Privacy policy

PRIVACY NOTICE

Thanks for using ATLAS! Here we describe how we collect, use, and handle your Personal or/and Sensitive Data when you use our website and services.

OVERVIEW

OWNER AND DATA CONTROLLER

ATLAS CAREER GUIDE INC.,

2330 Ponce De Leon Blvd.

Coral Gables, FL 33134

United States

Owner contact email: support@guidu.io

WHAT IS A PERSONAL DATA?

For this Privacy Notice, Personal Data (the “Personal Data”) means any information so captured that directly or indirectly identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to a natural person. Information is reasonably linkable to a natural person if used on its own or in combination with other reasonably available information to identify such natural person. This definition includes, but is not limited to, the following information:

i.First name, middle names, last names, and aliases;
ii.Social media, website-used usernames, login credentials and email addresses;
iii.Financial data, including account, credit card or social security number, details of financial and commercial transactions, and credit scores related to the financial capacity of an individual (natural person)
iv.Internet Protocol address, Browser personal or other electronic network activity information;
v.Inferences to create a profile about an individual reflecting the individual’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes;
vi.Technical identifiers such as a service ID number that can be tied back to an individual;
vii.Information pertaining to individuals’ behavior online, such as a record of the websites they visit or the files they download;
viii.Records of personal property;
ix.Records of products or services purchased;
x.Audio, electronic, visual, thermal, olfactory, or similar information;
xi.Home or postal address information;
xii.Telephone or cellphone numbers;
xiii.Driver’s license number;
xiv.Government-issued ID and vehicle license plate numbers;
xv.Passport number or information;
xvi.Professional or employment-related information, including resume, job history, and other similar records related to an individual;
xvii.Educational information;
xviii.Criminal history information;
xix.Date of birth or age information;
xx.Blood type;
xxi.Gender information;
xxii.Marital status;
xxiii.The views or opinions of an individual about another natural person;
xxiv.Any information concerning an individual which, because of name number, symbol, mark or other identifier can be used to identify that person;
xxv.Any online identifier, any identifying number, symbol, particular or unique identifier, or any similar identifiers assigned to the natural person;

It does not include aggregate or de-identified data or publicly available information.

WHAT IS A SENSITIVE DATA?

For this Privacy Notice, Sensitive Data (The “Sensitive Data”) is a subset of Personal Data that may affect the most intimate sphere of an individual, or that which, if misused, may lead to discrimination or carry a serious risk or damage to the individual. In particular, Sensitive Data are considered those that may reveal the following information:

i.Biometric data (This includes, but is not limited to, fingerprints, voice prints, genetic prints, retina or iris images, or any other biologically unique characteristic that can be used for identity authentication);
ii.Genetic data (This includes, but is not limited to, DNA, RNA, chromosomes, genes, alleles, genomes, alterations or modifications to genetic materials, single nucleotide polymorphisms, uninterrupted data from biological samples, and information extrapolated, derived, or inferred from genetic data);
iii.Citizenship or immigration status;
iv.National origin;
v.Race, ethnicity or colour;
vi.Medical history, mental or physical health past or present condition, or medical past, present or future treatment or diagnosis;
vii.Religious, political, philosophical, moral and emotional beliefs, opinions or characteristics;
viii.Union membership;
ix.Sex life or sexual orientation
x.Status as transgender or nonbinary;
xi.Status as a victim of crime;
xii.Facts or circumstances of one's emotional or family life;
xiii.Personal habits that belong to the most intimate sphere;
xiv.Personal data from a known child under the age of 13;
xv.Precise past or present geolocation data;

We do not generally seek to collect sensitive data as above defined. In the limited cases in which we will seek to collect such data, we will do this in accordance with this Privacy Notice requirements and/or ask for your explicit consent.

PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

If you are a California Resident we kindly ask you to learn more about in the Section 18 (PRIVACY NOTICE FOR CALIFORNIA RESIDENTS).

ADDITIONAL INFORMATION ABOUT US STATES PRIVACY LAWS

United States Federal laws and regulations encompass a wide array of sectors, spanning financial institutions, telecommunications companies, credit reporting agencies, healthcare providers, as well as governing driving records, children’s privacy, telemarketing, email marketing, and communications privacy laws.

There are also a number of state privacy and data security laws that overlap with federal law—some of these state laws are preempted in part by federal laws, but others are not. Beyond CALIFORNIA, several States in the US have passed local specific privacy and data security laws and regulations that apply across sectors and go beyond the Federal Law. These are the cases of COLORADO, CONNECTICUT, DELAWARE, FLORIDA, IOWA, MARYLAND, MINNESOTA, MONTANA, NEBRASKA, NEW HAMPSHIRE, NEW JERSEY, OREGON, TENNESSEE, TEXAS UTAH and VIRGINIA. Other States such as INDIANA, KENTUCKY MASSACHUSETTS, NEW YORK and, RHODE ISLAND are still in the process of building such specific legislation (Privacy Laws) which will be released soon in the beginning of 2026.

Generally, each state’s laws apply to personal information about residents of that state or activities that occur within that state. Thus, many businesses operating in the United States must comply not only with applicable federal law, but also with numerous state privacy and security laws and regulations.

This Privacy Notice has been carefully crafted to adhere to all aforementioned privacy and data security laws and regulations, with a particular focus on ensuring that local residents' rights are respected and their personal or sensitive information is treated correctly, respectfully, and appropriately.

EEA, SWITZERLAND AND UK RULES

If you are in the EEA, Switzerland, or the UK and where the processing of your Personal Information is subject to EU data protection laws, you have some special and additional rights, which you may find in the Section 17 (EEA, UK AND SWITZERLAND DATA PROTECTION SPECIFIC INFORMATION).

CANADA PRIVACY LAWS AND REGULATIONS

In Canada, there exist 28 privacy statutes at the federal, provincial, and territorial levels, regulating the safeguarding of personal information across private, public, and health sectors. While these statutes differ in their extent, specific requirements, available remedies, and enforcement mechanisms, they collectively establish a thorough framework governing the acquisition, utilization, and sharing of personal data.

The main regulations and statutes governing the Private Sector of CANADA are the following:

I.Personal Information Protection and Electronic Documents Act ('PIPEDA')
II.Personal Information Protection Act (Alberta) ('PIPA Alberta')
III.Personal Information Protection Act (British Columbia) ('PIPA BC')
IV.Act Respecting the Protection of Personal Information in the Private Sector ('Quebec Private Sector Act'), (collectively, 'Canadian Privacy Statutes')

This Privacy Notice has been carefully crafted to adhere to all aforementioned Private Sector’s privacy and data security regulations and statutes, with a particular focus on ensuring that Canadians rights are respected and their personal or sensitive information is treated correctly, respectfully, and appropriately.

MEXICO PRIVACY LAWS

The Federal Law on the Protection of Personal Data held by Private Parties ("Ley Federal de Protección de Datos Personales en Posesión de los Particulares"), commonly referred to as "the Law," serves as the primary legislation/act overseeing the management of personal data belonging to Mexican citizens. It came into effect on July 6, 2010.

Subsequently, the Executive Branch has also issued the following (collectively, with the Law, referred to herein as "Mexican Privacy Laws"):

A.The Regulations to the Federal Law on the Protection of Personal Data held by Private Parties (Reglamento de la Ley Federal de Protección de Datos Personales en Posesión de los Particulares) (the Regulations), which entered into force on December 22, 2011
B.The Privacy Notice Guidelines (the Guidelines), which entered into force on April 18, 2013
C.The Recommendations on Personal Data Security, on November 30, 2013
D.The Parameters for Self-Regulation regarding personal data, which entered into force on May 30, 2014
E.The General Law for the Protection of Personal Data in Possession of Obligated Subjects (Ley General de Protección de Datos Personales en Posesión de Sujetos Obligados), which entered into force on January 27, 2017

On June 12, 2018, a decree was published in the Official Gazette of the Federation approving two important documents:

1.Convention for the Protection of Individuals with regard to Automatic Processing of Personal Data dated January 28, 1981, and its
2.Additional Protocol regarding supervisory authorities and trans-border data flows dated November 8, 2001.

Mexican Privacy Laws apply to all personal data processing under any of the following circumstances:

i.Processing carried out by a data controller established in Mexican territory;
ii.Processing carried out by a data processor, regardless of its location, if the processing is performed on behalf of a data controller established in Mexico;
iii.Processing by or on behalf of a data controller not located in Mexico, where Mexican legislation is applicable pursuant to the execution of an agreement or Mexico’s adherence to an international convention; or
iv.Processing carried out within Mexican territory, on behalf of a data controller not established in Mexican territory, unless such processing is only for transit purposes.

This Privacy Notice has been carefully crafted to adhere to all aforementioned privacy laws and regulations, with a particular focus on ensuring that local residents' rights are respected and their personal or sensitive information is treated correctly, respectfully, and appropriately.

BRAZIL PRIVACY LAW

The Brazilian General Data Protection Law (“LGPD - Lei Geral de Proteção de Dados”), Federal Law nº 13.709/2018, became effective on September 18, 2020. Serving as Brazil’s inaugural comprehensive data protection legislation, the LGPD broadly aligns with the EU General Data Protection Act (GDPR).

