Stratum Atlas (“we”, “us”, or “our”) operates thestratumatlas.com and the invite-only Terminal. This policy explains how we collect, use, disclose, and safeguard personal information when you visit the public site, request access, or use a provisioned seat. Please read it so you know what we hold and why.
1. Who this policy covers
This policy applies to visitors of the public site, people who request access, and invited users of the Terminal. Stratum Atlas is the controller of personal information described here. Questions and requests: access@stratumatlas.com.
The public-filing book is compiled from issuer and agency records. Those records are not your personal data merely because you search them. Materials you type or upload into a personal case are Customer data we process to operate the Terminal for you.
2. Information we collect
Account and access
- Name and work email, when you request a seat or sign in
- Organization, role, and related professional context, when you provide them
- Account credentials and session tokens needed to keep you signed in
- Messages you send to access@stratumatlas.com, including access requests and support
What you put in the Terminal
Personal cases, private evidence, counterparties, dates, reported deal terms, and other materials you type or upload so a run can be held. We process these to operate the Terminal for you. We do not ask for payment-card numbers, medical records, or government identifiers on the public site, and you should not send them unless we have agreed in writing to hold that class of data.
Technical information
- Browser type and language
- IP address and approximate location derived from it
- Device and session identifiers
- Pages viewed, referring URL, and time of access
- Diagnostic logs needed to operate and secure the Services
Cookies
We use a session cookie (atlas-session) to keep an authenticated seat open. The public marketing pages do not require an account cookie. If we add analytics later, we will name the vendor here before it runs. We do not sell personal information. We do not use the public site for cross-context behavioral advertising.
3. How we use it
- To provide, secure, and maintain the site and the Terminal
- To decide whether a work email has a seat, and to send a sign-in link
- To respond to access requests and support
- To hold a personal case so later questions are asked on the same terms as the first
- To attach private evidence to that case when you upload it
- To detect abuse, unauthorized access, and fraud
- To comply with law and enforce the User Terms
Where coverage is insufficient, Atlas withholds a precise score rather than inventing one from your personal information or from a gap in the book.
4. What we do not do
- We do not use the contents of Customer deal files, personal cases, or private uploads to train a public model
- We do not share one Customer’s deal terms with another Customer
- We do not sell personal information, and we do not share it for cross-context behavioral advertising
- We do not send marketing mail unless you have asked for it
- We do not invent a probability, a COD, or a missing filing to fill a gap
5. Legal bases (EEA, UK, and similar regimes)
Where a legal basis is required, we rely on:
- Your consent, where we ask for it
- Performance of a contract, or steps you request before a contract — including evaluating an access request and operating a provisioned seat
- Compliance with a legal obligation
- Our legitimate interests in operating a secure professional Terminal, compiling a public-filing book, and preventing abuse, provided those interests are not overridden by your rights
Atlas produces measurement against a filed book for Customer’s professional use. It is not an automated decision that produces legal or similarly significant effects about you as an individual. Customer remains responsible for its own underwriting judgment.
6. Sharing
We share information with service providers who host, authenticate, or operate the Services on our instructions (including infrastructure and email delivery), with professional advisers under confidentiality, with authorities when the law requires it, and in connection with a merger, acquisition, or sale of assets, subject to appropriate protections.
We do not sell personal information. We do not share it for cross-context behavioral advertising. We do not use Customer deal files as a data-broker product.
7. Transfers and retention
If you are outside the country where our systems run, your information may be processed in the United States or another country. Where required, we use appropriate safeguards for that transfer.
We keep account and Terminal materials for as long as the seat is open and as needed for the purposes in this policy, then for a limited period after closure as described in the User Terms, or longer if the law requires it. The public-filing book is not your personal data; we retain editions as part of the product.
Personal cases and private uploads follow the seat. After termination we may retain them for thirty days, then delete them, except records we must keep by law or that exist independently in the public-filing book.
8. Your rights
Depending on where you live, you may have the right to access, correct, delete, or export personal information, to restrict or object to certain processing, and to withdraw consent where processing is based on consent.
California residents may also have rights under the CCPA/CPRA, including to know, delete, and correct personal information and to opt out of sale or sharing. We do not sell or share personal information as those statutes define those words. We do not use or disclose sensitive personal information for purposes that require a right to limit under those statutes, because we do not collect that class of data in the ordinary course.
We will not discriminate against you for exercising a privacy right. To exercise a right, write to access@stratumatlas.com. We may need to verify the request, and we may decline a request that is not required by law, that would compromise another person’s rights, or that would require us to reconstruct a deleted seat. You may lodge a complaint with a supervisory authority.
9. Security and children
We use commercially reasonable technical and organizational measures to protect personal information, including access control on the Terminal and encryption in transit. No transmission over the internet is completely secure.
The Terminal is a professional product. It is not directed to children under 16, and we do not knowingly collect their personal information. If we learn that we have, we will delete it.
10. Other sites
The site may link to issuer filings, agency portals, and other third-party pages. Their privacy practices are their own. Atlas is not responsible for those sites.
11. Changes
We may update this policy. The new version is indicated by the “Last updated” date and applies when it is posted. Material changes to how we use personal information will be reflected here before they take effect for that use.
12. Contact
Questions about this policy or our data practices: access@stratumatlas.com. Stratum Atlas · thestratumatlas.com.