Privacy notice

Last updated: 17 August 2026

Status: Working text for this internal Atlas deployment. Have Efectis legal counsel (and the DPO) review before you treat it as the final Article 13/14 notice.

This notice describes how Efectis Group processes personal data in Atlas, the internal AI workspace on this deployment.

1. Roles

Role	Who
Controller	Efectis Group (the Efectis company that operates this instance for its staff)
Software vendor	Elia Studio, which licenses Nemrut (branded Atlas here) exclusively to Efectis
You	An authorised user (employee, intern, contractor) of Efectis

Elia Studio does not offer Atlas to you as a public SaaS. Elia Studio is not the controller of employee data in this workspace. If Efectis later grants Elia Studio support access to this instance, Elia Studio acts only as a processor on Efectis instructions, under the licence or a data-processing agreement.

2. What this instance is

Atlas runs on infrastructure controlled by Efectis, for Efectis's own people. It is not a platform Efectis sells to its laboratory clients. Client files you place in Atlas remain subject to Efectis client contracts and confidentiality. They do not become a product sold by Atlas.

All personal data and content processed here stay in this Efectis deployment and belong to this deployment (or to the party that already owns the content).

3. Categories of data

Depending on your use of Atlas, Efectis may process:

• Account data: name, professional email, organisation, role, authentication identifiers
• Usage data: connection times, features used, adoption or activity signals that Efectis enables for programme owners
• Workspace content: documents, prompts, generated drafts, comments, and similar material you or colleagues store
• Support traces: if you ask an administrator for help, the minimum needed to diagnose an issue

Do not put special-category data or unnecessary personal data about third parties into Atlas unless your assignment and Efectis policy require it.

4. Purposes and legal bases

Efectis processes this data to:

• provide you with the internal Atlas workspace
• authenticate you and keep the instance secure
• administer licences, access, and IT operations
• where enabled, understand adoption of AI tools inside the group (not to sell advertising profiles)

Typical legal bases (GDPR): performance of your employment or contractor relationship (Art. 6(1)(b)), legitimate interest of Efectis in running a secure professional tool and measuring internal adoption (Art. 6(1)(f)), and any specific basis required by the employment law of the company that employs you (including Art. 88 GDPR where it applies). Mandatory workplace rules in France, the Netherlands, Turkey, and other countries where Efectis operates continue to apply.

5. Where data is stored and who sees it

Data is stored in this Efectis-controlled deployment. Efectis's current hosting design keeps application data in the European Union, subject to Efectis infrastructure choices.

Recipients, on a need-to-know basis:

• Efectis administrators and colleagues you share content with
• IT and security teams of Efectis
• technical subprocessors chosen by Efectis for hosting, backup, or operations of this instance
• Elia Studio only if Efectis grants contractual support access

Efectis does not sell this data. Content is not used to train public AI models.

6. Retention

Retention follows Efectis internal records, IT, and HR policies (account life, project archives, legal hold). When your access ends, Efectis decides what workspace content remains for the organisation.

7. Your rights

You may request access, rectification, erasure, restriction, objection, and portability, and you may withdraw consent if a processing was based on consent, within the limits of employment, security, and legal-hold rules.

Exercise these rights with Efectis, not as if Elia Studio were your employer or the operator of this instance.

Contact the Atlas administrators of Efectis Group.

You may also contact the Efectis Data Protection Officer through internal channels, and you have the right to lodge a complaint with a supervisory authority (for example CNIL in France, Autoriteit Persoonsgegevens in the Netherlands, or KVKK in Turkey), usually in the country of your usual workplace.

8. Automated decisions

Atlas assists drafting and search. Efectis does not use Atlas, through this notice, as the sole basis for automated decisions that produce legal effects about you as an employee (hiring, dismissal, or similar) without human involvement. Usage statistics, if enabled, are tools for programme adoption, not a secret performance score published in this notice. Local HR rules prevail.

9. Cookies

See the cookie notice.

10. Changes

Efectis may update this notice. The date at the top is the version on this instance.