Purpose

Atalanta Technologies (“Atalanta” or “Enterprise”) has conducted an initial review of the personally identifiable information, defined below (“PII”), that the Enterprise, through its website (the “Site”), receives, generates, accesses, collects, stores, processes, transmits and purges of users of the Site in the ordinary course of Atalanta’s business activities. On the basis of that review, Atalanta has developed this Website Privacy Policy, effective April 10, 2026.

This Website Privacy Policy has been designed to serve two purposes:

• first, to explain the ways in which Atalanta, through the Site, receives, generates, accesses, stores, processes, and transmits (“Manage”)PII of users of the Site; and,
• second, to establish the standard of care that Atalanta shall endeavor to meet to protect PII it Manages of users of the Site (“Site User(s)”).

This Website Privacy Policy will be reviewed annually by Atalanta and updated, as needed, to reflect lessons learned from the review, including an assessment of the scope and care of the Enterprise’s handling and protection of Site Users’ PII during the last 12-month review period, and where required by applicable federal or state law, an identification of the categories of PII the Enterprise has collected about Site Users in the preceding 12-month period.

This Website Privacy Policy has been tailored to the operations and activities of Atalanta, the narrow scope of user interaction with its Site, the fact that Atalanta may describe its products or services on the Site, but does not conduct any purchases or sales on the Site, and, as a result, Atalanta’s very limited exposure to and handling of Site Users’ PII.

Applicability

This Website Privacy Policy applies to all of the PII that the Enterprise Manages from or about Site Users as of the Effective Date (or the date of the most recent annual update). Atalanta does not, at present, have any subsidiary or any corporate affiliate and thus this Website Privacy Policy does not apply to any other business entity.

Policy

I. Definitions.

“Personally Identifiable Information” or “PII” means any information relating to an identified or identifiable individual that can be used to identify such individual or to distinguish or trace an individual’s identity or that can be used to uncover or steal the individual’s identity, either alone or when combined with other information that is linked or linkable to a specific individual, including, but not limited to name, postal address, email address or other online contact information (such as an online user ID), telephone number, date of birth, social security number (or its equivalent), driver’s license number (or other government-issued identification number), account information (including financial account information), payment card data (primary account number, expiration date, service code, full magnetic stripe data or equivalent on a chip), personal identification number, access code, password, security questions and answers, security tokens used for authentication, birth or marriage certificate, health insurance or medical information, or any other unique identifier or one or more factors specific to the individual’s physical, physiological, mental, economic or social identity, whether such data is in individual or aggregate form and regardless of the media in which it is contained.

“Process” or “Processing” means any operation or set of operations performed upon PII, whether or not by automatic means, such as creating, collecting, procuring, obtaining, accessing, recording, organizing, storing, adapting, altering, retrieving, consulting, using, disclosing or destroying the data.

II. Unaffiliated Site Users Whose PII Atalanta May Collect and Process.

Individual Site Users who are not affiliated with Atalanta (“Unaffiliated Site Users”) and who visit and elect to extend their use of the Site (at URL https://atalanta.tech) by initiating one or more communications with Atalanta through the Site (e.g., to express interest in being employed by Atalanta) may have their PII collected, stored, processed and transmitted by Atalanta, and Atalanta will Manage their PII in accordance with this Website Privacy Policy.

III. Kinds of Unaffiliated Site Users that Atalanta May Collect and Use.

The Unaffiliated Site Users’ PII that Atalanta Manages is limited to the PII such Site Users elect to provide Atalanta when initiating communications with Atalanta through the Site and in subsequent follow-up communications with Atalanta.

Examples of such PII that Atalanta may Manage include:

• First and last names
• Job titles or roles
• Office or personal e-mail addresses
• Office or personal phone numbers
• Text messaging app numbers (e.g., WhatsApp, Signal)
• Country and state of residence
• Data to verify that the communication originates with a human, not a bot or agentic AI

IV. Purposes for Which Atalanta May Manage PII of Unaffiliated Site Users.

Atalanta may Manage PII of Unaffiliated Site Users for the following purposes:

• Considering and responding to communications from individuals interested in employment with Atalanta and who initiated (and may have followed up) correspondence with Atalanta through the Site;
• Generally operating the Enterprise’s business, including responding to communications initiated by a Site User (for purposes other than seeking employment with Atalanta); and
• In connection with an actual or proposed M&A involving the Enterprise, subject to the Site User’s consent as explained below.

