Last updated: September 22, 2026

Hudson River Trading Global Applicant Privacy Notice

APPLICABILITY.

Hudson River Trading LLC and our affiliates (collectively, “HRT”) respect your concerns about privacy. This Applicant Privacy Notice (“Notice”) applies to personal information about individuals who are (1) current and former applicants and interview applicants, and (2) third parties whose information is provided to us in connection with an applicant’s job application (including, but not limited to, next of kin, emergency contacts or dependents).

The Notice sets out the basis on which any personal information about you will be processed by us. 

If you are a California consumer, please see HRT’s California Consumer Statement for more information.

PERSONAL INFORMATION THAT WE COLLECT ABOUT YOU.

We may collect and process the following personal information about you:

• personal details, such as your title and name, date of birth, age, gender, contact information (e.g., postal address, telephone number, and email address), government-issued identification number (e.g., passport, driver’s license or Social Security number), signature, work eligibility information, languages spoken, and sensory information such as photographs or video images or audio;
• recruitment and selection data, such as your skills and experience, education history, job history and qualifications, references, CV and application, record of interview, interview notes and assessment, vetting and verification information (e.g., results of credit reference check, financial sanction check and a criminal record check where permitted or required by applicable law), right to work verification, information related to the outcome of your application, and details of any offer made to you;
• demographic information, such as, where permitted by law and provided voluntarily, data regarding gender, race/ethnicity, marital status, religion, or citizenship status or nationality;
• information about travel arrangements, expense reimbursements and similar commercial information;
• information regarding the use of HRT websites, such as IP address, device ID and other browsing data;
• any other personal information which you choose to disclose during the recruitment process.

Subject to applicable law, some of the information described above constitutes special category data (also known as sensitive data). Sensitive data includes information relating to racial or ethnic origin, political opinions, religious or philosophical beliefs, health, trade union membership, sex life or sexual orientation, biometric or genetic information, and information relating to criminal records, offences or proceedings. HRT collects sensitive data only when permitted or required to do so by law, in circumstances described below.

SOURCES OF PERSONAL INFORMATION.

We obtain information from a variety of sources, often directly from you (e.g., when you apply for a job through our websites) or from third parties such as through social networks, internet service providers and operating systems, our affiliates, references from a previous employer or teacher; candidates from recruitment agencies, or where we employ a third party to carry out a background check (where permitted by applicable law). We may also obtain information from government entities or publicly available sources.

USES OF YOUR PERSONAL DATA.

To the extent required by applicable law, we may collect and process your personal information based on your consent or because it is in our legitimate business interests to do so. We rely on your consent only where we specifically indicate this at the point of collection; where we rely on consent, you may withdraw it at any time, as easily as you gave it, without affecting the lawfulness of processing before withdrawal. These legitimate business interests include:

• for recruitment and selection purposes, including to process, review and evaluate job applications; assess your skills, qualifications and suitability for a role; determine physical and/or mental fitness for work; carry out background and reference checks, where applicable; verify your identity; develop and improve our internal recruitment processes; conduct applicant trend analysis; make a job offer and provide a contract of employment; determine salary and other forms of compensation; onboard you as personnel where you accept an offer from us; provide access to facilities; provide references; reimburse expenses; make travel arrangements; secure immigration statuses; keep records related to our hiring processes; communicate with you about the recruitment process; review hiring decisions; map talent; develop market intelligence and insights; and handle any query, challenge or request for feedback received in relation to our recruitment decision;
• to protect private, confidential and proprietary information of HRT, its employees, and third parties;
• to enforce our legal rights and obligations, comply with legal or regulatory requirements (including checking your legal right to work) and for any purposes in connection with any legal claims made by, against or otherwise involving you;
• to comply with lawful requests by public authorities (including without limitation to meet national security or law enforcement requirements), discovery requests, or where otherwise required or permitted by applicable laws, court orders, government regulations, or regulatory authorities (including without limitation data protection, tax and employment authorities), whether within or outside your country; and
• for other purposes permitted by applicable law, including (subject to applicable law) legitimate interests pursued by HRT where these are not overridden by the interests or fundamental rights and freedoms of candidates and where these have been explained to you before the relevant data is collected or the processing is carried out.

