Atlastopper LLC respects your privacy and is
committed to protecting and respecting your personal data. This
privacy policy aims to give you information on how we collect and
process any personal data i.e. information about a Client (as
defined below) who is a natural person on the basis of which that
Client can be identified (hereinafter the data)
in accordance with the applicable data protection legislation and
best practice.
We strive to create the most secure infrastructure of any broker
in the world. In this privacy policy we would like to tell why you
can trust us with your data and rest assured that your data is
safe.
It is important that you read this privacy policy together with
any other privacy policy we may provide on specific occasions when
we are collecting or processing your data about you so that you
are fully aware of how and why we are using your data.
In this Privacy Policy, unless the context otherwise requires,
expressions defined herein shall have the meaning ascribed to them
in the Terms & Conditions.
Please note that this Privacy Policy is addressed to Clients and
potential customers. If you are an Atlastopper employee, a contractor to Atlastopper or a
third-party service provider, your personal information will be
used in connection with your employment contract, your contractual
relationship or in accordance with our separate policies which are
available by contacting us at the contact details listed in the
section OUR CONTACT DETAILS below.
1. WHO WE ARE
Atlastopper LLC, is a company registered in St.
Vincent and the Grenadines and having its registered address at
Hinds Building, Kingstown, St. Vincent and the Grenadines
(hereinafter
Atlastopper ). Althexinvestment
Limited is the controller and responsible for the data of the
Client disclosed to us in order to register for a Trading Account,
Demo Account and/or to make use of any other services offered by
the Atlastopper Group (as defined in Appendix A)
through the website (hereinafter
“Website”) (this term shall at all times include Website’s desktop
and mobile versions).
This Privacy Policy is issued on behalf of Althexinvestment
Limited Group so when we mention “Atlastopper ”,
“Company”, “we”, “us” or “our” in this Privacy Policy, we are
referring to the relevant company in the Atlastopper group responsible for collecting and/or processing your data when
you use the Trading Platform through the Website, either for a
Trading Account or a Demo Account (or their mobile/desktop
versions) (hereinafter the
Service(s)). In Atlastopper we
respect your privacy and therefore all companies within the
Atlastopper group are committed to protect your data,
which it collects, uses and/or has access to.
If you are participating in our affiliate and/or introducing
broker programs, we will process the data provided under our
agreement with you to exercise our rights and perform our
obligations under or in connection with the relevant agreement and
the term Client in this Privacy Policy shall be read to include
the term Affiliate and/or Introducing Broker (as applicable).
The Company takes measures to implement advanced data protection
policies and procedures and to update them from time to time for
the purpose of safeguarding the Client's data and the Client’s
account. Your data is protected by the legal, administrative and
technical measures that we take to ensure the privacy, integrity
and accessibility of data. To prevent security incidents with your
data, we use a mixed organizational and technical approach based
on the results of annual risk assessment.
The Company shall not divulge any private information of its
Clients and former Clients unless the Client approves in writing
such disclosure or unless such disclosure is required under
applicable law or is required in order to verify the Client's
identity or it is required for Atlastopper to perform
its contractual obligations under any agreement concluded with the
Client. The Clients' information is processed only by the
employees of the Company and/or employees of the Althexinvestment
Limited group and/or trusted third parties which provide specific
support services, dealing with the specific Client's Accounts and
necessary for the provision of our services. All such information
shall be stored on electronic and physical storage media according
to applicable law.
2. DATA USAGE
-
-
We may collect, use, store and transfer different kinds of
data about you which we have grouped together as follows:
-
Identity Data includes first name, last
name, and patronymic (if available), date of birth
gender, passport, ID, Driver’s number, and copy of
photo.
-
Contact Data includes billing address,
email address and telephone numbers.
-
Financial Data includes bank account,
payment card details and tax identification number
(including but not limited to social security number,
income tax identification number, national insurance
number).
-
Transaction Data includes details about
the transactions performed by you, details about
payments, withdrawals, exchanges, trading history,
profit, balance, deposited and withdrawal amount
methods, and any other details in relation to the
services you have made use of through our Website.
-
Technical Data includes internet
protocol (IP) address, your login data, browser type and
version, time zone setting and location, browser plug-in
type and versions, operating system and platform, and
other technologies on the devices you use to access the
Website and use of cookies stored on your device.
