Last Updated: 16 December 2022
Except as otherwise noted below, this Policy applies to the personal information that Atlas processes as a controller or business related to:
In some cases, we may provide separate privacy notices specific to certain personal information that we collect and process. For example, we may provide separate notice to users of SaaS platforms or other portals that we make available to our customers. The separate notice will control with respect to your personal information that is subject to that notice.
All users, except EEA/UK residents: Your use of our Site or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service including its applicable limitations on damages and the resolution of disputes.
Information We Collect Directly From You
Purpose of Processing and Use
We use your information, including your personal information, for the following purposes:
Disclosure of Personal Information
We may disclose the personal information we collect for the purposes described above and as follows:
We also disclose your personal information in the following circumstances:
Where we use, disclose or process de-identified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device), we will maintain and use the information in deidentified form and not attempt to reidentify the information, except in order to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.
We have a general policy of retaining personal information for as long as necessary in view of the purposes for which we process it, including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements. We typically retain personal information for a period of time corresponding to a statute of limitation, for example to maintain an accurate record of your dealings with us, such as pursuant to a contract so that we can raise or defend a legal claim. In some circumstances we may retain personal information for other periods of time, for instance where we are required or permitted to do so in accordance with legal requirements, or if required to do so by a legal process, legal authority, or other governmental entity having authority to make the request, for so long as required. We may also retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation.
Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
We have implemented safeguards that are intended to protect the personal information that we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
We make available several ways for you to manage your preferences and privacy choices. These include:
If you are a California resident, please review “Additional Information for California Residents” below, for specific information about your rights under California privacy laws and how to exercise them.
Our Services are not designed for children under 16. If we discover that a child under 16 has provided us with personal information in violation of applicable law, we will delete such information from our systems.
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at:
United States and all countries other than in the EEA/UK
Atlas Technology Solutions
1 North Franklin St., Suite 2600, Chicago IL 60606
Phone: +1 (312) 392-0145
Elements Global Services Spain SL
World Trade Center, Muelle de Barcelona, edif. Sur, 2a planta, 08039, Barcelona, Spain
Phone: +34 93 545 11 57
Atlas Technology Solutions UK Limited
4th Floor Cordy House, 87-95 Curtain Road, London EC2A 3BS, United Kingdom
Phone: +44 20 3989 6300
Changes to this Policy
This Policy is current as of the Last Updated date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by, for example, highlighting the change on our Site.
Additional Information for California Residents
This section provides California residents with additional information regarding our collection, use and disclosure of their personal information, as well as their privacy rights under California privacy laws.
In this section, we provide additional information to California residents about how we handle their personal information, as required by the California Consumer Privacy Act (“CCPA”). This section does not address or apply to our handling of personal information that is exempt under the CCPA.
Categories of Personal Information Collected and Disclosed. While our processing of personal information varies based upon our relationship and interactions with you, the table below identifies, generally, the categories of personal information (as defined by the CCPA) that we have collected about California residents, as well as the categories of other entities to whom we may disclose this information for a business or commercial purpose.
Categories of Personal Information Collected
Categories of Other Entities To Which We Disclose
Includes direct identifiers, such as name, email address, phone number, address and other contact information; IP address and other online identifiers
Includes personal information, such as name, contact information, and financial or payment information), that individuals provide us in order to purchase or obtain our products and services. For example, this may include information collected when an individual purchases or orders our products and services, or enters into an agreement with us related to our products and services.
Includes records of products or services purchased, obtained, or considered, or other purchasing or use histories or tendencies. For example, this may include demographic information that we receive from third parties in order to better understand and reach our customers.
Internet and electronic network activity information
Including, but not limited to, browsing history, clickstream data, search history, and information regarding interactions with an internet website, application, or advertisement, including other usage data related to your use of any of our Services or other online services.
Location information about a particular individual or device.
Includes professional and employment-related information position(s) and business contact information.
Sales and Sharing of Personal Information. California privacy laws define a "sale" as disclosing or making available to a third-party personal information in exchange for monetary or other valuable consideration, and “sharing” broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. Atlas does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing aright to opt out). Please note that we do use third-party cookies for our advertising purposes as described above. We do not sell or share sensitive personal information, nor do we sell or share any personal information about individuals who we know are under sixteen (16) years old.
