This Privacy Policy is applicable as of May 25, 2018.

1. PURPOSE

This Privacy Policy together with the Terms and Conditions and the Cookie Policy apply to you if you use the following ATLAS Services (hereinafter referred to as "Services" or "ATLAS Services"):

• Our site atlas.app, hereinafter referred to as the "Site", and the ATLAS platform available at my.atlas.app, hereinafter referred to as "Platform", "ATLAS" and / or "ATLAS Platform", accessible from compatible web browser and / or from the moment when you have installed a copy of the Microsoft Windows or Apple MacOS application on any compatible device;
• The ATLAS mobile application, hereinafter referred to as the App, available in the Apple AppStore and Google Play, as soon as you download a copy of it to your mobile phone or any compatible device;
• Any of the services available through the Application, the Site or the ATLAS Platform - hereinafter referred to as "External Services". Are added to this category, but are not limited to: our pages on social networks (Facebook, Twitter, Google+, Dribble, Reddit etc.) etc.

This document sets out the rules by which you submit your personal data, but also the situations in which we collect this data with your consent, and how all such data is processed or used by us.

Data Protection Officer

ATLAS INTEGRATED TECHNOLOGIES SRL has appointed a Data Protection Officer (DPO). Within ATLAS INTEGRATED TECHNOLOGIES, this role has a number of important responsibilities with respect to personal data, including:

• Monitoring compliance by ATLAS INTEGRATED TECHNOLOGIES with the rules outlined in the General Data Protection Regulation (GDPR) and other data protection laws;
• Raising awareness of data protection issues, training of ATLAS INTEGRATED TECHNOLOGIES staff and collaborators;
• Conducting internal audits of personal data and their protection;
• Cooperation with supervisors, in the interest and limits of the law.

If you have any questions about this Privacy Policy, including any request to exercise your legal rights, you may contact us at any time:

• Via email at [email protected];
• By opening a ticket here. 

Complaints

You have the right to submit a complaint at any time to the National Supervisory Authority for Personal Data Processing (https://www.dataprotection.ro), the Romanian supervisory authority for personal data protection issues.

However, we encourage you to contact us directly to be able to respond to any concerns or requests regarding your personal data.

Commitment

Since transparency is one of our values and to be no misunderstanding about how we manage your personal data, we will ensure that:

• We will always keep your data private and secure;
• We will never sell your data;
• We provide you, at any time, with ways to manage and review your options regarding marketing.

2. COOKIES

We use cookies to distinguish users who use the Site, the Application, or the ATLAS Platform. This helps us to provide the best experience when you use the Application or browse our Website or our Platform.

Cookies, by themselves, do not require personal data to be used.

Thus, using cookies will not identify personally or individually the users who have navigated the pages of the site and / or the ATLAS platform.

For detailed information on how and where we use cookies, you can always consult the Cookies Policy available here.

3. PERSONAL DATA USED

We register the following data types for processing:

a. Provided Information

It is the data that you provide us directly by filling in the pages / forms available in the ATLAS Services. Also, the information you provide when you correspond with us, by email or with the help of the chat available within the Application, Site, and / or Platform is also included in this category.

This data is transmitted when:

• You register within the Site, Application, or Platform;
• Download or register the ATLAS Application;
• You subscribe to any of our services listed on the Site, Application, or Platform;
• Initiate any transaction within the Application or Platform (Purchasing Services listed by Specialists, Purchasing Products and Services listed in ATLAS Store);
• Participate in discussions, discussion forums and / or other similar social media features within the Site, Application, Platform, or Services available through / within them;
• Participate in a competition, promotion or questionnaire available on the Site, Application, Platform, or Service;
• Report a Site, App, Service, or Platform issue.

Sent information may include your name, surname, address, date of birth, email address, telephone number, username, password and other information required for registration, financial information, your bank account details, IBAN code, details of your debit and / or credit cards, including card number, card expiration dates and CVC, identification documents and their numbers, copies of your identification documents (ID card, passport, driving license, diplomas studies, credentials from organizations and professional associations where you are active, etc.), your personal description, your photo, and other information you provide us to prove eligibility to use our services.

b. Collected Information

It is the data we collect from you and your device.

