Privacy Policy

Last revised: 4^th December 2024

Introduction

First Derivative companies including entities of the entire EPAM group with EPAM Systems Inc. as its holding company (“we”)) respects your privacy and are committed to protecting your personal data. This privacy notice (“Notice”) will inform you as to how we look after your personal data, tell you about your privacy rights and how the law protects you. We recommend that you read this Notice in full to ensure that you have a clear understanding of the data that we collect or receive and how we use that data.

Purpose of this privacy notice

This privacy notice aims to give you information on how we collect or receive and process your personal data;

in connection with a business relationship
for marketing/sales purposes
through your use of our websites, including any data you may provide through the websites when you sign up to our newsletters, webinars and events or purchase/trial a product or service and by corresponding with us, either through networking events or email/phone interaction
through your use of our community channels/forums.

This website is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this Notice together with any other privacy policy or notice or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

About us

We are a global technology provider with more than 30 years of experience working with some of the world’s largest finance, technology, automotive, utility, manufacturing and energy institutions. We are experts in KX technology incorporating the kdb+ time-series database, is a leader in high-performance, in-memory computing, streaming analytics and operational intelligence.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Business contact information – (e.g., your name, job title, mailing address, telephone number and/or email address)
Usage Data – includes information about how you use our website, products and services.
Marketing Data – includes your preferences in receiving marketing from us and your communication preferences.
Communications Data – includes any personal data you provide through your communication with chats, community channels etc.
Video/Image Data – includes footage which may be recorded during a sales, marketing or other business related call.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data which are used to identify you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences.

How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your business contact information by filling in forms or by corresponding with us by phone, email or otherwise. This includes personal data you provide when you purchase/trial a product or service, sign up to or attend our events or webinars, face to face through networking, download content or software from our website, interact with our chats/community channels, during a call or give us feedback/contact us.

Automated technologies or interactions. As you interact with our website, we may collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy below. Third parties or publicly available sources. We may receive personal data about you in the form of business contact data from various third-party providers and public sources.

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract that we are about to enter or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Where you have consented to being contacted by us.

Legal basis for processing the personal data

We rely on several different legal grounds for processing personal data including performance of a contract, consent and legitimate interest, depending on the circumstances surrounding the processing.

We may process personal data pursuant to specific purposes which are in our interests and that enable us to enhance the services we provide. For example, we may process Personal data pursuant to legitimate business purposes to respond to your inquiries and to fulfil your requests or to send you marketing information and offers (where permitted by law).

We will rely on consent to process Video/image footage of you which is obtained during sales, marketing or other business-related calls.

We may also from time to time rely on consent to process your data for marketing purposes particularly where this is required by law. You have the right to withdraw consent to marketing at any time by contacting us. Please see our section on “opting out” below.

If you are an individual from the EEA/UK, our legal basis for collecting and using personal data will depend on the personal data concerned and the specific context in which we collect it. However, we normally rely on our legitimate interests to collect personal data from you, except where such interests are overridden by your data protection interests or fundamental rights and freedoms.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the ‘contact us’ section below.

Purposes for which we will use your personal data

We may use and process your information based on the legal grounds and for the legitimate business purposes outlined in this Notice. We have set out below, a description of the ways we plan to use your personal data.

Note that we may process your personal data on more than one legal ground depending on the specific purpose for which we are using your data.

Personal data may be used for the following purposes;

Marketing purposes – We may use personal data to send you various marketing regarding our products and services via email or phone.
To make content and webinars available to you – We may process personal data provided by you to make available requested content or webinars.
To provide you with a service/product – personal data may be processed to provide you with products or services which may have been download from the website or purchased via other means.
Business purposes – We may use personal data for the purposes of exploring and maintaining a business relationship with you.
To enable you to attend an event – where you have provided your information to attend an event or and affiliated event. We may process this data to communicate further information to you which may be of interest.
Community forums/channels – personal data may be processed in connection with your participation in community forums/channels which you have signed up for.
To make suggestions and recommendations to you about goods or services that may be of interest to you – We may process your personal data to make available information We deem to be of interest to you regarding our products and services.
Support – Where applicable under a contract, we may process your personal data to provide support in connection with a product/service.

Marketing

Where permitted by law, you may receive marketing communications from us if you have requested information or purchased goods or services from us or where we have obtained you information for marketing purposes and you have not exercised your right to opt out of marketing. We may use your personal data along with other information to form a view on what we think may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

Third-party Marketing

If required by applicable law, we will get your express opt-in consent before we share your personal data with any third party for their marketing purposes.

Opting out and changing your marketing preferences

You can request to opt-out or change your preferences on how you would like to be contacted at any time by sending your request to FDOptOutMarketing@firstderivative.com.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase and for which we might need to process for other purposes and on other legal grounds.

Cookies

See our cookie policy for further information on how we use cookies and other similar technologies.

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, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

Please note that the use of online tracking mechanisms by third parties is subject to those third parties’ own privacy notice/policies, and not this Notice or our cookie policy. If you prefer to prevent third parties from setting and accessing cookies on your computer, you may set your browser to block cookies.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

Personal Data which you choose to provide through community forums/channels will be publicly available.

With regards disclosures of your personal data made by us, we may transfer personal data to our service providers and professional advisors, affiliates or other third parties in connection with our business operations, including any (potential) corporate or commercial transaction. Personal data may be shared as follows;

Personal data may be shared with third-party service providers that provide services to us, including billing and payment processing, customer service, advertising and marketing, consultancy services, security, usage and performance monitoring, processing or fulfilling orders and transactions, data hosting and storage, software support, auditing, conversational intelligence platforms, note takers and other IT systems, platforms and tools.
We may also share your information in connection with a substantial corporate transaction, such as a sale, transfer or merger of parts of our business or assets.
Personal data may also be shared to protect and defend our legal rights including the legal rights of affiliates, users, or the public as applicable, including to protect against fraud and malicious activity.
Information may also be shared with affiliates of the group (meaning any subsidiary, parent company or company under common control of EPAM Systems Inc.). Such affiliates will use your information only for the purposes described in this Notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

Personal data may be shared internationally in connection with the processing under this Notice either by us or any of the recipients set out above. Any transfers of your personal data from within the European Economic Area (EEA) or the United Kingdom (UK) to third parties outside the EEA/UK will be based on an adequacy decision or will be governed by the standard contractual clauses (EEA) or International data transfer agreement/addendum (UK) (as applicable). Any non-EEA/UK related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction and are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected, received or obtained it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to;

Request access to or ask that we change, update, or delete your personal data at any time.
Withdraw your consent at any time, where we are processing your data on the legal ground of consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.
Opt out of receiving marketing communications from us

If you are a resident of the European Economic Area (EEA), you may also have the right to:

Object to processing of your personal data, restrict processing of your personal data or request portability of your personal data.
Complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or refuse to comply with your request if your request is clearly unfounded, repetitive or excessive. we try 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, we will notify you and keep you updated.

Updates to the privacy notice

We keep our Notice under regular review. This version was last updated on 2 December 2024. If we make any material changes, we will notify you by means of a notification on our website.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy/notice of every website you visit.

Contact details

If you have any questions about this privacy notice or our privacy practices, please contact us:

By Mail;
FAO: Data Privacy team
The Conlon Building, 1-2A Marcus Square, Newry, Co Down, N. Ireland, BT34 1AY
By Email
Email us at: privacy@epam.com

You have the right to make a complaint at any time to your relevant supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance. The Information Commissioner’s Office (ICO) is the UK supervisory authority for data protection issues (www.ico.org.uk).