Privacy Policies

Updated and Effective Date: September 18 2026

This Privacy Policy describes how Two Sigma Investments, LP (“Two Sigma”, “we”, “our” or “us”) collects, uses, discloses and otherwise processes personal information (i.e., information reasonably related to a specific individual) collected through online and offline interactions, including on www.twosigma.com where this Privacy Policy is located (the “Site”), and other platforms or channels that direct to this Privacy Policy, and the rights you may have with respect to that information.

This Privacy Policy does not apply to websites or platforms where a different privacy policy is posted or provided, or to the practices of Two Sigma subsidiaries or affiliates that have their own privacy policy.  This Privacy Policy does not apply to information collected in the context of providing Two Sigma financial services or products. For additional information about our processing practices related to financial services, please contact us at privacy@twosigma.com to request a copy of the applicable notice.

SOURCES OF PERSONAL INFORMATION

We collect personal information from the following sources:

Directly from You:

We may collect personal information you provide to us directly such as when you visit our Sites, use our tools and services, apply for a job, attend events and programs, request information from us, contact us via email or contact form or otherwise interact with us. We also collect other personal identifiers that you provide to us voluntarily, such as through any user-generated content or feedback that you provide (including in connection with participation in our programs).

Collected Automatically:

We may use automatic data collection technologies on our Site and services to collect information that may include personal information. We collect this information from various sources including passively from you through your use of the Site and from our service providers. Learn more about these tools and how you can manage them, by visiting our Cookies Policy, here.

From Third Parties:

We may collect personal information from third parties such as service providers, commercial data partners, recruiting agencies, referral sources such as employers, business partners, and our affiliated companies and subsidiaries.

From Publicly Available Sources:

We may collect personal information from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Privacy Policy, including third party sources, and use or disclose the combined information for the purposes identified below.

TYPES OF PERSONAL INFORMATION COLLECTED

We may collect the following categories of personal information:

Identifiers:

We may collect personal identifiers (such as your name, address, phone number, username, email address), device identifiers (such as IP address and unique device identifiers), and internet or other network or device activity (such as browsing history).

Records About You:

We may collect information about you such as signatures; physical characteristics or a description of you; the content, timing and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Sites, such as user-generated content.

Demographic Information:

We may collect demographic information such as age (including birthdates) and gender.

Commercial Information:

We may collect commercial information, including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies, from you directly, or through third parties.

Internet or Other Similar Electronic Network Activity:

We may collect internet and other electronic information such as usage data about how you use our Site and how long you stay on the Site through the use of browser cookies or other commonly used technologies (e.g. pixels and web beacons). This may include information about your browser, device type, IP address, user session information, etc. and contain personal information about you.

Non-precise Geolocation Data:

We may collect your location derived from your IP address when you use the Site.

Professional or Employment Information:

When you register on the Site, apply for a job, or otherwise engage with us in a commercial context (such as in connection with our expert networks), we may collect professional and employment information such as information about your employers, awards, and associations.

Educational Information:

When you register on the Site, apply for a job, or otherwise engage with us in a commercial context (such as in connection with our expert networks), we may collect educational information such as information about schools you attended, degrees awarded and academic status.

Sensitive Information

When you apply for a job, we may collect sensitive information you choose to submit to us, such as racial or ethnic origin or disability information.

USE OF PERSONAL INFORMATION

We may use personal information for following purposes:

To Communicate with You:

We may use information about you to communicate with you, including responding to your requests, questions, complaints, and feedback; to correspond about your account; and provide you with information about this Privacy Policy or the Site’s Terms of Use. For example, we might use your information to contact you about employment opportunities or to process and evaluate your application for a job or to respond to your request to work on any of our projects.

To Provide you with Services and Operate the Site:

We may use information about you to operate our business and provide and maintain our Site and services, such as making our Site available to you; registering, verifying, and maintaining your account with us; and otherwise facilitating your relationship with us.

For Recruiting:

We may use your personal information to send you information about career opportunities. For example, we use personal information to review your job applications and contact you about employment opportunities. If you choose to voluntarily submit your ethnicity, gender, disability status, and/or veteran status in connection with a job application, we will use that information for internal purposes or as otherwise required by applicable law, and not for hiring decisions, in accordance with applicable law.

For Statistical Analysis, Product Improvement and Research:

We may use your personal information for statistical analysis, product improvement and research purposes, including but not limited to verifying or maintaining the quality or safety of our products or services; analyzing performance; improving our products or services and the Site; designing new products and services; developing and improving algorithms, artificial intelligence or machine learning tools and models; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.

For Security and Fraud Prevention and Detection:

We may use information for security purposes such as fraud prevention and detection. We may use personal information to enforce our rights, for fraud prevention, or to protect our company, affiliates, our customers, or our Site, or a third-party website or platform.

To Debug and Identify Errors:

We may use your personal information to debug, identify and repair errors that impair existing intended functionality.

For Compliance with Laws and to Protect Ourselves:

We may use your personal information to support auditing, legal and compliance purposes including responding to court orders or subpoenas, the exercise or defense of legal claims, or responding to requests from law enforcement, government agencies, or similar investigatory bodies. We may also use your personal information when we are investigating potential fraud or other areas of concern, including responding to security incidents, or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

For Marketing:

We may use personal information to inform you about Two Sigma and to provide marketing information about our products or new features or updates. We also use information to tailor and serve you ads about products and offers. These might be offers from Two Sigma, our subsidiaries or others and might include brands, products or services we think you would find interesting. To stop receiving our promotional emails, simply use the opt-out or unsubscribe method provided in emails you receive from us. Even if you opt out of getting marketing messages, we will still send you transactional messages, such as responses to your questions.

In Connection with a Corporate Transaction:

We may use your personal information if we acquire assets of another business, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.

Other Uses:

We may use your personal information for other purposes as we may notify you at the time of collection.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law. When we collect, process, or disclose aggregated or deidentified information, we will maintain and use it in deidentified form and will not attempt to reidentify the information, except to determine whether our deidentification processes satisfy any applicable legal requirements.

DISCLOSURES OF PERSONAL INFORMATION

We may share personal information with the following parties:

Two Sigma Companies:

We may share your personal information within the Two Sigma family of companies, including affiliates and subsidiaries.

Service Providers:

We may share personal information with third parties who perform services on our behalf. For example, we share personal information with our IT services and cloud providers; email marketing providers; data analytics providers; recruiting agencies and  background check vendors; and companies that provide business support services, financial administration, or event organizations.

Professional Consultants:

We may share information with professional consultants who provide us services such as accountants, lawyers, financial advisors, and audit firms.

For Legal Compliance:

We may share personal information in order to comply with the law or legal requirements or to protect ourselves, such as responding to court orders or subpoenas. We may also share your personal information in response to a request from law enforcement, government agency, or similar investigatory body. We may also share your personal information when we are investigating potential fraud or other areas of concern, including to enforce our Terms of Use or other agreements or policies; if we believe in good faith that disclosure is legally required; or as otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Business Successors and Transfers:

We may share personal information with any successor to all or part of our business, or in the event we choose to purchase assets. For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of Two Sigma or part of its business (or in anticipation of such an event) we may share your personal information as part of that transaction. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your personal information as set forth in this Privacy Policy.

Business Partners:

We may share personal information with business partners that may use personal information for their own purposes, such as:

• Advertisers, ad platforms and networks, and social media platforms;
• Third parties who place cookies as described in our Cookie Policy [LINK];
• Commercial data partners to whom we make information available for their own commercial purposes; and
• Partners who work with us on promotional opportunities, including co-branded products and services.

Where recipients use your personal information for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.

With Consent:

We will also share your personal information in the manner that you authorize us to.

Other Parties & Purposes:

We may share personal information for other reasons and to other third parties we may describe to you or as permitted by law.

COOKIES

Our Sites and authorized third parties use Cookies to collect information about you, your device, and how you interact with our Sites via Cookies. Please see our Cookie Policy available at [LINK] for more information.

NOTICE FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM

The following terms supplement the above disclosures with respect to our processing of European Economic Area (“EEA”) and United Kingdom (“UK”) personal information only.

Individuals who are located in or residents of countries in the European Economic Area (“EEA”) and the United Kingdom (“UK”) may have additional rights with respect to their personal information:

• Right to access and receive: You may request a copy of or access to the personal information we hold about you. You may also request that we transfer your personal information to a third party in a machine-readable format.

• Right to correct: You may ask us to update or correct inaccurate or incomplete personal information we hold about you.

• Right to limit or restrict: You may have the right to request that we stop using all or some of your personal information or to limit our use of it.

• Right to erase: You may have the right to request that we delete all or some of your personal information.

• Right to withdraw consent: You have the right to withdraw any consent you have previously given to us at any time. Your withdrawal of consent does not affect the lawfulness of our collecting, using, and sharing of your personal information prior to the withdrawal of your consent. Even if you withdraw your consent, we have the right to use your personal information if it has been fully anonymized and cannot be used to personally identify you.

• Right to lodge a complaint: You have the right to lodge a complaint with your supervisory authority if you are unhappy with how we process your personal information. You can find contact information for your supervisory authority on the European Commission Data Protection Authorities webpage or through other publicly available sources. You can also lodge a complaint with us using the information below if UK laws apply to you and you think we have infringed our UK data protection obligations when handling your personal information.

If you wish to exercise any of your rights under this Privacy Policy, please send us your request via email to GDPR@twosigma.com or submit a webform request here.

For the purposes of EEA and UK data protection laws, we are the data controller of your personal information collected on the Site and through your interactions with us. This means that we are responsible for, and control the processing of, your personal information.

UK inquiries: Our data protection representative in the UK is Two Sigma International Limited, which can be reached at GDPR@twosigma.com.

EEA inquiries: Leo RegTech Limited, incorporated and registered in England and Wales with company number 04829021, acting through its French branch located at 128 rue de la Boétie 75008, Paris, France, is a designated representative of Two Sigma Investments, LP (the “Company”) in the European Union, in accordance with article 27 of the EU General Data Protection Regulation (2016/679/EU) (the “GDPR”). The Company has mandated Leo and its branch to be the EU Representative of the Company with regards to any communications or enquiry from the Supervisory Authority and/or data subjects on all issues related to the processing of personal data. If you are in the EU, please contact Leo at the following details: Email: eurorep@leo.tech; Address: FAO EuroRep, c/o Leo, 128 rue de la Boétie 75008, Paris, France. When contacting Leo regarding the Company, please quote the name of the Company and the Ref: 0085.

Legal Bases

For the purposes of EEA and UK data protection laws, the legal basis for the processing of your personal information are generally when it is necessary for the performance of any contractual relationship with you, and where in our legitimate interests for the purposes described in this Privacy Policy. If we rely on another legal basis, we will inform you at the time of collection.

International Transfers

Personal information we collect may be transferred to and stored within the United States. Our Sites are subject to U.S. laws, which may not afford the same level of protection as those in your country. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. You acknowledge that if you do not consent or would like to withdraw your consent to such transfer by contacting GDPR@twosigma.com, it will impact your ability to use our Sites. You may also contact us at GDPR@twosigma.com to receive further information about how we transfer personal information or, where available, a copy of the relevant data transfer mechanism.

NOTICE FOR CALIFORNIA RESIDENTS

The following terms supplement the above disclosures with respect to our processing of California personal information only.

