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href="https://www.twosigma.com/careers/quantitative-research-data-science/"> Quantitative Research & Data Science </a> </li> <li class="child-link menu-item menu-item-type-custom menu-item-object-custom menu-item-3347"> <a href="https://careers.twosigma.com"> Open Roles </a> </li> </ul> </li> <li class=" menu-item menu-item-type-post_type menu-item-object-page menu-item-5161 is-single"> <a href="https://www.twosigma.com/contact-us/" class="link--is-single" > Contact Us </a> </li> <li class="js-modal-last menu-item menu-item-type-post_type menu-item-object-page menu-item-5019 is-single"> <a href="https://www.twosigma.com/investors/" class="link--is-single" > Investor Hub </a> </li> </ul> </div> </div> </header> <main id="main-content" class="main-content" data-js-component="ScrollFx"> <section class="pageHeader pageHeader--light page" data-scroll-fx> <div class="content"> <h1 class="h2"> Privacy Policies </h1> </div> </section> <section class="page legalDisclosure ld" data-js-component="LegalDisclosure"> <div class="content"> <div class="basic-body article-body ld-selectors-container"> <div class="ld-selectors"> <div> <select name="entity-selector" class="entity-selector js-entity-selector"> <option value="">Select an Entity</option> <option value="two-sigma-investments-lp">Two Sigma Investments, LP</option> <option value="two-sigma-securities">Two Sigma Securities</option> <option value="two-sigma-ventures-lp">Two Sigma Ventures, LP</option> <option value="tspi-lp">TSPI, LP</option> <option value="sightway-capital">Sightway Capital</option> <option value="alphastudio">AlphaStudio</option> <option value="real-estate">Real Estate</option> </select> </div> <div> <select data-entity="two-sigma-investments-lp" class="disclosure-selector js-disclosure-selector"> <option value="">Select a Disclosure</option> <option value="privacy-policy">Privacy Policy</option> <option value="cookie-policy">Cookie Policy</option> </select> <select data-entity="two-sigma-securities" class="disclosure-selector js-disclosure-selector"> <option value="">Select a Disclosure</option> <option value="privacy-policy">Privacy Policy</option> </select> <select data-entity="two-sigma-ventures-lp" class="disclosure-selector js-disclosure-selector"> <option value="">Select a Disclosure</option> <option value="privacy-policy">Privacy Policy</option> </select> <select data-entity="tspi-lp" class="disclosure-selector js-disclosure-selector"> <option value="">Select a Disclosure</option> <option value="privacy-policy">Privacy Policy</option> </select> <select data-entity="sightway-capital" class="disclosure-selector js-disclosure-selector"> <option value="">Select a Disclosure</option> <option value="privacy-policy">Privacy Policy</option> <option value="cookie-policy">Cookie Policy</option> </select> <select data-entity="alphastudio" class="disclosure-selector js-disclosure-selector"> <option value="">Select a Disclosure</option> <option value="privacy-policy">Privacy Policy</option> </select> <select data-entity="real-estate" class="disclosure-selector js-disclosure-selector"> <option value="">Select a Disclosure</option> <option value="privacy-policy">Privacy Policy</option> </select> </div> </div> </div> <article data-entity="two-sigma-investments-lp" class="ld-entity"> <section data-ld="privacy-policy" class="article-body basic-body ld-section"> <div class="ld-section-container"> Updated and Effective Date: June 28, 2023 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”) or other platforms that direct to this Privacy Policy. This Privacy Policy does not apply to websites or platforms where a different privacy policy is posted or 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. <h2>WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.</h2> 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. <h3>Personal Identifiers:</h3> 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. <h3>Commercial Information:</h3> 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. <h3>Communications:</h3> 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. <h3>Professional or Employment Information:</h3> 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. <h3>Educational Information:</h3> 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. <h3>Internet or Other Electronic Network Activity:</h3> 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, <a href="https://www.twosigma.com/legal-disclosure/cookies-policy/">here</a>. <h3>Geolocation Information:</h3> 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. <h3>Aggregate information.</h3> 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. <h2>WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.</h2> 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: <h3>Responding to Requests:</h3> 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. <h3>Provide you with Services and Improve the Site:</h3> 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. <h3>Security and Fraud Prevention and Detection:</h3> 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. <h3>Compliance with Laws and to Protect Ourselves:</h3> 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. <h3>Recruiting and Marketing:</h3> 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. <h3>Communications:</h3> 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. <h3>Debug and Identify Errors:</h3> We use your personal information to debug and identify and repair errors that impair existing intended functionality. <h3>Statistical Analysis and Research:</h3> 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. <h2>WE MAY SHARE PERSONAL INFORMATION WITH THIRD PARTIES.</h2> 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. <h3>Two Sigma Companies:</h3> We may share your personal information within the Two Sigma family of companies. <h3>To Respond to Your Requests:</h3> 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. <h3>Service Providers:</h3> 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. <h3>Comply with the Law:</h3> 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. <h3>Business Successors:</h3> 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. <h3>Business Transfers:</h3> 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. <h3>Information You Elect to Share:</h3> 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. <h3>Information We Share With Your Consent:</h3> 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. <h2>YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING TOOLS</h2> 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. <h2>RIGHTS FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM</h2> 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 <a href="mailto:GDPR@twosigma.com">GDPR@twosigma.com</a>. 