Titan Privacy Policy
Effective Date: October 6, 2026
Last Updated: October 2026
Contents
- Who We Are and What This Policy Covers
- Personal Information We Collect
- How We Use Personal Information
- Legal Bases for Processing
- Artificial Intelligence and Automated Decision-Making
- How We Disclose Personal Information
- Cookies and Similar Technologies
- Sale, Sharing, and Targeted Advertising
- How Long We Keep Personal Information
- International Data Transfers
- How We Protect Personal Information
- Your Privacy Rights
- How to Exercise Your Rights
- Additional Disclosures for California Residents
- Additional Disclosures for Other U.S. States
- Individuals in the EEA, United Kingdom, and Switzerland
- Individuals in Canada and Other Countries
- Children and Minors
- Third-Party Websites and Social Media
- Accessibility and Languages
- Changes to This Privacy Policy
- Contact Us
Appendix A: Job Applicant Privacy Notice
1. Who We Are and What This Policy Covers
1.1 About Titan
Titan OS, Inc., doing business as Titan Banking AI (“Titan,” “we,” “us,” or “our”), is a Delaware corporation headquartered at 5 Greenwich Office Park, Suite 100, Greenwich, CT 06831, United States. Titan provides a secure, auditable artificial intelligence platform for banks and other financial institutions. For the personal information described in this Privacy Policy, Titan is the controller (or “business,” as that term is used under California law). That means Titan decides why and how the information is processed.
1.2 Scope
This Privacy Policy explains how Titan collects, uses, discloses, retains, transfers, and protects personal information about:
- visitors to titanbanking.ai, our Trust Center, and any other website or online page that links to this Privacy Policy (the “Sites”), wherever those visitors are located;
- prospective customers, business contacts, and others who contact us or whom we contact about our products and services;
- representatives of our customers, partners, and vendors, including individuals authorized by our customers to access the Titan Platform (“Authorized Users”), to the extent we process their business contact, account, and access information to administer our business relationship and secure our services;
- individuals who register for or attend events and webinars that Titan hosts or sponsors;
- participants in meetings and calls with Titan;
- investors, prospective investors, and their representatives;
- job applicants, wherever located (see Appendix A); and
- independent contractors and vendors who provide services to Titan.
1.3 Information This Policy Does Not Cover
This Privacy Policy does not apply to data that our customers or their users submit to, upload to, or process through the Titan Platform (“Customer Data”). That includes any personal information about our customers’ own customers, employees, or other individuals.
Titan processes Customer Data only on behalf of, and under the instructions of, the relevant customer. In doing so, Titan acts as a processor or service provider under the customer’s Master Services Agreement and Data Processing Addendum with Titan. Each customer controls its Customer Data and is responsible for giving its own privacy notices to the individuals whose information it submits.
If you are a customer of a bank or financial institution that uses Titan, please review that institution’s privacy notice and contact it directly. If we receive a request about Customer Data, we will refer it to the relevant customer.
1.4 Titan Workforce
Titan employees and contractors receive a separate internal notice describing how Titan processes workforce personal information. Sections 2, 9, and 11 of this Privacy Policy summarize those practices.
1.5 Notice at Collection
This Privacy Policy is Titan’s notice at collection for the personal information described here. For job applicants, Appendix A is also a notice at collection.
1.6 Key Terms
- Personal information (or personal data) means information that identifies, relates to, describes, or could reasonably be linked to an identified or identifiable individual.
- Processing means any operation performed on personal information, including collection, use, storage, disclosure, and deletion.
- Sensitive personal information means the categories of personal information that applicable law treats as sensitive, such as government identification numbers, financial account information, and information about health, race, or ethnicity.
2. Personal Information We Collect
2.1 Categories of Personal Information
2.2 Sensitive Personal Information
Titan collects sensitive personal information only from applicants, employees, contractors, and investors. We collect it only when it is needed for hiring, employment, payment, tax, benefits, investment administration, legal compliance, or security purposes. This may include:
- Social Security or other government identification numbers;
- bank account details for payroll, contractor, or investor payments;
- background check information (with authorization);
- information needed to provide reasonable accommodations; and
- voluntarily provided demographic information used for equal employment opportunity reporting.
Where applicable law requires consent before processing sensitive personal information, we obtain it. We do not ask Site visitors, prospects, event attendees, or business contacts for sensitive personal information. Please do not include it in inquiries or communications to us.