If you require this notice in an alternative accessible format, please email us at CCPA@twosigma.com.

California Privacy Rights

Individuals who are located in or residents of California may have additional rights with respect to their personal information:

• Right to access: You can request that we disclose to you the following, where applicable: (i) the categories of personal information that we have collected about you; (ii) the categories of sources from which we have collected personal information about you; (iii) the business or commercial purpose for collecting, sharing, or selling your personal information; (iv) the categories of personal information that we have sold or shared about you and the categories of third parties to whom the personal information was disclosed; (v) the categories of personal information that we have disclosed about you for our business purposes and the categories of vendors to whom the personal information was disclosed; and (vi) the specific pieces of personal information that we have collected about you.
• Right to delete: You can request that we delete the personal information that we collected from you, subject to certain exceptions.
• Right to correct: You can request that we correct inaccurate personal information that we maintain about you, subject to certain exceptions.
• Right to opt out of sale and sharing for targeted advertising: Where applicable, you can request to opt out of the sale or sharing for targeted advertising (as such terms are defined under applicable laws) of your personal information. We do not knowingly sell or share the personal information of minors under 16 years of age. You can exercise this right by visiting the cookie preference center (Floating button in the bottom left corner) and selecting “opt out”.

To the extent required by law, we will honor at the browser level opt-out preference signals sent in a format commonly used and recognized by businesses, such as an HTTP header field or JavaScript object.

We do not use or disclose Sensitive Information for purposes other than: (i) to perform services or provide goods reasonably expected by an average person; (ii) to detect security incidents; (iii) to resist malicious, deceptive, fraudulent or illegal actions; (iv) to ensure the physical safety of persons; (v) for short-term, transient use, including non-personalized advertising; (vi) to perform internal business services; (vii) to verify or maintain the quality or safety of our products and services or improve, upgrade, or enhance our services or devices; and (viii) purposes that do not infer characteristics about you.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) email us at CCPA@twosigma.com; (ii) contact us at the toll-free telephone number 1-844-820-6577; or (iii) submit a webform request here.

We will not retaliate against you for exercising these rights conferred by the CCPA.

Authorized Agents:

A consumer may use an authorized agent to submit a request on their behalf. When using an authorized agent for requests to know, delete, and correct, we may reach out to you directly to verify your own identity and confirm that you provide the authorized agent permission to do so.  When using an authorized agent for requests to opt out of sale or sharing for targeted advertising, we may seek additional information directly from the authorized agent to process the request. If you would like to designate an authorized agent to make a request on your behalf, please email us at CCPA@twosigma.com.

Verification:

We have instituted a process for verifying that the person making an access, correction or deletion request is the consumer about whom we have collected information. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the personal information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary. If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.

Sale/Sharing of Personal Information

While we have not “sold” your personal information in the ordinary sense, over the preceding 12 months, we may have “sold” or “shared” for targeted advertising (as such terms are defined by the CCPA) the following categories of personal information to deliver targeted advertising: Identifiers, Commercial Information, Internet or Other Electronic Network Activity Information, Non-precise Geolocation Data.

Disclosures of Personal Information:

Within the past 12 months, we have disclosed each of the types of personal information we collect, as described in the TYPES OF PERSONAL INFORMATION COLLECTED section above, to a service provider or contractor for the business purposes described in the DISCLOSURES OF PERSONAL INFORMATION section above.

CHILDREN’S PERSONAL INFORMATION

Our Sites are meant for adults. We do not knowingly collect personal information from children under 13. If you are a parent or legal guardian and believe we have inadvertently collected personal information from a child under the age of 13, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.”

SECURITY MEASURES

We maintain reasonable security procedures and practices to protect personal information. But, the Internet is not 100% secure. We cannot promise that your use of our Sites or software will be completely safe. We encourage you to use caution when transmitting personal information over the Internet.

We generally retain personal information for so long as it may be relevant to the purposes set forth in this Privacy Policy. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain a record of your inquiries to us for as long as it takes to fulfill the inquiry. If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may de-identify it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

THIRD PARTY SERVICES AND SITES

If you click on a link to a third party website, you will be taken to website(s) that we do not control. This Privacy Policy does not apply to the privacy practices of such third party website(s). Read the privacy policy of other websites carefully before you submit any personal information to these third party website(s). We are not responsible for actions, omissions or practices of third party website(s).

CONTACT INFORMATION

If you have any questions about this Privacy Policy or other privacy concerns, please contact us at:

Two Sigma Investments, LP
100 Avenue of the Americas
16th Floor
New York, NY 10013
Attn: Legal / Privacy Matters

UPDATES AND CHANGES

From time to time, we may update or change our privacy policies. We will notify you of any material changes to our Privacy Policy by posting a notice on our Site. We will also post an updated copy on our Site with the effective date posted at the top of the web page. Please check our Site periodically for updates.

Last Updated: September 18 2026

This Cookie Policy describes how Two Sigma Investments, LP and its affiliates (“Two Sigma”, “we”, “our” or “us”) uses cookies, pixels, and similar technologies (collectively referred to as “Cookies”) on our websites, mobile applications, online advertisements, digital platforms, online communications (e.g., email), and other digital products and services (collectively, our “Digital Properties”). In this Cookie Policy, we explain:

• • The types of Cookies we use
  • What information we collect using these Cookies
  • The purposes for which we use these Cookies
  • How we disclose or make information collected through these Cookies available to others
  • Choices you may have regarding these Cookies
  • A general list of the individual Cookies we currently use or recently have used

The information in this Cookie Policy supplements our Privacy Notice, which describes our general privacy practices.  Our Privacy Notice is available here.

TYPES OF COOKIES WE USE

Our Digital Properties and the third parties that we authorize may use:

• Cookies, which are a type of technology that install a small amount of information on a user’s computer or other device when they visit our Digital Properties.
• Pixels, web beacons, and tags, which are types of code or transparent graphics that contain a unique identifier.  In addition to the uses described below, these technologies provide information about interactions with our Digital Properties, (including communications such as email we may send to you) and help us customize our marketing activities. In contrast to cookies, which are stored on a user’s device hard drive, pixels, web beacons, and tags are embedded invisibly on our Digital Properties.
• Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms.  In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
• Embedded scripts and SDKs, which allow us to build and integrate custom experiences on our Digital Properties.  Embedded scripts are temporarily downloaded onto your device from our web server, or from a third party with which we work, and are active only while you are connected to our Digital Properties and are deleted or deactivated thereafter.

We may use both first-party Cookies, which are set by us, and third-party Cookies, which are set by other parties.  Some of the Cookies we use may last solely for your browsing session and are deleted when you close your browser, while others are persistent and stored after you close your browser.

TYPES OF DATA COLLECTED

We may collect the following types of data about you or your device through Cookies:

• IP address;
• Location (both approximate and precise);
• Cookie ID;
• Device ID;
• Ad ID;
• Operating system;
• Device type;
• Device settings and other device information;
• Browser type;
• Browser history;
• Search history;
• Search queries;
• Login information;
• Information entered into webforms;
• Pages viewed; and
• Other data about your interactions with our Digital Properties.

USES OF DATA

We and authorized third parties use Cookies for purposes including:

• Strictly Necessary: These are technologies that our Digital Properties need to function, and that enable you to move around and use the Digital Properties.  Without these Cookies, the Digital Properties will not perform as smoothly for you as we would like them to, and we may not be able to provide the Digital Properties or certain features you request.  For example, we use these Cookies to determine when you are signed in, to determine when your account has been inactive, to provide you with privacy disclosures and choices, and for troubleshooting and security purposes.  We refer to Cookies used for this purpose as “Strictly Necessary” Cookies in this Cookie Policy;
• Functionality/Personalization: These are technologies that help enhance functionality, improve your user experience, and tailor your use of our Digital Properties.  For example, Functionality Cookies can be used to remember pages you have viewed in order to enhance and personalize your experience when you visit our Digital Properties.  We refer to Cookies used for this purpose as “Functional” Cookies in this Cookie Policy;
• Performance/Analytics: These technologies allow us to understand more about how visitors use our Digital Properties so we can understand and improve performance.  For example, we gather analytics to help us understand which pages within our Digital Properties are most popular and how users move around them. In particular, we use Google Analytics to help us improve our Digital Properties’ functionality.  Google may use cookies to provide Google Analytics. To learn how Google Analytics collects and processes data, please visit: “How Google uses information from sites or apps that use our services” located at https://policies.google.com/technologies/partner-sites. We refer to Cookies used for this purpose as “Performance” Cookies in this Cookie Policy; and
• Targeting: These are technologies used for targeted advertising and marketing.  For example, we use Cookies and conversion tracking tools to improve the effectiveness of our online marketing efforts (such as personalized advertisements placed on other Digital Properties you may visit). We refer to Cookies used for this purpose as “Targeting” Cookies in this Cookie Policy.

DISCLOSURES OF DATA

We may disclose data collected through Cookies to the following types of recipients or allow the following recipients to directly collect data using Cookies:

• Social media companies;
• Advertising networks;
• Analytics providers (including providers of ad tracking and reporting services);
• Security providers; and
• Other technology providers and business partners.

When we collect and disclose information to these recipients through tracking technologies, we act as joint controllers with the recipients, but only to the extent technically necessary for the collection and disclosure of the information. Once the data has been transmitted to the recipient, Two Sigma and the recipient act as independent controllers. We do not have any control over nor are we responsible for the recipient’s data processing activities as an independent controller. We recommend that you review these parties’ privacy policies and cookie policies to better understand their privacy practices.

YOUR CHOICES

You can control how we use Cookies.  Please be aware that if you disable the use of Cookies, the functionality of our Digital Properties may be negatively impacted, and certain areas or features may not display or work correctly.

PREFERENCE CENTER

You can modify your Cookie consent preferences at any time by [insert].

BROWSER SETTINGS

If you want to disable the use of certain specific Cookies or remove them from your device, you can disable or delete them using your browser settings.  Please be aware that not all Cookies can be deleted through browser settings. The following links contain instructions for commonly used browsers: Apple Safari; Google Chrome; Microsoft Edge; and Mozilla Firefox.

DO NOT TRACK

Web browsers and other technologies you may use to access the Digital Properties may include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your preference to not have data about your online browsing activities monitored and collected over time and across websites.  At this stage, we do not currently respond to DNT browser signals or similar mechanisms.

THE COOKIES WE USE OR HAVE RECENTLY USED

In general, our Digital Properties currently use the following Cookies.  This list may be updated regularly.

CONTACT US

If you have any questions regarding our Cookie Policy, please contact us at: privacy@twosigma.com

Updated and Effective Date: February 27, 2025

SIGNAL Privacy Policy

This Privacy Policy describes the policies and procedures of the applications or websites on which it is posted (each a “Platform”), followed by Two Sigma Investments, LP and its affiliates (“we”, “our” or “us”) in the collection, use and disclosure of your information on this Platform and the services, features, content, feedback or applications we offer including offline activities (collectively with the Platform, the “Services”). We receive personal information about you from various sources, including: (i) from you directly; (ii) if you use the Platform; (iii) through your use of the Services generally; (iv) recruiting platforms and recruiting events; (v) online platforms including professional and social networks and forums; (vi) financial institutions and (vii) referrals from third parties. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information described in this Privacy Policy.

