PRIVACY POLICY
Last updated May 22, 2023
This privacy notice for AtlasClear Holdings (doing business as AtlasClear) ("AtlasClear," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:
Visit our website at http://www.atlasclear.com, or any website of ours that links to this privacy notice
Engage with us in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at Info@AtlasFinTech.com.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with AtlasClear and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do we receive any information from third parties? We do not receive any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what AtlasClear does with any information we collect? Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR DO-NOT-TRACK FEATURES
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
names
email addresses
Sensitive Information. We do not process sensitive information.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
Provide the Services. We may use your personal information to provide the Services and any other Services or services you may request from us. (CONSENT; CONTRACT; LEGITIMATE INTEREST)
Monitor the Services. We collect your Perso personal information for monitoring purposes to help us diagnose problems with our servers, administer and troubleshoot the Services, calculate usage levels, analyze industry standards, and analyze transactions, trends, and statistics regarding the use of the Services. (CONSENT; LEGITIMATE INTEREST)
Respond to Inquiries and Fulfill Requests. We may use your personal information to respond to your inquiries and to fulfill your requests for information. (CONSENT)
Communicate with You. We may use your personal information to send you marketing information about the Services, special promotions, and other items that may be of interest to you. We may also contact you on behalf of our third-party business partners about a particular offering of theirs that may be of interest to you. (CONSENT; LEGITIMATE INTEREST)
Improve the Services. We may use your personal information to make the Services more stable and user-friendly, to analyze service issues, improve the design and content of the Services, personalize your experience, analyze how the Services is used, offer new services, and to develop new marketing programs relating to the Services. (CONSENT, LEGITIMATE INTEREST)
Customer Service. We may use your personal information when contacting you regarding customer service, the Services, or in response when you provide feedback. We may also use your information to send administrative emails regarding the Services or to inform you of any changes to this Privacy Policy, our Terms, or our third-party partner’s Terms. (CONSENT; LEGITIMATE INTEREST)
Support Business Operations. We may use your personal information to support our internal and business operations, including marketing, security, and advertising. (CONSENT; LEGITIMATE INTEREST)
Enforce Agreements. We may use your personal information to enforce separate agreements between you and us, enforce this Privacy Policy, our Terms of Use, or our third-party partner’s Terms of Use, or in connection with a transaction with a similar effect. (CONSENT; CONTRACT)
Fulfill Other Purposes. We may use your personal information to fulfill: (a) any other purpose for which you provide it; (b) any legal or regulatory requirements and any of our internal policies; (c) other purposes disclosed at the time of collection; (d) any other purpose with your consent; and (e) any other purposes set forth in this Privacy Policy. (CONSENT; LEGITIMATE INTEREST)
If our processing is based solely on your consent, subject to limited legal exceptions, you have the right to withdraw your consent at any time.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. This may include:
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
For investigations and fraud detection and prevention
For business transactions provided certain conditions are met
If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
For identifying injured, ill, or deceased persons and communicating with next of kin
If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
If the collection is solely for journalistic, artistic, or literary purposes
If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:
Ad Networks
Cloud Computing Services
Communication & Collaboration Tools
Data Analytics Services
Data Storage Service Providers
Finance & Accounting Tools
Payment Processors
Product Engineering & Design Tools
Retargeting Platforms
Sales & Marketing Tools
Social Networks
Website Hosting Service Providers
User Account Registration & Authentication Services
We also may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain information when you make location-specific requests. This includes: __________; and other similar information. A full list of what we use information for can be found in this section and in the previous section titled “HOW DO WE PROCESS YOUR INFORMATION?“. We obtain and store on your device (“cache”) your location. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. The Google Maps Platform APIs that we use store and access cookies and other information on your devices. If you are a user currently in the European Economic Area (EU countries, Iceland, Liechtenstein, and Norway) or the United Kingdom, please take a look at our Cookie Notice.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction.
Other Disclosures. We may disclose your personal information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) conform to legal requirements and comply with any court order, law, or legal process, including responding to any government, law enforcement, or regulatory request; (ii) enforce the Terms of Use, other agreements, including between you and us, and any other documents included or referenced therein (all of which are incorporated into and made a part of this Privacy Policy by reference); (iii) fulfill the purpose for which you provide it; (iv) detect, prevent, or otherwise address fraud or security issues; or (v) protect against harm to our, your, or third parties’ rights, property, or safety.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
6. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at Info@AtlasFinTech.com.