-
Profile Data includes your Client’s
account details, username and password, transactions
made by you, your interests, preferences, feedback
and/or information received through your interaction
with us within the course of providing our services and
survey responses.
-
Usage Data includes information about
how you use the Website, products and services,
registration date, account category, trading cluster,
number of complaints, number of requests filed and IP
history.
-
Marketing and Communication Data
includes your preferences in receiving marketing from us
and your communication preferences.
-
Special Categories of Data/ ‘Sensitive’ Data
includes details about your religious belief, annual
income, biometric data, and/or criminal convictions and
offences.
-
Conformity Data includes details about
your education, employment status, trading experience,
self-assessment test.
-
Banking Data includes details of the
number of payment wallets and/or information of your
bank card, including information of the issuing bank,
card number, cardholder name, card expiration date,
payment system, card validation code (CVV2 / CVC2), and
photos of both sides of the bank card.
-
Data in KYC (Know your customer)
includes identity document information, including copies
of recent dated Utility Bills, Identity Card, Passport,
and/or Driver’s License.
-
Economic Profile Data includes details
on occupation, purpose of investment, annual income, net
wealth, expected annual amount of investment and sources
of funds.
-
Location Data includes details on your
actual location when interacting with our Website (for
example, a set of parameters that determine regional
settings of your interface, namely residency country,
time zone, and the interface language).
-
Audio Data includes full voice
recordings of calls that you receive from us or make to
us.
(the above collectively referred to as
“Personal Data”)
-
Aggregated Data includes statistical or demographic data for
any purpose. Such data can be derived from your data but may
not be considered personal data in law as it will not
directly or indirectly reveal your identity. An example of
such Aggregated Data could be that we aggregate your Usage
Data to calculate the percentage of users accessing a
specific website feature and/or services/product preference.
Notwithstanding the above, if Atlastopper combines Aggregate Data with data in a way that the end
result can in any way identify the data subject,
Atlastopper shall treat such combined data as
data which will be treated as per the provisions herein
contained.
-
Processing of your data is carried out by Althexinvestment
Limited following the principles of lawfulness, fairness,
transparency, and always adhering to the intended purpose of
data processing, the principle of data minimization,
accuracy, limited data storage, data integrity,
confidentiality and accountability.
-
In general Atlastopper collects and process the
Personal Data, for any of the following reasons:
- To perform its contract with you,
-
To comply with its legal obligations including without
limitation to applicable anti-money laundering and
terrorist financing laws and regulations (hereby
referred to as Money-Laundering Law), and/or
- To safeguard its legitimate interest
-
The Client acknowledges that all or part of the data
concerning the Client's account and related transactions
will be stored by the Atlastopper and may be
used by the Company in case of dispute between the Client
and the Company.
-
The Client is responsible for updating any data provided to
us in case of any change. Although we will strive to keep
your data up to date and review and inspect any information
provided by you, we may not be able to always do so without
your help. The Client acknowledges that Althexinvestment
Limited holds neither commitment nor responsibility to the
Client due to any aforesaid review or inspection of
information.
3. HOW IS YOU PERSONAL DATA COLLECTED?
-
We use different methods to collect data from and about you
including through:
-
Direct Interactions. You will provide to us
your Identity, Contact and Financial Data online through the
Website and/or by filling in online forms and/or by
corresponding with us by emails or otherwise. Data may be
submitted to us by you when you wish to:
- Register for a Trading Account;
- Register for a Demo Account;
-
Subscribe to our publications and ongoing updates;
-
Request marketing and promotions to be sent to you;
-
Enter a competition, promotion or survey; and/or
- Give us feedback or contact us.
-
We require to collect the above data in order that we are
able to (i) provide our services efficiently, (ii) to comply
with our ongoing legal obligations, including, inter alia,
to prevent fraud and money laundering acts.
-
If you fail to provide the data when requested we may not be
able to perform the contract we have or are trying to enter
into with you (for example, to provide you with our
services). In this case, we may have to cancel a service you
have with us but we will notify you if this is the case at
the time. It is important that the data we hold about you is
accurate and current. Please keep us informed if your data
changes during your relationship with us.
-
Automated Technologies or Interactions.
