Privacy Policy

What Information We Collect

We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources. More detail is provided below.

Information You Provide

Profile Information. When you register and manage your account, we collect your username, email address, and password. For both registered and non-registered users, we may also collect your level of education.

User Content. We collect the content you create or upload to the Platform, such as your written content, comments, and questions, and any files you upload.

Messages. We collect the content of the messages you send and receive on the Platform when you communicate with our Chatbot using the Platform's chat functionality. We do this to support your requests.

Purchase Information. When you make a purchase on or through the Platform, such as when you purchase a course, we collect information about the purchase and payment method.

Surveys, Research, and Promotions Information. We collect information you provide if you choose to participate in a survey, research, promotion, contest, marketing campaign, or event conducted or sponsored by us.

Communication Information. When you contact or otherwise communicate with us, we collect the information you send us, such as feedback or inquiries about your use of the Platform, your data subject requests or queries, or information about possible violations of our Terms of Service (our "Terms"), our Honor Code, or policies.

Automatically Collected Information

Technical Information. We automatically collect certain device and network connection information when you access the Platform, including your IP address, unique device identifiers, mobile carrier and device information, and certain of your system settings (such as your system language and region). We also collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign each account a User ID to identify your activity across devices and give you a seamless and secure log-in experience.

Usage information. We automatically collect information and related metadata about how you engage with the Platform, including information about the content you view and your search history, and the duration, frequency, and approximate location of your use.

Cookies. We use cookies and similar tracking technologies to operate and provide the Platform. For example, we use cookies to remember your language and other preferences, for security purposes, and for analytics purposes. We will obtain your consent to our use of cookies where required by law.

Information From Other Sources

Linked Services Information. If you choose to sign-up or log-in to the Platform using a third-party service, that service will share your information with us, such as your username, email, and profile picture.

Payment and Transaction Fulfillment Provider Information. We receive information about you from payment and transaction fulfillment providers, such as payment confirmation details.

Information From Others. We may receive information about you from others, for example, where you are included or mentioned in a complaint, appeal, request or feedback submitted by a user or third party.

How We Use Your Information

We use your information to operate, provide, develop, and improve the Platform, including for the following purposes:

• To provide and administer the Platform to both registered and unregistered users, such as by enabling you to browse the website; create and manage your account; and create and consume content.
• To communicate with you and provide user support, including notifying you about changes to the Platform or to our Terms or policies; and responding to and otherwise processing your queries, requests, complaints, and feedback.
• To review, improve, and develop the Platform, including by monitoring usage across your devices; analyzing how people are using the Platform; and training and improving the Platform's technology, such as our machine learning models and algorithms. We do not use any data obtained through Google Workspace APIs to develop, improve, or train our generalized machine learning models.
• To facilitate your purchases, including sharing your information with payment and transaction fulfillment providers in order to process your orders.
• To promote the Platform through marketing communications, contests, or promotions.
• To maintain and enhance the Platform's safety, security, and stability by identifying and addressing technical or security issues and detecting inappropriate or illegal activity.
• To enforce our Terms, Honor Code, and other policies that apply to you, such as by reviewing User Content and other information to protect the safety and well-being of our community.
• To comply with our legal obligations, including where necessary to assist in law enforcement and government or regulatory investigations.

We may also use your information for any other purposes disclosed to you at the time we collect your information, with your consent, or as otherwise permitted by applicable laws.

How We Share Your Information

We share your personal information with the recipients or in the scenarios listed below, for the purposes described in this Privacy Policy.

Service Providers. We engage service providers that help us provide, support, and develop the Platform. They provide services such as cloud hosting, content delivery, customer and technical support, content moderation, marketing, analytics, and online payment. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services.

Third Party Platforms and Partners. We may share certain Information You Provide and Automatically Collected Information with third parties whose platform or services are integrated with the Platform. For example, if you sign-up or log-in to the Platform using your third party account details, we will share certain Technical Information to facilitate account sign-up or log-in.

Payment and Transaction Fulfillment Providers. When you make a purchase on or through the Platform we share Purchase Information related to the transaction with payment and transaction fulfillment providers and other service providers. We may also share certain Technical Information about your device or connection with these parties to help ensure the security of the transaction.

Our Corporate Group. Certain entities within our corporate group ("Corporate Group") receive and process personal information to support the provision of the Platform. These entities process Information You Provide, Automatically Collected Information, and Information From Other Sources for us, as necessary to provide certain functions, such as storage, content delivery, security, research and development, analytics, online payments, customer and technical support, and content moderation.

