Privacy Policy

Talos and its affiliates (collectively, “Talos,” “we,” “us,” and “our”) provides bilateral trading platform services that include pre-trade price discovery, order routing and execution, and portfolio management tools. This statement (“Privacy Policy”) is designed to help you understand how we collect, use, and share the personal information we collect from or about you when you use our websites and other services that include an authorized link or reference to this statement (“Services”), and to help you understand and exercise your privacy rights, where applicable. If your details are processed by us in the context of an agreement with you or the institution with which you are employed or affiliated, then the relevant data controller is the Talos entity identified in the contract. Otherwise, the data controller is Talos. when you use our Services. For information on how to contact us, please refer to Section 12 below. 

This Privacy Policy does not apply when Talos is processing your personal information as a service provider to our customers. We obtain certain information about you to provide them with Services. Our customers operate independently from us, and your agreement with the relevant customer governs how they use and share your personal information, including with Talos. Each customer’s privacy practices are subject to their privacy policies. If you have questions about a customer’s privacy policy, please direct those questions to the customer.

• Personal Information We Collect
• How We Use Your Information
• How We Disclose Your Information
• Your Privacy Choices and Rights
• Security of Your Information
• International Data Transfers
• Retention of Personal Information
• Supplemental Notice for California Residents
• Supplemental Notice for Nevada Residents
• Children’s Information
• Other Provisions
• Contact Us

We may collect or receive personal information that you provide to us directly, or that we obtain automatically when you use our Services, or that we obtain or receive from other sources, such as third-party services and organizations as described below.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us:

• Account Creation. We may collect information when you create an account with us, such as name, email address, phone number, business information such as company name and job title, and other sensitive information to conduct anti-money laundering and other required regulatory checks.
• Usage Information. We may collect information related to your use of and interactions with our Services, such as your name, account information, and trade information such as amounts traded.
• Financial Information. We may collect information such as your bank account details and billing address.
• Your Communications with Us. We may collect personal information such as name, email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us.
• Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
• Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public”, unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
• Contact Information. We may collect personal information from individuals when we attend conferences, trade shows, and other events. 

B. Information Collected Automatically

We may collect personal information automatically when you use our Services, including:

• Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. When we send you emails, we may track whether you open them to learn how to deliver a better customer and user experience and improve the Services. In addition, we may collect information that other people provide about you when they use our Services.
• Cookies, Pixel Tags/Web Beacons, and Other Technologies. Cookies are small text files placed on internet browsers that store information such as device type and configuration, preferences (e.g., language, time zone), and other information, to facilitate and enhance your online experience. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement with our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

Our uses of these Technologies fall into the following general categories:  

• Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security, or that allow you to make use of a particular functionality;
• Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
• Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
• Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
• Analytics. We may use Technologies and other third-party tools to process analytics information on our Services, such as Google Analytics. For more information, please visit  Google Analytics’ Privacy PolicyTo learn more about how to opt-out of Google Analytics’ use of your information, please click  here.
• Social Media Platforms. Our Services may contain social media plug-ins (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

See Section 4 below to understand your choices regarding these Technologies.  

C. Information Collected from Other Sources  

We may obtain information about you from other sources, including your name and email address from our customers, in order to create an account for you.   

If you do not provide certain information when requested, you may not be able to use the Services (or certain features or functionalities of the Services) if that information is necessary to provide you with the Services or if we are legally required to collect it.  

We may use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, and other purposes, as described below.

A. Provide Our Services

We use the personal information described above for the following business purposes: 

• To provide the Services. We may use your information to manage your information and accounts; provide access to certain areas, functionalities, and features of our Services; identify and authenticate access to our Services; process your transactions, and for other related purposes. 
• To send you electronic correspondence. We may answer requests for customer or technical support and communicate with you about your account, activities on our Services, and policy changes.
• To enable you to register for online or in-person events.
• Any other purposes related to providing the Services, which we may disclose to you at the time of collection.

B. Administrative Purposes 

We use your information for various administrative purposes, such as: 

• To improve our Services. We may use your information for research and development (including marketing research), network and information security, and fraud prevention; to measure interest and engagement in our Services; to improve, upgrade or enhance our Services; and to develop new products and Services. 
• To keep the Services, business, customers, and users safe and secure. This includes detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity; ensuring internal quality control and safety; authenticating and verifying individual identities; debugging to identify and repair errors with our Services; and auditing relating to interactions, transactions and other compliance activities.
• To comply with applicable laws and regulations. This includes, for example, meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us, or which we have been advised, recommended or informed that we are expected to comply with (including disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, and due diligence), internal policies, assisting law enforcement or investigations by relevant authorities, and/or handling your information protect or exercise our legal rights or defend against legal claims.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content, advertisements, and marketing materials. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking. If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below. 

D. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law. 

• Other Purposes. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information, and will obtain your consent when doing so if required by applicable law. 

E. Legal Basis

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 provide you the Services in accordance with our Terms;  
• To comply with legal obligations – for example, to comply with laws in relation to due diligence, accounting, taxes, and others;  
• To pursue our legitimate interests – for example, to improve and customize our Services; and  
• With your consent – for example, applicable laws may require us to obtain consent to collect and use your personal information or sensitive personal information, or send marketing materials to you.  

F. De-identified and Aggregated Information. 

We may use your personal information and other information about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. Such aggregated and/or de-identified data is not subject to this Privacy Policy.