Privacy Policy for Atlas Search LLC

Effective Date: January 1, 2020

Last Updated: July 1, 2024

1. Introduction

Welcome to Atlas Search LLC (“we,” “our,” or “us”). We are committed to protecting your privacy and ensuring that your personal information is handled in a safe and responsible manner. This Privacy Policy outlines how we collect, use, disclose, and safeguard your information when you visit or use our websites or mobile applications (each a “Site” and collectively “Sites”), contact our customer service team, engage with us on social media, communicate with us on behalf of a vendor or client, purchase our products or services, or otherwise interact with us.

2. Scope

This Privacy Policy does not apply to personal information processed in connection with your employment with Atlas Search LLC or appointment as a consultant to fulfill roles for Atlas Search LLC’s clients or companies that we represent. Our Workforce Privacy Policy applies to that personal information.

By using the website or any of our products or services, you understand and agree that we will collect, use, and disclose personal information as described in this Privacy Policy. Please read it carefully. If you have any questions, please contact us as provided below.

3. Categories of Personal Information We Collect

We collect the following categories and types of personal information with your consent or as otherwise required or permitted by law:

• Contact Information: Full name, email address, current and prior address, telephone number, and business contact information.
• Identifiers: Internet protocol address, signature, username and password, and social media user names.
• Protected Classifications: Date of birth, gender, age, nationality, racial or ethnic origin, religion, marital status, citizenship status, military or veteran status, and disability information.
• Financial Information: Tax identification number, financial or bank account information, tax-related information, wire instructions, payment card number, payment card expiration date and CVV code, card or account security details, and billing address.
• Commercial Information: Records of products or services purchased, obtained, or considered.
• Internet or Electronic Usage Data: Data related to network and website interaction history, IP address, website cookie information, interaction with advertisements, and browsing time.
• Audio/Visual Data: Audio, electronic, photographic, visual, or similar data including videos, photographs, or audio recordings.
• Geolocation Data: General region or area from which you access our Sites.
• Professional or Employment Information: Job title, office location, business contact details, and employer name when you contact us on behalf of a third-party company. If you apply to work for us, either as an employee or as a consultant, we collect job application details such as your resume, previous work history, reference information, and professional memberships and certifications.
• Non-Public Education Information: Education history, degrees, transcripts, and certifications if you apply to work for us, either as an employee or a consultant.
• Sensitive Personal Information: Social security number, driver’s license number, passport number, state identification card number, and health information.
• Inferences: Information from the categories of personal information described above to create a profile about you, to reflect your preferences, character, behavior, and attitude.

4. Sources of Personal Information

We collect information in a variety of ways:

• Directly from you: Contact information, identifiers, financial information, commercial information, and professional or employment information that you provide directly to us.
• When you visit our locations: Contact information and audio/visual data when you visit our offices or facilities.
• Automatically: Identifiers, geolocation data, and internet or electronic usage data using tools like browser cookies when you access our Sites.
• From third parties: Contact information, identifiers, financial information, commercial information, and professional or employment information from third parties including our vendors, clients, recruiters, and service providers.

5. Use of Personal Information

We use your personal information for the following purposes:

• Transactional Purposes: Contact information, identifiers, financial information, professional or employment information, and commercial information to provide you or our clients with products and services that we offer, communicate with you, provide you with customer assistance, and administer contracts with our vendors, clients, and service providers.
• Account Creation: Contact information and identifiers to create your account if you download our application and choose to create an account.
• Recruiting and Hiring: Contact information, identifiers, audio/visual data, professional or employment information, non-public education information, financial information, medical information, sensitive personal information, and inferences to make informed decisions on recruitment and assess your suitability for the role, communicate with you about your application, respond to your inquiries, schedule interviews, and reimburse you for any agreed expenses incurred in the application process. Also, to provide qualifications and credentialing information to our clients so that they may assess your suitability for a role, onboard you, and credential you into their systems.
• Background Checks: Identifiers, personal characteristics or traits, professional or employment information, non-public education information, and sensitive information to enable the completion of the background check form where permitted by law and with your consent.
• Business Operations: Contact information, identifiers, personal characteristics or traits, financial information, audio/visual data, professional or employment information, education information, sensitive information, and inferences for our day-to-day business operations including billing and collections, procurement, tax-related activities, maintaining records, planning, budgeting, calibration, headcount, database administration, diversity metrics, surveys, evaluations, reports, compliance, regulatory, audit, investigative purposes and other ethics and compliance reporting tools, and to support our business operations.
• Analytical Purposes: Identifiers, internet or electronic usage data, geolocation data, commercial information, and inferences to analyze preferences, trends, and statistics.
• Combination of Information: Combine contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information obtained from different sources with publicly available information, including to create inferences about you.
• Marketing and Promotional Purposes: Contact information, identifiers, financial information, professional or employment information, internet or electronic usage data, geolocation data, and inferences to improve our marketing efforts, conduct market research, prospect for new clients or consultants, client relationship management, client engagement, administering promotions, and to provide you with information about us, including personalized marketing communications.
• Maintenance and Improvement of our Sites and Systems: Identifiers, geolocation data, internet or electronic usage data to improve our Sites and systems, provide and maintain functionality on our Sites and systems, and help us diagnose technical and service problems and administer our Sites and systems.
• Develop and Improve Our Products and Services: Contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to help us develop new products and services and to improve and analyze our existing products and service offerings.
• Security and Fraud Prevention: Contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to protect our Sites, premises, assets, systems, products, services and intellectual property, protect us, our affiliated companies, our employees, our carriers and others from fraud, theft, and other misconduct, conduct vendor due diligence, and detect and prevent fraud, theft, and misconduct including by verifying the identity of those we are conducting business with.
• Legal: Contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information to comply with our legal obligations, including reporting requirements, and defend ourselves in legal proceedings, and protect our company and our property, employees, and others through legal proceedings.
• Other Purposes: Contact information, identifiers, financial information, commercial information, personal characteristics or traits, geolocation data, internet or electronic usage data, audio/visual data, inferences, and professional or employment information for other reasons we may describe to you.

