Effective Date: December 31, 2019

THIS PRIVACY POLICY APPLIES TO THE VENN PLATFORM AND VENN MARKETING SITE.

This Privacy Policy describes how Two Sigma Investor Solutions, LP (“Two Sigma”, “we”, “our” or “us”) treat
personal information collected on the VennTM Platform (the “Platform”) and any other web sites on which these
terms reside (collectively, the “Site”). This Privacy Policy also covers our treatment of any personal information
that our business partners share with us or that we share with our business partners. When you use the Platform
or the Site, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your
personal information described in this Privacy Policy and in accordance with applicable law.

This Privacy Policy does not apply to the practices of all Two Sigma affiliates, which are governed by their own
posted privacy policies, or the practices of any third party sites or services that may be linked to from our Platform
or Site.

WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

We collect contact and Account (defined below) information. If your employer registers for the Platform, your employer may provide us information that could be your personal information, such as your name, email address and work title. If you register through a user account (an “Account”), you will also provide information that could be personal information, such as your username, password, email address and other information requested on our registration page. You acknowledge that by creating an Account on the Platform and providing personal information to us, you allow us to identify you and therefore you may not remain anonymous to us. Where we require your personal information to comply with our contractual obligations, failure to provide such personal information means that we may not be able to maintain your Account and continue our relationship with you.


We collect information you email or otherwise submit. We collect information when you contact us using the email address provided on the Site or the Platform or through any other communication method available through the Site or the Platform. Some features of the Site and Platform allow you to provide content or subscribe to certain communications, and we collect all content and information you submit to the Site and Platform. This may contain personal information about you. We may receive a confirmation when you open an email from us.


We collect other information about your usage of the Site and Platform. We may also collect usage data on how you use our Site and Platform, how frequently you access the Site and Platform and how long you stay on the Site and Platform through the use of cookies or other commonly used technologies (e.g. web beacons). This may include information about your browser, device type, IP address, etc. and contain personal information about you.
Aggregate information. We collect statistical information about how users use the Site and Platform (“Aggregate Information”), some of which is derived from personal information but is not itself personal information.
No Children’s information. The Site and Platform are meant for adults. We do not knowingly collect personal information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us personal information, please contact us at the address below and mark your inquiries “Legal / COPPA Information Request.” Parents and guardians may learn more about how to protect children's privacy on-line here.

WE COLLECT INFORMATION IN DIFFERENT WAYS.

We collect information directly from you. For example, if you create an Account, use the Platform or the Site, upload content on the Platform or the Site, subscribe to the Site, send us an email or otherwise communicate with us through the Platform or the Site.


We collect information from you passively. We use tracking tools like browser cookies and web beacons to provide and support our Site and Platform and each of the uses outlined in this Privacy Policy. Learn more about these tools and how you can manage them, by visiting our Cookie Policy, here. In addition, Two Sigma, and Two Sigma’s third party service providers on its behalf, may use the information you provide to conduct analytics to help us better understand our customers and improve our services.

We may collect information about you from third parties. For example, our business partners or vendors, or your employer or one of its service providers, may give us personal information about you. We may combine this information with information that you give us via the Site or the Platform.

We may collect information about you from publicly available sources. For example, we may collect information about your use or interactions with public social media sites or other public postings.
We may collect personal information as otherwise described at the time of collection on the Site or Platform.

WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.

We may collect and process your personal information for the following purposes:


Purpose

Legal Ground

We use personal information about you to respond to your requests or questions. For example, we might use your personal information to respond to your questions about the Site or Platform or assist you while you use the Site or Platform.

We have a legitimate interest to respond to your requests and questions for ongoing business administration.

We use personal information about you to provide and improve the Site and Platform. We might use your personal information to provide and maintain the Site and Platform and/or personalize your visit to the Site and Platform. We may use your personal information for our internal purposes, including to analyze and improve the Site and Platform.

We have a legitimate interest to manage our relationship with you and ensure the Site and Platform are effective and efficient. 

We use personal information for security and compliance purposes. We may use personal information to enforce our rights, for fraud prevention, to comply with applicable laws and regulations, or to protect our company, affiliates, our customers, or our websites, or a third-party website or platform.

To comply with our legal obligations.

We use personal information to inform you about Two Sigma. For example, we might send you information about us and our affiliates, and what we offer. We might tell you about new features or updates.

We have a legitimate interest to manage our business and where required by applicable law, where we have received your consent. 

We use personal information to communicate with you about your Account or our relationship. We may contact you about your use of our Site or Platform. We may contact you about your Account or feedback. We might also contact you about this Privacy Policy, the Site’s Terms of Use, or the Platform’s End User License Agreement or Subscriber Agreement.

We have a legitimate interest to manage our business and it may also be necessary for the performance of our contractual relationship with you. 

We use personal information for business administration. We may use your personal information for our general business administration, including statistical analysis.