Every time you visit / use the ATLAS Services, we will automatically collect the following information:

• Technical information, including the IP address (internet protocol) used to connect your equipment (computer, phone, tablet, or any similar device) to the Internet, your connectivity information, the web browser type and version, time zone settings, browser plugin types and their versions, operating system and platform, information about the type of mobile device you are using, a unique device ID (for example, your device's IMEI number, the MAC address of your network card, or the phone number used by the device), mobile network information, operating system of the mobile device and its version, the type of browser / mobile web browser you are using, the time zone setting;
• Information regarding your visit, including the Uniform Resource Locator (URL) used to access the ATLAS Services, navigating through these Services and accessing external resources from the ATLAS Services as well as the date and time at which these URLs were accessed. Also included are the services you've viewed or searched for, the response times of the pages used, the errors you encountered, the duration of the visits on each page, how you interacted with each individual page (such as scroll, clicks, mouse movements) but also interaction and how you navigate between pages, methods used to navigate outside of the Services and their pages;
• Information about the events you make during Online Sessions, Offline Sessions (at the Office or at Home) as well as other services you purchase or take advantage through the ATLAS Platform. This information includes the date and time you initiate the reservation, the reservation process, the attempts to pay for the services and their actual payment, the attempts to access the meetings and effectively accessing them, attending the meetings, leaving the meetings, disconnecting and reconnecting within sessions, completion, and other similar events in the sense listed above. Also, the events during meetings also include the date and time you saved information related to Sessions (Private Notes, Shared Notes, etc.), transferred files during Sessions and actual files, sent messages during Sessions using the available chat service, etc. The actual information transmitted is encrypted and can only be accessed by you and your partner (s) within those Sessions. Also, video and audio communications are made directly between the equipment of those attending the Sessions and are not saved in any form by ATLAS INTEGRATED TECHNOLOGIES;
• Information on Transactions - date, time, sum of reserved session, currency used, data used for payment of services, IP address of the transfere, payer's name and registration information, device information used to facilitate payment;
• Information about the messages sent to the platform - the date and time at which they were transmitted, the details of the recipient, as well as information on attachments (photos, video files, and any other digital content) within conversations. The actual text of the messages is encrypted and is saved as a string and can be viewed only by the Sender and the Recipient and only within the ATLAS Application and / or Platform.
• Information stored on your device, including, if you explicitly allow access to the ATLAS Application to Contacts in your Phone Contacts, connectivity information, photos and / or video files as well as any other digital content.
• Details of your use of ATLAS Services or your visits to our site

c. Information regarding Location

We use the native capabilities of the Apple iOS and Google Android operating systems to determine your location. This information is only required when you access a video session and is used to identify the closest ATLAS server to your location to deliver the website content, application, ATLAS Platform, and high-quality video and audio content;

If you want to use this feature, you will be explicitly asked to agree to ATLAS using your data for that purpose. Once granted, you can withdraw your consent at any time by disabling location permission for the ATLAS application in your device settings.

d. Information that helps us deliver services to you

We work closely with third parties to help us deliver our Services to you. These third parties are business partners (such as external companies that promote or sell ATLAS Services to other companies or Companies that buy / negotiate ATLAS services to provide them to their own employees etc.), subcontractors in technical and payment services, advertising companies, analytics service providers, search providers, fraud prevention agencies, agencies and governmental bodies.

The information we may collect about you from such third parties may include information that helps us verify:

• Your identity;
• The veracity of the transmitted information;
• Eligibility to list services within the ATLAS platform;
• Eligibility to use ATLAS services (for example, Companies that offer ATLAS services in special conditions to employees can provide us with periodic information that can identify existing employees and those who have left the company)

e. Information you give us access to

If you allow us explicit access, we will collect the friends list on Facebook and other similar information from other third parties such as Google, Twitter, Instagram. The application will periodically collect this information to be of immediate relevance.

Once granted access to that information, you can withdraw your consent at any time by disabling the permissions for the ATLAS application in your device settings.

4. USE OF DATA

a. Use of Information

In the following lines, we'll present the details of how data types are used and for what purposes.

Thus, we use the information about you in the following ways:

i. Provided Information

We use this information:

• To fulfill our obligations arising from your interactions with the ATLAS Platform, such as: Online Sessions, Cabinet Sessions, Chat Services, Transactions, Payments and to provide you with all the information, services and products that you request;
• Provide information about other goods and services, whether listed or not on the ATLAS platform, which may be similar to those you have purchased or requested within the platform;
• Provide directly, or allow third parties to provide you, information about products and services that we think you are interested in or might be interested in;
• To verify identity for the purpose of fraud protection in order to comply with the laws of the state / country / territory in which you operate, but also the laws on financial crime, and to confirm the eligibility to use our services and products;
• Facilitate interactions between users through our services and give you the opportunity to distribute / recommend to your contacts the use of ATLAS services;
• Notify and inform about changes to our services;
• Ensure that the content presented on the ATLAS site, application, and / or platform is presented in a way that is as efficient as possible for you and your device.

ii. Collected information

We use this information:

