1. About Atlas
This Privacy Policy describes how JUMO Corporation, doing business as Atlas (“Atlas,” “we,” “us,” or “our”) collects, uses, discloses, stores, and protects personal information in connection with our website, communications, business-development activities, and other services that expressly link to this Privacy Policy. Legal Entity: JUMO Corporation, doing business as Atlas SEC Reference No.: SEC260922-DRMPWCQQLCND1C Country of Organization: Republic of the Philippines Principal Office: The KGY Empire OPC C. Aquino Drive and Taurus Street, corner Sharina Heights, Bacolod, 6100 Negros Island Region Philippines Privacy Contact: johnny@heyaude.com General Contact: johnny@heyaude.com Atlas provides business process outsourcing, operational support, bookkeeping support, legal virtual-assistant support, healthcare support services, data and reporting services, and AI-assisted software and web application development. This Privacy Policy applies only where Atlas determines the purposes and means of processing personal information or otherwise has responsibility for providing a privacy notice. When Atlas processes personal information solely on behalf of a client under the client's instructions, Atlas generally acts as a personal information processor, processor, service provider, contractor, business associate, or equivalent service provider, depending upon the applicable law. In those circumstances, the client's privacy notice and our contractual arrangements with that client primarily govern the processing.
2. Scope
This Privacy Policy may apply to personal information collected through: - the Atlas website; - contact and inquiry forms; - sales and business-development communications; - email, telephone, video conferences, and other business communications; - applications for employment or contractor opportunities; - events, demonstrations, consultations, and meetings; - Atlas software or technology services where this Privacy Policy is specifically referenced; - cookies and similar technologies used on our website; and - information supplied to us by customers, prospective customers, suppliers, professional advisers, partners, and other business contacts. Specific Atlas products or services may have additional privacy notices, data-processing terms, Business Associate Agreements, Data Processing Agreements, or product-specific terms. Where those documents conflict with this general Privacy Policy in relation to a specific service, the more specific document will control to the extent permitted by law.
3. Personal Information We May Collect
Depending on how you interact with Atlas, we may collect the following categories of information. Identity and Contact Information This may include: - name; - company; - business title; - business address; - email address; - telephone number; - professional or business contact details; and - other information you choose to provide. Business and Professional Information This may include: - employer or organization; - industry; - professional role; - service requirements; - project requirements; - business correspondence; - meeting information; - proposal information; - purchasing or procurement information; and - records relating to our business relationship. Website and Technical Information When you use our website, we or our technology providers may receive information such as: - IP address; - browser type; - device type; - operating system; - pages viewed; - referring pages; - approximate geographic region derived from IP address; - dates and times of access; - interaction data; - cookie identifiers; and - diagnostic, security, and performance information. Communications We may retain correspondence and other communications when you contact Atlas through email, telephone, contact forms, video conferencing, social media, or other communication channels. Recruitment Information If you apply to work with Atlas, we may collect: - résumé or curriculum vitae; - employment history; - education; - qualifications; - certifications; - contact information; - references; - interview information; and - other information relevant to recruitment. A separate applicant or workforce privacy notice may apply where appropriate.
4. Sensitive Information and Client Data
Because Atlas supports organizations operating in healthcare, legal, financial, and other sensitive industries, some client engagements may involve information that is confidential, privileged, sensitive, or otherwise specially protected by law. Do not submit patient records, Protected Health Information (PHI), medical information, financial account credentials, privileged legal information, government identification numbers, passwords, or other highly sensitive information through the general Atlas website contact form unless Atlas has specifically instructed you to do so through an approved secure channel. When Atlas processes sensitive information on behalf of a customer, that processing is governed by applicable law and the relevant customer agreement, which may include confidentiality obligations, security requirements, Data Processing Agreements, Business Associate Agreements, and other contractual safeguards.
5. How We Use Personal Information
Atlas may use personal information for legitimate business purposes including: Providing and Managing Services We may process information to: - respond to inquiries; - evaluate client requirements; - provide proposals; - establish and administer business relationships; - provide contracted services; - provide technical support; - communicate regarding projects; - manage accounts; - invoice and collect payment; and - maintain records relating to services. Operating and Improving Our Website and Services We may use information to: - maintain website functionality; - understand website usage; - troubleshoot problems; - improve user experience; - develop products and services; - conduct analytics; - maintain system performance; and - protect our systems. Business Communications We may communicate with customers, prospective customers, suppliers, partners, and professional contacts about: - inquiries; - requested services; - business relationships; - operational matters; - relevant Atlas services; - product updates; and - other legitimate business communications. Where applicable law requires consent for certain marketing communications, Atlas will seek that consent. Recipients may unsubscribe from marketing communications at any time. Security and Fraud Prevention We may process information to: - authenticate users; - prevent misuse; - investigate suspected security events; - detect fraud or malicious activity; - protect our systems and personnel; and - enforce our agreements. Legal and Regulatory Purposes We may process information when reasonably necessary to: - comply with applicable laws; - respond to lawful government requests; - establish or defend legal claims; - maintain corporate records; - comply with tax or accounting requirements; - protect rights and property; and - satisfy regulatory obligations.