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.
However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Advertising: We may also use third-party advertisers, ad networks, and other advertising, marketing, and promotional companies, to serve advertisements about the Services. Such third parties may gather information about your visit to the Services, monitor your access or market the Services to you, monitor the ads you view, click-on, or interact with, when they were delivered, and the screens and pages that they are on. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt out by clicking here. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
We and our service providers may use information about your interactions with the Services to predict your interests and select the ads you see on and off the Services. This is known as interest-based advertising. In providing interest-based ads, we follow the Self-Regulatory Principles for Online Behavioral Advertising developed by the Digital Advertising Alliance. For more information about interest-based advertising and how you can opt out, visit:
Digital Advertising Alliance: http://www.aboutads.info/choices
Network Advertising Initiative (NAI): http://www.networkadvertising.org/choices/
Marketing: From time to time if you have supplied your email address, we may send you marketing or informational emails. If you prefer not to receive any or all of our marketing and promotional communications, you may opt-out of these communications by following the opt-out prompts on these communications. You also may ask us not to send you other marketing or informational communications by contacting us as specified in the Contact Information section below, and we will honor your request. Please note that even after you are removed from our marketing lists, we may still send you non-promotional communications, such as responding to your support requests.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertisers on our Services.
We are providing this list to give you transparency into the cookies and similar technologies used by AtlasClear. While AtlasClear’s technologies change over time, the following tables provide brief descriptions of the key technologies used on AtlasClear properties.
The previous version of this disclosure can be found here.
1. Internal Cookies & Similar Technologies Used on AtlasClear.com
The following are first-party cookies used on AtlasClear properties including AtlasClear.com, the Apps and on custom domains run through AtlasClear Pattern
|
Name |
Domain |
Use |
Expiration |
|
_dc, _gtm_* |
*.AtlasClear.com |
Google Tag Manager for managing third party cookies and technologies |
Session |
|
_ga, _gat, _gcl, _gid |
*.AtlasClear.com |
Google Analytics (including related advertising services) |
1 Day to 13 Months |
|
activity_tracker_* |
*.AtlasClear.com |
Recent listings viewed (locally stored object) |
Varies |
|
analyticsTrackFunction, pageviewInfo, eventInfo |
*.AtlasClear.com |
Mobile analytics |
Session |
|
app_banner_dismissed |
*.AtlasClear.com |
Page and banner rendering |
1 Month |
|
bc_* |
*.AtlasClear.com |
AtlasClear blog authentication cookie |
1 Year |
|
coupons |
*.AtlasClear.com |
Temporary cookie that carries coupons to checkout |
Session |
|
dashboard_stats_channel |
*.AtlasClear.com |
Saves last selected channel in Shop Manager stats |
13 Months |
|
dashboard_stats_range |
*.AtlasClear.com |
Saves last selected date range in Shop Manager stats |
13 Months |
|
Datr, fr, sb, wd, fbp*, fblo*, fbm*, fbsr* |
*.AtlasClear.com |
Facebook browser identification, authentication, marketing, and other Facebook-specific function cookies |
Varies |
|
ecvc |
*.AtlasClear.com |
EU cookie notification flag |
10 Months |
|
et_* |
*.AtlasClear.com |
AtlasClear authentication cookie |
1 Year |
|
eud |
Pattern sites |
Page and banner rendering |
13 Months |
|
exp* |
*.AtlasClear.com |
Experiments |
3 Months |
|
fve |
www.AtlasClear.com |
AtlasClear analytics cookie for first visits |
1 Month |
|
G_AUTHUSER_H, G_ENABLED_ID |
*.AtlasClear.com |
Google authentication and analytics |
Session or Persistent |
|
granify_* |
.AtlasClear.com |
Granify cookie for marketing and offers |
Session to 11 Months |
|
gtm_* |
.AtlasClear.com |
Google tag manager |
1 Day |
|
last_browse_page |
*.AtlasClear.com |
Previous page browsed |
Session |
|
LD, sr |
.AtlasClear.com |
AtlasClear sign-in cookie |
Session to 1 Year |
|
MP_* |
*.AtlasClear.com |
AtlasClear international flags and view type |
