Privacy Policy
Last Revised: June 28, 2023
This privacy policy (“Privacy Policy”) for Two Sigma Investor Solutions, LP (“Two Sigma”, “we”, “our” or “us”) describes how we collect, use, and disclose personal information about individuals who use our Platform (the “Platform”) and any other web sites on which this Privacy Policy resides, including Two Sigma’s marketing site (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. For the purposes of this Privacy Policy, “you” and “your” means you as a user of the Platform or Site.
Please read this Privacy Policy carefully. When you use the Platform or the Site, you are consenting to the collection, use, and disclosure of your personal information described in this Privacy Policy and in accordance with applicable law. If you do not agree to this Privacy Policy, please do not use or access the Site or Platform. If you are a user in the EEA/UK, the lawful basis upon which we rely under EU/UK data protection law is set out in HOW WE USE PERSONAL INFORMATION below.
If you are a resident of the State of California, this Privacy Policy is supplemented by our California Notice at Collection and Privacy Policy at the end of this document that explains certain California privacy rights and how affected parties can exercise these rights.
This Privacy Policy does not apply to:
- the practices of other 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,
- the data collection and processing practices of Two Sigma outside our Platform, or
- the processing of personal information by us as a processor. For the avoidance of doubt, we act as a processor where you upload personal information of your clients to the Platform, and we process such personal information on your instructions.
PERSONAL INFORMATION WE COLLECT ABOUT YOU AND THE SOURCES FROM WHICH WE COLLECT IT.
The personal information we collect about you and the sources from which we collect it will depend on our relationship with you and your interaction with our products and services. For example:
We collect information directly from you. We collect information from you directly, for example, if you register via the Platform through a user account (an “Account”). In that case you will provide us with personal information such as your name, mobile number, username, password, email address, company name, job title, and other information requested on our registration page (“Account Information”).
We may also collect personal information from you directly when you upload content on the Platform or the Site, subscribe to the Site or our blog, or 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 such content and information you submit (“Content Information”).
We may also collect questions or comments submitted by you through our customer support solutions (e.g., through live chat, automated chat, or otherwise). Please note that, when you contact us via one of our customer support solutions, we may make, receive, and retain recordings of such chats. By contacting us through these methods, you agree to our recording and retention of such information. To learn about the criteria we use to determine how long such information is retained, please see the section entitled “Retention of Personal Information” below.
We may receive information about you from third parties. For example, our business partners, affiliates, or vendors, or your employer or one of its service providers, may give us personal information about you when your employer registers for the Platform, such as, your name, phone number, email address and work title (“Contact Information”). We may combine this information with information that you give us via the Site or the Platform.
We collect personal information from you automatically. We may also collect data on how you use our Site and Platform, how and how frequently you access the Site and Platform and how long you stay on the Site and Platform (“Usage Information”) through the use of cookies or other tracking technologies (e.g., web beacons). This may include information about your browser, device type, IP address, etc. and contain personal information about you. For more information about our use of cookies and other tracking technologies, and the ways in which we may share that information with third parties, please see “We May Share That Information With Third Parties” below and our Cookie Policy.
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.
Site and Platform information. We collect information about how you visit and navigate the Site and Platform, including your IP address, browser settings, internet service provider information, referring/exit pages, operating systems, and date and time stamps, some of which is derived from personal information. We also collect statistical information about how you visit and navigate the Site and Platform (“Aggregate Information”).We may collect personal information as otherwise described at the time of collection on the Site or Platform.
HOW WE USE PERSONAL INFORMATION.
We may collect and process your personal information for the following purposes:
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Categories of Personal Information
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Processing Purpose |
Lawful Basis |
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Contact Information, Account Information, Content Information, and Usage Information |
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.
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We have a legitimate interest to respond to your requests and questions for ongoing business administration. We have a legal obligation where your request relates to, for example, the exercise of your rights (as detailed further below), or in relation to claims in relation to the Platform or Site (and the services provided to you thereunder). To the extent your request relates to the provision of our services to you under, for example, our Terms of Use, the Platform’s End User License Agreement or Subscription Agreement, our processing is necessary to conclude / perform such contract entered into with you. |
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Contact Information, Account Information, Content Information, and Usage Information |
We use personal information about you to provide the Site and Platform and administer your Account. We might use your personal information to provide and maintain the Site and Platform including to govern access to the Site and Platform, to manage your Account, and/or personalize your visit to the Site and Platform. |
We have a legitimate interest to manage our relationship with you, comply with our contractual obligations to you, and to ensure your experience on the Site and Platform are effective and efficient. The processing is necessary to conclude or perform a contract with you, for example, our Terms of Use, the Platform’s End User License Agreement or Subscription Agreement. |
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Contact Information, Account Information, Content Information, and Usage Information |
We use personal information about you to improve the Site and Platform. We may use your personal information for our internal purposes, including to analyze and improve the Site and Platform. This may include, for example, identifying usage trends.