2.3 Biometric and Health Information
Titan does not collect biometric identifiers or biometric information, such as facial geometry, fingerprints, or voiceprints, from any individual covered by this Privacy Policy. Titan collects health-related information only in two situations: when you voluntarily provide it to request an accommodation, or when it is required for employment or benefits administration. We use it only for that purpose.
2.4 Sources of Personal Information
We collect personal information:
- directly from you, when you complete a form, request a demo, register for an event, attend a meeting, invest in Titan, apply for a job, sign a contract, or communicate with us;
- automatically, through cookies, pixels, and similar technologies when you use the Sites or open our emails (see Section 7);
- from our customers and partners, when they designate Authorized Users or business contacts;
- from professional networking platforms, including LinkedIn Sales Navigator, and from publicly available business sources;
- from recruiters and staffing agencies that refer candidates to Titan;
- from our legal, financial, and transaction advisors, in connection with investments in Titan; and
- from service providers, including our background check provider (with your authorization), recruiting, HR, and payroll platforms, and contractor management platforms.
2.5 Information We Obtain From Other Sources
When we obtain your personal information from a source other than you, such as LinkedIn Sales Navigator or a referral, we will make this Privacy Policy available to you. We will do so no later than our first communication with you, and in any event within one month after we obtain the information.
2.6 Whether You Must Provide Personal Information
You do not have to give us personal information to browse the Sites. Some information is required for us to:
- respond to your inquiry;
- register you for an event;
- administer an investment;
- consider your job application; or
- enter into or perform a contract with you or your organization.
If you do not provide that information, we may be unable to do those things. Where the law requires us to collect certain information, such as tax or employment eligibility information, we will tell you when we collect it.
3. How We Use Personal Information
3.1 Purposes
We use personal information to:
- respond to inquiries, schedule meetings and demonstrations, and communicate with you;
- identify and contact prospective customers and manage sales relationships;
- send marketing communications about Titan products, services, and events, subject to your right to opt out;
- administer customer, partner, and vendor relationships, including contracting, invoicing, payments, and account administration;
- create, authenticate, and manage Authorized User accounts and control access to the Titan Platform;
- record, transcribe, and summarize meetings where participants have been notified, to keep accurate records and follow up on discussions;
- secure our Sites, systems, and services, including detecting, preventing, and investigating security incidents, fraud, and misuse;
- understand how visitors use the Sites and how recipients engage with our emails, and improve our content and performance;
- host, administer, and follow up on events and webinars;
- administer investments in Titan, communicate with investors, and comply with securities, tax, anti-money laundering, and corporate law requirements;
- recruit, evaluate, and hire candidates, including conducting background checks with authorization;
- engage, manage, and pay independent contractors and vendors;
- administer employment, payroll, benefits, and workforce compliance;
- comply with legal, regulatory, tax, audit, and recordkeeping obligations, and respond to lawful requests from public authorities;
- establish, exercise, or defend legal claims and enforce our agreements;
- support corporate transactions, including financings, mergers, acquisitions, and related due diligence;
- create deidentified or aggregated information as described in Section 6.4; and
- carry out other purposes we describe to you when we collect the information, or with your consent.
3.2 Data Minimization and New Purposes
We collect only the personal information that is reasonably necessary and proportionate for these purposes. Before using personal information for a purpose materially different from those described here, we will give you notice and, where required by law, obtain your consent.
4. Legal Bases for Processing
4.1 Legal Bases by Purpose
Some laws require a legal basis for processing, including the EU General Data Protection Regulation (GDPR), the UK GDPR, and the Swiss Federal Act on Data Protection. Where those laws apply, Titan relies on the following legal bases:
4.2 Special Categories of Personal Data
When Titan processes special categories of personal data, such as health information for accommodations or voluntary demographic information, we rely on your explicit consent or on obligations and rights under employment and social security law, as applicable.
4.3 Withdrawing Consent and Objecting
You may withdraw consent at any time. Withdrawing does not affect processing that took place before you withdrew. You may also object at any time to processing based on legitimate interests, as described in Section 16.