• Administration of the ATLAS Application and Platform, including for audit, troubleshooting, data analysis, testing, research, statistics;
• Transparency and auditing of all your interactions in terms of evaluation, booking, payment / payment and consumption of products and services available on the ATLAS platform
• Improve our website, application and ATLAS Platform to ensure that information and content are presented in the most efficient way for you and the device you are using;
• To grant you the right to participate in the interactive sections of the Site, the Application or the ATLAS Platform when you choose to do so;
• Keeping the ATLAS Application, Platform and website secure and safe;
• Measure and understand the effectiveness of advertising that we can offer to ATLAS users, site visitors and others and to be able to offer relevant advertising.
• Make suggestions and recommendations to both ATLAS users, site visitors and others about the goods and services that may interest you or them;
• Verify identity for fraud protection in order to comply with the laws of the state / country / territory in which you operate, but also the laws on financial crime, and to confirm the eligibility to use our services and products;
• To comply with all policies, terms and conditions and other regulations contained in the Legal Agreements section.

iii. Information regarding Location

We use this information:

• Identify the nearest ATLAS server from your location to deliver the content of the website, the application, the ATLAS Platform, and video and audio content to the highest quality standards;
• Deliver relevant information and advertising - for example: nearby ATLAS Specialists, services and products that may be of interest to you, near you;
• Data analysis, research and statistics on the geographical distribution of ATLAS users and the use of our services.

iv. External / third party information

We will aggregate the external / third party information with the information you provide to us, but also with the information collected about you, and we will use this information to:

• Help us better understand your behavior so that we can make decisions about how we manage your ATLAS account;
• Analyze and process requests regarding the listing, booking, purchase and use of existing goods and services within the ATLAS Platform to be able to make decisions about accepting or rejecting such requests in the future.

b. Aggregating personal data

In order to use the data, we can associate / link the various categories of information, such aggregated data being considered personal data, to be treated in accordance with this Privacy Policy.

For example, we can use external / third-party companies regarding:

i. Registering as an ATLAS Specialist and conducting this activity on a regular basis

In order to be able to identify whether you are eligible to carry out activities within the Platform, external companies can search for:

• Your professional training;
• The accreditations obtained in view of legally exercising your professional activity;
• The financial situation of the Legal Entity you represent / have ownership of and of which you legally exercise your profession / activity
• Information on frauds, fraud attempts and any other facts related to financial crime;
• Information on the existence of the financial credits of you and of the Legal Entity involved

If you want details about external companies / third parties with whom we have obtained or we can obtain information about you please contact us at [email protected].

Likewise, you may also withdraw the consent to seek information about your financial credits at any time by contacting [email protected]

ii. Using and consuming services listed within ATLAS

In order to offer you the most personalized services within the ATLAS Platform, external companies can search for:

• Types of products and services that you currently use;
• Your online activity and behavior regarding the purchase of products and services;
• Your health status, medical history and medical interventions;

If we decide to hire Advertising Agencies to promote ATLAS products and services, these Agencies and their partners may request personal anonymous data to provide you with personalized information and advertising.

We will never disclose information that could lead to the identification of individuals, but we can provide aggregated and anonymous information about our users.

We can also use aggregated and anonymous information to help our partners deliver personalized and specific advertising campaigns relevant to a particular category of our users.

Furthermore, we can offer our partners, in some cases, such aggregated and depersonalized information to use in their own advertising campaigns for their target audience.

c. Purpose of using personal data

Hereinafter, you can find a description of all the ways in which we use your personal data as outlined above, and the legal grounds on which we proceed in this manner. Furthermore, where applicable, we will also provide the following information:

• Legitimate interest

Represents any conduct required to conduct, exercise, and manage ATLAS INTEGRATED TECHNOLOGIES's activities in order to achieve the purpose, mission and vision for which the ATLAS Platform was created. Legitimate interest also means any activity that allows us and helps us to provide our users with ATLAS services in conditions of maximum security.

We assure you that we always look first and foremost at your personal data rights and always consider the implications that such personal data might have on you before processing any kind of personal data in order to achieve our legitimate purpose.

Furthermore, even when certain activities would help us achieve our legitimate purpose, we will never use your personal data in activities that may have an impact on you as long as we do not have your consent or the legislation in force (applicable) will or will not require us to.

• Contractual obligations

The processing of your data is done for the purpose of executing the contractual relations in which you are a part of or to take action at your request, before concluding / deciding to take part in such a contract.

• Legal Obligations

Your personal data is used and processed for compliance and within the limits of applicable law (in force). These legal obligations apply, for example: mandatory data appearing on tax invoices, the obligation to keep tax invoices for a certain amount of time, etc.

