PRIVACY POLICY

Last updated December 27, 2022

This Privacy Policy (the “Privacy Policy”) describes the information WorldQuant, LLC and its affiliates (“we,” “us,” “our,” or other similar pronouns) may collect when you use this website (the “Website”), and/or any capability, software or service that may be made available through the Website (the “Services”) and how may we use that information.

By using the Website and/or the Services, you agree to the terms of this Privacy Policy as it may be amended from time to time. As we update and expand our Services, this Privacy Policy may change, so we suggest that you check back to this page from time to time. This Privacy Policy is incorporated into, and is part of, the Web Site Terms of Use and any agreement you may enter into with us in connection with the Services.

Information We Collect

In order to make your visits to the Website and your use of the Services as worthwhile as possible, we may ask you for certain personal information and we may collect certain information from your computer when you visit us.

Information That You Provide To Us

We collect personal information from users of the Website and natural persons who register to use the Services on the Website and/or submit information or materials on the Website, including, for example, when users apply for employment positions on the Website, submit resumes or other information or materials on or through the Website or the Services, send us an e-mail, or in any other way submit personal information to us via the Website.

The personal information we may collect from you includes:

• Contact information you provide to us (such as name, postal address, e-mail address and telephone and/or mobile phone numbers);
• Information contained in your resume and cover letter if you choose to submit it to us via the Website; and
• Other information you may provide to us through the “Contact Us” or similar features.

Information We Automatically Collect From You

We may also automatically collect the following information from the computers and devices you use to access the Website and/or the Services: your operating system type or mobile device model; the browser type, domain, and other system settings; the language your system uses; and geolocation data, including the country and time zone of your device. Browsers routinely send these types of information to web servers. Our server logs also record the Internet Protocol (“IP”) addresses of the computers and devices you use to interact with the Website and/or the Services.  An IP address is a unique identifier that computers and devices use to identify and communicate with each other on the Internet. To the extent that IP addresses, geolocation data, or similar identifiers are considered personal data or information under applicable law, we will treat these identifiers as such in compliance accordance with applicable law.  Similarly, to the extent that non-personal data or information is combined with personal data information, we treat the combined information as personal data or information for the purposes of this Privacy Policy.

We collect this information by automated or electronic means, using technologies such as cookies, pixel tags and web beacons, browser analysis tools, and web server logs. These technologies allow us to provide, protect, and improve our products and services, such as by personalizing content, understanding user behavior, and offering a safer experience. We also use these technologies to provide you with personalized advertisements, including on third-party websites and applications, and to determine the effectiveness of our promotional campaigns.

For more information on our use of cookies and other tracking technologies, including use for analytics and advertising purposes, please see our Cookie Policy.

Use of Information

We use your personal information for the following purposes stated in this Privacy Policy:

• the use of your personal information as described herein for our legitimate business interests;
• the use of your personal information in order to comply with applicable law and regulations;
• the use of your personal information in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; or
• the use of your personal information to the extent we have obtained your consent.

More specifically, we may use your personal information for the following legitimate business interests:

• to operate, maintain or improve the Website, the Services or our business;
• to contact you or respond to your requests or inquiries;
• to consider you for employment or business opportunities;
• to support auditing, legal or compliance functions;
• to provide our products and services;
• to create and manage online accounts;
• to send promotional materials, alerts and other communications, which may be through the Website or outside of the Website, such as via e-mail or through third party websites and/or apps;
• to optimize the Website and/or Services and understand usage patterns and user behavior;
• to communicate about, and administer participation in, special events; promotions, programs, offers, surveys, contests and market research; and/or
• to maintain our internal records.

How We Share Information

We may share your personal information under the following circumstances:

• We may share your personal information within our organization, including to our affiliates.
• We may disclose your personal information to service providers, including our subcontractors, agents and any person who provides professional, legal, tax or accounting advice or other services to us in order to provide a better service and user experience. All such service providers are required to maintain the confidentiality of such personal information to the extent they receive it. We may share your personal information with our vendors and other parties for analytics and advertising related purposes. These parties may act as our service providers, or in certain contexts, independently decide how to process your personal information.
• We may share your personal information with our third party business partners and/or with other third parties for the purposes as stated in this Privacy Policy or for other purposes disclosed to you.
• We may disclose your personal information or any portions thereof: (a) as required by, or to comply with, applicable law, regulation, court process or other statutory requirement or to enforce our legal rights or agreements with you or others; (b) to respond to requests from any regulatory, supervisory or governmental authorities; or (c) where we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Website or Services, or anyone else that could be harmed by such activities.
• If we or any of our affiliates are involved in a potential or actual transaction of merger, division, liquidation, acquisition or sale of assets or business, your personal information may be disclosed in connection with the transaction.
• We may disclose your personal information with notice to you and your consent
• We may disclose your personal information where you direct us to disclose the information.