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We have a legitimate interest in analyzing and improving the Platform and Site usability, since we understand that the processing of this data is also beneficial for you because the purpose is to improve the user experience and provide a higher quality service. |
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Contact Information, Account Information, Content Information, and Usage Information |
We use personal information for security purposes. We may use personal information to provide and increase safety and security on our Platform and Site (by preventing, detecting and implementing proper measures against e.g., misuse of our Platform and Site). |
We have a legitimate interest to ensure the Platform, Site and the services provided thereunder are safe and secure and are used in accordance with applicable terms. |
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Contact Information, Account Information, Content Information, and Usage Information |
We use personal information for compliance purposes. We may use personal information to defend / enforce our rights, in connection with investigations, for fraud prevention, or to protect our company, affiliates, our customers, or our Platform/Site, or a third-party website or platform or to comply with applicable laws or regulations. |
To comply with our legal obligations e.g., to respond to an official request. We have a legitimate interest to defend / enforce our rights and those of our customers and affiliates. |
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Contact Information, Account Information, Content Information, and Usage Information. |
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 send you marketing communications. Where required by law, we will ask for and rely on 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 email or contact us using the contact details below. You will not miss any service we provide by choosing not to receive marketing from us and you can change your mind whenever you like and as often as you like. Please note that your withdrawal of consent does not affect the lawfulness of our processing of your personal information based on consent before such withdrawal. |
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Contact Information, Account Information, Content Information, and Usage Information. |
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. |
The processing is necessary to conclude or perform a contract with you, for example, our Terms of Use, the Platform’s End User License Agreement or Subscription Agreement. |
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Contact Information, Account Information, Content Information, and Usage Information |
We use personal information for analytics and advertising purposes. We may use information we collect from you automatically, including personal information, such as IP address, device identifier and information about how you use the Site and Platform to analyze your activities, improve our services and enable targeted advertising. |
We have a legitimate interest to operate and improve our business. |
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Contact Information, Account Information, Content Information, and Usage Information |
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 operate, manage, improve and administer our business and to minimize any unintended disruption or risk thereto. |
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Contact Information, Account Information, Content Information, and Usage Information |
We use personal information in the context of due diligence. We may share your personal information with third parties to facilitate any due diligence for any actual or proposed merger, acquisition, reorganization, bankruptcy, financing transaction or joint venture contemplated by us or any affiliate. |
We have a legitimate interest to operate and improve our business. |
You have a right to object to the processing of your personal information where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfill this request in all instances. You are able to request a copy of the legitimate interest assessment carried out by us.
Where we need to collect the above mentioned categories of personal information by virtue of a legal obligation or in light of a contract entered or to be entered into with you, and if you do not provide this personal information when requested, we may not be able to comply with our legal obligations, provide you with a service or perform the contract we have or are trying to enter into with you or your employer. In such case, we may have to terminate our relationship with you or your employer.
In the situations in which we act as a controller, we will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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, live and automated chatbox provider, 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, or to comply with applicable laws or regulations.
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 your personal information for analytics and advertising purposes. We may share your personal information with third parties for analytics and advertising purposes, including those that we allow to place cookies and other tracking technologies on the Platform and our Site. Such third parties may include ad technology vendors, ad server and ad networks who may be allowed to receive certain information about you and your use of the Site and Platform and use the information for their own commercial purposes. Such information may be combined with information about your visits to, and activity on, other websites or applications to develop an understanding of your usage patterns and perceived interests and engage in analytics and targeted advertising.
We may share Aggregate Information or anonymized information. We may share Aggregate Information or anonymized 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, personal or 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 by you through your Account, unless otherwise specified by us. Please note that we may 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.
SPECIFIC INFORMATION FOR USERS IN THE EEA/UK.
Individuals who are located in countries in the European Economic Area (“EEA”) 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 processing or to object to the processing of your personal information as well as a right to data portability (i.e., to have your personal information be provided to a third party). You also have a right to withdraw your consent to the processing of your personal information at any time (where we are processing your personal information based on your consent).
You have the right to lodge a complaint about the processing of your personal information with a competent data protection authority.
If you wish to exercise any of your rights, 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 pursuant to this Privacy Policy 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.
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.
WE STORE PERSONAL INFORMATION IN THE UNITED STATES AND OTHER COUNTRIES.
Personal information we collect (including from individuals in the 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. 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 and the requirements of applicable privacy laws.
When accepting the Subscription Agreement, your employer to the extent located in the EEA/UK also entered into the Venn Data Transfer Addendum incorporating Standard Contractual Clauses with us, to legitimize the transfer of personal information. If you would like further information or a copy of the Standard Contractual Clauses, you can contact us at any time by contacting GDPR@twosigma.com.
CHILDREN’S PRIVACY.
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.
DATA SECURITY.
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, organizational, 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.
RETENTION OF PERSONAL INFORMATION.
We keep personal information for as long as it is necessary or relevant for the practices and purposes described in this Privacy Policy. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we process the personal information and whether we can achieve those purposes through other means. We also consider the applicable legal requirements and the extent to which it is necessary to process the personal information. In exceptional cases (e.g., in pending litigation matters or where the law requires us to), your personal information may need to be kept for longer periods of time.
WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITE OR PLATFORM WE DON’T CONTROL.
We may provide links to website or other online platforms operated by third parties. If you click on a link to an unaffiliated third party website, you will be taken to website(s) that we do not control, and you should review their privacy and security policies and other terms and conditions. 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). Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or their owners or operators.
FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS.
If you have any questions about our privacy practices or this Privacy Policy, including the use of service providers outside your jurisdiction of residence please contact us at 844-820-6577 or the Legal Department of Two Sigma 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.
We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. We will notify you of any material changes to our Privacy Policy as required by law such as by posting an announcement on the Site and Platform or sending you an email. We will also post an updated version on our Site and Platform. Please check our Site and Platform periodically for updates to this Privacy Policy. You are bound by any changes to the Privacy Policy when you use the Site or Platform after such changes have been first posted. If you do not agree with any updates to this Privacy Policy, please do not access or continue to use the Site or Platform.
California Notice at Collection and Privacy Notice
Last revised: June 28, 2023
Click here to download a copy of our California Notice at Collection and Privacy Notice.
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