The purposes for which we use your personal data are:

i. Service delivery

Motive:

• Providing all services and products you request or have you booked, reserved / paid and / or consumed;
• Fulfilling the obligations arising from your interactions with the ATLAS Platform, such as: Online Sessions, Office Sessions, Chat Services, Transactions, Payments and to provide you with all the information, services and products you require;
• Providing information about other goods and services, whether listed or not on the ATLAS platform, which may be similar to those you have purchased or applied for within the platform;

Type of information:

• Provided information

The purpose of processing:

• Contractual obligations
• Our legitimate interest
• Legal Obligations

Legitimate interest:

• Efficiency of fulfilling legal and contractual obligations
• Our commercial interest in delivering competitive products and services
• Complying with applicable regulations which have to be respected

ii. Transparency & Fight Against Fraud

Motive:

• The audit of all your interactions in terms of evaluating, booking, paying / paying and consuming products and services available on the ATLAS platform
• Identity verification for fraud protection in order to comply with the laws of the state / country / territory in which you operate, but also the laws on financial crime, as well as to confirm the eligibility to use our services and products;
• Help us better understand your behavior so that we can make decisions about how we manage your ATLAS account;

Type of information:

• Provided Information
• Collected Information
• External / third party Information

The purpose of processing:

• Contractual obligations
• Our legitimate interest
• Legal Obligations

Legitimate interest:

• Ensuring the transparency regarding the user's interaction with the products and services listed on the platform;
• Develop and improve the way we handle frauds and compliance with our legal obligations in this regard;
• Compliance with current legislation.

iii. Continuous improvement of services and products

Motive:

• Content presented on the ATLAS website, application, and / or platform to be presented as efficiently as possible to you and your device.
• Improving the site, application, and ATLAS Platform to ensure that information and content are presented in the most effective way for you and the device you are using;

Type of information:

• Provided Information
• Collected Information
• External / third party Information

The purpose of processing:

• Our legitimate interest

Legitimate interest:

• Continuous improvement of listed products and services within the platform;
• Providing customized services and products to suit the needs of users;
• Defining client types for new products and / or services;
• Efficiency of legal and contractual obligations.

iv. Promoting and delivering new products and services

Motive:

• Providing information about other goods and services, whether listed or not on the ATLAS platform, which may be similar to those you have purchased or requested within the platform;
• Providing directly or through third parties information about products and services that we think you are interested in or might be interested in;
• Measuring and understanding the effectiveness of advertising that we can offer ATLAS users, site visitors and others and to be able to offer relevant advertising.
• Creating and promoting suggestions and recommendations to ATLAS users, site visitors and others about the goods and services that may interest you or them;
• Analyzing and processing requests for listing, booking, purchasing, and use of existing goods and services within the ATLAS Platform to be able to make decisions about accepting or rejecting such requests in the future.

Type of information:

• Provided Information
• Collected Information
• External / third party Information

The purpose of processing:

• Our legitimate interest

Legitimate interest:

• Developing products and services for existing clients as well as any commissions
• Define client types for new products and / or services
• Efficiency of fulfilling legal and contractual obligations
• Obtaining your explicit consent when we need to contact you

v. Maintaining the ATLAS platform in operation

Motive:

• Administrating the ATLAS Application and Platform, including audit, troubleshooting, data analysis, testing, research, statistics;
• Granting the right to participate in the interactive sections of the Site, the Application or the ATLAS Platform, when you choose to do so;
• Notifying and informing you about changes to our services;
• Keeping the website, ATLAS Application and Platform safe and secure;

Type of information:

• Provided Information
• Collected Information

The purpose of processing:

• Contractual obligations
• Our legitimate interest
• Legal Obligations

Legitimate interest:

• Efficiency of fulfilling legal and contractual obligations
• Compliance with current legislation

vi. Facilitate interactions between users

Motive:

• Facilitate interactions between users through our services;
• The possibility of distributing / recommending to your personal contacts the use of ATLAS services.

Type of information:

• Provided Information
• Collected Information
• Information regarding location

The purpose of processing:

• Our legitimate interest

Legitimate interest:

• Developing new products and services and / or improving existing ones;
• Popularizing ATLAS services and products to other categories of users or non-users;
• Efficiency of fulfilling legal and contractual obligations
• Obtaining your explicit consent when we need to contact you

vii. Providing services based on / depending on the location

Motive:

• Deliver the content of the website, the application, the ATLAS Platform as well as video and audio content to the highest quality standards;
• Delivering relevant information and advertising - for example: nearby ATLAS Specialists, services and products that may interest you, near you

Type of information:

• Information regarding location

The purpose of processing:

• Contractual obligations
• Our legitimate interest
• Legal Obligations

Legitimate interest:

• Developing new products and services and / or improving existing ones;
• Efficiency of fulfilling legal and contractual obligations;
• Compliance with current legislation

Please note that we may process your personal data based on two or more legal grounds at the same time, depending on the specific purpose for which we use your data.

