Document ref: PRIV-001
What Atlas collects, why it is collected, who else touches it and where it sits. Every processor is named and every cookie is listed, because a notice that says “trusted partners” tells a reader nothing they can act on.
In effect from 11 September 2026
Atlas is operated from Dubai and is the controller of the personal data described here. The registered entity name, trade licence number and registered address are published on this page as soon as the licence is issued, rather than described in advance.
For anything in this notice, including a request to see, correct or delete what is held about you, write to hello@atlasfractional.com. A written answer comes from a named person, within 30 days.
This notice is written for Federal Decree-Law 45 of 2021 on the Protection of Personal Data, the UAE personal data law. Where a reader is covered by another regime, the rights below are offered on the same terms.
Ten separate things, kept separate. The first one is public by design and that is the point of it. Two of them describe a person who did not hand them over — the appraisal and the reference call — and those are the two worth reading twice.
Held: Name, photograph, prior seats and employers, sector, category, jurisdiction, stated weekly capacity, links offered as proof, and the date the verification was carried out.
Why: This is the register. A leader writes it, Atlas approves it, and it is public so a company can read and check it before speaking to anyone. Visibility is what a leader is here for.
Seen by: Public to anyone, including search engines and answer engines.
Held: Name, work email, company, and whatever is written in the message.
Why: To pass the enquiry to the leader and to make the introduction. It is used for that enquiry and not added to a marketing list.
Seen by: Seen by Atlas and by the leader the enquiry names.
Held: Email address and a hashed password, plus a session record while signed in. The password itself is never stored. Where a leader signed in through LinkedIn, the account also holds the identifier LinkedIn issues for them, which is how Atlas knows the profile is theirs. Atlas receives a name, an email address and a photograph from LinkedIn, and nothing else: no connections, no messages, no work history.
Why: So a leader can edit their own page and nobody else can.
Seen by: Never public.
Held: Whatever the document itself contains. A CV usually carries a career history, employers and dates, and often a personal email, a telephone number and a home city. A LinkedIn export carries the same, plus skills and education. Atlas stores the file as it was sent and, separately, the handful of fields read out of it to fill the registration form.
Why: To save a leader typing their own history in twice, and so the reference call has the leader's own account of their record to check against. The file is read by a set of rules on the server. It is not sent to any third party and it is not used to train anything.
Seen by: Never public, and never sent to a company. Stored encrypted in Google Cloud Storage in europe-west1, on a private bucket with public access blocked. A leader can read it back or delete it from their dashboard at any time, and deleting it deletes the file. It is removed when a leader account is removed.
Held: The seat, the jurisdiction, the cadence, the budget band, who the leader would report to, why the seat is being opened now, what would count as working ninety days in, who signs it off and by when, and the name, role and email address of the person filing it. A brief saved half-finished is held the same way as a sent one.
Why: To answer it. Atlas reads every brief itself and comes back with names or with a straight answer that the seat is not covered. The budget and the reasoning are what make a shortlist worth having rather than a search of job titles.
Seen by: Never public. Read by Atlas, and the parts of it a leader needs are given to the leaders named on it. A company's identity is not given to a leader before the company agrees to it.
Held: The company name, and for each person on the account a name, a role, an email address and a hashed password. The password itself is never stored.
Why: So a company can see where its briefs stand, who was named and why, what was agreed, and the one invoice, without digging through email. An account holds more than one person because the person who files a brief is often not the person who watched the work.
Seen by: Never public. An account is not needed to read the register.
Held: Who took the seat, the cadence, the dates, what the company said the seat had to fix in its own words, the agreed retainer the fee is calculated from, and the dates of the invoice and the payment. When the engagement ends, the company files an appraisal: its verdict against each of those outcomes, whether it would engage the leader again, and a written account of what the leader actually did, signed with the author's name and role.
Why: An engagement is the record of something that happened between two other parties, and it is what an invoice and a check-in date hang on. The appraisal is how a company tells Atlas whether an introduction was worth making.
