Privacy Policy

1. INTRODUCTION

1.1 Important information and who we are

Welcome to Atlas Labs Limited’s Privacy and Data Protection Policy (“Privacy Policy”).

At Atlas Labs Limited (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

• Third parties connected to your customers
• Potential or existing candidates for job opportunities at our customers' companies.

1.2 Your Data Controller and Data Protection Officer

Atlas Labs Limited is your Data Controller and responsible for your Personal Data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the DPO using the details set out below:

Name: Samandip Dhesi

Email: sam@joinpopp.com

Postal address: 71-75 Shelton Street Shelton Street, London, WC2H 9JQ, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We Atlas Labs Limited would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will dealwith your data on our behalf (known as “Processors”). The responsibilities below may beassigned to an individual or may be taken to apply to the organisation as a whole. TheData Controller and our Processors have the following responsibilities:

• Ensure that all processing of Personal Data is governed by one of the legal bases
  laid out in the GDPR (see 2.2 below for more information);
• Ensure that all processing of Personal Data is governed by one of the legal bases
  laid out in the GDPR (see 2.2 below for more information);
• Implement appropriate technical and organisational measures to ensure a level of
  security appropriate to the risk associated with the processing of Personal Data;
• Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
• Assist the Controller in the fulfilment of the Controller's obligation to respond to
  requests for exercising the data subject's rights
• Make available to the Controller all information necessary to demonstrate
  compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller
• Maintain a record of all categories of processing activities carried out on behalf of a
  Controller;
• Cooperate, on request, with the supervisory authority in the performance of its
  tasks;
• Designate a data protection officer where required by the GDPR, publish their
  details and communicate them to the supervisory authority;
• Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations and to maintain their expert knowledge;
• Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
• Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2. LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

• Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
• Contact Data: This is data relating to your phone number, addresses, email
  addresses, phone numbers.
• Marketing and Communications Data: This is your preferences in receiving
  marketing information and other information from us.
• Prospective candidate data: This is data provided by a prospective candidate either publicly (for example, in public social media profile information on LinkedIn), or in the context of their willing interest in sharing their personal information, including but not limited to data contained in their CV (resume), contact information, and messages shared with our conversational AI, and collected responsibly by our clients in compliance with local data collection and management regulations.

We also collect, use and share Aggregated Data such as We collect aggregated
demographic and usage data from candidate conversations with recruiters.. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better
understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and
processing of Personal Data. The main avenues we rely on are:

• “ Consent”: Certain situations allow us to collect your Personal Data, such as when
  you tick a box that confirms you are happy to receive email newsletters from us, or
  ‘opt in’ to a service.
• “Contractual Obligations ”: We may require certain information from you in order
  to fulfil our contractual obligations and provide you with the promised service.
• “Legal Compliance ”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
• “ Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3. HOW WE USE YOUR PERSONAL DATA

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.

4. YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 Your legal rights

Under certain circumstances, you have the following rightsunder data protection laws in relationto your personaldata:

• Right to be informed. You have a right to be informed about ourpurposes for processing your personal data, how long we storeit for, and who it will be shared with. We have provided this information to you in this policy.
• Right of access. This enables you to receive a copy of thepersonal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.5 below for more details on how you can make a data subjectaccess request.
• Right to rectification. You have a right to request correction of thepersonal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Right to erasure. You have the right to ask us to delete or removepersonal data where there is no good reason for us continuing toprocess it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are requiredto erase your personal data to comply with local law. Note,however, that we may not always be able to comply with your requestof erasure for specific legal reasons which will be notifiedto you, if applicable, at the time of your request.
• Right to object. You can object to the processing of personal datawe hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absoluteright and it only applies in certain circumstances, for example:

1. Where we are processing your personal data for direct marketing purposes.
2. Where we are relying on a legitimate interest (or those of a third party) and there is somethingabout your particular situation which makes you want to object to processing on this ground asyou feel it impacts on your fundamental rightsand freedoms.
3. In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process yourinformation which overrideyour rights and freedoms.

• Right to restrict processing. You have the right to request the restriction or suppression of their personaldata. Note that this is not an absolute rightand it only applies in certain circumstances:

1. If you want us to establish the data's accuracy.
2. Where our use of the data is unlawfulbut you do not want us to erase it.
3. Where you need us to hold the data even if we no longer requireit as you need it to establish, exercise or defend legal claims.
4. You have objected to our use of your data but we need to verifywhether we have overriding legitimate grounds to use it.

• Right to data portability. You have the right to request the transfer ofyour personal data to you or to a third party. If you make such a request, we will provideto you, or a third party you havechosen, your personal data in a structured, commonly used,machine-readable format. Note that this right only applies to automatedinformation which you initially providedconsent for us to use or where we used the information to perform a contract with you.

If you wish to make a request under any of these rights, please contact us at sam@joinpopp.com.