You may contact us at [email protected] at any time if you need further details on the specific legal basis that we take into account when processing your personal data, when data falls within one or more legal bases.

5. MARKETING

Since transparency is one of the values that we care about a lot, we will clarify how we use your data for marketing purposes and also how you can opt-out of receiving marketing messages whenever you want. 

We wanted to offer you as many options as possible on the use of certain personal data, especially in terms of marketing and advertising. So, on the My Profile page, we created a special section called "Legal Agreements" where you can see and make decisions about your personal use of your marketing emails, your notifications, etc.

ATLAS offered Marketing

We may use your personal information (Provided Information, Location Information, or Information about or regarding your Sessions and Transactions) to create an image of what we believe you want or need, what products and / or services would be of interest to you. This is the only way we can know which products, services or offers can be relevant to you.

You will receive from us messages and marketing communications only if:

• You have created an ATLAS user account and / or if you use the services listed in the ATLAS platform, and
• You have not opted-out of receiving such marketing notifications

Third party offered Marketing

If we want to employ marketing and advertising services offered by third parties / outside ATLAS INTEGRATED TECHNOLOGIES / the ATLAS INTEGRATED TECHNOLOGIES Group of Companies, we will always obtain your express consent before distributing your personal data.

Opting out of Marketing messages

You can always use the options available in the My Profile> Legal Agreements section to decide not to receive any further Marketing information or messages

6. DATA DISCLOSURE

We will make available, directly or indirectly, explicitly or anonymously, your personal data to other users of the ATLAS platform as well as to certain third-party companies / entities that use this data to provide various services to ATLAS INTEGRATED TECHNOLOGIES, but only to achieve legitimate purpose of the ATLAS platform and within the legal limits.

Personal data is used by third-party companies under conditions of complete security and confidentiality, under strict contractual conditions and in accordance with personal data protection laws.

a. To other users / beneficiaries of the ATLAS platform

The ATLAS Platform places great emphasis on keeping the confidentiality of user data both in their interaction and in their relationship with third parties.

That is why, in the project and design process of the platform, we have taken into consideration and always keep in mind the confidentiality of personal data.

That is why in the interactions between ATLAS users (written messages, video sessions, chat services, etc.) as well as regarding companies that provide employees with access to ATLAS, in special conditions, only relevant personal data with the aim of complying with both the legislation in force and ATLAS principles and values is made available.

In essence, the data users can see about other users they interact with within the ATLAS platform are the "names" and "surnames" each set in the "My Profile" section. Also, when a user purchases a product or service listed in the ATLAS platform, the data in the My Profile> Billing Info section will appear on invoices issued automatically by the ATLAS platform at the time of purchase.

We will then detail, in each case, what data ATLAS users have access to when interacting with other ATLAS users.

i. Customer Data to Specialists

When a Client user interacts with a Specialist user, the Specialist can access the following data:

• The truncated email address / just one part of that email address - When a user creates an ATLAS account, he / she is not required to enter his / her surname and surname within the platform. However, when the user decides to perform certain actions within the platform (use of various services, booking and payment of a meeting, etc.), it becomes mandatory to enter additional data necessary to achieve that purpose. Until the user decides to use such services but still interacts with other users within the platform, his email address, the one he registered with ATLAS, is available to those users in a truncated but not clear manner. Thus, only the first few characters of the email address can be viewed without being fully disclosed. This makes it impossible for that user to be contacted on his email address;
• Client First Name and Surname - can be viewed by the Specialist in the sections Messages, Meetings, Clients, as well as in the case of Sessions and Invoices automatically generated by the ATLAS platform with the purchase of a product or service;
• Billing Details - is the information that a Customer introduces into the My Profile> Billing Information section and which will be found on invoices issued automatically by the ATLAS platform with the purchase of any product or service
• Messages sent by the Customer - The Customer may exchange written messages with a Specialist at any time via the Messages or Chat section. Also, during online meetings, the Customer and the Specialist can use the Chat section to exchange written messages. The responsibility for the content of the transmitted messages is entirely the responsibility of the sender, its mandatory for them to be compliant with the ATLAS Terms and Conditions and with the applicable legislation.
• Clients' Attached Files - Clients can attach files to conversations they have with the Specialist, and can also send such documents to the Specialist during Online Meetings. The responsibility for the content of the transmitted files is entirely the responsibility of the sender, its mandatory for them to be compliant with the ATLAS Terms and Conditions and with the applicable legislation.
• Session Audit - Once a user decides to begin the process of booking a session (online or at the office), attending and / or completing the session, a series of collected data will be accessible to both the Specialist and the Client. Data includes: the date and time of the Customer's certain interactions regarding that meeting but also the details of the device used to participate in the Online Session. Details of the device used are available due to  ATLAS platform's legitimate interest, as they allow the Specialist, but also the Client, to provide support to the other party for participating in the online meeting and using the platform's functionality.
• Shared Notes during Sessions - during video conferencing and at the office meetings, the Specialist and the Client may decide to use the "Shared Notes" functionality, allowing both parties to see each other's notes. 

