Privacy Policy

1. Introduction

Atlas & Key ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This privacy policy explains how we collect, use, store, and protect your personal information when you visit our website or use our services. It also tells you about your privacy rights under the General Data Protection Regulation (GDPR) and other applicable data protection laws.

Data Controller: Atlas & Key is the data controller responsible for your personal data. For any questions about this policy or your data, contact us at: [email protected]

2. Data We Collect

We collect and process the following categories of personal data:

Information You Provide Directly

• Identity Data: First name, last name, title, nationality
• Contact Data: Email address, telephone number, mailing address
• Inquiry Data: Information you provide in consultation requests, including your interests, investment capacity, and timeline
• Communication Data: Records of correspondence between you and Atlas & Key

Information Collected Automatically

• Technical Data: IP address, browser type and version, time zone, operating system, device information
• Usage Data: Pages visited, time spent on pages, navigation paths, referral source
• Cookie Data: Information collected through cookies and similar technologies (see Section 7)

3. Legal Basis for Processing

We process your personal data only when we have a lawful basis to do so under GDPR:

• Consent: Where you have given explicit consent for us to process your data for specific purposes (e.g., marketing communications, analytics cookies). You may withdraw consent at any time.
• Contract: Where processing is necessary to perform a contract with you or to take steps at your request before entering into a contract.
• Legitimate Interests: Where processing is necessary for our legitimate business interests, provided these do not override your fundamental rights. Our legitimate interests include improving our services, preventing fraud, and ensuring network security.
• Legal Obligation: Where processing is necessary to comply with legal or regulatory requirements.

4. How We Use Your Data

We use your personal data for the following purposes:

• To respond to your inquiries and provide consultation services
• To send you requested information, including reports and newsletters (with your consent)
• To manage our relationship with you and provide client services
• To improve our website, services, and user experience
• To analyze website usage and optimize our content
• To comply with legal and regulatory obligations
• To protect against fraud and ensure the security of our systems

5. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

• Inquiry Data: Retained for 3 years from last contact, unless you become a client
• Client Data: Retained for 7 years after the end of our business relationship (for legal and regulatory compliance)
• Marketing Data: Retained until you withdraw consent or unsubscribe
• Technical/Usage Data: Retained for 26 months (Google Analytics default)

6. Third-Party Processors

We share your personal data with the following categories of third-party service providers who process data on our behalf:

• Google Analytics (Google LLC): Website analytics and usage tracking. Data may be transferred to the United States. Google Privacy Policy
• Resend: Email delivery service for transactional and marketing emails. Resend Privacy Policy
• Hosting Provider: Cloud infrastructure for website hosting and data storage

All third-party processors are contractually bound to process your data only on our instructions and in compliance with GDPR requirements.

7. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies. We categorize cookies as follows:

Essential Cookies

Required for the website to function. These cannot be disabled.

• Session management cookies
• Cookie consent preference storage

Analytics Cookies (Require Consent)

Help us understand how visitors interact with our website.

• Google Analytics (_ga, _gid): Tracks page views, session duration, and user behavior. Retention: 26 months.

You can manage your cookie preferences at any time by clicking the cookie settings link in our website footer or by adjusting your browser settings. Note that disabling certain cookies may affect website functionality.

8. International Data Transfers

Your personal data may be transferred to, and processed in, countries outside the European Economic Area (EEA), including the United States. When we transfer data outside the EEA, we ensure appropriate safeguards are in place:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by the European Commission
• Binding Corporate Rules where applicable

9. Your Rights Under GDPR

Under GDPR, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure ("Right to be Forgotten"): Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request that we limit how we use your data
• Right to Data Portability: Request your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Right to Lodge a Complaint: File a complaint with a supervisory authority

To exercise any of these rights, contact us at [email protected]. We will respond to your request within 30 days.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (TLS/SSL)
• Secure access controls and authentication
• Regular security assessments
• Staff training on data protection

11. Changes to This Policy

We may update this privacy policy from time to time. Any changes will be posted on this page with an updated "Last Updated" date. For significant changes, we will notify you by email or through a notice on our website.

12. Contact Us

If you have any questions about this privacy policy, wish to exercise your rights, or have concerns about how we handle your data, please contact us:

You also have the right to lodge a complaint with your local data protection supervisory authority if you believe we have not complied with applicable data protection laws.