1 Year |
|
msg-feedback-dismiss |
*.AtlasClear.com |
Page and banner rendering |
session |
|
p |
*.AtlasClear.com |
GDPR/CCPA and general privacy cookie |
1 Year |
|
perf |
*.AtlasClear.com |
Performance |
1 Session |
|
pla_spr |
*.AtlasClear.com |
Ad attribution |
1 Week |
|
prolist_* |
*.AtlasClear.com |
Ad formatting |
Varies |
|
search_options, guided_search_seen |
www.AtlasClear.com |
AtlasClear user search preferences |
Session |
|
st_*, sr |
*AtlasClear.com |
AtlasClear authentication cookie |
1 Year |
|
stats_linebar_filte\r_* |
*.AtlasClear.com |
Saves last selected graph filter in Shop Manager stats |
5 Years |
|
stats_visited, tabs_clicked |
Front end store options |
AtlasClear shop statistics cookie |
5 Years |
|
supports_apple_pay |
*.AtlasClear.com |
Flags if user's browser supports Apple Pay payment method |
1 Day |
|
UA*, UAID* |
*.AtlasClear.com |
AtlasClear browser cookie used for analytics, security, and site personalization |
Session to 13 Months |
|
user_prefs |
*.AtlasClear.com |
AtlasClear user preferences (such as locale, shipping, preferred language) |
11 Months |
2. Marketing & Third-Party Cookies & Similar Technologies
|
Name / Network |
Use |
Third-Party Privacy Policies |
User controls |
|
Awin / Digital Window / Zanox |
Affiliate Marketing |
||
|
Bing Ads |
Marketing |
Microsoft Privacy Statement / Microsoft Data Protection Policies |
|
|
Branch.io |
Link attribution |
||
|
Braze |
Marketing and Attribution |
||
|
Button |
Affiliate Marketing |
||
|
Facebook (Connect) |
Social media functionality |
||
|
Facebook (Custom Audience & Remarketing) |
Marketing |
||
|
ForeSee |
Performance and functionality |
||
|
FusePump |
Feed management |
||
|
Google Ads |
Marketing |
||
|
Google Analytics |
Analytics and marketing |
||
|
Google Tag Manager |
Management of cookies and tags for marketing and non-marketing functions |
||
|
iSpot |
Ad attribution |
||
|
Kenshoo |
Marketing |
||
|
Granify |
Personalized AtlasClear marketing notifications |
||
|
Full Story |
Browser analytics and mouse interactions |
||
|
Lithium / Khoros |
AtlasClear Forums login cookie and analytics |
Browser or mobile device settings , and contact at marketing@khoros.com |
|
|
Neustar |
Marketing Analytics / Ad attribution |
||
|
Oceanmedia |
Ad attribution |
Browser or mobile device settings , and contact at info@oceanmediainc.com |
|
|
Outbrain |
Marketing |
||
|
|
Social networking and marketing |
||
|
ReturnPath |
Email marketing |
||
|
|
Social networking and marketing |
3. Technologies Used in AtlasClear Mobile Apps
While AtlasClear’s app software development kits (“SDKs”) change over time, and can differ in app versions, some key app SDKs include:
|
Library Name |
Details |
Policy Link |
Link to User Control |
|
Apple Pay mobile payments |
Not a marketing service |
||
|
Mobile measurement & attribution |
|||
|
Link shortener and redirects, including device tracking |
Opt-out choices via Privacy Policy links |
||
|
Deep link attribution and handling |
|||
|
Marketing and attribution services |
|||
|
Marketing and attribution |
|||
|
Facebook Analytics |
|||
|
|
|||
|
Mobile app development |
Not a marketing service |
||
|
Google Pay |
Not a marketing service |
||
|
Sign-in via Google |
Not a marketing service |
||
|
User surveys |
Contained in email survey invitations |
||
|
Marketing Attribution via Salesforce |
|||
|
Real-time chat support for end users |
Not a marketing service |
4. Social Media Technologies
When you use social media platforms with AtlasClear, each platform has its own technologies and policies to be aware of. For information on limiting the use of widgets and sharing functions with social networks, see below:
For Twitter widgets, you can find more information here.
For Facebook widgets, you can find more information here.
For Pinterest widgets, you can find more information here.
5. Browser or Mobile Device Settings
*Please see our Cookies & Similar Technologies Policy for information about using settings to reflect your privacy preferences for browser cookies, browser privacy, mobile device, or IoT device privacy, and cookie and ad tracking.
If you have questions or comments about your privacy rights, you may email us at Info@AtlasFinTech.com.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a "resident" as:
(1) every individual who is in the State of California for other than a temporary or transitory purpose and
(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as "non-residents."