V. Sharing of Unaffiliated Site Users’ PII by Atalanta

1. With A Party or Parties Conducting an M&A Due Diligence Review. Atalanta may share Unaffiliated Site Users’ PII and, under agreements of confidentiality, grant access to such PII to parties to a contemplated corporate transaction (e.g., merger, acquisition, or joint venture (collectively, “M&A Deal”)) to conduct a due diligence review of Atalanta (“Due Diligence Review”); but access to, and provision of, such PII for a Due Diligence Review shall be subject to the following conditions and safeguards:
   1. Atalanta’s sharing of an Unaffiliated Site User’s PII in a Due Diligence Review shall be conditioned on such Site User’s prior written consent, which Atalanta will endeavor to obtain by written communication with such user (“DDR Consent”);
   2. If a Site User declines to provide his or her DDR Consent, withholds it, or does not otherwise provide it (as may happen if their contact information has changed and not been updated with Atalanta), such Site User shall be deemed by Atalanta to have not consented (“Non-Consenting Site Users”).
   3. Atalanta shall not share a Non-Consenting Site User’s PII with a party or parties conducting a Due Diligence Review.
   4. To protect the PII of Non-Consenting Site Users from inadvertent disclosure in the Due Diligence Review, Atalanta shall ensure such PII is erased or otherwise purged from Atalanta’s readily accessible storage media and shall not grant the Due Diligence Review party or parties access to Atalanta’s non-readily accessible, backup storage media where a copy of such PII may be stored;
   5. If a Site User provides Atalanta with a DDR Consent, the Site User may withdraw such consent at any time in a signed written statement (“Withdrawn Consent”)and sending it to us (see “How to Contact Atalanta” section below); however please be aware that a Withdrawn Consent will not be effective until Atalanta receives it (“Receipt Date”) and will not affect the lawfulness of Atalanta’s sharing of such Site User’s PII in the Due Diligence Review prior to such Receipt Date.
   6. If the Receipt Date of a Withdrawn Consent precedes Atalanta’s sharing of the relevant Site User’s PII in the Due Diligence Review, Atalanta shall take steps to prevent the sharing of such PII; if the Receipt Date, however, occurs after Atalanta has shared the relevant PII, Atalanta will make a good faith effort to retrieve or cause copies of the shared PII erased or purged from the data sets in the Due Diligence Review, but Atalanta shall not be responsible if erasing or purging such PII would be impracticable.
   7. The PII of Site Users who have provided Atalanta a DDR Consent can be shared by Atalanta with a party or parties to the Due Diligence Review, but shall be used by such party or parties solely for the Due Diligence Review and in accordance with this Website Privacy Policy, or as otherwise permitted under an applicable agreement to limit its use and protect it.
      
2. With Third-Party Service Providers. Atalanta may share PII of Unaffiliated Site Users with third parties who perform services for or on behalf of the Enterprise (“Service Providers”), for the limited purpose of carrying out such services.This includes, without limitation, third parties that assist in managing the Enterprise,hosting or administering the Enterprise’s website(s) or other systems, maintaining or analyzing the Enterprise’s data or providing it cybersecurity safeguards, or in otherwise providing Site services to the Enterprise and Site Users. The kinds of PII that Atalanta may share with its Service Providers are identified above in Part III.

VI. Mandatory Disclosure Required By California Law.

Atalanta makes the following disclosures and representations in order to comply with California law and relating to users of the Site who are residents of, or households within California.¹ In this disclosure, instead of the terms “Site” “PII,” the terms used are “Website” and “Personal Information” (including “Sensitive Personal Information”) as defined under applicable California laws and regulations and this disclosure addresses the relevant persons by the terms “You” and “Yours”.

• Atalanta does not sell Your Personal Information.
• Atalanta does not offer substantive financial incentives for the collection or sale of Your Personal Information.
• Atalanta will not discriminate or retaliate against You if you exercise your privacy rights under California law.
• Atalanta does not subject Your Personal Information to any fully-automated decision making that produces legal or similarly significant effects without suitable safeguards and an appropriate legal basis that may include Your consent.
• Atalanta does not re-identify de-identified or anonymized Personal Information.
• Atalanta does not use or disclose Sensitive Personal Information for purposes other than those permitted by California law.
• Atalanta does not use Sensitive Personal Information to “infer characteristics” about You.
• Atalanta’s collection and use of Your Personal Information are described in detail within this Website Privacy Policy.
• Atalanta’s retention of Your Personal Information is described in detail below in the “Retention of Personal Information or PII” section of this Website Privacy Policy.