This Privacy Policy covers the treatment of personal information, which is information relating to an identified or identifiable natural person (“Personal Information”) that is gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) or to individuals that we do not manage or employ. We take no responsibility for the content or privacy policies of any Third Party Services, and we encourage you to carefully review the privacy policies of any Third Party Services.

WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

The collection and processing of Personal Information about you may be necessary for the performance of any contractual relationship with you and where in our legitimate interests. For each of the categories of Personal Information listed below, we may use this information (i) to contact you and respond to your requests and queries; (ii) to provide you with the Services; (iii) for business administration, including statistical analysis and research and analyzing performance; (iv) to personalize your visit to the Platform and assist you while you use the Platform; (v) to optimize the Platform and improve, upgrade or enhance the services; (vi) for fraud prevention and detection and ensuring quality and safety of the Services; (vii) to comply with applicable laws, rules and regulations; (viii) for selection and on-boarding including recruiting analyses; (ix) to debug and identify and repair errors that impair existing intended functionality; (x) for payment purposes; and (xi) for any other purpose as described in this Privacy Policy.

For each of the categories listed below, we may share this information with various parties including (i) Two Sigma affiliates; (ii) service providers such as cloud providers; (iii) third parties you direct us to; (iv) government agencies and regulators to comply with the law and protect ourselves; (v) business transfers; (vi) business successors and (vii) third parties you direct us to.

We collect the following categories of Personal Information:

Personal Identifiers:

We collect Personal Information, such as your name, username(s), password, email address(es), phone number(s), domicile, educational and occupational data, such as your degrees, employment information, and such other information as requested on our Platform log-in page or otherwise requested through correspondences with you. You acknowledge that this information may be personal to you and that, by logging on to the Platform and/or providing Personal Information to us, you allow us to identify you and therefore you may not remain anonymous to us.

We may collect this information from various sources including from you directly, if you use the Platform, through your use of the Services generally, recruiting platforms and recruiting events, online platforms including professional and social networks and forums, financial institutions and referrals from third parties. We use and share this information as noted above in this section.

Professional and Employment Information:

We collect information related to your professional background and employment information such as your current or previous employer, social media professional profile, ability to work in location, and occupational data, such as your background and expertise.

We may collect this information from various sources including from you directly, through your use of the Services generally, online platforms including professional and social networks and forums, financial institutions and referrals from third parties. We use and share this information as noted above in this section.

Educational Information:

We collect information related to your education and credentials such as schools attended and associations.

We may collect this information from various sources including from you directly, through your use of the Services generally, online platforms including professional and social networks and forums, financial institutions and referrals from third parties. We use and share this information as noted above in this section.

Financial Information:

We collect financial information with your consent or that you provide to us (e.g., account and brokerage information, tax information).

We may collect this information from various sources including from you directly and from financial institutions. We use and share this information as noted above in this section.

Internet or electronic network activity:

We collect certain internet or electronic activity such as IP address, type of platform used, SSH keys, API keys or other credentialed tokens in order to provide access to our Services. We may also receive a confirmation when you open an email from us. We also may maintain logs of our correspondence with you.

We may collect this information from various sources including from you directly, if you use the Platform and through your use of the Services generally. We use and share this information as noted above in this section.

Geolocation Information:

We collect geolocation information such as IP address. We collect this information if you use the Platform and through your use of the Services generally. We use and share this information as noted above in this section.

Aggregate Information:

We collect statistical information about how users use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information. We may share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We may elect to share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Information about you that they have independently developed or acquired.

We may collect this information from various sources including from you directly, if you use the Platform, through your use of the Services generally, recruiting platforms and recruiting events, professional and social networks, online messaging and community forums and financial institutions. We use and share this information as noted above in this section.

WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.

How, and With Whom, Is My Information Shared?

Some of the information generated through the Services is shared with others including third parties. Such information may contain Personal Information about you. For each category of Personal Information listed above, we may share your Personal Information as follows:

Information Shared with Our Affiliates:

We may share your Personal Information within the Two Sigma family of companies.

Information Shared with Our Service Providers:

We employ and contract with individuals and entities that perform certain tasks on our behalf and who are under our control (our “Service Providers“). We may need to share Personal Information with our Service Providers, for example, in order to provide products or services to you (e.g., cloud providers, workplace solution providers, etc.) or to manage our processes.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.

Information We Share With Your Consent:

We will also share your Personal Information in the manner that you authorize us to.

Information We Share to Comply with the Law or Protect Ourselves

We will share personal information if we think we have to in order to comply with the law or to protect ourselves such as responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Information shared with Successor to all or part of our Business

We may share your Personal Information for example in the event of a merger, acquisition, divestiture, change of control, or liquidation of Two Sigma or part of its business (or in anticipation of such event).

Communications with Us:

As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to our services.

Is Information About Me Secure?

Your Platform information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Personal Information by selecting and protecting your password appropriately and limiting access to your computer, browser and/or mobile device by signing off after you have finished accessing your account.

We take reasonable steps consistent with industry standards, including technical, administrative and physical safeguards to protect the Personal Information submitted to us from loss, misuse and unauthorized access, disclosure, alteration or destruction. However, no method of security over the Internet is entirely secure.

We do not guarantee the security of any information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We keep your Personal Information for as long as it is necessary or relevant for the practices described in this Privacy Policy. We will also keep your Personal Information as otherwise required by law or for internal compliance and record-keeping purposes.

What If I Am Located in The European Economic Area or United Kingdom?

Individuals who are located in or residents of countries in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain data subject rights that may be subject to limitations and/or restrictions.

You have the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information. You also have the right to ask us to restrict the purpose or to object to the processing of your personal information as well as a right to data portability.

Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.

You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority.

If you wish to exercise any of your rights under this Privacy Policy, please send us your request via email to GDPR@twosigma.com.

For the purposes of EEA and UK data protection laws, we are the data controller of your personal information collected on the Site. This means that we are responsible for, and control the processing of, your personal information.

UK inquiries: Our data protection representative in the UK is Two Sigma International Limited, which can be reached at GDPR@twosigma.com.

EEA inquiries: Leo RegTech Limited, incorporated and registered in England and Wales with company number 04829021, acting through its French branch located at 128 rue de la Boétie 75008, Paris, France, is a designated representative of Two Sigma Investments, LP (the “Company”) in the European Union, in accordance with article 27 of the EU General Data Protection Regulation (2016/679/EU) (the “GDPR”). The Company has mandated Leo and its branch to be the EU Representative of the Company with regards to any communications or enquiry from the Supervisory Authority and/or data subjects on all issues related to the processing of personal data. If you are in the EU, please contact Leo at the following details: Email: eurorep@leo.tech; Address: FAO EuroRep, c/o Leo, 128 rue de la Boétie 75008, Paris, France. When contacting Leo regarding the Company, please quote the name of the Company and the Ref: 0085.

For the purposes of EEA and UK data protection laws, the legal basis for the processing of your personal information are when it is necessary for the performance of any contractual relationship with you, and where in our legitimate interests for the purposes described in this Privacy Policy.

We generally retain personal data for so long as it may be relevant to the purposes set forth this privacy policy. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain a record of your inquiries to us for as long as it takes to fulfill the inquiry.  If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may de-identify it, delete it or take other appropriate steps.  Data may persist in copies made for backup and business continuity purposes for additional time.

What if I am a Resident of California?

If you are a California resident, California law requires us to provide you with certain information about how we collect, use, and disclose your “personal information” as defined in the California Consumer Privacy Act (“CCPA”). Please note that this California Privacy Notice (“Notice”) applies only to information we collect from California consumers, and does not apply to any individual in their capacity as a) a Two Sigma investor or b) a Two Sigma employee. For more information about the privacy practices of our individual businesses, please see each business’s main Privacy Policy.

1. Categories of Personal Information we collect, use and disclose

We collect the following categories of personal information defined under the CCPA from California consumers and that we may, as discussed throughout this Policy, use and disclose for our business purposes:

Identifiers (such as name, address, email address); device identifiers (such as IP address and unique device identifiers); internet or other network or device activity (such as browsing history); general geolocation data derived from IP addresses; any user-generated content or feedback that you provide (including in connection with participation in our programs); professional, educational or employment related data; and username and password.

If you perform services for Two Sigma as an independent contractor, we may also collect additional information from you, such as additional identifiers (like social security number, drivers’ license number, or other government identifiers), citizenship or immigration documentation, and financial information to facilitate payments to you.

We collect such information: directly from you (such as when you contribute to or participate in one of our programs, apply for a job with Two Sigma, submit your business contact information, or send us questions or otherwise communicate with us); through automated technology (such as cookies on our websites) or online platforms; from third parties such as recruiting platforms and events, referrals, financial institutions, or your employer; and from other sources (such as publicly available information).

1. How we use and disclose these categories of personal information

We and our service providers may use the categories of personal information we collect from and about you for the following business and commercial purposes (as those terms are defined in applicable law):

• Our or our service providers’ operational purposes;
• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
• Bug detection and error reporting;
• Customizing content that we or our service providers display on the Services;
• Providing the Services (e.g., maintaining our Sites and communicating with you about programs and products);
• Improving our existing Services and developing new services (e.g., by conducting research and analysis to develop new products or features);
• Evaluating job applicants, individuals, and/or business opportunities;
• Onboarding and paying contractors;
• Other uses that advance our commercial or economic interests, such as third-party advertising (consistent with any privacy choices you have communicated to us) and internal statistical analysis and research purposes; and
• Other uses about which we notify you.

We may also use and disclose personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any user or device, and use such aggregate and de-identified information for any purpose.

We may also disclose this information to third parties for legal, compliance or security purposes or based on your elections, in connection with a business transfer or successor to all or part of the business, or our affiliates.

1. Sale/Sharing of Personal Information

The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for cross-context behavioral advertising purposes with third parties who do not act as service providers to that business. Two Sigma makes personal information available to non-service provider third parties only when individuals have affirmatively agreed to such disclosure (for example, where a site visitor has opted in to our use of advertising cookies) or where the disclosure of personal information is otherwise exempt from the CCPA (such as disclosing information to secure the Services). As such, Two Sigma does not “sell” or “share” personal information within the meaning of the CCPA.

Please note, in the limited circumstances that we process sensitive personal information as defined in the CCPA, we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

1. Your Personal Information Rights

California residents may make certain requests about their personal information under the CCPA, subject to certain limitations and/or restrictions. Specifically, under California law you have the right to:

• Request that we disclose information about the personal information that we have collected, used, disclosed or sold,
• Request access to a copy of the personal information we maintain about you;
• Request correction of inaccurate personal information;
• Request that we delete personal information collected from you; and
• Not receive discriminatory treatment for exercising your privacy rights.

A consumer may use an authorized agent to submit a request on their behalf. When using an authorized agent, we require that you provide the authorized agent written permission to do so and verify their own identity and agent status with us. If you would like to designate an authorized agent to make a request on your behalf, please email us at CCPA@twosigma.com.

If you require this notice in an alternative accessible format, please email us at CCPA@twosigma.com.

We have instituted a process for verifying that the person making an access, correction or deletion request is the consumer about whom we have collected information. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the personal information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary. For online requests to delete, we will use a two-step process where the consumer must first submit the deletion request and then separately confirm that they want their personal information deleted. If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.

For requests to know and requests to delete, we will confirm receipt of the request within ten (10) days and provide information about how the business will process the request, and we will respond within 45 days with an option to extend an additional 45 days provided we give you notice.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) email us at CCPA@twosigma.com; (ii) contact us at the toll-free telephone number 1-844-820-6577; or (iii) submit a webform request .

