Privacy and Cookies Policy
This policy describes personal data that we process, purposes for which we use such data, and how you can review and correct any personal data processed by us. ATLAS ensures, within the framework of applicable law, the confidentiality of Personal data and has implemented appropriate technical and organizational measures to safeguard Personal data from unauthorized access, unlawful processing or disclosure, accidental loss, modification or destruction.
“Client” means any natural person who uses, has used or has expressed a wish to use or is in other way related to any of the services provided by ATLAS.
“Personal data” means information relating to you or another identifiable individual.
“Processing” means any operation carried out with Personal data (incl. collection, recording, storing, erasure, transfer, etc.).
Collection of information
We collect your personal data and other information when you use or register into our products and services, or make a payment, take part in campaigns or subscribe to a newsletter, or otherwise interact with us. We are responsible for the processing of personal data we receive and if subsequently, we transfer to a third party acting as an agent on its behalf.
Personal data may be collected from a Client, from the Client’s use of the services and from external sources such as public and private registers or third parties. Personal data categories which ATLAS primarily, but not only, collects and processes are:
“Identification data” such as name, personal identification code, date of birth, data regarding the identification document (e.g. copy of the passport, ID card, video-call etc).
“Contact data” such as an address, telephone number, email address, language of communication etc.
“Financial data” such as accounts, credit cards details, ownership, transactions, credits, income, liabilities, the Client’s financial experience and investment objectives such as data collected during the selection and provision of investment services, investment or insurance services and other products carrying investment risk knowledge, trade requests or executed transactions in financial instruments etc.
“Data about trustworthiness and due diligence” such as data about payment behavior, damage afflicted to ATLAS or other party, data that enables ATLAS to perform its due diligence measures regarding money laundering and terrorist financing prevention and to ensure compliance with international sanctions, including the purpose of the business relationship and whether the client is a politically exposed person.
“Data obtained and/or created while performing an obligation” arising from law such as data resulting from inquiries made by authorities, such as Tax Agency, courts, Enforcement Agency, details of income, credit commitments, property holdings, remarks, and debt balances.
“Data about the Client’s tax residency” such as data about country of residence, tax identification number, etc.
“Communication data” collected when the Client communicates with ATLAS via telephone, visual and/or audio recordings, e-mail, messages and other communication mechanisms such as social media, data related to the Client’s visit at ATLAS ’s web sites or communicating through other ATLAS channels (e.g. internet- and mobile bank) etc.
“Data about habits, preferences and satisfaction” such as the activeness of using the services, services used, personal settings, survey responses, hobbies, Client satisfaction, etc.
Purposes and legal basis of processing Personal Data
We use your personal data to provide you with our services.
ATLAS processes Personal data primary to:
- Manage customer relations and provide and administrate access to products and services. To conclude and execute an agreement, for example a transaction/investment, with the Client, keeping data updated and correct by verifying and enriching data through external and internal registers based on: performance of an agreement or in order to take steps at the request of the Client prior to entering into an agreement or compliance with a legal obligation.
- Comply with legal obligations and verification of identity.
To comply with applicable law, inter alia related to due diligence, prevent, discover, investigate and report potential money laundering, terrorist financing, if the Client is subject to financial sanctions or is a politically exposed person and to verify identity based on: performance of an agreement or in order to take steps at the request of the Client prior to entering into an agreement or compliance with a legal obligation or ATLAS ’s legitimate interest for a sound risk management and corporate governance.
- Protect the interest of the Client and/or ATLAS .
To protect the interests of the Client and/or ATLAS and examine the quality of services provided by ATLAS and for the purpose of providing proof of a commercial transaction or of other business communication (recorded conversations) based on: performance of an agreement or in order to take steps at the request of the Client prior to entering into an agreement or compliance with a legal obligation or consent from the Client or ATLAS ’s legitimate interests to prevent, limit and investigate any misuse or unlawful use or disturbance of our services and products, internal training or quality assurance of services.
- Provide additional services, perform customer surveys, market analyses and statistics.
Offer to the Client the services of ATLAS or carefully selected cooperation partners, including personalized offers, based on: consent from the Client or ATLAS ’s legitimate interest to offer additional services. Perform Client surveys, market analyses and statistics; organize games and campaigns for a Client based on: our legitimate interest to improve services, improve the Client’s user experience of services and to develop new products and services or consent from the Client.
- Prevent misuse of services and ensure adequate provisions of services.
To authorize and control access to and functioning of digital channels, prevent unauthorized access and misuse of those and to ensure the safety of information based on: performance of an agreement or take steps at the request of the Client prior to entering into an agreement or compliance with a legal obligation or consent from the Client or ATLAS ’s legitimate interests to have control over authorizations, access to and functioning of ATLAS digital services.
Improve technical systems, IT-infrastructure, customizing the display of the service to the device and to develop ATLAS services inter alia by testing and improving technical systems and IT-infrastructure based on ATLAS ’s legitimate interests to improve technical systems and IT-infrastructure.
- Establishing, exercising and defending legal claims.