Subject to applicable law, we may also need to process your personal information to decide whether to enter into a contract of employment (or other arrangement) with you, or to take steps at your request prior to entering into such a contract.

Sensitive data may be collected and processed by HRT for the following purposes:

• documentation such as work permits, details of residency and proof of citizenship may be processed to assess and review your eligibility to work for HRT in the jurisdiction in which you apply. Subject to applicable law, we process this information where (1) we have your explicit consent to do so, (2) it is in the public interest to do so, such as, to determine whether an individual has committed an unlawful act or has been involved in dishonesty, malpractice or other serious misconduct, or (3) we need to process this information to exercise our rights and perform obligations in connection with your work for HRT;
• information about your health (including any medical condition, health and disability) may be collected to consider whether we need to provide appropriate adjustments during the recruitment process. We process this information where we have your explicit consent to do so or to exercise our rights and perform obligations in connection with your work for HRT;
• information relating to gender, military experience, disability status, racial or ethnic origin, religious or  philosophical beliefs, or other protected characteristics, may be used to review HRT’s equal opportunity profile if such processing is necessary and to ensure compliance with anti-discrimination laws or where it is in the public interest to do so, including the collection of statistical data or in the event of a complaint where such characteristics or information are provided and/or relevant to the particular complaint; and
• any information that is required for us to establish, exercise or defend legal claims may be processed to the extent permitted or required by applicable law.

Personal information relating to criminal convictions and offenses will only be processed where authorized by applicable laws. 

USE OF ARTIFICIAL INTELLIGENCE TOOLS

We use artificial intelligence (“AI”) technologies provided by third-party vendors to support and improve the efficiency of our business operations and recruiting efforts.

This includes using recruitment platforms which incorporate AI tools to assist us in evaluating and managing candidate applications. This may include AI-powered summarization, transcription, and the use of AI to analyse your personal data — such as your CV, application responses, and other information you provide during the recruitment process — to, among other things, identify relevant skills, experience, and qualifications, and to support us in assessing your suitability for a role. 

This processing may constitute profiling within the meaning of the UK and EU General Data Protection Regulation as it involves the automated processing of your personal data to evaluate certain personal aspects relating to you, including your professional capacity and suitability for employment.

No decisions regarding your application are made solely based on automated processing, including profiling. A member of our recruitment team will always review and consider any outputs generated by AI tools before any recruitment decision is made in relation to your application. 

The lawful basis on which we process your personal data using AI tools is our legitimate interest in operating an efficient and effective recruitment process, including the identification and assessment of suitable candidates. We have carried out a legitimate interests assessment and have concluded that our interests in using AI to support recruitment are not overridden by your rights and freedoms, particularly given the human oversight applied to all outputs and the measures we take to ensure fairness and transparency in our hiring practices.

RETENTION OF PERSONAL INFORMATION.

How long we hold your personal information for will vary. The retention period will be determined by the purpose for which we are using your personal information and as required by law.

DISCLOSURES OF PERSONAL INFORMATION.

We may share your personal information between our affiliates and any of their personnel for the purposes described in this Notice and in accordance with applicable law. We may also share personal information with service providers that perform services on our behalf, such as our recruitment platform providers, background and education verification agencies, HR and recruitment service providers, accounting, payment and expense reimbursement providers, travel providers, professional advisors (e.g., lawyers and accountants) and electronic signature providers.