1. Shine the Light

California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

1. Data Retention

We generally retain personal data for so long as it may be relevant to the purposes set forth in the relevant privacy policy. In determining how long to retain information, we consider the amount, nature and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we process the information, applicable legal requirements, and our legitimate interests. The purposes for which we process information (as well as the other factors listed above) may dictate different retention periods for the same types of information. For example, we retain a record of your inquiries to us for as long as it takes to fulfill the inquiry.  If you opt out of email marketing, we maintain your email on our suppression list for an extended time to comply with your request. To dispose of your information, we may de-identify it, delete it or take other appropriate steps.  Data may persist in copies made for backup and business continuity purposes for additional time.

How Do We Store Information?

Information we maintain may be stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. This Platform is subject to U.S. laws, which may not afford the same level of protection as those in your country.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we collect or use information, we will notify you as required by law, which may include by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

What If I Have Questions or Concerns?

If you have any questions about this Privacy Policy or other privacy concerns, please contact us at:

Two Sigma Investments, LP
100 Avenue of the Americas, 16th Floor
New York, NY 10013
Attn: Legal / SIGNAL Privacy Matters

Updated and Effective Date:  December 22, 2020

This Privacy Policy describes how Two Sigma Investments, LP and its affiliates (“Two Sigma”, “we”, “our” or “us”) treat personal information, including personal information collected on www.twosigma.com where this Privacy Policy is located (the “Site”). This Privacy Policy does not apply to websites or platforms where a different privacy policy is posted. It also may not apply to the practices of all Two Sigma subsidiaries or other affiliates.  For example, this Privacy Policy does not apply to customers or consumers of Two Sigma financial services or products with respect to your use of such financial services or products.

WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

We collect the following categories of personal information from you in different ways including from you directly, from you passively through your use of the Site, from third parties and from publicly available sources.

Personal Identifiers: We might collect your name, address, phone number, username, email address and log-in information when you register on our Site, sign up for our newsletters, apply for a job or contribute to any of our projects.  We also collect other information that you provide to us voluntarily.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers and other individuals. We use and share this information as noted below.

Commercial Information:  We may collect commercial information, including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies, from you directly, or through third parties.  We use and share this information as noted below.

Communications: We collect information you email, submit, or post. We collect information when you contact us using the email address provided on the Site. This may contain personal information about you such as personal identifiers and professional or employment information.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums and productivity and collaboration tool providers. We use and share this information as noted below.

Professional or Employment Information: When you register on the Site or apply for a job, we may collect professional and employment information such as information about your employers, awards and associations.

We may collect this information from various sources including from you directly, through your use the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums, educational institutions, financial institutions, service providers and other individuals. We use and share this information as noted below.

Educational Information: When you register on the Site or apply for a job, we may collect educational information such as information about schools you attended, degrees awarded and academic status.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums, educational institutions, financial institutions, service providers and other individuals. We use and share this information as noted below.

Internet or Other Electronic Network Activity: We collect internet and other electronic information such as usage data on how you use our Site and how long you stay on the Site through the use of browser cookies or other commonly used technologies (e.g. web beacons). This may include information about your browser, device type, IP address, user session information, etc. and contain personal information about you.

We may collect this information from various sources including from you passively through your use of the Site and from our service providers. We use and share this information as noted below. Learn more about these tools and how you can manage them, by visiting our Cookies Policy, here.

Geolocation Information: We collect your IP address when you use the Site and from our services providers. We collect this information through your use of the Site. We use and share this information as noted below.

Aggregate information.  We collect statistical information about how users use the website, some of which is derived from personal information but is not itself personal information. We collect this information through your use of the Site. We use and share this information as noted below.

We may collect personal information as otherwise described at the time of collection on the Site.

WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.

The provision of personal information by you may be necessary for the performance of any contractual relationship with you, where we have a legitimate interest or for business and commercial purposes. For each category of personal information above, we use your personal information to carry out the following purposes:

Responding to Requests: We use information about you to respond to your requests or questions.  For example, we might use your information to contact you about employment opportunities or to process your application for a job or to respond to your request to work on any of our projects.

Provide you with Services and Improve the Site: We use information about you to provide you services and improve our websites and the information we provide.  We might use your personal information to deliver the Site and/or customize your experience with us. For example, we may use your personal information to improve the Site, our recruiting efforts and our other internal business purposes.

Security and Fraud Prevention and Detection: We use information for security purposes such as fraud prevention and detection.  We may use personal information to enforce our rights, for fraud prevention, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.

Compliance with Laws and to Protect Ourselves: We use your personal information to support auditing, legal and compliance purposes including responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Recruiting and Marketing: We use personal information to inform you about Two Sigma.  For example, we might send you information about Two Sigma and what we offer.  We might tell you about new features or updates. We may also use your personal information to send you information about career opportunities.

Communications:  We use personal information to communicate with you about your account or our relationship.  We may contact you about your use of our Site. We may contact you about your account or feedback.  We might also contact you about this Privacy Policy or the Site’s Terms of Use.

Debug and Identify Errors: We use your personal information to debug and identify and repair errors that impair existing intended functionality.

Statistical Analysis and Research: We may use your personal information for statistical analysis and research purposes including analyzing performance.

We may use your personal information as otherwise described or permitted by law, for any other purpose as described in this Privacy Policy, or as we may notify you.

WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES.

We may collect and share personal information about you from third parties. For example, our business partners or vendors may give us personal information about you. We may combine this information with information that you give us via the Site.

For each of the personal information categories listed above, we may share this information with third parties and affiliates for business or commercial purposes.

Two Sigma Companies:  We may share your personal information within the Two Sigma family of companies.

To Respond to Your Requests:  We may use your personal information to respond to your requests or questions.  For example, we might share your personal information with third parties in order to provide you with services requested by you or answer your questions.

Service Providers:  We will share personal information with third parties who perform services on our behalf.  For example, we share personal information with our vendors (e.g., IT services providers, cloud providers, background check vendors, online platforms, recruiting agencies and platforms), partners and consultants. We may also share personal information with companies that operate our websites.

Comply with the Law:  We will share personal information if we think we have to in order to comply with the law or to protect ourselves such as responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Business Successors:  We may share personal information with any successor to all or part of our business.  For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of Two Sigma or part of its business (or in anticipation of such an event) we may share your personal information as part of that transaction.

Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.

Information You Elect to Share: You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Platform. We are not responsible for the privacy policies or practices of these Third Party Services.

Information We Share With Your Consent: We will also share your personal information in the manner that you authorize us to.

We may share personal information for other reasons we may describe to you or as permitted by law.

YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING TOOLS

You can opt out of receiving our marketing emails.  To stop receiving our promotional emails, simply use the opt-out or unsubscribe method provided in emails you receive from us.

Our Do Not Track Policy.  Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.  If you block cookies, certain features on our Sites may not work.  If you block or reject cookies, not all of the tracking described here will stop.

RIGHTS FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM

Individuals who are located in or residents of countries in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain data subject rights that may be subject to limitations and/or restrictions.

You have the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information. You also have the right to ask us to restrict the purpose or to object to the processing of your personal information as well as a right to data portability.

Please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.

You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority.

If you wish to exercise any of your rights under this Privacy Policy, please send us your request via email to GDPR@twosigma.com.

For the purposes of EEA and UK data protection laws, we are the data controller of your personal information collected on the Site. This means that we are responsible for, and control the processing of, your personal information.

UK inquiries: Our data protection representative in the UK is Two Sigma International Limited, which can be reached at GDPR@twosigma.com.

EEA inquiries: Laven Consulting Limited (incorporated and registered in England and Wales with company number 10918441) (“Laven”) acting through its Paris branch located at 128 Rue La Boetie 75008, Paris, France as designated representative of Two Sigma Investments LP and its affiliates, as applicable (“Company”), in accordance with art. 27 of the General Data Protection Regulation (the Regulation (EU) 2016/679) (“GDPR”). The Company has mandated Laven to be the European representative of the Company with regards to any communications or enquiry from the Supervisory Authority and/or data subjects on all issues related to the processing of personal data. Please contact Laven on info@eurorep.eu; the postal address is FAO EuroRep, c/o Laven Partners, 128 Rue La Boetie 75008, Paris, France. When contacting Laven regarding the Company please quote the name of the company and the Ref: 0085.

For the purposes of EEA and UK data protection laws, the legal basis for the processing of your personal information are when it is necessary for the performance of any contractual relationship with you, and where in our legitimate interests for the purposes described in this Privacy Policy.

RIGHTS FOR INDIVIDUALS IN CALIFORNIA

Individuals who are residents of California have certain consumer rights under applicable California privacy laws but which may be subject to certain limitations and/or restrictions. Specifically, under California law you may have the right to:

• Request that we disclose information about the personal information collected, used, disclosed or sold;
• Request that we delete personal information collected or maintained by us;
• Opt out of the sale of your personal information; and
• Not receive discriminatory treatment for exercising your privacy rights.

Please note that we do not, and will not, sell your Personal Information.

A consumer may use an authorized agent to submit a request on the consumer’s behalf. When using an authorized agent, we require that you provide the authorized agent written permission to do so and verify their own identity and agent status with us. If you would like to designate an authorized agent to make a request on your behalf, please email us at CCPA@twosigma.com.

If you require this notice in an alternative accessible format, please email us at CCPA@twosigma.com.

We have instituted a process for verifying that the person making a request to know or a request for deletion is the consumer about whom we have collected information. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the Personal Information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary.

In verifying your identity, we will consider the following factors:

• The type, sensitivity, and value of the personal information collected and maintained about the consumer. Sensitive or valuable personal information shall warrant a more stringent verification process.  The types of personal information identified in Civil Code section 1798.81.5(d) shall be considered presumptively sensitive;
• The risk of harm to the consumer posed by any unauthorized access or deletion. A greater risk of harm to the consumer by unauthorized access or deletion shall warrant a more stringent verification process;
• The likelihood that fraudulent or malicious actors would seek the personal information. The higher the likelihood, the more stringent the verification process will be;
• Whether the personal information to be provided by the consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;
• The manner in which the business interacts with the consumer; and
• Available technology for verification.

If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.

For online requests to delete, we will use a two-step process where the consumer must first, clearly submit the request to delete and then second, separately confirm that they want their personal information deleted.

For requests to know and requests to delete, we will confirm receipt of the request within ten (10) days and provide information about how the business will process the request, and we will respond within 45 days with an option to extend an additional 45 days provided we give you notice.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) email us at CCPA@twosigma.com; (ii) contact us at the toll-free telephone number 1-844-820-6577; or (iii) submit a webform request here.

TWO SIGMA SITES AND CHILDREN

Our Sites are meant for adults.  We do not knowingly collect personal information from children under 13 without permission from a parent or guardian.  If you are a parent or legal guardian and think your child under 13 has given us personal information, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.”  Parents and guardians may learn more about how to protect children’s privacy on-line here.

WE USE STANDARD SECURITY MEASURES

We maintain reasonable security procedures and practices.  But the Internet is not 100% secure.  We cannot promise that your use of our Sites or software will be completely safe.  We encourage you to use caution when transmitting personal information over the Internet. We keep personal information for as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep personal information as otherwise required by law or for internal compliance or record-keeping purposes.

