Privacy Policy

Last Update: September 21, 2026

This Privacy Policy explains how Atum Labs (“Atum,” “we,” “our,” or “us”) collects, uses, stores, shares and protects personal information we collect about you, including when you interact with us through our website(s), communications with us. By accessing this website or other of our domains and URLS that post this Privacy Policy and using our services (collectively, “Services”), you agree you have read and understood this Privacy Policy and our Terms & Conditions. If you do not agree with any portion of this Privacy Policy, please do not use or access or use our Services or provide us with any Personal Information.

If you are a user located in the European Economic Area (EEA) or United Kingdom (UK), please see Additional Disclosures for EU and UK in addition to this Privacy Policy.

1. Information We Collect and How We Collect It

Depending on how you interact with us, we may collect personal information from or about you. When we use the term “Personal Information,” we mean information that can help us directly or indirectly identify you. We may collect this information directly from you, from other third-party sources, and automatically from your use of our website.

a. Information You Provide to Us

We or our service providers may collect the following Personal Information about you when you use the website and/or our Services:

• Identifying Information. Such information may include name, email, company and business title.
• Correspondence and Content. This includes information provided when you communicate with us, such as when you send us messages providing feedback, requesting support or seeking information.
• Financial and Transactional Information. Such information includes transaction activity including transaction details and payments.
• Other Information. You may choose to voluntarily provide other Personal Information to us that we have not solicited from you and in such instances, you are solely responsible for such information.

b. Information We Collect Automatically

We may collect the following Personal Information automatically through your interactions with our website:

• Device Information. We may collect information about the device you use to access the website such as the device type, operating system, browser type, and screen height and width. This information helps us optimize the website for different devices and troubleshoot any technical issues.
• Usage Information. We may collect information about how you use the website including the time you access our website, pages you visit, the features and assets you interact with, the links you click, and the search queries you make. By analyzing this data, we gain a deeper understanding of user behavior which in turn allows us to make continuous improvements to the website and enhance the overall user experience.

We may collect this information through cookies and similar tracking technologies. Please also see Cookies and Online Tracking Technologies below for additional details regarding our use of cookies and other technologies to gather such information.

c. Information Collected from Other Sources

We may collect certain Personal Information through third parties, including businesses we partner with to offer referrals to and integrations with our Services. This includes your name, email address, etc.

2. Why We Collect Personal Information

We may use the Personal Information we collect for the following purposes:

• Establish and Maintain Our Relationship with You. This includes managing your relationship with us and your requests for our Services.
• Administering our Website and Services. For example, this includes providing our products and services to you, process billing and collection of any fees, administering our website and services, system administration and detecting usage patterns (including broad demographic information for aggregated use).
• Communicating with You. We may provide you with information on developments and new features or products and service announcements and use information to respond to your communications and requests.
• Security. We may use information and measures to maintain the security or integrity of our website and services, including to prevent or stop an attack on our computer systems or networks, investigate possible wrongdoing in connection with the website and services, enforce our terms.
• Legal Rights. We use information to exercise, establish or defend our legal rights, or to protect your vital interest or those of any other person.
• Improve Our Products and Services. For example, we may conduct surveys, analytics, and troubleshooting.
• Compliance with Law. We process information to comply with legal and regulatory requirements and with applicable industry self-regulatory, audit and security requirements.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

3. How We Disclose Personal Information

We may share Personal Information to the following categories of recipients:

• Within our Company and Group. We may share information with our employees, officers, directors, partners, affiliates, direct or indirect subsidiaries, our ultimate holding company and any other subsidiary of that holding company, including their respective shareholders, directors, officers, affiliates, employees, contractors, agents, partners, insurers, and attorneys or representatives.
• Service Providers. We may share your information with service providers that help us operate our business such as accountants, administrators, attorneys, auditors, compliance and IT consultants, custodians, SAAS (software as a service) providers, analytics providers, hosting providers and other third parties engaged by us to assist with or support our provision of services.
• Authorities and Law enforcement Agencies Worldwide. We will share information where we reasonably believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
• Transactions. We may share information as part of a transaction, with third parties that require the personal information to execute the contemplated transactions.

