Effective and Last Modified Date: December 19, 2019.

THIS PRIVACY POLICY APPLIES TO WWW.HALITE.IO.

This Policy describes how Two Sigma Open Source, LLC (“Two Sigma”, “we”, or “us”) treats personal information collected on www.halite.io where this policy is located (the “Site”). This policy also does not apply to websites or platforms where it is not posted and where a link to this privacy policy is not provided.

WE COLLECT INFORMATION FROM AND ABOUT YOU.

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 Site and from third parties.

Personal Identifiers: We collect your personal information when you register on the Site to participate to the competition via your Github account, such as your Github email address (and potentially a secondary email address), username, country of domicile, university/high school name, profession and academic status. We may process your photograph if displayed on your Github account. We may also collect personal information you provide when you edit information on your profile, sign up for emails or download materials from the Site or for some participants to the competition, your postal address, names and phone numbers.

We collect this information from you directly, if you use the Site and from third parties such as online platforms and forums. We use and share this information as noted in the sections below.

Professional or Employment Information: When you register on the Site to participate to the competition, we may collect information on your profession.

We collect this information from you directly, if you use the Site and from third parties such as online platforms and forums. We use and share this information as noted in the sections below.

Educational Information: When you register on the Site to participate to the competition, we may collect educational information such as university name and academic status.

We collect this information from you directly, if you use the Site and from third parties such as online platforms and forums. We use and share this information as noted in the sections below.

Communications: We collect information you submit or post. We collect the information you post in a public space on our Site. We also collect information when you contact us using the email address provided on the Site. This may contain personal information about you.

We collect this information from you directly, if you use the Site and from third parties such as online platforms and forums. We use and share this information as noted in the sections below.

Internet or Other Electronic Network Activity: We collect information from you passively through your use of the Site. 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. We may also collect usage data on how you use our 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 may contain personal information about you. We may also collect information about your use of our Site and how long you visited our Site. Learn more about these tools and how you can manage them by visiting our cookie policy here.

We collect this information from you directly and if you use the Site. We use and share this information as noted in the sections below.

Geolocation Information: We use browser cookies and web beacons, which may collect your browser, device ID, IP address, etc. We collect this information from you directly and if you use the Site. We use and share this information as noted in the sections below.

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

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.

Responding to requests: We use personal information to respond to your requests or questions. For example, we might use your personal information to confirm your registration or participation to the competition.

Provide you with services and improve the Site: We use personal information to provide you with services, and improve our Site and the services 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 look at site trends, user interests, or whether you are logged in.

Recruiting: We use personal information about you for recruitment purposes. We might use your personal information to contact you for a position at one of the Two Sigma group entity.

Security and Fraud Prevention and Detection: We use personal information for security purposes such as fraud prevention and detection. We may use your personal information to enforce our rights, protect our company, affiliates, our customers, or our websites, or a third-party website or platform.

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

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 such as contacting you about a Two Sigma product or service.

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 may use your personal information as otherwise described or permitted by law 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 or vendors, for example, Github Inc., 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. This includes Two Sigma Investments, LP.

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 may share personal share information with our vendors, partners and consultants such as email and subscription management providers. We may also share personal information with companies that operate our Site.  For example, we may make anonymous usage information publicly available on our Site. Google may use the data collected through Google Analytics to contextualize and personalize the ads of its own advertising network. For Google’s privacy policy see http://www.google.com/analytics/learn/privacy.html.

Other Users: We will share analytics and usage information with other parties. For example, we share aggregate anonymous usage data we obtain through Google Analytics and through our own analytics with third parties, including other users of Halite and the Site.

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 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.

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 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.

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

We may share information for other reasons we may describe to you or as permitted by law.

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 or manage preferences method provided in emails you receive from us. If you object to our use of your information for direct marketing purposes, please email us at halite@halite.io.

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.

THIS SITE AND CHILDREN.

This Site and children. We do not knowingly collect personal information from children under the age of 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, and have questions about our privacy practices you can email us at halite@halite.io.io. You can also write to us at the address listed at the end of this Policy. If you are in the US, please mark your inquiries “COPPA Information Request.”

Parents, you can learn more about how to protect children’s privacy on-line here.

YOUR EUROPEAN UNION PRIVACY RIGHTS.

Individuals who are located in or residents of the European Union 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 EU 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. Our data protection representative for the EU in the UK is Two Sigma International Limited, and can be reached at GDPR@twosigma.com.com.

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 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.

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, the Internet is not 100% secure. We cannot promise that your use of our Site or software will be completely safe.  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 long as it is necessary or relevant for the practices described in this Privacy Policy, for internal compliance or record-keeping purposes, or as otherwise required by law. Because information about, for example, the results of the competition, may be useful to you and to others for purposes of credentialing, we plan to keep that personal information available for approximately five years. If you want to be able to reference it beyond that period, you should arrange to copy and store it yourself.

WE MAY TRANSFER AND STORE PERSONAL INFORMATION IN THE UNITED STATES OR OTHER COUNTRIES.

By participating in the Halite competition using the Site, you understand that your personal information will be processed in the U.S. where we operate the Site. Personal information we maintain may be transferred to and 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 personal information to the United States. This 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.

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).

FEEL FREE TO CONTACT US IF YOU HAVE QUESTIONS.

Feel free to contact us if you have questions. If you have any questions about this Privacy Policy or want to access, delete or correct your information, please email us at halite@halite.io. You can also contact us at:

Two Sigma Open Source, LLC
100 Avenue of the Americas 16th Floor
New York, NY 10013
Attn: Legal – Halite Privacy Matters

WE MAY UPDATE THIS PRIVACY POLICY.

From time to time we may update our Privacy Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy on the Site, so please check it periodically for updates.