This Privacy Notice describes the data protection and privacy practices adopted and implemented by Soleviren OÜ, a legal entity duly registered under the laws of the Republic of Estonia, having its registered office at Tallinn, Kesklinna linnaosa, Karu tn 14-8, 10120, with Company Registration Number 17444847 (hereinafter referred to as the “Company”, “We”, “Us”, or “Our”), which delivers the Services (hereinafter referred to as the “Services”) through its Website at https://www.atropos.one/ (hereinafter referred to as the “Website”). This Privacy Notice applies to all individuals and legal entities using Our Website and Services (hereinafter referred to as the “Customer”, “You”, or “Your”), regardless of their country of residence or place of incorporation. This Privacy Notice forms an integral part of the Company’s General Terms and Conditions.
Contact details
If You have any questions, comments, or concerns relating to this Privacy Notice, We encourage You to contact Us using the details set out below:
Address: Tallinn, Kesklinna linnaosa, Karu tn 14-8, 10120, Estonia
Email: info@atropos.one
1. Scope of Application and Definitions
This Privacy Notice explains how We process personal data in circumstances where We act as the data controller.
Definitions:
Personal Data refers to any information that identifies, or is capable of identifying, an individual, either directly or indirectly. This includes, but is not limited to, names, contact details, and payment information.
Data Controller means an entity that determines the purposes and means of processing personal data. Where You provide Your details to register an account with Us, We are acting as the data controller in respect of that information.
This Privacy Notice does not apply where Our Customers or third parties process personal data for their own independent purposes. For example, where a Customer sends an email containing personal data in the course of their own business activities, that Customer is the data controller and We act solely as a data processor, processing the data in accordance with their instructions or as required by applicable law.
This Privacy Notice also does not cover the use of third-party applications accessed through Our Services or linked to from Our Website. We recommend that You review the privacy policies of those third parties prior to using their services.
2. Individual Rights
We recognise and respect the following fundamental privacy rights of all individuals:
- The right to be informed about the personal data We collect and hold about You.
- The right to access, correct, or request the deletion of Your personal data.
- The right to receive a copy of Your personal data in a structured, machine-readable format (data portability).
- The right to manage Your preferences in relation to marketing and advertising communications.
Where possible, We provide automated or self-service tools to assist You in exercising these rights efficiently.
Where such tools are unavailable, We will process Your privacy-related requests manually and will aim to do so without undue delay. If We require additional information in order to respond to Your request, We will contact You by email or, where this is not available, by the same method You used to contact Us.
Where We are unable to comply with a request, whether for legal, regulatory, or other justifiable reasons, We will inform You accordingly and provide an explanation. Where applicable, We will also advise You of Your right to appeal and how to submit a complaint, in accordance with Your location and applicable law.
3. Personal Data We Collect
Information You Provide to Us
We collect personal data directly from individuals when they register an account, use Our Services, or contact Us. This includes, but is not limited to, Your name, email address, telephone number, postal address, and payment details.
Information We Collect Automatically
When You access Our Website, use Our Services, communicate with Us, open Our emails, or interact with Our advertisements, We automatically collect certain technical and usage data. This may include Your device identifier, IP address, browsing behaviour, and other information relating to Your use of the Website.
Information from Third-Party Sources
We may supplement Our records with personal data obtained from third-party sources, including public registers, social media platforms, and data providers that share such information in accordance with applicable law.
Information We Derive
In the course of Our operations and ongoing efforts to improve Our Services, We generate insights and inferences about individuals using tools such as data analytics and artificial intelligence.
Notice on data collection
Categories of personal data
- Your name and surname
- Your date of birth
- Your place of birth
- Your time of birth
- Your sex
- Your email address
- Your account password
- Your IP address
- Your device information1
- Your location data2
- Query history3
- Billing details4
- Payment method5
- User behaviour patterns6
Purposes of collection
- Creation and management of Your account.
- Personalisation of the Services.7
- Customisation of Our Website.
- Development and improvement of Our Services and Website.8
- Processing of purchase requests and transactions.
- Provision of customer support.
- Measurement and analysis of Website traffic.
- Detection of DNS abuse, fraud, and other unlawful activity.
By using Our Website and Services, You acknowledge and agree that We may, on occasion, collect additional personal data for purposes not previously specified. In such circumstances, You will be individually notified by email with details of the data being collected and the purpose for its collection. You will also be given the opportunity to opt out of such data collection.
1 Browser type, device type, and operating system, collected primarily for analytics purposes and to optimise Your experience.
2 Location data may be required to personalise the Services and to provide You with more relevant information.
3 Records of queries submitted by You, used for the purposes of personalised responses and follow-up interactions.
4 Payment processing data collected in connection with purchases made through the platform.
5 Information relating to payment methods and transaction details, which will ordinarily be held by authorised third-party payment service providers registered in the UK and/or EEA.