5. Artificial Intelligence and Automated Decision-Making
5.1 How Titan Uses AI in Its Own Operations
Titan personnel may use generative AI tools to support internal business activities, such as drafting and summarizing communications, research, software development, and productivity. Titan governs the use of those tools through internal AI governance, data classification, and acceptable use policies. Those policies are designed to limit the personal information entered into the tools and to require human review of AI-generated output.
5.2 Automated Decision-Making
Except as described in Appendix A for recruiting, Titan does not use personal information covered by this Privacy Policy to make decisions based solely on automated processing that produce legal or similarly significant effects for individuals. In recruiting, AI-assisted tools support our recruiting team, and a person at Titan makes every hiring decision.
5.3 Large Language Model Training
Titan does not collect, use, or sell personal information covered by this Privacy Policy for the purpose of training large language models.
5.4 Interacting With AI on the Sites
If Titan offers an AI-powered chat or assistant feature on the Sites, we will tell you clearly that you are interacting with an AI system, unless that is obvious from the context.
5.5 Meeting Recordings and AI Note-Taking
Titan may record, transcribe, or generate AI summaries of meetings and calls using features of our video conferencing and productivity tools. We notify participants when a meeting is being recorded or transcribed, and we obtain consent where required by law. If you do not want a meeting recorded or transcribed, tell the Titan host and we will turn those features off.
5.6 Titan Platform AI
AI processing performed through the Titan Platform for our customers is governed by our customer agreements and is outside the scope of this Privacy Policy, as described in Section 1.3.
6. How We Disclose Personal Information
6.1 Service Providers
We disclose personal information to service providers that process it on our behalf. Our written contracts with them restrict their use of the information to providing services to Titan and require them to protect it. Our principal service providers include:
6.2 Other Disclosures
We may also disclose personal information:
- to recruiters and staffing agencies engaged by Titan, in connection with candidates they refer;
- to professional advisors, such as lawyers, auditors, accountants, and insurers, under confidentiality obligations;
- to comply with law, regulation, legal process, or lawful requests from public authorities, as described in Section 6.3;
- to protect the rights, property, or safety of Titan, our customers, personnel, or others, including to detect and prevent fraud and security incidents;
- to actual or prospective investors, acquirers, or successors in connection with a financing, merger, acquisition, reorganization, or sale of assets, subject to confidentiality obligations;
- to third-party technology providers through cookies on the Sites, as described in Sections 7 and 8; and
- with your direction or consent.
6.3 Requests From Public Authorities
Titan discloses personal information to public authorities only when we believe disclosure is required by applicable law or legal process. We review each request for legal validity and scope, and we disclose only the information the request requires. Where the law permits, we will notify the affected individual before disclosing.
6.4 Deidentified and Aggregated Information
Titan may create deidentified or aggregated information that cannot reasonably be used to identify you. Titan commits to maintain and use deidentified information only in deidentified form and not to attempt to reidentify it, except to test whether our deidentification processes are effective. We contractually require anyone who receives deidentified information from us to make the same commitments.
7. Cookies and Similar Technologies
7.1 What We Use
The Sites use cookies, pixels, and similar technologies that fall into these categories:
- Strictly necessary: required for the Sites to operate and stay secure, including to remember your cookie choices. These cannot be disabled.
- Analytics: including Google Analytics, which helps us understand how visitors use the Sites.
- Marketing: technologies that may help us measure the effectiveness of our marketing and reach business audiences, where used.
7.2 Email Pixels
Our marketing emails may contain small pixels or tracked links that tell us whether an email was opened or a link was clicked. You can limit this by turning off automatic image loading in your email client.
7.3 Region-Specific Consent
If you visit the Sites from the European Economic Area, the United Kingdom, or Switzerland, we ask for your consent before placing analytics or marketing cookies. You can withdraw that consent at any time.
7.4 Your Choices
You can review and change your cookie preferences at any time through the cookie settings tool on the Sites, which is managed through Ketch. You can also opt out of Google Analytics using Google’s browser add-on. Disabling certain cookies may affect how the Sites function.
7.5 Opt-Out Preference Signals
Titan recognizes Global Privacy Control (GPC) and similar legally recognized opt-out preference signals. When we detect one, we treat it as a request to opt out of the sale or sharing of personal information and targeted advertising. The opt-out applies to that browser or device and to any profile we associate with it.
7.6 Do Not Track
There is no industry standard for responding to browser “Do Not Track” signals, so we do not respond to them separately from GPC.