Notwithstanding the above, we may disclose publicly available information (as that term is defined by applicable law) or information that does not identify you (including information that has been aggregated or de-identified as those terms are defined by applicable law) to the extent permitted by applicable law.

International Transfer of Information

We are based in the U.S. and the personal information we collect is governed by U.S. law.  Some of the uses and disclosures of information mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries that may have different levels of privacy protection than your home country.

Where your personal information is transferred outside of your jurisdiction, we will take measures to ensure that the transfer is subject to appropriate safety measures (which may be contractual in nature) in accordance with applicable data protection laws, such as through standard contractual clauses.

Right to Opt In and Opt Out

You may have the right to “opt in” and “opt out” of certain of our uses of your personal information. For example, at the time you are requested to provide personal information (for example, when you fill out an online application), you may have the opportunity to elect not to have your personal information shared with other entities for marketing purposes. You can also make such requests by sending an e-mail to [email protected].

Data Retention

We take the protection of your personal information seriously, and have security measures, controls and policies in place.  We will hold your personal information on our systems for the longest of the following periods: (a) as long as is necessary for the relevant activity or as long as is set out in any relevant agreement you enter into with us; (b) the length of time it is reasonable to keep records to demonstrate compliance with professional or legal obligations; (c) any retention period that is required by law; or (d) the end of the period in which litigation or investigations might arise in respect of your use of our Website and/or the Services that we provide to you.

Security

We utilize administrative, technical, personnel, and physical measures designed to: (a) safeguard personal information against loss, theft, unauthorized use, disclosure, or modification; and (b) ensure the integrity of personal information.  However, while we will endeavor to protect the security and integrity of your personal information, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any personal information will be absolutely safe from intrusion by others, such as hackers, during transmission through the Internet or while stored on our systems or otherwise in our care.

If you contact us by e-mail or the “Contact Us” or similar feature on the Website and/or the Services, you should be aware that your transmission mechanism might not be secure. A third party could view personal information you send by these methods in transit. We will have no liability for disclosure of your personal information due to errors or unauthorized acts of third parties during or after transmission by you.

Privacy Policies of Third Party Websites

This Privacy Policy only addresses the use and disclosure of personal information we collect from you. Other third-party websites that may be accessible or linked through the Website have their own privacy policies and data collection, use and disclosure practices. If you access any such website, we urge you to review its privacy policy. We are not responsible for the policies or practices of third parties, including those of any sites, apps or services not owned by us.

Children

We do not collect or maintain personal information from anyone known to be under the age of 13, and no part of the Website or Services is designed to attract anyone under the age of 13. You must be over the age of 18 in order to sign up for the Services.

Accessing, Reviewing, Updating and Modifying Personal Information

You have the right to access, review, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access to, updates to and corrections of inaccuracies in your personal information by e-mailing to us as set forth under “Contact Us” below. We may request certain personal information for the purposes of verifying the identity of the individual seeking to access or update their personal information records.

Processing of Personal Information in the European Union

WorldQuant is what is known as a “data controller” for the purposes of the European data protection laws, including the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).  If we are processing your personal data in the context of the activities of our establishment in the European Union or the GDPR otherwise applies, these data protection laws may provide you with additional rights not specifically mentioned in this Privacy Policy, including the rights to object to marketing, to access data, or for data to be erased, corrected, used for only limited purposes, not used at all, or transferred to you or a third party.  More specifically, you have the following rights:

• Right of subject access: The right to make a written request for details of personal information about you held by us and a copy of that personal data;

• Right to rectification: The right to have inaccurate or incomplete personal information about you rectified;
• Right to erasure (“right to be forgotten”): The right to have certain personal information about you erased. Please note that there may be circumstances where you ask us to erase your personal information but we are legally entitled or required  to retain it;
• Right to object to, or request that we restrict, our processing: Again, there may be circumstances where you object to, or ask us to restrict, our processing of your personal information but we are legally entitled to refuse that request;
• Right to data portability: In some circumstances, the right to ask for personal information you have made available to us to be transferred to you or a third party in machine-readable formats where this is technically feasible. Please note that this right only applies to personal information which you have provided directly to us; and
• Right to withdraw: Please note, however, that we may still be entitled to process your personal information if we have another legitimate reason for doing so. For example, we may need to retain personal information to comply with a legal obligation.