6 Data relating to how the Website is used, including pages visited, time spent on the platform, and user interactions, collected for the purpose of improving the quality of Our Services.
7 As We provide access to artificial intelligence technology designed to deliver helpful and informative content for entertainment purposes, the nature of this service inherently requires personalisation. In order to deliver a personalised experience, it is necessary to provide the AI system with certain personal data.
8 As We continually seek to expand and improve the scope and quality of Our Services, We collect personal data for internal use only, in order to identify emerging trends in user behaviour and adapt Our Services accordingly.
4. No Sale of Personal Data
We do not sell, lease, rent, or otherwise disclose Your personal data to third parties in exchange for money or any other form of consideration.
5. Disclosures to Third Parties
We may share personal data in the following circumstances:
- With service providers (processors): We engage third parties who support Our operations and assist in the delivery of Our Services. These include, for example, providers of security services, payment processors, customer support platforms, survey and feedback tools, data analytics providers, and other business support functions.
- With business partners: Specifically, those involved in the delivery of particular Services, such as email delivery or payment processing.
- For legal and safety purposes: Where required by law or in response to a lawful request from a public authority (such as a law enforcement agency), or where necessary to protect Our legal rights, ensure the safety of individuals, prevent harm, or enforce Our policies and agreements.
- In connection with business transactions: In the event that We are involved in a merger, acquisition, corporate restructuring, or sale of assets, personal data may be transferred to the acquiring entity or the newly formed organisation as part of that transaction.
6. Identifiers
Use of Identifiers
We make use of both optional and mandatory identifiers:
- Optional identifiers are used to enhance customer support, improve Website performance, and enable advertising functionality.
- Mandatory identifiers are required for core functions such as account management, user verification, service continuity, security, and other essential operations of Our Website and Services.
7. “Do Not Track” and Preference Signals
Some web browsers offer a “Do Not Track” feature; however, as there is currently no universally recognised or legally mandated standard for this signal, We do not respond to “Do Not Track” requests. We do, however, recognise and comply with universal opt-out mechanisms such as the Global Privacy Control where required to do so by applicable law.
8. Data Storage
We store personal data on Our own systems and with trusted third-party service providers, including Amazon Web Services.
9. International Data Transfers
Personal data will generally be stored and processed within the European Economic Area (EEA). There may, however, be circumstances in which We transfer Your data to third-party providers located outside the EEA. In such cases, We will take all necessary steps to ensure that appropriate safeguards are in place and that data protection standards equivalent to those applicable within the EEA are maintained throughout the transfer.
10. Data Retention
We will retain Your personal data for as long as is necessary for the purposes for which it was collected, including for the duration of Your use of Our Website and Services and for as long as Your account remains active. We will also retain certain data as required by applicable legislation, including anti-money laundering (AML) and counter-terrorist financing (CTF) obligations. In addition, We will retain personal data as necessary to respond appropriately to any legitimate claims brought by You or third parties, including in the context of litigation.
11. Security
We apply risk-based approaches to the protection of personal data, including the implementation of appropriate technical and organisational security measures and the provision of relevant training to Our staff. We also require Our service providers, business partners, and other third parties to implement comparable security safeguards. Where personal data is transferred outside the EEA, We put appropriate contractual arrangements in place and take all necessary steps to ensure that Your data continues to be protected to the required standard.
12. Data Relating to Minors
We do not knowingly collect personal data from individuals under the age of 18 without the consent of a parent or legal guardian. If You believe that We have inadvertently collected data from a minor without the requisite consent, please contact Us at support@atropos.one.
13. Legal Basis for Processing
We process personal data on the basis of Your instructions, Your consent, the performance of a contract to which You are a party, Our legitimate interests, or other applicable legal grounds. The specific legal basis for any given processing activity will depend on the Services You use, the nature of the data involved, the location of the processing, and Your country of residence. If You have any questions regarding the legal basis on which Your personal data is processed, please contact Us at support@atropos.one.
14. Non-Discrimination
We will not subject You to any form of discriminatory treatment as a consequence of Your exercising any of Your privacy rights.
15. No Financial Incentives
We do not offer financial incentives or other forms of compensation in exchange for the provision of personal data.
16. Amendments to This Notice
We may update this Privacy Notice from time to time by publishing a revised version on Our Website or by notifying Customers directly. Any amendments to this Privacy Notice will also apply to personal data collected prior to the update, provided that such changes do not diminish the rights of the individuals whose data is affected.
17. Contact Us
If You have any questions or concerns, please contact Us at support@atropos.one.
We aim to respond to all enquiries within 30 days of receipt.
