Privacy Policy

Lucas Financial Consulting, LLC (“Lucas Financial,” “we,” “us,” or “our”) owns and operates the financial technology and information platform known as DST Atlas (“Atlas” or the “Platform”). This Privacy Policy explains how we collect, use, disclose, retain, and protect Personal Information in connection with Atlas, DSTAtlas.com, and related services.

Atlas is a professional-only Platform primarily used by broker-dealers, registered investment advisers, registered representatives, investment adviser representatives, alternative-investment sponsors, authorized administrative personnel, due-diligence and compliance firms, distribution organizations, and other approved industry participants.

This Privacy Policy should be read together with the Atlas Terms of Service. If a separate agreement, notice, or data-processing arrangement applies to a particular service or category of information, that document may supplement this Privacy Policy.

1. Scope and Definitions

This Privacy Policy applies to Personal Information we process when you visit our website, register for or use Atlas, communicate with us, purchase or administer Atlas services, interact with sponsors or offerings, participate in testing or Portfolio Builder functionality, or otherwise engage with Atlas.

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or can reasonably be linked to an individual, household, or device, or that is otherwise protected as personal data or personal information under applicable law.

Personal Information does not include information that has been aggregated or de-identified so that it cannot reasonably be linked to an identifiable person, or information excluded from the definition of personal information under applicable law.

This Privacy Policy does not govern the privacy practices of third-party websites, sponsor websites, due-diligence rooms, payment providers, or other services that you access outside Atlas. Those parties maintain their own privacy practices.

2. Personal Information We Collect

The information we collect depends on how you interact with Atlas, your professional role, the features available to you, and the information you or your firm choose to provide.

A. Information You Provide to Us

• Business contact information, including your name, company email address, business telephone number, employer or firm, office location, title, and other professional contact information.
• Professional and eligibility information, including broker-dealer or registered investment adviser affiliation, licensing or registration information, role, supervisory relationship, and other information used to determine or maintain eligibility for Atlas.
• Account information, including username, authentication information, account preferences, firm permissions, and information used to secure or administer your account.
• Communications and support information, including messages, requests, feedback, survey responses, support inquiries, and records of communications with us.
• Sponsor and firm information, including company profiles, employee or wholesaler information, events, documents, offering information, logos, photographs, videos, and other information submitted by sponsors or authorized firm personnel.
• Commercial and subscription information, including services purchased, billing contact information, subscription status, offering-package selections, advertising purchases, placement credits, and transaction records relating to paid Atlas services.
• Portfolio Builder and workflow information, including information a professional user enters to model a client exchange or portfolio, such as client or household names, transaction amounts, property information, allocation information, portfolio selections, notes, and generated-report information.
• Testing information, including exams assigned or accessed, answers, completion status, scores, dates, and related testing records.
• Other information you voluntarily submit through Atlas or provide to us in connection with the Platform.

B. Information Collected Automatically

• Log and access information, including date and time of access, login history, authentication events, IP address, and related security information.
• Device and browser information, including device type, operating system, browser type, language, user agent, and similar technical information.
• Approximate location information derived from IP address or similar technical information, including information that may be used to identify unusual login activity. Atlas does not treat this as precise device geolocation unless a feature expressly collects precise location and provides an appropriate notice.
• Platform usage and interaction information, including pages viewed, offerings viewed, sponsors viewed, searches, clicks, downloads, documents accessed, links selected, time and frequency of use, features used, navigation patterns, request rates, and other interactions with Atlas.
• Portfolio Builder activity, including use of Portfolio Builder, modeled portfolios, offerings included in modeled portfolios, report-generation activity, and related feature usage.
• Testing activity, including exams accessed, started, completed, or passed, and related engagement information.
• Security and abuse-detection information, including information used to detect scraping, credential sharing, bulk extraction, unauthorized automation, circumvention of controls, suspicious activity, or misuse of Atlas.

C. Cookies and Similar Technologies

We may use cookies, local storage, web beacons, pixels, session technologies, and similar technologies to authenticate users, maintain sessions, remember preferences, protect security, understand Platform usage, measure performance, improve Atlas, and support other purposes described in this Privacy Policy.

Some cookies and similar technologies may be provided by third parties that support authentication, hosting, analytics, security, communications, payment processing, or other Platform functions. Your browser settings and, where available, Atlas cookie or consent controls may allow you to manage certain technologies.

D. Information From Other Sources

We may receive Personal Information from sources other than you, including:

• your employer, broker-dealer, registered investment adviser, sponsor, supervising firm, or other organization with which you are affiliated;
• firm administrators who create, approve, manage, or update user access and permissions;
• sponsors, distribution organizations, due-diligence providers, and other industry participants that provide professional or firm information;
• publicly available professional-registration, licensing, company, or regulatory sources;
• service providers that support authentication, fraud prevention, security, payments, communications, analytics, or other business operations; and
• other users or organizations that provide information where they represent that they are authorized to do so.