When using our services, your device automatically
transmits to us its technical characteristics. Locale (a set
of parameters that determine regional settings of your
interface, namely, residence country, time zone and the
interface language) is used for the purpose of providing you
with the best possible service within our platform.
Using the information about IP address, cookies files,
information about browser and operating system used, the
date and time of access to the site, and the requested pages
addresses allows us to provide you with the optimal
operation on our web application, mobile and/or desktop
versions of our application and monitor your behaviour for
the purpose of improving the efficiency and usability of our
Services.
We use web analytics tools to track
performance of our website and marketing source of user by
cookies in order to optimize our marketing costs and provide
users with better experience.
You may at any time
request that we refrain from any such transmissions (to the
degree this is possible and subject to any of our legal
obligations) by sending your request to the DPO using our
details in the OUR CONTACT DETAILS below using the
registered email address you disclosed and registered with
us through your Account. We will address your request within
30 business days.
-
About Cookies.
A cookie is a small
amount of data that often includes a unique identifier that
is sent to your computer or device browser from a website's
computer and is stored on your device's hard drive for
tracking site usage. A website may 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 websites. Many websites do this
whenever a user visits their website in order to track
online traffic flows. When you visit our Website, our system
automatically collects information about your visit, such as
your Technical Data, including inter alia to, your browser
type, your IP address and the referring website.
Cookies stored may determine the path the Client took
on our site and used to anonymously identify repeat users of
the website and what pages were most popular for Clients.
However, the Company protects the Client’s privacy by not
storing the Client’s names, personal details, emails, etc.
Using cookies is an industry standard and is currently used
by most major websites. Stored cookies allow the Website to
be more user-friendly and efficient for Clients by allowing
Atlastopper to learn what information is more
valued by Clients versus what isn’t. You can set your
browser not to save any cookies of this website and you may
also delete cookies automatically or manually. However,
please note that by doing so you may not be able to use all
the provided functions of our website in full.
Please
see our Cookies Policy for
further details.
4. PURPOSE FOR WHICH WE WILL USE YOUR DATA AND ON WHAT LEGAL BASIS
-
-
We process the aforementioned data in compliance with the
applicable legislation as amended from time to time in order
to (i) be able to perform our contractual obligations
towards the Client and offer them the best possible service,
(ii) provide our Services efficiently, (iii) comply with our
legal obligations, including, inter alia, to prevent fraud
and money laundering acts, and (iv) protect our legitimate
interests and your vital interests.
-
We process all data based on the following legal basis:
-
For compliance with our legal obligations;
-
For the performance of our contractual obligations
towards the Client;
-
For the purposes of safeguarding our legitimate
interests and your interests and fundamental rights do
not override those interests; and/or
- On the basis of your consent.
-
Indicatively we set out below a description of all the ways
we plan to use your data and which of the legal bases we
rely on to do so. We have also identified what our
legitimate interests are where appropriate. Note that we may
process the data for more than one lawful ground depending
on the specific purpose for which we are using your data.
| - |
PURPOSE ACTIVITY |
TYPE OF DATA |
LAWFUL BASIS FOR PROCESSING INCLUDING BASIS OF LEGITIMATE
INTEREST
|
| a. |
1. To accept to register you as a Client
2. To notify
you about changes to our terms or privacy policy
3. To
communicate with you and provide you with secure
identifications, authentication and support services
4.
To confirm you are at age of majority as recognized and
declared by the laws of your jurisdiction
|
1. Identity Data
2. Profile Data
3. Contact
Data
4. Data in KYC
5. Financial Data
6.
Economic Profile Data
|
1. Necessary to perform our contract with you
2.
Necessary to comply with our legal obligations
|
| b. |
1. To perform our Scoring Processing under which a Client is
scored on a scale basis with regard to the level of risk he
is to Atlastopper |
1. Banking Data
2. Economic Profile Data |
1. Necessary to perform our contract with you
2.
Necessary to comply with our legal obligations
|
| c. |
1. To confirm the information provided by You under (a)
above in relation to your location.
|
1. Location Data |
1. Necessary to perform our contract with you
2.
Necessary to comply with our legal obligations
|
| d. |
1. To secure authentication, identification and support
services via social networks protocols and use the links to
your accounts in social networks for these purposes.
|
1. Technical Data |
1. Necessary to perform our contract with you
2.
