ATLAS TECHNOLOGY SOLUTIONS Privacy Policy

Last Updated: 16 December 2022

In this Privacy Policy (“Policy”), we describe how Atlas Technology Solutions Inc. (“Atlas”, “we”, or “us”) collects, uses, discloses, and otherwise processes personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information. If you are a resident of California, please also refer to “Additional Information for California Residents” below for information about the personal information we collect, the way we use that information and your rights under California privacy laws. If you are a resident of the EEA or UK, please also refer to “Additional Information for EEA/UK Residents” below for information about the personal information we collect, the way we use that information and your rights under EEA/UK privacy laws.

Scope
Except as otherwise noted below, this Policy applies to the personal information that Atlas processes as a controller or business related to:

• users of https://www.atlashxm.com/ (the “Site”), and the services we provide through the Site (collectively, the “Services”);
• individuals who register for or participate in our webinars and other events;
• individuals who are subscribed to receive news, information and marketing communications from us;
• individuals who communicate with us or otherwise engage with us related to our Services; and
• individuals who are our contacts at the vendors and service providers who assist us in providing our Services.
• Not In Scope. This Policy does not apply to the personal information that we collect and process about Atlas employees and personnel or job applicants and candidates. This Policy does not apply to services provided to our customers through our Atlas Technologies Platform. In addition, this Policy does not apply to the extent we process personal information, as a processor or service provider, on behalf of our business clients (“Client Content”).  Our processing of Client Content is subject to the terms of our contracts with each business client, who is the controller and business for the Client Content that we process on their behalf.‍‍

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.

• The Personal Information We Collect About You
• Purposes of Processing and Use
• Disclosures of Personal Information
• Cookies and Other Tracking Mechanisms
• Retention
• Third-Party Links
• Security
• Your Choices
• Children
• Contact Us
• Changes to this Policy
• Additional Information for California Residents
• Additional Information for Persons in the EEA/UK

Information We Collect Directly From You

• Contacting Us. If you request a demo or otherwise contact us through our Site, we will ask for your name, company name and location, business email address, telephone number and the reason for your request.
• Purchasing from Us. If you make a purchase from our Site, such as a white paper, we (or our payment processors) will collect the information we need to process your payment, such as your credit card information and billing address.
• Webinars. When you register for a webinar that we host, we will collect personal information from you to complete your registration, to provide you with the event details and to further contact you for future events. We may record our webinars, and all presenters will have their image and audio  captured in the recording. If you are an attendee, you may have the option of sharing your image and audio during the session. If you choose to do so, your image and audio will also be captured in the recording. Some webinars will feature a moderated Q&A. If you choose to interact with the Q&A, your comments may be published to others at the event and will also form part of there recording. For some events, we may publish the recording on our website and/or YouTube channel and these events will be viewable by visitors to our site and channel.
• Business Contacts.  If you are an employee or other representative of a vendor or service provider that does or may assist us in providing our Services, we will collect your name and contact information, such as your email address or telephone number, so that we can contact you in furtherance of our business relationship.
• Device and Browsing Information. We may use cookies, pixel tags, and other similar tracking technologies to automatically collect personal information when you access or use our Services, such as IP address, general location information such as your region, state, and city, browser type, domain names, access times, pages views, date/time stamps, operating system, language, mouse clicks, mouse movements, scrolling activity, device type, unique ID, Internet service provider, referring and exiting URLs, and similar device and browsing information.
• Activities and Usage. We may collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, and time spent within the Services.
• Location information. We may collect or derive location information about you, such as through your IP address.  

Where required by law, we may not collect this information without your prior consent. To the extent permitted by law, we may combine this information with other information that we have collected about you. For more information about our use of cookies and other similar technologies, please see the “Cookies and Other Tracking Mechanisms” section below and our EEA/UK cookie policy here.

Purpose of Processing and Use
‍We use your information, including your personal information, for the following purposes:

• Services and support. To provide and operate our Services, communicate with you about your use of the Services (including by email, telephone or text/SMS message), provide troubleshooting and technical support, respond to your inquiries, communicate with you about the Services, and for similar support purposes.
• Analytics and improvement. To better understand how users access and use the Services and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop our Services and its features, and for internal quality control and training purposes.
• Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
• Marketing and Promotions. For marketing and promotional purposes. For example, to send you information about our Services, such as newsletters and other marketing content, including information about Atlas events, technologies, and new offerings, as well as any other information that you sign up to receive. We also use the information that we learn about you to assist us in advertising our Services on third party websites and to assist us in evaluating the success of our advertising campaigns in various platforms.
• Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
• Planning and Managing Events. For event planning and management purposes, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
• Security and Protection of Rights. To protect the Services and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Service.
• Compliance and Legal Process; Litigation. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority. To establish, exercise or defend our interests in the context of disputes or litigation and other legal claims or proceedings in which we are involved.
• Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, recordkeeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures.
• General Business and Operational Support. To assess and implement business transfers, mergers, acquisitions, reorganizations, bankruptcies, financings and other business transactions, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