8. Sale, Sharing, and Targeted Advertising
8.1 Website Technologies
Titan does not sell personal information in exchange for money. Titan allows certain third-party analytics and marketing technology providers to collect information through cookies on the Sites, as described in Section 7. Under some state privacy laws, this may be considered a “sale” or “sharing” of personal information or processing for “targeted advertising.”
8.2 How to Opt Out
You may opt out at any time by:
- clicking the “Your Privacy Choices” link in the footer of the Sites;
- adjusting your cookie preferences; or
- enabling GPC in your browser.
8.3 Information We Never Sell or Share
Titan does not sell or share the personal information of job applicants, employees, contractors, investors, or Authorized Users. Titan does not sell personal information of individuals it knows are under 18 years of age, and does not use their personal information for targeted advertising.
9. How Long We Keep Personal Information
9.1 Retention Criteria
We keep personal information only as long as reasonably necessary for the purposes described in this Privacy Policy. We set retention periods based on:
- the purpose of the processing;
- our relationship with you;
- legal and regulatory retention requirements;
- statutes of limitations; and
- the sensitivity of the information.
When we no longer need personal information, we delete or deidentify it. We may keep a record longer than the period shown below in three situations: when the law requires it, when the record is subject to a legal hold, or when it is needed to establish, exercise, or defend legal claims. Where applicable law gives you the right to have specific records deleted sooner, we will honor that right.
9.2 Retention Periods
10. International Data Transfers
10.1 Where We Process Personal Information
Titan is based in the United States, and our primary systems are hosted in Microsoft Azure data centers located in the United States. If you are located outside the United States, your personal information will be transferred to, stored in, and processed in the United States. Data protection laws in the United States may differ from those in your country.
Some of our service providers may also process personal information in other countries. For example, our contractor management provider processes information about contractors in the countries where those contractors reside.
10.2 Safeguards
Some transfers go from the European Economic Area, the United Kingdom, or Switzerland to the United States or to another country that has not been recognized as providing adequate protection. For those transfers, we rely on appropriate safeguards, including:
- the European Commission’s Standard Contractual Clauses;
- the UK International Data Transfer Addendum;
- the corresponding Swiss transfer mechanisms; and
- supplementary technical, contractual, and organizational measures, where appropriate.
Where no safeguard is available, we transfer personal information only as otherwise permitted by law, for example where the transfer is necessary to perform a contract with you or is made at your request.
10.3 Copies of Safeguards
You may request a copy of the safeguards we use for international transfers by contacting privacy@titanbanking.ai. We may redact commercial terms that are not relevant to your data protection rights.
11. How We Protect Personal Information
11.1 Security Measures
Titan maintains administrative, technical, and physical safeguards designed to protect personal information, including:
- encryption of data in transit and at rest;
- multi-factor authentication and role-based access controls based on least privilege;
- logging and monitoring of system access and activity;
- security due diligence on, and contractual security obligations for, service providers;
- documented incident response, business continuity, and disaster recovery procedures, which we test regularly;
- independent third-party penetration testing; and
- security awareness and privacy training for personnel.
More information about Titan’s security program is available in our Trust Center on the Sites.
11.2 Security Incidents
No method of transmission or storage is completely secure, and we cannot guarantee the security of personal information. If we experience a security incident affecting your personal information, we will notify you and the relevant authorities as applicable law requires.
12. Your Privacy Rights
12.1 Rights Available
Depending on where you live, and subject to exceptions under applicable law, you may have the right to:
- Know and access: confirm whether we process your personal information, and obtain the categories and specific pieces of personal information we hold, the sources, the purposes, and the categories of recipients;
- Correct: ask us to correct inaccurate personal information;
- Delete: ask us to delete personal information we collected from or about you;
- Portability: receive personal information you provided to us in a portable, readily usable format;
- Opt out: opt out of the sale or sharing of personal information, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects;
- Limit: limit the use of sensitive personal information to permitted purposes. Titan uses sensitive personal information only for purposes that do not give rise to this right;
- Third-party list: where state law provides it, obtain a list of the specific third parties, or categories of third parties, to which we disclosed your personal information or any personal information;
- Question profiling: where state law provides it, question the result of profiling used for a decision with legal or similarly significant effects, learn the reason for the decision, review the personal information used, and have the decision reevaluated if it was based on inaccurate information;
- Withdraw consent: withdraw any consent you have given, without affecting processing that took place before withdrawal;
- Appeal: appeal our decision on your request; and
- Non-retaliation: exercise these rights without discrimination or retaliation.
