Talos Privacy Policy

1. Introduction

Talos ("we", "our", or "us") is committed to protecting the privacy and security of personal information processed through our mortgage application processing platform. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our services.

This policy applies to mortgage brokers, financial institutions, and other entities ("Brokerages") that use the Talos platform to process mortgage applications and related documents, as well as to the individuals whose information is processed through our platform ("Applicants").

2. Information We Collect

2.1 Information Provided by Brokerages

Brokerages may upload to our platform various documents containing personal information of Applicants, including but not limited to:

  • Identification documents (driver's licenses, passports, etc.)
  • Financial statements and records
  • Tax documents
  • Employment information
  • Credit reports
  • Bank statements
  • Property documents
  • Loan applications

2.2 User Account Information

We collect information from Brokerage users when they register for and use our platform, including:

  • Name and contact details
  • Employment information
  • Login credentials
  • Usage data and analytics

3. How We Use Information

We use the information collected through our platform solely for the following purposes:

  • Providing document processing, organization, and analysis services
  • Generating reports and summaries of mortgage application data
  • Facilitating communication between Brokerages and Applicants
  • Maintaining the security and integrity of our platform
  • Complying with legal and regulatory requirements

We do not use client data to train, improve, or enhance our services or AI systems. All data uploaded to Talos is used exclusively for processing the specific mortgage applications for which it was provided.

4. Data Storage and Security

4.1 Storage Architecture

All data is stored in isolated, encrypted AWS S3 buckets specific to each Brokerage. Our serverless architecture via AWS Amplify provides additional security benefits by eliminating traditional server vulnerabilities.

4.2 Security Measures

We implement and maintain appropriate technical, administrative, and physical safeguards to protect personal information, including:

  • Encryption of data at rest and in transit
  • Role-based access controls through AWS Cognito
  • Isolated data environments for each Brokerage
  • Regular security assessments
  • Comprehensive access logging

4.3 Data Retention

Brokerages have control over the retention of data processed through the platform. When an application is marked as "COMPLETE," all associated data is removed from our system. However, Brokerages are responsible for maintaining records in accordance with applicable regulations.

5. Data Sharing and Disclosure

We exclusively use Amazon Web Services (AWS) to operate our platform. We do not engage any other third-party service providers to process personal information. All data stored on our platform occurs within AWS's Australian data centers.

6. Data Subject Rights

Under the Privacy Act 1988 and the Australian Privacy Principles, individuals have rights regarding their personal information. Applicants should contact their Brokerage directly to exercise these rights, which may include:

  • Accessing personal information
  • Correcting inaccurate information
  • Withdrawing consent for processing
  • Requesting deletion of information (subject to legal retention requirements)

7. Data Breach Procedures

We maintain a data breach response plan. In the event of a breach affecting personal information, we will:

  1. Assess the breach and determine if it is likely to result in serious harm
  2. Notify affected Brokerages promptly
  3. Assist Brokerages in fulfilling their obligations under the Notifiable Data Breaches Scheme
  4. Take steps to contain and remediate the breach

8. Data Storage and Processing

All client data uploaded to the Talos platform is stored securely within AWS's Australian data centers. While data storage occurs exclusively within Australia, certain specialized AI processing may utilize AWS services that operate in other regions. In such cases, we implement appropriate safeguards to protect personal information and ensure that no data is permanently stored outside of Australia. We have carefully selected our AWS services to balance powerful AI capabilities with strong data protection practices.

9. Cookies and Analytics

Our platform uses cookies and similar technologies to enhance user experience and collect analytics data. Users can manage cookie preferences through their browser settings.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify Brokerages of material changes by email or through the platform, and we encourage periodic review of this policy.

11. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us at: talos@somerson.co

Last updated: June 16, 2025