Prior to the LGPD's implementation, data privacy regulations in Brazil were fragmented across different pieces of legislation. For instance, Federal Law no. 12.965/2014, along with its implementing Decree no. 8.771/16 (collectively known as the Brazilian Internet Act), imposed security requirements and outlined obligations for service providers, network operators, and application providers, while also granting rights to Internet users regarding the processing of personal data.

The following laws also contain general provisions and principles applicable to data protection:

I.The Federal Constitution
II.The Brazilian Civil Code, and
III.Laws and regulations that address
i.Certain types of relationships (Consumer Protection Code

and employment laws);

ii.Regulated sectors (financial institutions, health industry, or

telecommunications); and

iii.Particular professional activities (medicine and law).

The LGPD applies to any processing operation carried out by a natural person or a legal entity (of public or private law), irrespective of (1) the means used for the processing, (2) the country in which its headquarter is located, or (3) the country where the data are located, provided that:

1)The processing operation is carried out in Brazil;
2)The purpose of the processing activity is to offer or provide goods or services, or the processing of data of individuals located in Brazil; or
3)The personal data was collected in Brazil.

On the other hand, the law does not apply to the processing of personal data that is:

1)Carried out by a natural person exclusively for private and non-economic purposes;
2)Performed for journalistic, artistic, or academic purposes;
3)Carried out for purposes of public safety, national security, and defense or activities of investigation and prosecution of criminal offenses (which will be the subject of a specific law);
4)Originated outside the Brazilian territory and are not the object of communication; or
5)Shared data use with Brazilian processing agents or the object of international transfer of data with another country that is not the country of origin, provided that the country of origin offers a level of personal data protection adequate to that established in the Brazilian law.

Furthermore, on October 20, 2021, the Brazilian Senate unanimously endorsed Proposed Amendment to the Constitution (PEC) no. 17/2019, incorporating into the Federal Constitution the safeguarding of personal data, including in digital formats, as an intrinsic fundamental right. This amendment also delegates to the Union (federal government) the exclusive authority to legislate on this matter. As of February 10, 2022, data protection is enshrined in the Federal Constitution as a fundamental right.

This Privacy Notice has been carefully crafted to adhere to all aforementioned privacy and data security laws and regulations, with a particular focus on ensuring that Brazilian’s rights are respected and their personal or sensitive information is treated correctly, respectfully, and appropriately.

PERU PRIVACY LAW

In Peru, the Personal Data Protection Law Nº 29733 (“PDPL”) has been the foundation of the country's data protection legal framework since its implementation in June 2011. It was supplemented in March 2013 by Supreme Decree No. 003-2013-JUS, which implemented, clarified, and expanded on the PDPL's requirements through specific rules, terms, and provisions.

A significant legislative development occurred with the enactment of Supreme Decree Nº. 016-2024-JUS (the "New Regulation") on November 30th, 2024. This New Regulation, which took effect on March 30th, 2025, introduced enhancements to the PDPL to strengthen personal data rights in the context of rapidly evolving digital landscapes, including e-commerce and artificial intelligence.

This Privacy Notice has been carefully crafted to adhere to all aforementioned privacy and data security laws and regulations, with a particular focus on ensuring that Peruvian’s rights are respected and their personal or sensitive information is treated correctly, respectfully, and appropriately.

If you are a Peruvian citizen or resident and want to learn more about your rights and how we handle your personal data, we kindly ask you to visit our Section 19.

1. INTRODUCTION

Atlas Career Guide, INC (“Atlas”, “The Company” or “We”) believes TRUST is a strong and inviolable value. The privacy of users who visit our website, located at https://guidu.io/ or who download and use our mobile application (the “App”), available at “Google Play Store” and at “App Store”. is very important to us, and so is our concern in being transparent about how we access and handle their Personal Data or/and Sensitive Data. Our website is a homepage that provides general information about Atlas and its products; it is not itself an online platform through which our services are provided. Access to and use of our services takes place through the App, once you have downloaded and installed it on your device.

This Privacy Notice explains our privacy practices for the activities described herein. Please read this Privacy Notice carefully to learn how we collect, store, use, share, transfer protect, disclosure, and otherwise process information relating to individuals (“Personal Data” and “Sensitive Data”). Here you can also learn about your rights and choices regarding your Personal Data or/and Sensitive Data. We NEVER SELL Personal or/and Sensitive Data, and we carry out all processing operations in strict compliance with this Privacy Notice.

If you disagree with our policies and practices, your choice is not to visit our website or to download and use our App. This Privacy Notice describes our data practices; it is not, by itself, a request for your consent. Where consent is the legal basis for a specific processing activity, we will request it separately, for that purpose. This notice may change from time to time, and where we make a material change, we will notify you as described in Section 14 below.

2. PROCESSING ACTIVITIES COVERED

This Privacy Notice applies to the processing of personal data and information Atlas collects:

i.When you visit Atlas’ Website that displays or links to this notice.
ii.When you use Atlas’ App that displays or links to this notice.
iii.In communications received by you from us or otherwise communication sent by you to us, including but not limited to emails, phone calls, and other electronic messages.
iv.Through the App itself, once downloaded, which provides dedicated interaction between you and Atlas outside the browser.
v.Through your participation in surveys, research or other similar data collection facilitated by us.
vi.When you interact with our advertising and applications on third-party websites and services, those applications or advertising include links to this notice.

It does not apply to the processing of personal data and information collected by:

i.us offline or through any other means, including on any other website operated by The Company or any third party; or
ii.any third party; including through any application or content (including advertising) that may link to or be accessible from or on the Website.

As above stated, our website and App may contain links to other websites, applications, platforms, and services maintained by third parties. The information practices of these third parties are governed by their privacy statements/policy, which you should review to better understand their privacy practices. Please note Processing of Personal Data is required for receiving certain products or services.

3. RESPONSIBILITY FOR PROCESSING PERSONAL DATA

Automated systems of Atlas Career Guide, INC bears responsibility for lawfully processing your data as carried out on our website and App.

4. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

You may visit our site anonymously. However, in the course of Atlas’ services, you may provide us with personally identifiable information. This refers to information about you that can be used to contact or identify you, and information about your use of the services that may be connected with you (“Personal Information” or “Personal Data”).

Usually, the information collected by us or provided by you refers to:

1.Profile and Registration Information: Information associated with the Atlas profile of a user who uses the App which may include, email address, password, complete name (first name, middle names and surname), birth date information, location, career or employment stage and educational information, or other information provided by the user.
2.Account Information: Information associated with an account that licenses Atlas services, which may include administrator name, contact information, account ID, billing or financial information (such as but not limited to full bank account numbers or credit card numbers, etc.), and subscription/account plan information. This does not apply to GUIDU accounts: the App does not collect or store full bank account or credit card numbers, since all purchases made through the App are processed entirely by the Apple App Store or Google Play.
3.Navigation Log information: Information that your browser sends whenever you visit our App. This log file information may include information such as your computer’s Internet Protocol address, browser type, browser version, the pages of our App that you visit, the time and date of your visit, the time spent on those pages, and other statistics.
4.App Transaction Log information: Information that your use and operations you make on the application generate and are directly associated to your user on the App.
5.Settings, opt-ins, and opt-outs: Information associated with the preferences and settings on an Atlas account or user profile, which may include audio and video settings, opt-in or opt-out for the application functionalities, including sending of notifications, email messages, newsletter, etc., and other settings and configuration information.
6.Device Information: Information about the computers, phones, and other devices people use when interacting with Atlas services, which may include information about the speakers, microphone, camera, OS version, MAC address, IP address (which may be used to infer general location at a city or country level), device attributes (like operating system version), internet connection information.
7.Communications with Atlas: Information about your communications with Atlas, including information relating to support questions, your account, and other inquiries.
8.Information from Partners: Atlas obtains information about account owners and their users from third-party companies, such as credit bureaus, identity verification services, and market data enrichment services, including but not limited to information about an account owner’s company size or industry, contact information, or activity of certain enterprise domains.
9.Anonymized data: Information that is about you but individually does not identify you.
10.Analytics services (non-personally identifiable information only): Atlas uses third-party analytics tools to help us measure traffic and usage trends for the App. These tools collect information sent by your device or our App, including the web pages you visit, add-ons, and other information that assists us in improving the App. The tools use ‘cookies’, which are text files placed on your device, to collect your log information and behavior information in an anonymous form.

We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User. We collect this information:

I.Directly from you when you provide it to us:
a.If you express an interest in obtaining additional information about our services; request customer support; use our “Contact Us” or similar features; register to use our website or App; participate in a program or survey; or act as an authorized user for our services; or download certain content, we may require that you provide “Personal Information” or “Personal Data.
b.If you voluntarily submit certain information to us, such as filling out a survey, responding to a questionnaire, or participating in other forms of research, we may collect the information you have provided as part of that request, which may include special categories of Personal Data, to the extent you voluntarily choose to provide it.
II.Automatically as you navigate through the site. Information gathered automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

If you provide us, our service providers or our affiliates with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Notice. If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us using the contact details specified in the Section 21 below.

