SIA "Atlas aerospace" Personal Data
Processing Policy

1. This document (hereinafter – the Policy) has been prepared to inform the natural persons specified herein about the activities performed with their personal data by SIA “Atlas Aerospace”, registration number 40103911104, legal address: Ulbrokas iela 19A, Rīga, LV-1021, Latvia (hereinafter – Atlas Aerospace).

2. Atlas Aerospace specializes in the manufacturing of professional unmanned aerial vehicles.

3. Scope of the Policy

3.1.
This Policy governs the processing of personal data that applies to all Atlas Aerospace:
3.1.1. current clients who are natural persons using Atlas Aerospace services;
3.1.2. potential clients who are natural persons with no established relationship with Atlas Aerospace but who are interested in Atlas Aerospace services;
3.1.3. former clients, including those whose contractual obligations are not fulfilled or who have agreed to receive commercial communications after contract termination;
3.1.4. client representatives, including contact persons and legal representatives;
3.1.5. users of information systems and websites;
3.1.6. individuals participating in marketing activities.
3.2. This Policy provides information on how Atlas Aerospace processes personal data in connection with its offered Services, using its internal resources including information systems, social networks, and websites:
🔗 https://www.atlasuas.com/
🔗 https://www.linkedin.com/company/atlas-dynamics---drone-based-solutions/
🔗 https://www.youtube.com/channel/UC-hjgaNqLOQEPC6GMpEGlkA
3.3. To provide information about personal data processing, Atlas Aerospace supplies the details below in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (hereinafter – the Regulation).
The Controller of the personal data referred to in this Policy is Atlas Aerospace.

Atlas Aerospace contact details regarding data protection matters:

📍 Address: Ulbrokas iela 19A, Rīga, LV-1021, Latvia
📞 Phone: +371 661 000 46
📧 Email: info@atlasdynamics.eu

4. Personal Data and the Purposes of Processing

4.1.
When processing personal data, Atlas Aerospace processes the following categories of data according to the purposes of processing:
4.1.1. Identification Data
4.1.1.1. Name, surname;
4.1.1.2. Personal identification number or other ID number;
4.1.1.3. Date of birth;
4.1.1.4. Nationality.
4.1.2. Contact Information Data
4.1.2.1. Declared and actual residential address;
4.1.2.2. Phone number;
4.1.2.3. Email address;
4.1.2.4. Communication language.
4.1.3. Contract and Financial Data
4.1.3.1. Contents of concluded contracts and information about their execution;
4.1.3.2. Bank details and payment information;
4.1.3.3. Accounting and billing data;
4.1.3.4. Tax and accounting documents as required by legislation.
4.1.4. Professional Activity Data
4.1.4.1. Information about workplace, position, or professional status;
4.1.4.2. Representation rights (e.g., company representatives in contracts).
4.1.5. Communication Data
4.1.5.1. Content of communication with the company (emails, phone calls, applications, complaints, responses);
4.1.5.2. Customer service history.
4.1.6. Security Data
4.1.6.1. IT system access data (username, passwords, IP address, log files);
4.1.6.2. Video surveillance recordings (if video monitoring is performed in company premises or territory).
4.1.7. Marketing and Service Improvement Data
4.1.7.1. Information about services used and usage habits;
4.1.7.2. Cookie data and website usage information;
4.1.7.3. Consent to receive commercial communications and record of withdrawal.
4.1.8. Special Category Data (processed only in exceptional cases)
4.1.8.1. Health data (e.g., for occupational safety or insurance purposes, only based on legislation or explicit consent);
4.1.8.2. Other sensitive data only when permitted by law and necessary for a specific purpose.

4.2. Atlas Aerospace processes personal data:
4.2.1.
For the provision of Atlas Aerospace services:
4.2.1.1. for the conclusion and execution of contracts and for the provision of Services;
4.2.1.2. for settlements and payment execution;
4.2.1.3. for financial accounting.
4.2.2. To improve the quality of Atlas Aerospace Services and for business planning:
4.2.2.1. for customer consultations;
4.2.2.2. for notifying and informing customers about Atlas Aerospace updates;
4.2.2.3. for statistical and business analysis (including business planning);
4.2.2.4. for ensuring recordkeeping and accounting processes, including information archiving.
4.2.3. For security and legal protection purposes:
4.2.3.1. for preventing and investigating personal data processing violations;
4.2.3.2. for ensuring security within Atlas Aerospace premises;
4.2.3.3. for providing information to state authorities and other entities.
4.2.4. For compliance with legal requirements or the exercise of Atlas Aerospace’s legal rights in accordance with laws and regulations:
4.2.4.1. for providing information to state and municipal institutions;
4.2.4.2. for providing information to other third parties, including state and municipal authorities, if required by law and necessary for the performance of the concluded contract.

