Talos Trading, Inc.
Applicant & Employee Privacy Policy

Effective Date: March 29, 2023

Welcome to Talos!

Regardless of whether you’re a current Talos team member, or you are applying to be part of our team, it’s important to us that you are aware of personal information that we collect, how we use that information, and your privacy rights and choices.

This notice (“Privacy Notice”) applies to all applicants and job candidates(collectively, “Applicants”);employees, officers, directors, contractors, agents contingent and other personnel (collectively, “Workers”)of Talos; and certain others whose personal information is processed in connection with our human resources activities, including emergency contacts and beneficiaries . The terms “Talos,” “we,” “us,” and “our” in this policy apply to all companies in the Talos family of companies, which includes Talos Trading, Inc., its affiliates, and subsidiaries.  

We are committed to complying with all data privacy laws in the jurisdictions in which we collect personal information of Applicants and Workers. Applicants, Workers, emergency contacts or beneficiaries with disabilities may access this notice in an alternative format by contacting the People team at peopleteam@talostrading.com.


What information Talos collects

The personal information we collect directly from Workers andApplicants may include, as applicable:  

●     General HR information. This might include your name, alias, postal address, phone number, unique personal identifier, online identifier, email address, date of birth, age, passport number, driver’s license number, Social Security number or other government-issued identification number, employment history, education information and records, professional qualifications, salary information, information that may be submitted in a resume/CV or application form (such as education history, education records such as grades and transcripts, and employment history), language abilities, business or professional licenses and insurance information, motor vehicle records, and contact information of third parties incase of an emergency (whose authorization you have obtained to provide us their contact details).

●     Financial information. This might include information related to credit checks, bank account number, routing number, and other details required for payroll or recruiting-related reimbursements.

●     Demographic and Health information. Where permitted or required by law, we may ask Applicants and Workers to voluntarily disclose information like race, disability, ethnicity, sexual orientation and gender identity, or military and veteran status, in order to help us achieve our diversity goals. Where required to run our business and ensure the safety of our Workers and workplace, as well as to provide health benefits and other benefits, we may also collect information such as details of health and disability, vaccination status, health insurance information, mental health, medical leave, and maternity leave, national origin, and immigration or work visa status.

●     Performance Information. We also receive or collect other information to help evaluate your application or your performance, such as information you choose to disclose during the interview process (as an Applicant) or provided by you during performance reviews (as a Worker). From Workers, we may also collect information about your job assignments, work schedule, hours worked, accomplishments and awards, training and development information, discipline and counseling information, opinions, evaluations, and other information provided to us from other Workers as part of the performance review process.

●     Your Communications with Us. If you contact us, for example to inquire about benefits or ask about a job opportunity, we will receive your information, including any information you disclose in order to contact us.

●     Posting on Intra-Company Sites. We may offer intra-company accessible sites, pages, messaging channels, blogs, or forums for Workers to communicate and collaborate with each other, like Discord or Slack (“Intra-CompanySites”). We and other individuals who use the Intra-Company Sites may collect the information you submit or make available through these sites. If you choose to make content available on any public area of the Intra-CompanySites, such content will be visible to other Workers and not subject to the privacy protections set forth here in this Privacy Notice.

●     Surveys and Promotions. From time to time, we may ask Workers or Applicants to participate in optional surveys to help inform our decision-making and to ensure that your views are represented and considered. If you decide to participate, you may be asked to provide certain information, which may include personal information. In that same vein of building bonds and community at Talos, we also frequently run optionalWorker promotions and contests. It’s possible that you may be asked to provide certain information to participate, which may include personal information.

●     Legal Information. We also collect contractual information, such as information necessary to comply with legal and contractual obligations, exercise legal and contractual rights, and initiate or respond to legal claims.

●     Personal Information about Dependents or Other FamilyMembers. We may collect information about your dependents under the age of 18 or other family information if you provide such information in connection with the enrollment and administration of benefits, or for other human resource purposes involving such dependents.

Apart from information you offer, Talos also collects information automatically from you or from others. For example:

●     Device Information. Like most companies, we receive data about your use of our systems or a device we have issued to you for work purposes, like your internet protocol (IP) address, your location based on your IP address or online activities, identifiers associated with your computer or device, cellphone-related information, activity logs, browsing history, search history, information regarding your interaction with a website, and other information about activities you engage in while working with us, and on our equipment, accounts, systems, and networks.

●     System Monitoring. To ensure that our hardware and software is working optimally, we may monitor and review the use of Talos’ equipment, accounts, information technology systems and networks to both ensure they’re used appropriately and to determine what IT upgrades may be necessary. Should it become necessary, Talos may also access and review electronic files, messages, and emails sent or stored on its information technology systems and hardware. To the full extent permitted by applicable law, Talos may monitor all activity and communications on its premises, information technology systems, networks, and electronic communication tools. Any and all telephone conversations or transmissions, electronic mail or transmissions, or internet access or usage by an employee by any electronic device or system, including but not limited to the use of a computer, telephone, wire, radio or electromagnetic, photoelectronic or photo-optical systems may be subject to monitoring at any and all times and by any lawful means.

●     Audiovisual or Other Sensory Data. We may collect audio and visual information such as through photographs used for identification purposes, and we might also use those photos to promote Talos. We may also collect audio and video recordings of training sessions or other Talos meetings.

●     Inferences Drawn from Other Personal Information. We may collect inferences drawn from other personal information such as your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

●     Information from Other Sources. We may collect or receive information about you from other sources, including through third-party services and organizations to supplement information provided by you. For example, where permitted by law, we may conduct background and credit checks on you or request information from your former employers prior to your employment with Talos.

How Talos uses this information

We collect your personal information to operate our business, including to consider Applicants for a position at Talos and manage the employment relationship with Workers, which includes purposes such as:

●     to evaluate your application and determine if you are a good fit for our team, and to help you get on-boarded if we make you an offer, or consider your application for other or future opportunities  at Talos if we do not make an offer;

●     to provide your salary, compensation, expenses, bonuses, vacation pay, leave pay, and any other disbursements or benefits you are entitled to receive;

●     to contact your emergency contact person(s) in the event something happens to you at work, such as in the event of a medical emergency;

●     to keep you safe and provide efficient resources to support you in your work at Talos, including IT and Human Resources support;

●     to respond to your HR-related questions and support our HR operations generally(administration, communication, running diversity and inclusion initiatives, worker safety, absence management, help desk and IT support services);

●     to comply with applicable laws (for example, for fraud prevention laws, network and information security requirements, whistleblowing schemes, or to perform internal and/or external or governmental compliance investigations or audits);

●     to disclose information related to your employment at Talos to affiliated organizations for administrative tasks;

●     to conduct Worker monitoring for safety or management-related purposes,

●     to establish, exercise, or defend legal claims; and

●     for research purposes.

Where applicable law requires a legal basis to process personal information, we do so in accordance with the following:

●     To fulfill our contractual obligations to you – for example, to pay your salary in accordance with the terms of your contract;

●     To comply with legal obligations – for example, to comply with laws in relation to accounting, taxes, workplace safety, and others;

●     To pursue our legitimate interests – for example, to operate our business, attract a talented workforce, and manage the employment relationship with Workers; and

●     With your consent – for example, where you voluntarily disclose information about your race, ethnicity, and so forth, to help us in promoting a diverse workforce. Where we rely on consent as the legal basis to process your personal information, you have the right to withdraw consent at any time without affecting the lawfulness of the processing prior to such withdrawal.

How we disclose your information

To run our business, including for the purposes described above, we may share your information with the following categories of parties:

●     other entities of the Talos family of companies, including Talos Trading, Inc., our affiliates and subsidiaries;

●     other businesses with whom we work, who may need certain information about you (for example, your business contact details) to enable you to

●     vendors and other service providers, such as those we use for HR and IT needs; and

●     law enforcement, a court, or other governmental authorities, if we’re served with a court order, a subpoena, receive a lawful request from law enforcement, or if we reasonably believe it is necessary to comply with the law or protect the rights or safety of you or our Workers.

Additionally, if we are involved in or considering a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or other corporate transition of service to another entity, this may entail the transfer of your personal information in connection such a transaction, as permitted by law and/or contract.

Retention of your information

We retain the personal information described above for so long as reasonably necessary and proportionate to fulfill the business purposes set out above. The criteria that inform our retention practices include compliance with applicable laws, audit requirements, HR operations, dispute resolution, contractual requirements and business needs.


All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws. For personal information originating in Europe, we have put in place standard contractual clauses to help ensure the adequate protection of such information when it is transferred to non-adequate countries outside those jurisdictions.  If you are a resident of a European country, you may request a copy of such clauses.

Your choices and rights

Where recognized by (and in accordance with) applicable law, you may have the right to request:

●     confirmation of whether we are processing your personal information;

●     access to or a copy of your personal information;

●     that we send your personal information to another company or other third party in a machine-readable format;

●     objection or restriction of our use or disclosure of your personal information (including sensitive personal information, as applicable);

●     correction of inaccurate or incomplete personal information;

●     withdrawal of your consent; and

●     erasure of personal information held about you by us, subject to certain exceptions prescribed by law.

If you would like to exercise any of these rights, please contact us as set forth below.  

We will process such requests in accordance with applicable laws. To protect your privacy, Talos will take steps to verify your identity before fulfilling your request.

Where provided by applicable law, you may also have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

What should I know about information security?  

We work hard to ensure that your information is kept secure and in accordance with this Privacy Notice. We maintain safeguards designed to ensure that your personal information will remain protected, and require our third-party service providers and partners to have appropriate safeguards as well. That said, despite our efforts, there exists the possibility of an unauthorized disclosure. We also depend on ourWorkers to help protect the confidentiality of data in accordance with our relevant policies and procedures. To the fullest extent permitted by applicable law, we disclaim liability for any unauthorized disclosure.


Various resources and sites at Talos may contain links to third party websites/applications, and other websites/applications may reference or link to Talos. These third-party services are not controlled by us. We encourage Applicants and Workers to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Supplemental notice for California residents

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). Any terms defined in the CCPA have the same meaning when used in this notice. This Supplemental Notice should be read together with the rest of our Privacy Notice, which more comprehensively discusses our processing activities.

Consistent with the “What Information Talos Collects,”“How Talos Uses This Information,” and “How We Disclose Your Information”sections above, we have or may have collected the following categories and specific pieces of personal information from or about you for the following business or commercial purposes (“Business Purpose”) over the prior twelve (12)months:

Category  of Personal Information Collected by Talos

Identifiers. A real name, alias, postal  address, unique personal identifier, online identifier, Internet Protocol  address, email address, account name, Social Security number, or other  similar identifiers.

Protected  classification characteristics under California or federal law. Age (40 years or older), race,  color, national origin, citizenship, marital status, medical condition,  physical or mental disability, sex (including gender, gender identity, gender  expression, pregnancy or childbirth and related medical conditions), veteran  or military status.

Commercial  information. Records of  products or services purchased, obtained, or considered, or other purchasing  or consuming histories or tendencies.

Internet  or other electronic network activity Browsing history, search history, information on a  consumer’s interaction with an internet website, application, or  advertisement.

Geolocation  data Physical location or movements.

Professional  or employment-related information. Work history, professional experience, accomplishments  and awards, community and board service, professional activities, for  example.

Non-public  education information.  Education records directly related to a student maintained by an educational  institution or party acting on its behalf, such as grades, transcripts, class  lists, student schedules, student identification codes, student financial  information, or student disciplinary records.

Inferences.   Inferences drawn from any of the information identified above to  create a profile about an individual reflecting the their preferences,  characteristics, psychological trends, predispositions, behavior, attitudes,  intelligence, abilities and aptitudes

Sensitive  Personal Data. Social  security, driver’s license, state identification card, or passport number,  account log-in in combination with any required security or access code,  password, or credentials allowing access to an account, your racial or ethnic  origin, and the contents of your business mail, emails, and text messages on  a company-issued mobile device.

Business  Purposes for Processing Personal Information

• Evaluating applications for  employment or internal promotion

• Managing day-to-day aspects of  your employment relationship, including payroll, benefits, and other  reimbursable expenses; and other administrative and human resource related  processes necessary during the course of your employment

• Administering benefits

• Protecting the health and safety  of our Workers

• Maintaining and controlling  access to the physical security of our buildings and controlling access to  physical and digital assets

• Locating company-issued mobile  devices and equipment

• Producing internal and external  communications (such as newsletters, magazines and website articles)

For more  information, see the “How Talos Uses This Information” section above.

Category  of Third Parties Information is Disclosed to for a Business Purpose

• Other businesses we work with

• Vendors and other service  providers

• Law enforcement, courts, and  other government authorities

For more  information, see the “How We Disclose Your Information” section above.


Talos retains the categories of personal information described above for so long as reasonably necessary and proportionate to fulfill the business purposes set out above.  For Workers, we retain identifiers and sensitive personal information as necessary for the duration of your employment or other business relationship with you and thereafter as required by applicable law.  For more information, see the “How Talos Uses This Information” section above.

We do not sell or share for cross-context behavioral advertising your personal information collected under this Privacy Notice, neither currently nor in the last 12 months.   

Some of the personal information that we collect may be considered sensitive under the CCPA. To the extent we collect sensitive personal information, we only use and disclose it for purposes that the CCPA recognizes are not subject to a right to limit use or disclosure. For example, we may use sensitive information to conduct anti-money laundering and other regulatory checks and for purposes that do not infer characteristics about you.

The categories of sources from which we collect personal information are set forth in the “How Talos Uses This Information” section above.

Privacy Rights for California Residents

If you are a California resident, you or your authorized agent may submit a request to exercise the following rights (as applicable and subject to relevant exceptions or exemptions under the law) pursuant to the“Your Choices and Rights” section above. This also includes the following:

●     Non-Discrimination.You have the right to be free from unlawful discriminatory treatment for exercising your rights under the CCPA.

●     Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent to exercise your rights and choices on your behalf, please provide your authorized agent with signed, written permission demonstrating that they have been authorized by you to act on your behalf.

●     Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include your name, email address, and phone number.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact the People team at peopleteam@talostrading.com.  We will process such requests in accordance with applicable laws.

Changes To this Privacy Notice

We may revise this Privacy Notice from time to time in our sole discretion, as indicated by the effective date at the top. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have acknowledged the updated Privacy Notice if you continue your employment with or services to Talos after the new Privacy Notice takes effect.


If you have any questions about this Privacy Notice or would like to make a request, please feel free to reach out to us by contacting our People team at peopleteam@talostrading.com.