WE STORE PERSONAL INFORMATION IN THE UNITED STATES

Personal information we collect may be transferred to and stored within the United States. Our Sites are subject to U.S. laws, which may not afford the same level of protection as those in your country. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. You acknowledge that if you do not consent or would like to withdraw your consent to such transfer by contacting GDPR@twosigma.com, it will impact your ability to use our Sites.

WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITES WE DON’T CONTROL

If you click on a link to a third party website, you will be taken to website(s) that we do not control.  This Privacy Policy does not apply to the privacy practices of such third party website(s).  Read the privacy policy of other websites carefully before you submit any personal information to these third party website(s). We are not responsible for actions, omissions or practices of third party website(s).

reCAPTCHA

We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on this site. This plugin checks if you are a person in order to prevent certain website functions from being (ab)used by spam bots (particularly comments). This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. For this purpose your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within member states of the European Union or in other states which are party to the agreement on the European Economic Area and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCaptcha from your browser shall not be merged with any other data from Google.

This data collection is subject to the data protection regulations of Google (Google Inc.). For more information about Google’s privacy policy, please visit: https://www.google.com/intl/en/policies/privacy/
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By using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS

If you have any questions about this Privacy Policy or other privacy concerns, please contact us at:

Two Sigma Investments, LP
100 Avenue of the Americas
16th Floor
New York, NY 10013
Attn: Legal / Privacy Matters

We may update this Privacy Policy

From time to time we may change our privacy policies.  We will notify you of any material changes to our Privacy Policy as required by law by posting a notice on our Site prior to the change becoming effective. We will also post an updated copy on our Site.  Please check our Site periodically for updates.  You are bound by any changes to the Privacy Policy when you use the website after such changes have been first posted

© 2020 Two Sigma Investments, LP. All rights reserved.

Updated and Effective Date: April 6, 2023

This Privacy Policy describes how TSPI, LP (“TSPI”, “we”, “our” or “us”) treats personal information, including personal information collected on the website where this Privacy Policy is located (the “Site”). This policy covers our treatment of any third party personal information that you share with us via the Site or that we receive about you from certain of our Investment Companies (defined below). It is important that you show this Privacy Policy to any other person about whom you provide personal information to us.

This Privacy Policy does not apply to websites or platforms where a different privacy policy is posted. It also may not apply to the practices of all TSPI affiliates. In addition, this Privacy Policy does not apply to customers or consumers of TSPI or its affiliates financial services or products (including, but not limited to, any investment managed by TSPI) with respect to your use of such financial services or products. By using this Site, you are deemed to have read, acknowledged and accepted all the provisions stated in this Privacy Policy, including any changes we may make from time to time. This acceptance does not equate to consent for the processing of your personal data to the extent you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”). As required, we will specifically seek your prior consent for certain processing (e.g. providing marketing materials to you) of personal information.

WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

We collect the following categories of personal information from you in different ways including from you directly, from you passively through your use of the Site, from third parties (including certain companies that investment vehicles we manage invest in (“Investment Companies”)) and from publicly available sources.

Personal Identifiers: We collect your name, address, phone number, username, email address, log-in information and any other information that you provide to us voluntarily, when you register on our Site, sign up for our newsletters or apply for a job.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Commercial Information:  We may collect commercial information, including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies, from you directly, or through third parties.  We use and share this information as noted below.

Communications: We collect information you email, submit, or post. We collect information when you contact us using the email address provided on the Site. This may contain personal information about you such as personal identifiers and professional or employment information.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Professional or Employment Information: When you register on the Site or apply for a job, we may collect professional and employment information such as information about your employers, awards and associations.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Educational Information: When you register on the Site or apply for a job, we may collect educational information such as information about schools you attended, degrees awarded and academic status.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies platforms and events, employers,  online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Internet or Other Electronic Network Activity: We collect internet and other electronic information such as usage data on how you use our Site and how long you stay on the Site through the use of browser cookies or other commonly used technologies (e.g. web beacons). This may include information about your browser, device type, IP address, user session information, etc. and contain personal information about you.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies, platforms and events, employers,  online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below. Learn more about these tools and how you can manage them, by visiting our Cookies Policy.

Geolocation Information: We collect your IP address when you use the Site and from our services providers. We collect this information through your use of the Site. We use and share this information as noted below.

Aggregate information.  We collect statistical information about how users use the website, some of which is derived from personal information but is not itself personal information. We use and share this information as noted below. We use and share this information as noted below.

We may collect personal information as otherwise described at the time of collection on the Site.

WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.

The provision of personal information by you may be necessary for the performance of any contractual relationship with you, where we have a legitimate interest for business and commercial purposes. For each category of personal information above, we use your personal information to carry out the following purposes:

Responding to Requests: We use information about you to respond to your requests or questions.  For example, we might use your information to contact you about employment opportunities or to process your application for a job.

Provide you with Services and Improve the Site: We use information about you to provide you services and improve our Site and the information we provide.  We might use your personal information to deliver the Site and/or customize your experience with us.  For example, we may use your personal information to improve the Site, our recruiting efforts and our other internal business purposes.

Security and Fraud Prevention and Detection: We use information for security purposes such as fraud prevention and detection.  We may use personal information to enforce our rights, for fraud prevention, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.

Compliance with Laws and to Protect Ourselves: We use your personal information to support auditing, legal and compliance purposes including responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Recruiting and Marketing: We use personal information to inform you about TSPI.  For example, we might send you information about TSPI and what we offer.  We might tell you about new features or updates. We may also use your personal information to send you information about career opportunities. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us, you can unsubscribe via the link at the bottom of the relevant marketing e-mail or contact us using the contact details below. We have a legitimate interest to carry out direct marketing in certain instances.

Communications:  We use personal information to communicate with you about your account or our relationship.  We may contact you about your use of our Site. We may contact you about your account or feedback.  We might also contact you about this Privacy Policy or the Site’s Terms of Use.

Debug and Identify Errors: We use your personal information to debug, identify, and repair errors that impair existing intended functionality.

Statistical Analysis and Research: We may use your personal information for statistical analysis and research purposes including analyzing performance.

We may use your personal information as otherwise described or permitted by law, for any other purpose as described in this Privacy Policy, or as we may notify you.

WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES.

We may collect and share personal information about you from third parties. For example, our business partners, Investment Companies, or vendors may give us personal information about you. We may combine this information with information that you give us via the Site.

For each of the personal information categories listed above, we may share this information with third parties and affiliates for business or commercial purposes.

Two Sigma Companies:  We may share your personal information within the Two Sigma family of companies.

To Respond to Your Requests:  We may use your personal information to respond to your requests or questions.  For example, we might share your personal information with third parties in order to provide you with services requested by you or answer your questions.

Service Providers:  We will share personal information with third parties who perform services on our behalf.  For example, we share personal information with our vendors (e.g., IT services providers, cloud providers, background check vendors, online platforms, recruiting agencies and platforms), partners and consultants. We may also share personal information with companies that operate our websites.

Comply with the Law:  We will share personal information if we think we have to in order to comply with the law or to protect ourselves such as responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Business Successors:  We may share personal information with any successor to all or part of our business.  For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of TSPI or part of its business (or in anticipation of such an event) we may share your personal information as part of that transaction.

Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.

Aggregate Information: We may share Aggregate Information with third parties, including vendors, partners and consultants, to further our internal business purposes and/or their services or websites. In addition, these third parties may share with us non-private, aggregated or otherwise non-personal information about you that they have independently developed or acquired.

Information You Elect to Share: You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Platform. We are not responsible for the privacy policies or practices of these Third Party Services.

Information We Share With Your Consent: We will also share your personal information in the manner that you authorize us to.

We may share personal information for other reasons we may describe to you or as permitted by law.

YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING TOOLS

You can opt out of receiving our marketing emails.  To stop receiving our promotional emails, simply use the opt-out or unsubscribe method provided in emails you receive from us.

Our Do Not Track Policy.  Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.  If you block cookies, certain features on our Sites may not work.  If you block or reject cookies, not all of the tracking described here will stop.

RIGHTS FOR INDIVIDUALS IN THE EEA AND THE UK

Individuals who are located in or residents of countries in the EEA and the UK have certain data subject rights that may be subject to limitations and/or restrictions.

You have the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information. You also have the right to ask us to restrict the processing of your personal information as well as a right to data portability.

Please note that you have a right to object to processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing.

You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority.

If you wish to exercise any of your rights under this Privacy Policy, please send us your request via email to GDPR@twosigma.com.

For the purposes of EEA and UK data protection laws, we are the controller of your personal information collected on the Site. This means that we are responsible for, and control the processing of, your personal information.

UK inquiries: Our data protection representative for the UK is Two Sigma International Limited, which can be reached at GDPR@twosigma.com.

EEA inquiries:  Leo RegTech Limited, incorporated and registered in England and Wales with company number 04829021, acting through its French branch located at 128 rue de la Boétie 75008, Paris, France, is a designated representative of Two Sigma Investments, LP (the “Company”) in the European Union, in accordance with article 27 of the EU General Data Protection Regulation (2016/679/EU) (the “GDPR”). The Company has mandated Leo and its branch to be the EU Representative of the Company with regards to any communications or enquiry from the Supervisory Authority and/or data subjects on all issues related to the processing of personal data. If you are in the EU, please contact Leo at the following details: Email: eurorep@leo.tech; Address: FAO EuroRep, c/o Leo, 128 rue de la Boétie 75008, Paris, France. When contacting Leo regarding the Company, please quote the name of the Company and the Ref: 0085.

For the purposes of EEA and UK data protection laws, the legal basis for the processing of your personal information are when it is necessary for the performance of any contractual relationship with you, and where in our legitimate interests for the purposes described in this Privacy Policy.

RIGHTS FOR INDIVIDUALS IN CALIFORNIA

Individuals who are residents of California have certain consumer rights under applicable California privacy laws but which may be subject to certain limitations and/or restrictions. Specifically, under California law you may have the right to:

Request that we disclose information about the personal information collected, used, disclosed or sold;

Request that we delete personal information collected or maintained by us;

Opt out of the sale of your personal information; and

Not receive discriminatory treatment for exercising your privacy rights.

Please note that we do not, and will not, sell your Personal Information.

A consumer may use an authorized agent to submit a request on the consumer’s behalf. When using an authorized agent, we require that you provide the authorized agent written permission to do so and verify their own identity and agent status with us. If you would like to designate an authorized agent to make a request on your behalf, please email us at CCPA@twosigma.com.

If you require this notice in an alternative accessible format, please email us at CCPA@twosigma.com.

We have instituted a process for verifying that the person making a request to know or a request for deletion is the consumer about whom we have collected information. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the Personal Information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary.

In verifying your identity, we will consider the following factors:

The type, sensitivity, and value of the personal information collected and maintained about the consumer. Sensitive or valuable personal information shall warrant a more stringent verification process. The types of personal information identified in Civil Code section 1798.81.5(d) shall be considered presumptively sensitive;

The risk of harm to the consumer posed by any unauthorized access or deletion. A greater risk of harm to the consumer by unauthorized access or deletion shall warrant a more stringent verification process;

The likelihood that fraudulent or malicious actors would seek the personal information. The higher the likelihood, the more stringent the verification process will be;

Whether the personal information to be provided by the consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;

The manner in which the business interacts with the consumer; and

Available technology for verification.

