Privacy Policy

§ 01

Introduction.

This Privacy Policy describes how SAR SOLUTIONS, LLC ("ATLAS", "we", "us", or "our") collects, uses, discloses, and protects personal information in connection with the ATLAS platform at atlas-stocks.com, including our websites, dashboards, simulations, reports, emails, and APIs (together, the "Services").

By creating an account or using the Services, you confirm that you have read this policy. If you do not agree with it, do not use the Services.

§ 02

Who we are.

The entity responsible for your personal information (the "controller" under EEA/UK law, and the "business" under California law) is:

ATLAS is the commercial name of the platform through which we provide the Services.

§ 03

Who this policy covers.

The Services are operated from the United States and this policy is written under U.S. law. We also offer the Services to users in Mexico, the European Economic Area, and the United Kingdom.

If you are in one of those regions, the annexes at the end of this policy give you additional rights. Where an annex conflicts with the main body of this policy, the annex controls for users in that region.

The Services are not directed at anyone under 18. We do not knowingly collect personal information from children. If you believe a minor has given us personal information, contact us and we will delete it.

§ 04

Personal information we collect.

We collect the following categories of personal information. The California statutory category is noted in brackets.

Account data

Name, email address, country, language, time zone, date of birth (for age eligibility), and a hashed password or a Google sign-in identifier. [Identifiers]

Billing data

Plan, subscription and trial status, credit balance, Stripe customer and subscription IDs, invoices, and payment history. Card numbers are collected and stored by Stripe, not by us. [Commercial information; financial information]

Investment data

Tickers, positions, quantities, cost basis, allocations, watchlists, notes, simulations, saved portfolios, and alert settings that you enter. [Commercial information]

Usage data

IP address, browser and device type, pages viewed, features used, simulations run, session and login timestamps, error logs. [Internet or network activity]

Usage analytics in the ATLAS platform

When you use ATLAS while signed in — the platform for individual investors and the challenges and classes on ATLAS Universities — we keep a first-party record of how the platform is used, linked to your account: which screens you open and for how long, which buttons, tabs and controls you use, which companies, ETFs and portfolios you look at, and the simulations, searches and portfolio actions you run. We do not record what you type into text fields, and never your password. We use it to see which features are used and which are not, to improve the platform, to give support, and to prepare usage statistics; in ATLAS Universities the university or professor may also receive them per participant, as described in § 07. ATLAS does not use it to grade you, to advertise to you or for automated decisions about you, and it is never sold; in ATLAS Universities, your university or professor may use your participation summary in their own assessment. Records at account level are visible to SAR SOLUTIONS, LLC staff and, in ATLAS Universities, to the people described in § 07. We keep them for up to 12 months and then delete them or keep only anonymous totals. In the EEA and the UK the legal basis is our legitimate interest in measuring and improving the product (Art. 6(1)(f) GDPR); you can object at any time by writing to info@atlas-stocks.com and we will stop recording your account. This record does not use cookies or store anything on your device. [Internet or network activity]

ATLAS Universities activity

When you take part in a challenge or class on ATLAS Universities: your team and role, the trades you propose and the reasoning you write for them, your votes, the orders your team executes, your notes, watchlist and portfolio, your team’s reports and presentations, your progress in the learning material, and the times you were active. [Commercial information; internet or network activity; education information]

Team chat

The messages you write in your team’s chat on ATLAS Universities, with their date and time, and which messages each member has read. [Identifiers; internet or network activity]

Communications

Emails and support messages you send us, email preferences, and whether you opened or clicked our emails. [Identifiers; internet activity]

Approximate location

Country or region inferred from your IP address, used for language, tax, and regulatory purposes. We do not collect precise GPS location. [Geolocation data]

We do not intentionally collect sensitive personal information such as government ID numbers, health data, biometric data, precise geolocation, or racial, religious, or political information. Please do not enter it into notes fields.

§ 05

Where it comes from.