We may also disclose Personal Information to third parties in the following circumstances:

• In the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).
• If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of us, our clients, or others, including to defend ourselves from legal claims.

4. Cookies and Online Tracking Technologies

We may use cookies and other online tracking technologies (collectively, “cookies”), which may be provided by our vendors, for purposes of session replay. These cookies record your interactions with our website, including mouse movements, text, and other information, associated with your visit to our website. This information is used to help us improve our website and better provide you with information you are interested in when you visit our website. They may be set by us or by third party providers whose services we have added to our pages. This information is used to help us improve our website and better provide you with information you are interested in when you visit our website.

We may also use third party service providers like Google and MailChimp to collect such information. For example, Google utilizes the data collected to track and examine the use of this application, prepare reports on its activities and share them with other Google services. Google may use the data collected to contextualize and personalize the ads of its own advertising network. To learn more about Google’s privacy practices, click here.

We may use the following types of cookies on the website:

• Essential Cookies. These cookies are essential for the website to function properly and enable basic features such as page navigation and access to secure areas of the site. You can set your browser to block or alert you about these cookies, but some parts of the website may not work properly.
• Performance/Analytics Cookies. We may use cookies that collect information about your use of our Sites and allow us to count visits and traffic sources so we can measure and improve the performance of our website. They help us to know which pages are the most and least popular and see how visitors move around the website. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our website and will not be able to monitor its performance.
• Functional Cookies. These cookies collect information about your choices on the website you are visiting and enable the website to provide enhanced functionality and personalization such as your choice of language or region. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
• Targeting Cookies. We may use cookies to display advertisements or display targeted promotions or to manage our advertising. They collect information about your activities on websites. These cookies may be set through our website by our advertising providers. They may be used by those companies to build a profile of your interests and show you relevant adverts on other websites. They do not store directly personal data but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
• Social Media. We may use certain social media cookies that are set by a range of social media services that we have added to the website to enable you to share our content with your friends and networks on those platforms. They can track your browser across other websites and build up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies, you may not be able to use or see these sharing tools.

a. How to Control Cookies

You can control our use of cookies through your internet browser or through third party tools:

• Cookie Management Tool. You can customize or change your cookie preferences at any time by accessing our cookie management system, including, where applicable, withdrawing any consent you provided at any time. You can access the management system through the Consent Preferences icon available on the website.
• Internet Browser. You can also control cookies through most browsers by changing your cookie settings. These settings will typically be found in the “options” or “preferences” menu of your browser.
• Third Party Tools. Various third-party tools exist that can help you manage cookies. For additional information you can also visit http://www.allaboutcookies.org/ where you will find information on cookie management and blocking.

5. How We Protect Personal Information

We use reasonable and appropriate technical and organizational measures designed to protect your Personal Information. As effective as modern security practices are, no physical or electronic security system is entirely secure. We cannot guarantee complete security, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the Internet. Any transmission of Personal Information is at your own risk.

6. How Long We Keep Personal Information

We keep Personal Information for as long as reasonably necessary for the purposes described in this Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting or other purposes), whichever is the longer.

7. International Data Transfers

Details on the specific cookies we use can be found in the management system through the Consent Preferences icon available on the website.

The Personal Information that we collect or receive about you may be transferred to and processed by recipients who are located in a jurisdiction where the level of data protection may not be equivalent to the level of protection applicable at your location. Where local laws require, we will take steps to ensure that any transfer of Personal Information outside of the originating jurisdiction is carefully managed to protect your privacy rights and ensure that adequate safeguards are in place. If your location lacks international data transfer instructions or standard forms from the local supervisory authority, we may use other legally acceptable mechanisms from other jurisdictions.