6. Legal Bases for Processing
Depending upon applicable law and the circumstances, Atlas may rely upon one or more legal bases for processing personal information, including: - consent; - performance of a contract; - steps requested before entering into a contract; - compliance with legal obligations; - protection of legitimate interests; - protection of vital interests where applicable; and - other lawful grounds permitted under applicable privacy law. For users subject to the GDPR or UK GDPR, our legitimate interests may include operating and securing our business, responding to business inquiries, maintaining customer and supplier relationships, preventing fraud, improving services, and conducting reasonable B2B marketing, provided those interests are not overridden by the rights and interests of affected individuals. Where processing depends upon consent, you may withdraw consent subject to applicable law.
7. When Atlas Acts for a Client
A substantial portion of Atlas's work involves processing information on behalf of customer organizations. For example, Atlas personnel may access or process information within a client's systems in order to provide operational, administrative, bookkeeping, reporting, healthcare-support, legal-support, technology, or other contracted services. In such cases: - the client generally determines why the information is processed; - Atlas processes the information according to the client's instructions and applicable agreements; - access should be limited to personnel whose work requires it; - use of the information is limited to authorized purposes; and - requests relating to the information may need to be directed to the relevant client. If you contact Atlas concerning information we process exclusively for one of our customers, we may refer your request to that customer.
8. Healthcare Information and HIPAA
Certain Atlas healthcare-support engagements may involve U.S. healthcare organizations subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Where Atlas qualifies as a Business Associate or subcontractor Business Associate, our handling of Protected Health Information is governed by HIPAA to the extent applicable, the relevant Business Associate Agreement, applicable security requirements, and the instructions of the covered entity or Business Associate for whom Atlas performs services. This public Privacy Policy is not a Business Associate Agreement. Protected Health Information should be exchanged only through systems and workflows authorized for the relevant healthcare engagement.
9. AI-Assisted Systems
Atlas develops and may use AI-assisted technologies in certain workflows and products. Depending upon the application, AI systems may assist with activities such as: - organizing information; - classification; - summarization; - workflow automation; - analysis; - extraction; - reporting; - anomaly identification; and - decision support. Atlas does not represent that AI-generated results are infallible. Where an application involves decisions that materially affect individuals, Atlas seeks to design appropriate human review and oversight consistent with the purpose of the application and applicable law. Atlas will not intentionally use confidential client information to train publicly available AI models unless such use has been authorized and is permitted under the applicable agreement and law. Product-specific AI practices may be described in additional product notices.
10. Cookies and Similar Technologies
Atlas may use cookies and similar technologies for purposes including: Essential Technologies These support basic website functionality, security, session management, and user preferences. Analytics Technologies These may help us understand website traffic, performance, and how visitors interact with our website. Marketing Technologies If Atlas later uses advertising or marketing technologies, these may measure campaign effectiveness or assist with relevant business advertising. Where required by applicable law, non-essential cookies will be used only after obtaining appropriate consent. Where available, visitors should be provided with controls to: Accept All, Reject Non-Essential, or Manage Preferences. You may also control cookies through your browser settings.
11. Disclosure of Personal Information
Atlas may disclose personal information to appropriate recipients including: Service Providers and Subprocessors These may include providers of: - web hosting; - cloud infrastructure; - email; - Microsoft 365 or similar business platforms; - analytics; - cybersecurity; - communications; - CRM; - accounting; - payment processing; - software development; - data storage; and - professional services. Providers are expected to process information only for authorized purposes and subject to appropriate contractual and security obligations where required. Customers Where Atlas performs services on behalf of a customer, relevant information may be made available to that customer. Professional Advisers We may disclose information to lawyers, accountants, auditors, insurers, consultants, and other professional advisers where reasonably necessary. Legal or Regulatory Authorities Information may be disclosed when required by applicable law, valid legal process, regulatory obligation, or when reasonably necessary to protect legal rights. Corporate Transactions If Atlas or JUMO Corporation undergoes a merger, acquisition, financing, restructuring, reorganization, sale of assets, or similar transaction, information may be disclosed to appropriate parties subject to applicable safeguards.
12. Sale and Sharing of Personal Information
Atlas does not intend to operate its website as a business that sells personal information for monetary consideration. Certain privacy laws define “sale” or “sharing” more broadly and may classify some advertising, analytics, or technology-provider arrangements differently from ordinary use of those terms. Where our activities constitute a regulated sale, sharing, targeted advertising activity, or similar processing under applicable law, Atlas will provide any notices and opt-out rights legally required. Atlas does not knowingly sell personal information belonging to children.
13. International Data Transfers
Atlas is based in the Philippines and supports organizations in other countries, including the United States. As a result, information may be processed in the Philippines, the United States, or other countries where Atlas, its clients, or its service providers operate. Privacy and data-protection laws vary between jurisdictions. Where required, Atlas may use appropriate safeguards for international transfers, including: - contractual data-protection clauses; - Data Processing Agreements; - applicable model contractual clauses; - European Commission Standard Contractual Clauses; - UK international transfer mechanisms; - ASEAN or other recognized model contractual provisions; - confidentiality obligations; - access controls; and - other lawful transfer mechanisms.