To establish, exercise and defend legal claims based on performance of an agreement or in order to take steps at the request of the Client prior to entering into an agreement or compliance with a legal obligation or ATLAS ’s legitimate interests to exercising legal claims.
- Execute transactions in national and international payment systems.
To fulfill obligations to execute national and international transactions via credit institutions and payment-systems based on performance of an agreement or take steps at the request of the Client prior to entering into an agreement or compliance with a legal obligation.
Sharing personal data
We share your personal data with our affiliates in order to provide you our services. Personal data is shared with other recipients, such as:
- Authorities (such as Tax Agency, supervisory authorities, and Financial Supervisory Authority). We may also occasionally be required by law, court order or governmental authority to disclose certain types of personal data. Examples of the type of situation where this would occur would be:
• in the administration of justice; or
• where we have to defend ourselves legally.
- ATLAS ’s affiliates and subsidiaries.
- Credit and financial institutions, insurance providers and intermediaries of financial services, third parties participating in the trade execution, settlement and reporting cycle.
- Financial and legal consultants, auditors or any other service providers of ATLAS .
- Third parties maintaining databases and registers e.g. to credit registers, population registers, commercial registers, securities registers or other register holding or intermediating Personal data debt collectors and bankruptcy or insolvency administrators.
- Participants and/or parties related to domestic, European and international payment systems.
- Processors authorized by ATLAS .
- We may disclose depersonalized data (such as aggregated statistics) about the users of our site in order to describe our traffic patterns and their site information to prospective partners, advertisers, investors and other reputable third parties and to other lawful purposes, but these statistics will include no personal data.
- Finally, in the event of a reorganization, sales or takeover we may need to disclose personal data.
ATLAS may use authorized processors for processing Personal data or transfer Personal data to other recipients. In such cases, we take needed steps to ensure that such data processors process Personal data under the instructions of ATLAS and in compliance with applicable law and requires adequate security measures.
Geographical area of processing
As a general rule the Personal data is processed within the European Union/European Economic Area (EU/EEA) but in some cases transferred and processed to countries outside the EU/EEA.
Transfer and processing of Personal data outside the EU/EEA can take place provided there is a legal ground i.e. due to a legal requirement or Client’s consent and appropriate safeguards are in place. Appropriate safeguards, such as:
– There is an agreement in place including the EU Standard Contractual Clauses or other approved clauses, code of conducts, certifications etc., approved in accordance with the General Data Protection Regulation;
– The country outside of the EU/EEA where the recipient is located has an adequate level of data protection as decided by the EU Commission;
– The recipient is certified under the Privacy shield (applies to recipients located in the United States)
Upon request, the Client can receive further details on Personal data transfers to countries outside the EU/EEA.
Personal data will be processed no longer than necessary. Personal data will be saved as long as the contractual relationship exists and thereafter for a maximum of 10 years with regard to rules of limitation. In some cases, the data may be saved longer due to capital adequacy legislation applicable to ATLAS. Other deadlines may also apply when Personal Data is stored for purposes other than due to the contractual relationship. The retention period may be based on agreements with the Client or Partner, the legitimate interest of ATLAS or applicable law (such as laws related to accounting (7 years), anti-money laundering (5 years), the statute of limitations, civil law, etc.).
You have various rights in relation to your personal data, including:
- the right to request information regarding what personal data is processed;
- the right to have your personal data rectified if inaccurate or out of date;
- the right to have your personal data erased;
- the right to object to certain processing or to have certain processing restricted; and
- the right to have your personal data transferred from one data controller to another;
- the right to receive his/her Personal data that is provided by him-/herself and is being processed based on consent or in order to perform an agreement in written or commonly used electronic format and were feasible transmit such data to another service provider (data portability);
- the right to withdraw his/her consent to process his/her Personal data.
- the right not to be subject to fully automated decision-making, including profiling, if such decision-making has legal effects or similarly significantly affects the Client. This right does not apply if the decision-making is necessary in order to enter into or to perform an agreement with the Client, if the decision-making is permitted under applicable law or if the Client has provided his/her explicit consent.
- the right to lodge complaints pertaining to the use of Personal data to the Data Protection Authority if he/she considers that processing of his/her Personal data infringes his/her rights and interests under applicable law.
Please note, these rights are not absolute and there may be conditions which must be met before you can enforce these rights.
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Why are cookies used?
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This is how you can handle cookies in your browser
If you want, you can delete cookies through the settings on your browser. Please note that some services might not work if you remove or block cookies. It can also affect the rest of our site and how it works for you.
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We are committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure.
Links to other websites
Our site may contain links to other websites. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content, security, or privacy practices employed by other websites.
You may contact ATLAS with any inquiries, withdrawal of consents, requests to exercise data subject rights and complaints regarding the use of Personal data. Contact details of ATLAS are available on ATLAS website: www.atlasdynamics.eu.
Contact details of the appointed Data Protection Officer: Ulbrokas iela 19A, Riga, LV-1021. Email: email@example.com
Last updated on 10/07/2019