6. How We Share Personal Information

We share personal information in the following circumstances or as otherwise described in this Privacy Policy:

• Service Providers: With vendors and service providers who support the operation of our services, website, and our business and who need access to such information to carry out their work for us.
• Affiliates: With and among our parent company, subsidiaries, affiliates, or their successors or assigns.
• Clients: With our clients and companies we represent so that they may assess your suitability for employment or work as a consultant, onboard you into their systems, and credential you.
• Marketing/Analytics/Advertising Partners: With third party marketing, analytics or advertising partners, including social media platforms and networks, for commercial purposes such as sending you marketing emails. Please note that SMS consent or phone numbers for the purpose of SMS are not shared.
• Professional Advisors: With professional advisors, such as lawyers, bankers, tax consultants, auditors, and insurers, where necessary in the course of the professional services that they render to us.
• Government Entities: With regulatory and government entities including government, administrative, law enforcement and regulatory agencies; tax authorities; and other public agencies or authorities if we think we should in order to comply with any applicable law, regulation, legal process or other legal obligation.
• Corporate Transaction Recipients: With potential investors, purchasers, merger partners, and their advisors in the event we sell or transfer, or are considering selling or transferring, all or a portion of our business or assets.
• With Your Consent or At Your Direction: With third parties whenever you consent to or direct such sharing, please note SMS is excluded from being shared.
• We do not buy, sell, or otherwise share SMS opt-in or phone numbers for the purpose of sending SMS with third-parties.
  
• Other Reasons: For other reasons we may describe to you.

7. How Long We Keep Personal Information

We will retain and use your information for as long as we need it to provide you services or products, or as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We will not share SMS opt-in or phone numbers for the purpose of sending SMS with third-parties.

Where we process personal information for marketing purposes, we process the data until you ask us to stop and for a short period after this to allow us to implement your requests. We also keep a record of the fact that you have asked us not to send you direct marketing so that we can respect your request in the future. We use the following criteria to determine retention periods:

• How long the information is needed to provide our services and operate our business.
• Whether there are contractual or legal obligations that exist that require us to retain the information for a period of time.
• Whether any law, statute, or regulation allows for a specific retention period.
• Whether an individual has agreed to a longer retention period.
• Whether the data is considered to be sensitive data.
• What the expectation for retention was at the time the data was provided to us.

8. Cookies, Analytics, and Other Tracking Technology

Certain online tools exist to help us serve and recognize you when you visit our website. When you access the website, we (including companies we work with) may place small data files on your computer or other device. These data files may be web beacons, cookies, clear gifs, pixel tags, e-tags, flash cookies, log files, or other local storage provided by your browser or associated applications. These tracking technologies, which are often referred to collectively as cookies, allow us to understand how users navigate to and around our website, view different pages, access content and request Services. We may use them, for example, to keep track of your preferences and profile information and collect general usage and volume statistical information.

