link in an applicable communication or contacting us at contact@atlanciaworldwide.com.

You may continue to receive transactional, contractual, security, or service-related communications even after opting out of marketing communications.

24 Children's Privacy

Our website and Services are intended primarily for businesses, professionals, enterprises, and organizations.

Atlancia does not knowingly seek to collect personal information from children where such collection is prohibited by applicable law. If you believe that a child has provided personal information to Atlancia without appropriate authorization, please contact us so that we can review and take appropriate action.

26 Social Media and External Platforms

If you interact with Atlancia through social media platforms, messaging platforms, or other third-party services, those platforms may independently collect and process information according to their own privacy policies. Your interaction with those platforms is subject to their respective terms and privacy practices.

27 Business and Client Communications

When you communicate with Atlancia as a representative of a company or organization, we may process your professional contact information for purposes such as managing the business relationship, communicating about Projects, providing Services, sending quotations, managing contracts, providing support, processing invoices, and maintaining business records.

This may include your name, business email address, business telephone number, job title, company name, and communication history.

28 Payment Information

Where payments are made for Atlancia Services, payment information may be processed through applicable payment providers, banks, financial institutions, or other payment processors.

Unless expressly stated otherwise, Atlancia does not intend to store complete payment-card information where payment processing is handled directly by a third-party payment provider. Payment providers may process information according to their own privacy policies and contractual requirements.

29 Analytics

Atlancia may use analytics technologies to understand how visitors interact with our website and to improve website performance and user experience. The specific analytics technologies used by Atlancia may vary.

Analytics Providers: [INSERT ACTUAL PROVIDERS, IF ANY]

Where required, appropriate consent will be obtained before using non-essential analytics technologies.

30 Advertising and Tracking

Atlancia may use advertising, remarketing, conversion tracking, or similar technologies if implemented on our website. If such technologies are used, they may collect information regarding website interactions and may be operated by third-party advertising or technology providers.

Advertising / Tracking Providers: [INSERT ACTUAL PROVIDERS OR STATE "NONE"]

Where required by applicable law, Atlancia will obtain appropriate consent or provide applicable opt-out mechanisms.

31 Do-Not-Track and Global Privacy Control

Certain browsers and devices may provide privacy preference signals or mechanisms. The availability and legal effect of such signals may vary depending on jurisdiction and applicable law.

Where Atlancia is legally required to recognize a particular privacy signal, we will process that signal in accordance with applicable requirements.

32 Sensitive Personal Information

Certain jurisdictions define categories of personal information as "sensitive" or "special category" data. Examples may include: health information, biometric information, financial information, government identifiers, precise location information, racial or ethnic information, religious information, genetic information, information concerning sexual orientation, or other categories protected by applicable law.

Atlancia does not intentionally request sensitive personal information through its general website unless reasonably necessary for a specific purpose.

Where sensitive or special-category information is required for a Project, the parties should establish appropriate contractual, security, privacy, and legal requirements before processing such information.

33 AI, Automation and Automated Decision-Making

Atlancia develops AI and intelligent automation solutions that may support business processes and decision-making. Where Atlancia processes personal information through automated systems, the applicable Project agreement and privacy requirements will govern the processing.

Unless expressly agreed otherwise, Atlancia does not represent that its AI systems independently make legally binding decisions about individuals. Where applicable law provides specific rights regarding automated decision-making or profiling, Atlancia will address those rights according to the relevant legal requirements.

35 Subprocessors

Atlancia may engage third-party providers to assist in delivering Services. Depending on the Project, such providers may support cloud infrastructure, hosting, AI processing, data storage, communications, analytics, security, software infrastructure, or other operational functions.

Subprocessor Information: [INSERT SUBPROCESSOR LIST / URL IF APPLICABLE]

Where required by applicable law or contractual arrangements, Atlancia will provide appropriate information regarding relevant subprocessors.

36 International Clients

Atlancia serves Clients internationally. By interacting with Atlancia, you acknowledge that your information may be processed in countries other than your country of residence, subject to applicable legal requirements and appropriate safeguards where required.

Where applicable law provides specific protections for international data transfers, Atlancia will use legally recognized transfer mechanisms.

37 Data Retention and Deletion

When personal information is no longer reasonably required for its original purpose, contractual obligations, legal requirements, dispute resolution, security, or legitimate business needs, Atlancia may delete, anonymize, or otherwise securely dispose of it.

Certain information may need to be retained for longer periods due to legal obligations, accounting requirements, tax requirements, contractual obligations, dispute resolution, security requirements, or other lawful purposes.

38 Legal Disclosures

Atlancia may disclose personal information where reasonably necessary to comply with law, respond to legal process, respond to government requests, protect Atlancia's legal rights, protect Clients or users, investigate fraud, prevent security incidents, enforce contractual terms, or protect the safety and security of individuals and systems.

39 Corporate Transactions

If Atlancia participates in a merger, acquisition, restructuring, financing, sale, transfer, or other corporate transaction, personal information may be transferred as part of the relevant transaction. Any such transfer will be handled in accordance with applicable privacy and legal requirements.

41 Changes to This Privacy Policy

Atlancia may update this Privacy Policy from time to time to reflect changes in our Services, technology, data practices, applicable law, business operations, or other relevant developments.

When we make changes, we will update the "Last Updated" date at the top of this Privacy Policy. Where required by applicable law, we will provide additional notice regarding material changes.

42 Your Responsibility to Keep Information Accurate

Where you provide personal information directly to Atlancia, you are responsible for providing accurate and reasonably current information. You should notify us if information you have provided becomes inaccurate or requires updating.

43 Complaints

If you have concerns regarding Atlancia's handling of your personal information, please contact us first so that we can investigate your concern.

Privacy Contact: contact@atlanciaworldwide.com

Where applicable law provides a right to lodge a complaint with a supervisory or data protection authority, you may also have that right. For example, individuals protected by GDPR may have the right to lodge a complaint with a relevant Data Protection Authority.

44 Data Protection Authority

If you are located in a jurisdiction with a data protection regulator, you may have the right to contact the relevant supervisory authority regarding concerns about the processing of your personal information. The appropriate authority will depend on your location and the applicable privacy law.

45 Contact Us About Privacy

For questions, requests, complaints, or concerns regarding this Privacy Policy or the processing of your personal information, contact:

46 Governing Framework

This Privacy Policy is intended to describe Atlancia's general approach to privacy and personal information. The privacy laws applicable to a particular individual or Client may depend on factors including location, residency, nature of the relationship, type of information, Services provided, processing activities, applicable contractual arrangements, and applicable law.

Where a specific data-processing agreement, privacy agreement, or other contractual arrangement applies, that agreement will govern the relevant processing activities to the extent of any conflict.

47 Acknowledgement

By using the Atlancia Worldwide website or Services, you acknowledge that you have read and understood this Privacy Policy. Where consent is required for a particular processing activity, Atlancia will obtain consent in accordance with applicable law.