Necessary to comply with our legal obligations
|
| e. |
1. To process and deliver your transactions and requests
(Deposits; Trades; Withdrawals)
2. Manage payments,
fees and charges;
3. To collect and recover money owed
to us.
|
1. Banking Data
2. Transaction Data |
1. Necessary to perform our contract with you
2.
Necessary for our legitimate interest (recover charges owed
to us, make a withdrawal in case of breach of our contract)
|
| f. |
1. To administer and protect our business and Website
(including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data)
|
1. Identity Data
2. Contact Data
3. Technical Data
|
1. Performance of our contract with you
2. Necessary to
comply with our legal obligations
3. Necessary for our
legitimate interests (take reasonable steps to confirm that
you do not use any ways to manipulate our platform & for
running our business, provision of administration and IT
services, network security, to prevent fraud)
|
| g. |
1. To deliver relevant Website content and advertisements to
you and measure or understand the effectiveness of the
advertising we serve to you
2. To provide you with an
optimal operation on our web application, mobile and/or
desktop versions of our application and monitor your
behavior for the purpose of improving the efficiency and
usability of our services.
|
1. Identity Data
2. Contact Data
3. Profile
Data
4. Usage Data Technical Data
5. Marketing and
Communication Data
|
1. Necessary to perform our contract with you
2.
Necessary for our legitimate interests (to study how
customers use our products/services, to develop them, to
grow our business)
|
| h. |
1. to study how customers use our products/services, to
develop them, to grow our business and to inform our
marketing strategy;
2. statutory limitations
|
1. Transaction Data |
1. Necessary for our legitimate interests (including
statutory limitations provisions by applicable laws)
|
| i. |
1. To inform you about any of the following:
— new
services and/or products we may offer;
— Any new
development and/or features of the current products/services
we offer
|
1. Identity Data
2. Profile Data
3. Contact
Data
4. Technical Data
5. Usage Data
6.
Transactions
7. Marketing and Communication Data
|
1. Necessary to perform our contract with you
2.
Necessary for our legitimate interests (to study how
customers use our products/services, to develop our
products/services and grow our business)
|
| j. |
1. To send direct marketing of our services to you always
within the boundaries of our legitimate interests.
2.
To send to you newsletters, push-messages and calls to keep
you in touch with our new feature and new development of the
current products/services we offer, news and events and the
efficient provision of the full scope of our services.
Please
note that we will never use your data to communicate to you
and/or promote any third party marketing material.
|
1. Identity Data
2. Profile Data
3. Contact
Data
4. Data that may be provided by you during your
activity at the Website.
Marketing and Communication
Data
|
1. Necessary to perform our contract with you
2.
Necessary for our legitimate interests (to provide effective
and personalized customer services to you and to update you
in relation to our services that are available to you.
|
| k. |
1. To allow us to provide you with the optimal operation on
our Website, mobile and desktop versions of our application
and monitor your behavior for the purpose of improving the
efficiency and usability of our Services.
2. To use
analytics tools to track performance of the Website and
marketing source of our Clients in order to optimize our
marketing costs and provide you with better experience.
|
1. Location Data
2. Technical Data
3. Usage
Data
4. Marketing and Communication Data
|
1. Necessary to perform our contract with you
2.
Necessary for our legitimate interests (to provide effective
and personalized customer services to you and to update you
in relation to our services that are available to you).
|
| l. |
1. to allow us to monitor and train our employees for your
benefit
2. to safeguard your or our interests in case
of a dispute
3. to take steps for fraud prevention
4.
to improve the services provided to you
|
Audio Data |
1. Necessary to perform our contract with you
2.
Necessary to comply with our legal obligations
3.
Necessary for our legitimate interests
|
| m. |
1. To confirm that your annual income corresponds with your
employment status
2. To confirm that you have no
criminal history.
|
Sensitive Data |
1. Necessary to comply with our legal obligations
2.
Necessary to protect your vital interests.
|
-
If you are an existing Client of the Website where we have a
legitimate interest in communicating with you, or if you have
given us your consent we will collect and process your personal
data to communicate with you in case of support and/or sending
newsletters, push-messages and calls to keep you in touch with
our new features, news and events and the efficient provision of
the full scope of our services. We will also use your data to
send you marketing information regarding our services that we
believe may be of interest to you via email or otherwise.
