Privacy

Privacy Policy

DRAFT FOR ATTORNEY REVIEW — NOT YET EFFECTIVE. This is a working draft to be reviewed and finalized by qualified counsel and conformed to the Company's actual data practices and applicable privacy laws (including, as applicable, state privacy statutes) before publication. Bracketed, highlighted items (e.g., [Date]) require confirmation.
Controller: Ward & Co. Investment Holdings, LLC, dba Atlas Signalis Version: [v0.1 — Draft] Last updated: [Date]

This Privacy Policy explains how Atlas Signalis ("Atlas," "we") collects, uses, and shares information when you use our websites and services (the "Services"). It is incorporated into our Platform Terms of Use.

1. Information We Collect

2. How We Use Information

3. How We Share Information

We do [not] sell personal information. [Confirm and align with state-law definitions of "sale"/"sharing."]

4. Payment Information

Payments are processed by [Stripe]. We do not store full payment card numbers; payment data is handled by the processor under its own privacy terms.

5. Your Choices & Rights

You may opt out of marketing emails via the unsubscribe link. Depending on your location, you may have rights to access, correct, delete, or port your personal information, or to opt out of certain processing. [Insert state-specific rights (e.g., CCPA/CPRA) and how to exercise them, and a verification process.] To make a request, contact us at [privacy@atlassignalis.com].

6. Data Retention & Security

We retain information for as long as needed to provide the Services and for legitimate business or legal purposes, then delete or de-identify it. We use reasonable administrative and technical safeguards, though no system is perfectly secure.

7. Communications by Managers

Managers who receive advisor inquiries must use that information only to respond and in compliance with applicable communications and privacy laws (including, as applicable, CAN-SPAM and TCPA). Atlas is not responsible for managers' independent communications.

8. Children

The Services are for business users and are not directed to children, and we do not knowingly collect information from children.

9. Changes

We may update this Policy and will post the updated version with a new date; material changes will be communicated as required.

10. Contact

Questions or requests: [privacy@atlassignalis.com] · [mailing address].

Not legal advice. This draft must be reviewed and finalized by qualified counsel and conformed to the Company's actual practices and applicable law before publication or use.