Privacy Notice

ATLAUA Inc. and/or its respective subsidiaries, parents, and affiliates ("ATLAUA", "we", "us", "our", or the "Company") collect, use, and are responsible for certain Personal Information about you. We collect, use and are responsible for certain Personal Information about you. By doing so, we are subject to various laws in the United States, including but not limited to the California Consumer Privacy Act of 2018 ("CCPA") as well as other state and federal privacy laws and regulations.

By using our website, you acknowledge that you have read and understood this Privacy Notice and consent to the collection and use of your Personal Information as described herein.

1. Mobile Application

This Privacy Notice applies to both our website (atlaua.shop) and our mobile application ("ATLAUA App") available on the Apple App Store. When you use the ATLAUA mobile app, we may collect additional information including: device identifiers (iOS Identifier for Vendor / IDFV), push notification tokens (only if you opt in), crash and performance data via Sentry, and app usage patterns. We do not collect your precise GPS location. We do not access your camera, contacts, or health data.

2. Key Terms and Definitions

Personal Information. Personal Information means information that identifies, relates to, describes, is capable of being associated with, or could be linked, directly, or indirectly, with a particular individual or household. Personal Information does not include publicly available information.

Processing. Any operation or set of operations which is performed on Personal Information or on sets of Personal Information.

Sensitive Personal Information. Personal Information revealing a consumer's driver's license or state identification numbers, credit card numbers, and precise geolocation.

3. Personal Information We Collect About You

We may collect and use the following Personal Information, including Sensitive Personal Information, that identifies, relates to, describes, is reasonable capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

• First and last name, address, telephone number, e-mail address, IP address, payment details, social media profiles, government identification numbers
• Driver's license or state identification card numbers, account numbers, financial and billing information
• Internet or other electronic network activity information including browsing history, search history
• Geolocation data
• Inferences drawn from any of the information identified above to create a profile about a consumer

If you do not provide Personal Information required to provide our products and services to you, it may delay or prevent us from providing such products or services to you.

4. Sources of Personal Information We Collect

4.1 Personal Information Provided by You

When you make a purchase, subscribe to any newsletter or other form of periodic communication, or contact customer service, we may collect the following Personal Information:

• Full name
• Email address
• Phone number
• Shipping and billing address
• Payment information (credit/debit card details, billing address, etc.)
• Government-issued identification (e.g., driver's license or state ID) that may be used to verify your age and identity in compliance with applicable law

4.2 Automatically Collected Personal Information

When you visit our website, we automatically collect certain data through cookies and similar tracking technologies, including:

• IP address
• Device information (browser type, operating system, device model, etc.)
• Website usage data (pages visited, time spent on site, clicks, and browsing behavior)
• Location data (only if permitted by your device settings)

4.3 Personal Information Collected from Third Parties

We may receive information from third-party partners, including:

• Payment processors (transaction details, fraud detection data)
• Marketing partners and advertising networks
• Shipping carriers (tracking and delivery updates)

5. How and Why We Use Your Personal Information

We collect and process your Personal Information for the following purposes:

• Improve our products and services, functionality, and overall user experience
• Deliver our products and services to you
• Better cater and market to our users, as well as learn about preferences and usage habits
• Respond to customer service requests, comments and questions
• Send periodic emails, notifications, and text messages regarding our products and services including exclusive offers and promotions
• Follow up with you after correspondence (live chat, email, or phone inquiries)
• Conducting checks to identify and/or age of our customers and verify their identity and/or age
• Communicate about our partners' products and services
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity
• Troubleshoot technical difficulties and errors
• Link or combine user information with other Personal Information
• Marketing our products and services and those of selected third parties
• Statistical analysis to help us manage our business
• External audits and quality checks
• To aggregate your Personal Information to ensure it is no longer identifying
• As permitted or required by applicable law or regulatory requirements
• For our legitimate interests or those of a third party
• For any additional purposes for which we have obtained your consent
• Cross-context behavioral advertising or targeted advertising

6. Categories of Personal Information We Disclosed for a Business Purpose

In the preceding 12 months, we have disclosed the following categories of Personal Information for a business purpose:

• Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, driver's license number, state identification number, or other similar identifiers)
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual
• Commercial information (e.g., records of products purchased, obtained, or considered)
• Internet or other electronic network activity information
• Geolocation data
• Inferences drawn from any of the information identified above to create a profile about a consumer
• Sensitive Personal Information

7. Who We Share Your Personal Information With

We may routinely share Personal Information with:

• Our affiliates, including companies and brands owned or controlled by the Company, if any
• Service providers we use to help deliver our products and/or services to you, such as payment service providers, warehouses, and delivery companies
• Other third parties we use to help us run our business, such as IT and administration and hosting, marketing agencies, vendors, service providers, contractors, and agents
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers
• Social media platforms and networks such as Facebook, Twitter, TikTok, Pinterest, and Instagram
• Our insurers and brokers
• Our banks
• Third-parties for legal, protection, and safety purposes
• Third-parties when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets

We may also sell, rent, or share aggregate consumer information (i.e., anonymized summary data) with others for their own uses. This aggregate consumer information will never include your name, phone number, email address, or mailing address.

7a. Information Security and Payment Data Transmission

We protect your Personal Information using industry-standard administrative, technical, and physical safeguards. Specifically:

• Encryption in transit: All data exchanged between your browser and our website, including payment information at checkout, is transmitted over TLS 1.2 or higher (SSL Secured, minimum 128-bit). You can verify the secure connection by the padlock icon in your browser address bar.
• Encryption at rest: Sensitive data stored in our systems is encrypted using AES-256 or equivalent.
• Payment data: We do not store full card numbers on our servers. Payment data is tokenized and processed through PCI DSS Level 1 compliant payment processors (Stripe for memberships and identity verification; the merchant processor connected to our Shopify checkout for product purchases).
• Hosting: Our website is hosted on Vercel Inc. (a US-based SOC 2 Type II compliant infrastructure provider) with our application backend on Supabase Inc. Hosting provider contact: vercel.com/contact.
• Access controls: Access to Personal Information is restricted to authorized personnel on a need-to-know basis, protected by multi-factor authentication.
• Incident response: If we become aware of a security breach affecting your Personal Information, we will notify you in accordance with applicable law.

While we take these measures seriously, no method of electronic transmission or storage is 100% secure. If you have reason to believe your interaction with us is no longer secure, please contact us immediately at privacy@atlaualabs.com.

8. Notice of Financial Incentives

We may offer financial incentives such as discounts, coupons, or promotional credits in exchange for your Personal Information (e.g., email address for signing up for marketing communications). These incentives are optional and participation is voluntary. You may withdraw from the incentive at any time by unsubscribing or contacting us at info@atlaualabs.com. We value your Personal Information consistent with the incentive provided, based on factors such as estimated revenue generated or marketing value.

9. Personal Information We Sold

As of the date of this Privacy Notice, in the preceding 12 months, we have not sold any Personal Information. However, we may sell the following categories of Personal Information in the future, as permitted by applicable law:

• Identifiers
• Information that identifies, relates to, describes, or is capable of being associated with, a particular individual
• Commercial information
• Internet or other electronic network activity information
• Geolocation data
• Professional or employment-related information
• Inferences drawn from any of the information identified above

10. How Long Your Personal Information Will Be Kept

We will keep your Personal Information while you have an account with us or while we are providing products or services to you. Thereafter, we will keep your Personal Information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf
• To show that we treated you fairly
• To keep records required by law

We will not retain your Personal Information for longer than necessary for the purposes set out in this Privacy Notice. When it is no longer necessary to retain your Personal Information, we will delete or anonymize it.

11. Your Privacy Rights

11.1 Your Privacy Rights

Certain states, countries, and regions provide individuals with certain data subject rights ("Privacy Rights"). Depending on where you reside, you may have the following Privacy Rights:

• To know whether we process your Personal Information
• To correct or update your Personal Information
• To know the categories of Personal Information we collect about you, the purposes for the collection, how long we retain your Personal Information, and whether that information is sold or shared
• To request access to your Personal Information, including obtaining a copy of Personal Information, or have your Personal Information transferred to another controller
• To request deletion of your Personal Information
• To opt out of the sale or sharing of your Personal Information
• To limit the use of your Sensitive Personal Information, as defined by applicable law
• To opt-out of some types of automated decision-making
• Not to be discriminated against for exercising your Privacy Rights
• To withhold or withdraw consent for the processing of your Personal Information

You or your authorized agent may make a request to exercise your Privacy Rights concerning your Personal Information by contacting us using the information in the "How to Contact Us" section below.