We have a legitimate interest to properly manage and administer our relationship with you and to ensure that we are effective and efficient. 

 

We may 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 and for which, where required by applicable law, we have obtained your consent.

WE MAY SHARE INFORMATION WITH THIRD PARTIES.

We may share your personal information with Two Sigma affiliates.

We may share your personal information to respond to your requests or questions. For example, we might share your personal information with third parties in order to provide you with services requested by you or answer your questions, including with third parties that you intentionally interact with through our services.

We will share personal information with third parties who perform services on our behalf. For example, we share personal information with our vendors (e.g., IT services providers, cloud storage providers and other companies that help us operate and improve the Site or Platform), partners and consultants for the purposes outlined above.

We will share personal information if we think we have to in order to comply with the law or to protect ourselves. For example, we may share personal information to respond to a court order or subpoena. We may also share it if a government agency or investigatory body requests. We might also share personal information when we are investigating potential fraud or if we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others.

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

We may share Aggregate Information. We may share Aggregate Information with third parties, including vendors, partners and consultants, to better understand how and how often people use the Site and Platform and/or their services or websites. In addition, these third parties may share with us non-private, aggregated or otherwise non-personal information about you that they have independently developed or acquired.


We may share personal information for other reasons we may describe to you and for which, where required by applicable law, we have obtained your consent or as permitted by law.


YOU HAVE CERTAIN CHOICES ABOUT OUR MARKETING TOOLS.


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

DELETING YOUR ACCOUNT.

Should you ever desire to delete your Account, you may do so by submitting a written request to the address listed below. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account, unless otherwise specified by us. Please note that we will need to verify that you have the authority to delete the Account.

If you are a subscriber to our Site and decide to unsubscribe, you may do so by submitting a written request to the address listed below.


YOUR ACCESS TO INFORMATION.

If you are a registered user, you can access certain information associated with your Account by logging into the Platform. You may also ask us for a notice identifying the categories of personal information which we share with our affiliates and third parties for marketing purposes, and to provide contact information for such affiliates and third parties. If you would like a copy of this notice, please submit a written request to the address listed below.

RIGHTS FOR INDIVIDUALS IN THE EUROPEAN UNION

To the extent provided by applicable law, individuals who are located in or a resident of the European Union or the United Kingdom (“UK”) have certain data subject rights which may be subject to limitations and/or restrictions, including the right to access, rectify and, subject to our other legal obligations and business considerations, erase your personal information, and the right to ask us to restrict the purpose or to object to the processing of your personal information as well as a right to data portability.


To the extent provided by applicable law, please note that you have a right to object to processing of your personal data where that processing is carried out for our legitimate interest or for direct marketing.

You may have the right to lodge a complaint about the processing of your personal information with your local data protection authority.
If you wish to exercise any of your rights under this Privacy Policy, please send us your request via email to GDPR@twosigma.com or venn-legal@twosigma.com.
For the purposes of EU and UK data protection laws, we are the data controller of your personal information collected when you are using or accessing the Site or Platform. This means that we are responsible for, and control the processing of, your personal information. Our data protection representative for the EU in the UK is Two Sigma International Limited, and can be reached at GDPR@twosigma.com.

WE STORE PERSONAL INFORMATION IN THE UNITED STATES AND OTHER COUNTRIES.

Personal information we collect (including from individuals in the European Economic Area (“EEA”) and the UK) may be transferred to and stored within the United States or other countries which do not provide a similar level of protection to that provided by the jurisdiction in which you are located, including the countries in the EEA or UK. Our Site and Platform 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. When signing the End User License Agreement to access the Platform or accessing the Site and subjecting yourself to the Terms of Use, you gave your explicit consent to the transfer of your personal information outside the jurisdiction in which you are located, which is the basis for such transfer. You acknowledge that if you do not consent to such transfer, it may impact your ability to use the Site and Platform. You can withdraw your consent at any time by contacting GDPR@twosigma.com or venn-legal@twosigma.com.

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.

reCAPTCHA


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

WE USE STANDARD SECURITY MEASURES.

Your profile and registration information relating to your Account will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and personal information by selecting and protecting your password appropriately and limiting access to your computer and browser such as by signing off after you have finished accessing your Account.
We 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 or Platform 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 MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITE OR PLATFORM WE DON’T CONTROL.

If you click on a link to an unaffiliated 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).

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS.

If you have any questions about this Privacy Policy, including the use of service providers outside your jurisdiction of residence, or other privacy concerns, please contact us at 844-820-6577 or the General Manager of Venn at:
Two Sigma Investor Solutions, 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 means of posting an announcement on the Site and Platform or sending you an email. We will also post an updated copy on our Site and Platform. Please check our Site and Platform periodically for updates. You are bound by any changes to the Privacy Policy when you use the Site or Platform after such changes have been first posted.

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