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 <a href="mailto:GDPR@twosigma.com">GDPR@twosigma.com</a>. 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: <a href="mailto:eurorep@leo.tech">eurorep@leo.tech</a>; 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. <h2>RIGHTS FOR INDIVIDUALS IN CALIFORNIA</h2> 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. A. 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). B. 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): <ul> <li>Our or our service providers’ operational purposes;</li> <li>Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;</li> <li>Bug detection and error reporting;</li> <li>Customizing content that we or our service providers display on the Services;</li> <li>Providing the Services (e.g., maintaining our Sites and communicating with you about programs and products);</li> <li>Improving our existing Services and developing new services (e.g., by conducting research and analysis to develop new products or features);</li> <li>Evaluating job applicants, individuals, and/or business opportunities;</li> <li>Onboarding and paying contractors;</li> <li>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</li> <li>Other uses about which we notify you.</li> </ul> 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. C. 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. D. 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: <ul> <li>Request that we disclose information about the personal information that we have collected, used, disclosed or sold,</li> <li>Request access to a copy of the personal information we maintain about you;</li> <li>Request correction of inaccurate personal information;</li> <li>Request that we delete personal information collected from you; and</li> <li>Not receive discriminatory treatment for exercising your privacy rights.</li> </ul> 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 <a href="mailto:CCPA@twosigma.com">CCPA@twosigma.com</a>. If you require this notice in an alternative accessible format, please email us at <a href="mailto:CCPA@twosigma.com">CCPA@twosigma.com</a>. 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 <a href="mailto:CCPA@twosigma.com">CCPA@twosigma.com</a>; (ii) contact us at the toll-free telephone number <a href="tel:+18448206577">1-844-820-6577</a>; or (iii) submit a webform request <a href="https://www.twosigma.com/legal-disclosure/privacy-policy/privacy-contact-request-form/">here</a>. E. 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. F. 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. <h2>TWO SIGMA SITES AND CHILDREN</h2> 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 <a href="http://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online">here</a>. <h2>WE USE STANDARD SECURITY MEASURES</h2> 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. <h2>WE STORE PERSONAL INFORMATION IN THE UNITED STATES</h2> 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 <a href="mailto:GDPR@twosigma.com">GDPR@twosigma.com</a>, it will impact your ability to use our Sites. <h2>WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITES WE DON’T CONTROL</h2> 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). <h2>reCAPTCHA</h2> 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: <a href="https://www.google.com/intl/de/policies/privacy/">https://www.google.com/intl/en/policies/privacy/ </a> 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. <h2>FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS</h2> 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. </div> </section> <section data-ld="cookie-policy" class="article-body basic-body ld-section"> <div class="ld-section-container"> Effective Date: August 15, 2017 THIS COOKIE POLICY APPLIES TO OUR WEBSITES AND PLATFORMS Cookies This Policy describes how Two Sigma Investments, LP and its affiliates (“Two Sigma”, “we”, or “us”) uses cookies on our websites and platforms (each a “Site”). To make our Site(s) work properly, we sometimes place small data files (called cookies) on your 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 <a href="https://www.aboutcookies.org/">aboutcookies.org</a>. What types of cookies do we use? We use two types of cookies on the Site(s): session cookies and persistent cookies. A session cookie is a temporary cookie that remains on your device until you leave the Site(s). Session cookies are essential to make our Site(s) work correctly, as they enable you to move around our Site(s) 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(s) so it’s easier and convenient to return to and interact with our Site(s). In addition, persistent cookies also help us recognize and record information about your web browsing habits during the lifetime of the persistent cookie. What are cookies used for? We use cookies on our Site(s) to personalize your experience on the Site(s) and to make your future activities and experience on our Site(s) 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(s), and to help us improve the structure and content of the Site(s). The cookie-related information is not used to identify you personally. What third-party cookies do we use? We may also work with third-party service providers who may set cookies on our Site(s). These third-party service providers help us track and analyze your use of our Site(s) and to optimize our Site(s) and improve your experience. These third-party service providers are responsible for the cookies they set on our Site(s). If you want further information please go to the website for the relevant third-party service provider. For additional information regarding Google Analytics, please visit: <a href="https://analytics.google.com/">analytics.google.com.</a> How to control cookies? You can control and/or delete cookies as you wish, for details see <a href="https://analytics.google.com/">analytics.google.com</a>. 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(s) and functionalities may not work. </div> </section> </article> <article data-entity="two-sigma-securities" class="ld-entity"> <section data-ld="privacy-policy" class="article-body basic-body ld-section"> <div class="ld-section-container"> 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, <a href="https://www.twosigma.com/legal-disclosure/cookies-policy/">here</a>. 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 <a href="mailto:GDPR@twosigma.com">GDPR@twosigma.com</a>. 