Privacy Policy

Last Updated: 05 January 2023

Atumra Group (“Atumra,” “we,” “our,” or “us”) values your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at atumragroup.com, and in the course of our investment and business operations.

Please read this policy carefully. By accessing or using our website, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy.

1. Information We Collect

We may collect the following types of personal and non-personal information:

A. Information You Provide to Us

  • Contact details (e.g., name, email address, phone number)

  • Business affiliation and job title

  • Information submitted through contact forms or email inquiries

  • Subscription preferences for updates or newsletters

B. Information We Collect Automatically

When you access our website, we may automatically collect:

  • IP address and device type

  • Browser type and version

  • Pages visited and referring URL

  • Cookies and tracking technologies (see Section 5)

C. Information from Third Parties

We may obtain additional data from third-party sources (e.g., data providers, public databases, or professional platforms) to enhance our records.

2. How We Use Your Information

We use the information we collect to:

  • Operate, maintain, and improve our website and services

  • Communicate with you about your inquiries or our offerings

  • Comply with legal and regulatory obligations

  • Analyze website traffic and usage trends

  • Detect and prevent fraud or misuse

  • Manage internal recordkeeping and data integrity

3. Disclosure of Information

We do not sell your personal information. We may disclose information in the following circumstances:

  • Service Providers: To third-party vendors who support our operations under confidentiality obligations

  • Legal Requirements: When required by law, regulation, subpoena, or court order

  • Business Transfers: In the context of a merger, acquisition, restructuring, or sale of assets

  • With Consent: When you give us explicit permission to do so

4. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your information against unauthorized access, loss, misuse, or alteration. However, no method of transmission or storage is 100% secure.

5. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance website functionality and gather analytics. You can adjust your browser settings to refuse cookies or alert you when they are being used. Please note that disabling cookies may affect your user experience.

6. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as required by law, regulation, or contractual obligation.

7. International Data Transfers

As a global firm, we may transfer your personal information across jurisdictions. Where applicable, we ensure that such transfers are made in accordance with recognized legal safeguards, such as Standard Contractual Clauses or adequacy decisions under GDPR.

8. Your Rights and Choices

Depending on your jurisdiction, you may have rights including:

  • Access to the personal data we hold about you

  • Correction of inaccurate or outdated data

  • Deletion of your personal data (“right to be forgotten”)

  • Objection to or restriction of certain data processing

  • Portability of your data in a structured, commonly used format

To exercise any of these rights, please contact us at contact@atumragroup.com.

9. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites.

10. Additional Information

Request Verification and Additional Rights

To ensure the privacy and security of personal data, we may take reasonable steps to confirm your identity before fulfilling any request related to your Personal Information. Depending on the nature of your request—such as access, correction, or deletion—we may ask you to verify key details such as your address, date of birth, phone number, email address, nationality, CV information, or information about prior transactions. For certain sensitive requests, such as disclosure of specific data elements, we may also require a signed statement affirming, under penalty of perjury, that you are the rightful data subject.

Non-Discrimination and Fees

You will not be treated unfairly for exercising your data rights under applicable law. However, where allowed, we may charge a reasonable fee to process complex or repetitive requests.