These rights are not absolute: they do not always apply and exemptions may be engaged. We may, in response to a request, ask you to verify your identity and to provide information that helps us to understand your request better. If we do not comply with your request, we will explain why.

To exercise any of these rights, or if you have any other questions about our use of your personal information, please contact [email protected].

You have a right to contact the data protection regulator in the EU Member State where you live or work if you think a breach of your personal information has taken place.

Processing of Personal Information of Citizens of Armenia

WorldQuant is what is known as a “data processor” for the purposes of Armenian data protection laws. If you are a citizen of Armenia and we are processing your personal data in the context of the activities of our establishment in Armenia, or Armenia data privacy law otherwise applies, you may have additional rights provided to you that are not specifically mentioned in this Privacy Policy. More specifically you may have the following rights:

• Right to be informed: The right to know what personal information we process about you and to whom your personal data may be transferred;
• Right of access: The right to be aware of and verify the lawfulness of the processing of your data;
• Right to rectification and to be forgotten: The right to require we rectify, block, or destroy your personal data;
• Right to decline: The right to withdraw your valid consent to the processing of your data if you find out the processing of your data violates applicable law or your basic rights and freedoms;
• Right to appeal actions or inaction of processor: Where you consider the processing of your personal data is carried out in violation of the requirements of the applicable legislation or otherwise violates your rights and freedoms, you shall have the right to appeal our actions or inaction before an authorized state body.

To exercise any of these rights, or if you have any other questions about our use of your personal information, please contact [email protected].

Processing of Personal Data of the Citizens of the Russian Federation

If you are our employee (or consultant) and a citizen of the Russian Federation (“RF”), please be informed that we process your personal information in full accordance with the RF applicable data protection laws, including Federal Law  No. 152-FZ “On Processing Personal Data”, dated 27.07.2006 (as amended). We procure that while collecting your personal information through the Website, we confirm that the recording, systematizing, accumulating, storage, adjustment (updating, amending), extracting of personal information of the RF citizens is being performed with the use of databases located in the RF as required by Federal Law No. 242-FZ “On Amending Certain Laws of the Russian Federation with regard to the Procedure for Personal Data Processing in Information-Telecommunications Networks”, dated 21.07.2014. We further ensure that the cross-border transfer of personal information of the RF citizens is made in accordance with the RF applicable data protection laws. When you register for use of or use in any capability, a software or service that may be made available through the Website, you agree with our processing of your personal information and transmission (including cross-border transfer) to other jurisdictions, including those that do not provide adequate protection of personal information as provided by the RF applicable laws.

Обработка Персональных Данных Граждан Российской Федерации

Если Вы являетесь нашим работником (или консультантом) и гражданином Российской Федерации («РФ»), пожалуйста, примите во внимание, что обработка Ваших Персональных Данных осуществляется нами в строгом соответствии с применимыми законами РФ в сфере защиты персональных данных, в том числе, Федеральным законом № 152-ФЗ «О персональных данных» от 27.07.2006 (с изменениями и дополнениями). Мы обеспечиваем, что при сборе Персональных Данных запись, систематизация, накопление, хранение, уточнение (обновление, изменение), извлечение персональных данных граждан РФ осуществляется с использованием баз данных, находящихся на территории РФ, в соответствие с требованиями Федерального закона от 21.07.2014 N 242-ФЗ “О внесении изменений в отдельные законодательные акты Российской Федерации в части уточнения порядка обработки персональных данных в информационно-телекоммуникационных сетях”. Мы гарантируем, что трансграничная передача Персональных Данных граждан РФ также осуществляется в соответствие с применимыми законами РФ в сфере защиты персональных данных. Когда Вы регистрируетесь на Веб-сайте или используете возможности, сервисы, программное обеспечение, которое может быть доступно через Веб-сайт, тем самым Вы соглашаетесь с тем, что мы обрабатываем Ваши Персональные Данные и осуществляем их передачу (включая трансграничную передачу) их в другие страны, в том числе, страны, не обеспечивающие адекватную защиту Персональных Данных, как предусмотрено законодательством РФ.