Other Users and the Public. Certain User Content may be visible to other users as well as third parties, such as search engines.

Corporate Transactions. Your information may be disclosed to third parties in the event that we discuss or negotiate the sale or sell any business or assets, in which case we may disclose your information to the prospective buyer of such business or assets; or in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business including asset sales, consolidations, or in the unlikely event of bankruptcy.

Legal Obligations and Rights. We may access, preserve, and share the information described in "What Information We Collect" with any competent law enforcement body, regulatory or government agency, court, public authority, copyright holder, or other third party if we have good faith belief that it is necessary to:

• Comply with applicable laws, regulations, codes of practice, legal process, or government guidance or requests, as consistent with internationally recognised standards;
• Protect the rights, property, and safety of the Platform, our users, copyright holders, and others, as required or permitted by law;
• Exercise or defend any legal claims, including to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries;
• Investigate potential violations of and enforce our Terms, Honor Code, or any other applicable terms, policies, or standards; or
• Detect, investigate, prevent, or otherwise address copyright infringement and other misleading or illegal activities.

With Your Consent. We may share your information for other purposes pursuant to your consent or at your direction.

Your Rights and Choices

You may have rights and choices when it comes to your information.

Depending on where you live, your rights under applicable laws may include the right to access, delete, transfer, or correct your personal information; to be informed of the ways in which we process your personal information; to object to certain processing activities; to file complaints with authorities; and more. Some of your rights apply generally, while others will only apply in certain circumstances. And, depending on the scenario, these rights may be subject to some limitations by law.

For detailed information about the specific rights and choices available to you in your region, please see the "Supplemental Terms - Jurisdiction Specific" section below.

If you have questions or would like to exercise any of your personal information rights, please contact us at support@askatlasapp.com, or see the "Supplemental Terms - Jurisdiction Specific" section below, in case a local contact is available in your region. Before we can respond to your request, you may be asked to verify your identity or account details, or provide additional information so that we can properly understand your request.

Controls. If you have registered for an account, you may also directly access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities. In addition, your device and/or browser settings may also allow you to manage our collection and use of certain types of personal information, including cookies. Because each browser and device is different, please consult the instructions provided by your browser or device settings (as applicable). You can also refuse or disable cookies through the choices available at https://www.networkadvertising.org/managing/opt_out.asp and https://www.aboutads.info/choices. Please note that if you choose to refuse, disable, or delete cookies, some of the Platform's features and functionalities may no longer be available to you.

If you are not satisfied with our response to any of your rights requests, we encourage you to contact us at support@askatlasapp.com.

Data Security

Security of your information is important to us. We maintain technical, administrative, and physical security measures designed to protect your information from unauthorized access, theft, disclosure, modification, or loss, and to provide a level of security appropriate to the processing risk. We regularly review our security measures to consider newly available technology and methods.

To help protect your personal information, please do not disclose personal or sensitive information when you engage with the Platform's Chatbot.

The Platform may, from time to time, contain links to policies, functionality, or content maintained by third parties we do not control. We are not responsible for, and make no representations regarding, such third party policies and practices.

Data Retention

We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Platform, and enhancing its safety, security, and stability), and for the exercise or defense of legal claims. The retention periods will be different depending on the type of information and the purposes for which we use the information.

International Data Transfers

Your personal information may be stored in a secure server located outside of your country of residence. We may also transfer your personal information internationally for one or more of the purposes described in this Privacy Policy. Any international transfer of, or access to, your personal information is conducted according to the requirements of applicable data protection laws.

Minimum Age and Children Under 13

Atlas is not directed at, and may not be used by, children under the age of 13. In certain countries or regions, this minimum age may be higher due to local regulatory requirements. Please review the "Supplemental Terms - Jurisdiction Specific" section relevant to your country or region for more information. If you believe that we have collected personal information from or about an individual under the minimum age, please contact us at support@askatlasapp.com.

Privacy Policy Updates

We may amend or update this Privacy Policy from time to time. We will notify you of material changes by updating the "Last Updated" date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing other notice required or permitted by applicable law. We recommend that you regularly review the Privacy Policy to stay informed of our privacy practices.

Contact Us

Questions, comments, and requests regarding this Privacy Policy should be addressed to:

Supplemental Terms - Jurisdiction Specific

If you access or use the Platform in any of the jurisdictions listed below, the supplemental terms relevant to that jurisdiction will apply. In the event of a conflict between those jurisdiction-specific terms and the main body of this Privacy Policy, the relevant jurisdiction's supplemental terms will supersede and control.