If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.

For online requests to delete, we will use a two-step process where the consumer must first, clearly submit the request to delete and then second, separately confirm that they want their personal information deleted.

For requests to know and requests to delete, we will confirm receipt of the request within ten (10) days and provide information about how the business will process the request, and we will respond within 45 days with an option to extend an additional 45 days provided we give you notice.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) email us at CCPA@twosigma.com; (ii) contact us at the toll-free telephone number 1-844-820-6577; or (iii) submit a webform request here.

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

TSPI SITES AND CHILDREN

Our Site is meant for adults.  We do not knowingly collect personal information from children under 13 without permission from a parent or guardian.  If you are a parent or legal guardian and think your child under 13 has given us personal information, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.”  Parents and guardians may learn more about how to protect children’s privacy on-line here.

WE USE STANDARD SECURITY MEASURES

We maintain reasonable security procedures and practices.  However, the Internet is not 100% secure.  We cannot promise that your use of our Sites or software will be completely safe. . We cannot promise that your use of our Site will be completely safe. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of personal information at any time. We encourage you to use caution when transmitting personal information over the Internet.

We keep personal information for as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep personal information as otherwise required by law or for internal compliance or record-keeping purposes. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes), the type of personal data being used, and any legal or contractual obligations we are subject to (as, for example, laws or regulations may set a minimum period for which we have to keep your personal data).

WE STORE PERSONAL INFORMATION IN THE UNITED STATES

Personal information we collect will be transferred to and stored within the United States. Our Sites are subject to U.S. laws, which may not afford the same level of protection as those in your country. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy. For example, we may enter into EU-style data transfer agreements (known as Standard Contractual Clauses) with our Investment Companies. However, if you live outside of the United States, and you submit your personal information directly via the Site, you understand and agree that we will transfer your personal information to the United States. If you do not consent or would like to withdraw your consent to such transfer by contacting GDPR@twosigma.com, it will impact your ability to use our Sites.

WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITES WE DON’T CONTROL

If you click on a link to a third party website, you will be taken to website(s) that we do not control.  This Privacy Policy does not apply to the privacy practices of such third party website(s).  Read the privacy policy of other websites carefully before you submit any personal information to these third party website(s). We are not responsible for actions, omissions or practices of third party website(s).

reCAPTCHA and Google APIs

We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on this site. This plugin checks if you are a person in order to prevent certain website functions from being (ab) used by spam bots (particularly comments). This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. For this purpose, your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within Member States of the European Union or in other States, which are party to the agreement on the EEA and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCaptcha from your browser shall not be merged with any other data from Google.

We also use certain third party information sources and services, including the Google Places API, to collect information such as user reviews to inform our data-driven investment strategies. The information collected through these third party sources, including API services, may include your name or any other publicly available information if you have shared that information with Google.

This data collection is subject to the data protection regulations of Google (Google Inc.). For more information about Google’s privacy policy, please visit: https://www.google.com/intl/en/policies/privacy/

By submitting your information to Google and using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS

If you have any questions about this Privacy Policy or other privacy concerns, please contact us at:

TSPI, LP
100 Avenue of the Americas
16th Floor
New York, NY 10013
Attn: Legal / Privacy Matters

We may update this Privacy Policy

From time to time, we may change our privacy policies.  We will notify you of any material changes to our Privacy Policy as required by law by posting a notice on our Site prior to the change becoming effective. We will also post an updated copy on our Site.  Please check our Site periodically for updates.  You are bound by any changes to the Privacy Policy when you use the website after such changes have been first posted.

Updated and Effective Date: April 6, 2023

This Privacy Policy describes how TSPI, LP (“TSPI”, “we”, “our” or “us”) treats personal information, including personal information collected on the website where this Privacy Policy is located (the “Site”). This policy covers our treatment of any third party personal information that you share with us via the Site or that we receive about you from certain of our Investment Companies (defined below). It is important that you show this Privacy Policy to any other person about whom you provide personal information to us.

This Privacy Policy does not apply to websites or platforms where a different privacy policy is posted. It also may not apply to the practices of all TSPI affiliates. In addition, this Privacy Policy does not apply to customers or consumers of TSPI or its affiliates financial services or products (including, but not limited to, any investment managed by TSPI) with respect to your use of such financial services or products. By using this Site, you are deemed to have read, acknowledged and accepted all the provisions stated in this Privacy Policy, including any changes we may make from time to time. This acceptance does not equate to consent for the processing of your personal data to the extent you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”). As required, we will specifically seek your prior consent for certain processing (e.g. providing marketing materials to you) of personal information.

WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

We collect the following categories of personal information from you in different ways including from you directly, from you passively through your use of the Site, from third parties (including certain companies that investment vehicles we manage invest in (“Investment Companies”)) and from publicly available sources.

Personal Identifiers: We collect your name, address, phone number, username, email address, log-in information and any other information that you provide to us voluntarily, when you register on our Site, sign up for our newsletters or apply for a job.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Commercial Information:  We may collect commercial information, including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies, from you directly, or through third parties.  We use and share this information as noted below.

Communications: We collect information you email, submit, or post. We collect information when you contact us using the email address provided on the Site. This may contain personal information about you such as personal identifiers and professional or employment information.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Professional or Employment Information: When you register on the Site or apply for a job, we may collect professional and employment information such as information about your employers, awards and associations.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as notedbelow.

Educational Information: When you register on the Site or apply for a job, we may collect educational information such as information about schools you attended, degrees awarded and academic status.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies platforms and events, employers,  online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Internet or Other Electronic Network Activity: We collect internet and other electronic information such as usage data on how you use our Site and how long you stay on the Site through the use of browser cookies or other commonly used technologies (e.g. web beacons). This may include information about your browser, device type, IP address, user session information, etc. and contain personal information about you.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies, platforms and events, employers,  online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below. Learn more about these tools and how you can manage them, by visiting our Cookies Policy.

Geolocation Information: We collect your IP address when you use the Site and from our services providers. We collect this information through your use of the Site. We use and share this information as noted below.

Aggregate information.  We collect statistical information about how users use the website, some of which is derived from personal information but is not itself personal information. We use and share this information as noted below. We use and share this information as noted below.

We may collect personal information as otherwise described at the time of collection on the Site.

WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.

The provision of personal information by you may be necessary for the performance of any contractual relationship with you, where we have a legitimate interest for business and commercial purposes. For each category of personal information above, we use your personal information to carry out the following purposes:

Responding to Requests: We use information about you to respond to your requests or questions.  For example, we might use your information to contact you about employment opportunities or to process your application for a job.

Provide you with Services and Improve the Site: We use information about you to provide you services and improve our Site and the information we provide.  We might use your personal information to deliver the Site and/or customize your experience with us.  For example, we may use your personal information to improve the Site, our recruiting efforts and our other internal business purposes.

Security and Fraud Prevention and Detection: We use information for security purposes such as fraud prevention and detection.  We may use personal information to enforce our rights, for fraud prevention, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.

Compliance with Laws and to Protect Ourselves: We use your personal information to support auditing, legal and compliance purposes including responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Recruiting and Marketing: We use personal information to inform you about TSPI.  For example, we might send you information about TSPI and what we offer.  We might tell you about new features or updates. We may also use your personal information to send you information about career opportunities. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us, you can unsubscribe via the link at the bottom of the relevant marketing e-mail or contact us using the contact details below. We have a legitimate interest to carry out direct marketing in certain instances.

Communications:  We use personal information to communicate with you about your account or our relationship.  We may contact you about your use of our Site. We may contact you about your account or feedback.  We might also contact you about this Privacy Policy or the Site’s Terms of Use.

Debug and Identify Errors: We use your personal information to debug, identify, and repair errors that impair existing intended functionality.

Statistical Analysis and Research: We may use your personal information for statistical analysis and research purposes including analyzing performance.

We may use your personal information as otherwise described or permitted by law, for any other purpose as described in this Privacy Policy, or as we may notify you.

WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES.

We may collect and share personal information about you from third parties. For example, our business partners, Investment Companies, or vendors may give us personal information about you. We may combine this information with information that you give us via the Site.

For each of the personal information categories listed above, we may share this information with third parties and affiliates for business or commercial purposes.

Two Sigma Companies:  We may share your personal information within the Two Sigma family of companies.

To Respond to Your Requests:  We may use your personal information to respond to your requests or questions.  For example, we might share your personal information with third parties in order to provide you with services requested by you or answer your questions.

Service Providers:  We will share personal information with third parties who perform services on our behalf.  For example, we share personal information with our vendors (e.g., IT services providers, cloud providers, background check vendors, online platforms, recruiting agencies and platforms), partners and consultants. We may also share personal information with companies that operate our websites.

Comply with the Law:  We will share personal information if we think we have to in order to comply with the law or to protect ourselves such as responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Business Successors:  We may share personal information with any successor to all or part of our business.  For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of TSPI or part of its business (or in anticipation of such an event) we may share your personal information as part of that transaction.

Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.

Aggregate Information: We may share Aggregate Information with third parties, including vendors, partners and consultants, to further our internal business purposes and/or their services or websites. In addition, these third parties may share with us non-private, aggregated or otherwise non-personal information about you that they have independently developed or acquired.

Information You Elect to Share: You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Platform. We are not responsible for the privacy policies or practices of these Third Party Services.

Information We Share With Your Consent: We will also share your personal information in the manner that you authorize us to.

We may share personal information for other reasons we may describe to you or as permitted by law.

YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING TOOLS

You can opt out of receiving our marketing emails.  To stop receiving our promotional emails, simply use the opt-out or unsubscribe method provided in emails you receive from us.

Our Do Not Track Policy.  Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.  If you block cookies, certain features on our Sites may not work.  If you block or reject cookies, not all of the tracking described here will stop.

RIGHTS FOR INDIVIDUALS IN THE EEA AND THE  UK

Individuals who are located in or residents of countries in the EEA and the UK have certain data subject rights that may be subject to limitations and/or restrictions.

You have the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information. You also have the right to ask us to restrict the processing of your personal information as well as a right to data portability.

Please note that you have a right to object to processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing.

You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority.

If you wish to exercise any of your rights under this Privacy Policy, please send us your request via email to GDPR@twosigma.com.

For the purposes of EEA and UK data protection laws, we are the controller of your personal information collected on the Site. This means that we are responsible for, and control the processing of, your personal information.

UK inquiries: Our data protection representative for the UK is Two Sigma International Limited, which can be reached at GDPR@twosigma.com.

EEA inquiries: Laven Consulting Limited (incorporated and registered in England and Wales with company number 10918441) (“Laven”) acting through its Paris branch located at 128 Rue La Boetie 75008, Paris, France as designated representative of Two Sigma Investments LP and its affiliates, as applicable (“Company”), in accordance with art. 27 of the General Data Protection Regulation (the Regulation (EU) 2016/679) (“GDPR”). The Company has mandated Laven to be the European representative of the Company with regards to any communications or enquiry from the Supervisory Authority and/or data subjects on all issues related to the processing of personal data. Please contact Laven on info@eurorep.eu; the postal address is FAO EuroRep, c/o Laven Partners, 128 Rue La Boetie 75008, Paris, France. When contacting Laven regarding the Company please quote the name of the company and the Ref: 0085.

For the purposes of EEA and UK data protection laws, the legal basis for the processing of your personal information are when it is necessary for the performance of any contractual relationship with you, and where in our legitimate interests for the purposes described in this Privacy Policy.

