**GDPR PRIVACY NOTICE** This notice provides information about your rights under the European Union General Data Protection Regulation (GDPR). **DATA CONTROLLER** Atlas Media Washington DC, USA Email: gdpr@atlas.news EU Representative: [EU representative details available upon request] **DATA COLLECTED AND PROCESSING PURPOSES** | Data Category | Processing Purpose | Legal Basis | |---------------|-------------------|-------------| | Identity information | Account management | Contract | | Contact information | Newsletter, notifications | Consent | | Usage data | Analytics, improvement | Legitimate interest | | Cookie data | Site functionality | Consent/Legitimate interest | | Payment information | Subscription processing | Contract | **LEGAL BASES (GDPR ARTICLE 6)** We process your personal data based on the following legal grounds: 1. **Consent (Article 6(1)(a)):** Marketing communications, preference cookies 2. **Contract (Article 6(1)(b)):** Account creation, service provision 3. **Legal Obligation (Article 6(1)(c)):** Tax records, legal requests 4. **Legitimate Interest (Article 6(1)(f)):** Security, fraud prevention, analytics **YOUR RIGHTS UNDER GDPR** As EU/EEA residents, you have the following rights: **Right of Access (Article 15)** You can request access to your personal data and receive a copy. **Right to Rectification (Article 16)** You can request correction of inaccurate or incomplete personal data. **Right to Erasure / Right to be Forgotten (Article 17)** You can request deletion of your personal data under certain conditions: • If the data is no longer necessary • If you withdraw your consent • If you object to processing • If the data was unlawfully processed **Right to Restriction of Processing (Article 18)** You can request restriction of processing in certain situations. **Right to Data Portability (Article 20)** You have the right to receive your data in a structured, commonly used, and machine-readable format. **Right to Object (Article 21)** You can object to processing based on legitimate interest. **Rights Related to Automated Decision-Making (Article 22)** You have the right not to be subject to decisions based solely on automated processing. **Right to Withdraw Consent** For consent-based processing, you can withdraw your consent at any time. **INTERNATIONAL DATA TRANSFERS** Your personal data is processed on servers located in the USA. For transfers outside the EU/EEA, we use the following safeguards: • EU-US Data Privacy Framework • Standard Contractual Clauses (SCCs) • Additional security measures and encryption **DATA RETENTION** We retain your personal data only for as long as necessary: | Data Type | Retention Period | |-----------|-----------------| | Account data | While account is active + 3 years | | Transaction records | 7 years | | Marketing data | Until consent is withdrawn | | Analytics data | 26 months | | Support requests | 5 years | **DATA SECURITY** Pursuant to GDPR Article 32, we implement the following technical and organizational measures: • Encryption in transit and at rest (TLS 1.3, AES-256) • Access control and role-based permissions • Regular security testing and penetration testing • Incident response and breach notification procedures • Employee training and privacy awareness • Data processing agreements (DPAs) **DATA BREACH NOTIFICATION** In the event of a data breach: • We will notify the relevant supervisory authority within 72 hours • We will inform you immediately in high-risk situations • We will report the scope of the breach and measures taken **RIGHT TO LODGE A COMPLAINT** If you have concerns about our data processing practices: 1. Contact us first: gdpr@atlas.news 2. If you do not receive a satisfactory response, you can lodge a complaint with a supervisory authority **EU Supervisory Authorities:** Each EU member state has its own data protection authority. You can contact the authority in your country of residence. **CHILDREN'S DATA** We do not knowingly collect personal data from children under 16. If we learn that a child has provided data without consent, we will delete this data immediately. **AUTOMATED DECISION-MAKING** We do not make decisions based solely on automated processing that significantly affect you. Our analytics tools are used only for statistical analysis. **CHANGES** We may update this notice in accordance with GDPR requirements. We will notify you of significant changes by email or through the site. **CONTACT** For GDPR rights requests: Email: gdpr@atlas.news Response time: 30 days (may be extended to 60 days for complex requests) Last updated: January 2025 Version: 2.0

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