By accessing and using our Services, you signify acceptance to the terms of this Privacy Policy. Where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your personal information as described further below. We may provide additional "just-in-time" disclosures or information about the data processing practices of specific Services. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your data.
If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue access or use of our Services.

We may modify this Privacy Policy from time to time which will be indicated by changing the date at the top of this page. If we make any material changes, we will notify you by email (sent to the email address specified in your account), by means of a notice on our Services prior to the change becoming effective, or as otherwise required by law.

Where You Reside	Services Provided	Your Operating Entity	Contact Address
Anywhere but the United States and Singapore	Digital Currency services Credit and Lending services Margin Trading services	Attlas Pte. Ltd.	63 Ngo Si Lien street, Dong Da District, Hanoi, Vietnam

Attlas determines the means and purposes of processing your personal information in relation to the Services provided to you (typically referred to as a “data controller”).
You may be asked to provide personal information anytime you are in contact with Attlas . They may also combine it with other information to provide and improve our products, services, and content (additional details below).
If you have any questions about your Attlas Account, your personal information, or this Privacy Policy, please submit your request via our Support Centre.

Personal information is typically data that identifies an individual or relates to an identifiable individual. This includes information you provide to us, information which is collected about you automatically, and information we obtain from third parties. The definition of personal information depends on the applicable law based on your physical location. Only the definition that applies to your physical location will apply to you under this Privacy Policy.

To establish an account and access our Services, we'll ask you to provide us with some important information about yourself. This information is either required by law (e.g. to verify your identity), necessary to provide the requested services (e.g. you will need to provide your bank account number if you'd like to link that account to Attlas ), or is relevant for certain specified purposes, described in greater detail below. As we add new features and Services, you may be asked to provide additional information.
Please note that we may not be able to serve you as effectively or offer you our Services if you choose not to share certain information with us. Any information you provide to us that is not required is voluntary.

To the extent permitted under the applicable law, we may collect certain types of information automatically, such as whenever you interact with the Sites or use the Services. This information helps us address customer support issues, improve the performance of our Sites and applications, provide you with a streamlined and personalized experience, and protect your account from fraud by detecting unauthorized access. Information collected automatically includes:

• Online Identifiers: Geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.
• Usage Data: Authentication data, security questions, click-stream data, public social networking posts, and other data collected via cookies and similar technologies.

For example, we may automatically receive and record the following information on our server logs

• How you came to and use the Services;
• Device type and unique device identification numbers;
• Device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
• How your device interacts with our Sites and Services, including pages accessed and links clicked;
• Broad geographic location (e.g. country or city-level location); and
• Other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

We may also use identifiers to recognize you when you access our Sites via an external link, such as a link appearing on a third party site.

From time to time, we may obtain information about you from third party sources as required or permitted by applicable law. These sources may include

• Public Databases, Credit Bureaus & ID Verification Partners: We obtain information about you from public databases and ID verification partners for purposes of verifying your identity in accordance with applicable law. ID verification partners like World-Check use a combination of government records and publicly available information about you to verify your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data. We obtain such information to comply with our legal obligations, such as anti-money laundering laws. In some cases, we may process additional data about you to assess risk and ensure our Services are not used fraudulently or for other illicit activities.
• Blockchain Data: We may analyze public blockchain data to ensure parties utilizing our Services are not engaged in illegal or prohibited activity under our Terms, and to analyze transaction trends for research and development purposes.
• Joint Marketing Partners & Resellers: For example, unless prohibited by applicable law, joint marketing partners or resellers may share information about you with us so that we can better understand which of our Services may be of interest to you.
• Advertising Networks & Analytics Providers: We work with these providers to provide us with de-identified information about how you found our Sites and how you interact with the Sites and Services. This information may be collected prior to account creation.

Anonymization is a data processing technique that modifies personal information so that it cannot be associated with a specific individual. Except for this section, none of the other provisions of this Privacy Policy applies to anonymized or aggregated customer data (i.e. information about our customers that we combine together so that it no longer identifies or references an individual customer).
Attlas may use anonymized or aggregate customer data for any business purpose, including to better understand customer needs and behaviors, improve our products and services, conduct business intelligence and marketing, and detect security threats. We may perform our own analytics on anonymized data or enable analytics provided by third parties.
Types of data we may anonymize include, transaction data, click-stream data, performance metrics, and fraud indicators.

