Effective Date: December 20, 2019

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, here.  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 here. 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 UNION.

Individuals who are located in or a resident of the European Union 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 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.

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 EU 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. Our data protection representative for the EU in the UK is Two Sigma International Limited, and can be reached at GDPR@twosigma.com.

For the purposes of EU 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 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 GDPR@twosigma.com to such transfer it may impact your ability to use the Services.

YOUR CALIFORNIA PRIVACY RIGHTS.

Individuals who are residents of California have certain consumer rights under the California Consumer Privacy Act (“CCPA”), effective January 1, 2020, but which may be subject to certain limitations and/or restrictions. Specifically, under the CCPA 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.

How do I Authorize an Agent?

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.

Can I Receive this Privacy Policy in Alternative Formats?

Yes. If you require this notice in an alternative accessible format, please email us at CCPA@twosigma.com.

What is your process for verifying consumer requests?

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.

How do I Submit a Consumer Request?

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) call us at the toll-free telephone number 1- 844-820-6577; or (iii) submit a webform request here.

Shine the Light Inquiries

In addition, 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.

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 here.

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.