Disclosure of Personal Information

We may disclose the personal information we collect for the purposes described above and as follows:

• Affiliates. We disclose the information we collect from you to other entities within our corporate group.
• Vendors and Services Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting, marketing and marketing research providers, customer support, data storage, analysis and processing providers, auditors, consultants and legal counsel.
• Marketing and Analytics Providers. We may also disclose your personal information, such as device and browsing, and activities and usage information, with marketing and advertising networks, data analytics providers, and other companies who provide marketing or analytics services to us or on our behalf. For more information see the “Cookies and Other Tracking Mechanisms” section below.

We also disclose your personal information in the following circumstances:

• Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected from you to the other company.  As part of the business transfer process, we may share certain of your personal information with lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. We may disclose personal information to comply with our legal and compliance obligations and to respond to legal inquiries. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
• Security and Protection of Rights. We may disclose personal information where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, detect, investigate and take action in response to violations of our Terms of Service. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Aggregate and Non-Identifiable Information. Notwithstanding anything else in this Policy, to the extent permitted by law, we may share, use, disclose, and otherwise process aggregate or de-identified information related to our business and the Serviceswith third parties for quality control, analytics, marketing, research, development, and other purposes.

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.

Retention
‍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.

Third-Party Links
‍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.

Security
‍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.

Your Choices
‍We make available several ways for you to manage your preferences and privacy choices. These include:

• Contact Information. You can update certain personal information we maintain about you (e.g., name and email address) by contacting us using the contact information provided below.
• Marketing and Other Communications. You can opt out of receiving marketing or other email communications from us by following the instructions provided in each email we send you.
• Cookie Preferences.  You can update your preferences related to the cookies operating on our Site here.

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.

Children
‍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.

Contact Us
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        
Email: compliance@atlashxm.com        

EEA
Elements Global Services Spain SL      
World Trade Center, Muelle de Barcelona, edif. Sur, 2a planta, 08039, Barcelona, Spain  
Phone: +34 93 545 11 57          
Email: compliance@atlashxm.com

UK
‍Atlas Technology Solutions UK Limited
4^th Floor Cordy House, 87-95 Curtain Road, London EC2A 3BS, United Kingdom
Phone: +44 20 3989 6300
Email: compliance@atlashxm.com

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.

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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:

• Directly from the individual
• Advertising networks
• Data analytics providers
• Social networks
• Business partners

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:

• Services and support
• Analytics and improvement
• Customization and personalization
• Marketing and promotions
• Research and surveys
• Planning and managing events
• Security and protection of rights
• Compliance and legal process
• Auditing, reporting and other internal operations
• General business and operational support

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:

• To our affiliates
• To our vendors and service providers who perform services for us
• To third party platforms, providers and networks
• In support of business transfers
• To comply with legal obligations
• To secure and protect rights

California Residents’ Rights.  Under the CCPA, California residents have the following rights (subject to certain limitations):

• To opt out of sales and sharing. The right to opt-out of our sale and sharing of their personal information.
• To limit certain uses and disclosures of sensitive personal information. If applicable, the right to limit our use or disclosure of sensitive personal information to those uses authorized by the CCPA.
• Deletion. The right to the deletion of their personal information that we have collected, subject to certain exceptions.
• To know/access.  The right to know what personal information we have collected about them, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about them.
• Correction. The right to correct inaccurate personal information that we maintain about them.
• Non-discrimination. The right not to be subject to discriminatory treatment for exercising their rights under the CCPA.  

‍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 info@atlashxm.com. 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 info@atlashxm.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:

• Performance of a contract with you, or taking pre-contractual steps at your request: This may include performance of an agreement with you, such as Site Terms of Use, or terms and conditions applicable to the Services you use, or Terms and Conditions of Sale. When we ask you to provide your personal information, we will let you know if it is required to enter into a contract with us, or necessary for us to perform a contract, and your failure to provide that information may mean we cannot enter into the contract.
• To comply with an EEA or UK legal obligation to which we are subject: Personal information may be processed in order to comply with our legal obligations, such as to retain records of transactions. In some cases, we may need your personal information in order to comply with a statutory obligation.
• For our legitimate interests: We may process personal information in furtherance of our legitimate interests, where those interests are not overridden by your rights, freedoms and interests.
• With your consent: We may process personal information about you based on your consent, for example (where required by law) to send you marketing communications, surveys, news, and updates. Where our processing of personal information is based on your consent, you may withdraw consent at any time; please see Your Choices above, or Contact Us below, for information on how to withdraw your consent.

