Privacy Policy

EPAM Systems, Inc., together with its subsidiaries ("EPAM") has created this Privacy Policy in line with EPAM's commitment to your privacy on EPAM websites and marketing initiatives. The following discloses EPAM's information gathering, dissemination and protection practices.

Compliance

If you do not agree to the terms of this Privacy Policy, please do not access or use EPAM websites. If you wish to stop receiving EPAM marketing materials then please click on the Unsubscribe button within the marketing email you have received from us.

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

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.

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

Any information collected by EPAM will be done in accordance with this Privacy Policy for the purposes of making better business decisions, supporting the activities you choose to engage in, and providing higher quality solutions and services to EPAM's customers. EPAM uses your location information to tailor your experience with EPAM websites. It may also use any non-personal information collected to enhance EPAM websites, and your IP address for website diagnostics and administration. EPAM will only retain your personal information for as long as necessary to fulfil the purposes it was collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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.

International Transfers

EPAM processes information on servers in many countries around the world and you consent to your personal information being processed on a server located outside the country in which you reside. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). However, EPAM has taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy, including, utilizing the European Commission's Standard Contractual Clauses for transfers of personal information between its group companies, which requires all group companies to protect personal information being processed from the European Economic Area to an equivalent standard to that required under European Union data protection law.

Information Security

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.

Marketing

As 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 contact [email protected].

Links

EPAM websites contains links, plug-ins and applications to various third party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. EPAM has no control over, and is not responsible for the content, privacy policies or reliability of such third party connections. When you leave EPAM's website, EPAM encourages you to read the privacy notice and privacy policy of every website you visit.

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 request deletion of your personal information, you can do that in the Settings of your profile on Profile.epam.com.
• If you wish to access, correct, update 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 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.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies some parts of EPAM websites may become inaccessible or not function properly. For more information about the cookies that EPAM uses, please see EPAM's Cookie Policy.

Changes to the Policy

EPAM reserves the right to modify or amend this Privacy Policy at its own discretion from time to time. The changes can be viewed here or elsewhere on EPAM websites. Your continued use of EPAM websites constitutes your acceptance of those changes.

This version was last updated on 06 July 2018 and historic versions can be obtained by contacting EPAM.

Contact Details

It is important that the personal information EPAM holds about you is accurate and current. Please keep EPAM informed if your personal information changes during your relationship with EPAM. Additionally, if you have any questions about this Privacy Policy, the practices of EPAM websites or your interaction with EPAM via EPAM websites, please contact:

EPAM Systems, Inc.
41 University Drive, Suite 202
Newtown, PA 18940
P: +1-267-759-9000
F: +1-267-759-8989
E: [email protected]