Ensuring the flow of the world’s critical minerals

Legal

Privacy Policy

Effective date:

At Atana Elements Inc. and its subsidiaries, including Atana Elements (UK) Limited (“the Company,” “we,” “us,” “our”), we respect your privacy and are committed to protecting your personal data. This Privacy Policy applies to visitors to our website, users of our services, and individuals interacting with our global team.

1. Important Information and Data Controllers

Data Controllers

  • UK & EU Visitors and Customers: Atana Elements (UK) Limited acts as the primary Data Controller for individuals located in the United Kingdom and the European Economic Area (EEA).
  • US & Global Visitors: Atana Elements Inc. (Delaware, USA) acts as the Data Controller for US residents and overall corporate operations.
  • European Establishments: For EEA residents, our offices in Berlin, Germany and Warsaw, Poland serve as local contacts for data protection matters.

Data Protection Lead: We have appointed a Data Protection Lead. You may contact our privacy team at GRC@atanaelements.com.

We collect personal data only when permitted by law. Below are the categories of data we collect and our lawful bases under UK/EU GDPR:

  • Identity & Contact Data: Name, email address, job title, company name, phone number, and physical business address.
    • Legal basis: Performance of a contract or Legitimate Interests (to communicate with business partners and respond to inquiries).
  • Technical & Usage Data: IP address, device type, browser details, operating system, pages visited, and the date and time of each request. Our website is hosted on Firebase Hosting, a service provided by Google, whose servers process this technical data on our behalf to deliver the site and keep it secure. Our corporate systems run in a Microsoft-hosted environment.
    • Legal basis: Legitimate Interests (securing and optimizing our website) and Consent (for analytics cookies; see “Cookies and analytics” below).
  • Environmental Impact Data: Environmental, chemical usage, and sustainability data collected from commercial operations, including information on water usage, chemical consumption, and waste management.
    • Legal basis: Compliance with legal and environmental reporting obligations.
  • Data Collected from Third Parties: We may also receive information about you from third-party sources, such as business partners, affiliates, and publicly available sources.

Cookies and analytics

Our website uses cookies. Essential cookies are needed for the website to function. Non-essential cookies are set only with your consent, which you can give or refuse through the cookie banner shown on your first visit; your choice is stored on your device.

Analytics cookies (Google Analytics). If you accept, we use Google Analytics 4, a web analytics service provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (“Google”), to understand how visitors use our website: the pages viewed, how visitors reach the site, approximate location (country or city), and device and browser type. Google Analytics sets the cookies _ga (distinguishes visitors) and _ga_<container-id> (keeps session state), each expiring after 2 years. Google Analytics 4 does not log or store IP addresses. We have disabled Google Signals and advertising features and do not link Google Analytics to Google Ads, so this data is not used for advertising and is not combined with Google account data. Usage data is retained in Google Analytics for no longer than 14 months. Google processes this data on our behalf as our processor under Google’s data processing terms; see Google’s privacy policy and how Google uses information from sites that use its services.

  • Legal basis: Consent (Article 6(1)(a) UK/EU GDPR and the UK and EU ePrivacy rules on cookies).

Changing your choice. You can withdraw or change your consent at any time using the “Cookie settings” link in the footer of every page, which clears your stored choice and shows the banner again; if you then reject, the analytics cookies are deleted and Google Analytics stops. You can also block or delete cookies in your browser settings, or install Google’s opt-out browser add-on to opt out of Google Analytics on every website. We do not use cookies for cross-context behavioral advertising.

3. How We Use Your Information

  • Service Delivery: To provide, manage, and improve our technology and services.
  • Business Communications: To respond to inquiries, provide updates, and communicate regarding partnerships.
  • Legal Compliance: To meet legal and regulatory requirements, including those related to environmental impact reporting.
  • Marketing: To send promotional materials related to our business, including new technologies, projects, or partnerships, only if you have opted in to such communications.