In the event that, during meetings and other interactions with the Specialist, the Customer decides to submit / send personal information, he / she assumes full responsibility but also the consequences of his / her actions. Furthermore, if the Customer believes that he has shared / transmitted personal data to the Specialist (during the exchange of messages and / or chat, but also during online or at the office meetings), he may address the Specialist directly regarding his / her rights in respect of personal data under the laws in force / applicable.

The ATLAS Platform has no responsibility for the transmission of personal data during message exchange, or Online / At the Office Sessions between the Specialist and Client.

Also, ATLAS INTEGRATED TECHNOLOGIES will ensure that the Specialist will never have:

• Access to the location from where you attend Online Sessions or interact with the ATLAS platform;
• The ability to record / store, totally or partially, audio and / or video content of online sessions through features available in the ATLAS platform.

ii. Customer data to other platform users

The only information that other users of the ATLAS platform, whether logged in or out of the platform, can view in relation to ATLAS Customers are:

• Service Evaluations - At the end of an Online Meeting or At the Office Meeting, the Customer has the ability to evaluate the services provided by the Specialist, but also the video and audio quality (for Online Sessions only). Only the number of stars offered for the evaluation of the services provided by the Specialist are aggregated and displayed as an average within the Profile of the Specialist, information being anonymized (no information or personal data about those who carried out those evaluations are displayed);
• Reviews - At the end of an Online Meeting or At the Office Meeting, the Customer can, besides evaluating the service provided, also provide reviews (commentary and written observations / testimonials) about services. These written comments / observations will be displayed explicitly in the Profile of the Specialist, along with:
  
  • Customer First Name and Surname (if the data in question is not available, the Customer's truncated email address will be displayed);
  • The number of sessions the Client has had with that Specialist;
  • Rating - the number of stars offered by the client for session for which they added the review.

All this information is public and available to any ATLAS user due to the legitimate interest of the platform.

ATLAS INTEGRATED TECHNOLOGIES has the mission to provide users with the highest quality of service, evaluations and reviews stand as highly effective tools through which Customers can effectively inform other platform users about the quality and effectiveness of the service they are consuming. This is the reason why, on the ATLAS platform, all reviews and ratings are real, being provided by Clients only after they have consumed the service in question.

iii. Specialist data to other platform users

ATLAS platform users can access data, both authenticated on the ATLAS platform and also anonymous / not authenticated, from Specialists. Below is the Specialist data that ATLAS users have access to:

• Specialist Profile - All data the Specialist includes in his / her Profile is available to all ATLAS users, whether they are logged in or not. The Specialist can always see his / her public data by visiting My Profile> Personal> Profile URL, which is:
  
  • Specialist name and surname
  • Profile description
  • Reviews received from Clients and personal comments received in response to those reviews;
  • Videos added by the Specialist
  • Details regarding his / her specializations
  • Education
  • Member of various organizations or professional associations;
  • Licenses
  • Documents - files that the Specialist uploaded to certify the information in his Profile;
  • Physical location of the office where he / she can hold meetings offline (at the office);
  • Sessions listed on the platform and all their details - will only show public sessions (those that all users can see, regardless of whether they are logged in or out of the platform) and private sessions (can only be viewed by the authenticated client for whom they have were added).
• Specialist Name and Surname - can be viewed by the Client in the Messages and Meetings sections as well as in invoices automatically generated by the ATLAS platform with the purchase of a product or service;
• Billing Info - is the information the Specialist introduces into the My Profile> Billing Information section and which will be on invoices issued automatically by the ATLAS platform with the purchase of any product or service
• Messages sent by Specialist - the Specialist can exchange written messages with a Customer at any time via the Messages or Chat section. Also, during online meetings, the Specialist and the Client can use the Chat section to exchange written messages. The responsibility for the content of the transmitted messages is entirely the responsibility of the sender, its mandatory for them to be compliant with the ATLAS Terms and Conditions and with the applicable legislation.
• Clients' Attached Files - Clients can attach files to conversations they have with the Specialist, and can also send such documents to the Specialist during Online Meetings. The responsibility for the content of the transmitted files is entirely the responsibility of the sender, its mandatory for them to be compliant with the ATLAS Terms and Conditions and with the applicable legislation.
• Session Audit - Once a user decides to begin the process of booking a session (online or at the office), attending and / or completing the session, a series of collected data will be accessible to both the Specialist and the Client. Data includes: the date and time of the Customer's certain interactions regarding that meeting but also the details of the device used to participate in the Online Session. Details of the device used are available due to  ATLAS platform's legitimate interest, as they allow the Specialist, but also the Client, to provide support to the other party for participating in the online meeting and using the platform's functionality.
• Shared Notes during Sessions - during video conferencing and at the office meetings, the Specialist and the Client may decide to use the "Shared Notes" functionality, allowing both parties to see each other's notes. 
• The address of the Specialist's office - if the Specialist decides to offer his / her Clients the opportunity to hold meetings at the office, he / she may add to the Specialist Profile the exact address where the meetings will take place. The office address will be available both on the profile page of the Specialist and when a client reserves an At the Office Meeting.