Personal Information Collected. This Website will enable You to decide whether to provide a limited set of Personal Information about You, including Your first and last name, email or other digital address, and the name of Your employer (e.g., name of a company, entity, government agency).

This Website provides a Notice of Collection on the Home Page (or on the link(s) for You to enter Your Personal Information and that recommends You review this Website’s Terms of Use, Website Privacy Policy, and Correction/Deletion Procedure Information before entering Your Personal Information for collection, storage, and processing by Atalanta so that You will know what collection, storage, and processing activities Atalanta will perform with Your Personal Information before You consent to such activities by providing Your Personal Information to the Website.

This Website will explain what use(s) Atalanta will make of the Personal Information that You provide and what benefits (e.g., products, services, responsive communications) You can reasonably expect to receive in exchange for providing Your Personal Information to Atalanta via this Site.

This Site:

• will not track Your use of this Site,
• will insert cookies on the digital device Your uses to access this Website,
• will not input Your Personal Information into an artificial intelligence (“AI”) model or generative AI (“GenAI”)model,
• will not sell or share any Personal Information that Your provide with any third parties without Your prior written consent and without disclosing to You the categories of businesses to whom, if You consent, it will be sold or shared and the commercial purpose for such sale or sharing² and without giving You the right and a mechanism to “opt-out” of such sale or sharing,³
• will not use a “dark pattern”⁴ to obtain the Your consent to collect Your Personal Informationand to store and process such information, and
• will not collect any Personal Information that You do not voluntarily provide to this Website.

This Site contains on the Home Page conspicuous links to the Site’s Terms of Use and to this Website Privacy Policy, which contains Correction/Deletion Procedure information, explained briefly below.

User Right to Correct and Delete Personal Information: This Website provides You with procedures to correct and delete Personal Information that You provided and that, as a result, Atalanta collected, stored, and may have started to process; those procedures are set forth below in the sections on “Consent and Withdrawal of Consent” and “Updating PII and Personal Information.”

VII. Consent and Withdrawal of Consent.

Atalanta may share a Site User’s PII in accordance with any express consent that a Site User or Site User’s authorized agent give Atalanta that is specific to the purposes of the processing that the Site User will be informed about at the time Atalanta requests such consent (e.g. a request for consent to collect PII an Site User decides to upload to the Site). The relevant Site User does not have to give such consent, and if he or she does not give their consent, Atalanta will not share their PII.

If the Site User does give consent, the Site User may withdraw it at any time by contacting us (see “How to Contact Atalanta” section below), however please be aware that such withdrawal will not affect the lawfulness of PII collected and processed prior to the date Atalanta receives the relevant Site User’s withdrawal of consent.

VIII. Updating PII and Personal Information.

If any of the PII or Personal Information that Atalanta has collected or that a Site User has provided to Atalanta (e.g. by uploading it to the Website) happens to change, for example if the Site User’s email address or phone number changes, or if a relevant Site User wishes to cancel any request made of Atalanta concerning his or her PII or Personal Information, or if a Site User becomes aware that we have any inaccurate PII or Personal Information about such Site User, please contact Atalanta as specified in the “How to Contact Atalanta” section below.Atalanta shall not be responsible for any losses arising from any inaccurate, inauthentic, unauthorized, deficient, or incomplete PII or Personal Information that an individualhas provided to Atalanta through this Website.

IX. Legal Requirements and Law Enforcement.

Atalanta may disclose (or grant access to) selected PII of Site Users in the following circumstances:

• to government authorities or courts when Atalanta believes in good faith that the applicable law requires it;
• at the request of government authorities conduct an audit or investigation;
• pursuant to a court order, subpoena, or discovery request in litigation;
• to verify or enforce compliance with Atalanta agreements or policies and applicable laws and regulations;
• or whenever Atalanta believes disclosure is necessary to limit Atalanta’s legal liability or to protect or enforce the rights, interests, or safety of Atalanta, its customers, contractors, Site Users, or other third parties;
• Atalanta reserves the right to report to law enforcement agencies any activities that Atalanta, in good faith, believe to be unlawful and would require the disclosure of PII to substantiate and make such reports actionable for law enforcement agencies.