5. Legal Basis for Personal Data Processing
5.1.
Atlas Aerospace processes personal data in the following cases:
5.1.1. when a contract has been or will be concluded between you and Atlas Aerospace. In this case, Atlas Aerospace processes personal data for contract performance or to take steps at your request before concluding a contract;
5.1.2. when processing is required to fulfill legal obligations applicable to Atlas Aerospace under laws and regulations. This includes obligations to provide information to state authorities, comply with accounting documentation requirements, and archive documents;
5.1.3. when processing is necessary for the legitimate interests of Atlas Aerospace or a third party.
5.1.3.1. Legitimate interests are rights permitted under applicable laws, including those arising from contracts concluded with Atlas Aerospace. Atlas Aerospace’s legitimate interests include:
5.1.3.1.1. ensuring the development of its business activities;
5.1.3.1.2. developing and improving its Services;
5.1.3.1.3. maintaining positive relationships with Clients;
5.1.3.1.4. preventing potential financial and organizational risks;
5.1.3.1.5. mitigating legal risks (e.g., retaining personal data for a defined period to resolve potential disputes);
5.1.3.1.6. preventing security risks;
5.1.3.1.7. ensuring fulfillment of contractual obligations;
5.1.3.1.8. protecting its financial interests;
5.1.3.1.9. retaining and attracting Clients;
5.1.3.1.10. maintaining website operations, developing and implementing improvements, and ensuring client usability;
5.1.3.1.11. maintaining social media profiles, developing and improving them, and ensuring client usability;
5.1.3.1.12. performing marketing activities, including service promotion and distribution;
5.1.3.1.13. protecting its rights through authorized and competent institutions.

5.2. Within this Policy, specific data processing activities of Atlas Aerospace may be subject to a NIDA (Assessment of Impact on Data Subject’s Interests) or a DPIA (Data Protection Impact Assessment) if required under GDPR Article 35.

5.3. When using cloud services (e.g., Microsoft 365, Google Workspace), the respective providers are ensured compliance with GDPR requirements, and a necessary impact assessment is performed.

5.4. When automated decision-making or artificial intelligence tools are used (for example, profiling for marketing purposes), Atlas Aerospace ensures human involvement, transparency, and the right of the data subject to object to such processing.

6. Recipients and Sources of Personal Data

6.1.
Atlas Aerospace may disclose personal data to the following recipients:
6.1.1. Atlas Aerospace employees and authorized persons processing the data specified in this Policy on behalf of Atlas Aerospace, within their competence and work duties;
6.1.2. persons involved in providing Atlas Aerospace services and business development:
6.1.2.1. IT system consultants and service providers;
6.1.2.2. postal and delivery service providers;
6.1.2.3. banks and other payment and financial service providers, as well as intermediaries ensuring information exchange between Atlas Aerospace and financial institutions;
6.1.2.4. public information service providers (e.g., media);
6.1.2.5. insurance service providers;
6.1.2.6. legal service providers;
6.1.2.7. debt collection agencies and credit information bureaus;
6.1.2.8. security and protection service providers.
6.1.3. authorized persons with whom Atlas Aerospace communicates to ensure service delivery or protect its interests, as well as for other purposes mentioned in this Policy;
6.1.4. law enforcement agencies, other state authorities, public bodies, and similar entities, if deemed necessary or mandatory under applicable legislation (e.g., law enforcement institutions, State Revenue Service, notaries).

6.2. Additionally, Atlas Aerospace may receive personal data from third parties, such as:
6.2.1. Atlas Aerospace business partners;
6.2.2. Atlas Aerospace clients.

7. Retention Period of Personal Data

7.1.
Personal data are processed to the extent reasonably necessary, depending on the specific purpose of processing, and in accordance with applicable legal requirements.

7.2. Atlas Aerospace stores personal data:

7.2.1. for as long as required or permitted by applicable laws;
7.2.2. while a contract is in force (if the data are related solely to that contract);
7.2.3. as long as necessary to achieve the processing purposes specified in Section 4 of this Policy.

8. Transfer of Personal Data Outside the European Union

8.1.
If Atlas Aerospace transfers personal data outside the European Union, it ensures that internationally recognized protection mechanisms are applied, including EU Standard Contractual Clauses (SCC) or the EU–U.S. Data Privacy Framework (2023).

