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Privacy Policy

Last updated: December 15, 2025

Portico Atlas LLC (“Portico Atlas”, “we”, “us”, “our”) is
committed to protecting the privacy, confidentiality, and security
of personal data processed in the course of our operations. This
Privacy Policy explains how we collect, use, disclose, and protect
personal data in accordance with the General Data Protection
Regulation (EU) 2016/679 (“GDPR”) and other applicable data
protection laws.

1. Data Controller

For the purposes of the GDPR, the data controller is:

Portico Atlas LLC
Registered address: [Insert Wyoming registered address]
Email:
info@porticoatlas.com

2. Scope of This Policy

This Privacy Policy applies to personal data collected and
processed through:

  • Our website
  • Assessment and engagement processes
  • Due diligence, KYC, and AML procedures
  • Communications with clients, prospective clients, and
    professional counterparties

This policy applies regardless of whether data is provided
electronically, in writing, verbally, or through third-party
service providers.

3. Categories of Personal Data

Depending on the nature of the engagement, we may process the
following categories of personal data:

3.1 Identification and Contact Data

  • Name
  • Contact details
  • Nationality and residency
  • Identification documents
  • Proof of address

3.2 Professional, Business, and Financial Data

  • Company and ownership information
  • Corporate records
  • Jurisdictional and operational details
  • Banking and transactional information

3.3 Due Diligence and Compliance Data

  • KYC and AML documentation
  • Source-of-funds and source-of-wealth information
  • Risk assessments and eligibility determinations

We do not collect personal data indiscriminately or for purposes
unrelated to our professional activities.

4. Purposes of Processing

Personal data is processed strictly for purposes that may include:

  • Conducting assessments and determining eligibility
  • Performing due diligence and compliance checks
  • Designing and implementing cross-border structures
  • Coordinating with professional advisers and service providers
  • Complying with legal, regulatory, and risk-management
    obligations
  • Maintaining internal records, audit trails, and controls

We do not use personal data for advertising or unrelated marketing
activities.

5. Lawful Bases for Processing

Personal data is processed on one or more of the following lawful
bases under Article 6 GDPR:

  • Performance of a contract or steps taken prior to entering into
    a contract
  • Compliance with legal obligations, including AML and regulatory
    requirements
  • Legitimate interests, including risk management, fraud
    prevention, and professional standards
  • Consent, where required and obtained

Certain personal data is mandatory for assessment and engagement.
Failure to provide required information may prevent us from
proceeding.

6. Special Category Data

Where required, we may process special category data under Article
9 GDPR solely for purposes permitted by law, including compliance
with legal obligations and the establishment, exercise, or defence
of legal claims.

7. Disclosure of Personal Data

Personal data may be disclosed, on a need-to-know basis, to:

  • Regulated professional advisers (legal, tax, compliance)
  • Financial institutions and escrow providers
  • Third-party service providers supporting operational or
    compliance functions
  • Public authorities or regulators where required by law

We do not sell, rent, or trade personal data.

8. International Data Transfers

Due to the cross-border nature of our work, personal data may be
transferred outside the European Economic Area.

Where international transfers occur, appropriate safeguards are
implemented in accordance with GDPR requirements, including
contractual protections or legally recognised transfer mechanisms.

9. Data Security

We implement appropriate technical and organisational measures to
protect personal data against unauthorised access, loss, misuse,
alteration, or disclosure.

While no system can guarantee absolute security, we take
reasonable and proportionate steps consistent with the sensitivity
of the data we process.

10. Data Retention

Personal data is retained only for as long as necessary to:

  • Fulfil the purposes for which it was collected
  • Comply with legal, regulatory, and professional obligations
  • Support audit, compliance, and risk-management requirements

Retention periods vary depending on the nature of the data and
applicable obligations.

11. Data Subject Rights

Subject to applicable law, individuals have the right to:

  • Request access to their personal data
  • Request rectification of inaccurate or incomplete data
  • Request erasure of personal data
  • Request restriction of processing
  • Object to processing based on legitimate interests
  • Request data portability where applicable
  • Withdraw consent where processing is based on consent

Requests may be subject to identity verification and legal
limitations.

12. Complaints

Individuals have the right to lodge a complaint with a supervisory
authority, particularly in the EU Member State of their habitual
residence, place of work, or place of alleged infringement.

13. Third-Party Services

Our website and processes may reference or link to third-party
services, including escrow or verification providers. We are not
responsible for the privacy practices of third parties. Their
privacy policies apply independently.

14. Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes
in law, regulation, or operational practice. The most current
version will be published on our website.

15. Contact

Questions regarding this Privacy Policy or the processing of
personal data may be directed to:

Portico Atlas LLC
Email:
info@porticoatlas.com