4.1. INFORMATION YOU VOLUNTARILY PROVIDE TO US

In the course of using our website and/or our App, you may choose to provide us with information to help us serve your needs. The information we collect may include:

i.Information that you provide by filling in forms on our website or our App. It includes information provided at the time of registering to use our website or App, subscribing to our services or the services provided by other providers on the website, posting material, or requesting further services. We may also ask you for information when you report a problem with our website.
ii.Records and copies of your correspondence (including email addresses) if you contact us.
iii.Your responses to surveys that we might ask you to complete for research purposes.
iv.Details of transactions you carry out through our website or App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our website or App. This does not apply to purchases made through the App: transactions there are processed entirely by the Apple App Store or Google Play, and Atlas does not receive or store your full card or bank account number.
v.Your search queries on the Website.

You may choose to provide us with access to specific personal data stored by third parties such as social media sites (e.g., Facebook, Instagram, Twitter, etc.). The information we may receive varies by location and is controlled by that site. By associating an account managed by a third party with your account and authorizing Atlas Career Guide, INC to access this information, you agree that we may collect, store and use this information following this Privacy Notice. You also may provide information to be published or displayed (from now on, “posted”) on public areas of the website, or transmitted to other users of the website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to individual pages, please know that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

4.2. INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our website and/or our App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

i.Details of your visits to our website, including traffic data, location data, logs, and other communication data, and the resources you access and use on the Website.
ii.Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Go to https://guidu.io/privacy for details on how you can opt-out of behavioral tracking on this Website and how we respond to web browser signals and other mechanisms that enable users to exercise choice about behavioral tracking.

The information we collect automatically may include personal information or maintain it or associate it with personal information we collect in other ways or receive from third parties. We process this usage data to facilitate your access to our services (e.g., to adjust our services to the device you are using), and to recognize and stop any misuse. It helps us to deliver better and more personalized service, including by enabling us to:

i.Estimate our audience size and usage patterns.
ii.Store information about your preferences, allowing us to customize our Website according to your interests.
iii.Speed up your searches. Recognize you when you return to our Website.

We also process usage data in an anonymized form for statistical purposes and to improve our website. We collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

The legal basis for this processing is your consent and our legitimate interests, as monitoring and improving our website and services. The technologies we use for this automatic data collection may include:

i.Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser Cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our website. Unless you have adjusted your browser setting to refuse cookies, our system will issue cookies when you direct your browser to our website.
ii.Flash Cookies. Certain features of our website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
iii.Web Beacons. Pages of our website and our email may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We use cookies and other tracking technologies to process information, operate and administer the website. This is done to provide you with a better experience, ensuring the security of our website and services, marketing purposes and to facilitate the use of certain functions. To realize our legal interest to control the load on-site, ensure site quality and speed, we may collect anonymized statistical information collected by Universal Analytics cookies. We do not automatically collect personal information, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

4.3. THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications, including advertisements, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information. They may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should directly contact the provider responsible.

4.4. AUTHENTICATION AND FRAUD DETECTION

To help protect you from fraud and misuse of your personal information, we may collect information about you and your interactions with our services and with our third-party service providers. We may also evaluate your computer, mobile phone, or another access device to identify any malicious software or activity.

4.5. SOCIAL MEDIA FEATURES

Our website may use social media features, such as the “Instagram” and the ”Facebook” button and other sharing widgets (“Social Media Features”). Social Media Features may allow you to post information about your activities on our website to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our website. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our website, the platform may receive information showing that you have visited our website. Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.

5. PURPOSES FOR WHICH WE PROCESS PERSONAL DATA AND THE LEGAL BASES ON WHICH WE RELY

We only collect, use, and process your Personal Data (including, where legally permissible, special categories of Personal Data) in a lawful, transparent, and fair manner. Where required by law, we obtain your consent to use and process your Personal Data for the below purposes. Depending on the specific personal data concerned and the factual context, when ATLAS processes personal data as a controller for individuals in regions such as the EEA, Switzerland, and the UK, we rely on the following legal bases as applicable in your jurisdiction. Otherwise, we rely on another authorized legal basis (including but not limited to the (i) performance of a contract or (ii) legitimate interest) to collect and process your Personal Data, as further detailed below.

a.Consistent with specific revocable consents: we rely on your prior consent in order to process your personal data for certain activities (such as utilizing cookies to engage advertising and analytics partners to deliver tailored advertising and analysis of our website usage). You are free and have the right to withdraw your consent at any time by contacting us using the contact details specified in the Section 21 below. If you withdraw your consent, it will not affect the lawfulness of any processing based on your consent before you withdrew it. Where applicable, we may ask for your consent to the processing at the point where you provide your personal data/information.
b.Providing and promoting our website and services (including necessary functionality): we process your Personal Data to perform our contract with you for the use of our website and services and to fulfill our obligations under the applicable terms of use and service; if we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our website and services and to provide you with content you access and request (e.g., to download content from our website);
c.Promoting the security of our website and services: we process your Personal Data by tracking use of our website and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for our legitimate interest in promoting the safety and security of the services, website, systems and applications and the security of ATLAS generally, and in protecting our rights and the rights of others;
d.Managing user registrations: if you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
e.Handling contact and user support requests: if you fill out a “Contact Me” web form or request user support, or if you contact us by other means including but not limited to via email, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
f.Managing event registrations and attendance: we process your Personal Data to plan and host events or webinars for which you have registered or that you attend, including sending related communications to you or to perform our contract with you or where we receive your consent;
g.Managing, and participating in, contests, programs or promotions: if you register for a contest, promotion, or a program, we process your Personal Data to perform our contract with you or where we seek your consent. Some contests, programs and promotions have additional rules containing information about how we will process your Personal Data;
h.Managing payments: if you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you (this basis does not apply to purchases made through the App, which are processed entirely by the applicable app store);
i.Contract fulfillment (as necessary for our contract): when we enter into a contract directly with you, we process your personal data on the basis of our contract in order to prepare and enter into the contract, as well as to perform and manage our contract (i.e., providing Atlas Products, features and services to account owners, their users, and those they invite to join meetings and webinars hosted on their accounts, and manage our relationship and contract, including billing, compliance with contractual obligations, and related administration). If we do not process your personal data for these purposes, we may not be able to provide you with all Products, features, and services;
j.Developing and improving our websites and services: we process your Personal Data to analyze trends and to track your usage of and interactions with our website and services to the extent it is necessary for our legitimate interest in developing and improving our website and services and providing our users with more relevant content and service offerings, or where we seek your consent;
k.Assessing and improving user experience: we process device and usage data as described in Section 4.2 above, which in some cases may be associated with your Personal Data, to analyze trends and assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the service offering or website, or where we seek your consent;
l.Reviewing compliance with applicable usage terms: we process your Personal Data to validate that you are a licensed user and to review compliance with the applicable usage terms in our customer’s or user’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
m.Assessing capacity requirements: we process your Personal Data to assess the capacity requirements of our services to the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements of our service offering;
n.Identifying customer opportunities: we process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we meet the demands of our customers and their users’ experiences;
o.Displaying personalized advertisements and content: We process your Personal Data to conduct market research, advertise to you, provide personalized information about us on and off our website and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our website or, where necessary, to the extent you have provided your prior consent (please see Sections 10 and 15 below, to learn how you can control the processing of your Personal Data by ATLAS);
p.Administering surveys and conducting research: we process your Personal Data (including special categories of Personal Data) in order to meet the goals, set out in surveys or research as well as to analyze our compliance with internal policies. If required under applicable law, we will obtain your consent to process your responses;
q.Sending communications: We will process your Personal Data or device and usage data, which in some cases may be associated with your Personal Data, to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions, news or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent (please see Sections 10 and 15 below, to learn how you can control the processing of your Personal Data by ATLAS);
r.Collection of diversity information: We may process your Personal Data (including special categories of Personal Data) to the extent you voluntarily consent to provide it to meet our broader community-minded goals related to diversity and equality of opportunity. If required under applicable law, we will obtain your consent or explicit consent;
s.Protect your vital interests or those of others: we process certain personal data in order to protect vital interests for the purpose of detecting and preventing illicit activities that impact vital interests and public safety, including child sexual abuse material; and
t.Compliance with legal obligations: we process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our website or services, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes. We also process your personal data to comply with the legal obligations to which we are subject for the purposes of compliance with EEA laws, regulations, codes of practice, guidelines, or rules applicable to us, and for responses to requests from, and other communications with, competent EEA public, governmental, judicial, or other regulatory authorities. This includes detecting, investigating, preventing, and stopping fraudulent, harmful, unauthorized, or illegal activity (“fraud and abuse detection”) and compliance with privacy laws;

If we need to collect and process Personal Data by law, or under a contract we have entered into with you, and you fail to provide the required Personal Data when requested, we may not be able to perform our contract with you.

6. CHILDREN UNDER THE AGE OF 13 AND ADOLESCENTS

Our website is not intended for children under 13 years of age. No one under the age of 13 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verifying parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using the contact details specified in the Section 21 below.