In addition, to the extent required by law, we may disclose personal information about you: (1) if we are required or permitted to do so by law or legal process (e.g., due to a court order) or in response to an order or request from a law enforcement or regulatory agency or other legally valid inquiry, which may include lawful access by U.S. or foreign courts, law enforcement or other government authorities, (2) to comply with legal and regulatory requirements, (3) when we believe disclosure is necessary or appropriate to protect safety or prevent physical harm or financial loss, (4) in connection with an investigation of suspected or actual fraudulent or other illegal activity, or (5) in connection with a potential or actual sale or transfer of all or a portion of our business or assets (e.g., in the event of an acquisition, merger, reorganization, dissolution or liquidation).

HOW WE PROTECT PERSONAL INFORMATION.

We maintain administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized access, collection, copying, modification, disposal, destruction, loss, alteration, disclosure, use or similar risks.

TRANSFERS OF PERSONAL INFORMATION.

Information that we collect from you may be transferred to and stored within countries other than the country in which information originally was collected in accordance with applicable law, including transfers between our affiliates. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer information to recipients in other countries, we will protect that information as described in this Notice.

Where we transfer personal information outside of the UK, the European Union, the European Economic Area, Singapore or other territories subject to data transfer restrictions, we will provide an adequate level of protection of your personal data, including appropriate technical and organizational security measures and through the implementation of appropriate contractual measures to secure such transfer, in compliance with applicable law.

To obtain more information about the safeguards we have put in place, please contact us as indicated below. Further information regarding data recipients and data transfers will be provided upon request, where required by applicable law.

YOUR RIGHTS.

Subject to applicable law and depending on the jurisdiction that applies, you may have the right to request:

• confirmation of whether we process personal information relating to you and, if so, to request access to or a copy of that personal information;
• a summary of the personal data which is being processed and the processing activities;
• that we rectify or update your personal information that is inaccurate, incomplete or outdated;
• that we cease to process certain personal information, including the AI processing described above, where you object to its use and we do not have an overriding legitimate interest in carrying out the processing and/or it is not necessary for the establishment, exercise or defense of legal claims;
• that we delete or erase your personal information in certain circumstances, such as where we collected personal information on the basis of your consent and you withdraw that consent, or when you object to use of your personal information;
• that we restrict the use of your personal information in certain circumstances, such as while we consider another request that you have submitted (such as a request that we update your personal information);
• withdrawal of your consent where you have given us consent to process your personal information;
• to lodge a complaint with the relevant supervisory authority;
• to nominate another individual to exercise your rights in the event of your death or incapacity; and
• that we provide a copy of your personal information to you in a structured, commonly used and machine readable format in certain circumstances.

If you wish to exercise your rights, please contact us as described in the contact section below. Subject to applicable law, if you believe that we have processed your personal information in violation of applicable law and failed to remedy such violation to your reasonable satisfaction, you also may lodge a complaint with the data protection authority in your jurisdiction.

India residents have the right to lodge a complaint with the Data Protection Board of India.

California residents should refer to HRT’s California Consumer Privacy Statement for more information about the rights available to them under California law.

UK residents have the right to make a data protection complaint to us if you consider that we have infringed data protection law in connection with your personal data. You can submit a complaint by email to employmentlaw@hudson-trading.com. We will acknowledge your complaint within 30 days and will take appropriate steps to investigate and respond without undue delay. If you are not satisfied with the outcome of your complaint, you have the right to complain to the Information Commissioner’s Office (ICO) at ico.org.uk.

CHANGES TO THIS NOTICE.

We may update this Notice from time to time and without prior notice to you, subject to applicable law, to reflect changes in our personal information practices. We will indicate at the top of the notice when it was most recently updated.

CONTACTING US.

If you would like further information on the collection, use, disclosure, transfer or processing of your personal information or the exercise of any of the rights listed above, please email us at employmentlaw@hudson-trading.com.

You can also write to us at:

• Huson River Trading LLC
• c/o Legal Department
• Three World Trade Center, 175 Greenwich St.
• New York, NY 10007
• United States

For residents of Singapore: please email us at sgp-data-protection-officer@hudson-trading.com.