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Privacy policy


The website available at the following address: https://www.atoa.io/ (hereinafter referred to as the "Site") is published by the company ATOA, a simplified joint-stock company with a share capital of 30,000 euros, registered with the Lyon Trade and Companies Register under number 914 449 103, whose registered office is located at 14 rue Sylvain Simondan, 69009 LYON 9EME (hereinafter referred to as "ATOA"). In its capacity as the data controller, ATOA attaches great importance to the protection and respect of privacy. This privacy policy aims to inform any person using the Site (hereinafter referred to as "Users" or the "User") about ATOA's practices regarding the conditions for the collection, use, and sharing of the information that Users are required to provide, as well as their rights. The Site complies with French and European standards related to data protection and privacy, including the Law No. 78-17 known as "Information Technology and Liberties" of January 6, 1978 related to information technology, files, and liberties, modified by the Law 2004-801 of August 6, 2004, and the Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016 known as the "GDPR" concerning the protection of individuals concerning the processing of personal data and the free movement of such data. IMPORTANT: NOTE TO USERS, ANY NAVIGATION ON THE SITE AFTER THE PUBLICATION OF THIS PRIVACY POLICY CONSTITUTES ACCEPTANCE OF THIS POLICY WITHOUT RESERVATION. If the User wishes to withdraw their consent regarding the processing of their data, they simply need to request this by email at the following address: [email protected]. Furthermore, in the event that it is required by law and/or under certain circumstances, the User's consent will be obtained, or an option to refuse will be provided before any data transmission.
Controller of Personal Data Collected
The data controller for the personal data collected is ATOA.
Nature of Data Collected
The data collected on the Site in the course of using the Site are those that allow ATOA to directly or indirectly identify Users. This may include the following categories of data concerning Users: personal identification data, images such as name, first name, postal address, email address, phone number, and identity document; data concerning personal life, such as investment; economic and financial data, such as payment methods and payment history; and connection data, such as IP address, visited web pages on the site, and browsing data, including cookies. The mandatory or optional nature of the personal data collected and the potential consequences of not responding are indicated when collected on the associated forms. Users who provide personal data of a third party must confirm that they have obtained the consent of that third party for the Site to process their personal data.
Purpose and Legal Basis for Processing Activities

Purpose of Personal Data Collected The personal data collected on the Site is used solely for the execution of services for the following purposes:


Management of commercial relationships: Validation of User profiles; Processing and management of User subscriptions; Communication with Users; Combating money laundering and the financing of terrorism; Data collection through cookies and other trackers; Proper operation and continuous improvement of the Site and its features: General administration of the Site; Site performance monitoring; General Site security management. Additionally, ATOA may use data to meet its legal and/or regulatory obligations. Legal Basis for Processing Activities The processing activities and collection of personal data are authorized based on the following legal grounds:


Performance of contractual or pre-contractual obligations for managing commercial relationships; - Fulfillment of legal or regulatory obligations for combating money laundering and terrorism financing; - ATOA's legitimate interest in ensuring the best level of operation and quality of the Site for the proper functioning and continuous improvement of the Site; - User consent for the use of cookies and other trackers. Aggregation with Non-Personal Data ATOA reserves the right to publish, disclose, and use aggregated information (information about Users or specific groups or categories of Users combined in a way that individual Users cannot be identified or mentioned) and non-personal information for industry and market analysis, demographic profiling, promotional and advertising purposes, and other business purposes.


Data Collection Timing The data collected by ATOA is freely provided by Users during the creation of an account on the Site or during the subscription process. They may also be collected automatically during the use of the Site, especially when the User browses the Site's pages, registers on the Site, and subscribes to services. These data collected automatically do not reveal the User's identity but relate to the use of the services. This collection is necessary for the maintenance and operation of ATOA's services and for its internal analysis and reports. This information includes information about the use of the services (frequency, traffic data, User's way to access the Site), information about the device used to access the services (device name, country, location, IP address, browser and device features, operating system, language preferences, referrer URL). In any case, the personal data collected: - Will be obtained and processed fairly and lawfully; - Will be collected for specified, explicit, and legitimate purposes, and not further processed in a way incompatible with those purposes; - Will be adequate, relevant, and limited to what is necessary in relation to the purposes for which they are processed; - Will be accurate, complete, and, if necessary, kept up to date; - Will be kept in a form that allows identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; - Will be processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.


Data Recipients Within the limits of their respective attributions and for the purposes mentioned above, the main people liable to have access to User data are primarily ATOA's authorized personnel. Apart from ATOA's authorized personnel, some data may be shared with subcontractors in charge of User relationship management (client representatives, research, etc.). In compliance with the regulations in effect, User consent will be obtained before transmitting their data to third parties for commercial purposes, or for any other purpose.


Data Transfer to a Third Country ATOA does not send or transmit personal data to a recipient situated in a non-member state of the European Union.


Data Retention Period ATOA keeps Users' personal data for the duration of their contractual or commercial relationship. Data are stored for additional periods under the terms set out by law or regulations to meet archiving obligations and to answer to requests made by authorized authorities. As regards connection data, ATOA stores the data for a period of six (6) months. After this period, the data is anonymized.