Sources of Personal Information. In general, we may collect the categories of personal information identified in the table above from the following categories of sources:
Third Parties that Control Collection of Personal Information. As further described in “Cookies and Other Tracking Mechanisms” above, we work with third-party ad companies and analytics providers who may collect information about users of our Services through cookies, pixels and similar tools. For example, we work with third party ad companies to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites and online services. These third-party ad companies may collect usage and browsing information within our Services, as well as on third-party sites, apps and services, such as IP address, location. They use this information to provide you more relevant ads and content and to evaluate the success of such ads and content. In addition, we work with third party analytics companies, who may collect usage data about our Services in order to provide us with reports and metrics that help us to evaluate usage and improve performance and user experiences.
Purposes of Collection and Use. As described in more detail in “How We Use Your Information” above, we collect, use and otherwise process the above personal information in order to provide our Services to you, respond to and fulfil your requests, as otherwise directed or consented to by you, and for the following business or commercial purposes:
Atlas only uses sensitive personal information that it collects subject to this Policy for the purposes permitted by the CCPA and does not collect or process sensitive personal information for the purpose of inferring characteristics about an individual.
Disclosure. As described in more detail in “Disclosures of Personal Information” above, we may disclose your personal information for the purposes described above, in order to provide our Services to you, to respond to and fulfil your requests, as otherwise directed or consented to by you, and as follows:
California Residents’ Rights. Under the CCPA, California residents have the following rights (subject to certain limitations):
Submitting CCPA Requests. California residents may exercise their CCPA privacy rights as set forth below.
Request to know/access, correct, and delete. California residents may submit CCPA requests to access/know, correct and delete their personal information maintained by us online by submitting a request via our email address at firstname.lastname@example.org. Alternatively, California residents may submit a request by calling us at 1 (800) 827-4660.
We will take steps to verify your request by matching the information provided by you with the information we have in our records. You must complete all required fields on our webform (or otherwise provide us with this information via the above toll-free number). We will process your request based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us at 1 (800) 827-4660; authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.
Requests to opt Out. California residents may exercise their right to opt out online by submitting an opt out request via our email address at email@example.com, or by calling us at 1 (800) 827-4660. We will apply your opt out based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request.
For more information about our privacy practices, you may contact us as set forth in “Contact Us” above.
Additional Information for Persons in the EEA/UK
A. Purposes of Processing and Legal Bases
This section details the purposes for processing personal information and the legal bases for which we process personal information, as required by the EEA and UK General Data Protection Regulation (the “GDPR”).
Legal Bases under GDPR. Pursuant to the GDPR, processing personal information may be justified by one of the following legal bases:
Purposes and Legal Bases of Use and Processing. We use personal information for the purposes set forth below, and for the legal bases described below:
B. Your Rights in respect of Your Personal Information
GDPR gives you certain rights regarding your personal information, subject to any conditions or limitations set out in applicable law:
See below, Contact Us, for information about how to exercise your rights.
You also have the right to submit a complaint to the relevant data protection authority of your habitual residence, your place of work or the place of the alleged infringement/violation of your rights. A list of EEA authorities is available here: Our Members |European Data Protection Board (europa.eu). The UK authority is available here: Contact us | ICO
C. International Data Transfers
We transfer personal information to countries outside of the EEA, and notably to the United States, which is not deemed by the European Commission to provide an adequate level of personal information protection.
Transfers within the Atlas group of companies will be performed on the basis of the EEA / UK standard contractual clauses for transfers as approved by the European Commission or the ICO. Transfers to service providers or other third parties will be made pursuant to the recipient’s compliance with standard contractual clauses; pursuant to the consent of the individual to whom the personal information pertains; as necessary to perform a contract with that individual or in the individual’s interest, or to carry out pre-contractual steps; or as otherwise permitted by applicable law. See below, Contact Us, for information about how to obtain a copy of standard contractual clauses.
D. Contact Us
If you wish to exercise any rights, or have any questions about this Policy or our privacy practices, you can reach us at:
Elements Global Services Spain SL
World Trade Center, Muelle de Barcelona, edif. Sur, 2a planta, 08039 Barcelona, Spain
Phone: +34 93 545 11 57
Atlas Technology Solutions UK Limited
EC2M 1NH London, Middlesex, England, United Kingdom
Phone: +4420 3989 6300
Atlas Technology Solutions, Inc.
1 North Franklin St, Suite 2600, Chicago, IL, 60606 United States
Phone: +1(312) 392-0145 or +1(800)827-4660
Our established legal entities span more than 160 countries, enabling us to support your global talent strategy wherever it takes you.