United States

Your Rights and Choices

Depending on where you live, you may be entitled to certain rights with respect to your personal information, as described below:

• Right to Know. You may have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.
• Access and Data Portability. Subject to certain exceptions, you may have the right to request a copy of the personal information that we collected about you during the 12 months before your request.
• Deletion. You may have the right to request that we delete information that we collected from or about you, subject to certain exceptions.
• Correct Inaccurate Information. You may have the right to request that we correct inaccuracies in the personal information we maintain about you.

You may exercise these rights by submitting your request via the following methods:

• Email: support@askatlasapp.com
• Mail: Capra AI, Inc., 8 The Green STE A, Dover, DE 19901

We will respond to your request consistent with applicable law and subject to proper verification. To verify your request, we may require you to send it from the email address associated with your account, or to provide information necessary to verify your identity.

You may appeal any decision we have made about your request by replying to the communication you receive from us communicating your decision. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on this Platform may change or no longer be available to you.

Authorized Agent. You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

No Sale or Sharing. The Platform does not sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising where restricted by applicable law.

Profiling. We do not engage in profiling which results in legal or similarly significant effects, as defined under applicable laws.

Sensitive Personal Information. Although some of the information we collect may be considered sensitive personal information under applicable state privacy laws (such as information from users under the age of 18), we only process such information in order to provide the Platform and within other exemptions under applicable laws.

Other California Rights

You can request that we disclose the categories of personal information we have shared with third parties for the third parties' direct marketing purposes. Requests may be submitted via the contact methods listed above.

Your browser may offer you a "Do Not Track" option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our products do not support Do Not Track requests at this time.

Canada

Information Relating to Children and Teens. If you are a resident of the Province of Quebec, you are only permitted to use the Platform if you are at least 14 years old.

Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information in our custody and control, and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out in the "Contact Us" section. We may require certain personal information for the purpose of verifying the identity of the individual making the request.

Internal Policies and Access Controls. We implement and maintain internal policies and technical measures to restrict access to your personal information within our organization. Access to personal information within our organization is limited to employees who need the information to perform their job functions.

Transfer Outside Your Jurisdiction. We and our service providers may access, store and otherwise process personal information outside of Canada. We and our service providers may disclose your personal information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate.

European Economic Area ("EEA"), Switzerland, and UK

Legal Bases for Processing. We use your personal data only as permitted by law. Our legal bases for processing include: performance of our contract with you, our legitimate interests, compliance with legal obligations, and your consent.

International data transfers. When we transfer your personal data outside of the EEA, the UK, or Switzerland, we ensure it benefits from an adequate level of data protection by relying on adequacy decisions or standard contractual clauses approved by the European Commission.

Your Rights:

• The right to request confirmation of whether we process your personal data and access to a copy of the personal data retained by us.
• The right to request to update or request deletion of your personal data or restrict processing of your personal data.
• Where processing is based on your consent or contract and carried out by automated means, the right to receive the personal data in a structured, commonly used and machine-readable format or to have it transmitted directly to another company.
• The right to withdraw your consent at any time where processing is based on consent.
• The right not to be subject to automatic individual decisions, including profiling, which produces legal effects on you.
• The right to object to processing on the basis of our legitimate interest.
• The right to request restriction of processing in certain circumstances.
• The right to opt-out of marketing communications at any time.
• The right to complain to a supervisory authority about our collection and use of your personal data.

To exercise any of your rights, contact us at: support@askatlasapp.com

Brazil

Exercise of Data Protection Rights. Brazilian law provides certain rights to individuals with regard to their personal data under the Brazilian General Data Protection Law ("LGPD"). You have the following rights:

• Confirmation of whether your personal data are being processed;
• Access to your personal data;
• Correction of incomplete, inaccurate or outdated personal data;
• Anonymization, blocking or erasure of personal data;
• Portability of personal data to a third party;
• Objection to processing of personal data;
• Access to information about public and private entities with which we share personal data;
• Access to information about the possibility of refusing to provide your personal data and the respective consequences;
• Withdrawal of your consent;
• Request of a review of decisions made solely based on automated processing of personal data.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Brazilian Data Protection Authority ("ANPD").

International Transfers of Data. International data transfers are necessary for us to provide our services. We will always rely on one of the international data transfer mechanisms under applicable data protection laws.

Argentina

Your Rights and Choices. According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information ("AAIP"), you have the following rights with respect to your personal data: access, rectification and deletion regarding data protection. You can exercise your rights by sending your request to support@askatlasapp.com free of charge.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the AAIP.