Seen by: Never public, in whole or in part, in any form that identifies a leader. The leader named in an appraisal reads it in full, with the company's name and the author's name on it, and may file one reply that Atlas does not edit and does not remove. Neither statement can be changed afterwards by anybody, including Atlas.
Held: The referee's name, their organisation, the date of the call, and the answer they gave to one question: would you engage this person again for the same seat.
Why: It is Stage V of the published standard. A register that says it checks and does not is worth nothing.
Seen by: Never public and never shown to a company. The referee is named by the leader, who confirms the referee has agreed to be contacted, and Atlas says at the start of the call who it is, who named them, and what the record is for. A leader may ask what their referee said.
Held: A signed agreement or an invoice, as the file itself.
Why: So the company can find it later. A twelve-month term matters eleven months after anyone last thought about it, and an agreement that exists only in one person's inbox has effectively gone.
Seen by: Never public. Stored on the same private bucket as a CV, and served only through a link Atlas signs after checking the session, which expires in fifteen minutes.
Held: Pages viewed, referrer, approximate location and device, through Google Analytics 4.
Why: To know which pages are read and which are not. No profile is built about an individual reader, and nothing is sold.
Seen by: Aggregate.
A leader page is published on two bases at once: the leader’s own consent, given when they publish it and withdrawable in one click, and the fact that they made it public by their own act. An enquiry is handled to take the step the sender asked for. An account exists to keep a page under its owner’s control. A brief, an engagement and a document are held to perform the agreement the company asked Atlas to perform. Analytics runs on consent, given at the banner and withdrawable from the footer of any page.
Atlas does not rely on a legitimate interest for anything, because the UAE personal data law does not offer one. Article 4 of Federal Decree-Law 45 of 2021 begins by prohibiting processing without consent and then lists eleven exceptions, and a legitimate interest of the person holding the data is not among them. Where this notice names a basis, it is consent, performance of a contract, data the person made public themselves, or the establishing and defending of a legal claim.
Two of them are about a person who did not hand them over, and they are stated separately because they are the ones that matter. An appraisal is a company’s judgement of a named leader, held so that Atlas can tell whether an introduction was worth making, and held on the footing that the leader reads it in full and may answer it. A reference call is a third party’s answer about a named leader, held as the evidence behind a published claim, and made only to a referee the leader named and confirmed had agreed to be called.
Atlas asks for no Emirates ID number, no passport copy, no salary history and no bank details. Atlas never holds a company’s payment details and never takes a payment on a leader’s behalf. A verification is carried out against a permit or a licence and a reference call, and the outcome and its date are recorded rather than the documents.
Five, named. Nothing is sold, and nothing is shared for anyone else’s marketing.
Hosting, and the Firestore database that holds a leader page and an enquiry.
Where: europe-west1, Belgium.
Page views and referrers, so we know which pages are read. No profile is built and no data is sold.
Where: Google infrastructure.
The private bucket holding a leader's CV and any document Atlas has issued to a company. Public access is blocked at the bucket, and a file is only ever served through a link Atlas signs that expires in fifteen minutes.
Where: europe-west1, Belgium.
The transactional email that carries an enquiry to a leader, an account email to its owner, and the monthly Atlas letter to an address that confirmed it. A message contains what it says on its face and nothing more: no register, no brief and no appraisal is attached to one.
Where: Sent from ap-northeast-1, Tokyo. Resend's own processing operations are in the United States, and its published subprocessor list is entirely United States entities.
The check that a person, and not a script, is opening an account. It runs on three forms only: claiming a leader page, opening a company account, and the account offered when a brief is sent. While it runs, Cloudflare sees the reader's IP address and signals from the browser and the device. It does not see anything typed into the form, and Atlas receives back only whether the check passed. Atlas sets no cookie for it. Cloudflare also uses those signals to improve its own bot detection, and for that use it is a controller in its own right, under its Turnstile privacy addendum.
Where: Whichever Cloudflare location is nearest the reader. Cloudflare does not publish a single processing location for it.