X. Retention, Location of Processing, and Purging of Personal Information or PII.

All collection, storage, and processing of Site User PII by Atalanta takes place in the United States.

Atalanta stores Site User PII for periods depending on the categories of individuals to whom it relates and the purposes for which Atalanta needs to retain it, and that are set forth in its corporate retention schedules (“Helpful PII”).

At the end of the third calendar year after the retention periods for certain categories of PII expired (“Unhelpful PII”), Atalanta will schedule within the following 60 days a purge from readily accessible storage the Unhelpful PII in a manner that makes it irrecoverable by Atalanta. But Atalanta may retain a copy of Unhelpful PII in the routine backup of the Enterprise’s from which it is not readily accessible and will not be made readily available or shared or sold to any third party.

Helpful PII and its retention periods, includes:

• PII of Site Users Who Provided It to the Website.PII of Site Users that voluntarily uploaded it to the Site – will be retained until the earlier of: (i) a written request by the Site User to purge all of his or her PII stored by Atalanta, (ii) Atalanta’s decision to purge certain categories of Site User PII, or (iii) within sixty (60) days of the end of the calendar year in which the Site User’s PII will have been stored by Atalanta for two (2) years (e.g., if an individual uploaded his or her PII to the Site in March of 2026, Atalanta will purge it within 60 days after the end of 2028).

XI. Security.

Atalanta has implemented appropriate technical and organizational safeguards to protect Site Users’ PII from loss, misuse, unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the collection, storage, and processing and the nature of the Site Users’ PII.

XII. Choice.

If a Site User’s PII covered by this Website Privacy Policy is to be used for a new purpose that is materially different from that for which the PII was originally collected or subsequently authorized, or is to be disclosed to a non-agent third party in a manner not specified in this Policy, Atalanta will provide each Site User whose PII is affected with an opportunity to choose whether to have his or her PII so used or disclosed. Requests to opt out of such uses or disclosures of PII should be sent to Atalanta as specified in the “How to Contact Atalanta” section below.

XIII. Data Integrity and Purpose Limitation.

Atalanta shall only process Site Users’ PII and Personal Information in a way that is compatible with, and relevant for, the purpose for which it was collected or authorized by the relevant Site User.To the extent necessary for those purposes, Atalanta shall take reasonable steps to ensure that PII is accurate, complete, current and reliable for its intended use.

XIV. Website Privacy Policy Changes.

Atalanta may revise this Website Privacy Policy from time to time, which will become effective as of its posting on this Website.Atalanta will use Site Users’ PII and Personal Information in a manner consistent with the version of this Website Privacy Policy in effect at the time Atalanta collected it or that an individual provided it, unless Atalanta receives the individual’s consent to the new or revised Website Privacy Policy.

XVI. How to Contact Atalanta.

If a Site User has any questions concerning this Website Privacy Policy, or wants to exercise any of the Site User’s rights as a data subject, or to pursue any action (such as withdrawing consent or requesting correction or deletion of collected Personal Information or PII) covered by this Website Privacy Policy, or wishes to communicate to Atalanta any complaints regarding the manner in which Atalanta handles or protects Site Users’ PII or Personal Information, the Site User may contact Atalanta at this email address: privacy at atalanta dot tech

[1] Applicable regulations include Title 11. Law Division 6, California Privacy Protection Agency (“CCPA”), Chapter 1, California Consumer Privacy Act Regulations, as amended most recently and effective as of 2023, https://cppa.ca.gov/regulations/pdf/20230329_final_regs_text.pdf, including §7004 Requirements for Methods for Submitting CCPA Requests and Obtaining Consumer Consent, §7010 Overview of Required Disclosures, and §7012 addressing the required Notice of Collection.

[2] As required by CPPA § 7011(c)(1).

[3] As required by CPPA § 7011(c)(2).

[4] Under CPPA, §7004(c), a user interface is a “dark pattern” if “the interface has the effect o substantially subverting or impairing user autonomy, decisionmaking, or choice.” Moreover, “A business’s intent in designing the interface is not determinative in whether the user interface is a dark pattern, but a factor to be considered.If a business did not intend to design the user interface to subvert or impair user choice, but the business knows of and does not remedy a user interface that has that effect, the user interface may still be a dark pattern.Similarly, a business’s deliberate ignorance of the effect of its user interface may also weigh in favor of establishing a dark pattern.”