Privacy Policy

The controller responsible for personal data processed through this website is Atlasy Equity Partners Ltd., a private company limited by shares registered in the Republic of Cyprus (registration number HE 482465), registered office 1 Nikis, 2350 Nicosia, Cyprus. You can contact us about data protection at contact@atlasy-equity.com or by post to our registered office.

This site describes Atlasy’s white-label software. It is not an on-ramp and does not open exchange accounts. Privacy notices for an operator’s instance are issued by that operator, not by Atlasy.

If you write to the company, we may process:

• Name, organisation, role, and email address
• The content of your message
• Technical connection data created automatically when you visit the site and processed by our hosting provider: IP address, date and time of the request, requested page, referrer and browser user agent

The contact form does not send your entries to our servers or store them. When you click “Open email draft”, your entries are passed to the email application on your own device. Nothing is sent until you send that email yourself. We then receive it in our mailbox, which is hosted by our email provider (see section 5). Providing your data is voluntary. Without a name, email address and message we cannot reply to your enquiry.

We process personal data under the EU General Data Protection Regulation (GDPR) and the Cyprus Law 125(I)/2018 for the following purposes:

• Answering business enquiries about software subscriptions, the product and go-live, and preparing or performing a contract. Where you contact us on your own behalf, the legal basis is Art. 6(1)(b) GDPR (steps prior to entering into a contract, or performance of a contract). Where you contact us on behalf of your employer or another organisation, the legal basis is Art. 6(1)(f) GDPR. Our legitimate interest is in communicating with prospective and existing business customers.
• Operating and securing the website (delivering pages, preventing abuse and investigating security incidents) using technical connection data. The legal basis is Art. 6(1)(f) GDPR, our legitimate interest in a secure and functioning website.
• Complying with legal obligations, such as accounting, tax and company-law record-keeping and responding to lawful requests from authorities. The legal basis is Art. 6(1)(c) GDPR.
• Establishing, exercising or defending legal claims. The legal basis is Art. 6(1)(f) GDPR.

We do not use your data for advertising or profiling and do not send marketing emails without a separate legal basis.

Within Atlasy Equity Partners Ltd., only directors and staff who need the data to handle your enquiry have access to it. We use the following service providers, which process personal data on our behalf as processors under Art. 28 GDPR:

• Fly.io, Inc., United States: website hosting. The application runs on servers in Frankfurt, Germany. Fly.io’s global network may route and process connection data, such as your IP address, at edge locations outside the European Economic Area.
• Hostinger International Ltd, 61 Lordou Vironos Str., 6023 Larnaca, Cyprus: domain registration, DNS and hosting of our email mailbox (including enquiries you send us).

Where necessary, we may also share data with professional advisers (such as lawyers, auditors and accountants), who act as independent controllers bound by professional secrecy, and with courts or public authorities where required by law. We do not sell personal data.

• Enquiries that do not lead to a contract: deleted 24 months after our last contact with you.
• Correspondence and records relating to a contract: kept for the duration of the contract and then for as long as required by Cyprus tax, accounting and company law (generally up to seven years after the end of the relevant tax year), or longer where needed for pending legal claims.
• Technical connection data (server logs): deleted or anonymised within 30 days, unless needed for longer to investigate a specific security incident. In that case it is kept until the incident is resolved.

Our website runs on servers in Frankfurt, Germany. Our hosting provider Fly.io, Inc. is based in the United States, and its network may process connection data outside the European Economic Area (EEA). Fly.io, Inc. is certified under the EU-U.S. Data Privacy Framework, which the European Commission has recognised as providing an adequate level of protection (Art. 45 GDPR). In addition, our data processing agreement with Fly.io incorporates the European Commission’s Standard Contractual Clauses (Art. 46(2)(c) GDPR). Where Hostinger or any sub-processor processes data outside the EEA, the transfer is protected by Standard Contractual Clauses under Hostinger’s data processing agreement. You can request a copy of the relevant safeguards by writing to contact@atlasy-equity.com.

Under the GDPR you have the right to access your personal data (Art. 15), to have it rectified (Art. 16) or erased (Art. 17), to restrict its processing (Art. 18) and to receive it in a portable format (Art. 20).

Right to object (Art. 21 GDPR): where we process your data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you may object at any time on grounds relating to your particular situation. We will then stop the processing unless we can demonstrate compelling legitimate grounds or need the data to establish, exercise or defend legal claims.

To exercise your rights, write to contact@atlasy-equity.com. We will respond within one month, which can be extended where permitted by Art. 12(3) GDPR. We may need to verify your identity.

You also have the right to lodge a complaint with a supervisory authority. In Cyprus this is the Commissioner for Personal Data Protection, Kypranoros 15, 1061 Nicosia (postal address: P.O. Box 23378, 1682 Nicosia), Cyprus, email commissioner@dataprotection.gov.cy, website www.dataprotection.gov.cy. You may also complain in the EU member state where you live or work.

This website does not set cookies and does not store or read any information on your device (no local storage, analytics, tracking pixels, social-media plug-ins or advertising technologies). Fonts are served from our own server, so no request is made to Google or other third parties when you load a page. A cookie banner is therefore not required. If we introduce any cookie or similar technology that is not strictly necessary, we will ask for your prior consent, as required by Cyprus Law 112(I)/2004, and update this policy.

We do not use automated decision-making, including profiling, within the meaning of Art. 22 GDPR.

We are not required to appoint a data protection officer under Art. 37 GDPR, because our core activities do not involve large-scale regular and systematic monitoring of individuals or large-scale processing of special categories of data. Please send data-protection questions to contact@atlasy-equity.com.

We may update this policy when our website or our service providers change. The current version is always available on this page.