This Privacy Notice describes how Atlas Warehouse Lending Company, L.P. (together with its subsidiaries and affiliates “AWLC”, “us”, “we” or “our”) gathers and uses personal information about you in relation to our services, when you visit our website (“Website”) and when communicate with us; how we protect and share this information; and the rights you may have in relation to this information. If you interact with ATLAS SP Partners LP or one of its subsidiaries or affiliates, (collectively, “ATLAS”), such interactions are governed by ATLAS' Privacy Policy, available here.
If you are a California Resident (as defined below), please review the below section Additional Information for California Residents for additional disclosures and Notice at Collection and Use of Personal Information for a description of your rights under the California Consumer Privacy Act (with any implementing regulations, as amended by the California Privacy Rights Act (“CPRA”), and as may be amended from time to time, “CCPA”).
In the event that you have any questions or concerns about this Privacy Notice, if you object to our uses of your personal information, or if you wish to exercise your rights under applicable law, please contact us at atlas-sp.privacy@atlas-sp.com.
In general, we may collect information when you directly provide it to us and automatically when you interact with us online. When we use the term “personal information”, we mean any information that can help us directly or indirectly identify you and as otherwise defined under applicable law.
We collect certain information when you provide it to us, such as when you request access to certain materials or otherwise interact with us, we may collect the following categories of personal information:
We or our service providers may collect certain information automatically from your use of the Website or other online interactions. Please note that we also facilitate access to a data site (“Data Site”) which is operated by one of our service providers and subject to their respective privacy policy.
Generally, our Website uses cookies for various purposes, including to distinguish you from other users of our website and collect certain information about your interactions with our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. We generally use the following types of cookies:
We may also use third-party web analytics services on the website, including Google Analytics and Adobe. We use Google Analytics to help us understand how people are using our website. To find out more about how Google Analytics collects and processes data, please click here. Google Analytics has its own cookies that it uses to track and aggregate this information. You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available here. As described above, we share personal information with analytics providers on the basis that it is necessary to meet our legitimate interests in efficiently managing our business and for developing future business. For more information on how you can control cookies and other tracking technologies, please see Your Choices and Rights below. If you communicate with our employees and other staff members via email, telephone, or other electronic channels, our information technology systems record details of those communications, sometimes including their content, for compliance and record-keeping purposes.
We may collect personal information about you from other sources such as our service providers or other vendors that assist with our business. Additionally, some of our third-party partners may ask you to provide personal information on their websites and may share such personal information with us, as governed by their respective privacy policies.
How we use your personal information may vary depending on how you interact with us. Generally, we use information we collect about you primarily to provide services to you in accordance with any contract with you, communicate with you, including providing information on our Data Site, and manage and improve our services for you and our other investors, as permitted by applicable laws.
We may collect, use or process your personal information for the following business or commercial purposes, and, whether required by applicable law, the following lawful bases:
We may share your information in the manner and for the purposes described below:
In addition, we may disclose information about you: (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government entities; and (iii) when we believe disclosure is necessary or appropriate to prevent harm or financial loss, or in connection with an investigation of suspected or actual espionage, cybersecurity or security events or other fraudulent or illegal activity. We may also share information about you to the extent reasonably necessary to proceed with the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets.
The above-described disclosures are provided on the basis that they are either necessary to comply with our legal obligations or they are necessary to meet our legitimate interests in managing our business efficiently and for developing future business. Additionally, we reserve the right to share with third-parties, information that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.
We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
You may update your contact information and/or modify your communication preferences by sending us an e-mail at awlc.investorinquiry@atlas-sp.com.
The Website is intended for use by those over 18, and minors under the age of 13 may not use the Website. We do not knowingly solicit or collect personal information on the Website from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personally identifiable information to us through the Website, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).
Please note that some web browsers may transmit “do not track” (“DNT”) signals. We currently do not respond to DNT settings in your web browser.
This Website may contain links to websites operated by third-parties, and your personal information may be collected by those third-parties when you use their websites. Should you choose to visit these third-party sites, you should review their privacy policies to ensure you understand and are comfortable with their practices concerning your information. We do not accept, and do disclaim, any responsibility for the privacy policies and information collection, use, and sharing practices of any third-party website (whether or not such site is linked on or to the Website). These links are provided to you for convenience purposes only, and you access them at your own risk.
If you no longer wish to receive marketing materials from us, you can let us know by contacting us at awlc.investorinquiry@atlas-sp.com or using other unsubscribe features that we provide in our marketing communications.
Subject to local law, you may have certain additional rights regarding your personal information. These may include the following rights to: (i) access your personal information; (ii) rectify the information we hold about you; (iii) erase your personal information; (iv) restrict our use of your personal information; (v) object to the processing of your personal information in certain circumstances, including where we process personal information for direct marketing purposes or where we have processed such data on the basis of our legitimate interests; (vi) withdraw your consent to the processing of your personal information (where applicable); (vii) receive your personal information in a usable electronic format and transmit it to a third-party (also known as the right of data portability); and (viii) lodge a complaint with your local data protection authority, and withdraw any consent you have given to uses of your personal information.
If you would like to discuss or exercise the rights you may have, contact us at atlas-sp.privacy@atlas-sp.com call us toll-free at 833-381-5803. We will review your request and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. We will process your request within the time provided by applicable law.
You can also control our use of certain non-necessary cookies in various ways, including:
Please note that if you turn cookies off, you may not have access to many features that may improve your browsing, like the features mentioned above, and some of our services may not function properly.