If, during meetings and other interactions with the Client, the Specialist decides to transmit personal information, he / she assumes the full responsibility and the consequences of his / her actions. Moreover, if the Specialist believes that he / she has shared / transmitted personal data to the Client (during messaging and / or chat, but also during online or at the office meetings), he can address the Client directly in relation to his / her rights and in respect of personal data under the laws in force (applicable)

The ATLAS Platform has no responsibility for the transmission of personal data during message exchange, or Online / At the Office Sessions between the Specialist and Client.

Also, ATLAS INTEGRATED TECHNOLOGIES will ensure that the Client will never have:

• Access to the location from where you attend Online Sessions or interact with the ATLAS platform;
• The ability to record / store, totally or partially, audio and / or video content of online sessions through features available in the ATLAS platform.

iii. Customer data to their employers

In order to increase the addressability of the listed services and products, ATLAS INTEGRATED TECHNOLOGIES can conclude contracts and partnerships with Companies that decide to offer employees access to ATLAS services under specific and special conditions.

Also, ATLAS INTEGRATED TECHNOLOGIES will promote these services to the business / corporate environment, as Companies can get substantial benefits in terms of reducing presenteeism, reducing employees' stress levels, etc.

This is our legitimate interest and, in such cases, ATLAS INTEGRATED TECHNOLOGIES may transmit to the Company anonymized data regarding access to ATLAS services by their employees. This anonymous data is meant to raise awareness of the problems, and their intensity, which employees face, in order to take internal measures outside the ATLAS platform, in relation to that specific data.

The data transmitted is anonymized and we will never disclose information and personal data that could cause identification of individuals using such services.

b. To third parties

We will transmit personal data to the following third-party entities, personal data processors, in order to provide ATLAS INTEGRATED TECHNOLOGIES with their services:

i. Cloud service providers

In order to keep your personal data safe and secure due to the use of the ATLAS Platform services, the applications and the site, ATLAS INTEGRATED TECHNOLOGIES uses the cloud services of its suppliers.

Service providers do not have direct access to your personal data, which is saved in databases installed in closed operating systems (accessed only by ATLAS INTEGRATED TECHNOLOGIES) hosted only on the hardware of the provider.

ii. Advertising agencies and data analysis service providers

If we decide to hire Advertising Agencies to promote ATLAS products and services, these Agencies and their partners may request personal anonymous data to provide you with personalized information and advertising.

We will never disclose information that could lead to the identification of individuals, but we can provide aggregated and anonymized information about our users.

We can use aggregated and anonymized information to help our partners deliver personalized and specific advertising campaigns relevant to a particular category of our users.

Furthermore, we can offer our partners, in some cases, such aggregated and depersonalized information with the purpose to perform their own advertising campaigns for their target audience.

We also use the information provided by internet search, statistical / analytical data providers to help us improve and optimize the services available on the site, the application and the ATLAS Platform.

iii. Online payment service providers

Users of the ATLAS application and platform can purchase products and services listed on the platform using online payment as a payment method. All online payments are processed by vendors specializing in such services that ATLAS INTEGRATED TECHNOLOGIES has integrated with its application and platform.

Whenever you make a payment for a product or service listed on ATLAS, the card data you enter is sent directly to the payment processor without being saved within our platform. ATLAS does not save or process information about your card and its details.

However, ATLAS sends information to the payment processors about the service or product you have purchased (the unique identifier of the service or product, the name you gave the service or product in question, the date and time the service or product is going to to be delivered / consumed as appropriate) and receives from them the status / state of the transaction initiated by you regarding payment.

iv. Videoconferencing service providers

For Online Sessions available within ATLAS, ATLAS INTEGRATED TECHNOLOGIES uses both a proprietary video conferencing solution embedded within the ATLAS platform, but can use (depending on the system's own load, the availability of its own system, as well as the location used by users to participate in the Online Meeting) one or more external solutions made available by third-party companies as a service.