-
Our Website is not intended for children and we do not knowingly
collect data relating to children. As we do not allow users
under the age of 18 to use our services, we need to obtain your
birth date in order to confirm the Clients’ age checks.
5. OPTING OUT
If you do not want to receive any marketing newsletters or
transmit your data to the third-parties for marketing purposes,
you can configure your preferences. Such configuring can be done
when (i) opening an account or (ii) when receiving such
advertising content or (iii) by logging in and going to My Account
> Personal Details > Notification Settings. You may also
send to the Company, at any time, an email to
support@atlastopper
using the registered email address you disclosed and registered
with us through your Account asking the Company to cease from
sending such advertising content or sending your data to the
third-parties for marketing purposes. The aforesaid mark removal
and/or e-mail received by Atlastopper will oblige us
to cease sending advertisement content to you within 7 (seven)
business days.
6. DISCLOSURE OF DATA
-
We may share your data with the parties for the purposes set out
above.
-
We require all Atlastopper Group companies and any
third parties processing data on our behalf to respect your data
and to treat it in accordance with the provisions of the General
Data Protection Regulation and applicable local legislation as
amended from time to time. We take all reasonable steps so that
our third-party service providers do not use your personal data
for their own purposes and only permit them to process your data
for specific purposes and in accordance with our instructions.
-
Atlastopper group companies. In
general, your data is used by the processors of the
Atlastopper group.
-
In addition, a transfer of your data to another legal entity may
occur as part of a transfer of our business or parts thereof in
form of a reorganization, sale of assets, consolidation, merger
or similar.
-
With regard to the transfer of data to recipients outside the
Atlastopper group, we note that we strive to
maintain discretion with respect to client related matters and
assessments of which we acquire knowledge. We may disclose data
that concerns you only if (i) we are legally required to do so;
(ii) if required when you expressly order us to process a
transaction or any other service and (iii) it is required for
the provision of our services under our contractual relationship
and/or (iv) protection of our legitimate interests and
applicable legislation as amended from time to time.
-
External Third Parties. Your data is shared
with third party organisations/entities including but not
limited to:
-
A. Service Providers. We may share your
data with our trusted third party service providers, who, on
our behalf, operate, maintain, and/or support our IT systems
and IT infrastructure, our websites, manage our payment
solutions, perform statistical analysis, marketing and
advertising purposes, sending newsletters, provide customer
support and perform other important services for us.
-
B.
Other Atlastopper Affiliates.
We may also disclose your data to other Althexinvestment
Limited Affiliate companies in order for them to provide us
with the relevant services.
-
C. State authorities. The Client's details
that are provided and/or that will be provided by the Client
during his/her activity on the site may be disclosed by the
Company to official authorities. The Company will make such
disclosure only if required to be disclosed by the Company
by applicable law or court order and to the minimum required
extent.
-
D. Other disclosures. In addition to where
you have consented to a disclosure of the data or where
disclosure is necessary to achieve the purpose(s) for which,
it was collected, data may also be disclosed in special
situations, where we have reason to believe that doing so is
necessary to identify, contact or bring legal action against
anyone damaging, injuring, or interfering (intentionally or
unintentionally) with our rights or property, users, or
anyone else who could be harmed by such activities, or
otherwise where necessary for the establishment, exercise or
defence of legal claims.
-
Where reasonably possible, management shall ensure that third
parties collecting, storing or processing personal information
on behalf of the Company have:
-
a. Signed agreements to protect personal information
consistent with this Privacy Policy and information security
practices or implemented measures as prescribed by
applicable laws;
-
b. Signed non-disclosure agreements or confidentiality
agreements which includes privacy clauses in the contract;
and
-
c. Established procedures to meet the terms of their
agreement with third party to protect personal information.
-
Remedial action shall be taken in response to misuse or
unauthorized disclosure of personal information by a third party
collecting, storing or processing personal information on behalf
of Atlastopper .
-
If you want to obtain further information on any data transfers
mentioned above please contact us using the registered email
address you disclosed and registered with us through your
Account through the points of contact listed in the Section OUR
CONTACT DETAILS below.
7. DATA RETENTION
We store your data for as long as reasonably necessary to fulfil
the purposes we collected it for, including for the purposes of
satisfying any legal, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event
of a complaint or if we reasonably believe there is a prospect of
litigation in respect to our relationship with you.
