Effective Date: December 31, 2019
WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.
We collect contact and Account (defined below) information. If your employer registers for the Platform, your employer may provide us information that could be your personal information, such as your name, email address and work title. If you register through a user account (an “Account”), you will also provide information that could be personal information, such as your username, password, email address and other information requested on our registration page. You acknowledge that by creating an Account on the Platform and providing personal information to us, you allow us to identify you and therefore you may not remain anonymous to us. Where we require your personal information to comply with our contractual obligations, failure to provide such personal information means that we may not be able to maintain your Account and continue our relationship with you.
We collect information you email or otherwise submit. We collect information when you contact us using the email address provided on the Site or the Platform or through any other communication method available through the Site or the Platform. Some features of the Site and Platform allow you to provide content or subscribe to certain communications, and we collect all content and information you submit to the Site and Platform. This may contain personal information about you. We may receive a confirmation when you open an email from us.
Aggregate information. We collect statistical information about how users use the Site and Platform (“Aggregate Information”), some of which is derived from personal information but is not itself personal information.
No Children’s information. The Site and Platform 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 COLLECT INFORMATION IN DIFFERENT WAYS.
We collect information directly from you. For example, if you create an Account, use the Platform or the Site, upload content on the Platform or the Site, subscribe to the Site, send us an email or otherwise communicate with us through the Platform or the Site.
We may collect information about you from third parties. For example, our business partners or vendors, or your employer or one of its service providers, may give us personal information about you. We may combine this information with information that you give us via the Site or the Platform.
We may collect information about you from publicly available sources. For example, we may collect information about your use or interactions with public social media sites or other public postings.
We may collect personal information as otherwise described at the time of collection on the Site or Platform.
WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.
We may collect and process your personal information for the following purposes:
|We use personal information about you to respond to your requests or questions. For example, we might use your personal information to respond to your questions about the Site or Platform or assist you while you use the Site or Platform.||We have a legitimate interest to respond to your requests and questions for ongoing business administration.|
|We use personal information about you to provide and improve the Site and Platform. We might use your personal information to provide and maintain the Site and Platform and/or personalize your visit to the Site and Platform. We may use your personal information for our internal purposes, including to analyze and improve the Site and Platform.||We have a legitimate interest to manage our relationship with you and ensure the Site and Platform are effective and efficient.|
|We use personal information for security and compliance purposes. We may use personal information to enforce our rights, for fraud prevention, to comply with applicable laws and regulations, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.||To comply with our legal obligations.|
|We use personal information to inform you about Two Sigma. For example, we might send you information about us and our affiliates, and what we offer. We might tell you about new features or updates.||We have a legitimate interest to manage our business and where required by applicable law, where we have received your consent.|
|We use personal information for business administration. We may use your personal information for our general business administration, including statistical analysis.||We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient.|
WE MAY SHARE INFORMATION WITH THIRD PARTIES.
We may share your personal information with Two Sigma affiliates.
We may share 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, including with third parties that you intentionally interact with through our services.
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 storage providers and other companies that help us operate and improve the Site or Platform), partners and consultants for the purposes outlined above.
We will share personal information if we think we have to in order to comply with the law or to protect ourselves. For example, we may share personal information to respond to a court order or subpoena. We may also share it if a government agency or investigatory body requests. We might also share personal information when we are investigating potential fraud 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.
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. You acknowledge that such transfers may occur, and that any direct or indirect acquirer of us or our assets may continue to use your personal information as set forth in this policy.
We may share Aggregate Information. We may share Aggregate Information with third parties, including vendors, partners and consultants, to better understand how and how often people use the Site and Platform 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.
We may share personal information for other reasons we may describe to you and for which, where required by applicable law, we have obtained your consent 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.
DELETING YOUR ACCOUNT.
Should you ever desire to delete your Account, you may do so by submitting a written request to the address listed below. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account, unless otherwise specified by us. Please note that we will need to verify that you have the authority to delete the Account.
If you are a subscriber to our Site and decide to unsubscribe, you may do so by submitting a written request to the address listed below.
YOUR ACCESS TO INFORMATION.
If you are a registered user, you can access certain information associated with your Account by logging into the Platform. You may also ask us for a notice identifying the categories of personal information which we share with our affiliates and third parties for marketing purposes, and to provide contact information for such affiliates and third parties. If you would like a copy of this notice, please submit a written request to the address listed below.
RIGHTS FOR INDIVIDUALS IN THE EUROPEAN UNION
To the extent provided by applicable law, individuals who are located in or a resident of the European Union or the United Kingdom (“UK”) have certain data subject rights which may be subject to limitations and/or restrictions, including the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information, and 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.
To the extent provided by applicable law, 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.
For the purposes of EU and UK data protection laws, we are the data controller of your personal information collected when you are using or accessing the Site or Platform. This means that we are responsible for, and control the processing of, your personal information. Our data protection representative for the EU in the UK is Two Sigma International Limited, and can be reached at GDPR@twosigma.com.
WE STORE PERSONAL INFORMATION IN THE UNITED STATES AND OTHER COUNTRIES.
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.
We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on the 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.
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.
WE USE STANDARD SECURITY MEASURES.
Your profile and registration information relating to your Account will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and personal information by selecting and protecting your password appropriately and limiting access to your computer and browser such as by signing off after you have finished accessing your Account.
WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITE OR PLATFORM WE DON’T CONTROL.
FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS.
Two Sigma Investor Solutions, LP
100 Avenue of the Americas 16th Floor
New York, NY 10013
Attn: Legal / Privacy Matters
© 2020 Two Sigma Investments, LP. All rights reserved.