Privacy Policy

1. Introduction

Atrium Data, Inc. ("the Company," "we," "us," or "our") operates the website atruimdata.com (the "Service"). Atrium provides private-credit fund operations teams with a platform for reconciling loan tapes, tracking covenants, attributing cash flows, and generating investment committee reports. In the course of operating the Service and communicating with prospective and active clients, the Company collects certain personal information. This Privacy Policy explains what information we collect, how we use it, how we protect it, and the rights available to you.

We are based at 195 Broadway, Floor 24, New York, NY 10007 and can be reached at [email protected].

2. Information We Collect

2.1 Information You Provide

We collect information you submit directly, including:

• Contact details (name, work email, phone number) when you complete a demo request form, send an inquiry, or correspond with us directly;
• Fund or firm information you choose to share (organization name, role, approximate portfolio size, operational context);
• The content of messages you send us through the site's contact form or by email.

The data Atrium processes as a service provider -- that is, the fund portfolio data, loan tapes, position records, covenant terms, and cash flow data that clients submit to the Atrium platform -- is governed by the data processing terms in each client's service agreement, not by this Policy. This Policy addresses personal information collected through atruimdata.com and direct communications with the Company.

2.2 Information Collected Automatically

When you visit atruimdata.com, we automatically collect limited technical information:

• IP address and approximate location (city or region level);
• Browser type, operating system, and device class;
• Pages visited, referring URLs, and time on page;
• Cookie and similar identifiers (see Section 5 and our Cookie Policy).

2.3 We Do Not Knowingly Collect Children's Data

atruimdata.com is a financial data platform directed at business professionals, not children under 13. We do not knowingly collect personal information from children. If you believe a child has provided us information, contact [email protected] and we will delete it.

3. How We Use Information

We use the information we collect to:

• Respond to demo requests, inquiries, and direct communications from prospective and active clients;
• Schedule and conduct onboarding sessions, tape format reviews, and reconciliation demonstrations;
• Operate, maintain, and improve the marketing website and the Atrium platform;
• Send service updates and (with your consent where required) relevant communications about the Atrium platform;
• Detect, investigate, and prevent fraudulent or unauthorized access;
• Comply with legal and regulatory obligations applicable to the Company.

No training on client data. The Company does not use fund portfolio data, loan tape content, or any other client-submitted data to train, improve, or develop machine learning models or AI systems. This is a contractual commitment in every client service agreement.

We do not sell personal information for monetary value. Where applicable state law treats certain advertising arrangements as a "sale" or "share," see your state's section below.

4. Sharing of Information

We share personal information only with:

• Service providers acting on our behalf (such as hosting infrastructure, email delivery, and usage analytics providers) under contractual confidentiality and data-handling terms;
• Regulatory authorities or law enforcement when required by law or necessary to protect the rights, safety, or property of the Company or others;
• A successor entity in the event of a merger, acquisition, or asset sale, subject to this Policy.

We do not sell personal information to third parties. Fund and firm information you share with us in connection with a demo or sales conversation is used only to serve that conversation and is not shared outside the Company for marketing purposes.

5. Cookies and Tracking

We use cookies and similar technologies to operate the site, remember preferences, and measure usage patterns. For full details, including how to manage your cookie preferences, see our Cookie Policy. atruimdata.com operates on a notice-only consent model for US visitors: non-essential cookies may load by default. You may opt out through the cookie banner or your browser settings.

6. Data Retention

We retain personal information only as long as needed for the purposes described in this Policy, to satisfy legal or accounting obligations, or to resolve disputes. Demo request and inquiry records from contacts who do not become active clients are retained for up to 24 months after the last interaction, then purged. Server access logs are retained for 90 days, after which they are aggregated and anonymized. Client account records are retained for the duration of the service relationship and for a period thereafter consistent with applicable financial record-keeping requirements.

7. Security

The Company implements administrative, technical, and physical safeguards designed to protect personal information, including TLS 1.3 encryption in transit, AES-256 encryption at rest, dedicated per-client data isolation on AWS us-east-1, and least-privilege access controls with mandatory multi-factor authentication. The platform infrastructure is designed with SEC Rule 17a-4 record-keeping requirements in mind -- all reconciliation runs and data access events are logged with a full audit trail. No system is perfectly secure and we cannot guarantee absolute security, but fund data confidentiality is a core design constraint, not an afterthought.

8. Your General Rights

Depending on your jurisdiction, you may have rights including the right to access, correct, or delete personal information we hold about you, and the right to limit certain processing. To make a request, email [email protected]. We will respond within the timeframe required by applicable law, and in any event within 45 days.

9. New York Residents

New York does not currently have a comprehensive consumer privacy statute. As a matter of policy, the Company extends the following baseline rights to all U.S. residents regardless of state of residence.

9.1 Baseline Rights

• Right to Know: request the categories of personal information we have collected about you.
• Right to Delete: request deletion of personal information you have provided.
• Right to Correct: request correction of inaccurate personal information.
• Right to Opt Out of Marketing: unsubscribe from marketing emails or opt out via the link in each marketing message.

9.2 How to Exercise

Email [email protected] with a description of your request and enough detail to allow us to verify your identity. We respond within 45 days.

9.3 Sector-Specific Rights

If you are protected by federal sector laws (such as GLBA with respect to financial institution data), those laws may give you additional rights with respect to data covered by them. Clients operating registered investment advisers or broker-dealers remain responsible for their own recordkeeping obligations under applicable SEC and FINRA rules; Atrium's platform infrastructure is designed to support those obligations but does not substitute for each client's own compliance program.

9.4 California Visitors

If you are a California resident, you may also exercise the rights granted under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, and the right to opt out of sale or sharing. The Company does not sell personal information and does not "share" personal information for cross-context behavioral advertising.

To submit a CCPA / CPRA request, email [email protected] with the subject line "California Privacy Request."

10. Changes to This Policy

We may update this Policy from time to time. Material changes will be reflected by a new "Last updated" date and, where appropriate, a notice on the Service. Continued use of the Service after the effective date of the updated Policy constitutes your acknowledgment of the changes.

11. Contact

Questions, requests, or complaints about this Policy can be sent to: