Privacy Policy

Last updated: February 17, 2026

1. Data Controller

Datary Analytics, S.L. Tax ID: B87634895 Registered address: Calle Princesa 41, 28008, Madrid, Spain Email: legal@atogu.com

2. Personal Data Processed

Atogu may process the following categories of personal data:

• Identification data (name, surname, email address, company name).
• Professional data (job title, corporate contact details).
• Account credentials.
• Platform usage data (logs, access timestamps, activity).
• Limited billing-related data (subscription status, transaction reference, plan type).

Atogu does not process full payment card details.

3. Payment data and Paddle

3.1. Payment processing is carried out through Paddle, acting as Merchant of Record.

3.2. Payment and billing data (cards, IBAN, tax addresses) are collected and processed directly by Paddle, not by Atogu.

3.3. Paddle acts as an independent data controller for payment and billing data. Users must refer to Paddle’s Privacy Policy for information regarding the processing of such data and for the exercise of related rights.

3.4. Atogu and Paddle operate as separate data controllers for their respective processing activities.

4. Purposes and legal basis

• Performance of the contract (Art. 6.1.b GDPR).
• Compliance with legal obligations (Art. 6.1.c GDPR).
• Legitimate interest (Art. 6.1.f GDPR) for Service improvement and B2B commercial communications.

5. Service Providers and Subprocessors

Atogu may rely on third-party service providers for hosting, infrastructure, analytics and technical support.

These providers act as data processors under contractual data protection agreements in accordance with Article 28 GDPR.

6. International Data Transfers

Where personal data is transferred outside the European Economic Area (EEA), such transfers are carried out under appropriate safeguards, including Standard Contractual Clauses approved by the European Commission or other legally recognized mechanisms.

7. Data retention

Data will be retained for the duration of the contractual relationship and for applicable statutory periods thereafter.

8. Data subject rights

The User may exercise their rights of access, rectification, erasure, objection, restriction and portability by writing to legal@atogu.com.

For payment-related data processed by Paddle, users must exercise their rights directly with Paddle as independent controller.

9. Security measures

Atogu implements reasonable technical and organizational measures to protect personal data.

10. Policy updates

This Privacy Policy may be updated. Any changes will be duly communicated.

11. Cookies and Analytics

The Platform may use technical and analytical cookies to ensure proper functioning and improve user experience.

Where required by law, users will be informed and asked for consent prior to the use of non-essential cookies.

12. Automated Decision-Making

Atogu does not perform automated decision-making or profiling that produces legal or similarly significant effects on users.