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 <a href="mailto:GDPR@twosigma.com">GDPR@twosigma.com</a>. 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: <ul> <li>Request that we disclose information about the personal information collected, used, disclosed or sold;</li> <li>Request that we delete personal information collected or maintained by us;</li> <li>Opt out of the sale of your personal information; and</li> <li>Not receive discriminatory treatment for exercising your privacy rights.</li> </ul> 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 <a href="mailto:CCPA@twosigma.com">CCPA@twosigma.com</a>. If you require this notice in an alternative accessible format, please email us at <a href="mailto:CCPA@twosigma.com">CCPA@twosigma.com</a>. 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: <ul> <li>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;</li> <li>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;</li> <li>The likelihood that fraudulent or malicious actors would seek the personal information. The higher the likelihood, the more stringent the verification process will be;</li> <li>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;</li> <li>The manner in which the business interacts with the consumer; and</li> <li>Available technology for verification.</li> </ul> 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 <a href="mailto:CCPA@twosigma.com">CCPA@twosigma.com</a>; (ii) contact us at the toll-free telephone number 1-844-820-6577; or (iii) submit a webform request <a href="https://www.twosigma.com/legal-disclosure/privacy-policy/privacy-contact-request-form/">here</a>. 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 <a href="http://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online">here</a>. 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: <a href="https://www.google.com/intl/de/policies/privacy/">https://www.google.com/intl/en/policies/privacy/ </a> 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. </div> </section> </article> <article data-entity="two-sigma-ventures-lp" class="ld-entity"> <section data-ld="privacy-policy" class="article-body basic-body ld-section"> <div class="ld-section-container"> Updated and Effective Date: June 13, 2022 This Privacy Policy describes how Two Sigma Ventures, LP (“Two Sigma Ventures”, “we”, “our” or “us”) treats personal information, including personal information collected on www.twosigmaventures.com where this Privacy Policy is located (the “Site”). This policy covers our treatment of any third party personal information that you share with us or that we share with our business partners. 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 Ventures affiliates. In addition, this Privacy Policy does not apply to customers or consumers of Two Sigma Ventures or its affiliates financial services or products (including, but not limited to, any investment managed by Two Sigma Ventures) with respect to your use of such financial services or products. When you use this site, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your personal information described in this Policy and in accordance with applicable law. 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, third party licensed data, from third parties (including 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 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 and any other information that you provide to us voluntarily. We also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. We use and share this information as noted below. Commercial Information: We 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. We also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. 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 also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. 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 also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools 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 also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools 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 also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. Learn more about these tools and how you can manage them, by visiting our Cookies Policy, <a href="https://www.twosigma.com/legal-disclosure/cookies-policy/">here</a>. 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 also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. 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 from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. We use and share this information as noted below. 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. 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 Ventures. For example, we might send you information about Two Sigma Ventures 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. Business or Commercial Purposes: We may use your personal information for business or commercial purpose including statistical research and analysis of third party licensed data. 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 Two Sigma Ventures 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. 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. 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 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: 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: <ul> <li>Request that we disclose information about the personal information collected, used, disclosed or sold;</li> <li>Request that we delete personal information collected or maintained by us;</li> <li>Opt out of the sale of your personal information; and</li> <li>Not receive discriminatory treatment for exercising your privacy rights.</li> </ul> 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: <ul> <li>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;</li> <li>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;</li> <li>The likelihood that fraudulent or malicious actors would seek the personal information. The higher the likelihood, the more stringent the verification process will be;</li> <li>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;</li> <li>The manner in which the business interacts with the consumer; and</li> <li>Available technology for verification.</li> </ul> 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 <a href="https://www.twosigma.com/legal-disclosure/privacy-policy/privacy-contact-request-form/">here</a>. Shine the Light Inquiry 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. 