To determine the appropriate retention period for your data, we
consider the amount, nature and sensitivity of the data, the
potential risk of harm from unauthorised use or disclosure of your
data, the purposes for which we process your data and whether we
can achieve those purposes through other means, and the applicable
legal, tax, accounting and other requirements.
We shall keep your data (including call recordings) during our
contractual relationship and for a minimum period of 5 (five)
years from the date of termination of the Platform/Service used by
the Client.
In general, all other data is stored for a period of 30 (thirty)
business days after the date of termination of the provision of
our services unless there is any other legal reason to keep it.
At the expiration of the data retention period the data is erased
by irreversible destruction and we also inform all third parties,
to whom the data was transferred, regarding such erasure and
request implementation of similar actions on their part.
8. YOUR RIGHTS AND HOW TO WITHDRAW CONSENTS AND UNSUBSCRIBE
-
We ask you to provide us with true, accurate and updated
information on your identity and not misrepresent yourself to be
another individual or legal entity. Any changes in your
identifying details shall be notified to the Company immediately
and in any case no later than the 7th day from the date of such
changes. If your data is incorrect or incomplete, please contact
our support services at the contact details listed in the
section OUR CONTACT DETAILS below in order to change your data.
-
Under certain circumstances, you have rights in accordance with
applicable legislation and our policies as amended from time to
time. Some of the rights are rather complex and include
exemptions, thus we strongly advise you to contact us (at the
contact details listed in the section OUR CONTACT DETAILS
below). You can find a summary of your rights below in this
section.
-
A. The right to access. You have a right to
obtain the confirmation as to whether or not your data are
being processed by us. In addition, you have a right to
obtain more detailed information about the data kept and the
processing undertaken by us and under certain circumstances
the right to receive a copy of this data.
-
B. The right to rectification. You have the
right to have inaccurate data about you rectified, and,
taking into account the purpose of the processing, to have
incomplete data completed.
-
C. The right to erasure. This enables you
to ask us to delete or remove personal data where there is
no good reason for us continuing to process it. Please note
however that we may not always be able to comply with your
request of erasure for specific legal reasons which will be
notified to you, if applicable, at the time of your request.
In case if you want to obtain complete erasure of your data
(to apply the “right to be forgotten”), please note that we
may not always be able to comply with your request of
erasure for specific legal reasons which will be notified to
you, if applicable, at the time of your request.
-
D. The right to restriction of processing.
You have the right to request the restriction of processing
of your personal data (a) if it is not accurate;(b) where
processing may be unlawful but you do not want us to erase
your data; (c) where you need us to hold the data even if we
no longer require it; or (d) where you may have objected to
our use of your data but we need to verify whether we have
overriding legitimate grounds to use it.
-
E. The right to data portability. To the
extent the legal basis for the processing is your consent,
and such processing is carried out by automated means, you
have the right to receive your data in a structured,
commonly used and machine-readable format. However, this
right does not apply where it would adversely affect the
rights and freedoms of others and/or in case it may be
technically impossible to do so.
-
F. The right to object. Subject to the
legal basis on which the processing activity is based, you
may object to processing of your personal data. Please note
that in some cases, we may have compelling legitimate
grounds to process your information which we need to comply
with.
-
G. The right to withdraw consent. To the
extent that the legal basis for the processing is your
consent, you have the right to withdraw from that consent at
any time. This may apply to marketing purposes and/or with
regards to the transfer of your data to third parties. In
case you withdraw from a consent given, then we will cease
to process your data, unless and to the extent the continued
processing is permitted or required according to the
applicable data regulation or other applicable laws and
regulations. The withdrawal from your consent will in no
event affect the lawfulness of processing based on consent
before its withdrawal.
-
H. The right to complaint to data protection supervisory
authority. We do our best to ensure that we protect your data, keep
you informed about how we process your data and comply with
the applicable data protection regulation. In case you are
not satisfied with the processing and protection of your
data or the information you have received from us, then we
urge you to inform us in order for us to improve. Please
also do not hesitate to contact us, if you want to make use
of your rights.
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If you want to exercise any of your rights mentioned above
and/or obtain more information regarding your rights and/or our
policies and procedures please contact us through the points of
contact listed in the Section OUR CONTACT DETAILS below. Please
also provide us with relevant information to take care of your
request, including your full name and email address so that we
can identify you. We will respond to your request without undue
delay.