• Cross-Contextual Behavioral Advertising and Targeted Advertising: We allow third-parties to provide analytics and advertising services and serve advertisements on our behalf across the Internet and in mobile applications. Our advertising partners may collect information about your activities on our Sites on your current device and combine it with information about your activities on other websites, mobile apps, and devices. They may also collect IP address, browser or operating system type and version, and demographic or inferred-interest information, as well as personal information if you have submitted such information to us through the Sites, such as your name, postal address, email address, or device ID. They collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs, cross-device linking, and similar technologies.
• Session Replay Technology: We use session replay technology on our Sites. Session replay technology, also referred to as session playback or user experience (UX) replay, collects information regarding, records, and tracks your interactions with a website or application.
• ChatBot Technology: We use chatbots to help provide customer service and support, including through the use of a virtual assistant. A chatbot is a software application that mimics human conversations in text or voice interactions on our website or through our customer service hotline.
• Global Privacy Control and Opt-Out Preference Signals: Some browsers or browser extensions allow you to tell websites not to share your information for cross-contextual behavioral advertising or targeted advertising.
• Do Not Track Signals: Some browsers have a “do not track” feature. Our Sites are not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.
• Google Analytics: We use analytics services provided by Google Analytics. If you would like more information on how Google uses data when you visit or use our Sites, please visit https://www.google.com/policies/privacy/partners. If you would like to opt-out, Google provides an opt-out tool which is available at https://tools.google.com/dlpage/gaoptout.

9. Links to Other Websites

Our Sites may include links to other websites or applications whose privacy practices may differ from ours. If you submit personal information to any of those websites or applications, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit or application that you use.

10. Security

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organizational, administrative, and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

11. Processing in the United States

Please be aware that information we obtain about you will be processed in the United States by us, our affiliates, our clients, our marketing/analytics/advertising partners, or our service providers. By using the Sites or our services, you acknowledge your personal information may be transferred to and processed in jurisdictions outside your own as described in this Privacy Policy. Please be aware that the data protection laws and regulations that apply to your personal information transferred to the United States or other jurisdictions may be different from the laws in your country of residence. The United States may not afford the same level of protection as laws in your own country.

12. This Website Is Not Intended for Children

We do not knowingly collect or store any personal information from anyone under the age of 13. If we become aware that we have collected or stored personal information from an individual under age 13, we will remove his or her personal information from our files. If you are a parent or guardian and believe we may have inadvertently collected personal information from your child, please notify us immediately by sending an email to privacy@atlassearchllc.com.

13. Marketing Communications

• Marketing Emails: You can opt out of marketing or advertising emails by using the “unsubscribe” link or mechanism noted in communications you receive from us. You may also request to opt out of marketing or advertising emails by contacting us at privacy@atlassearchllc.com. 
• Phone Calls and Text Messages: If you do not want to receive marketing phone calls or text messages from us, please inform us that you no longer want to receive calls from us when you receive a call from us, or reply STOP to a text message from us. You can also opt-out of telemarketing by contacting us at privacy@atlassearchllc.com. Please note that SMS consent or phone numbers for the purpose of SMS are not shared.

14. Jurisdiction-Specific Privacy Rights

California Privacy Rights/Notice to California Residents

If you are a resident of the state of California, this section applies to you.

• Shine The Light: The California Shine the Light law (Cal. Civ. Code § 1798.83) permits residents of California to request certain details about how their information is shared with third parties for the third-parties’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at privacy@atlassearchllc.com and include “CA Shine the Light” in the subject line of your email.
• California Consumer Privacy Act (CCPA):

Categories, Sources, and Uses of Personal Information We Collect: In the preceding 12 months, we have collected the following categories of personal information: identifiers, commercial information, internet or electronic usage data, geolocation data, professional or employment information, non-public education information, audio/visual data, protected classification, information described in California Civil Code §1798.80(e), and inferences. For details about precise data points we collect, the categories of sources of such collection, and the business and commercial purposes for collecting personal information, please see the sections above titled Categories of Personal Information We Collect, Sources of Personal Information, and Purposes for Collecting Personal Information.

Use or Disclosure of Sensitive Personal Information: In the preceding 12 months, we have not used or disclosed sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.

Sale or Sharing of Personal Information: In the preceding 12 months, we have “sold” or “shared” (as those terms are defined in the CCPA) identifiers, commercial information, internet or electronic usage data, geolocation data, and inferences to marketing/analytics/advertising partners. We do not knowingly sell or share the personal information of minors under the age of 16.

