COLLECTION OF INFORMATION
EPAM collects information to provide better services to its users and to better understand the visitors to its websites and what content is of interest to them. EPAM collects information in the following ways:
- information you affirmatively choose to submit to us (such as your name, email address, company name, title, country) for the purpose of accessing various downloads, viewing specific content, subscribing to EPAM newsletters, registering for events and your preferences in receiving marketing from EPAM and its third party partners and your communication preferences, etc. Information we have obtained about you from publicly available sources such as social media, marketing platforms or on events, you attended. You will receive marketing communications from EPAM if you have requested information from EPAM or you or your employer has purchased services from EPAM;
- information EPAM receives from your use of EPAM websites, such as the IP address, browser type, ISP, referring/exit pages, platform type, date/time stamp, number of clicks, domain name and country/state of all visitors to EPAM’s websites;
- location information when you use EPAM’s websites as EPAM may collect and process information about your location. EPAM use various technologies and tools to determine location;
- information that is considered aggregated data such as statistical or demographic data which EPAM may use for any purpose. Aggregated data may be derived from your personal information but is not considered personal information in law as it does not directly or indirectly reveal your identity, unless EPAM combines or connects aggregated data with your personal information so that it can directly or indirectly identify you; and
- EPAM collects technical data from various third parties and public sources as, such as:
- analytics providers
- advertising networks
- search information providers
- In particular in relation to the CSAT EPAM collects the information you submit. The information will be linked to your profile and it will be visible for EPAM that this information was submitted by you. The information you provide will be used in relation to assess your satisfaction with the services provided and possible improvements to the services. It will not be used for general marketing campaigns.
Other than as required by law, EPAM websites do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). EPAM will not collect any information about criminal convictions and offences.
EPAM will only use your personal information for the purposes for which it was collected, unless it reasonably considers that it needs to use it for another reason that is compatible with the original purpose. If EPAM needs to use your personal information for an unrelated purpose, EPAM will notify you and explain the legal basis which allows EPAM to do so.
SHARING OF INFORMATION
EPAM may disclose your personal information to the following categories of recipients:
- to its group companies, professional advisers, third party services providers and partners who provide data processing services to EPAM (for example, to support the delivery of, provide functionality on, or help to enhance the security of EPAM websites), or who otherwise process personal information for purposes that are described in Privacy Notices or notified to you when EPAM collects your personal information. A list of EPAM’s current group companies is available upon request.
- to any competent law enforcement body, regulatory, government agency, court or other third party where EPAM believes disclosure is necessary (a) as a matter of applicable law or regulation, (b) to exercise, establish or defend its legal rights, or (c) to protect your vital interests or those of any other person.
- to any other person with your consent to the disclosure.
LEGAL BASIS OF PROCESSING
If your personal information is protected by EU data protection law, EPAM’s legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which EPAM collects it.
However, EPAM will normally collect personal information from you only (a) where it needs the personal information to perform a contract with you, (b) where the processing is in its legitimate interests and is not overridden by your rights, or (c) where it has your consent to do so. In some cases, EPAM may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
In relation to the CSAT EPAM has a legitimate interest in collecting and using your personal information. The information is only used for the CSAT and how satisfied you or your employer is with the services provided by EPAM. In addition, it is in your control which information you provide as part of the CSAT. Furthermore, results of the CSAT will only be used to help improve the services which are provided to you or your employer.
If you have questions about or need further information concerning the legal basis on which EPAM collects and uses your personal information, please contact EPAM using the contact details provided under the “Contact Details” heading below and in the right-hand side column.
USE OF INFORMATION
To determine the appropriate retention period for personal information, EPAM considers the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which EPAM processes your personal information and whether it can achieve those purposes through other means, and the applicable legal requirements.
EPAM protects your personal information in the same way that it protects its other confidential information, such as storing it on secure servers that only select EPAM personnel have access to, and by encrypting it to help prevent access by any unauthorized parties. EPAM has put in place procedures to deal with any personal information breach and will notify you and any applicable regulator of a breach when legally required to do so.
As and to the extent explained above, EPAM will collect and use your personal data for marketing purposes. Your data will be stored in our CRM system. We will use your data to inform you about EPAM products and services we think may be of your interest and sending you our newsletters. For statistical purposes, we will collect information about your response to our emails and our interaction with you to make decisions on future marketing. If you wish to stop that we collect and use this information please click here.
YOUR DATA PROTECTION RIGHTS
If your personal information is protected by EU data protection law, you have the following data protection rights which you may be able to exercise by contacting EPAM using the contact details provided under the “Contact Details” heading below and in the right-hand side column:
- If you wish to access, correct, update or request deletion of your personal information, you can do so at any time by contacting EPAM.
- In addition, you can object to processing of your personal information, ask EPAM to restrict processing of your personal information or request portability of your personal information by contacting EPAM.
- You have the right to opt-out of marketing communications or of requests to participate in the CSAT that EPAM sends you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails EPAM sends you or by using the relevant opt-out mechanism for non-email based marketing.
- Similarly, if EPAM has collected and processes your personal information based on your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing EPAM conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about EPAM’s collection and use of your personal information. For more information, please contact your local data protection authority.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, EPAM may charge a reasonable fee or refuse to comply with your request if your request is clearly unfounded, repetitive or excessive. EPAM tries to respond to all legitimate requests within one month. Occasionally, it may take longer if your request is particularly complex or you have made a number of requests. In this case, EPAM will notify you and keep you updated.
CHANGES TO THE POLICY
This version was last updated on 06 July 2018 and historic versions can be obtained by contacting EPAM.
EPAM Systems, Inc.
41 University Drive, Suite 202
Newtown, PA 18940