• Directly from you — when you register, subscribe, build a portfolio, run a simulation, or contact us.
• Automatically — through server logs, cookies, and similar technologies as you use the Services.
• From service providers — for example, Stripe tells us whether a payment succeeded, and Google tells us your email address if you sign in with Google.
• From public and licensed market data sources — used to generate analysis. These are not sources of personal information about you.

§ 06

Why we use it.

We use personal information for these business purposes:

• To create and maintain your account and authenticate you.
• To operate the Services — run simulations, build and track portfolios, generate reports and dashboards.
• To process payments, subscriptions, trials, and credit balances through Stripe.
• To send transactional messages (verification, receipts, password resets, trial and billing notices) and, if you opt in, product or marketing emails.
• To provide support and respond to your requests.
• To monitor, debug, secure, and improve the Services, including detecting fraud and abuse.
• To produce aggregated, de-identified statistics about how the Services are used.
• To comply with legal, tax, accounting, and regulatory obligations, and to establish or defend legal claims.

We do not use your personal information for automated decision-making that produces legal or similarly significant effects about you.

§ 07

Who we share it with.

We disclose personal information to service providers who process it on our behalf, under contract, and only for the purposes we specify. Our main providers are:

Stripe

Payments, subscriptions, invoicing, and tax. Stripe is the processor of record for card data.

Vercel

Hosting and delivery of the ATLAS web application.

Hetzner

Hosting of the ATLAS backend and database, on servers in Germany (European Union).

Resend

Delivery of transactional and product emails.

Google

Sign-in with Google, where you choose to use it.

AI providers

Model providers, including Anthropic, used to generate written analysis. Prompts sent to these providers are not used to train their models.

Market data vendors

Providers of price, fundamentals, and news data. We send them tickers, not personal information about you.

We may also disclose personal information: (a) when required by law, subpoena, court order, or a lawful request from a public authority; (b) to enforce our Terms or protect the rights, safety, or property of ATLAS, our users, or the public; and (c) to a buyer or successor in a merger, acquisition, financing, or sale of assets, subject to this policy.

ATLAS Universities: who can see what, and what ATLAS can do

In a challenge or class on ATLAS Universities, your information is visible to these people, and only to them:

• Your teammates see your first name and initials, the trades you propose and the reasoning you write, your votes, your team’s orders, portfolio, chat, notes and reports, and when you were last active.
• Other participants in the same challenge see team names, team members’ first names and initials, and team results in the ranking. They do not see your chat, your votes or your reasoning.
• Your professor, in a class run on ATLAS Universities, sees the activity, submissions, participation and grades of the students in that class. In an ATLAS challenge run with a university, the university and its professors may receive team results, team reports, aggregated statistics and each participant’s participation summary (activity, proposals, votes and contribution to the team), and may use them in their own assessment.
• ATLAS staff (SAR SOLUTIONS, LLC), to run the challenge or class, give support, keep it fair, measure participation and improve the platform.

ATLAS administrators can:

• See each participant’s platform activity: which screens they opened and for how long, the buttons and controls they used, the companies and ETFs they looked at, their searches and simulations, a timeline of that activity, their active days and the time they were last active.
• Read every team’s chat and write in it. Messages from ATLAS appear in the chat signed by ATLAS; ATLAS can also send members an email about a new message.
• See every team’s proposals, reasoning, votes, orders, positions, notes, reports and presentations.
• Open the platform as a specific participant sees it (“view as”), to check that it works correctly. This access is read-only: ATLAS cannot propose, vote, write or change anything in your name. It lasts at most two hours, it is not visible to other participants, and every use is recorded with who opened it and when.
• Manage challenges and classes: create and edit them, invite participants, create teams, move a participant to another team, name a team captain, reset a team, close enrollment, give a professor demo access, and delete a participant’s account.
• Send participants emails about their challenge: orders executed or rejected, proposals waiting for votes, new chat messages, deadlines and reminders.

