Privacy Policy
Effective Date: 02 Jun 2025 • Last Updated: 03 Jun 2025
This Privacy Policy (the “Policy”) explains how Atto Trading Technologies LLC (“Atto,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information obtained through our public website located at https://atto-trading.com and any sub-pages (collectively, the “Site”).
By accessing or using the Site, you agree to this Policy.
1. Scope
This Policy applies only to information collected through the Site. It does not apply to information collected offline or through other websites or services that do not link to this Policy. When you leave the Site—e.g., by clicking “Apply” on a job posting and being redirected to Workable.com—the privacy practices of that destination site will govern.
2. Personal Information We Collect
We collect the following categories of personal information (“PI”):
Category: Identifiers
Examples: Name, email address, IP address
Sources: You (contact form), cookies
Purpose(s): P1, P2
Disclosed To: Service providers (hosting, email); legal recipients
Category: Internet / Network Activity
Examples: Device type, browser, pages viewed, time on page
Sources: Cookies, reCAPTCHA
Purpose(s): P2
Disclosed To: Service providers (analytics, security)
Category: Geolocation (coarse)
Examples: Country or region inferred from IP address
Sources: Cookies
Purpose(s): P2
Disclosed To: Service providers (analytics)
Purpose Definitions:
P1: Respond to inquiries and provide customer support
P2: Operate, secure, and improve the Site, including debugging, analytics, fraud prevention, and cookie management
We do not sell or share personal information for targeted advertising. We also do not intentionally collect sensitive personal information as defined under applicable U.S. state laws.
See §7 for data retention periods.
3. How & Why We Use Personal Information
We use your personal information for the following purposes:
P1 – To respond to your inquiries, provide support, and communicate with you.
P2 – To operate, secure, and improve the Site, including debugging, analytics, and fraud prevention.
You may withdraw consent or object to processing at any time (see §9). We do not operate any financial incentive or loyalty programs tied to personal information.
4. Cookies & Similar Technologies
On your first visit, a cookie banner appears allowing you to accept or reject non-essential cookies. By default, only strictly necessary cookies (e.g., reCAPTCHA, load-balancing) are set.
We honor the Global Privacy Control (GPC) signal and provide a persistent footer link labeled “Your Privacy Choices”, which opens the cookie-preference center and opt-out form for data “sale,” “sharing,” or “targeted advertising” under CPRA, FDBR, and similar state laws.
5. Sharing & Disclosure
We may share your personal information as follows:
Service Providers: For hosting, analytics, email delivery, and site security. These vendors are contractually prohibited from selling or sharing PI and may only process it under our written instructions in compliance with applicable law, including FDBR §501.711(5).
Legal Compliance & Protection: Where required by law, regulation, or legal process, or to protect the rights, property, or safety of Atto or others.
Business Transfers: If we are involved in a merger, acquisition, or asset sale, your personal information may be transferred under confidentiality agreements.
We do not sell your personal information and do not use it for cross-context behavioral advertising.
6. Security & Breach Notification
We maintain industry-standard administrative, technical, and physical safeguards to protect your information (e.g., encryption in transit, role-based access, regular patching, and incident response protocols). However, no system is completely secure.
Breach Notice: In the event of a data-security incident affecting personal information, we will notify affected individuals and regulators as required by CPRA §1798.150, FDBR, and other applicable laws.
7. Data Retention
We retain personal information for as long as necessary to fulfill the purposes outlined in this Policy or as permitted by law. Specifically:
Job applicant and contact-form submissions: Retained indefinitely for recruiting and talent relationship management, unless you request deletion.
Analytics / cookie identifiers: 14 months (Google Analytics default)
Server logs: 12 months
We may also retain backups or archival copies for legal, regulatory, or legitimate business purposes. When no longer needed, personal information is securely deleted or anonymized.
8. Your Privacy Rights & How to Exercise Them
You may request the following:
Access, correction, or deletion of your PI
A portable copy of your data
Opt-out of sale/sharing/targeted advertising
Restriction of processing of sensitive data (if applicable)
To exercise these rights, email [email protected] with the subject line “Privacy Request.”
We will respond within 45 days and may extend once for an additional 45 days if necessary.
You may appeal a denial by replying to our response within 60 days. We will respond to your appeal within 45 days.
You may also designate an authorized agent to submit a request on your behalf. We may request proof of your identity and agent’s authority.
8.1. Florida Privacy Rights (Fla. Stat. §§501.701–.722)
This section applies to Florida residents and governs if it conflicts with any other part of this Policy.
Your Rights
Florida residents have the right to:
(i) Confirm and access their PI
(ii) Correct inaccuracies
(iii) Delete PI
(iv) Obtain a portable copy
(v) Opt out of:
(a) Sale of PI
(b) Targeted advertising
(c) Profiling producing legal or similar significant effects
We do not currently engage in any of the above (a–c). We also do not intentionally process “sensitive personal information.” If we ever do, we will seek your opt-in consent.
How to Exercise Your Rights
Email [email protected] with the subject line “Florida Privacy Request.”
We will verify your identity and respond within 45 days (one 15-day extension may apply). Appeals must be submitted within 60 days; we will respond within 60 days.
We will not discriminate against you for exercising your FDBR rights.
9. Children’s Privacy
The Site is not directed to children, and we do not knowingly collect personal information from anyone under 18. If you believe we may have collected such information, please contact us so we can delete it.
10. Third-Party Sites & Services
The Site may link to third-party websites (e.g., Workable.com). We are not responsible for their privacy practices. Please review their policies before submitting your personal information.
11. California Privacy Rights
California residents: please see our California Privacy Notice to learn about your rights under California law.
12. Changes to This Policy
We may update this Policy from time to time. We will post the revised version on this page and update the “Last Updated” date above. Your continued use of the Site after a change constitutes acceptance of the updated Policy.
13. Contact Us
Atto Trading Technologies LLC – Privacy Team
Email: [email protected]
Mailing Address: 5966 South Dixie Hwy, Ste. 300 Miami, FL, 33143, USA
If any term of this Policy conflicts with rights provided under applicable law, those statutory rights will control.