Processing of Personal Information in China

The following notice is provided for citizens of the People’s Republic of China. The Personal Information Protection Law (PIPL) applies to the processing of personal information of natural persons within, and in certain circumstances outside of, the territory of the People’s Republic of China. If we are processing your personal data in the context of the activities of our establishment in China or the PIPL otherwise applies, these data protection laws may provide you with additional rights not specifically mentioned in this Privacy Policy, including the rights to restrict or refuse the processing of your personal data (unless otherwise required by laws and administrative regulations), consult, copy, correct, supplement or delete the data. Further, your rights may include the right for you to request an explanation of our processing rules for your personal information and/or request the transfer your personal information to the personal information handler you designate when the legal conditions for such transfers are satisfied.

With your explicit consent, which is provided when you use submit your information to us via the website and accept the terms of this Privacy Policy, we may share your personal information within our organization, with our third party business partners, business associates, or subcontractors, and/or with other third parties (including, but not limited to: software service providers, background check vendors, email delivery platforms, and analytics providers) only for the purposes as stated in this Privacy Policy.

We take steps to safeguard your personal information. We will not transfer your personal data to any company, organization or individual outside of WorldQuant and our affiliates, except as set forth in this Privacy Policy.

Notice to California Residents

The notice below is provided to California, U.S.A residents who are users of the Website or Services. Depending on the nature of your interaction with us, the following categories of personal information may be, or may have been within the last 12 months, collected:

From job applicants or contractors we may collect personal information that is also considered “sensitive personal information” under the CCPA. That sensitive personal information may include:

• Social security, driver’s license, or passport numbers
• Information concerning your health
• Information about racial or ethnic origin, sex, sexual orientation, or union membership
• Biometric information

We use sensitive personal information for lawful purposes in compliance with the CCPA and do not use sensitive personal information collected in the context of employment or an application for employment to infer characteristics about employees.

We collect and use this personal information for the business and commercial purposes set out in the “Use of Information” section above. We disclose this personal information to the categories of persons set out in the “How We Share Information” section above.

We do not sell your personal information as that term is traditionally understood. However, some of our disclosures of personal information may be considered a “sale ” as that term is defined under the CCPA. A “sale” is broadly defined under the CCPA to include a disclosure for something of value. We may collect or sell the following categories of personal information for commercial purposes: identifiers, characteristics, commercial or transactions information, internet activity, geolocation data, and inferences drawn. The categories of third parties to whom we may sell your personal information include, where applicable, vendors and other parties involved in cross-context behavioral advertising.

Subject to certain limitations, under the CCPA, if you are a Consumer, you have the right to know certain details about our data practices. In particular, you may request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of persons to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.

You also have the right to delete the personal information we have collected from you.

If you would like to make a request and exercise your rights described above, please reach out to [email protected]. If you have an account with us, we may require you to use the account to submit the request. We will confirm receipt of your request within 10 business days. In the request, please specify which right you are seeking to exercise and the scope of the request. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your request.

In addition, you have the following rights:

• Effective January 1, 2023, right to correction: The right to have inaccurate or incomplete personal information about you rectified.
• Right to limit use and disclosure of sensitive personal information in some circumstances.
• Right to Opt-Out of the Sale of your personal information.  You have the right to opt-out of the sale of your personal information by us.  You may exercise this right by emailing us at [email protected] and specifying you wish to opt-out.
• Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for the exercise of your privacy rights conferred by the CCPA.
• Authorized Agent. You may designate an authorized agent to make a request under the CCPA on your behalf by us with a copy of your power-of-attorney document granting that right.

Customers who are residents of California may request (i) a list of the categories of personal information (as that term is defined by Shine the Light) disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such personal information. To exercise a request, please write us at the address set out in “Contact Us” below and specify that you are making a “California Shine the Light Request.” We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Changes to this Privacy Policy

We reserve the right to change or update this Privacy Policy, or any other of our policies or practices, at any time, and will notify users of the Website and/or Services by posting such changed or updated Privacy Policy on this page. Any changes or updates will be effective immediately upon posting to the Website. We will notify you of significant changes or updates to our Privacy Policy by additional means, such as posting a notice on the front page of the Website and/or sending you an e-mail.

Contact Us

If you have any questions about this Privacy Policy, or our privacy related practices, you can contact us at [email protected] or in writing sent to WorldQuant at Attn: General Counsel, WorldQuant, LLC, 1700 E. Putnam Avenue, Third Floor, Old Greenwich, CT 06870, with a copy to [email protected].