9. Data Subject (Your) Rights in the Context of Personal Data Processing

9.1.
Your rights regarding the Personal Data mentioned in this Policy:
9.1.1. Right of Access:
9.1.1.1. to obtain confirmation from Atlas Aerospace as to whether or not Personal Data concerning you are being processed;
9.1.1.2. if Atlas Aerospace processes your Personal Data, you have the right to access those data and receive information about the purposes of processing, categories of Personal Data, categories of recipients, retention period, your data protection rights, the source of the data, and automated decision-making (if any). This information can be reviewed in this Policy.
9.1.1.3. Additional information about your Personal Data can be requested using the Atlas Aerospace contact details provided in Section 3 and its subsections of this Policy.
9.1.1.4. If the request is submitted electronically, Atlas Aerospace will provide the information in electronic form.
9.1.2. Right to Rectification:
9.1.2.1. you have the right to request Atlas Aerospace to correct inaccurate Personal Data.
9.1.3. Right to Erasure:
9.1.3.1. you have the right to request Atlas Aerospace to delete your Personal Data if:
9.1.3.2. you withdraw your consent to processing (noting that withdrawal does not affect processing carried out while the consent was valid);
9.1.3.3. the Personal Data are no longer necessary for the purposes stated in Section 4 of this Policy;
9.1.3.4. the Personal Data have been unlawfully processed;
9.1.3.5. the Personal Data must be erased to comply with legal requirements.
9.1.3.6. The right to erasure does not apply where Atlas Aerospace has a legal obligation to process the data, or where processing is necessary for archiving, for reasons of public interest or statistical purposes, or for the establishment, exercise, or defense of legal claims.
9.1.4. Right to Restrict Processing:
9.1.4.1. you have the right to request Atlas Aerospace to restrict processing if:
9.1.4.1.1. you contest the accuracy or lawfulness of the data (restriction applies while the objection is being assessed);
9.1.4.1.2. processing is unlawful but you oppose erasure;
9.1.4.1.3. Atlas Aerospace no longer needs the data, but you need them to establish, exercise, or defend legal claims.
9.1.5. Right to Object:
9.1.5.1. you may object at any time to processing of your Personal Data based on the legitimate interests and consent described in Section 5. Atlas Aerospace may continue processing despite an objection if it demonstrates compelling legitimate grounds overriding your interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.
9.1.6. Right to Withdraw Consent:
9.1.6.1. you may withdraw your consent where consent is the legal basis for processing;
9.1.6.2. to withdraw consent, use the Atlas Aerospace contact details provided in Section 3;
9.1.6.3. if you withdraw consent, Atlas Aerospace may limit provision of services where those depend on the relevant Personal Data;
9.1.6.4. withdrawal does not affect processing carried out while consent was valid.
9.1.7. Right to Data Portability:
9.1.7.1. you have the right to receive the Personal Data you provided to Atlas Aerospace in a structured, commonly used, machine-readable format and to request that such data be transmitted to another controller (service provider) if processing is based on a contract or on consent.
9.1.8. Right to Lodge a Complaint:
9.1.8.1. you may lodge a complaint with Atlas Aerospace and with the Latvian supervisory authority, the Data State Inspectorate, if you believe your data protection rights have been violated. Before contacting the Inspectorate, please contact Atlas Aerospace first — we care about your Personal Data protection and will provide the necessary support.
9.1.8.2. To exercise the above rights, use the Atlas Aerospace contact details in Section 3, unless otherwise specified in this section.

10. Processing of Personal Data via Cookies

10.1.
To improve the functionality of Atlas Aerospace’s website and tailor it to your usage habits, as well as to obtain statistics on user actions, Atlas Aerospace uses cookies.
10.2. Cookies are small text files stored on your computer or mobile device when you visit a website. When you next visit Atlas Aerospace’s site, the browser remembers your actions and performs some of them for you (e.g., language selection).
10.3. The following types of cookies are used to improve functionality and ease of use:
10.3.1. Session cookies — stored only while the browser is open; they help remember choices on the previous page so you don’t need to re-enter information.
10.3.2. Persistent cookies — identify you as a unique user and help remember information about actions you performed previously when you return to the site.
10.3.3. Tracking cookies — used for website traffic statistics.
10.3.4. Third-party cookies — e.g., Google cookies used to serve advertisements and optimize marketing communications.
10.4. If you wish to restrict (disallow) or delete cookies, you can do so via your browser settings or otherwise. More information: https://www.aboutcookies.org/ or http://www.allaboutcookies.org/manage-cookies/.
10.5. Atlas Aerospace also provides an appropriate mechanism for users to consent to or refuse non-essential cookies, in accordance with GDPR and the ePrivacy Directive.
10.6. If cookies are restricted (disallowed), some website services may not function fully. The website may contain links to other sites. If you use these links, note that Atlas Aerospace does not control those sites and cannot be responsible for the protection and confidentiality of any information you provide when visiting them; this notice does not apply to those sites. Please exercise caution and review the respective site’s privacy notice.

11. Policy Updates
This Policy is reviewed at least once a year or immediately after significant changes in legislation or company operations to ensure compliance with current data protection requirements.

SIA “ATLAS AEROSPACE” 2025
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