Security and Confidentiality ATOA commits to keeping personal data safe and confidential and not disclosing them to unauthorized third parties.


User Rights
In accordance with the regulations in effect, Users have the following rights:

The right of access: they can request information about their personal data held by ATOA. The right to rectify: if they believe that their personal data is inaccurate or incomplete, they can request its modification. The right to erasure: they can request the deletion of their personal data when they are no longer needed for the purposes for which they were collected. The right to object: Users can object to their data processing for any reason. The right to restriction of processing: they can request the restriction of their data processing in specific cases. The right to data portability: Users can request a copy of their data in a structured and commonly used format. The right to withdraw consent: they can withdraw consent for processing at any time. The right to define the fate of their data after death: they can choose whether ATOA keeps or deletes their data in case of death. To exercise these rights, Users can contact ATOA at the following address: [email protected]. Users must provide proof of identity, which may be requested by ATOA before the User's request is processed. ATOA will make its best efforts to respond to these requests promptly. Complaint to the Authority If Users consider that ATOA is not complying with its obligations regarding personal data, they can address a complaint to the competent authority. In France, the competent authority is the CNIL. Users can find information on how to file a complaint on the CNIL website: www.cnil.fr.


Conditions for Modifying this Privacy Policy ATOA may change this Privacy Policy to reflect changes in the law, regulations, or business practices. Users will be notified of any significant changes through ATOA's regular communication channels. Nevertheless, the latest version of the Privacy Policy is always accessible on the Site. Users are encouraged to review this Privacy Policy regularly to stay informed of how ATOA is protecting personal data.


COOKIES
Nature of Cookies and Other Trackers
Cookies are small text files that may be stored in a dedicated space on the hard drive of the User's device (e.g. computer, tablet) when consulting an online service using the User's browser software. They are sent by the website server to the User's browser. These cookies may be used to track Users' browsing activity on the Site.
Cookies and other trackers installed by ATOA on the Site serve various purposes, the main of which are:

Cookies for audience measurement; - Cookies for User profile authentication; - Cookies to store User choices. Objectives of Cookies and Other Trackers


Cookies are used to:

Establish statistics and volumes of frequentation and use of the various elements composing the Site (sections and contents visited, routes), allowing ATOA to improve the interest and ergonomics of the Site. Adapt the presentation of the Site to the display preferences of the User's device (language used, display resolution, operating system used, etc.) during their visits to the Site, according to the hardware and software viewing or reading equipment that the device has. Implement security measures to block certain activities. Provide Users with personalized services. Enhance the user experience on the Site. Consent to Cookies and Other Trackers By continuing to browse the Site, the User agrees to the installation of these cookies and other trackers on their device. However, the User can configure their browser to disable cookies.


Duration of Cookies
Cookies have a maximum lifetime of 13 months.

Managing Cookies and Other Trackers The User has several options for managing cookies. Most browsers are configured to accept, control, or potentially disable cookies through the settings. The User's browser can be configured to reject cookies, or accept them on a case-by-case basis, before a cookie is saved. Users can also regularly delete cookies from their device via their browser. For the management of cookies and User choices, the configuration of each browser is different. It is described in the browser's help menu, which will inform the User of how to change their cookie preferences.


User Right to Object
If Users choose to refuse cookies on their device or if they delete cookies that are registered on their device, they may no longer be able to use certain features necessary for browsing certain areas of the Site. This would be the case if Users tried to access content or services that require them to identify themselves. This would also be the case when ATOA or its service providers could not recognize, for technical compatibility purposes, the type of browser used by the User's device, its language and display settings, or the country from which the device appears to be connected to the internet. In such cases, ATOA declines any responsibility for the consequences related to the degraded functioning of the Site and its services resulting from the User's choice to refuse, delete, or block the cookies necessary for the Site to operate. For the management of cookies and User choices, the configuration of each browser is different. It is described in the browser's help menu, which will inform the User of how to change their cookie preferences.Chrome, Internet Explorer, Edge, Safari, Firefox, Opera
However, in case of opposition to the storage of cookies or the uninstallation of a cookie, Users are informed that some services may no longer function properly.

Modification of the Privacy Policy ATOA reserves the right to modify and update this privacy policy at any time, especially to take into account any legal and/or jurisprudential developments and to comply with the requirements of the regulations applicable to the protection of personal data. The version that prevails is the one accessible online on the day of consultation of the Site. Any consultation of the Site after the publication of the modified privacy policy constitutes an unconditional acceptance of the new privacy policy.


Contacts For any inquiries or to learn more about the processing of their personal data, including exercising their rights as indicated above, Users can contact ATOA via the rights exercise form, by email, or postal mail at the following address:


Postal mail: ATOA - 14 rue Sylvain Simondan, 69009 LYON 9EME Email: [email protected]


For any complaints or dissatisfaction regarding the use of their personal data by ATOA, Users can contact ATOA via the rights exercise form, by email, or postal mail at the following address:

Postal mail: ATOA - 14 rue Sylvain Simondan, 69009 LYON 9EME Email: [email protected]


When Users contact ATOA, they will be asked to identify themselves. Updated version on March 17, 2023.



Please note that this is a translation of the key points from the privacy policy. The translation is provided for informational purposes, and the original French version remains the legally binding document.