Disclosure for a Business Purpose: In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of third party recipients:

Category of Personal Information	Categories of Recipients
Identifiers	Service Providers, Affiliates, Clients, Marketing/Analytics/Advertising Partners, Professional Advisors, Government Entities
Information described in California Civil Code §1798.80(e)	Service Providers, Affiliates, Clients, Professional Advisors, Government Entities
Characteristics of protected classifications under California or federal law	Service Providers, Affiliates, Clients, Marketing/Analytics/Advertising Partners, Professional Advisors, Government Entities
Commercial Information	Service Providers, Affiliates, Marketing/Analytics/Advertising Partners, Professional Advisors, Government Entities
Geolocation Data	Service Providers, Marketing/Analytics/Advertising Partners
Internet or Electronic Usage Data	Service Providers, Marketing/Analytics/Advertising Partners
Professional or Employment Information	Service Providers, Affiliates, Clients, Professional Advisors, Government Entities
Non-Public Education Information	Service Providers, Affiliates, Clients, Professional Advisors, Government Entities
Sensitive Information	Service Providers, Affiliates, Clients, Government Entities
Audio/Visual Data	Service Providers, Affiliates, Professional Advisors
Inferences	Service Providers, Affiliates, Marketing/Analytics/Advertising Partners

For a more expansive description of the categories of recipients and business purposes for which we share personal information, please see the How We Share Personal Information section above.

Your Rights Under the CCPA

Subject to certain exceptions and limitations, the CCPA affords California consumers the following rights:

• Right to Know: You have the right to request that we tell you (i) the categories of personal information we have collected, sold, or shared about you, (ii) the sources of that information, (iii) the business or commercial purposes for collecting, selling or sharing the personal information; and (iv) the categories of third parties to whom we have disclosed, sold or shared personal information.
• Right to Access: You have the right to request that we provide you with a copy of your personal information.
• Right to Delete: You have the right to request that we delete personal information that we have collected from you.
• Right to Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
• Right to Opt-Out of Sharing: You have the right to opt-out of the sharing of your personal information for cross-contextual behavioral advertising.
• Right to Limit Use of Sensitive Personal Information: You have the right to direct us to limit the use or disclosure of your sensitive personal information to only the purposes specified in the CCPA.
• Right to Correct: You have the right to correct inaccurate personal information that we hold about you.
• Right to Non-Discrimination: You have the right to not be discriminated against for exercising any of your CCPA rights. We will not discriminate against you, deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA rights.

Exercising Your Rights

To exercise any of your CCPA rights, please use our webform, which is available at https://atlassearchllc.com/contact-us/, or call us toll-free at 212-655-5477. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request. In order to designate an authorized agent to act on your behalf, you must provide us with a signed, written authorization. If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.

Cookie Based Opt-Outs for Targeted or Cross-Context Behavioral Advertising

We engage in online advertising practices (and certain analytics or similar activities), which may be considered a “sale” or “sharing” of personal information for cross-context behavioral advertising/targeted advertising. To opt-out of cookie and tracking technology-based sales and sharing, you will need to disable cookies set by third parties on our Sites. Exercising your rights through our webform or toll-free number will not opt you out of this sharing because we may not be readily able to associate your personal information with all of your IP addresses or Device IDs. To complete your opt-out, please click the Cookie Preferences link at the bottom of our webpages and change your cookie preferences to reject analytics & customization, advertising, and performance & functionality cookies.

Nevada Privacy Rights

If you are a Nevada resident, you may request that we stop selling certain categories of personal information that we collect. To submit a request please use our webform, which is available at https://atlassearchllc.com/contact-us/, or call us toll-free at 212-655-5477. For all requests, you must provide us with your name, email address, phone number, and mailing address so that we can verify your identity by matching the information we have collected against the information you have provided. Failure to provide all of the foregoing information may prevent us from processing your request.

Other US State Privacy Rights

This section only applies to you if you are a resident of Texas, Oregon, Virginia, Colorado, Utah, or Connecticut.

• We set forth above in our Privacy Policy the categories of personal data we process, the purpose for processing personal data, the categories of personal data shared, and the categories of third parties with whom personal data is shared.

Your Rights

You may have the following rights with respect to your personal data:

• Right to Confirm: You have the right to request that we confirm whether or not we are processing your personal data and to access your personal data.
• Right to Data Portability: You have the right to obtain a copy of your personal data in a portable and, to the extent technically feasible, readily usable format to allow data portability.
• Right to Correct: You have the right to correct inaccurate personal data that we hold about you, taking into account the nature of the personal data and the purposes of the processing of the data.
• Right to Delete: You have the right to request that we delete personal information that we have collected from you or obtained about you.
• Right to Opt-Out: You have the right to opt out of the processing of the personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) automated decision-making or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Exercising Your Rights

To exercise any of your rights, please use our webform, which is available at https://atlassearchllc.com/contact-us/, or call us toll-free at 212-655-5477. For all requests, you must provide us with your name, email address, phone number, and mailing address. We will verify your identity by matching the information we have collected against the information you have provided. Failure to provide the foregoing information may prevent us from processing your request. In order to designate an authorized agent to act on your behalf, you must provide us with a signed, written authorization. If you have requested that we correct your personal information, we may contact you to request additional information about the personal information that you believe is inaccurate, including supporting documentation.

