Atlas Trust Bank

Privacy Policy

Last updated: March 1, 2026

Atlas Trust Bank AG ("Atlas Trust Bank," "we," "our," or "us") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, store, share, and protect your data when you use our banking services, digital platforms, and related products. This policy applies to all clients, prospective clients, and visitors to our services worldwide.

1. Information We Collect

Atlas Trust Bank collects information necessary to provide you with secure, compliant, and personalized financial services. The categories of information we collect include:

Personal Identification Information: Full legal name, date of birth, nationality, government-issued identification numbers (passport, national ID, driver's license), tax identification numbers, and photographs for identity verification purposes.

Contact Information: Residential and mailing addresses, email addresses, telephone numbers, and emergency contact details.

Financial Information: Income and employment details, source of funds documentation, existing bank account information, credit history, investment experience and objectives, and risk tolerance profiles.

Transactional Data: Records of all transactions conducted through your accounts, including amounts, dates, counterparties, payment references, and associated metadata.

Technical Data: IP addresses, device identifiers, browser type and version, operating system, login timestamps, session duration, and interaction patterns with our digital platforms. This data is collected through cookies, server logs, and similar technologies.

Communications: Records of correspondence between you and Atlas Trust Bank, including emails, chat messages, telephone recordings (where permitted by law), and support ticket submissions.

2. How We Use Your Information

We process your personal information for the following purposes, each grounded in a lawful basis under applicable data protection regulations:

Service Delivery: To open and maintain your accounts, process transactions, issue payment instruments, and provide the financial services you have requested. This processing is necessary for the performance of our contract with you.

Regulatory Compliance: To fulfill our obligations under banking regulations, anti-money laundering (AML) laws, counter-terrorism financing (CTF) requirements, tax reporting obligations, and sanctions screening requirements. This processing is necessary for compliance with legal obligations.

Risk Management: To assess creditworthiness, detect and prevent fraud, manage operational risk, and conduct internal auditing. This processing is necessary for our legitimate interests in maintaining the security and integrity of our services.

Service Improvement: To analyze usage patterns, improve our products and digital platforms, develop new services, and conduct market research. Where not based on legitimate interest, we will seek your explicit consent for such processing.

Communications: To send you account statements, transaction confirmations, security alerts, regulatory notices, and, where you have opted in, marketing communications about products and services that may be relevant to your financial profile.

3. Information Sharing and Disclosure

Atlas Trust Bank does not sell your personal information to third parties. We may share your information in the following circumstances:

Regulatory and Legal Authorities: We disclose information to banking regulators, tax authorities, law enforcement agencies, and courts when required by law, regulation, or legal process. This includes mandatory reporting under AML/CTF regulations and international tax information exchange agreements (such as CRS and FATCA).

Service Providers: We engage carefully vetted third-party service providers who process data on our behalf, including payment processors, cloud infrastructure providers, identity verification services, and IT support vendors. All service providers are contractually bound by data processing agreements that ensure equivalent levels of data protection.

Correspondent Banks: International transactions may require us to share transaction details with correspondent and intermediary banks to facilitate the transfer of funds. These disclosures are limited to the information necessary to complete the transaction.

Group Companies: We may share information with Atlas Trust Bank subsidiaries and affiliates for internal administrative purposes, consolidated regulatory reporting, and risk management, subject to appropriate intra-group data sharing agreements.

With Your Consent: We may share your information with third parties when you have provided explicit, informed consent for a specific purpose, such as granting a financial advisor access to your portfolio data.

4. Data Security

Protecting your personal and financial information is fundamental to our operations. Atlas Trust Bank employs comprehensive security measures including:

Encryption: All data transmitted between your devices and our systems is protected using TLS 1.3 encryption. Sensitive data at rest is encrypted using AES-256 encryption. End-to-end encryption is applied to all internal communications containing client data.

Access Controls: We enforce strict role-based access controls, ensuring that only authorized personnel with a legitimate business need can access your information. All access to client data is logged and regularly audited.

Infrastructure Security: Our data centers are ISO 27001 and SOC 2 Type II certified, featuring physical access controls, redundant power systems, environmental monitoring, and 24/7 security operations centers.

Monitoring and Incident Response: We maintain continuous security monitoring systems, advanced threat detection capabilities, and a dedicated incident response team. In the event of a data breach, we will notify affected individuals and relevant regulatory authorities within the timeframes required by applicable law.

Employee Training: All employees undergo mandatory annual security awareness training and are bound by strict confidentiality obligations.

5. Cookies and Tracking Technologies

Atlas Trust Bank uses cookies and similar technologies on our digital platforms. Cookies are small text files stored on your device that help us provide and improve our services.

Essential Cookies: These cookies are strictly necessary for the operation of our digital banking platform. They enable core functionality such as session management, authentication, and security features. These cookies cannot be disabled without impacting your ability to use our services.

Analytical Cookies: With your consent, we use analytical cookies to understand how visitors interact with our website and application. This data helps us improve user experience, optimize page performance, and identify areas for enhancement. We use aggregated, anonymized analytics where possible.

Preference Cookies: These cookies remember your settings and preferences, such as language selection, display preferences, and regional settings, to provide a more personalized experience.

You can manage your cookie preferences through your browser settings or through our cookie consent management tool. Please note that disabling certain cookies may limit your ability to use specific features of our digital platforms.

6. Your Rights

Depending on your jurisdiction, you may have the following rights with respect to your personal information:

Right of Access: You have the right to request a copy of the personal information we hold about you, together with information about how and why it is processed.

Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal information we hold about you.

Right to Erasure: Subject to our legal and regulatory retention obligations, you may request the deletion of your personal information where it is no longer necessary for the purposes for which it was collected.

Right to Restriction: You have the right to request that we restrict the processing of your personal information in certain circumstances, such as when you contest its accuracy or object to our processing.

Right to Data Portability: Where technically feasible, you have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit it to another data controller.

Right to Object: You have the right to object to processing based on legitimate interests or for direct marketing purposes. Where you object to direct marketing, we will cease such processing immediately.

To exercise any of these rights, please contact our Data Protection Officer at privacy@atlastrust.com or through your account settings. We will respond to your request within 30 days, in accordance with applicable law.

7. Changes to This Policy

Atlas Trust Bank reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or regulatory guidance.

Material changes will be communicated to you at least 30 days before they take effect through email notification, in-app notification, or prominent notice on our website. We will clearly indicate the nature of the changes and the effective date.

We encourage you to review this Privacy Policy periodically. The "Last updated" date at the top of this page indicates when this policy was most recently revised.

Your continued use of our services after the effective date of any changes constitutes your acknowledgment of the modified Privacy Policy.

8. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

Data Protection Officer: Atlas Trust Bank AG, Bahnhofstrasse 42, 8001 Zurich, Switzerland. Email: privacy@atlastrust.com. Telephone: +1 (800) 482-7878 (US) / +44 20 7946 0958 (International).

For residents of the European Economic Area, you also have the right to lodge a complaint with your local supervisory authority if you believe that our processing of your personal information violates applicable data protection law.

For residents of Switzerland, complaints may be directed to the Federal Data Protection and Information Commissioner (FDPIC).

Atlas Trust Bank AG is registered in Zurich, Switzerland under company registration number CHE-123.456.789. Regulated by the Swiss Financial Market Supervisory Authority (FINMA).