Certain Atlas products, including GUIDU, are specifically designed for use by adolescents under the supervision of a Legal Guardian. Where this is the case, a dedicated product- and jurisdiction-specific privacy supplement applies and takes precedence over this Section 6 for that product. Please refer to the applicable supplement for details on the age range covered, the safeguards that apply, and how to exercise rights.( https://guidu.io/supplementary )

7. HOW WE USE YOUR INFORMATION

As above stated, our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information to:

i.To present our website and its contents to you.
ii.To provide our services and customer support.
iii.To provide you with our or our third-party providers’ information, products, or services.
iv.To process transactions and send notices about your transactions.
v.To verify your identity, including during account creation and password reset processes.
vi.To resolve disputes, collect fees, and troubleshoot problems.
vii.To manage risk or detect, prevent, or remediate fraud or other potentially prohibited or illegal activities.
viii.To detect, prevent or remediate violations of policies or applicable user agreements.
ix.To fulfill any other purpose for which you provide it.
x.To provide you with notices about your account, including expiration and renewal notices.
xi.To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including billing and collection.
xii.To notify you about changes to our website or any products or services we offer or provide through it.
xiii.To allow you to participate in interactive features on our website.
xiv.For any other purpose with your consent.

In any other way, we may describe when you provide the information. We may also use your information to contact you about our own and third parties’ services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.

We may use the information we have collected from you to display advertisements to our advertisers’ target audiences. Even though we do not disclose your data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may contact you via electronic means or postal mail to notify you regarding your account, troubleshoot problems with your account, resolve a dispute, collect fees or monies owed, and poll your opinions through surveys or questionnaires or as otherwise necessary to service your account. Additionally, we may contact you to offer coupons, discounts, and promotions.

Finally, we may contact you as necessary to enforce our policies, applicable law, or any agreement we may have with you. When contacting you via phone, we may use and consent to receive auto-dialed or prerecorded calls and text messages to reach you as efficiently as possible. Where applicable and permitted by law, you may decline to receive certain communications.

8. DISCLOSURE OF YOUR PERSONAL AND SENSITIVE INFORMATION

We do not sell your Personal and Sensitive information to any third parties or disclose it in exchange for money or other valuable consideration. We do not disclose, share, or otherwise use your personal and sensitive information without your consent, except to the extent required by law, in accordance with your instructions, or as indicated within this Privacy Notice, or when we inform you and give you an opportunity to opt-out of having your Personal and Sensitive Data shared.

We undertake that your personal and sensitive data will not be used for any direct marketing communications (e.g., email, SMS, physical mail) without your prior, explicit, and informed consent. Any such marketing for our own or a third party's products and services is conditional upon you granting this separate consent, which you may withdraw at any time.

We may disclose aggregated information about you and information that does not identify you without restriction. We may disclose personal information that we collect about you, or you provide in the following ways:

1.With third-party Service Providers, agents, contractors, or government entities: We use other companies, agents, or contractors (“Service Providers”) to perform services on our behalf or to assist us with providing services to you. We may engage service providers to process credit card transactions or other payment methods. We may also engage service providers to provide services such as monitoring and developing ATLAS services; aiding in communications, infrastructure, and IT services; customer service; debt collection; analyzing and enhancing data. These service providers may have access to your personal or other information in order to provide these functions. In addition, some of the above-listed types of information that we request may be collected by third-party service providers on our behalf. We may share information with service providers and government entities for legal, security, and safety purposes. This includes sharing information in order to enforce policies or contracts, address security breaches, and assist in the investigation of fraud, security issues, or other concerns. We require service providers to agree to take reasonable steps to keep the Personal Data that we provide to them confidential and secure. We do not authorize them to use or disclose your Personal Data except in connection with providing their services and for the purposes and pursuant to the legal bases described above in Section 5.
2.Subsidiaries and Affiliates: We may disclose information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Notice. If you use our website to register for an event or webinar organized by one of our affiliates or subsidiaries, we may share your Personal Data with the affiliate or subsidiary to the extent this is required on the basis of the affiliate’s or subsidiary’s contract with you to process your registration and ensure your participation in the event; in such instances, our affiliate or our subsidiary will process the relevant Personal Data as a separate controller and will provide you with further information on the processing of your Personal Data, where required.
3.Third parties involved in a corporate transaction: We may disclose information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Atlas Career Guide, INC‘s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Atlas Career Guide, INC about our website users is among the assets transferred. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party;
4.Marketing, Advertising, and Analytics Partners: ATLAS collaborates with third-party marketing, advertising, and analytics providers like Google, Facebook, LinkedIn, YouTube, among others. We may process, share, or disclose your personal information to provide comprehensive statistics and analysis of your usage patterns across Atlas services and our website. Additionally, we utilize this data to deliver tailored advertising and marketing for Atlas services, including targeted and personalized content based on your preferences, likely interests, or website interactions. This assists us in updating, expanding, and analyzing our records, identifying new customers, and creating more tailored advertising to offer services that align with your interests. These third-party partners may receive insights into your activities on Atlas’ website through third-party cookies placed there. To opt out of our use of third-party cookies sharing data with these partners, please visit our cookie management tool. Atlas is committed to obtaining your consent, where required by law, before engaging in such disclosures or marketing activities. Furthermore, Atlas contractually obligates these third parties to maintain the confidentiality of personal information and utilize it solely for the purposes and legal bases outlined in Section 5 above.

For accounts identified as belonging to adolescents in Brazil, this item 4 does not apply: we do not use vocational profile data, assessment responses, progress data, interactions with an in-app guide, or inferences derived from such products to direct advertising, build advertising audiences, or personalize third-party commercial offers. This restriction is not an opt-out — it applies by default. See the applicable product-specific privacy supplement for details. .( https://guidu.io/supplementary )

5.Professional advisers: In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data;
6.Legal Matters: ATLAS may preserve, and has the right to disclose any information about you or your use of this website without your prior permission if the Company has a good faith belief that such action is necessary to: (1) comply with applicable law or respond to a subpoena, court order, warrant, etc., investigate, or participate in valid legal process and proceedings, including from law enforcement or government agencies; (2) enforce or investigate potential violations of its Terms of Service (Terms and Conditions) or policies; (3) detect, prevent, or investigate potential fraud, abuse, or safety and security concerns, including threats to the public; (4) meet our corporate and social responsibility commitments; (5) protect our and our customers’ rights, safety and property; and (6) resolve disputes and enforce agreements.

We may also disclose information about you:

i.To fulfill the purpose for which you provide it.
ii.For any other purpose disclosed by us when you provide the information.
iii.With your consent.
iv.To enforce or apply our terms of use https://guidu.io/terms and other agreements, including billing and collection purposes.

8.1. HOW WE SHARE PERSONAL INFORMATION WITH OTHER USERS AND THIRD-PARTY SERVICE PROVIDERS

When transacting with others, we may provide those parties with information about you, which are necessary to complete the transaction, such as your name, account ID, contact details, or other information needed to promote the transaction’s reliability and security. If a transaction is held, fails, or is later invalidated, we may also provide details of the unsuccessful transaction. The receiving party cannot use this information for unrelated purposes, such as to directly market to you, unless you have agreed to it.

Nevertheless, we will not disclose your credit card number or bank account number to anyone, except with your express permission or if we are required to do so to comply with credit card rules, a subpoena, or another legal process.

Contacting users with unwanted or threatening messages is against our policies and constitutes a violation of our Terms of Use.

9. LINKS TO OTHER WEBSITES, SOCIAL MEDIA PLATFORMS, AND INTERNATIONAL DATA TRANSFERS

We may provide hyperlinks (links) to other websites, including other ATLAS CAREER GUIDE INC., websites, third-party websites, and our official pages on social media platforms such as Facebook, Instagram and LinkedIn.

ATLAS is not responsible for the privacy policies, cookie policies, or terms and conditions of:

i.websites owned or managed by third parties; and
ii.social media platforms.

When you click on these links, you acknowledge that you may be redirected to environments outside of our control, where these independent entities may collect personal information such as IP addresses, device details, location, browsing behavior, and preferences. We recommend you review the privacy policies and terms of these entities before proceeding with browsing or interaction.

Furthermore, our website may feature Social Media Features (like the "Instagram" or "Facebook" buttons) that allow you to post or highlight activities, and your interactions with these are subject to the respective platform's privacy policy. When transacting with other users, we may share personal information necessary to complete the transaction (such as your name and contact details) for reliability and security, but we will never disclose your credit card or bank account number without your express permission or legal requirement.

Regarding International Data Transfers, we collect information globally and may transfer, process, and store your data outside your country of residence, including to the United States, to provide our services. Your Personal Data may be stored in places not subject to adequacy decision by the European Commission or your local regulator, which may not provide the same level of data protection.

To ensure an adequate level of protection for these international transfers, we implement appropriate legal mechanisms, such as standard contractual clauses approved by the European Commission and other relevant authorities, and, where required by applicable law (including the GDPR, UK Data Protection Act, CCPA and other Data Privacy Acts, Peru's PDPL, and Brazil's LGPD), we will obtain your consent prior to such processing.

For instance, data collected by Meta through your interaction with our official Facebook and Instagram pages may be transfered to servers located outside the European Economic Area (EEA), including to the United States. To ensure the legality of such transfers, Meta adopts appropriate safeguards such as:

i.adherence to the EU-U.S. Data Privacy Framework, and/or
ii.use of Standard Contractual Clauses (SCCs) approved by the European Commission.