In the case of online meetings where video conferencing services are provided by third-party companies, the service provider has access to the following collected data: information about the device accessed by the conference, the IP address from which it was accessed, the capabilities of the internet network used (frame rate, packet loss). In addition to this information, the ATLAS platform also conveys data about the meeting in question, but we will never disclose any personal information and data that could lead to the identification of individuals using such services.

Also, the audio and video signals do not pass through any ATLAS INTEGRATED TECHNOLOGIES server or external / third party video contractor provider, communication being made only between the devices / equipment participating within the Online Meeting. Moreover, both the audio and video signals are not saved on any equipment or server, neither ATLAS INTEGRATED TECHNOLOGIES's nor its third-party service provider.

v. Messenger / SMS service providers

ATLAS Platform users can opt for two factor authentication when they are going to start an Online Meeting, with the additional security code being sent via SMS. Also, all users can benefit from SMS notifications when they receive a new message from another user or when the meeting time approaches.

For these SMS services, the ATLAS platform has integrated external service providers to send text messages anywhere in the world.

The data transmitted by ATLAS to this type of vendor are the phone number entered by the user under his ATLAS profile and the actual notification / message.

Thus, we will never disclose personal information and data that could cause identification of individuals using such services.

vi. Navigation service providers

In the case of Offline Sessions, ATLAS users have the possibility to navigate to the address of the Specialist's office. This is achieved by integrating ATLAS with Google Maps, Waze and Uber platforms.

The data transmitted by ATLAS to these external platforms, automatically following the integration of the platforms, is only the address of the physical office introduced by the Specialist within his / her profile.

Thus, we will never disclose personal information and data that could cause identification of individuals using such services.

vii. Ticket Service Providers and Help Center

The ATLAS Platform uses external partners to provide Ticketing and Help Center services (problem / suggestion and Help Center). In case you decide to use these services and want to register as a user, we inform you that ATLAS INTEGRATED TECHNOLOGIES did not integrate any of these platforms into the ATLAS platform in any way.

Thus, any information or personal data you introduce / send / add / include on those platforms is not automatically transmitted to the ATLAS platform. Furthermore, ATLAS platform does not, in any way, transmit any information or personal data to those platforms.

Thus, we will never disclose personal information and data that could cause identification of individuals using such services.

viii. Debt recovery service providers

For any product or service listed or available within the ATLAS platform, ATLAS INTEGRATED TECHNOLOGIES may charge a fee for that transaction when it is purchased by users. In the event that such a fee is charged, a tax document certifying that purchase will automatically be generated and will contain the actual value paid by the user.

Since, within the ATLAS platform, users may have as options other methods of payment, besides online card payments (cash payment at the office, payment with ATLAS Credit, etc.), there are situations when tax documents are automatically issued for ATLAS commissions, the respective amounts are not paid on the platform.

In these cases, debtors of the amounts in question must pay / offset their respective invoices to ATLAS INTEGRATED TECHNOLOGIES. If this does not happen within a reasonable time period, ATLAS INTEGRATED TECHNOLOGIES may decide to call on external suppliers of debt recovery services or even sell those debts to specialized companies.

ATLAS INTEGRATED TECHNOLOGIES will provide all these external service providers with all user personal data that will be filed on both the tax documents in question and other data that will help recover damages.

ix. Manufacturers and suppliers of cards and customization services

If ATLAS deems it appropriate to offer personalized cards to its users, it can call on external suppliers to produce and personalize those cards. In this way, the following data will be sent: Your First Name and Your Name, the date when you created your ATLAS Account, but also your referral code or the unique address of your ATLAS profile (for Specialists).

x. Courier companies

When there is a need to transport certain products (cards, personalized materials, etc.), ATLAS INTEGRATED TECHNOLOGIES can make the decision to call on outside suppliers to deliver them to you. Also, besides the address in question, we will also transfer to the external supplier your First and Last Name and phone number.

c. To other entities, under special conditions

ATLAS INTEGRATED TECHNOLOGIES can provide your personal information and data in the following situations:

• In the event that ATLAS INTEGRATED TECHNOLOGIES or all of its assets are acquired by a third party, in which case personal data we hold about our users will be one of the assets transferred;
• When we are required to disclose personal data to comply with legal obligations and / or requests;
• In order to determine the puting into practice aspect as well as respecting the Legal Agreements and / or any other agreements concluded between you and ATLAS INTEGRATED TECHNOLOGIES, or to investigate potential violations of these Agreements;
• To protect the rights, property and safety of ATLAS INTEGRATED TECHNOLOGIES, the ATLAS platform and listed services, our Clients and users and other people. This could include the exchange of information with other companies and / or organizations to protect against fraud or debt recovery.