3. How We Use Personal Information

We may use Personal Information for the following purposes:

• Provide and operate Atlas, including authenticating users, maintaining accounts, displaying applicable offerings and features, generating reports, administering testing, and providing requested services.
• Determine and maintain eligibility for Atlas, including verifying professional status, firm affiliation, licensing, registration, supervision, and permitted use.
• Administer firm controls and permissions, including applying broker-dealer, registered investment adviser, sponsor, or other organizational settings to user access.
• Provide Sponsor Insights and other sponsor services as described in Section 4 of this Privacy Policy.
• Communicate with you regarding your account, security, testing, services, transactions, support requests, Platform changes, events, products, educational content, sponsor communications, and other matters relating to Atlas.
• Analyze and improve Atlas, including evaluating feature usage, understanding user needs, developing new functionality, measuring performance, conducting research, and producing market intelligence or analytics.
• Protect Atlas and its users, including detecting and preventing fraud, scraping, credential sharing, security threats, misuse, unauthorized access, and violations of the Atlas Terms of Service.
• Administer paid services, including Sponsor Insights, Offering Packages, advertising, testing, and other sponsor or firm purchases.
• Comply with law and enforce our rights, including responding to legal process, regulators, law enforcement, disputes, audits, and contractual obligations.
• Support business operations, including accounting, recordkeeping, corporate transactions, insurance, legal services, and other legitimate operational purposes.
• Create aggregated or de-identified information as described below.

4. Sponsor Insights and Professional-User Engagement

Atlas includes sponsor-facing services designed to help sponsors understand professional engagement with their offerings and participation in the Platform. Sponsor Insights and related features may therefore make certain professional-user information and Platform activity available to the applicable sponsor or its authorized representatives.

Depending on the feature and applicable settings, this may include a professional user’s identity, firm affiliation, professional role, and engagement events such as whether the user viewed a sponsor or offering, included an offering in a modeled portfolio, accessed or downloaded sponsor or offering materials, or participated in testing associated with that sponsor or offering. Where Atlas makes business contact information available as part of a sponsor-facing feature, that use will be limited to professional contact information associated with the user’s Atlas account.

Atlas may also provide sponsors with aggregated or de-identified market analytics, such as broader viewing, modeling, testing, availability, or engagement trends across the Platform.

Sponsor Insights is intended to provide visibility into professional-user engagement, not to provide sponsors with client or investor identities. Atlas does not disclose a client’s or investor’s Personal Information to a sponsor merely because a professional user enters that information into Portfolio Builder or includes the sponsor’s offering in a modeled portfolio.

A sponsor may authorize certain employees, distribution personnel, managing broker-dealers, or other approved representatives to access sponsor-facing information or administer sponsor activity. Information made available through sponsor services may therefore be visible to those authorized parties consistent with the applicable permissions and service configuration.

5. How We Disclose Personal Information

We may disclose Personal Information to the following categories of recipients when reasonably necessary for the purposes described in this Privacy Policy:

6. Client and Investor Information

Professional users may enter limited client or household information into Portfolio Builder or other workflow tools. Atlas uses that information to provide the requested functionality, generate reports, secure and support the Platform, and otherwise process the information as described in this Privacy Policy and the Atlas Terms of Service.

Professional users are responsible for ensuring they have an appropriate basis to provide client or investor information to Atlas and for complying with their own privacy, regulatory, supervisory, and contractual obligations.

If Atlas introduces subscription-document or transaction-processing functionality that collects additional sensitive investor information, such as taxpayer identification numbers, banking information, signatures, financial information, or suitability information, Atlas may provide supplemental privacy or security terms before that functionality is used. Atlas does not currently treat planned future functionality as a commitment to collect such information.

Atlas does not use client or investor Personal Information entered into Portfolio Builder for unrelated third-party advertising and does not provide client or investor identities to sponsors merely because an offering is modeled or included in a Portfolio Builder report.

7. Aggregated, De-Identified, and Derived Information

We may aggregate, de-identify, normalize, categorize, or derive information from Platform activity and other data so that the resulting information does not reasonably identify a particular individual.

We may use aggregated or de-identified information for analytics, benchmarking, market intelligence, research, product development, sponsor analytics, Platform improvement, security, commercial products, and other lawful business purposes, and we may disclose such information to sponsors, firms, service providers, business partners, or other parties.

Where required by applicable law, we will maintain de-identified information in de-identified form and will not attempt to re-identify it except as permitted by law.

8. Sale, Sharing, Targeted Advertising, and Sponsor Services

Atlas does not sell Personal Information to data brokers and does not sell Personal Information for cash consideration. We also do not provide client or investor Personal Information to sponsors for their independent marketing merely because that information was entered into Portfolio Builder.

Atlas does, however, provide paid services such as Sponsor Insights and other sponsor-facing functionality. As described in Section 4, those services may involve disclosure of professional-user identity, firm affiliation, business contact information where applicable, and professional engagement with sponsor or offering content.

Sponsors pay for Atlas services, analytics, visibility, and functionality rather than for ownership of Personal Information. Some privacy laws define terms such as “sale,” “share,” or similar regulated disclosures broadly, and a particular disclosure may be treated differently under applicable law even when no payment is made specifically for Personal Information.

