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 or applications 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 or applications. 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 applications and what content is of interest to them. EPAM collects information in the following ways:

• Personal Information: when you sign up as a user of our services we may collect information such as your such as your name, surname, your bio or story, your city or place, your occupation, your image, approximate home location, choices of interests and employment-related information, including your role, company, and years of experience to personalize content for your purposes, and enrich user’s future networking and connections.
• When accessing our services, your device and browser will automatically provide unique information such as account ID, mobile device ID, internet protocol (IP) address, cookie ID or online identifiers, operating system, browser type, time zone setting, location and date and time of access.
• Our systems may record usage data about how you navigate and engage with our services, use our features, download materials, security logs will be kept, online activity data such as clickstream data with URLs visited previously, page interaction information (such as scrolling, clicks, and mouse-overs), your preferences (including country and language), and methods used to browse away from our services.
• Some of our features rely on real-time information about the location of your device where you enabled the functionality on your device, real-time information isn’t collected.
• Information that you provide about your interests and occupation or that we otherwise collect about your preferences and interests known, observed or inferred.
• When we send you emails or other communications, we may collect technical interaction information, such as open rates and if you clicked on any content.
• When you contact or visit us, we may process the details of your request, communications, complaints, or other interaction.
• We ask that you not send us, and you not disclose, any sensitive Personal Information (e.g. information related to racial or ethnic origin, political opinions, religion or other beliefs, biometrics or genetic characteristics, trade union membership or criminal background) on or through the services or otherwise to us, except where explicitly requested.
• We may store your picture and other images you upload which will be publicly accessible as part of your profile and events created by you.

Sharing of Information

We will generally not share your information except with our third party service providers and advisors who may process personal information on our behalf, our advertising, marketing and analytics partners, as explained above, (iii) our group companies for the purposes set out above, persons or authorities where we are compelled by law, to the relevant entity in case of a merger, acquisition or collaboration, and other third parties where you have provided your consent. Your stories may be shared between application or website users. We share analytical data with Amplitude, Firebase.

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 supporting the activities you choose to engage in, and providing higher quality solutions and services to platform's customers.

We collect certain information from our users to provide them with a personalized experience on our platform. This section of the Privacy Policy outlines how we use the information we collect.

• Providing and Improving Our Services: We use the information we collect to provide and improve our services, including creating and maintaining user profiles, processing user content, and responding to user inquiries.
• Personalizing Your Experience: We use the information we collect to personalize your experience on our platform, such as suggesting content or users to connect with based on your activity such as your city or place, your occupation, your image, approximate home location, choices of interests and employment-related information, including your role and years of experience. Approximate home location is collected to show neighbors to each other through presenting distance between collected approximate user’s home locations.
• Display information about You: To share information about you with our platform users, such as your username, story, image and other user information which is visible by all members of our platform.
• Display information about events: To share information about events created by you with our platform users, such as your username, event description, uploaded images, other information which is visible by all members of our platform.
• Communicating with You: We may use the information we collect to communicate with you, such as to send you updates or promotional messages.
• Research and Development: We may use the information we collect for research and development purposes, such as to understand how our users are using our platform and to improve our services.
• Compliance with Laws and Regulations: We may use the information we collect to comply with applicable laws and regulations.
• Our mobile applications may also send push notifications to your mobile device. If you have previously consented to receiving push notifications and no longer wish to receive them, you can also turn push notifications off at the device level. Said applications may also request access to your device’s calendar application, camera, photo album and microphone. If you have previously allowed access to your device’s calendar, camera, photo album or microphone and no longer wish to allow access, you may edit the application settings at the device level.

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 privacy@epam.com.

Links

EPAM websites and applications 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 or application, 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 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 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: privacy@epam.com