RIGHTS FOR INDIVIDUALS IN CALIFORNIA

Individuals who are residents of California have certain consumer rights under applicable California privacy laws but which may be subject to certain limitations and/or restrictions. Specifically, under California law you may have the right to:

• Request that we disclose information about the personal information collected, used, disclosed or sold;
• Request that we delete personal information collected or maintained by us;
• Opt out of the sale of your personal information; and
• Not receive discriminatory treatment for exercising your privacy rights.

Please note that we do not, and will not, sell your Personal Information.

A consumer may use an authorized agent to submit a request on the consumer’s behalf. When using an authorized agent, we require that you provide the authorized agent written permission to do so and verify their own identity and agent status with us. If you would like to designate an authorized agent to make a request on your behalf, please email us at CCPA@twosigma.com.

If you require this notice in an alternative accessible format, please email us at CCPA@twosigma.com.

We have instituted a process for verifying that the person making a request to know or a request for deletion is the consumer about whom we have collected information. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the Personal Information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary.

In verifying your identity, we will consider the following factors:

• The type, sensitivity, and value of the personal information collected and maintained about the consumer. Sensitive or valuable personal information shall warrant a more stringent verification process. The types of personal information identified in Civil Code section 1798.81.5(d) shall be considered presumptively sensitive;
• The risk of harm to the consumer posed by any unauthorized access or deletion. A greater risk of harm to the consumer by unauthorized access or deletion shall warrant a more stringent verification process;
• The likelihood that fraudulent or malicious actors would seek the personal information. The higher the likelihood, the more stringent the verification process will be;
• Whether the personal information to be provided by the consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;
• The manner in which the business interacts with the consumer; and
• Available technology for verification.

If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.

For online requests to delete, we will use a two-step process where the consumer must first, clearly submit the request to delete and then second, separately confirm that they want their personal information deleted.

For requests to know and requests to delete, we will confirm receipt of the request within ten (10) days and provide information about how the business will process the request, and we will respond within 45 days with an option to extend an additional 45 days provided we give you notice.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) email us at CCPA@twosigma.com; (ii) contact us at the toll-free telephone number 1-844-820-6577; or (iii) submit a webform request here.

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

TSPI SITES AND CHILDREN

Our Site is meant for adults.  We do not knowingly collect personal information from children under 13 without permission from a parent or guardian.  If you are a parent or legal guardian and think your child under 13 has given us personal information, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.”  Parents and guardians may learn more about how to protect children’s privacy on-line here.

WE USE STANDARD SECURITY MEASURES

We maintain reasonable security procedures and practices.  However, the Internet is not 100% secure.  We cannot promise that your use of our Sites or software will be completely safe. . We cannot promise that your use of our Site will be completely safe. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of personal information at any time. We encourage you to use caution when transmitting personal information over the Internet.

We keep personal information for as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep personal information as otherwise required by law or for internal compliance or record-keeping purposes. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes), the type of personal data being used, and any legal or contractual obligations we are subject to (as, for example, laws or regulations may set a minimum period for which we have to keep your personal data).

WE STORE PERSONAL INFORMATION IN THE UNITED STATES

Personal information we collect will be transferred to and stored within the United States. Our Sites are subject to U.S. laws, which may not afford the same level of protection as those in your country. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy. For example, we may enter into EU-style data transfer agreements (known as Standard Contractual Clauses) with our Investment Companies. However, if you live outside of the United States, and you submit your personal information directly via the Site, you understand and agree that we will transfer your personal information to the United States. If you do not consent or would like to withdraw your consent to such transfer by contacting GDPR@twosigma.com, it will impact your ability to use our Sites.

WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITES WE DON’T CONTROL

If you click on a link to a third party website, you will be taken to website(s) that we do not control.  This Privacy Policy does not apply to the privacy practices of such third party website(s).  Read the privacy policy of other websites carefully before you submit any personal information to these third party website(s). We are not responsible for actions, omissions or practices of third party website(s).

reCAPTCHA and Google APIs

We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on this site. This plugin checks if you are a person in order to prevent certain website functions from being (ab) used by spam bots (particularly comments). This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. For this purpose, your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within Member States of the European Union or in other States, which are party to the agreement on the EEA and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCaptcha from your browser shall not be merged with any other data from Google.

We also use certain third party information sources and services, including the Google Places API, to collect information such as user reviews to inform our data-driven investment strategies. The information collected through these third party sources, including API services, may include your name or any other publicly available information if you have shared that information with Google.

This data collection is subject to the data protection regulations of Google (Google Inc.). For more information about Google’s privacy policy, please visit: https://www.google.com/intl/en/policies/privacy/

By submitting your information to Google and using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS

If you have any questions about this Privacy Policy or other privacy concerns, please contact us at:

TSPI, LP
100 Avenue of the Americas
16th Floor
New York, NY 10013
Attn: Legal / Privacy Matters

We may update this Privacy Policy

From time to time, we may change our privacy policies.  We will notify you of any material changes to our Privacy Policy as required by law by posting a notice on our Site prior to the change becoming effective. We will also post an updated copy on our Site.  Please check our Site periodically for updates.  You are bound by any changes to the Privacy Policy when you use the website after such changes have been first posted.

© 2020 TSPI, LP. All rights reserved.

Effective Date: November 20, 2020

THIS COOKIE POLICY APPLIES TO THIS WEBSITE.

 Cookies

This Policy describes how and why Sightway Capital, a business of TSPI, LP (“we”, “us” or “our”) uses cookies on the websites on which these terms reside (collectively, the “Site”). To make our Site work properly, we sometimes place small data files (called cookies) on your computer or mobile device.

What are cookies?

A cookie is a small text file that a website saves on your computer or mobile device when you visit a website. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the website or browse from one page to another. To learn more about cookies, please visit aboutcookies.org.

What are cookies used for?

We use cookies on our Site to personalize your experience on our Site and to make your future activities and experience on our Site more efficient. We also use cookies to track, compile and analyze usage, navigational and other statistical information that allow us to understand how people use our Site, and to help us improve the structure and content of our Site.

What types of cookies do we use?

We use two types of cookies on our Site: session cookies and persistent cookies. A session cookie is a temporary cookie that remains on your device until you leave our Site. Session cookies are essential to make our Site work correctly, as they enable you to move around our Site and use our features. A persistent cookie remains on your device for much longer, or until you manually delete it (how long the cookie remains on your device will depend on the duration or “lifetime” of the specific cookie and your browser settings). Persistent cookies help us recognize you as a return user of our Site so it’s easier and convenient to return to and interact with our Site. In addition, persistent cookies also help us recognize and record information about your web browsing habits during the lifetime of the persistent cookie.

We use different types of analytical cookies that allow us to provide you with more efficient and contextual support and that also provide us with data around your usage of the Site that we may use to improve the Site but also to benefit our business and the businesses of our affiliates, including with respect to business purposes unrelated to the Site.

What third-party cookies do we use?

We may also work with third-party service providers who may set cookies on our Site. These third-party service providers help us track and analyze your use of our Site and to optimize our Site and improve your experience. These third-party service providers are responsible for the cookies they set on our Site. We do not control the dissemination of these cookies. We are not responsible for these third party sites or the content of such third party sites. Once you have left our Site, we cannot be responsible for the protection and privacy of any information of which you provide. If you want further information please go to the website for the relevant third-party service provider.

 How to control cookies?

If you continue to use our Site without changing your settings, we will assume that you are happy to receive all cookies on our Site. You can control and/or delete cookies as you wish. For details see aboutcookies.org.

You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may have to manually adjust some preferences every time you visit our Site and functionalities may not work.

Contact us

If you have any concerns about the way we use cookies, or if you have any questions, please email us at Legal@twosigma.com.

© 2020 TSPI, LP. All rights reserved.

Updated and Effective Date: April 6, 2023

This Privacy Policy describes how Two Sigma Real Estate, LP (“TSRE”, “we”, “our” or “us”) treats personal information, including personal information collected on the website where this Privacy Policy is located (the “Site”). This policy covers our treatment of any third party personal information that you share with us via the Site or that we receive about you from certain of our Investment Companies (defined below). It is important that you show this Privacy Policy to any other person about whom you provide personal information to us.

This Privacy Policy does not apply to websites or platforms where a different privacy policy is posted. It also may not apply to the practices of all TSPI affiliates. In addition, this Privacy Policy does not apply to customers or consumers of TSPI or its affiliates financial services or products (including, but not limited to, any investment managed by TSPI) with respect to your use of such financial services or products. By using this Site, you are deemed to have read, acknowledged and accepted all the provisions stated in this Privacy Policy, including any changes we may make from time to time. This acceptance does not equate to consent for the processing of your personal data to the extent you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”). As required, we will specifically seek your prior consent for certain processing (e.g. providing marketing materials to you) of personal information.

WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

We collect the following categories of personal information from you in different ways including from you directly, from you passively through your use of the Site, from third parties (including certain companies that investment vehicles we manage invest in (“Investment Companies”)) and from publicly available sources.

Personal Identifiers: We collect your name, address, phone number, username, email address, log-in information and any other information that you provide to us voluntarily, when you register on our Site, sign up for our newsletters or apply for a job.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Commercial Information:  We may collect commercial information, including records of personal property, products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies, from you directly, or through third parties.  We use and share this information as noted below.

Communications: We collect information you email, submit, or post. We collect information when you contact us using the email address provided on the Site. This may contain personal information about you such as personal identifiers and professional or employment information.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Professional or Employment Information: When you register on the Site or apply for a job, we may collect professional and employment information such as information about your employers, awards and associations.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, platforms and events, employers, online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Educational Information: When you register on the Site or apply for a job, we may collect educational information such as information about schools you attended, degrees awarded and academic status.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies platforms and events, employers,  online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below.

Internet or Other Electronic Network Activity: We collect internet and other electronic information such as usage data on how you use our Site and how long you stay on the Site through the use of browser cookies or other commonly used technologies (e.g. web beacons). This may include information about your browser, device type, IP address, user session information, etc. and contain personal information about you.

We may collect this information from various sources including from you directly, through your use of the Site, recruiting agencies, Investment Companies, platforms and events, employers,  online platforms including professional and social networks and forums, productivity and collaboration tool providers.  We use and share this information as noted below. Learn more about these tools and how you can manage them, by visiting our Cookies Policy.

Geolocation Information: We collect your IP address when you use the Site and from our services providers. We collect this information through your use of the Site. We use and share this information as noted below.

Aggregate information.  We collect statistical information about how users use the website, some of which is derived from personal information but is not itself personal information. We use and share this information as noted below. We use and share this information as noted below.

We may collect personal information as otherwise described at the time of collection on the Site.

WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.

The provision of personal information by you may be necessary for the performance of any contractual relationship with you, where we have a legitimate interest for business and commercial purposes. For each category of personal information above, we use your personal information to carry out the following purposes:

Responding to Requests: We use information about you to respond to your requests or questions.  For example, we might use your information to contact you about employment opportunities or to process your application for a job.

Provide you with Services and Improve the Site: We use information about you to provide you services and improve our Site and the information we provide.  We might use your personal information to deliver the Site and/or customize your experience with us.  For example, we may use your personal information to improve the Site, our recruiting efforts and our other internal business purposes.