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:

• Services and support. To provide and operate our Services, communicate with you about your use of the Services (including by email, telephone or text/SMS message), provide troubleshooting and technical support, respond to your inquiries, and communicate for similar support purposes. (Legal basis: Performance of our contract with you; if your employer has entered a contract with us or requested that we take steps prior to entering into a contract, the legal basis is our legitimate interest in efficiently managing that contract or request in order to satisfy expectations and expand our business.)
• Analytics and improvement. To better understand how users access and use the Services and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop our Services and its features, and for internal quality control and training purposes. (Legal basis: Our legitimate interests in improving our products and Services in order to expand our business and increase our revenue.)
• Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences. (Legal basis: Our legitimate interests in improving our users’ experience with our products and Services in order to expand our business and increase our revenue.)
• Marketing. For marketing and promotional purposes. For example, to send you information about our Services, such as newsletters and other marketing content, including information about Atlas events, technologies, and new offerings, as well as any other information that you sign up to receive. (Legal basis: Where required by law, your consent. In other cases, we rely on our legitimate interests in promoting our products and Services in order to expand our business and increase our revenue.)
• Advertising. We may use the information that we learn about you to assist us in advertising our Services on third party websites and to assist us in evaluating the success of our advertising campaigns in various platforms. (Legal basis: Our legitimate interests in improving the relevancy of our advertising in order to encourage interactions with us and grow our business.)
• Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes. (Legal basis: Our legitimate business interests in improving the relevancy of our Services, products and advertising in order to improve Services and products and to encourage interactions with us, which allows us to grow our business.)
• Planning and Managing Events. For event planning and management purposes, such as connecting you with other event attendees. (Legal basis: Our legitimate interest in ensuring that events generate interest and participation, and well-managed, in order to satisfy expectations and maintain our reputation.)
• Managing Event Participation. For event planning and management purposes, including registration, attendance, and contacting you about relevant events and Services. (Legal basis: Performance of a contract to manage your registration; if your employer has registered, the legal basis is our legitimate interest in efficiently managing event participation in order to satisfy expectations and expand our business.)
• Security and Protection of Rights. To protect the Services and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Service. (Legal basis: Our legitimate interests in conducting our business in a lawful manner and establishing, exercising and defending our rights and interests as well as those of our stakeholders and as applicable, society at large.)
• Compliance and Legal Process; Litigation. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority. To establish, exercise or defend our interests in the context of disputes or litigation and other legal claims or proceedings in which we are involved. (Legal basis: To comply with an EEA or UK legal obligation; where we are not subject to such an obligation or are subject to anon-EEA or UK legal obligation, in reliance on our legitimate interests in conducting our business in a lawful manner and protecting our rights and interests as well as those of our stakeholders and society at large.)
• Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures. (Legal basis: Our legitimate interests in running our business efficiently in order to improve our performance metrics and maintain profitability.)
• General Business and Operational Support. To assess and implement business transfers, mergers, acquisitions, reorganizations, bankruptcies, financings and other business transactions, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions. (Legal basis: Our legitimate interests in organizing our business efficiently.)

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:

• Access. You have the right to obtain information about our processing of your personal information, and obtain access to and a copy of your personal information.
• ‍Rectification. You have the right to update, complete or correct inaccuracies in your personal information.
• ‍Erasure. You have the right to have your personal information deleted.
• ‍Portability. You have the right to obtain a machine-readable copy of your personal information or to have us transfer it to another controller of your choice.
• ‍Restriction. You have the right to restrict the processing of your personal information, meaning that we will not further process your personal information except to store it.
• ‍Withdrawal of consent. You have the right to withdraw your consent to our processing of your personal information, without affecting the lawfulness of processing up until withdrawal.
• Access. You have the right to obtain information about our processing of your personal information, and obtain access to and a copy of your personal information.
• Rectification. You have the right to update, complete or correct inaccuracies in your personal information.
• Erasure. You have the right to have your personal information deleted.
• Portability. You have the right to obtain a machine-readable copy of your personal information or to have us transfer it to another controller of your choice.
• ‍Restriction. You have the right to restrict the processing of your personal information, meaning that we will not further process your personal information except to store it.
• Withdrawal of consent. You have the right to withdraw your consent to our processing of your personal information, without affecting the lawfulness of processing up until withdrawal.

‍

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:

EEA
Elements Global Services Spain SL      
World Trade Center, Muelle de Barcelona, edif. Sur, 2a planta, 08039 Barcelona, Spain  
Phone: +34 93 545 11 57          
Email: compliance@atlashxm.com

UK
‍Atlas Technology Solutions UK Limited
EC2M 1NH London, Middlesex, England, United Kingdom
Phone: +4420 3989 6300
Email: compliance@atlashxm.com

US
‍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
Email: compliance@atlashxm.com