ATLAS does not use this information to advertise to you, does not sell it, and does not use it for automated decisions about you. Participation information may be shared with the university and its professors as described above.

§ 08

We do not sell or share your data.

We do not sell personal information for money. If you accept “Ads” cookies, we share browser identifiers and browsing data with Meta and LinkedIn for advertising, which California law may treat as “sharing.” You can opt out anytime at Your Privacy Choices (atlas-stocks.com/cookies) or by turning on Global Privacy Control in your browser. We do not sell or share the personal information of anyone under 16.

Disclosures to the service providers listed above are made for business purposes, not for sale.

§ 09

International transfers.

We are based in the United States. Our backend and database are hosted in Germany (European Union), and our web hosting and other service providers are located primarily in the United States and the European Union. If you use the Services from Mexico, the EEA, or the UK, your personal information will be transferred to and processed in the United States.

For transfers of personal data out of the EEA or the UK, we rely on the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable), together with supplementary technical measures such as encryption in transit and at rest. You can request a copy of the relevant transfer mechanism by emailing us.

§ 10

How long we keep it.

We keep personal information only as long as we need it for the purposes described above.

• Account, portfolio, and simulation data — for as long as your account is open, and up to 90 days after you delete it, to allow for recovery and to complete deletion across backups.
• Billing and tax records — for at least seven (7) years, as required by U.S. tax and accounting rules.
• Server and security logs — typically up to 12 months.
• ATLAS platform usage analytics (individual investors and ATLAS Universities) — up to 12 months.
• ATLAS Universities activity and team chats — for the duration of the challenge or class and up to 12 months after it ends; then deleted or kept only as anonymous totals. Certificates and final rankings may be kept longer.
• Support correspondence — up to 3 years after the matter is closed.
• Aggregated, de-identified statistics — indefinitely, since they no longer identify you.

§ 11

Security.

We use technical and organizational measures appropriate to the risk, including HTTPS/TLS in transit, encryption at rest, hashed passwords, role-based access controls, least-privilege access to production systems, and logging and monitoring.

No system is perfectly secure. We cannot guarantee absolute security, and you are responsible for keeping your password confidential. If we become aware of a breach affecting your personal information, we will notify you and the relevant authorities as required by applicable law.

§ 12

Cookies and similar technologies.

Strictly necessary

Session and authentication cookies that keep you logged in and protect against fraud. These cannot be turned off without breaking the Services.

Preferences

Local storage entries that remember your language and light/dark theme.

Analytics

First-party measurement of feature usage, so we can see what works. Used only with your consent where consent is legally required.

Advertising

Meta Pixel and LinkedIn Insight Tag, to measure our ads on those networks. They load only if you accept “Ads” in the cookie banner or at atlas-stocks.com/cookies, never on ATLAS Universities pages, and you can withdraw at any time there.

Where consent is required (EEA, UK), we ask for it before setting non-essential cookies, and you can withdraw it at any time. You can also block or delete cookies through your browser settings, though this may break parts of the Services. We do not currently respond to browser Do Not Track signals; we do honor Global Privacy Control (GPC) signals as an opt-out of sale/sharing where applicable.

§ 13

United States — your privacy rights.

If you live in California, Colorado, Connecticut, Virginia, Texas, or another U.S. state with a comprehensive privacy law, you have the following rights, subject to that law:

• Know and access — what personal information we have collected about you, where it came from, why we collected it, and who we disclosed it to.
• Delete — request deletion of your personal information, subject to exceptions such as records we must keep for tax or legal reasons.
• Correct — ask us to fix inaccurate personal information.
• Portability — receive a copy of your data in a portable, machine-readable format.
• Opt out of sale, sharing, and targeted advertising — we do not sell or share your data, so there is nothing to opt out of, but the right stands.
• Limit the use of sensitive personal information — we do not collect sensitive personal information for these purposes.
• No retaliation — we will not deny you service, charge you a different price, or give you a lower quality of service for exercising these rights.

