Updated and Effective Date: March 13, 2023
WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.
We may collect the following categories of personal information in different ways including from you directly, 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. The categories of personal information we have collected from individuals on the Platform over the last twelve (12) months include the following:
Personal Identifiers: We collect your name, address, phone number, username, email address and other information you provide when you use the “Contact Us” or other features on the Platform.
We may also collect this information from other sources including service partners and providers. We use and disclose this information as noted below.
Commercial Information: We may collect commercial information 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 disclose this information as noted below.
We also collect this information from other sources including employers, collaboration tool providers, service partners and providers.
Communications: We collect information you email, submit, or post. We collect information when you contact us using the email address provided on the Platform. This may contain personal information about you such as personal identifiers and professional or employment information.
Professional or Employment Information: When you use features on the Platform, we may collect professional and employment information such as information about your employers, and sector.
Internet or Other Electronic Network Activity: We collect internet and other electronic information such as usage data on how you use our Platform and how long you stay on the Platform 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.
Learn more about these tools and how you can manage them, by visiting our Cookies Policy, here.
Geolocation Information: We collect your IP address when you use the Platform and from our services providers. We collect this information through your use of the Platform.
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 respond to your request for additional information.
Provide you with Services and Improve the Platform: 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 Platform and/or customize your experience with us. For example, we may use your personal information to improve the Platform, 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 disclose 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, reputation, and property, or the rights, property or safety of others.
Marketing: We use personal information to inform you about us. For example, we might send you information about us and what we offer. We might tell you about new features or updates.
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 to improve or modify the Platform.
WE MAY DISCLOSE PERSONAL INFORMATION WITH THIRD PARTIES.
We may collect and disclose personal information about you from third parties. For example, our business partners,. We may combine this information with information that you give us via the Platform.
For each of the personal information categories listed above, within the last twelve (12) month we have disclosed, and may disclose this information with the following third parties for business or commercial purposes.
Two Sigma Companies: We may disclose 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 disclose your personal information with third parties in order to provide you with services requested by you or answer your questions.
Service Providers: We will disclose personal information with third parties who perform services on our behalf. For example, we disclose personal information with our vendors (e.g., IT services providers, cloud providers, online platforms, partners and consultants. We may also disclose personal information with companies that assist us in providing the Platform, and any tools or services on the Platform.
Comply with the Law: We will disclose 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 disclose 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 disclose 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 Impact or part of its business (or in anticipation of such an event) we may disclose 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.
Aggregate Information: We may de-identify and aggregate the personal information we receive about you. Once deidentified and/or aggregated, we may disclose this de-identified and aggregated information with third parties, including vendors, partners and consultants, to further our internal business purposes and/or their services or websites.
Information We Disclose With Your Consent: We will also disclose your personal information in the manner that you authorize us to.
We may disclose 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 Platform 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.
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: firstname.lastname@example.org; 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.
CALIFORNIA CONSUMER PRIVACY ACT RIGHTS FOR INDIVIDUALS IN CALIFORNIA
In addition to the personal information we collect for you described in the “We Collect Personal Information From and About You” section above, we may also collect Sensitive Personal Information, including account log-in in combination with any required security or access code password, or credentials allowing access to an account. We do not collect or use sensitive personal information other than:
- To perform services, or provide goods, as would reasonably be expected by an average consumer who requests those goods or services;
- As reasonably necessary and proportionate to detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of stored or transmitted personal information;
- As reasonably necessary and proportionate to resist malicious, deceptive, fraudulent, or illegal actions directed at us and to prosecute those responsible for such actions;
- For short-term, transient use (but not in a manner that discloses such information to another third party or is used to build a profile of you or otherwise alter your experience outside of your current interaction with us);
- To perform services on behalf of our business;
- To verify or maintain the quality or safety of a service or to improve, upgrade, or enhance such service or device; and
- To collect or process sensitive personal information where such collection or processing is not for the purpose of inferring characteristics about a consumer.
We retain this information and categories of personal information set forth above in the “We Collect Personal Information From and About You” section only as long as is reasonably necessary for those purposes set forth above in the “We Use Information As Disclosed and Described Here” section, except as may be required under applicable law, court order or government regulations.
Individuals who are residents of California have certain consumer rights under the CCPA. Specifically, under California law you may have the right to:
- Request that we disclose information about the personal information collected, used, disclosed or sold/shared;
- Request that we delete personal information collected or maintained by us;
- Request that we correct any inaccuracies in the personal information with retain;
- Not receive discriminatory treatment for exercising your privacy rights.
Please note that we do not, and will not, sell or share 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.
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 or correct, 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, correct or 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.
Shine the Light Inquiry
If you reside in California, you have the right to ask us one time each year if we have disclosed 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.
OUR SITES AND CHILDREN
Our Sites are meant for adults. We do not knowingly collect personal information from children under 18 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 STORE PERSONAL INFORMATION IN THE UNITED STATES
WE MAY LINK TO OTHER WEBSITES OR HAVE THIRD PARTY SERVICES ON OUR SITES WE DON’T CONTROL
FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS
Two Sigma Impact, LP
100 Avenue of the Americas
New York, NY 10013
Attn: Legal / Privacy Matters