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 <a href="http://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online">here</a>. WE USE STANDARD SECURITY MEASURES We take reasonable steps, including technical, administrative and physical safeguards to protect the personal information submitted to us. However, no method of security is entirely secure. 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. 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. 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: <a href="https://www.google.com/intl/de/policies/privacy/">https://www.google.com/intl/en/policies/privacy/</a> <a href="https://www.google.com/intl/de/policies/privacy/"></a> 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 Ventures, 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. </div> </section> </article> <article data-entity="tspi-lp" class="ld-entity"> <section data-ld="privacy-policy" class="article-body basic-body ld-section"> <div class="ld-section-container"> 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: <a href="https://www.google.com/intl/en/policies/privacy/">https://www.google.com/intl/en/policies/privacy/</a> 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. </div> </section> </article> <article data-entity="sightway-capital" class="ld-entity"> <section data-ld="privacy-policy" class="article-body basic-body ld-section"> <div class="ld-section-container"> 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 <a href="mailto:GDPR@twosigma.com">GDPR@twosigma.com</a>. 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 <a href="mailto:info@eurorep.eu">info@eurorep.eu</a>; 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: <ul> <li>Request that we disclose information about the personal information collected, used, disclosed or sold;</li> <li>Request that we delete personal information collected or maintained by us;</li> <li>Opt out of the sale of your personal information; and</li> <li>Not receive discriminatory treatment for exercising your privacy rights.</li> </ul> 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: <ul> <li>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;</li> <li>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;</li> <li>The likelihood that fraudulent or malicious actors would seek the personal information. The higher the likelihood, the more stringent the verification process will be;</li> <li>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;</li> <li>The manner in which the business interacts with the consumer; and</li> <li>Available technology for verification.</li> </ul> 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 <a href="https://www.twosigma.com/legal-disclosure/privacy-policy/privacy-contact-request-form/" target="_blank" rel="noopener">here</a>. 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 <a href="http://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online" target="_blank" rel="noopener">here</a>. 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. </div> </section> <section data-ld="cookie-policy" class="article-body basic-body ld-section"> <div class="ld-section-container"> 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 <a href="https://www.aboutcookies.org/">aboutcookies.org</a>. 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 <a href="https://www.aboutcookies.org/">aboutcookies.org</a>. 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 <a href="mailto:Legal@twosigma.com">Legal@twosigma.com</a>. © 2020 TSPI, LP. All rights reserved. </div> </section> </article> <article data-entity="alphastudio" class="ld-entity"> <section data-ld="privacy-policy" class="article-body basic-body ld-section"> <div class="ld-section-container"> Effective Date: June 28, 2023 AlphaStudio Privacy Policy This Policy describes how Two Sigma Investments, LP and its affiliates (“Two Sigma”, “We”, “we”, or “us”) treats personal information collected on this Website and Platform (the “Site” and the “Platform”) and the services, features, content or applications we offer including from offline activities and third parties (together with Site and Platform, “Services”). 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”) that you elect to access through the 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 that you choose to access. WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU IN DIFFERENT WAYS. We collect the following categories of Personal Information from our users in different ways including from you directly, from you passively through your use of the Services and from third parties. Personal Identifiers: We collect personal identifiers such as contact information. For example, we might collect your name, company name, address, phone number, username or identifier, domicile and email when you use or download our products and services including on the Site and the Platform. We also collect user profile information such as username or other identifiers. We collect this information from various sources including from you directly; through your use of our Services (including the Site and Platform) and from third parties including cloud and data analytics tool providers (e.g., Google’s BigQuery), productivity and collaboration tool providers, recruiting platforms and recruiting events, online platforms including professional and social networks and forums, financial institutions and referrals. We use and share this information as noted in the sections below. Professional or Employment Information: We collect information related to your professional background and employment information such as professional experience, current and previous employers, professional associations, social media professional profile, ability to work in location, contract information and sources of this information. We also collect information related to our engagement with you such as contract related information and disclosure questionnaires. We collect this information from various sources including from you directly; through your use of our Services (including the Site and Platform) and from third parties including cloud and data analytics tool providers (e.g., Google’s BigQuery), productivity and collaboration tool providers, recruiting platforms and recruiting events, online platforms including professional and social networks and forums and referrals. We use and share this information as noted in the sections below. Educational Information: We collect information related to your educational background such as schools attended, awards and credentials. We collect this information from various sources including from you directly; through your use of our Services (including the Site and Platform) and