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Thank you for using the services of EPAM Systems, Inc. (“EPAM”). This Privacy Policy (the “Policy”) is here to explain how we collect and use certain information form you when you use our services or website. By continuing to use our services and website you give us consent to collect and use your information as described below. If you do not consent, you are prohibited from using our services and website.

WHAT INFORMATION IS COLLECTED.

We will have access to the information you voluntarily provide to us. Such information may include, but may not be limited to, your name and email address. We also collect other information, such as your device’s IP address, information on your use of our services, your internet service provider, the type operating system you use, and the URL’s of websites you visited linking to us or from us. We also collect information on any custom tags you use and searches you perform.

All information collected may be anonymized and aggregated to enhance the research and search functions of our services, to improve the quality and usability of our services.

We do not knowingly collect personal information from children under the age of thirteen.

USE OF INFORMATION COLLECTED.

We will only use your personal information for the purposes for which it was collected, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose.  If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. We may use the information we collect from you for the following:

·       to respond to your requests, searches, and orders

·       to personalize the content and services provided to you

·       to inform you of any maintenance or upgrades we may perform

·       to inform you of any new products, versions, services, features or promotions

·       to inform you of the best way to optimize your use of our services and website

·       to optimize the functionality of our services and website

·       to improve our understanding of users’ needs

SHARING OF INFORMATION.

We may disclose your personal information to the following categories of recipients:

·       to EPAM’s 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.

THIRD PARTY WEBSITES.

We are not responsible for the use or misuse of any information that you may provide to third party websites to which we may provide a link. We do not control such third party websites, including the methods by which they collect information or how they use such collected information. You should independently review the privacy policies of such third party websites.

PROTECTION.

We use various administrative, technical, procedural and physical measures to protect the information we collect against theft, unauthorized use, disclosure or modification, 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. We have 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. To better protect this information you should not share your login or account information with anyone other than authorized persons.

All companies and individuals we employ or may employ to perform various functions on our behalf are required to protect the information in a manner that is consistent with this Policy.

Please be aware that any information you post to a blog or any other forum provided by our website or through our services, will be available to all persons accessing these blogs or forums, and as such may be collected or used by others for any purpose. We are not responsible for any information you elect to submit in such blogs or forums, or for the way any such information may be used or misused by third parties.

SHARING INFORMATION.

We will not share your personal information with (or sell it to) anyone except (a) our service providers or subcontractors with whom we deal in connection with providing, modifying, operating or updating the services, and in such cases, only for those purposes, (b) to comply with the law or in response to a subpoena, court order, government request, law enforcement request or other legal process, (c) to protect our interests, rights, safety, or property, (d) to protect the interests, rights, safety, or property of our contributors, affiliates, partners, or licensors, and (e) to enforce our Terms of Use, our contractual rights, or this Policy.

OTHER COUNTRIES.

Your information may be stored and processed in the United States or any other country where EPAM has facilities, and by subscribing to and/or using our services, you consent to the transfer of information outside of your country (to the extent that any such information is generated in your country). Please note that other countries may have higher or lower standards for the protection of personally information, but we will always endeavor to protect such information and take reasonable steps to do so in accordance with this policy and applicable laws, including, (where applicable) 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. In countries where it may be required, you will be permitted to correct any inaccurate personally information, opt out of provision of such information to third parties, and/or delete such information, subject to our right to limit or no longer provide the services to you if you delete information necessary for us to provide them.

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 unsubscribing here or by using the “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.

CALIFORNIA CONSUMER PRIVACY ACT (CCPA).

The CCPA provides residents in California with the additional rights as set out below. If you are a Californian resident, you have the right not to be discriminated against for exercising any of the rights listed below.

We collect your personal information as set out in the “What Information is Collected” paragraph above. The categories of information described above generally fall within the following categories that are defined under the CCPA: Identifiers; Personal information listed in the California Customer Records Statute; internet or similar network activity; geolocational data; and inferences drawn from other personal information.

We may disclose your personal information to a third party (such as service providers) for a business purpose. When we disclose personal information for a business purpose, it enters a contract that describes the purpose and requires the recipient to keep your personal information confidential and not to use it for any purpose other than performing its contract with us. The CCPA prohibits third parties who purchase the personal information we hold from reselling it, unless you have received explicit notice and an opportunity to opt-out of further sales.

Right to Know. You have the right to request what data we have collected about you over the past 12 months once a verifiable consumer request is confirmed, including:

·       The categories of personal information we have collected about you.

·       The categories of sources from which the personal information is collected.

·       The business or commercial purpose for collecting your personal information.

·       The categories of third parties with whom we have shared your personal information.

·       The specific pieces of personal information we have collected about you.

·       If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

o    sales, identifying the personal information categories that each category of recipient purchased; and 

o    disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Delete. You have the right to request that we delete the personal information it has collected from you (and require its service providers to do the same), once a verifiable consumer request is confirmed. There are a number of exceptions including, without limitation, when the information is necessary for us or a third party to:

·       Complete your transaction.

·       Provide you a good or service.

·       Perform a contract.

·       Protect your security and prosecute those responsible for breaching it.

·       Fix its system in the case of a bug.

·       Protect the free speech rights of you or other users.

·       Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).

·       Engage in public or peer-reviewed scientific, historical, or statistical research in the public interests that adheres to all other applicable ethics and privacy laws.

·       Comply with a legal obligation.

·       Make other internal and lawful uses of the information that are compatible with the context in which you provided it.

Do Not Sell My Personal Information. If you would like to opt-out of us selling your personal information then please click on the following link. The sale of personal information does not include (a) if you direct us to interact with a third party, (b) the sharing of information is necessary to perform a business purpose, or (c) information that is transferred as part of an asset in a merger, acquisition, bankruptcy or other change of control of the business. Note that third parties receiving data from us cannot resell your personal information unless you have explicitly consented and are given an opportunity to exercise your right to opt-out. This applies even if you have not opted out of the sale of your personal information under this paragraph.

Other Californian Residents’ Rights. You have the right to request, once a year, from us (at no charge) a list of third party companies that we have shared your personal information with for use by such third party companies in their direct marketing campaigns during the preceding calendar year.

To request access to or deletion of your personal information, or to exercise any other data rights under Californian law, please contact us using the contact details provided below. We aim to respond to a consumer request, once verified, for access or deletion within 45 days of receiving that request. If more time is required, we will inform you of the reason and extension period.

AMENDMENT OF MODIFICATION OF POLICY.

We reserve the right to change, amend or modify the terms of this Policy, with or without prior notice. We will make reasonable efforts to notify you of any change in this Policy that may require your consent under applicable data protection standards. Your continued use of our services and website constitutes your acceptance of those changes. All changes, amendments or modifications to the Policy will be posted here. Please return to this website at regular intervals to see whether the Policy has been changed, amended or modified.

CONTACT DETAILS.

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us. Additionally, if you have any questions about this Policy, the practices of EPAM or your interaction with us, 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