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We may need to request specific information from you to help us
confirm your identity and ensure your right to access your data
(or to exercise any of your other rights). This is a security
measure to ensure that personal data is not disclosed to any
person who has no right to receive it. We may also contact you
to ask you further information in relation to your request to
speed up our response.
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We try to respond to all legitimate requests within one month.
Occasionally it could take longer than a month if your request
is particularly complex or you have made a number of requests.
In this case, we will notify you and keep you updated.
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We may charge you a reasonable administrative fee for any
unreasonable or excessive requests we may receive, and for any
additional copies of the data you may request.
9. DATA SECURITY
We have put in place appropriate security measures to prevent your
data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit
access to your data to those employees, agents, contractors and
other third parties who have a business need to know. They will
only process your data on our instructions and they are subject to
a duty of confidentiality.
We have put in place procedures to deal with any suspected data
breach and will notify you of a breach where we are legally
required to do so.
Your help is always valuable in ensuring that your data is kept
safe. Upon registration to the Website (or its mobile version),
the Client will be asked to choose a username and password to be
used by the Client on each future login and for the performance of
transactions and use of the Company's Services. In order to
protect the Client's privacy and operation with the Website
sharing registration details (including without limitation,
username and password) by the Client with other persons or
business entities is strictly prohibited. The Company shall not be
held responsible for any damage or loss caused to the Client due
to improper use (including prohibited and unprotected use) or
storage of such username and password, including any such use made
by a third party, and whether or not known to or authorized by the
Client.
Any use of the Website with the Client's username and password is
Client's sole responsibility. The Company shall not be held
responsible for any such use, including for validation that Client
is actually operating in his/her account.
The Client is obliged to forthwith notify the Company's client
service of any suspicion for unauthorized use of the Client’s
account. You may contact us at any time through the points of
contact listed in the Section OUR CONTACT DETAILS below.
Encryption of your data in transit. Encryption
provides a high level of security and privacy for your data. When
you enter your data in our platform we use strong encryption
technologies (such as Transport Layer Security) to protect your
data during transmission from your devices to our servers.
For providing more trust and security we use digital EV (Extended
Validation) Certificates issued by trusted Certificate
Authorities. You can see the ‘Green Bar’ in the supported browser
versions which confirms what all transmitted data is secure.
Protection of your data in our infrastructure. We
make it a priority to develop services that are secure "by
default". The "default" security of our services means that all
new services and features are designed with strict security
requirements in mind before we even begin development. This is the
key to guaranteed protection and privacy of all data that our
services handle and store, once the service or new feature is
released.
To secure your data, we use the pseudonymisation which allows most
of our services to operate without using your actual data. Instead
of that, our services use a system ID that can't be traced back to
identify you.
The Company is always vigilant about the security of your data
stored in our infrastructure. Because of that we locate all our
equipment which is used for your data processing in secure data
centres. Network access to this equipment is isolated from the
Internet. We use network segmentation for isolation of services
which need different levels of security from each other. In
addition, we restrict logical access to your data for our
employees on a "need to know" basis. So, only the personnel that
really requires access to your data for the purpose of providing
you with our best service, will have access to it.
Threats protection. Our Company is highly
knowledgeable about modern threats to data security and privacy,
and we are well prepared to combat them. All events that occur in
our infrastructure are continuously monitored, analysed and
responded, which allows us to ensure proper protection of your
data, keeping it safe from threats, vulnerabilities, and the
effects of malware.
In the event of a failure that affects the accessibility of your
data, we have data backup and recovery procedures in place that
will help us restore your data in a short time. To guarantee quick
recovery, we use high availability mode enabled for most critical
databases which allows us to minimize downtime.
Employee awareness of data security. Our
employees may handle your data in order to provide you with the
first-class service. To guarantee the security and confidentiality
of your data, we monitor all employees’ actions with access to
your data in our systems and grant access strictly on a "need to
know" basis: only employees who need access will receive it. We
hold regular training sessions to make sure that each employee
understands the principles that the Company follows to achieve
robust data security and privacy.
If you choose not to give your personal information. In the context of our business relationship we may need to
collect data by law, or under the terms of a contract we have with
you. Without this data, we are, in principle, not in a position to
close or execute a contract with you.
