Effective Date: June 28, 2023
Alpha Partnerships Privacy Policy
This Privacy Policy describes the policies and procedures of the applications or websites on which it is posted (each a “Platform”), followed by Two Sigma Investments, LP and its affiliates (“we”, “our” or “us”) in the collection, use and disclosure of your information on this Platform and the services, features, content, feedback or applications we offer including offline activities (collectively with the Platform, the “Services”). We receive personal information about you from various sources, including: (i) from you directly; (ii) if you use the Platform; (iii) through your use of the Services generally; (iv) recruiting platforms and recruiting events; (v) online platforms including professional and social networks and forums; (vi) financial institutions and (vii) referrals from third parties. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information described in this Privacy Policy.
This Privacy Policy covers the treatment of personal information, which is information relating to an identified or identifiable natural person (“Personal Information”) that is gathered when you are using or accessing the Services. 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.
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”) 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.
WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.
The collection and processing of Personal Information about you may be necessary for the performance of any contractual relationship with you and where in our legitimate interests. For each of the categories of Personal Information listed below, we may use this information (i) to contact you and respond to your requests and queries; (ii) to provide you with the Services; (iii) for business administration, including statistical analysis and research and analyzing performance; (iv) to personalize your visit to the Platform and assist you while you use the Platform; (v) to optimize the Platform and improve, upgrade or enhance the services; (vi) for fraud prevention and detection and ensuring quality and safety of the Services; (vii) to comply with applicable laws, rules and regulations; (viii) for selection and on-boarding including recruiting analyses; (ix) to debug and identify and repair errors that impair existing intended functionality; (x) for payment purposes; and (xi) for any other purpose as described in this Privacy Policy.
For each of the categories listed below, we may share this information with various parties including (i) Two Sigma affiliates; (ii) service providers such as cloud providers; (iii) third parties you direct us to; (iv) government agencies and regulators to comply with the law and protect ourselves; (v) business transfers; (vi) business successors and (vii) third parties you direct us to.
We collect the following categories of Personal Information:
Personal Identifiers:
We collect Personal Information, such as your name, username(s), password, email address(es), phone number(s), domicile, educational and occupational data, such as your degrees, employment information, and such other information as requested on our Platform log-in page or otherwise requested through correspondences with you. You acknowledge that this information may be personal to you and that, by logging on to the Platform and/or providing Personal Information to us, you allow us to identify you and therefore you may not remain anonymous to us.
We may collect this information from various sources including from you directly, if you use the Platform, through your use of the Services generally, recruiting platforms and recruiting events, online platforms including professional and social networks and forums, financial institutions and referrals from third parties. We use and share this information as noted above in this section.
Professional and Employment Information:
We collect information related to your professional background and employment information such as your current or previous employer, social media professional profile, ability to work in location, and occupational data, such as your background and expertise.
We may collect this information from various sources including from you directly, through your use of the Services generally, online platforms including professional and social networks and forums, financial institutions and referrals from third parties. We use and share this information as noted above in this section.
Educational Information:
We collect information related to your education and credentials such as schools attended and associations.
We may collect this information from various sources including from you directly, through your use of the Services generally, online platforms including professional and social networks and forums, financial institutions and referrals from third parties. We use and share this information as noted above in this section.
Financial Information:
We collect financial information with your consent or that you provide to us (e.g., account and brokerage information, tax information).
We may collect this information from various sources including from you directly and from financial institutions. We use and share this information as noted above in this section.
Internet or electronic network activity:
We collect certain internet or electronic activity such as IP address, type of platform used, SSH keys, API keys or other credentialed tokens in order to provide access to our Services. We may also receive a confirmation when you open an email from us. We also may maintain logs of our correspondence with you.
We may collect this information from various sources including from you directly, if you use the Platform and through your use of the Services generally. We use and share this information as noted above in this section.
Geolocation Information:
We collect geolocation information such as IP address. We collect this information if you use the Platform and through your use of the Services generally. We use and share this information as noted above in this section.
Aggregate Information:
We collect statistical information about how users use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal 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.
We may collect this information from various sources including from you directly, if you use the Platform, through your use of the Services generally, recruiting platforms and recruiting events, professional and social networks, online messaging and community forums and financial institutions. We use and share this information as noted above in this section.
WE USE INFORMATION AS DISCLOSED AND DESCRIBED HERE.
How, and With Whom, Is My Information Shared?
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 category of Personal Information listed above, we may share your Personal Information as follows:
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 (e.g., cloud providers, workplace solution providers, etc.) or to manage our processes.
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).
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.
Is Information About Me Secure?
Your Platform information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Personal Information by selecting and protecting your password appropriately and limiting access to your computer, browser and/or mobile device by signing off after you have finished accessing your account.
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 do not guarantee the security of any information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
We keep your Personal Information for as long as it is necessary or relevant for the practices described in this Privacy Policy. We will also keep your Personal Information as otherwise required by law or for internal compliance and record-keeping purposes.
What If I Am Located in The European Economic Area or 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.
We generally retain personal data for so long as it may be relevant to the purposes set forth 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.
What if I am a Resident of 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):
- Our or our service providers’ operational purposes;
- Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;
- Bug detection and error reporting;
- Customizing content that we or our service providers display on the Services;
- Providing the Services (e.g., maintaining our Sites and communicating with you about programs and products);
- Improving our existing Services and developing new services (e.g., by conducting research and analysis to develop new products or features);
- Evaluating job applicants, individuals, and/or business opportunities;
- Onboarding and paying contractors;
- 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
- Other uses about which we notify you.
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:
- Request that we disclose information about the personal information that we have collected, used, disclosed or sold,
- Request access to a copy of the personal information we maintain about you;
- Request correction of inaccurate personal information;
- Request that we delete personal information collected from you; and
- Not receive discriminatory treatment for exercising your privacy rights.
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 .
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.
How Do We Store Information?
Information we maintain may be stored both within and outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your information to the United States. This Platform is subject to U.S. laws, which may not afford the same level of protection as those in your country.
What Happens When There Are Changes to this Privacy Policy?
We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make material changes in the way we collect or use information, we will notify you as required by law, which may include by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.
What If I Have Questions or Concerns?
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 / Alpha Partnerships Privacy Matters