If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
|
A. Identifiers |
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name |
NO |
|
B. Personal information categories listed in the California Customer Records statute |
Name, contact information, education, employment, employment history, and financial information |
NO |
|
C. Protected classification characteristics under California or federal law |
Gender and date of birth |
NO |
|
D. Commercial information |
Transaction information, purchase history, financial details, and payment information |
NO |
|
E. Biometric information |
Fingerprints and voiceprints |
NO |
|
F. Internet or other similar network activity |
Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements |
NO |
|
G. Geolocation data |
Device location |
NO |
|
H. Audio, electronic, visual, thermal, olfactory, or similar information |
Images and audio, video or call recordings created in connection with our business activities |
NO |
|
I. Professional or employment-related information |
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us |
NO |
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J. Education Information |
Student records and directory information |
NO |
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K. Inferences drawn from other personal information |
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics |
NO |
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L. Sensitive Personal Information |
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We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at Info@AtlasFinTech.com, by calling toll-free at (727) 446-6660, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.
Categories of Personal Information We Disclose to Each Type of Third Party
We may share your personal information with certain categories of third parties, as described below.
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Types of Third Parties to Which the Personal Information Was Disclosed for a Business Purpose |
Categories of Personal Information Disclosed for a Business Purpose |
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Financial service vendors |
Demographic information |
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(See example above Co-Branded Products and Services) |
Device and online identifiers |
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Financial information |
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Individual preferences and characteristics |
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Location |
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Personal identifiers |
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Purchase history information |
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Those we are legally required to share with |
Audio, visual and other sensory information |
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(See example above Legal Requirements and Protection of Our Company and Others) |
Background and criminal information |
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Biometric information |
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Characteristics of protected classifications under California or federal law |
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Demographic information |
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Device and online identifiers |
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Education information |
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Employment information |
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Financial information |
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Government identifiers |
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Health and health insurance information |
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Individual preferences and characteristics |
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Internet, application, and network activity |
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Location information |
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Personal identifiers |
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Purchase history information |
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Service providers that receive data in order to provide services to us (e.g. technology providers, cloud storage providers, etc.) |
Audio, visual and other sensory information |
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(See example above Service Providers) |
Background and criminal information |
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Biometric information |
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Characteristics of protected classifications under California or federal law |
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Demographic information |
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Device and online identifiers |
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Education information |
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Employment information |
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Financial information |
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Government identifiers |
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Health and health insurance information |
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Individual preferences and characteristics |
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Internet, application, and network activity |
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Location information |
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Personal identifiers |
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Purchase history information |
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Third parties with whom individuals direct us to share their personal information |
Audio, visual and other sensory information |
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(See example above Co-Branded Products and Services and With Your Consent) |
Demographic information |
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Device and online identifiers |
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Employment information |
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Financial information |
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Health and health insurance information |
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Individual preferences and characteristics |
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Location information |
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Personal identifiers |
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Purchase history information |
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Our suppliers or marketplace vendors |
Audio, visual and other sensory information |
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(See example above Products and Services Offered by Other Businesses) |
Device and online identifiers |
|
Employment information |
|
|
Government identifiers |
|
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Individual preferences and characteristics |
|
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Personal identifiers |
|
|
Purchase history information |
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.
AtlasClear Holdings has not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. AtlasClear Holdings will not sell or share personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information
We do not process consumer's sensitive personal information.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at Info@AtlasFinTech.com, by calling toll-free at (727) 446-6660, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
12. DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.
Virginia CDPA Privacy Notice
Under the Virginia Consumer Data Protection Act (CDPA):
"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.
"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified data or publicly available information.
"Sale of personal data" means the exchange of personal data for monetary consideration.
If this definition "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how you interact with AtlasClear Holdings and our Services. To find out more, please visit the following links:
Your rights with respect to your personal data
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")
AtlasClear Holdings has not sold any personal data to third parties for business or commercial purposes. AtlasClear Holdings will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA
More information about our data collection and sharing practices can be found in this privacy notice.
You may contact us by email at Info@AtlasFinTech.com, by submitting a data subject access request, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification process
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.
Right to appeal
If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at Info@AtlasFinTech.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal if denied, you may contact the Attorney General to submit a complaint.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at Info@AtlasFinTech.com or contact us by post at:
AtlasClear Holdings
4221 W. Boy Scout Blvd.
Suite 300
Tampa, FL 33607
United States
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.