Effective Date:  March 12, 2019

THIS PRIVACY POLICY APPLIES TO THIS WEBSITE.

This Privacy Policy describes how Two Sigma Investor Solutions, LP (“Two Sigma”, “we”, “our” or “us”) treat personal information collected on the web sites on which these terms reside (collectively, the “Site”). This Privacy Policy does not apply to personal information Two Sigma collects offline or through other sites, including through venn.twosigma.com or otherwise through your use of the VennTM platform. This Privacy Policy also does not apply to websites or platforms where it is not posted and where a link to the Privacy Policy is not provided. It also does not apply to the practices of all Two Sigma affiliates.  For example, this Privacy Policy does not apply to customers or consumers of Two Sigma financial services or products with respect to your use of such financial services or products. When you use 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.

WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

We collect contact information.  For example, we might collect your name, address, and email address when you subscribe to our Site.

We collect information you email, submit, or post. We collect information when you contact us using the email address provided on the Site. This may contain personal information about you.

We collect other information.  We may also collect usage data on how you use our Site, how frequently you access our Site and how long you stay on the Site 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 website (“Aggregate Information”), some of which is derived from personal information but is not itself personal information.

WE COLLECT INFORMATION IN DIFFERENT WAYS.

We collect information directly from you.  For example, if subscribe to our Site or send us an email via 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 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.

We may collect information about you from third parties.  For example, our business partners or vendors may give us personal information about you.  We may combine this information with information that you give us via the Site.

We may collect personal information as otherwise described at the time of collection on the Site.

WE USE 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, or where we have a legitimate interest to carry out the following purposes:

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.

We use personal information about you to improve our Site and the information we provide.  We might use your personal information to deliver the Site and/or customize your experience with us. For example, we may use your personal information for our internal business purposes, including to analyze and improve the Site.

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.

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

We use personal information to communicate with you about our relationship.  We may contact you about your use of our Site. We may contact you about your account or feedback.  We might also contact you about this Privacy Policy or the Site’s Terms of Use.

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

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.

WE MAY SHARE INFORMATION WITH THIRD PARTIES.

We may share your personal information with Two Sigma affiliates.

We may use 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.

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 and cloud storage providers), partners and consultants. We may also share personal information with companies that help us operate and improve the Site.

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/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 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.

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 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 support@venn.twosigma.com.

For the purposes of EU data protection laws, we are the data controller of your personal information collected when you are using or accessing the Site. 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.

Personal information we collect (including from individuals in the European Economic Area (“EEA”)) 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 countries in the EEA. Our Site is 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 Site, you gave your explicit consent to the transfer of your personal information outside of the EEA, which is the lawful ground for such transfer. You acknowledge that if you do not consent to such transfer, it may impact your ability to use the Site. You can withdraw your consent at any time by contacting GDPR@twosigma.com or support@venn.twosigma.com.

THE SITE AND CHILDREN.

Our Site is 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 USE STANDARD SECURITY MEASURES.

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 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 SITES 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).

DELETING YOUR 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.

You may 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.

reCAPTCHA

We use the reCAPTCHA service provided by Google Inc. (Google) to protect your submissions via internet submission forms on this 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.

FEEL FREE TO CONTACT US IF YOU HAVE MORE QUESTIONS.

If you have any questions about this Privacy Policy or other privacy concerns, please contact us 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 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 Privacy Policy when you use the Site after such changes have been first posted

© 2019 Two Sigma Investments, LP. All rights reserved.