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.
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