By interacting with these pages, you acknowledge that your personal data may also be processed by Meta as a joint controller, in accordance with Article 26 of the General Data Protection Regulation (GDPR). For more information on how Meta processes data, we recommend reviewing the Privacy Policies of Facebook and Instagram.

If you would like more details about the international transfer of personal data or wish to exercise your data subject rights in relation to our processing, please contact us using the channels indicated in this Privacy Notice. For matters related to data processing by Facebook and Instagram, you should refer to the respective platforms' privacy policies/notices.

10. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

1.Tracking Technologies and Advertising: You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. Please note that some parts of this site may then be inaccessible or not function properly if you disable or refuse cookies.
2.Disclosure of Your Information for Third-Party Advertising: Suppose you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes. In that case, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form). You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or sending us a message stating your request at the contact details specified in the Section 21 below.
3.Promotional Offers from the Company: Suppose you do not wish to have your Company’s contact information to promote our own or third parties’ products or services. In that case, you can opt-out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us a message stating your request at at the contact details specified in the Section 21 below.. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided for the Company as a result of a service purchase, warranty registration, product service experience, or other transactions.
4.Targeted Advertising: Suppose you do not want us to use information that we collect or provide to us to deliver advertisements according to our advertisers’ target-audience preferences. In that case, you can opt-out by checking the relevant box located on the form on which we collect your data (the order form). You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or sending us a message stating your request at the contact details specified in the Section 21 below. For this opt-out to function, you must have your browser set to accept browser cookies.

The choices described in this Section 10 do not apply, as an opt-out, to accounts identified as belonging to adolescents in Brazil with respect to advertising based on vocational, behavioral, or profile data: for that population, such use is not offered as a choice — it is not used at all, by default. See the applicable product-specific privacy supplement for details ( https://guidu.io/supplementary ).

We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s Website.

11. ACCESSING AND CORRECTING YOUR INFORMATION

You can review and change your personal information by logging into the Website and visiting your account profile page. You may also send us a request at the contact details specified in the Section 21 below in order to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Suppose you delete your User Account from the website. In that case, your Anonymized User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other website users. Proper access and use of information provided on the website, including User Contributions, is governed by our terms of use https://guidu.io/terms. If you close your account, we will mark your account in our database as “Closed.” Still, we may retain personal information from your account for a certain period to collect any fees owed, resolve disputes, troubleshooting problems, assist with any investigations, prevent fraud, enforce our Terms of Use, or take other actions as required or permitted by law. If you would like to limit your personal data processing, please feel free to contact us at the contact details provided below in Section 21. However, please note that all information requested from you is obligatory to be provided by you unless stated otherwise. Should you fail to provide us with your data, we may not process your request for our services.

12. RETENTION OF YOUR PERSONAL DATA

We will retain your Personal Data for as long as it is necessary for the purposes set out in this Privacy Notice (see Section 5 above), for as long as your account is active, or as needed to provide you the Service or for the duration required by law, whichever is the longer. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, and whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).

If you wish to delete your account or request that we no longer use your information to provide you with the Service, you may ask that we delete your account by contacting us at the contact details specified in the Section 21 below. We may retain, use, or disclose your information (including Personal Data) as necessary to comply with our legal obligations, to resolve disputes or enforce our agreements, and carry out our legitimate business interests such as for analytics purposes, safety, and security (see Section 11 above). Consistent with and subject to these requirements, we will try to delete your information quickly upon request. In addition, we do not delete from our servers Content that you have in common with other Users. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data. For more information on data retention periods, please contact us by using the information in Section 21 below.

13. DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in the website’s public areas, like message boards. Any user of the website may view the information you share in public places. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your data, we cannot guarantee your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

14. CHANGES TO OUR PRIVACY NOTICE

We may update this Privacy Notice from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, the date the privacy notice was last revised is identified at the top of the page. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a notice on our website or by contacting you directly, or where required under applicable law and feasible, seeking your consent to these changes. You are responsible for ensuring we have an up-to-date active and deliverable email address for you. We encourage you to periodically visit our website and this Privacy Notice to check for any changes and stay informed about our collection, processing and sharing of your Personal Data. Material changes affecting adolescent users are communicated in a clear, prominent, and age-appropriate manner, in addition to being posted here. Continued use of our Services does not, by itself, constitute acceptance of a material change where consent is the applicable legal basis for that change — in that case, we will request your consent separately. All changes take effect on the sooner of the day you use the site and/or services, or 30 calendar days after they are initially posted, except where a longer period or separate consent is required by applicable law.

15. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA

You may have certain rights relating to your Personal Data, subject to local data protection laws. If you are in the European Economic Area (EEA), Switzerland, or the UK, or a resident of California, please refer to the respective dedicated sections below. Otherwise, depending on the applicable laws, these rights may include:

1.Right to know or confirm and access: If you ask us, we will confirm whether we are collecting, processing, sharing or selling your Personal or/and Sensitive Data, including details on the purposes, methods, categories of data involved, recipients or categories of recipients to whom your Personal or/and Sensitive Data have been or will be disclosed, and the anticipated duration of data retention. If feasible, we'll specify the duration or criteria used for retention. Additionally, we'll disclose the presence of automated decision-making, including profiling, along with insights into the logic, significance, and potential consequences of such processing of your Personal and/or Sensitive Data. Upon your request, we may provide you with a copy of that Personal or/and Sensitive Data along with certain other details of the processing procedure.
2.Right to rectification or correction: If your Personal or/and Sensitive Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we’d shared your Personal or/and Sensitive Data with others, we would tell them about the correction. If you ask us, and where it is possible and lawful to do so, we will also tell you with whom we’d shared your Personal or/and Sensitive Data so you can contact them directly.
3.Right to erasure or delete: You may ask us to delete or remove your Personal or/and Sensitive Data, such as where our legal basis for the processing is your consent and you withdraw consent. If we’d shared your data with others, we would tell them about the erasure. If you ask us, and where it is possible and lawful to do so, we will also tell you with whom we’d shared your Personal or/and Sensitive Data with so you can contact them directly. We may continue processing Personal Data where this is necessary for a legitimate interest in doing so according to applicable law, as described in this Privacy Notice.
4.Right to restrict processing: You may ask us to restrict or ‘block’ the processing of your Personal or/and Sensitive Data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we’d shared your Personal or/and Sensitive Data with others, we would tell them about the restriction. If you ask us, and where it is possible and lawful to do so, we will also tell you with whom we’d shared your Personal or/and Sensitive Data so you can contact them directly.
5.Right to data portability: You have the right to obtain your Personal or/and Sensitive Data from us in order to transfer it to another controller, to the extent possible. We will give you your Personal or/and Sensitive Data in a structured, commonly used, and machine-readable format. You may reuse it elsewhere.
6.Right to object: You may ask us at any time to stop processing your Personal or/and Sensitive Data, and we will do so (i) If we are relying on an illegitimate interest to process your Personal or/and Sensitive Data — unless we demonstrate compelling legitimate grounds for the processing, or (ii) If we are processing your Personal or/and Sensitive Data for direct marketing or advertisement.
7.Right to revoke or withdraw consent: If we rely on your consent to process your Personal or/and Sensitive Data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent.
8.Right to consent: We are committed to obtaining your consent prior to the collection, processing, and sharing of your Personal or/and Sensitive Data, prior to their treatment, ensuring transparency and respect for your privacy preferences.
9.Right to lodge a complaint with the data protection authority: If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.
10.Right to opt out: You have the right to opt out of:
i.the simple collection or processing of your Sensitive Data — for accounts identified as belonging to adolescents in Brazil, this opt-out does not apply to collection or processing that is necessary to provide the GUIDU service or required by law; see the applicable product-specific privacy supplement for what that means in practice.( https://guidu.io/supplementary ).
ii.certain disclosures of your Personal or/and Sensitive Data to third parties;
iii.the collection or processing of your Personal or/and Sensitive Data for purposes of (1) targeted advertising; (2) the sale of your Personal or/and Sensitive Data; and (3) the profiling in furtherance of solely automated decisions that produce legal or similarly significant impact to you.

You may also have the right to:

i.Control the disclosure of your Personal or/and Sensitive Data;
ii.Not be discriminated against for exercising your rights described above;
iii.Challenge/contest and not be subject to a decision based solely on automated processing, which produces legal effects ("Automated Decision-Making");
iv.A verification procedure, which is the process of verifying your identity when you exercise any of the rights embraced under this Privacy Notice. This verification procedure ensures that requests related to your Personal or/and Sensitive Data are legitimate and safeguard against unauthorized access or manipulation of personal information; and
v.If you’re under the age of 16, or such other applicable age of consent for privacy purposes in relevant individual jurisdictions, opt-in to certain disclosures of your Personal or/and Sensitive Data to third parties.

Please note that we do not perform decision-making based solely on automated processing that produces legal or similarly significant effects on you. Certain features do involve automated analysis to generate informational recommendations — see Section 20 below for how this applies to AI-powered features.

