Privacy

Privacy Policy

Last updated: February 10, 2026

Atlas Capital Infrastructure LLC ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our post-close servicing platform for structured finance.

1. Information We Collect

1.1 Information You Provide

  • Account Information: Name, email address, phone number, job title, and organization details when you register or are invited to the platform.
  • Payment Credentials: Wire instructions, bank account information, routing numbers, and related financial data that you submit for verification purposes.
  • Transaction Records: Information about payment schedules, distributions, and related transaction data entered into the platform.
  • Communications: Messages, support requests, and other communications you send to us.

1.2 Information Collected Automatically

  • Usage Data: Pages visited, features used, actions taken, and time spent on the platform.
  • Device Information: IP address, browser type, operating system, and device identifiers.
  • Audit Logs: Records of all actions taken within the platform for compliance and security purposes.

2. How We Use Your Information

We use the information we collect to:

  • Provide, maintain, and improve our platform services
  • Process and verify payment credentials
  • Facilitate transaction record-keeping and audit trails
  • Send notifications about account activity, credential verification, and transaction updates
  • Send optional SMS notifications for critical alerts (with your consent)
  • Respond to your requests and provide customer support
  • Ensure platform security and prevent fraud
  • Comply with legal obligations and regulatory requirements

3. SMS Communications

If you opt in to SMS notifications, we will send text messages to the phone number you provide for critical platform alerts, including:

  • Credential verification requests
  • Payment cutoff reminders
  • Phone number verification codes

Consent: SMS notifications are disabled by default. You must explicitly enable them in your notification settings and verify your phone number to receive SMS messages.

Opt-Out: You can disable SMS notifications at any time in your notification settings or by removing your phone number from your account.

Message Frequency: Message frequency varies based on platform activity. Standard message and data rates may apply.

4. Data Security

We implement industry-standard security measures to protect your information:

  • Encryption: Payment credentials and sensitive data are encrypted at rest using AES-256 encryption.
  • Transport Security: All data in transit is protected using TLS 1.2 or higher.
  • Access Controls: Role-based access controls limit data access to authorized users only.
  • Audit Trails: All platform actions are logged for security and compliance purposes.
  • Two-Party Verification: Payment credentials require verification by multiple parties before activation.

5. Information Sharing

We may share your information with:

  • Other Platform Users: Information necessary for credential verification and transaction coordination is shared with relevant project participants (trustees, servicers, investors) according to their roles and permissions.
  • Service Providers: Third-party vendors who assist us in operating the platform, including cloud hosting, email delivery, and SMS services.
  • Legal Requirements: When required by law, regulation, legal process, or governmental request.
  • Business Transfers: In connection with a merger, acquisition, or sale of assets.

We do not sell your personal information to third parties.

6. Data Retention

We retain your information for as long as necessary to provide our services and comply with legal obligations:

  • Account Data: Retained while your account is active and for a reasonable period thereafter.
  • Transaction Records: Retained according to applicable financial record-keeping requirements (typically 7+ years).
  • Audit Logs: Retained for compliance and security purposes as required by law.

7. Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate information
  • Request deletion of your information (subject to legal retention requirements)
  • Opt out of certain data processing activities
  • Export your data in a portable format

To exercise these rights, please contact us at privacy@atlasci.io.

8. Cookies and Tracking

We use essential cookies to operate the platform, including session management and security features. We do not use third-party advertising or tracking cookies.

9. Children's Privacy

Our platform is designed for business use and is not intended for individuals under 18 years of age. We do not knowingly collect information from children.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the "Last Updated" date. Your continued use of the platform after changes constitutes acceptance of the updated policy.

11. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

Atlas Capital Infrastructure LLC
Email: privacy@atlasci.io