CORPORATE PRIVACY POLICY & DATA GOVERNANCE

1. OVERVIEW AND THE ONBOARDING PROTOCOL

This Privacy Policy (the “Policy”) governs the collection, use, and protection of personal data by ATLAS QUANT SYSTEMS INC. (“AQS”).

The Gated Access Framework: While the AQS public website allows for general browsing of analytical tools and core offerings, all subscriptions and services are strictly gated. Users acknowledge that they cannot gain access to the Customer Portal without successfully completing the mandatory onboarding sequence:

• KYC Identity Verification
• Execution of Terms of Service (ToS)
• Execution of this Privacy Policy
• Disclaimer Confirmation
• Final Account Activation

2. LEGAL COMPLIANCE STANDARDS

AQS operates under a "Canada-First" legal structure. This Policy is designed to comply with:

• PIPEDA (Personal Information Protection and Electronic Documents Act, Canada)
• CASL (Canada Anti-Spam Legislation)
• GDPR (General Data Protection Regulation) principles for global Users.
• Ontario Privacy Standards.

3. CATEGORIES OF DATA COLLECTED

To maintain the security of the AQS Customer Portal environment and enforce licensing, AQS collects:

• Onboarding & KYC Data: Full legal name, date of birth, valid email address and cell phone number, address and country of residence, government-issued ID and selfie verification (processed via encrypted third-party verification).
• Licensing & Technical Data: Unique Machine Identifiers (Machine ID), IP addresses, and operating system details. This is mandatory to enforce the "1 User = 1 License" policy and to ensure compatibility with Windows-based environments.
• Financial & Billing Data: Record of transactions and subscription tiers (e.g., AQS Core, AQS Advanced) for the 4-week (28-day) recurring billing cycle.
• Activity Logs: Time-stamped records of portal access, tool utilization, and IP geolocation to prevent unauthorized credential sharing.
• Communication Data: Audio, video, and chat transcripts from Atlas Live Analysis Rooms (LAR) or one-on-one and group consulting sessions.

4. PURPOSE OF PROCESSING

AQS processes data solely for the following mechanical and legal necessities:

• Identity Authentication: Ensuring all portal users are verified individuals.
• License Enforcement: Binding software access to a specific Machine ID and preventing concurrent sessions on unauthorized devices.
• Service Delivery: Facilitating the deployment of proprietary indicators and generalized research.
• Regulatory Shielding: Maintaining an audit trail to demonstrate that AQS provides technology and generalized analysis rather than regulated financial advice.

5. DATA SHARING AND CROSS-BORDER TRANSFERS

AQS does not sell or lease personal data. Data sharing is limited to:

• Identity Verifiers: For mandatory KYC processing.
• Payment Processors: For secure subscription management.
• Enterprise Infrastructure: Data is hosted on secure cloud servers which may be located outside of Ontario or Canada. By completing the onboarding process, Users provide express consent for cross-border data processing.

6. DATA RETENTION POLICY

Personal data is retained for the duration of the active subscription plus a period of seven (7) years to satisfy Canadian tax and regulatory record-keeping requirements. Biometric or KYC document copies are handled by our verification partners according to strict industry-standard deletion schedules once identity is confirmed.

1. FUNCTIONAL NECESSITY

The AQS website and Customer Portal utilize cookies and local storage for:

• Session Persistence: Maintaining secure access to the member portal.
• Security: Detecting fraudulent login attempts and verifying device consistency.
• System Check: Verifying that the User's system meets the technical eligibility requirements for AQS software.

2. ANALYTICS AND PERFORMANCE

AQS uses limited analytical tracking to monitor platform stability and optimize the performance of the analytical engines. Users may adjust browser settings to reject cookies; however, this will render the Customer Portal and associated analytical tools non-functional.

1. ACCESS AND RECTIFICATION

Users have the right to request a copy of their data or request corrections to inaccurate information. Due to the high-security nature of fintech data, all requests require identity re-verification.

2. DATA ERASURE (RIGHT TO BE FORGOTTEN)

Users may request the deletion of their personal data. AQS will comply with such requests unless the data is required for:

• Legal/Regulatory Compliance (e.g., financial audit trails).
• Contractual Obligations (e.g., active subscription terms).

3. SUBMISSION PROCESS

All data rights requests must be submitted via the official Data Request Form or by emailing compliance@atlasquantsystems.com. AQS will provide a formal response within thirty (30) days.

1. Governing Law & Exclusive Jurisdiction

This Privacy Policy, and all matters relating to the collection, use, or storage of personal data, shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein. Any dispute, controversy, or claim arising out of or relating to your data privacy rights shall be subject to the exclusive jurisdiction of the provincial and federal courts located in Toronto, Ontario.

2. Deemed Agreement & Execution of Onboarding

By continuing to access this website, utilizing AQS services, or interacting with the myAtlas / AQS Customer Portal, you are deemed to have read, understood, and irrevocably consented to the data practices described in this Policy. You further acknowledge and certify that:

• You have successfully completed the mandatory AQS Identity Verification (KYC) process;
• You have executed and agreed to the AQS End-User License & Terms of Service (ToS); and
• You provide express and informed consent for AQS to process your diagnostic telemetry, authentication data, and personal identifiers as required to maintain your software licensing and account security.

3. Revocation of Consent

If you do not agree to these terms or do not wish to be bound by the exclusive jurisdiction of Ontario, you must immediately cease use of all AQS platforms and uninstall any associated software. Continued interaction with the AQS ecosystem constitutes a voluntary affirmation of consent.