Privacy Policy

This Privacy Policy explains how Atrean Inc. (“Atrean,” “we,” “us”) handles personal information when you visit atrean.com, request access, use the Atrean platform, or otherwise interact with us.

If your organization has a signed agreement with Atrean, that agreement governs how we process Customer Data and controls where it conflicts with this Policy. Use of the Service is also subject to our Terms of Service.

We handle information in two capacities.

• Customer Data. The financial records, documents and other information our customers load into or connect to the platform. We process it on the customer’s behalf and only on its instructions, as a processor or service provider. The customer, typically a family office or wealth firm, decides what goes in and who can see it.
• Everything else. Website visits, access requests, account and billing details, and correspondence with us. Here we decide how information is used and are responsible for it as a controller.

Information you give us

• Access requests: name, work email, organization, organization type, assets-under-management band, and anything you add in your message.
• Accounts: name, email, role, sign-in credentials and preferences.
• Support and correspondence: the content of emails, calls and support requests.
• Billing: billing contacts and payment details for the subscribing organization.

Customer Data

Depending on how a customer configures the platform: capital call and distribution notices, capital account and custodial statements, entity and ownership structures, holdings and transactions, documents stored in the vault, and queries submitted to platform features. Customer Data can include personal information about principals, beneficiaries, trustees and advisors.

Information collected automatically

Device and browser type, IP address, pages viewed, referring URLs, timestamps and in-platform activity logs. In-platform activity logs are treated as Customer Data.

Information from third parties

Data from custodians, fund administrators, general partners and aggregators that a customer authorizes us to connect to, and business contact details from referrals and events.

• Provide, operate and maintain the platform and the features a customer enables.
• Authenticate users, enforce entitlements and keep the service secure.
• Respond to access requests, arrange demonstrations and provide support.
• Send service, security and billing notices. You can opt out of marketing emails at any time.
• Understand and improve the website and the service using aggregated usage information.
• Meet legal, regulatory and contractual obligations, and establish or defend legal claims.

We do not sell personal information, and we do not share it for cross-context behavioral advertising.

AI features process a customer’s data on that customer’s behalf, within that customer’s environment.

• We do not use Customer Data to train AI models.
• AI features are designed to respect the access permissions a customer sets.
• Model providers we use are bound by confidentiality and data protection obligations.

We share personal information only:

• With subprocessors that host, secure, support and deliver the service, subject to appropriate confidentiality and data protection obligations.
• At a customer’s direction, such as with its advisors, administrators or auditors.
• When required by law, subpoena or court order.
• To protect the rights, safety or property of Atrean, our customers or others.
• In a merger, acquisition or sale of assets, subject to this Policy and to existing customer agreements.
• With your consent.

We use administrative, technical and organizational measures designed to protect information, including keeping each family’s data separate. See Security for more.

No system is perfectly secure, and we cannot guarantee the security of any information. If an incident affects your information, we will provide notice as required by law and our agreements.

• Customer Data is retained, returned and deleted as set out in the customer’s agreement with Atrean.
• Other information is kept only as long as needed for the purposes described in this Policy.
• Legal requirements. We may keep some records longer where the law requires or permits it.

Depending on where you live, you may have the right to access, correct, delete or receive a copy of your personal information, to object to or restrict certain processing, and to withdraw consent. This includes residents of California and other U.S. states with privacy laws. We will not discriminate against you for exercising these rights.

To make a request, email admin@atrean.com. We will verify your identity before acting. If your information is held as a customer’s Customer Data, we will refer your request to that customer. You may use an authorized agent, and you may complain to your local data protection authority.

Atrean is based in the United States and stores and processes information there. Where information is transferred across borders, we take steps intended to comply with applicable law.

We use cookies and similar technologies to operate the website and platform, keep sessions secure and understand how the website is used. You can block or delete cookies in your browser settings; some features may not work without them.

Atrean is a business service and is not directed to anyone under 18. We do not knowingly collect information from minors. Customer Data may include records about minor beneficiaries, which we process only on the customer’s instructions.

We may update this Policy from time to time. Changes take effect when posted here with a new effective date.

Questions about this Policy or our privacy practices go to admin@atrean.com. Atrean Inc., New York, NY.