The site is served from Belgium, files sit on a private bucket in Belgium, transactional email is sent from Tokyo by a provider whose own processing operations are in the United States, and the check on the three account forms runs at whichever Cloudflare location is nearest the reader. So data about a reader in the Gulf is processed outside the UAE, and data about a reader elsewhere is processed outside their country too. Those transfers rest on the data processing terms agreed with each provider, which oblige them to apply the protections this notice describes. Beyond these five, data is disclosed only where the law requires it.
Four things Atlas stores in your browser. Two only after a sign-in, one only once a brief has been saved, and one that records the answer you gave to the banner.
Keeps a leader signed in to their own dashboard. Set only after a sign-in, cleared on sign-out, and never used to track reading.
Keeps a company signed in to its own account. A separate cookie from the leader one, so a person who is both stays signed in to both.
Remembers whether you allowed analytics. Stored in your browser rather than as a cookie, because setting a cookie to record that you have not yet agreed to cookies would be absurd. It is the only thing Atlas stores before you have chosen, it holds one word, and clearing it means you are asked again.
Holds the reference of a half-finished brief so it can be picked up again. Set the moment a brief is first saved, cleared when it is sent, and it identifies a draft rather than a person.
Google Analytics sets its own cookies, and it only runs if you allowed it. Until you answer the banner the tag is not loaded at all, so nothing is set and no request reaches Google. Article 4 of the UAE personal data law prohibits processing without consent and does not offer a legitimate interest as an alternative, so consent is the only basis available and asking is not a courtesy.
You can change your answer at any time from the analytics link in the footer of any page, and withdrawing is one click, the same as giving it. Withdrawing takes effect on your next page load, because a tag already running cannot be unloaded from a live page, and it does not reach back over what was already collected lawfully. Nothing on this site depends on analytics, so declining costs you nothing at all. Reading the register requires no cookie, no consent and no account.
A leader page and its account are kept while the page is live, and removed when the leader asks or when approval is withdrawn. A verification record and its date are kept for as long as Atlas has published a claim that rests on it, because that is the evidence behind the claim. A CV is deleted the moment a leader deletes it, and with the account.
An enquiry is kept while the introduction is being made and for as long afterwards as an invoice or a dispute may need it. A brief, an introduction and an engagement are kept for seven years from the end of the engagement, because a fee can be owed for twelve months after an introduction and a claim on it has to be provable after that. A document Atlas issued is kept for the same seven years. Analytics is kept in aggregate on the retention that Google Analytics applies.
An appraisal and the leader’s reply to it are kept for seven years and neither can be edited by anybody, including Atlas. That is deliberate: a statement one party can quietly revise is worth nothing to the other, and both people named in it are entitled to rely on it saying what it said. A leader who leaves Atlas takes their page down and the appraisal stays, because it is a company’s statement as much as it is about the leader.
Six, under the UAE personal data law. Write to the address above to use any of them.
Ask what Atlas holds about you and get a copy.
Have anything wrong put right. A leader can do this directly on their own page at any time.
Ask for your page or your account to be removed. A page comes down on request.
Receive what you gave us in a form you can carry to someone else.
Object to a use of your data, including analytics, and have it stopped where the law allows.
Withdraw a consent you gave, without affecting what was lawful before you withdrew it.
None of them costs anything and none of them requires a reason. If an answer from Atlas does not settle the matter, a complaint can be taken to the UAE Data Office.
Two limits, said plainly rather than discovered later. Atlas keeps the record of a brief, an introduction and an engagement after a relationship ends, because a fee can be owed for twelve months after an introduction and a claim on it has to be provable. And an appraisal is not deleted at the request of either of the two people named in it, because it is a statement by one about the other and neither owns it alone. In both cases Atlas will say what it is keeping and why, rather than agreeing to delete everything and then not.
This notice changes when the site changes. The date at the top is the date of the current text. A change that affects what is collected or who it is shared with is announced on the page, and a leader with a live page is told directly.
What Atlas is, what it charges and the law that governs a dispute are a separate document. They are on the terms of use.