Appealing Our Decision

If we refuse to take action on your request, you may appeal our decision within a reasonable period of time, not to exceed 90 calendar days from the date of your receipt of our response. To exercise your appeal rights, please use our webform or call us toll-free at 212-655-5477. Please include your full name and any additional information you would like us to consider.

Cookie Based Opt-Outs for Cross Context Behavioral Advertising

We engage in online advertising practices and certain analytics or similar activities, which may be considered a “sale” of personal information for cross-context behavioral advertising/targeted advertising. To opt-out of cookie and tracking technology-based sales and sharing, you will need to disable cookies set by third parties on our Sites. Exercising your rights through our webform or toll-free number will not opt you out of this sharing because we may not be readily able to associate your personal information with all of your IP addresses or Device IDs. To complete your opt-out, please click the Cookie Preferences link at the bottom of our webpages and change your cookie preferences to reject analytics & customization, advertising, and performance & functionality cookies.

Privacy Rights Of Individuals Outside of the United States

This section applies to you if you reside outside the United States or are located outside the United States.

• Controller: The controller of your personal information is Atlas Search, LLC.

To contact your local privacy representative, please reach out to privacy@atlassearchllc.com.

• International Data Transfers: Personal information that is shared with affiliates and third parties as described in this Privacy Policy is done in compliance with requisite protections under applicable data protection laws. In accordance with these laws, transfers of personal information are conducted through mechanisms and with protections that comply with applicable laws (such as data transfer agreements that contain standard contractual clauses adopted by the European Commission, Information Commissioner, and/or Federal Data Protection and Information Commissioner). In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.
• Lawful Basis for Processing Personal Information: The lawful basis for our collection and use of your personal information described in this Privacy Policy is that the processing is (i) necessary for our legitimate interests in carrying out our business, provided those interests are not outweighed by your rights and interests; (ii) necessary to perform a contract with a third-party or with you; (iii) necessary to comply with a legal obligation; or (iv) based, when necessary and appropriate, on your consent.
• Segmentation and Automated Decision Making: We do not use segmentation or automated decision-making without human intervention, including profiling.
• Your Rights Over Your Personal Information: Worldwide privacy and data protection laws give you certain rights. Subject to certain exceptions and limitations and depending on your residence or location, you have the right to:
  • Ask us to confirm whether we are processing your personal information.
  • Ask us to provide you or a third party that you designate with certain of your personal information in a commonly used, machine readable format. Please note, however, that data portability rights apply only to personal information that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
  • Request that we update or correct your personal information when it is inaccurate or incomplete.
  • Request that we delete your personal information in certain circumstances.
  • Request that we limit processing or stop processing your personal information in certain circumstances including for marketing activities and profiling for statistical purposes and, subject to certain exceptions, where such processing is based on our legitimate business interests.
  • Withdraw or revoke consent previously granted to the extent permitted by law.

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on our Sites may change or no longer be available to you. Any difference in the Services is related to the value provided.

In certain cases, these rights may be limited, for example if fulfilling your request would reveal personal data about another person or if you ask us to delete data which we are required by law to keep.

Exercising Your Rights

To exercise any of your rights, please use our webform, available at https://atlassearchllc.com/contact-us/, or call us toll-free at 212-655-5477. We will respond to all such requests within the timeframes provided by Applicable Data Protection Laws. Please note, however, that certain personal information may be exempt from such rights pursuant to applicable data protection laws. In addition, we will not respond to any request unless we are able to appropriately verify the requester’s identity.

Lodge A Complaint

You also have the right to lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection laws occurs. For the EEA, a list of the national data protection authorities can be found at https://edpb.europa.eu/about-edpb/about-edpb/members_en. For the UK, you have the right to lodge a complaint with the Information Commissioner’s Office. The ICO’s complaint procedures may be found at https://ico.org.uk/make-a-complaint/.

15. Contact Us

If you have any questions about this Policy or our data practices, please email us at privacy@atlassearchllc.com. You can also write to us at:

Atlas Search, LLC
1540 Broadway, 10th Floor
New York, NY 10036
privacy@atlassearchllc.com
212-655-5477

16. Updates to Our Privacy Policy

From time to time we may change our privacy policy. We will notify you of any material changes to our privacy policy as required by law. We will also post an updated copy on the website where this appears. Please check our website periodically for updates. The “Last Updated” legend above indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on any of our Sites.