11.2 Opting Out of Marketing Communications

You can unsubscribe from our marketing communications at any time by clicking on the unsubscribe link provided in the emails.

11.3 Managing Cookies and Tracking Technologies

You can manage your preferences regarding cookies and tracking technologies through your browser settings. Note that altering these settings may affect the functionality of our website.

11.4 Communication Preferences

If you would like to change your contact information, please contact us using the information in the "How to Contact Us" section below. We will make a good faith effort to make requested changes in our active databases as soon as reasonably practicable.

11.5 Do Not Track

Do Not Track is a web browser setting that requests that a web application disable its tracking of an individual user. Currently we do not respond or take any action with respect to these signals or similar mechanisms.

11.6 Opt-Out Preference Signals

Some browsers and browser extensions support opt-out preference signals such as the Global Privacy Control. In certain regions, when we detect such a signal, we will make reasonable efforts to respect your choices as required by applicable law.

11.7 How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Notice, you can do so by contacting us at info@atlaualabs.com or by calling us at +1 (213) 715-1466.

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address, and customer or matter reference number)
• Proof of your identity and address (e.g., a copy of your driving license or state issued identification and a recent utility or credit card bill)
• A description of what right you want to exercise and the information to which your request relates

12. Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent Personal Information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your Personal Information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

13. Apple App Store — Data Privacy Disclosure

In accordance with Apple App Store requirements, we disclose the following categories of data collected through the ATLAUA mobile app:

14. App Tracking Transparency (ATT)

ATLAUA does not engage in cross-app or cross-site tracking. We do not use Apple's Advertising Identifier (IDFA). You will not be prompted for ATT authorization. If this changes in a future version of the app, we will update this policy and request explicit permission through Apple's ATT framework.

15. Children's Privacy

Our website is designed for a general audience and not intended for children under 18 years old. We do not knowingly collect or process personal data from those under 18 years of age. If you believe a child has provided Personal Information, please contact us for immediate removal.

16. California Residents

California Civil Code Section 1798.83, California's "Shine the Light" law, permits users of our Site that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year. You may request this information once per calendar year.

17. European Users (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the following applies:

• Legal basis for processing: We process your personal data based on: (a) performance of a contract (to fulfill your orders and provide membership services); (b) legitimate interests (fraud prevention, security, product improvement); and (c) your consent (marketing communications, push notifications).
• Data transfers: Your data may be transferred to and processed in the United States. We rely on Standard Contractual Clauses (SCCs) approved by the European Commission for such transfers.
• Data Protection contact: privacy@atlaualabs.com
• Your rights: In addition to the rights listed above, EU/UK residents have the right to lodge a complaint with their local data protection authority.

18. Changes to This Privacy Notice

We reserve the right to modify this Privacy Notice at any time to reflect changes in our practices or service offerings. Changes will be posted on our website and take effect immediately upon posting. Here's how we handle Notice changes:

• Notification: We will notify users of significant changes to our Privacy Notice via email or a prominent notice on our website.
• Review: Users are encouraged to periodically review this page for the latest information on our privacy practices.
• Acceptance of Changes: Continued use of our website and services following the posting of changes to this Privacy Notice will indicate your acceptance of those changes.

19. Your Acceptance of These Terms

By using this website, you accept and agree to the terms of this Privacy Notice.

20. Terms of Service

Our Terms of Service are incorporated into and are a part of this Privacy Notice. It is important that you read the Terms of Service, as where there is a conflict between this Privacy Notice and the Terms of Service, the Terms of Service shall prevail.

21. How to Contact Us

Please contact us by post, email or telephone if you have any questions about this Privacy Notice or the information we hold about you:

22. Do You Need Extra Help?

If you would like this notice in another format (e.g., audio, large print, braille) please contact us (see "How to Contact Us" above).

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