If you choose not to give us this data, it may delay or prevent us
from meeting our obligations. It may also mean that we cannot
perform services needed to run your accounts or policies.
To what extent we carry automated decision-making and
profiling. In establishing and carrying out a business relationship, we
generally do not use automated decision-making. If we use this
procedure in individual cases, we will inform you of this
separately. In some cases, we may proceed with profiling in order
to evaluate certain personal aspects. We shall inform you
accordingly in case we perform any profiling. In general, any data
collection that is optional would be made clear at the point of
collection.
10. OUR CONTACT DETAILS
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Who is responsible for the data processing and who you can
contact.
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The entity responsible for your data processing is
Atlastopper LLC and you can contact us using the
details set out below:
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Hinds Building, Kingstown, St. Vincent and the Grenadines
- Data Protection Officer
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We have appointed a data protection officer (hereinafter
DPO) who is responsible for overseeing
questions in relation to this Privacy Policy. If you have any
questions about this privacy policy, including requests relating
to the data, please contact the DPO using the details set out
below:
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Hinds Building, Kingstown, St. Vincent and the Grenadines
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support@atlastopper
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To enable us to process your request, please contact us using
the registered email address you disclosed and registered with
us through your Account. We may require that you provide us with
proof of your identity, such as by providing us with a copy of a
valid form of identification. This is to ensure that we
appropriately protect the personal data we hold from
unauthorised access requests and comply with our security
obligations.
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If you have any questions, or want more details about how we use
your data, you may contact us at the above contact details and
we will be happy to provide you with further details.
11. LINKS TO OTHER WEBSITES
We may provide links to third party websites in our Website. These
linked websites are not under our control, and we therefore cannot
accept responsibility or liability for the conduct of third
parties linked to our websites, including without limitation to
the collection or disclosure of your data. Before disclosing your
data on any other website, we encourage you to examine the terms
and conditions of using that website and its privacy policies.
12. CHANGES TO THIS PRIVACY POLICY
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This Privacy Policy was last updated 09 November 2020. We
reserve the right, at our discretion, to add, modify or
remove portions of this Privacy Policy in the future to
ensure that the information herein provides relevant and
adequate information about our collecting and processing of
your data.
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This privacy policy may be supplemented by other information
received from the Atlastopper group and other
terms and conditions applicable to the Website or which you
have agreed to as part of your interaction with us.
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In case of updates, we will post the revised Privacy Policy
on our website. Changes will take effect as soon as the
revised version is made available on our website. Your
comments and feedback are always welcome. You may contact us
at any time through the points of contact listed in the
Section OUR CONTACT DETAILS above.
APPENDIX A
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In relation to a company, that company, any subsidiary or
subsidiary undertaking or any holding company or holding
undertaking or any connected company from time to time of
that company.
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An undertaking is a parent undertaking in relation to
another undertaking, a subsidiary undertaking, if
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a. it holds a majority of the voting rights in the
undertaking, or
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b. it is a member of the undertaking and has the right
to appoint or remove a majority of its board of
directors, or
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c. it has the right to exercise a dominant influence
over the undertaking—
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d. by virtue of provisions contained in the
undertaking's articles, or
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e. by virtue of a control contract, or
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f. it is a member of the undertaking and controls alone,
pursuant to an agreement with other shareholders or
members, a majority of the voting rights in the
undertaking.
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For the purposes of the above an undertaking shall be
treated as a member of another undertaking—
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a. if any of its subsidiary undertakings is a member of
that undertaking, or
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b. if any shares in that other undertaking are held by a
person acting on behalf of the undertaking or any of its
subsidiary undertakings.
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A parent undertaking shall be treated as the parent
undertaking of undertakings in relation to which any of its
subsidiary undertakings are, or are to be treated as, parent
undertakings; and references to its subsidiary undertakings
shall be construed accordingly.
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A company is connected with another company if:
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a. the same person has direct or indirect control of
both companies,
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b. a person (“A”) has control of one company and persons
connected with A have control of the other company,
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c. A has control of one company and A together with
persons connected with A have control of the other
company, or
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d. a group of two or more persons has control of both
companies and the groups either consist of the same
persons or could be so regarded if (in one or more
cases) a member of either group were replaced by a
person with whom the member is connected.