from third parties including cloud and data analytics tool providers (e.g., Google’s BigQuery), productivity and collaboration tool providers, recruiting platforms and recruiting events, online platforms including professional and social networks and forums and referrals. We use and share this information as noted in the sections below. Financial Information: We collect information such as account information and associated information such as name, email address, phone number that allows us to facilitate processing of payments and for tax purposes. We collect this information from various sources including from you directly and from financial institutions. We use and share this information as noted in the sections below. Internet or Electronic Network Activity: We collect information you email, submit or post via the Site and the Platform. We collect information when you contact us using the email address provided on the Site or through any other communication method available through the Site. We collect other information passively about your usage on the Site and the Platform. We may collect usage data on how you use the Site and the Platform, how frequently you access the Site and how long you stay on the Site or Platform through the use of tracking tools such as cookies or other commonly used technologies (e.g., web beacons). Learn more about these tools and how you can control them, <a href="https://www.twosigma.com/legal-disclosure/cookies-policy/">here</a>. This may include the programming language used for each cell you execute and what types of file formats you use when loading notebooks and other related usage of the notebooks. We may also collect information about your browser, device type, your IP address, etc. that contains personal information about you. We might look at what site you came from, or what site you visit when you leave the Site or Platform. Third party analytics services may use cookies and web beacons through our Site to provide us with information about how you use and interact with our Site. Cookies allow us to recognize you when you return so you will not be required to register again for use of the same, and they track your use of the Site and/or any such capability, software or service. They are also used for security reasons and help us to detect certain kinds of fraud. We collect personal information as otherwise described at the time of collection on the Site and Platform. We collect this information from your use of our Services (including the Site and Platform) and from third parties including cloud and data analytics tool providers (e.g., Google’s BigQuery) and productivity and collaboration tool providers. We use and share this information as noted in the sections below. Geolocation Information: We collect location information such as your IP address. We collect this information from your use of our Services (including the Site and Platform) and from third parties including cloud and data analytics tool providers (e.g., Google’s BigQuery) and productivity and collaboration tool providers. We use and share this information as noted in the sections below. WE USE PERSONAL INFORMATION AS DISCLOSED AND DESCRIBED HERE. The collection and processing of personal information about you may be necessary for the performance of any contractual relationship with you, where we have a legitimate interest and for business or commercial purposes. For each of the personal information categories listed above, we use your personal information to carry out the following purposes. Contact you and respond to your requests: We use personal information to contact you and respond to your requests or questions. For example, we might use your information to respond to your questions about the Site or Platform or assist you while you use the Site or Platform. We use personal information to communicate with you about our relationship. We may contact you about your use of our goods and services. We might also contact you about this Policy or our Site terms. To provide you with Services: We use personal information to provide you with services or facilitate your participation in the program. Improving Site and Platform: We use personal information to operate, maintain or improve the Site and any capability, software or service that may be made available through the Site or our business. We might use your personal information to provide the Site and Platform to you and/or customize your experience when you visit the Site and Platform. We may use your personal information for our internal purposes, including to analyze or improve the Site. We may do this by looking at site trends or user interests. Fraud Prevention and Detection: We may use your personal information for security. We may use personal information to protect our company, affiliates, our customers, or our website, or a third-party website or platform or for fraud prevention and detection. To ensure data is protected from misuse, we use various techniques to monitor your Site sessions. You should assume everything you do on the Site is audited and monitored closely. 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. Marketing: We use personal information for marketing purposes. For example, we might send you information about professional opportunities that we believe you may be interested in. These might be our own offerings, or third party offerings we think you might find interesting. Selection and Business Opportunities: We use your personal information to contact you and consider and evaluate you for employment or business opportunities. Payment Processing: We use your personal information for payment processing and tax purposes. Debug and Identify Errors: We use your personal information to debug and identify and repair errors that impair existing intended functionality. Internal Statistical Analysis: We use your personal information for internal recordkeeping and statistical analysis and research. We use personal information as otherwise described or permitted by law, for any other purpose as described in this Policy. WE SHARE PERSONAL INFORMATION AS DISCLOSED AND DESCRIBED HERE. 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 of the personal information categories listed above, we may share this information with third parties and affiliates for business or commercial purposes. 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, for example, cloud and data analytics tool providers (e.g., Google’s BigQuery) and productivity and collaboration tool providers. 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). 