Titan extends these rights to individuals in all U.S. states, to the extent the law permits, whether or not a specific state law applies to Titan. Individuals in the EEA, United Kingdom, and Switzerland have the additional rights described in Section 16.
12.2 Marketing Opt-Out
You may unsubscribe from marketing emails at any time, either by using the unsubscribe link in any marketing email or by contacting privacy@titanbanking.ai. We may still send you transactional or relationship communications.
13. How to Exercise Your Rights
13.1 Submitting a Request
You may submit a request by:
- emailing privacy@titanbanking.ai;
- submitting our online privacy request form, available through the “Your Privacy Choices” link in the footer of the Sites; or
- writing to us at the mailing address in Section 22.
13.2 Verification
To protect your information, we will verify your identity before responding. We generally ask you to confirm information we already hold, such as your name and email address. We may ask for more information for requests involving sensitive personal information or specific pieces of personal information. We use information provided for verification only for that purpose.
13.3 Authorized Agents
You may use an authorized agent to submit a request. We will require the agent to provide your signed written permission. Unless the agent holds a valid power of attorney, we may also ask you to verify your identity directly with us and confirm that you gave the agent permission.
13.4 Response Timing
We will confirm receipt of your request within 10 business days and respond within 45 calendar days. If we need more time, we may extend the response period once by up to 45 additional days, as permitted by law, and will tell you why.
For individuals in the EEA, United Kingdom, and Switzerland, we respond within one month. As permitted by law, we may extend that period by up to two additional months for complex or numerous requests.
13.5 Appeals
If we deny your request in whole or in part, you may appeal within 60 days of our decision by emailing privacy@titanbanking.ai with the subject line “Privacy Request Appeal.” We will respond in writing within the period required by applicable law. If your appeal is denied, you may contact the attorney general of your state.
13.6 Privacy Complaints
If you have a concern about how Titan handles your personal information, you may submit a complaint through our online privacy request form or by emailing privacy@titanbanking.ai with the subject line “Privacy Complaint.” We will acknowledge your complaint within 30 days, look into it, keep you informed of our progress, and tell you the outcome.
14. Additional Disclosures for California Residents
14.1 Applicability
This Section supplements this Privacy Policy for California residents, to the extent the California Consumer Privacy Act, as amended (CCPA), applies to Titan.
14.2 Categories Collected and Disclosed in the Past 12 Months
We collect these categories from the sources described in Section 2.4, for the purposes described in Section 3, and keep them for the periods described in Section 9.
14.3 Sensitive Personal Information
Titan uses and discloses sensitive personal information only for purposes permitted under California regulations, such as performing services reasonably expected by the individual, security and integrity, and employment and legal compliance purposes. Titan does not use sensitive personal information to infer characteristics about individuals.
14.4 Sale and Sharing
See Section 8. To opt out, click the “Your Privacy Choices” link in the footer of the Sites or enable GPC.
14.5 Financial Incentives
Titan does not offer financial incentives or price or service differences in exchange for personal information.
14.6 Shine the Light
California residents may ask whether we disclosed personal information to third parties for their own direct marketing purposes in the prior calendar year. Titan does not disclose personal information to third parties for their own direct marketing purposes. Requests may be sent to privacy@titanbanking.ai.
15. Additional Disclosures for Other U.S. States
15.1 State Privacy Laws
Residents of states with comprehensive consumer privacy laws may exercise the rights described in Section 12 to the extent their state’s law applies. These states include Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. Titan applies the same practices to residents of states whose privacy laws take effect after the date of this Privacy Policy.
15.2 Specific Third Parties
Residents of Oregon, Minnesota, and other states that provide this right may request a list of the specific third parties to which Titan has disclosed their personal information. If we do not maintain that information in a format specific to you, we will provide a list of the specific third parties to which we have disclosed personal information generally.
15.3 Profiling
Titan does not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers, except as described in Appendix A for recruiting. Where state law gives you the right to question the result of such profiling, you may exercise it as described in Section 13.
15.4 Nevada
Titan does not sell covered information for monetary consideration as defined under Nevada law. Nevada residents may submit an opt-out request to privacy@titanbanking.ai, and we will honor it if our practices change.