15.1. HOW TO EXERCISE YOUR RIGHTS

To exercise your rights, please contact us by using the information in Section 21 below. Your Personal Data may be processed in responding to these rights. We try to respond to all legitimate requests within (01) one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, considering the complexity and number of requests we receive. This one-month benchmark reflects a general international practice and is not a uniform deadline across all jurisdictions — for Brazil, see the applicable product-specific privacy supplement for the response deadlines that apply under the LGPD and the ECA Digital. If you are an employee of an Atlas’ customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information. Some registered users may update their user settings, profiles, organization settings, and event registrations by logging into their accounts and editing their settings or profiles. To update your billing information, discontinue your account, or request the return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in Section 21 below.

15.2. YOUR RIGHTS RELATING TO CUSTOMER DATA

As described above, we may also process Personal Data submitted by or for a customer to our products and services. To this end, if not stated otherwise in this Privacy Notice or in a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliates) who is the controller of the Personal Data. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Notice. If your data has been submitted to us by or on behalf of an Atlas’ customer and you wish to exercise any rights you may have under applicable data protection laws, please inquire with them directly. Because we may only access a customer’s data upon their instructions, if you wish to make your request directly to us, please provide us the name of the Atlas’ customer who submitted your data to us. We will refer your request to that customer and will support them as needed in responding to your request within a reasonable timeframe.

16. LEGITIMATE INTERESTS

“Legitimate interests” means our interests in conducting our business, managing, and delivering the best Service to you. This Privacy Notice describes when we process your Personal Data for our legitimate interests, what these interests are and your rights. We will not use your Personal Data for activities where the impact on you overrides our interests, unless we have your consent, or those activities are otherwise required or permitted by law.

17. EEA, UK AND SWITZERLAND DATA PROTECTION SPECIFIC INFORMATION

There are currently two General Data Protection Regulations in effect: one applicable in the European Economic Area (EEA GDPR) and another in the United Kingdom (UK GDPR), which is tailored by the Data Protection Act. Both the EEA GDPR and the UK GDPR govern the collection, use, transfer, storage, and other processing activities involving personal data of individuals within their respective jurisdictions.

The EEA GDPR applies to all 27 member countries of the European Union (EU): Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden as well to all countries in the European Economic Area (the EEA), which is an area larger than the EU and includes Iceland, Norway, and Liechtenstein.

In Switzerland, The Federal Data Protection Act (DPA) serves as the cornerstone of Swiss privacy law. It outlines principles and rules for the processing of personal data, including the collection, use, disclosure, and retention of such data. The FADP has recently been revised with the aim to strengthen data protection in general and to align it with the requirements of the EEA GDPR in order to facilitate compliance of Swiss companies with those aspects of the EEA GDPR that are applicable to controllers or processors outside of the EU, and to ensure that the EU will continue to consider Switzerland as providing an adequate level of data protection,

17.1. WHEN DO THE EEA GDPR, THE UK GDPR AND DPA APPLY?

There are three types of situations that are subject to the EEA GDPR and UK GDPR:

I.If you are present in the EEA or the UK, any personal data collected from you in connection with the offering of a good or service is protected by that area’s GDPR, even if the organization offering the good or service is not established in that area. Protection for the personal data continues after you leave the EEA or the UK.
II.Establishments in the EEA or UK. If personal data is collected or otherwise processed in the context of the activities of any establishment in the EEA or UK, then the personal data is protected by that area’s GDPR, even if the processing occurs outside the EEA or the UK.
III.If you are present in the EEA or UK, any personal data collected from you in connection with the monitoring of your behavior where the behavior takes place within the EEA or the UK.

The FADP, like the EEA GDPR, boasts an extraterritorial reach, extending its applicability to situations impacting Switzerland, irrespective of their origin. This encompasses scenarios involving international corporations with Swiss-based subsidiaries, or in certain cases, even those without such entities but engaged in business activities within Switzerland.

Furthermore, the FADP stipulates that foreign-based private controllers must appoint a representative in Switzerland if they handle personal data of Swiss data subjects, provided the data processing meets the following criteria:

i.The processing is linked to offering goods or services in Switzerland or monitoring the behavior of Swiss data subjects.
ii.The processing is substantial, regular, and poses a significant risk to the privacy of the data subjects.

17.2. YOUR EEA, UK AND FDA RIGHTS

If you are in the EEA, Switzerland, or the UK and where the processing of your Personal or/and Sensitive Data is subject to EU data protection laws, your rights in relation to your personal data processed by us as a controller specifically include (please note that these rights are not absolute and in certain cases are subject to conditions as specified in applicable law):

1.Right to know and access: you have the right to know whether we are collecting and processing your Personal or/and Sensitive Data, the purposes behind it, the categories of personal or/and sensitive data involved, the recipients or categories of recipients to whom your Personal or/and Sensitive Data have been or will be disclosed, if feasible, the anticipated duration for which the personal or/and sensitive data will be retained, or, if not feasible, the criteria used to establish that duration and the existence of automated decision-making, including profiling, the logic involved, as well as the significance and the envisaged consequences of such processing of your Personal or/and Sensitive Data.

You also have the right to know you can, at any time, request us the rectification, erasure and restriction of processing of your personal or/and sensitive data; as well as lodge a complaint with a supervisory authority if you believe we are processing your personal or/and sensitive not in an appropriate way.

2.Right to rectification: if your Personal or/and Sensitive Data is inaccurate or incomplete, you have the right to require us to correct or complete it.
3.Right to erasure (‘'right to be forgotten’'): you have the right to request us to delete your Personal or/and Sensitive Data, without delay, if one of the following conditions is met: (a) your Personal or/and Sensitive Data are no longer needed for the purpose they were collected or processed. (b) you withdraw or revoke the previously given consent, and there is no other legal basis for processing. (c) you object to the processing, and there are no overriding legitimate reasons for it. (d) your Personal or/and Sensitive Data have been processed unlawfully. (e) erasure is required to comply with a legal obligation; and (f) your Personal or/and Sensitive data were collected regarding the offer of online services.
4.Right to restrict processing: you have the right to request us to limit the processing of your Personal or/and Sensitive Data in the following cases: (a) if you contest the accuracy of your Personal or/and Sensitive Data, we can restrict processing while verifying its accuracy; (b) if the processing is unlawful and you oppose erasure, you can request the restriction of data use instead; (c) if we no longer need your Personal or/and Sensitive Data for processing purposes but you require them for legal claims; and (d) if you have objected to processing of your Personal or/and Sensitive Data, we may restrict its processing while we verify our legitimate grounds.
5.Right to data portability: you have the right to receive your Personal or/and Sensitive Data, which you have provided to us, in a structured, commonly used, and machine-readable format and to have that information transmitted to another organization, without obstruction, under the conditions that: (a) the processing of your Personal or/and Sensitive Data is based on your consent or contract performance; and (b) the processing is automated.

Your exercise of this right does not affect your right to ask us to erasure your Personal or/and Sensitive Data. However, this erasure right does not apply to processing necessary for public interest tasks or the exercise of official authority. Nevertheless, your right to data portability must not infringe upon the rights and freedoms of others.

6.Right to object processing: You have the right to object to the processing of your Personal or/and Sensitive Data, including profiling, at any time if it's based on public interest tasks, official authority, or our legitimate interests as well as legitimate interests of third parties. However, this right doesn't apply if your interests or fundamental rights override our legitimate interests, especially if you are a child.

In the context of using online services, you can object using automated means. Additionally, when your Personal or/and Sensitive Data are processed for scientific, historical, or statistical purposes, you can object based on their specific circumstances, except if the processing is essential for a task in the public interest.

7.Right to stop automated decision-making: you have the right not to have a decision made about you that is based solely on automated processing if that decision produces legal or similarly significant effects concerning you.

In addition to the above, you have the right to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Information infringes applicable data protection law. While we will make reasonable efforts to accommodate your request, we reserve the right to reject such access requests or to impose restrictions or requirements upon such requests if required or permitted by applicable law.

To exercise your rights or if you have any other questions about our use of your personal data, please send a request at the contact details specified in the Section 21 below. Please note that we may request you to provide us with additional information in order to confirm your identity and ensure that you are entitled to access the relevant personal data.

18. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

The content of this Section applies solely to Atlas’ Users, Viewers, and Invitees who live in the State of California (“California Residents”). Atlas adopts this notice to comply with the California Consumer Privacy Act of 2019 and any subsequent amendments (“CCPA”). All terms used in this California Notice have the same meaning as when used in the CCPA.

18.1. WHAT IS WHAT A PERSONAL DATA ACCORDING TO CCPA?

Personal Data according to the California Consumer Privacy Act of 2019 and its subsequent amendments means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (individual) or household. This definition includes, but is not limited to, the following information:

i.First name, middle names, last names, aliases, and signatures;
ii.Physical characteristics or description;
iii.Social media, website-used usernames, login credentials account name and email addresses;
iv.Financial data, including bank account number, credit card or debit card number, or any other financial information;
v.Internet Protocol address;
vi.Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies;
vii.Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement;
viii.Audio, electronic, visual, thermal, olfactory, or similar information;
ix.Home or postal address information;
x.Telephone or cellphone numbers;
xi.Driver’s license number;
xii.Insurance policy number
xiii.Passport number or information;
xiv.Social Security number;
xv.State identification card number;
xvi.Professional or employment-related information, including resume, job history, and other similar records related to an individual;
xvii.Educational information;
xviii.Medical or health insurance information;
xix.Biometric information;
xx.Geolocation data.
xxi.Any online identifier, particular or unique identifier, or any similar identifiers assigned to the natural person or household;
xxii.Sensitive personal information/data.