Mexico

Your Rights. You have the following rights with respect to your personal data: access, rectification, cancellation, consent withdrawal, and limitation of use and disclosure of your data. You may exercise your rights by sending your request to support@askatlasapp.com.

Information Relating to Minors. If you are under 18 years of age, you may exercise your rights through a parent or guardian.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the data protection authority.

Australia

Certain entities in our corporate group, located outside of Australia, are given limited remote access to your information so that they can provide certain functions, as described in the section on "How We Share Your Information".

South Korea

Data retention. We retain information for as long as necessary to provide the Platform and for the other purposes set out in this Privacy Policy. We will continue to store your personal data for statutorily-prescribed periods where applicable.

Destruction of Personal Data. We destroy personal data whose purposes of collection have been achieved, or whose periods of use have expired. We destroy your personal data in a manner that renders it unrestorable.

Your Rights. You have the right to access personal data we hold about you, to rectify any personal data held about you that is inaccurate, to request the deletion of personal data held about you, and the right to request the suspension of the processing of your personal data. You can exercise your rights by contacting us at support@askatlasapp.com.

Information Relating to Children. The Platform is not directed at children under the age of 14.

Indonesia

Age and Parental and Guardian Consent. By accessing and/or using our Services, you represent that you are at least 18 years of age or married or not under guardianship. If you are below 18 years old and you are not married, or under guardianship, you must obtain approval from your parent(s) or legal guardian(s).

Your Choices. Upon your request, we will display, publish, transmit, disseminate, and/or open the access to your personal data to third parties. You may withdraw such consent. You may also request that we disclose to you the history of personal data that we have collected; and/or erase and dispose of your personal data. To exercise any of your rights, contact us at: support@askatlasapp.com.

Notification. In the event of any breach affecting your personal data, we will notify you and provide you with information regarding such breach.

Data Retention. We retain your information for as long as it is necessary to provide you with the Platform. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations.

Philippines

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Vietnam

Age and Parental and Guardian Consent. By accessing and/or using the Platform, you represent that you are at least 16 years of age or not under guardianship. If you are below 16 years old or under guardianship, you must obtain approval from your parent(s) or legal guardian(s).

Methods of Processing Your Personal Data. We may process your personal data by manual or automated methods.

Your Rights and Choices. Subject to certain exceptions, you have statutory rights under applicable laws including: Right to know; Right to consent and withdraw consent; Right to access; Right to delete data; Right to restrict data processing; Right to be provided with data; Right to object data processing; Right to complain, denounce or initiate lawsuits; Right to claim for damages; and Right to self-protection. You may exercise these rights by contacting us through the details in the "Contact Us" section.

Egypt

Age and Parental and Guardian Consent. You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13, and that you have read and acknowledged this Privacy Policy and Terms and agree to the use by such user of the Platform, including registration for an account where applicable.

Israel

Age and Parental and Guardian Consent. You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged this Privacy Policy and Terms and agree to the use by such user of the Platform, including registration for an account where applicable.

South Africa

Age and Parental and Guardian Consent. You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged this Privacy Policy and the Platform's Terms and agree to the use by such user of the Platform and registration for an account, where applicable.

Türkiye

Legal bases for processing your personal data. We rely on the following legal bases while processing your personal data in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data: processing is explicitly laid down or dictated by laws; processing is necessary for the conclusion or fulfillment of the contract between us; processing is mandatory for us to comply with our legal obligations; relevant data is made available to the public by yourself; processing is mandatory for the establishment, exercise or protection of a right; processing is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms; your explicit consent.

Your rights. According to Article 11 of the Data Protection Law, you have rights including: the right to learn whether we process your personal data; the right to request information with regard to such processing; the right to learn the purposes of the processing; the right to know the third parties to whom we transfer your personal data; the right to request correction of incomplete or inaccurate personal data; the right to request deletion or destruction of your personal data; the right to request notification to third parties of corrections or deletions; the right to object to negative results from automated processing; and the right to claim indemnification for damages from illegal processing.

If you would like to exercise your rights, please contact us at support@askatlasapp.com. Requests will be resolved within thirty days at the latest free of charge.

United Arab Emirates

How we share your personal data. By using the Platform in the United Arab Emirates ("UAE") you agree to the terms of this Privacy Policy and consent to our sharing of your personal data in line with the main text of this Privacy Policy.

Governing law and dispute resolution. By using the Platform in the UAE, this Privacy Policy will be governed by and interpreted in accordance with the laws of the UAE.