16. Individuals in the EEA, United Kingdom, and Switzerland
16.1 Applicability and Controller
This Section applies to the extent the GDPR, the UK GDPR, or the Swiss Federal Act on Data Protection applies to Titan’s processing of your personal data. The controller is Titan OS, Inc., 5 Greenwich Office Park, Suite 100, Greenwich, CT 06831, United States. You can contact us at privacy@titanbanking.ai.
16.2 Purposes and Legal Bases
The purposes for which we process your personal data, the legal bases we rely on, and the legitimate interests we pursue are described in Section 4.
16.3 Your Rights
Subject to applicable law, you have the right to:
- access your personal data and receive information about how we process it;
- correct inaccurate or incomplete personal data;
- erase your personal data;
- restrict our processing of your personal data;
- object to processing based on our legitimate interests, and object at any time to processing for direct marketing;
- receive personal data you provided to us in a structured, commonly used, machine-readable format and have it transmitted to another controller;
- withdraw consent at any time, where processing is based on consent, without affecting processing that took place before withdrawal; and
- not be subject to a decision based solely on automated processing that produces legal or similarly significant effects, except as permitted by law. As described in Section 5.2, Titan does not make such decisions.
16.4 Automated Decision-Making
Titan’s use of AI-assisted tools in recruiting is described in Appendix A, Section A.7. A person at Titan makes every hiring decision. Titan does not make decisions based solely on automated processing about individuals covered by this Privacy Policy.
16.5 Complaints
You may make a complaint to Titan about how we handle your personal data, using the online privacy request form or by emailing privacy@titanbanking.ai with the subject line “Privacy Complaint.” We will:
- acknowledge your complaint within 30 days;
- take appropriate steps to investigate it;
- keep you informed of progress; and
- tell you the outcome without undue delay.
You also have the right to lodge a complaint with the data protection supervisory authority in the country where you live or work, or where you believe a violation occurred. In the United Kingdom, that is the Information Commissioner’s Office. In Switzerland, it is the Federal Data Protection and Information Commissioner.
16.6 International Transfers
Section 10 describes how we transfer personal data outside the EEA, United Kingdom, and Switzerland, and how you can obtain a copy of the safeguards we use.
17. Individuals in Canada and Other Countries
17.1 Canada
Titan is accountable for personal information under its control, including information transferred to service providers for processing. Personal information about individuals in Canada may be stored and processed in the United States and other countries where our service providers operate. While there, it may be accessible to courts, law enforcement, and national security authorities of those countries under their laws.
Titan’s Privacy Officer (see Section 22) is accountable for Titan’s compliance with this Privacy Policy. You may request access to or correction of your personal information, or ask questions about our handling of it, by contacting privacy@titanbanking.ai. You also have the right to file a complaint with the Office of the Privacy Commissioner of Canada or the applicable provincial privacy regulator.
17.2 Other Countries
If you are located in another country with data protection laws that give you rights over your personal information, you may exercise those rights by contacting privacy@titanbanking.ai. We will respond as required by the law that applies to you.
18. Children and Minors
The Sites and Titan’s services are intended for businesses and professionals and are not directed to individuals under 18. We do not knowingly collect personal information from children under 16. We do not sell personal information of individuals we know are under 18, and we do not use their personal information for targeted advertising. If we learn that we have collected personal information from a child under 16 without appropriate consent, we will delete it.
19. Third-Party Websites and Social Media
The Sites may link to third-party websites and services, such as LinkedIn. Titan does not control those websites, and their own policies govern their privacy practices.
If you interact with Titan’s pages on social media platforms, the platform may collect information about your interaction and provide Titan with aggregated statistics about page activity. The platform’s own privacy policy governs its processing.
20. Accessibility and Languages
This Privacy Policy is designed to be accessible to individuals with disabilities. To receive it in an alternative format, contact privacy@titanbanking.ai. If Titan provides contracts, notices, or other business information in a language other than English, we will make this Privacy Policy available in that language.
21. Changes to This Privacy Policy
We review this Privacy Policy at least once every 12 months and update it when our practices change. The “Last Updated” date at the top shows the month and year of the most recent revision.
If we make material changes, we will notify you by posting a notice on the Sites or by other appropriate means. Where the law requires it, we will obtain your consent before applying material changes to personal information collected before the change, or give you an opportunity to withdraw your consent.
22. Contact Us
Titan has designated a Privacy Officer who is responsible for overseeing Titan’s privacy practices and compliance with this Privacy Policy. For questions, requests, or complaints:
Email: privacy@titanbanking.ai
Legal: legal@titanbanking.ai
Mail:
Titan OS Inc
Attn: Privacy Officer
5 Greenwich Office Park, Suite 100
Greenwich, CT 06831
United States
Appendix A: Job Applicant Privacy Notice
A.1 Purpose and Scope
This notice applies to all individuals who apply for employment or for engagement as an independent contractor with Titan, wherever they are located. It is a notice at collection and describes:
- the personal information Titan collects about applicants;
- why we collect it;
- how we use AI-assisted tools in recruiting; and
- how long we keep applicant information.
Section A.12 contains additional disclosures for applicants in specific jurisdictions. This notice supplements the Titan Privacy Policy.
A.2 Personal Information We Collect
A.3 Sources
We collect applicant information from:
- you;
- recruiters and staffing agencies;
- references you provide;
- professional networking sites such as LinkedIn;
- Checkr, with your authorization; and
- our applicant tracking platform, Ashby.
A.4 Purposes
We use applicant information to:
- evaluate your qualifications and communicate with you about your application;
- schedule, conduct, and record interviews and assessments;
- verify information you provide and conduct background checks, with authorization;
- provide reasonable accommodations;
- consider you for future roles, if you agree to join our talent pool;
- comply with equal employment opportunity, immigration, tax, and other legal obligations;
- extend and administer offers and onboard new hires;
- protect the security of our recruiting systems and prevent fraud; and
- establish, exercise, or defend legal claims.
Where the law requires a legal basis for this processing, Section 4 of the Privacy Policy describes the bases we rely on.
A.5 Sensitive Personal Information
Titan collects sensitive personal information from applicants, such as Social Security numbers, government identification, background check information, and voluntary demographic information. We collect it only for hiring, legal compliance, and security purposes, and we do not use it to infer characteristics about you.
A.6 Background Checks
Titan conducts background checks only after a conditional offer of employment. Before any check, Titan gives you a separate written disclosure and obtains your written authorization, as required by the Fair Credit Reporting Act and applicable state, local, and foreign law.
Where applicable fair chance laws require it, Titan will:
- not ask about or consider criminal history until after a conditional offer;
- make an individualized assessment; and
- give you notice and an opportunity to respond before taking any adverse action based on a background check.
A.7 Use of AI and Automated Tools in Recruiting
(a) What We Use
Titan uses Ashby, an applicant tracking platform that includes AI-assisted features, to help organize, summarize, and evaluate application materials against the qualifications and requirements of the role.
(b) Human Decision-Making
These tools support human judgment and do not replace it. A member of Titan’s recruiting team reviews applications and makes every hiring decision.
(c) Notice
Titan identifies its use of AI-assisted tools in this notice, on our careers page, and in job postings. Titan also gives any additional advance notice required by the law of the place where you live or where the role is based.
(d) Alternatives and Accommodations
You may request an alternative selection process or a reasonable accommodation at any time by contacting privacy@titanbanking.ai. Requesting an alternative or accommodation will not negatively affect your candidacy.
(e) Fairness
Titan monitors its use of AI-assisted tools for potential bias and keeps data used in or resulting from them as described in Section A.10.
(f) Facial Recognition and Video Analysis
Titan does not use facial recognition technology to create a facial template of any applicant during an interview, and does not use AI to analyze applicant video interviews. If Titan ever does either, it will first give the notice and obtain the consent or signed waiver required by applicable law.
A.8 Interview Recordings
Titan may record video or audio interviews to support accurate evaluation and consistency across candidates. We will tell you before an interview is recorded and ask for your consent. You may decline recording without affecting your candidacy. Titan shares interview recordings only with personnel and service providers who need them to evaluate your candidacy.
A.9 Disclosures
We disclose applicant information to:
- service providers that support recruiting, including Ashby for applicant tracking, Zoom for video interviews, and Checkr for background checks;
- recruiters and staffing agencies engaged by Titan;
- professional advisors; and
- others as required by law.
Titan does not sell or share applicant personal information, including for cross-context behavioral advertising.