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We generally use personal information to create, develop, operate, deliver, and improve our Services, content and advertising; and for loss prevention and anti-fraud purposes.
We may use this information in the following ways:

Direct Marketing: Direct marketing includes any communications to you that are only based on advertising or promoting our products and services. We will only contact you by electronic means (email or SMS) based on our legitimate interests, as permitted by applicable law, or your consent. To the extent we can rely on legitimate interest under the applicable law, we will only send you information about our Services that are similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, we will contact you by electronic means for marketing purposes only if you have consented to such communication. If you do not want us to send you marketing communications, please go to your account settings to opt-out or submit a request via our website. You may raise such objection with regard to initial or further processing for purposes of direct marketing, at any time and free of charge. Direct marketing includes any communications to you that are only based on advertising or promoting our products and services.
Third Party Marketing: We will obtain your express consent before we share your personal information with any third parties for marketing purposes.

We take care to allow your personal information to be accessed only by those who require access to perform their tasks and duties, and to share only with third parties who have a legitimate purpose for accessing it. ATTLAS will never sell or rent your personal information to third parties without your explicit consent. We will only share your information in the following circumstances:

• With third party identity verification services in order to prevent fraud. This allows ATTLAS to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your personal information that can be used in connection with the provision of identity verification and fraud prevention services. With financial institutions with which we partner to process payments you have authorized.
• With service providers under contract who help with parts of our business operations. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else. Examples of the types of service providers we may share personal information with (other than those mentioned above) include:
  • Network infrastructure
  • Cloud storage
  • Payment processing
  • Transaction monitoring
  • Security
  • Document repository services
  • Customer support
  • Internet (e.g. ISPs)
  • Data analytics
  • Information Technology
  • Công nghệ thông tin
  • Marketing
• Với các công ty hoặc tổ chức khác mà chúng tôi dự định hợp nhất hoặc được mua lại. Bạn sẽ nhận được thông báo trước về bất cứ thay đổi nào trong các chính sách hiện hành.
• Với các công ty hoặc pháp nhân khác mua tài sản Attlas theo một giao dịch bán được tòa án chấp thuận hoặc nơi chúng tôi được yêu cầu chia sẻ thông tin của bạn theo luật mất khả năng thanh khoản ở bất kỳ khu vực pháp lý hiện hành nào.
• Với các cố vấn chuyên nghiệp của chúng tôi, những người cung cấp các dịch vụ ngân hàng, pháp lý, tuân thủ, bảo hiểm, kế toán hoặc các dịch vụ tư vấn khác để hoàn thành kiểm toán tài chính, kỹ thuật, tuân thủ và pháp lý của bên thứ ba đối với hoạt động của chúng tôi hoặc tuân thủ các nghĩa vụ pháp lý của chúng tôi.
• Với cơ quan thực thi pháp luật, các quan chức hoặc các bên thứ ba khác khi chúng tôi buộc phải làm như vậy theo trát đòi hầu tòa, lệnh tòa hoặc thủ tục pháp lý tương tự hoặc khi chúng tôi tin rằng việc tiết lộ thông tin cá nhân là cần thiết để ngăn ngừa tổn hại về thể chất hoặc tài mất mát, để báo cáo hoạt động bất hợp pháp bị nghi ngờ hoặc để điều tra vi phạm Thỏa thuận người dùng của chúng tôi hoặc bất kỳ chính sách hiện hành nào khác.

If you establish a ATTLAS Account indirectly on a third party website or via a third party application, any information that you enter on that website or application (and not directly on a ATTLAS website) will be shared with the owner of the third party website or application and your information will be subject to their privacy policies.

If you authorize one or more third-party applications to access your ATTLAS Services, then information you have provided to ATTLAS may be shared with those third parties. A connection you authorize or enable between your ATTLAS account and a non-ATTLAS account, payment instrument, or platform is considered an “account connection.” Unless you provide further permissions, Attlas will not authorize these third parties to use this information for any purpose other than to facilitate your transactions using ATTLAS Services. Please note that third parties you interact with may have their own privacy policies, and ATTLAS is not responsible for their operations or their use of data they collect. Information collected by third parties, which may include such things as contact details, financial information, or location data, is governed by their privacy practices and Attlas is not responsible for unauthorized third-party conduct. We encourage you to learn about the privacy practices of those third parties.
Examples of account connections include:

• Merchants: If you use your ATTLAS account to conduct a transaction with a third party merchant, the merchant may provide data about you and your transaction to us.
• Your Financial Services Providers: For example, if you send us funds from your bank account, your bank will provide us with identifying information in addition to information about your account in order to complete the transaction.

Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party's privacy practices. Please review the privacy notice of any third-party that will gain access to your personal information. Attlas is not responsible for such third party conduct.

We understand how important your privacy is, which is why ATTLAS maintains (and contractually requires third parties it shares your information with to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.
We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.
For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. However, we cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur. Please recognize that you play a vital role in protecting your own personal information. When registering with our Services, it is important to choose a password of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.
Furthermore, we cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us using the contact information provided in this Privacy Policy.

CWe store your personal information securely throughout the life of your ATTLAS Account. We will only retain your personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting obligations or to resolve disputes. While retention requirements vary by jurisdiction, information about our typical retention periods for different aspects of your personal information are described below.

• Personal information collected to comply with our legal obligations under financial or anti-money laundering laws may be retained after account closure for as long as required under such laws.
• Contact Information such as your name, email address and telephone number for marketing purposes is retained on an ongoing basis until you unsubscribe. Thereafter we will add your details to our suppression list to ensure we do not inadvertently market to you.
• Content that you post on our website such as support desk comments, photographs, videos, blog posts, and other content may be kept after you close your account for audit and crime prevention purposes (e.g. to prevent a known fraudulent actor from opening a new account).
• Recording of our telephone calls with you may be kept for a period of up to six years.
• Information collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from expiry of the cookie.

We do not knowingly request to collect personal information from any person under the age of 18. If a user submitting personal information is suspected of being younger than 18 years of age, ATTLAS will require the user to close his or her account and will not allow the user to continue using our Services. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.
If you have a complaint about our privacy practices and our collection, use or disclosure of personal information please submit your request via our website.
Attlas Pte. Ltd.. is responsible for the processing of personal information it receives and subsequently transfers to a third party acting as an agent on its behalf. Before we share your information with any third party, Attlas Pte. Ltd.. will enter into a written agreement that the third party provides at least the same level of protection for the personal information as required under applicable data protection laws.

TDepending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, ATTLAS has absolute discretion in providing you with those rights.
Your rights to personal information are not absolute. Depending upon the applicable law, access may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; (d) where the request is frivolous or vexatious, or for other reasons.

• Access and portability. You may request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to a potential fee associated with gathering the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. In certain circumstances, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another data controller.
• Rectification of incomplete or inaccurate personal information. You may request us to rectify or update any of your personal information held by ATTLAS that is inaccurate. You may do this at any time by logging in to your account and clicking the Profile or My Account tab.
• Erasure. You may request to erase your personal information, subject to applicable law. If you close your ATTLAS Account, we will mark your account in our database as "Closed," but will keep certain account information, including your request to erase, in our database for a period of time as described above. This is necessary to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account, and to comply with Attlas 's legal obligations. However, if you close your account, your personal information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.
• Withdraw consent. To the extent the processing of your personal information is based on your consent, you may withdraw your consent at any time. Your withdrawal will not affect the lawfulness of Attlas 's processing based on consent before your withdrawal.
• Restriction of processing. In some jurisdictions, applicable law may give you the right to restrict or object to us processing your personal information under certain circumstances. We may continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.
• Automated individual decision-making, including profiling. ATTLAS relies on automated tools to help determine whether a transaction or a customer account presents a fraud or legal risk. In some jurisdictions, you have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

You can make privacy rights requests relating to your personal information by going to your Privacy Rights Dashboard or, if you cannot access the Dashboard, by contacting us via our website. Our Privacy Rights Dashboard also allows you to set your communication preferences and make individual rights requests relating to your personal information. We strongly encourage you to make any individual rights requests through the Privacy Rights Dashboard because it ensures that you have been authenticated already (based on the KYC information you have provided to open your account and by providing the necessary login credentials and multi-factor authentication to access the account). Otherwise, when we receive an individual rights request via other intake methods, we may take steps to verify your identity before complying with the request to protect your privacy and security.

If you believe that we have infringed your rights, we encourage you to first submit a request via our website so that we can try to resolve the issue or dispute informally. If that does not resolve your issue, you may contact the ATTLAS D via the given phone number.

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, please contact us on our Fanpage or by writing to us at the address of your head office (provided above).