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. Aggregate 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. 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. YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING AND TRACKING 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. You can control cookies and tracking tools. Your browser may give you the ability to control cookies. How you do so depends on the type of cookie. Certain browsers can be set to reject browser cookies. To control flash cookies, which we may use on certain websites from time to time, you can go <a href="http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager07.html">here</a>. Why? Because flash cookies cannot be controlled through your browser settings. If you block cookies on your browser, you may no longer be able to access the Site or certain features on our sites may not work. Options you select are browser and device specific. And, if you block or delete cookies, not all of the tracking that we have described in this policy will stop. Do Not Track. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are not currently set up to respond to those signals. RIGHTS FOR INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA AND UNITED KINGDOM. Individuals who are located in or a resident of countries in the European Economic Area (“EEA”) and the United Kingdom (“UK”) have certain data subject rights pertaining to personal data as defined under European law and which 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 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 for your personal information collected when you are using or access the Site and Platform. 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, and 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 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. RIGHTS FOR INDIVIDUALS IN 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. A. 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). B. 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): <ul> <li>Our or our service providers’ operational purposes;</li> <li>Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;</li> <li>Bug detection and error reporting;</li> <li>Customizing content that we or our service providers display on the Services;</li> <li>Providing the Services (e.g., maintaining our Sites and communicating with you about programs and products);</li> <li>Improving our existing Services and developing new services (e.g., by conducting research and analysis to develop new products or features);</li> <li>Evaluating job applicants, individuals, and/or business opportunities;</li> <li>Onboarding and paying contractors;</li> <li>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</li> <li>Other uses about which we notify you.</li> </ul> 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. C. 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. D. 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: <ul> <li>Request that we disclose information about the personal information that we have collected, used, disclosed or sold,</li> <li>Request access to a copy of the personal information we maintain about you;</li> <li>Request correction of inaccurate personal information;</li> <li>Request that we delete personal information collected from you; and</li> <li>Not receive discriminatory treatment for exercising your privacy rights.</li> </ul> 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 <a href="https://www.twosigma.com/legal-disclosure/privacy-policy/privacy-contact-request-form/">here</a>. E. 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. F. 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. WE STORE PERSONAL INFORMATION IN THE UNITED STATES OR OTHER COUNTRIES. The Site and Platform are controlled and operated by us from the U.S. and we use third parties providers to support the Site and Platform and perform the Services. As a result, personal information that we collect about you or that you provide to us while using the Site and Platform will be transferred and hosted in the U.S. or other countries which does not provide a similar level of protection to that provided by the countries in the EEA. By using the Site and Platform, you consent to the transfer of your personal information outside of the EEA. You acknowledge that if you do not consent or withdraw your consent by sending an email to <a href="mailto:GDPR@twosigma.com">GDPR@twosigma.com</a> to such transfer it may impact your ability to use the Services. THIS SITE AND CHILDREN. Our site is meant for adults. We do not knowingly collect personally identifiable 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 information, you can write to us at the address listed at the end of this policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line <a href="https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online">here</a>. WE USE STANDARD SECURITY MEASURES. 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 cannot promise that your use of our Site, Platform or software will be completely safe. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We encourage you to use caution when using the Internet. We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law or for internal compliance or record-keeping purposes. WE MAY LINK TO OTHER SITES OR HAVE THIRD PARTY SERVICES ON OUR SITE WE DON’T CONTROL. If you click on a link to a third party site, you will be taken to websites we do not control. This Policy does not apply to the privacy practices of that website. 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 these third party sites. FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS. If you have any questions about this 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: AlphaStudio Privacy Matters WE MAY UPDATE THIS POLICY. From time to time we may change our privacy policies. We will notify you of any material changes to our Policy as required by law by means of posting an announcement on the Site or sending you an email. 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 Policy when you use the Site after such changes have been first posted. </div> </section> </article> <article data-entity="real-estate" class="ld-entity"> <section data-ld="privacy-policy" class="article-body basic-body ld-section"> <div class="ld-section-container"> 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: <a href="https://www.google.com/intl/en/policies/privacy/">https://www.google.com/intl/en/policies/privacy/</a> 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. 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