Updated and Effective Date:  June 26, 2020

This Privacy Policy describes how Sightway Capital, LP (“Sightway”, “we”, “our” or “us”) treats personal information, including personal information collected on www.sightwaycapital.com where this Privacy Policy is located (the “Site”). This policy covers our treatment of any third party personal information that you share with us or that we share with our business partners. This Privacy Policy does not apply to websites or platforms where a different privacy policy is posted. It also may not apply to the practices of all Sightway affiliates.  In addition, this Privacy Policy does not apply to customers or consumers of Sightway or its affiliates financial services or products (including, but not limited to, any investment managed by Sightway) with respect to your use of such financial services or products. When you use this site, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your personal information described in this Policy and in accordance with applicable law.

WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU.

We collect the following categories of personal information from you in different ways including from you directly, from you passively 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.

Personal Identifiers: We collect your name, address, phone number, username, email address and log-in information when you register on our Site, sign up for our newsletters, apply for a job or contribute to any of our projects and any other information that you provide to us voluntarily.

We also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. We use and share this information as noted below.

Commercial Information:  We collect commercial information, including records of personal property, 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 share this information as noted below.

We also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. We use and share this information as noted below.

Communications: 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 such as personal identifiers and professional or employment information.

We also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. We use and share this information as noted below.

Professional or Employment Information: When you register on the Site or apply for a job, we may collect professional and employment information such as information about your employers, awards and associations.

We also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. We use and share this information as noted below.

Educational Information: When you register on the Site or apply for a job, we may collect educational information such as information about schools you attended, degrees awarded and academic status.

We also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. We use and share this information as noted below.

Internet or Other Electronic Network Activity: We collect internet and other electronic information such as usage data on how you use our Site and how long you stay on the Site 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.

We also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals.

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 Site and from our services providers. We collect this information through your use of the Site.

We also collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies,  online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. We use and share this information as noted below.

Aggregate information.  We collect statistical information about how users use the website, some of which is derived from personal information but is not itself personal information.

We collect this information from other various sources including recruiting agencies, platforms and events, employers, Investment Companies, online platforms including professional and social networks and forums, productivity and collaboration tool providers, educational institutions, financial institutions, service providers, third party-licensed data, business vendor tools and other individuals. We use and share this information as noted below.

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.

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 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 contact you about employment opportunities or to process your application for a job or to respond to your request to work on any of our projects.

Provide you with Services and Improve the Site: 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 Site and/or customize your experience with us. For example, we may use your personal information to improve the Site, our recruiting efforts 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 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.

Recruiting and Marketing: We use personal information to inform you about Sightway.  For example, we might send you information about Sightway and what we offer.  We might tell you about new features or updates. We may also use your personal information to send you information about career opportunities.

Communications:  We use personal information to communicate with you about your account or 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.

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 of third party licensed data.

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 PERSONAL INFORMATION WITH THIRD PARTIES.

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

For each of the personal information categories listed above, we may share this information with third parties and affiliates for business or commercial purposes.

Two Sigma Companies:  We may share 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 share your personal information with third parties in order to provide you with services requested by you or answer your questions.

Service Providers:  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 providers, background check vendors, online platforms, recruiting agencies and platforms), partners and consultants. We may also share personal information with companies that operate our websites.

Comply with the Law:  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.

Business Successors:  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 Sightway 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.

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.

Aggregate Information: We may share Aggregate Information. We may share Aggregate Information with third parties, including vendors, partners and consultants, to further our internal business purposes 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.

Information We Share With Your Consent: We will also share your personal information in the manner that you authorize us to.

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.

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 Sites may not work.  If you block or reject cookies, not all of the tracking described here will stop.

RIGHTS FOR INDIVIDUALS IN CALIFORNIA

Individuals who are residents of California have certain consumer rights under applicable California privacy laws but which may be subject to certain limitations and/or restrictions. Specifically, under California law 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.

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.

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.

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 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.

SIGHTWAY SITES 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 STORE PERSONAL INFORMATION IN THE UNITED STATES

Personal information we collect may be transferred to and stored within the United States. Our Sites 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. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States.

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 a 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).

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:

Sightway Capital, 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 posting a notice on our Site prior to the change becoming effective. 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 website after such changes have been first posted

© 2019 Sightway Capital, LP. All rights reserved.