To exercise any of these rights, email info@atlas-stocks.com from the address on your account, or use the account deletion option in Settings. We will verify your identity by confirming control of your registered email, and we will respond within 45 days (extendable by another 45 days where permitted). You may use an authorized agent; we may ask for proof of authorization.

If we deny your request, you may appeal by replying to our decision. California residents may also complain to the California Privacy Protection Agency or the California Attorney General.

§ 14

Annex A — Mexico.

This annex is the privacy notice ("aviso de privacidad") required by the Federal Law on Protection of Personal Data Held by Private Parties (LFPDPPP) for users in Mexico.

Data controller

SAR SOLUTIONS, LLC, 1111b S Governors Ave, Suite 55731, Dover, DE 19904, United States. Privacy contact: info@atlas-stocks.com.

Data collected

The categories listed in section 04 of this policy: identification, contact, billing, investment, and usage data.

Primary purposes

Providing the Services, managing your account and subscription, processing payments, and providing support. These purposes are necessary for our relationship with you.

Secondary purposes

Product and marketing emails, and user surveys. You may refuse these without affecting your access to the Services.

Transfers

Your data is transferred to and processed in the United States and the European Union by the service providers listed in section 07. These transfers do not require your consent under Article 37 of the LFPDPPP, as they are necessary to perform our contract with you.

You have ARCO rights: Access, Rectification, Cancellation (deletion), and Opposition to processing. You may also revoke your consent and limit the use or disclosure of your data. To exercise these rights, email info@atlas-stocks.com with your name, the account email, a description of the right you are exercising, and proof of identity. We will respond within 20 business days and, if the request is granted, act within 15 business days.

To refuse secondary purposes, reply to any of our marketing emails, adjust your email preferences in Settings, or write to us. If you believe your rights have been infringed, you may file a complaint with the INAI (inai.org.mx).

§ 15

Annex B — European Economic Area (GDPR).

If you are in the EEA, SAR SOLUTIONS, LLC is the controller of your personal data and we process it on the following legal bases (Article 6 GDPR):

Contract — Art. 6(1)(b)

Creating your account, running simulations, building and tracking portfolios, processing your subscription, and providing support. Without this data we cannot provide the Services.

Legal obligation — Art. 6(1)(c)

Keeping tax, accounting, and billing records.

Legitimate interests — Art. 6(1)(f)

Securing the platform, preventing fraud and abuse, debugging, measuring and improving the product, and defending legal claims. We balance these against your rights and you may object at any time.

Consent — Art. 6(1)(a)

Non-essential cookies and marketing emails. You can withdraw consent at any time, without affecting processing carried out before withdrawal.

You have the right to access your data; to have it rectified; to have it erased; to restrict or object to processing (including profiling based on legitimate interests); to data portability; and to withdraw consent. You are not subject to decisions based solely on automated processing that produce legal or similarly significant effects.

To exercise any of these rights, email info@atlas-stocks.com. We will respond within one month, extendable by two further months for complex requests. You also have the right to lodge a complaint with your local supervisory authority — in Spain, the Agencia Española de Protección de Datos (aepd.es).

§ 16

Annex C — United Kingdom.

If you are in the UK, Annex B applies to you in the same way, read as referring to the UK GDPR and the Data Protection Act 2018 instead of the EU GDPR.

Transfers of your personal data to the United States are made under the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. You have the right to complain to the Information Commissioner's Office (ico.org.uk).

§ 17

Changes to this policy.

We may update this policy to reflect changes in the Services, the law, or our providers. The version published on this page is the current one, and the effective date is shown at the top.

If we make a material change, we will notify you by email or through the platform before it takes effect. Continuing to use the Services after that means you accept the updated policy.

§ 18

Contact.

For any privacy question, request, or complaint, write to us. We read every message.