If you are a California Resident, please review Additional Information for California Residents below for a description of your California-specific rights regarding your personal information and how to exercise those rights.
Our activities and the jurisdictions in which we are established are such that we process information collected via the Website in and subject to the laws of the United States and other countries, which may not provide the same level of protection for your information as your home country. The information may be available to the United States government or its agencies under a lawful order made in the United States. In addition, we may transfer your information outside the United States to our affiliates, business partners, and service providers located in other countries.
In some cases, your personal information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for personal information under European Union or other applicable laws. However, we will seek to ensure that a similar degree of protection is afforded to your personal information by ensuring that, where possible, we have put in place appropriate safeguards (such as standard contractual clauses approved by the European Commission) in accordance with applicable legal requirements, or otherwise transfer personal information in accordance with applicable laws, such as, where the transfer is necessary for the performance of a contract between you and us or between us and a third party in your interest, where the transfer is necessary to establish, exercise or defend legal claims, or where the transfer is made for important reasons of public interest. For more information on the appropriate safeguards in place or to obtain a copy, please contact us at atlas-sp.privacy@atlas-sp.com.
We retain your personal information for as long as we have a relationship with you and for a period after our relationship with you has ended.
When deciding how long to keep your personal information after our relationship with you has ended, we take into account how long we need to retain the information to fulfill the purposes described above and to comply with our legal obligations, including obligations to financial services regulators. We may also retain personal information to investigate or defend against potential legal claims in accordance with the limitation periods of jurisdictions where legal action may be brought.
The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) regarding “personal information.” If you are a California Resident, please review the following information about your potential rights to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law. Terms used herein have the meaning ascribed to them in the CCPA.
Notice at Collection and Use of Personal Information
Depending on how you interact with us, we may collect the categories of personal information listed above in the above section, Types of Information We Collect and How We Collect It.
We may collect and use personal information from you for the purposes described above in How We Use the Information We Collect.
We do not “sell” your personal information under the CCPA, meaning we do not rent, release, disclose, transfer, make available, or otherwise communicate personal information to another business or third party for monetary or other valuable consideration. We also do not “share” your personal information, as defined under the CCPA to mean sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.
We retain your personal information as described above in the section How Long Is Information Retained?
For more information about our privacy practices, please review our entire Privacy Notice.
Our Collection, Use, and Disclosure of Personal Information and Sensitive Personal Information
In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information from the categories of sources listed above in Types of Information We Collect and How We Collect It. We may collect all or a few of these categories of personal information for the business or commercial purposes identified in How We Use the Information We Collect.
We do not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell or share the personal information of California Residents under 16 years old. In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information (described in more detail in Types of Information We Collect and How We Collect It) to the following categories of third parties, as describe in the below chart:
| Category of Third Parties | Categories of Personal Information | Business or Commercial Purpose for Disclosure |
|---|---|---|
| Our affiliates | Identifiers; Commercial information; Internet or Electronic Network Activity Information; Audio (e.g., voicemail), electronic, visual or similar information; Inferences | Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); Internal research for technological development and demonstration; Activities to verify, maintain, or improve the quality of our services; Business development and marketing initiatives. |
| Professional services organizations, such as auditors and law firms | Identifiers; Commercial information; Internet or Electronic Network Activity Information; Audio (e.g., voicemail), electronic, visual or similar information; Inferences | Performing services; Auditing related to interactions with you and concurrent transactions; Short-term transient use; Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging and repainting errors impairing functionality (such as website); Internal research for technological development and demonstration; and Activities to verify, maintain, or improve the quality of our services. |
In addition, we may disclose and in the preceding 12 months, may have disclosed for all of the categories of personal information identified in The Types of Information We Collect and How We Collect It above to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose the categories of personal information identified in Types of Information We Collect and How We Collect It for the business or commercial purposes identified above in How We Use the Information We Collect. Additionally, we may disclose your personal information to third parties upon your request, at your direction, or with your consent.
We may also disclose your personal information or otherwise make it available to our service providers such as our IT and/or CRM providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.
We do not currently collect “sensitive personal information” (as defined under the CCPA) from our website visitors.
If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected, and the purposes for which the categories of personal information shall be used; (ii) not be discriminated against because you exercise any of your rights under the CCPA; (iii) request that we delete any personal information about you that we collected or maintained, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not); (v) opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not); (vi) limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit); (vii) correct inaccurate personal information (“Request to Correct”); and (viii) request that we disclose to you the personal information we have collected, used, and disclosed about you during the past 12 months (“Request to Know”).
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold or disclosed pursuant to the GLBA. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
You may submit a Request to Know, Request to Correct or Request to Delete (“Consumer Rights Request”), as described above, through the following toll-free telephone number 833-381-5803 or email us at atlas-sp.privacy@atlas-sp.com.
When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
If you would like to use an authorized agent to submit a request, we may request proof that that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
We may change this Privacy Notice from time to time. Should we do so, we will post the changes to this page. We suggest that you periodically consult this Privacy Notice to review any changes. Your continued use of the Website after the effective date of any modification to the Privacy Notice will be deemed to be your agreement to the changed terms.
This Privacy Notice is available in alternative formats upon request. If you have any questions regarding this policy or our privacy or data protection practices, or to request this Privacy Notice in an alternative format, please feel free to contact us at atlas-sp.privacy@atlas-sp.com.