8. Children

The website is intended for general audiences and is not directed at children. We do not knowingly collect Personal Information from children. If you are a parent or guardian and believe we have collected Personal Information of a child, please contact us at legal@atumlabs.xyz.

9. Links to Other Websites

The website may contain links to third-party websites. Any access to and use of such third-party websites is not governed by this Privacy Policy, but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.

10. Your Rights and Choices

Depending on how you interact with us, you have certain rights regarding your Personal Information. Please note any rights described in this Privacy Policy are subject to exemptions and other limitations under applicable law.

Depending on where you are located and applicable law, you may have the following rights:

• Right to Know and Access. You may have the right to know and access the Personal Information we have collected about you.
• Right to Delete. You may have the right to request that we delete the Personal Information we have collected about you, subject to certain legal exceptions.
• Right to Correct. You may have the right to request that we correct any inaccurate Personal Information we have collected about you.
• Data Portability. At your request, we will provide you with your Personal Information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Information to another controller.
• To Object to or Restrict Processing. You may object to or restrict processing of your personal information so long as we are processing such personal information on the legal basis of pursuing our legitimate interest, under appliable data protection laws.
• Right to No Discrimination. You will not receive any discriminatory treatment by us for the exercise of your privacy rights as outlined in this Privacy Policy.
• Right to Contact Supervisory Authority: You may have the right to complain to the relevant supervisory authority.

To exercise these rights, please use the information below in How to Contact Us and include “Rights Request” in the subject line.

11. Marketing Communications

In addition to the rights listed above, you have certain controls on our marketing communications. We may use your Personal Information to inform you about our products or services that we believe will be of interest to you and/or to provide you with our newsletter. We may contact you by email, post, or telephone, or through other communication channels and we may use cookies or other online tracking as described in our Cookies and Online Tracking Technologies. In all cases, we will respect your preferences regarding how you would like us to manage marketing activity with you. You can manage your marketing preferences in several ways:

• Direct Marketing. You can ask us to stop direct marketing at any time. You can ask us to stop sending email marketing by clicking on the “unsubscribe” link you will find on all the email marketing messages we send you. Alternatively, you can contact legal@atumlabs.xyz. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g., email).
• Cookies and Online Tracking. You can change the way your browser manages Cookies, which may be used to deliver online advertising and by using the options explained in Cookies and Online Tracking Technologies.

12. Additional Disclosures for EU and UK

The GDPR imposes certain obligations on us, as a data controller, and grants certain rights to data subjects located in the EEA or UK (“data subject,” “you” or “your”). Information related to your rights and how to exercise them are described above in Your Rights and Choices.

a. Roles

The GDPR and UK GDPR distinguish between organizations that process Personal Information for their own purposes (known as “controllers”) and organizations that process Personal Information on behalf of other organizations (known as “processors”). We act as a controller with respect to Personal Information collected as you interact with the website or where you are using or purchasing our Services.

b. Lawful Basis for Processing

As described above in Why We Collect Personal Information, we process Personal Information for various purposes. Our lawful bases for processing such personal data include:

• Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. Our legitimate interests include performing our investment advisory business (or those of a third party), detecting potential conflicts of interest in the provision of our services, and supporting our interactions with you.
• To comply with certain legal and regulatory requirements.
• Depending on the circumstances, we may need to process your personal data for the performance of a contract to which you are a party, or related pre-contractual steps.
• With your consent, as required by the GDPR (as applicable).

13. California Shine the Light

Under California’s “Shine the Light” law (Civil Code section 1798.83), California customers can ask certain businesses to share details about their practices related to disclosing or sharing personal information. If you want to find out how this might apply to you and what rights you might have, just email us at legal@atumlabs.xyz and include “Shine the Light Request,” in the subject line.

14. Do Not Track

Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.

15. Updates to this Privacy Policy

If we make changes to this Privacy Policy, we may notify you by updating it with a “Last Updated” date at the top. The most current version of our Privacy Policy will be available on our website.

16. How to Contact Us

For any privacy-related inquiries, please contact us at: legal@atumlabs.xyz.