Where applicable law gives you a right to opt out of a sale, targeted advertising, profiling, or another regulated disclosure, Atlas will provide and honor the rights required by that law. If Atlas engages in cross-context behavioral advertising or another activity that requires a specific opt-out mechanism, Atlas will provide the required notice and controls.

Where legally required, Atlas will also recognize valid browser-based universal opt-out preference signals, such as Global Privacy Control, for the browser or device from which the signal is received.

9. Communications

We may use your business email address, business telephone number, and other contact information to communicate with you about your account, authentication, security, Platform functionality, testing, offerings, transactions, services, support, policy changes, educational content, events, products, sponsor communications, advertising, and other Atlas-related matters.

You may unsubscribe from marketing emails using the unsubscribe mechanism provided in those messages. Even if you opt out of marketing communications, we may continue to send transactional, security, account, legal, and other non-promotional communications relating to your use of Atlas.

Where applicable law requires separate consent for automated or promotional telephone calls or text messages, we will obtain that consent before using those channels for communications that require it.

10. Data Retention

We retain Personal Information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide Atlas, maintain account and business records, administer sponsor and firm services, support security and abuse prevention, resolve disputes, enforce agreements, comply with law, and protect our legal rights.

Retention periods vary based on the type of information, the feature involved, the relationship with the user or organization, legal or regulatory requirements, and legitimate business needs. Certain account, testing, security, audit, transaction, and enforcement records may be retained after access to Atlas ends.

Backups may retain information for a limited period after deletion from active systems. Aggregated or de-identified information may be retained for longer periods where permitted by law.

11. Information Security

We use administrative, technical, and organizational safeguards designed to protect Personal Information against unauthorized access, use, disclosure, alteration, and loss. Safeguards may include access controls, authentication, encryption or secure transmission technologies, logging and monitoring, vendor controls, backup procedures, security testing, and other measures appropriate to the nature of the information and service.

Atlas may monitor account and Platform activity to identify security threats, suspicious behavior, scraping, credential sharing, unauthorized automation, and other misuse.

No electronic system, network, transmission, or storage method is completely secure, and we cannot guarantee absolute security. Users are responsible for protecting their credentials and devices and for promptly notifying Atlas of suspected unauthorized access.

12. Your Privacy Rights

Depending on where you reside, the nature of your relationship with Atlas, and whether an applicable privacy law covers the relevant processing, you may have rights concerning your Personal Information. These rights may include:

• the right to know or confirm whether we process Personal Information about you and to access certain Personal Information;
• the right to correct inaccurate Personal Information;
• the right to request deletion of certain Personal Information, subject to applicable exceptions;
• the right to obtain a portable copy of certain Personal Information;
• the right to opt out of certain sales, targeted advertising, profiling, or other regulated processing where applicable;
• the right to limit certain uses or disclosures of sensitive Personal Information where applicable;
• the right to appeal a denial of a privacy request where applicable; and
• the right not to receive unlawful discriminatory treatment for exercising applicable privacy rights.

To submit a privacy request, email info@DSTAtlas.com with the subject line “Privacy Request” and describe the right you wish to exercise. We may request information reasonably necessary to verify your identity, account, authority, or relationship with Atlas before completing a request.

Where permitted by law, an authorized agent may submit a request on your behalf. We may require proof of the agent’s authority and may also require you to verify your identity directly.

Certain rights may not apply to information processed in a business, employment, regulatory, or other context that is exempt from a particular privacy law. We may also retain or decline to delete information where permitted or required by law, including for security, fraud prevention, legal compliance, contractual, recordkeeping, or dispute-resolution purposes.

13. Firm Administrator and Employer Visibility

If you use Atlas through or in connection with a broker-dealer, registered investment adviser, sponsor, employer, or other organization, authorized administrators of that organization may be able to view or manage information associated with your Atlas account.

Depending on the organization’s role and Platform configuration, this may include your identity, account status, firm affiliation, permissions, testing activity, feature availability, and certain Platform usage or administrative information.

Your organization’s own collection and use of information is governed by its policies and obligations and is separate from this Privacy Policy.

14. Third-Party Services and Links

Atlas may contain links to or integrate with third-party services, websites, due-diligence rooms, document repositories, authentication services, payment providers, or other external systems.

We are not responsible for the privacy practices of third parties when they process Personal Information for their own purposes. We encourage you to review the privacy notices of third-party services you choose to use.

15. Children

Atlas is a professional-use Platform and is not directed to children. We do not knowingly provide Atlas accounts to individuals under 18 years of age. If we learn that we collected Personal Information directly from a child in circumstances where collection was not permitted, we will take appropriate steps to delete or otherwise address the information.

16. Changes to This Privacy Policy

We may update this Privacy Policy as Atlas, our services, our business practices, or applicable laws change. When we make material changes, we may provide notice through Atlas, by email, or by another reasonable method.

The effective date at the top of this Privacy Policy indicates when the current version became effective. We encourage you to review this Privacy Policy periodically.

17. Contact Us

Questions about this Privacy Policy or our privacy practices may be directed to:

Lucas Financial Consulting, LLC
Operator of DST Atlas
Email: info@DSTAtlas.com