14. Data Retention
Atlas retains personal information only for as long as reasonably necessary for the purposes for which it was collected, including: - providing services; - maintaining customer relationships; - complying with contractual obligations; - resolving disputes; - establishing or defending legal claims; - satisfying regulatory, accounting, tax, or legal requirements; and - maintaining necessary business and security records. Retention periods may vary according to the type of information, applicable agreement, client instructions, legal requirements, and business need. Where Atlas processes information solely for a client, retention and deletion may be governed by the client's instructions and the relevant agreement.
15. Information Security
Atlas uses administrative, organizational, physical, and technical safeguards designed to protect personal information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, misuse, or unauthorized access. Safeguards may include, depending on the system and engagement: - access controls; - authentication; - workforce confidentiality requirements; - security policies; - approved business systems; - account management; - device and endpoint controls; - encryption where appropriate; - backup and recovery processes; - logging and monitoring; - staff training; - incident-response processes; and - contractual confidentiality and security obligations. No electronic system is completely secure. Atlas therefore cannot guarantee absolute security.
16. Personal Data Breaches and Security Incidents
Atlas maintains processes for identifying, evaluating, escalating, and responding to suspected privacy or security incidents. Where an incident triggers legally mandated notification requirements, Atlas will take steps required under applicable law and contractual obligations. Where Atlas processes affected data for a client, Atlas will cooperate with that client in accordance with the applicable agreement.
17. Your Privacy Rights
Privacy rights vary by jurisdiction. Subject to applicable law and exceptions, individuals may have rights to: - receive information about processing; - request access to personal information; - correct inaccurate information; - request deletion or erasure; - request blocking or restriction of processing; - object to certain processing; - withdraw consent; - request data portability; - opt out of certain marketing; - opt out of certain sales, sharing, profiling, or targeted advertising where applicable; - request information regarding recipients or categories of recipients; - complain to an appropriate privacy regulator; and - exercise rights without unlawful discrimination or retaliation. Atlas may need to verify your identity before completing a request. Authorized agents may exercise certain rights where permitted by applicable law. Atlas may decline or limit requests when permitted or required by law.
18. Philippine Data Subjects
Individuals protected by the Philippine Data Privacy Act of 2012 may have rights including the rights to: - be informed; - object; - access; - correct inaccurate information; - seek rectification, erasure, or blocking under applicable circumstances; - obtain data portability where applicable; and - seek remedies provided by law. Questions and complaints may also be raised with the Philippine National Privacy Commission.
19. European Economic Area and United Kingdom
Where the GDPR or UK GDPR applies, individuals may have rights including: - access; - rectification; - erasure; - restriction; - objection; - portability; - withdrawal of consent; and - the right to complain to the relevant supervisory authority. Where applicable law grants rights relating to solely automated decisions with legal or similarly significant effects, Atlas will respect those rights. International transfers from the EEA or United Kingdom will be handled using an appropriate lawful transfer mechanism where required.
20. United States Privacy Rights
Residents of certain U.S. states may have privacy rights under applicable state law. Depending upon the jurisdiction and whether the law applies to Atlas's processing, these may include rights to: - know or access; - correct; - delete; - obtain a portable copy; - opt out of sale; - opt out of certain sharing or targeted advertising; - opt out of certain profiling; and - appeal certain privacy-request decisions. Atlas will honor legally recognized browser-based preference signals where required by applicable law and where technically applicable to our processing. We will not discriminate against individuals for exercising legally protected privacy rights.
21. Children
Atlas's website and business services are intended for businesses and adults. They are not directed to children under 13 years of age, and Atlas does not knowingly collect personal information online from children under 13 through its general website. If we learn that such information has been collected improperly, we will take appropriate steps to delete it. Product-specific services involving minors, if any, will be governed by separate agreements and privacy requirements appropriate to the service.
22. Third-Party Websites
Our website may link to websites operated by third parties. Atlas does not control their privacy practices. We encourage visitors to review the privacy notices of third-party websites before providing personal information.
23. Changes to This Privacy Policy
Atlas may update this Privacy Policy periodically to reflect changes in law, technology, our services, or our data-processing practices. The updated policy will display a revised “Last Updated” date. Where applicable law requires additional notice or consent for a material change, Atlas will provide it.
24. Contact Atlas About Privacy
Questions, privacy requests, or concerns may be submitted to: JUMO Corporation doing business as Atlas SEC Reference No. SEC260922-DRMPWCQQLCND1C The KGY Empire OPC C. Aquino Drive and Taurus Street, corner Sharina Heights, Bacolod, 6100 Negros island Region Philippines Philippines Privacy Email: johnny@heyaude.com Please use the subject line: Privacy Request We may request reasonable information necessary to verify your identity and process your request.