4. Disclosure & Sharing of Personal Data

We share personal data with third parties only in accordance with applicable laws:

  • Service Providers & Sub-processors: Third-party IT support, cloud hosting providers (Google Firebase for this website; Microsoft for our corporate environment), and payment processors.
  • Analytics Services: Google Analytics (Google Ireland Limited, with Google LLC in the United States as its sub-processor), only if you have accepted analytics cookies.
  • Corporate Group Entities: Shared internally among Atana Elements Inc. (US) and its subsidiaries for management, operational, and strategic oversight.
  • Legal Authorities & Business Transfers: To comply with statutory obligations, court orders, or during corporate restructuring, mergers, or asset sales.

No Sale of Personal Data

We do not sell your personal information for monetary value, nor do we “share” personal data for cross-context behavioral advertising.

5. International Data Transfers (UK, EU, and USA)

Data collected in the UK or EEA is primarily stored within UK and EU data centers. Because Atana Elements is a global organization, data may be accessed by our parent company in the United States.

To safeguard cross-border transfers, for transfers not covered by an adequacy decision we implement EU Standard Contractual Clauses (SCCs) and the UK International Data Transfer Agreement (IDTA) to ensure protection equivalent to UK/EU standards.

Google Analytics data may be processed on Google servers in the United States. Google LLC is certified under the EU-US Data Privacy Framework, including its UK Extension, and Google’s data processing terms additionally incorporate the EU Standard Contractual Clauses.

6. Data Security & Retention

  • Data Security: We maintain strict security measures to prevent unauthorized access, loss, or alteration. Technical controls include Multi-Factor Authentication (MFA), device encryption enforced via Microsoft Intune, firewalls, and strict “Least Privilege” access roles. However, no system is 100% secure, and we cannot guarantee the absolute security of your data.
  • Data Retention: We retain personal data only as long as necessary to fulfill the purposes for which it was collected, including legal, tax, accounting, or environmental compliance reporting.

7. Your Rights (UK, EU, US, and Argentina)

A. UK & EU Residents (GDPR)

Under UK and EU GDPR, you have the right to:

  • Access, Correct, or Erase your personal data.
  • Restrict or Object to our processing of your data.
  • Data Portability and the right to Withdraw Consent at any time.

Supervisory Authorities: You have the right to lodge a complaint with your local data protection authority:

  • UK: Information Commissioner’s Office (ICO) — ico.org.uk
  • Germany: Berliner Beauftragte für Datenschutz und Informationsfreiheit — datenschutz-berlin.de
  • Poland: Urząd Ochrony Danych Osobowych (UODO) — uodo.gov.pl

B. US Residents (California CCPA/CPRA, Delaware DPDPA)

If you reside in California, Delaware, or other applicable US states, you have the right to:

  • Know & Access: Request details regarding the categories and specific pieces of personal information collected, used, or disclosed over the past 12 months.
  • Deletion & Correction: Request deletion or correction of your personal data, subject to statutory exemptions.
  • Opt-Out of Sale or Sharing: We do not sell your personal information for monetary value, nor do we “share” personal data for cross-context behavioral advertising.
  • Non-Discrimination: Exercise your rights without receiving discriminatory treatment.
  • Sensitive Personal Information: We do not collect or process sensitive personal information to infer characteristics about consumers.

C. Argentine Data Protection Regime

The data subject has the right to exercise, free of charge, the right of access, rectification or deletion of the personal data pursuant to Section 14, subsection 3 and Section 16 of Law No. 25,326 (as amended), by communicating to GRC@atanaelements.com.

The AGENCY FOR ACCESS TO PUBLIC INFORMATION, Control Body of Law No. 25,326, has the power to deal with complaints and claims filed by those affected in their right due to breach of the Personal Data legislation in force.

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

Our website may contain links to external sites that are not operated by us. We are not responsible once you leave our website, as we do not have any control over the privacy practices of third-party websites, and we encourage you to review their privacy policies before interacting with them.

9. Children’s Privacy

Our services are strictly intended for business operations and are not directed to individuals under 13 years of age. We do not knowingly collect personal data from children. If you believe we have collected such information, please contact us immediately at GRC@atanaelements.com.

10. Changes to This Policy & Contact Information

We may update this policy periodically to reflect operational or regulatory changes. Material changes will be posted here with an updated effective date at the top of this page.

Contact us: To exercise your privacy rights or submit questions, please email us at:

Atana Elements
Email: GRC@atanaelements.com