Security and Fraud Prevention and Detection: We use information for security purposes such as fraud prevention and detection.  We may use personal information to enforce our rights, for fraud prevention, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.

Compliance with Laws and to Protect Ourselves: We use your personal information to support auditing, legal and compliance purposes including responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Recruiting and Marketing: We use personal information to inform you about TSPI.  For example, we might send you information about TSPI and what we offer.  We might tell you about new features or updates. We may also use your personal information to send you information about career opportunities. If applicable law requires that we receive your consent before we send you certain types of marketing communications, we will only send you those types of communications after receiving your consent. If you wish to stop receiving marketing or market research communications from us, you can unsubscribe via the link at the bottom of the relevant marketing e-mail or contact us using the contact details below. We have a legitimate interest to carry out direct marketing in certain instances.

Communications:  We use personal information to communicate with you about your account or our relationship.  We may contact you about your use of our Site. We may contact you about your account or feedback.  We might also contact you about this Privacy Policy or the Site’s Terms of Use.

Debug and Identify Errors: We use your personal information to debug, identify, and repair errors that impair existing intended functionality.

Statistical Analysis and Research: We may use your personal information for statistical analysis and research purposes including analyzing performance.

We may use your personal information as otherwise described or permitted by law, for any other purpose as described in this Privacy Policy, or as we may notify you.

WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES.

We may collect and share personal information about you from third parties. For example, our business partners, Investment Companies, or vendors may give us personal information about you. We may combine this information with information that you give us via the Site.

For each of the personal information categories listed above, we may share this information with third parties and affiliates for business or commercial purposes.

Two Sigma Companies:  We may share your personal information within the Two Sigma family of companies.

To Respond to Your Requests:  We may use your personal information to respond to your requests or questions.  For example, we might share your personal information with third parties in order to provide you with services requested by you or answer your questions.

Service Providers:  We will share personal information with third parties who perform services on our behalf.  For example, we share personal information with our vendors (e.g., IT services providers, cloud providers, background check vendors, online platforms, recruiting agencies and platforms), partners and consultants. We may also share personal information with companies that operate our websites.

Comply with the Law:  We will share personal information if we think we have to in order to comply with the law or to protect ourselves such as responding to court orders or subpoenas. We may also share your personal information if a government agency or investigatory body requests. We may also use your personal information when we are investigating potential fraud or other areas of concern or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

Business Successors:  We may share personal information with any successor to all or part of our business.  For example, in the event of a merger, acquisition, divestiture, change of control, or liquidation of TSPI or part of its business (or in anticipation of such an event) we may share your personal information as part of that transaction.

Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this Privacy Policy.

Aggregate Information: We may share Aggregate Information with third parties, including vendors, partners and consultants, to further our internal business purposes and/or their services or websites. In addition, these third parties may share with us non-private, aggregated or otherwise non-personal information about you that they have independently developed or acquired.

Information You Elect to Share: You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Platform. We are not responsible for the privacy policies or practices of these Third Party Services.

Information We Share With Your Consent: We will also share your personal information in the manner that you authorize us to.

We may share personal information for other reasons we may describe to you or as permitted by law.

YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING TOOLS

You can opt out of receiving our marketing emails.  To stop receiving our promotional emails, simply use the opt-out or unsubscribe method provided in emails you receive from us.

Our Do Not Track Policy.  Some websites have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.  If you block cookies, certain features on our Sites may not work.  If you block or reject cookies, not all of the tracking described here will stop.

RIGHTS FOR INDIVIDUALS IN THE EEA AND THE UK

Individuals who are located in or residents of countries in the EEA and the UK have certain data subject rights that may be subject to limitations and/or restrictions.

You have the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information. You also have the right to ask us to restrict the processing of your personal information as well as a right to data portability.

Please note that you have a right to object to processing of your personal information where that processing is carried out for our legitimate interest or for direct marketing.

You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority.

If you wish to exercise any of your rights under this Privacy Policy, please send us your request via email to GDPR@twosigma.com.

For the purposes of EEA and UK data protection laws, we are the controller of your personal information collected on the Site. This means that we are responsible for, and control the processing of, your personal information.

UK inquiries: Our data protection representative for the UK is Two Sigma International Limited, which can be reached at GDPR@twosigma.com.

EEA inquiries:  Leo RegTech Limited, incorporated and registered in England and Wales with company number 04829021, acting through its French branch located at 128 rue de la Boétie 75008, Paris, France, is a designated representative of Two Sigma Investments, LP (the “Company”) in the European Union, in accordance with article 27 of the EU General Data Protection Regulation (2016/679/EU) (the “GDPR”). The Company has mandated Leo and its branch to be the EU Representative of the Company with regards to any communications or enquiry from the Supervisory Authority and/or data subjects on all issues related to the processing of personal data. If you are in the EU, please contact Leo at the following details: Email: eurorep@leo.tech; Address: FAO EuroRep, c/o Leo, 128 rue de la Boétie 75008, Paris, France. When contacting Leo regarding the Company, please quote the name of the Company and the Ref: 0085.

For the purposes of EEA and UK data protection laws, the legal basis for the processing of your personal information are when it is necessary for the performance of any contractual relationship with you, and where in our legitimate interests for the purposes described in this Privacy Policy.

RIGHTS FOR INDIVIDUALS IN CALIFORNIA

Individuals who are residents of California have certain consumer rights under applicable California privacy laws but which may be subject to certain limitations and/or restrictions. Specifically, under California law you may have the right to:

Request that we disclose information about the personal information collected, used, disclosed or sold;

Request that we delete personal information collected or maintained by us;

Opt out of the sale of your personal information; and

Not receive discriminatory treatment for exercising your privacy rights.

Please note that we do not, and will not, sell your Personal Information.

A consumer may use an authorized agent to submit a request on the consumer’s behalf. When using an authorized agent, we require that you provide the authorized agent written permission to do so and verify their own identity and agent status with us. If you would like to designate an authorized agent to make a request on your behalf, please email us at CCPA@twosigma.com.

If you require this notice in an alternative accessible format, please email us at CCPA@twosigma.com.

We have instituted a process for verifying that the person making a request to know or a request for deletion is the consumer about whom we have collected information. Whenever feasible, we will match at least two data points in the identifying information provided by the consumer to the Personal Information already maintained by us, but it may require more data points depending on the information requested. We will avoid collecting highly sensitive pieces of personal information, unless necessary.

In verifying your identity, we will consider the following factors:

The type, sensitivity, and value of the personal information collected and maintained about the consumer. Sensitive or valuable personal information shall warrant a more stringent verification process. The types of personal information identified in Civil Code section 1798.81.5(d) shall be considered presumptively sensitive;

The risk of harm to the consumer posed by any unauthorized access or deletion. A greater risk of harm to the consumer by unauthorized access or deletion shall warrant a more stringent verification process;

The likelihood that fraudulent or malicious actors would seek the personal information. The higher the likelihood, the more stringent the verification process will be;

Whether the personal information to be provided by the consumer to verify their identity is sufficiently robust to protect against fraudulent requests or being spoofed or fabricated;

The manner in which the business interacts with the consumer; and

Available technology for verification.

If we cannot verify your identity in accordance with California law, we may deny your request in whole or in part.

For online requests to delete, we will use a two-step process where the consumer must first, clearly submit the request to delete and then second, separately confirm that they want their personal information deleted.

For requests to know and requests to delete, we will confirm receipt of the request within ten (10) days and provide information about how the business will process the request, and we will respond within 45 days with an option to extend an additional 45 days provided we give you notice.

If you wish to exercise any of your rights under this section, you may submit your request through any of these methods: (i) email us at CCPA@twosigma.com; (ii) contact us at the toll-free telephone number 1-844-820-6577; or (iii) submit a webform request here.

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email, or write to us at the address listed below. Indicate in your letter that you are a California resident making a “Shine the Light” inquiry.

TSPI SITES AND CHILDREN

Our Site is meant for adults.  We do not knowingly collect personal information from children under 13 without permission from a parent or guardian.  If you are a parent or legal guardian and think your child under 13 has given us personal information, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.”  Parents and guardians may learn more about how to protect children’s privacy on-line here.

WE USE STANDARD SECURITY MEASURES

We maintain reasonable security procedures and practices.  However, the Internet is not 100% secure.  We cannot promise that your use of our Sites or software will be completely safe. . We cannot promise that your use of our Site will be completely safe. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of personal information at any time. We encourage you to use caution when transmitting personal information over the Internet.

We keep personal information for as long as it is necessary or relevant for the practices described in this Privacy Policy. We also keep personal information as otherwise required by law or for internal compliance or record-keeping purposes. The retention period will be determined by various criteria, including the purposes for which we are using it (as it will need to be kept for as long as is necessary for any of those purposes), the type of personal data being used, and any legal or contractual obligations we are subject to (as, for example, laws or regulations may set a minimum period for which we have to keep your personal data).

WE STORE PERSONAL INFORMATION IN THE UNITED STATES

Personal information we collect will be transferred to and stored within the United States. Our Sites are subject to U.S. laws, which may not afford the same level of protection as those in your country. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this Privacy Policy. For example, we may enter into EU-style data transfer agreements (known as Standard Contractual Clauses) with our Investment Companies. However, if you live outside of the United States, and you submit your personal information directly via the Site, you understand and agree that we will transfer your personal information to the United States. If you do not consent or would like to withdraw your consent to such transfer by contacting GDPR@twosigma.com, it will impact your ability to use our Sites.

WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITES WE DON’T CONTROL

If you click on a link to a third party website, you will be taken to website(s) that we do not control.  This Privacy Policy does not apply to the privacy practices of such third party website(s).  Read the privacy policy of other websites carefully before you submit any personal information to these third party website(s). We are not responsible for actions, omissions or practices of third party website(s).

reCAPTCHA and Google APIs

We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on this site. This plugin checks if you are a person in order to prevent certain website functions from being (ab) used by spam bots (particularly comments). This plugin query includes the sending of the IP address and possibly other data required by Google for the Google reCAPTCHA service. For this purpose, your input will be communicated to and used by Google. However, your IP address is previously truncated by Google within Member States of the European Union or in other States, which are party to the agreement on the EEA and is, as such, anonymized. Only in exceptional cases is a full IP address transmitted to a Google server in the United States and truncated there. On behalf of the operator of this website, Google will use this information to evaluate your use of this service. The IP address provided by reCaptcha from your browser shall not be merged with any other data from Google.

We also use certain third party information sources and services, including the Google Places API, to collect information such as user reviews to inform our data-driven investment strategies. The information collected through these third party sources, including API services, may include your name or any other publicly available information if you have shared that information with Google.

This data collection is subject to the data protection regulations of Google (Google Inc.). For more information about Google’s privacy policy, please visit: https://www.google.com/intl/en/policies/privacy/

By submitting your information to Google and using the reCAPTCHA service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS

If you have any questions about this Privacy Policy or other privacy concerns, please contact us at:

TSPI, LP
100 Avenue of the Americas
16th Floor
New York, NY 10013
Attn: Legal / Privacy Matters

We may update this Privacy Policy

From time to time, we may change our privacy policies.  We will notify you of any material changes to our Privacy Policy as required by law by posting a notice on our Site prior to the change becoming effective. We will also post an updated copy on our Site.  Please check our Site periodically for updates.  You are bound by any changes to the Privacy Policy when you use the website after such changes have been first posted.