It does not include aggregate, de-identified data or publicly available information that is lawfully made available to the general public from federal, state, or local government records.

18.2. WHAT IS WHAT A SENSITIVE PERSONAL INFORMATION/DATA ACCORDING TO CCPA?

Sensitive Personal Information/Data according to the California Consumer Privacy Act of 2019 and its subsequent amendments means:

1.Personal information that reveals:
a.A consumer’s social security, driver’s license, state identification card, or passport number;
b.A consumer’s account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
c.A consumer’s precise geolocation;
d.A consumer’s racial or ethnic origin, religious or philosophical beliefs, or union membership;
e.The contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication;
f.A consumer’s genetic data.
g.The processing of biometric information for the purpose of uniquely identifying a consumer.
i.Personal information collected and analyzed concerning a consumer’s health.
ii.Personal information collected and analyzed concerning a consumer’s sex life or sexual orientation.

It does not include aggregate, de-identified data or publicly available information that is lawfully made available to the general public from federal, state, or local government records.

We do not generally seek to collect sensitive data as defined above. In the limited cases in which we will seek to collect such data, we will do this in accordance with these Privacy Notice requirements and/or ask for your explicit consent.

18.3. INFORMATION ATLAS MAY COLLECT REGARDING CALIFORNIA RESIDENTS

We may have collected the following categories of Personal or/and Sensitive Information from California Resident Users, Invitees, and Viewers within the last twelve months, for the purpose of establishing, maintaining, and supporting the services that we provide through our website:

A.Identifiers: first name; surname; email address; internet protocol address, social security number.
B.Financial information: bank account number, credit card or debit card number.
C.Professional or employment-related information, including resume, job history, and other similar records related to an individual.
D.Educational information.
E.Social media information: login credentials, account name and email addresses.
F.Commercial information: Purchase records regarding Atlas products.
G.Internet or other similar network activity: Data on Viewers’ interaction with the Atlas Website.

Atlas obtains the Categories of Personal Information Listed Above from the Following Categories of Sources

i.Directly from our Users and Invitees.
ii.Indirectly from our Users and Invitees.
iii.Directly and indirectly from activity on our Website.
iv.From third parties that interact with us in connection with the services we perform.

We may also derive insights about California Resident Users, Invitees, and Viewers based on the information described above and collect additional information about them as outlined in this Pivacy Noticed. If they provide us with personal information about another individual (such as a potential employee/referral or relative), they are responsible for ensuring that the individual is informed about the contents of this Privacy Notice and has provided his/her consent for sharing the information with Atlas.

The aforementioned categories of Personal or/and Sensitive Information/Data have been obtained either directly from the California Resident Users, Invitees, and Viewers (for example, when they provide information to log in to our App, etc.,) or indirectly from certain third parties (for example, through our website’s technology). These third parties may include our affiliates, public authorities, public websites, and social media platforms, as well as suppliers/providers and clients. Unless certain information is required by law, the California Resident Users, Invitees, and Viewers’ decision to provide any Personal or/and Sensitive Information/Data to us is voluntary. Please note that if they do not provide certain information, we may not be able to accomplish some or all of the purposes outlined in this Privacy Notice, and they may not be able to use certain tools and systems that require the use of such Personal or/and Sensitive Information/Data.

18.4. HOW CALIFORNIA RESIDENTS’ PERSONAL INFORMATION MAY BE USED

We may use or disclose the Personal or/and Sensitive Information/Data we collect for one or more of the following business purposes:

●To fulfill or meet the reason for which the information is provided.
●To exercise our legitimate interests;
●To provide you with information or services that you request from us.
●To provide you with email alerts and other notices concerning our services, or news that may be of interest to you.
●To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
●To improve our website.
●For testing, research, analysis, and service development.
●As necessary or appropriate to protect Atlas and our Users.
●To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
●As described to you when your Personal Information was collected, or as otherwise set forth in the CCPA.
●To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Atlas is among the assets transferred.

Atlas will not collect additional categories of Personal Information or use the Personal Information we collect for materially different, unrelated, or incompatible purposes without providing you notice.

18.5. SHARING PERSONAL INFORMATION

We may disclose your Personal or/and Sensitive Information/Data to a third-party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing your contract. We disclose your Personal Information for a business purpose to the following categories of third parties:

●Service Providers, including, but not limited to, marketing, advertising, and analytics providers.
●Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the services we provide to you.
●Government representatives as required by law.

18.6. YOUR RIGHTS ACCORDING TO CCPA

Despite the Rights assured to you in the above Section 15 (“YOUR RIGHTS RELATING TO YOUR PERSONAL DATA”), if you are a California Resident User, Invitee or Viewer, the CCPA grants you specific rights regarding your Personal or/and Sensitive Information/Data, such as:

1.Right to know: You have the right to request that we disclose certain information to you about our collection and use of your Personal or/and Sensitive Information/Data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
i.The categories of Personal or/and Sensitive Information/Data we collected about you.
ii.The categories of sources for the Personal or/and Sensitive Information/Data we collected about you.
iii.Our business or commercial purpose for collecting that Personal or/and Sensitive Information/Data.
iv.The categories of third parties with whom we share that Personal or/and Sensitive Information/Data.
v.The specific pieces of Personal or/and Sensitive Information/Data that we have collected about you.
2.Right to Opt Out of Sale or Sharing of Personal Information: You have the right to tell us not to sell or share your Personal or/and Sensitive Information/Data with other companies. This is called the "right to opt-out.” If we sell or share your Personal or/and Sensitive Information/Data, we must let you know about it and give you the option to opt-out. However, if you are under 16 years old, we cannot sell or share your Personal or/and Sensitive Information/Data unless you (if you are between 13 and 16) or your parent/guardian (if you are under 13) agrees to it.
3.Right to rectification or correction: If your Personal or/and Sensitive Information/Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it. If we’d shared your Personal or/and Sensitive Information/Data with others, we would tell them about the correction. If you ask us, and where it is possible and lawful to do so, we will also tell you with whom we’d shared your Personal or/and Sensitive Information/Data so you can contact them directly.
4.Right to erasure or delete: You have the right to request that we delete any of your Personal or/and Sensitive Information/Data that we have collected from you and retained, subject to certain exceptions. Deletion requests should be sent to the contact details specified in the Section 21 below.. Once we receive and confirm your verifiable request, we will delete (and direct our Service Providers to delete) your Personal or/and Sensitive Data from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
i.Complete the transaction for which we collected the Personal or/and Sensitive Information/Data, provide a service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
ii.Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
iii.Debug software to identify and repair errors that impair existing intended functionality.
iv.Comply with the California Electronic Communications Privacy Act.
v.Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
vi.Comply with a legal obligation.
vii.Otherwise lawfully use that information in compatibility with the context in which you provided it.
5.Right to data portability: You have the right to obtain your Personal or/and Sensitive Information/Data from us in order to transfer it to another controller, to the extent possible. We will give you your Personal or/and Sensitive Information/Data in a structured, commonly used, and machine-readable format. You may reuse it elsewhere.
6.Right to Limit Use and Disclosure of Sensitive Personal Information: If we are collecting, processing or treating your Sensitive Personal information, you have the right, at any given time, to ask us to restrict its utilization solely to the extent required for providing our services.
7.Right to Non-Discrimination/No Retaliation: You have the right not to be discriminated against or retaliated against for exercising any of the rights set out in the CCPA.
8.Right to Notice: You have a right to receive notice of our practices at or before collection of Personal or/and Sensitive Information/Data.
9.Right to Designate an Authorized Agent: You may designate an authorized agent to exercise some of your rights; however, in order to help protect the security of your personal information, the authorized agent must follow the same authentication procedures that are required if you exercise your rights without using an agent. We will verify requests made through authorized agents to help ensure the safety of your account and to comply with our policies and procedures.

18.7. EXERCISING THE RIGHTS SET OUT IN THE CCPA

To exercise any of the rights described above, please submit a verifiable consumer request to us by reaching out the contact details specified in the Section 21 below. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable California Resident request for access or data portability twice within a 12-month period. The request must:

●Provide sufficiently detailed information to allow Atlas to reasonably verify that you are the person to whom the requested Personal Information pertains or their authorized representative.
●Include sufficient detail to allow us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us. Atlas will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

18.8. SALES OF PERSONAL DATA UNDER THE CCPA

For purposes of the CCPA, ATLAS does not sell Personal or/and Sensitive Information/Data, nor do we have actual knowledge of any sale of Personal or/and Sensitive Information/Data of minors under 16 years of age.

19. PRIVACY NOTICE FOR PERUVIAN CITIZENS AND RESIDENTS

If you are located in Peru or if your Personal Data is processed in connection with activities in Peru, the processing of your Personal Data is subject to Peruvian Law nº 29733, the Personal Data Protection Law (the “PDPL”), and its Regulations, including the new Regulation approved by Supreme Decree nº 016-2024-JUS, effective March 30th, 2025. This section supplements the information in this Privacy Notice and reflects updates for enhanced transparency, accountability, and data subject rights.