4.2 Your control over Atlas Labs Limited’suse of your Personal Data

You may delete your account at any time – this will remove your account page from our systems and our relatedsoftware.

We guarantee this will delete all stored data.

You can access information associated with your account by logging into your accountyou created with us.

Your account information will be protectedby a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your passwordappropriately and limiting access to your computeror device and by signing off after you have finished accessingyour account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, Californiaresidents are entitled to ask us for a notice identifying the categories of personal customerinformation which we share with our affiliates and/or third parties formarketing purposes, and providingcontact information for such affiliates and/or third parties. If you are a California resident and would like a copyof this notice, please submit a written request to sam@joinpopp.com.

4.3 How Atlas Labs Limitedprotects customers' PersonalData

We are concerned with keeping your datasecure and protecting it from inappropriate disclosure. We implement a variety ofsecurity measures to ensure the security of your Personal Data on oursystems, including We implement certain security measures to ensurethe security of your Personal Data on our systems, including adopting asecure protocol, encrypting our databases and installing security softwareon every device associated with our company. Our securityinfrastructure is fully managed by an accredited third-party provider, Agency(https://getagency.com/).. Any Personal Datacollected by us isonly accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when weuse subcontractors to store your data, we will not relinquish control of yourPersonal Data or expose it to securityrisks that wouldnot have arisen had the data remainedin our possession. However, unfortunately no transmission of data overthe internet is guaranteed to be completely secure. It maybe possible for third parties not under the controlof Atlas Labs Limited to intercept or access transmissions or private communicationsunlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of anyPersonal Data you transmit to us. Any such transmission is done at your own risk. Ifyou believe that your interaction with us is no longer secure, pleasecontact us.

4.4 Opting out of marketingpromotions

You can ask us to stop sending you marketing messages at any time by usingor clicking unsubscribe links appended to our marketing communications..

Where you opt out of receiving these marketing messages, we will continueto retain otherPersonal Data provided to us as a result of interactions with us notrelated to your marketing preferences.

4.5 How to request your data and the process for obtainingit

You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.

We may need to request specificinformation from you to help us confirm your identity and ensure you have theright to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensurethat Personal Data is not disclosed to any person who has no right to receiveit. We may also contactyou to ask you for further information in relation to your requestto speed up our response.

5. YOUR DATA AND THIRD PARTIES

5.1 Sharing your data with third parties

We may sharenon-Personal Data with thirdparties. We may share your Personal Data with subcontractors or affiliates, subjectto confidentiality obligations to use it only for the purposesfor which we disclose it to them and pursuantto our instructions.

We may also sharePersonal Data with interested parties in the event that Atlas Labs Limited anticipates a change in control or the acquisition of all or part of our businessor assets or with interested partiesin connection with the licensing of our technology.

If Atlas LabsLimited is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entitymay govern the further use of your Personal Data. Inall other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).

We may shareyour Personal Data at any time if required for legal reasonsor in order to enforceour terms or this PrivacyPolicy.

6. HOW LONG WE RETAINYOUR DATA

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your Personal Data for a longer periodthan usual in the eventof a complaint or if we reasonably believe there is a prospect oflitigation in respect to our relationship with you.

7. AGE LIMIT FOR OUR USERS

You must not use Atlas Labs Limited unlessyou are aged 16 or older. If you are under 16 and you access Atlas Labs Limited by lying about yourage, you must immediately stop using Atlas Labs Limited.

This website is not intended for children and we do not knowingly collect data relatingto children.

8. INTERNATIONAL TRANSFEROF DATA

Your information may be stored andprocessed in the US or other countries or jurisdictions outside the US where AtlasLabs Limited has facilities. By using Atlas Labs Limited, you are permitting and consenting to the transferof information, includingPersonal Data, outsideof the US.

9. NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We keep our Privacy Policy under review and will place any updates here.This version is dated 1 August 2023.

By using Atlas Labs Limited, you consentto the collection and use of data by us as set out in this PrivacyPolicy. Continued access or use of Atlas Labs Limited will constituteyour express acceptance of any modifications to this PrivacyPolicy.

10. INTERPRETATION

All uses of the word"including" mean "including but not limited to" and theenumerated examples are not intendedto in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may beused solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored.Unless otherwise required by law, we reserve the right to not respond toemails, even if they relate to a legitimate subject matter for which we have provided an emailaddress. You are more likely to get a reply if your request or questionis polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website,etc.).

Our staff are not authorised to contract on behalf ofAtlas Labs Limited, waive rights or make representations (whether contractual orotherwise). If anything contained in an email from a AtlasLabs Limited address contradicts anything in this policy, our terms orany official public announcement on our website,or is inconsistent with or amounts to a waiverof any Atlas Labs Limited rights, the email content will be read down to grant precedence to the latter.The only exceptionto this is genuine correspondence expressed to be from the Atlas Labs Limited legal department.