A.10 Retention
Titan keeps applicant records for four years after the date of the hiring decision. This includes application materials, interview notes and recordings, assessment results, background check results, and data used in or resulting from AI-assisted tools.
Records may be kept longer if they relate to a pending claim, charge, investigation, or legal hold. If applicable law gives you the right to have specific records deleted sooner, such as interview videos under Section A.12(b), or requires a shorter retention period in your country, we will honor that right or requirement.
If you are hired, your application records become part of your personnel file and are kept as described in Section 9 of the Privacy Policy. With your consent, Titan may consider your application for future roles for up to 24 months. This does not shorten the four-year retention period above.
A.11 Your Rights
Depending on where you live, you may have the rights described in Sections 12 and 16 of the Privacy Policy, including the rights to know, access, correct, and delete personal information, subject to legal exceptions. Titan will not retaliate against you for exercising these rights. To submit a request, follow the instructions in Section 13.
A.12 Additional Disclosures for Specific Jurisdictions
(a) California
California applicants have the rights described in Section 14 of the Privacy Policy, to the extent the CCPA applies to Titan. Titan keeps employment records, including data used in or resulting from automated-decision systems, for at least four years. Where California law requires a separate pre-use notice before automated decisionmaking technology is used to make a significant decision about you, Titan will provide it, along with any opt-out and access rights required by law.
(b) Illinois
Titan notifies Illinois applicants that it uses AI-assisted tools in recruiting and hiring, as described in Section A.7. If Titan asks applicants for Illinois-based positions to record video interviews and uses AI to analyze them, Titan will, before the interview:
- notify you that AI may be used;
- explain how the AI works and the general types of characteristics it evaluates; and
- obtain your consent.
Titan will not use AI to evaluate you without that consent. Titan will share those videos only with persons whose expertise or technology is needed to evaluate your candidacy. Within 30 days after your request, Titan will delete your interview videos, including backup copies, and instruct anyone who received copies to delete them.
(c) New York City
If Titan uses an automated employment decision tool to evaluate candidates who reside in New York City, Titan will:
- use the tool only after it has been subject to an independent bias audit within the prior year;
- publish a summary of the most recent bias audit results and the tool’s distribution date on our careers page; and
- notify you at least 10 business days before use that the tool will be used, describe the job qualifications and characteristics it will assess, and explain how to request an alternative selection process or accommodation.
You may also request information about the type of data collected for the tool, its source, and Titan’s data retention policy by contacting privacy@titanbanking.ai.
(d) Colorado
Beginning January 1, 2027, if Titan uses automated decision-making technology to materially influence a hiring decision about a Colorado applicant, Titan will notify you before the decision is made. If the decision is adverse, Titan will provide a plain-language description of the technology’s role within 30 days. You may request correction of inaccurate personal data used by the technology.
(e) Connecticut
Beginning October 1, 2027, if Titan uses automated employment-related decision technology in making a decision about a Connecticut applicant, Titan will provide written notice describing:
- the purpose of the technology;
- the technology used;
- the categories and sources of personal data it analyzes; and
- how to contact Titan.
Titan will also tell you when you are interacting directly with such technology, unless that is obvious.
(f) Maryland
Titan will not use a facial recognition service to create a facial template during an interview with a Maryland applicant unless the applicant signs a waiver that states:
- the applicant’s name;
- the date of the interview;
- that the applicant consents to the use of facial recognition during the interview; and
- whether the applicant read the waiver.
(g) Other U.S. Jurisdictions
Where other state or local laws give applicants additional rights regarding AI, automated tools, background checks, or recordings, Titan will provide the notices and honor the rights those laws require.
(h) Applicants Outside the United States
If you apply from the EEA, United Kingdom, Switzerland, Canada, or another country, your application information will be transferred to and processed in the United States as described in Section 10 of the Privacy Policy. Titan conducts background checks on applicants outside the United States only to the extent local law permits. Where the EU Artificial Intelligence Act or similar laws impose obligations on employers that use AI systems in recruitment, Titan will comply with the obligations that apply to it, including human oversight and notice to affected applicants.
A.13 Contact
Send questions about this notice, requests for an alternative selection process or accommodation, privacy requests, and complaints to privacy@titanbanking.ai or to:
Titan OS Inc
Attn: Privacy Officer
5 Greenwich Office Park, Suite 100
Greenwich, CT 06831
United States