19.1. LEGAL BASIS FOR PROCESSING

We process your Personal Data based on the legal grounds permitted by the PDPL. Our primary legal basis is your prior, free, express, unequivocal, and informed consent, which we obtain before collection. Where consent is not required, we may process your data on other legal bases, including but not limited to:

I.The execution of a contractual or pre-contractual relationship with you, where processing is necessary for the execution or fulfillment of contractual obligations;
II.The development and compliance of a scientific or professional relationship with you;
III.The fulfillment of a legal obligation applicable to us;
IV.The safeguarding of your legitimate interests or our own, provided that your fundamental rights and freedoms do not prevail;
V.When the data is from a publicly available source or has been anonymized or dissociated.

19.2. PROCESSING OF SENSITIVE DATA

Sensitive data includes personal data referring to:

i.racial and ethnic origin,
ii.political, religious, philosophical, and moral beliefs,
iii.union membership,
iv.physical or mental health,
v.sexual life,
vi.physical, moral, and emotional characteristics,
vii.facts or circumstances of emotional or family life,
viii.personal habits corresponding to the most intimate sphere, and
ix.biometric data that can by itself identify the owner.

We will only process your Sensitive Data after obtaining your free, prior, unequivocal and written consent/permission. This permission must be:

1.Informed: you understand exactly what you agree to.
2.Explicit: you must directly confirm your agreement.
3.Documented: we keep a record of your consent.

Your "written" consent can be given in simple, digital ways, such as:

1.Clicking "I Agree" on a checkbox or button.
2.Tapping "Accept" on a screen.
3.Using an electronic signature.
4.Or any other clear action that shows you agree to the terms presented.

The request for your permission will always be shown in clear, simple language that is easy to read and understand.

We will only use this sensitive data for specific, legitimate purposes that are directly related to our services.

19.3. YOUR RIGHTS (ARCO RIGHTS AND OTHERS)

As a data subject (holder of personal data) under Peruvian law, you have the right to:

1.Access/Information: To request and receive information on the processing of your data, the purposes of collection, who ordered the processing, and any cross-border transfers.
2.Rectification (Correction/Update/Inclusion): To update, include, or correct your personal data when it is inaccurate, incomplete, or false.
3.Cancellation (Deletion/Suppression): To request the deletion of your personal data when it is no longer necessary or relevant for its collection purpose, or when the expiration date established for the processing occurs.
4.Opposition: To object to the processing of your personal data for legitimate reasons relating to your individual situation.
5.Prevent Disclosure: To prevent the disclosure of your personal data to third parties, especially when it impacts your fundamental rights (this right does not apply to disclosures made to our data processors, which Peru's law refers to as managers of personal data banks).
6.Non-Automated Decision-Making: Not to be subject to a decision based solely on automated processing with legal or significant effects, unless it occurs during the negotiation of a contract or the process of hiring for a public office.
7.Indemnification: To be indemnified or claim compensation for any damages caused by an infringement of data protection law.

Additionally, you have the right to Portability (effective September 30th , 2025), allowing you to receive your Personal Data in a structured, commonly used, and machine-readable format for transfer to another controller, where technically feasible.

You may exercise these rights by contacting us using the details in Section 21. We will respond to your request within the legal terms: 20 business days for access and portability requests and 10 business days for rectification, cancellation, or opposition requests, which may be extended for a further 10 business days with justification.

If you are not satisfied with our response, you may file a claim before the National Authority for Personal Data Protection (NAPDP) or a petition for the writ of habeas data before the Judiciary.

19.4. INTERNATIONAL DATA TRANSFERS

Your Personal Data may be stored and processed in countries outside Peru, including the United States where ATLAS is based.

We may transfer your data to other countries if they provide an adequate level of protection (at least the same level as Peruvian law). For countries without an adequate level of protection, we will ensure that any international transfer of your data is conducted with adequate safeguards as required by Peruvian law, such as standard contractual clauses, adequacy decisions, or other approved mechanisms and legal instruments that establish the same legal obligations as the Amended PDPL, to ensure the security and confidentiality of your information.

Alternatively, a transfer can be made if:

●You have given prior, free, express, unequivocal, and informed consent to the transfer.
●The transfer is necessary to execute a contractual relationship to which you are a party (which may include activities like user authentication, service improvement, maintenance, and billing).

International transfers are performed only when necessary for contractual performance, compliance with legal obligations, international cooperation, or other lawful grounds under Peruvian legislation.

We maintain detailed records of all transfers and require that foreign recipients provide equivalent levels of data protection and confidentiality.

19.5. SUPERVISORY AUTHORITY

You have the right to file a complaint with the Peruvian data protection authority, the National Authority for the Protection of Personal Data (“Autoridad Nacional de Protección de Datos Personales – ANPD”), under the Ministry of Justice and Human Rights, if you consider that the processing of your Personal Data infringes the law.

For more information, visit the ANPD's platform “I take care of my personal data” for citizen support.

20. AUTOMATED PROCESSING, ARTIFICIAL INTELLIGENCE, AND USER RIGHTS

To enhance your experience and provide you with innovative, personalized services, we utilize advanced Artificial Intelligence (“AI”) models and technologies, including large language models provided by one or more third-party AI providers, integrated within our App. These technologies assist us in analyzing data and generating insights to deliver personalized career guidance, assessments, and solutions, ensuring measurable and meaningful outcomes aligned with each user’s needs and preferences.

20.1. PURPOSES FOR USING AI

The primary purposes for using AI are:

i.Personalized Career Guidance: To analyze your profile, preferences, and activity to generate tailored career insights, recommendations, and action plans.
ii.Content and Solution Generation: To assist in creating, summarizing, and personalizing content and solutions that help you achieve measurable and meaningful career outcomes.
iii.User Experience Improvement: To understand user interactions and feedback, enabling us to continuously improve the functionality, relevance, and effectiveness of our App.

20.2. DATA PROCESSING AND ARTIFICIAL INTELLIGENCE (AI)

When you use AI-powered features, we may process the Personal Data and Sensitive Data you provide (such as your profile information, career history, and system inputs) through third-party AI models. Where technically feasible, such data is de-identified (through anonymization or pseudonymization, as appropriate) before it is processed by a third-party AI model; the specific technique used depends on the provider and feature involved and does not, in every case, eliminate the possibility of re-identification from the content of a conversation. This processing is necessary to provide the requested services and is based on our legitimate interest in offering a sophisticated and customized user experience, or on your prior and express consent where required by law.

We do not use AI systems to perform fully automated decision-making that produces legal or similarly significant effects concerning you. AI-generated recommendations are informational and exploratory in nature. Human oversight and review mechanisms apply to the processing activities for which they have been implemented; where a specific feature does not yet have such a mechanism in place, this Notice will be updated accordingly before that feature is relied upon for decisions with a significant effect on you.

20.3. THIRD-PARTY AI PROVIDERS

The AI models used within our App are provided by third-party service providers. We enter into contractual agreements with these providers requiring them to protect your data and to use it solely as necessary to deliver services to us, in full compliance with this Privacy Notice and applicable data protection laws.

We do not use any data submitted to or generated by the AI systems to independently train or improve the underlying foundational models of our third-party providers without your explicit consent. Your data is processed exclusively to generate your personalized results and is handled in accordance with our strict data security and confidentiality standards.

20.4. DATA PROTECTION AND COMPLIANCE

All AI-related processing activities are conducted in compliance with the General Data Protection Regulation (GDPR and UK GDPR), the Lei Geral de Proteção de Dados (LGPD – Brazil), the Personal Data Protection Law (PDPL – Peru), the California Consumer Privacy Act (CCPA), and other Data Privacy Acts of the USA. We adhere to the principles of lawfulness, fairness, transparency, purpose limitation, accuracy, data minimization, integrity, and accountability in all AI-based operations.

Personal and sensitive data processed through AI technologies are de-identified (anonymized or pseudonymized, as appropriate) prior to any processing by third-party AI models, and are handled solely for legitimate, specific, and informed purposes. Such data are protected by appropriate technical and organizational safeguards, including de-identification, encryption, and strict access controls, to ensure the security and confidentiality of your data. We are firmly committed to preventing any unauthorized or discriminatory profiling.

20.5. YOUR RIGHTS

Where required by applicable law, we will obtain your prior and express consent before processing your personal or sensitive data through AI technologies. You have the right to:

a.request clear and transparent information about how AI is used in relation to your personal data;
b.object to or restrict AI-based processing;
c.withdraw your consent at any time; and
d.request human intervention, correction, or deletion of personal data processed through AI systems.

For more information on how your data may be shared with third-party service providers, please refer to Section 8 (DISCLOSURE OF YOUR PERSONAL AND SENSITIVE INFORMATION).

If you have any questions about our use of AI or wish to exercise your rights regarding the processing of your data in this context, please contact us using the communication channels indicated in Section 21 of this Privacy Notice.

21. CONTACT INFORMATION

To ask questions or comment about this privacy notice and our privacy practices, contact us at support@guidu.io.

Last Update in September 2026

Last updated: September 26, 2026 · version 2026-09-24