I. Glossary – basic conceptsPersonal data – all information related to you that we process. For example first name, last name, e-mail address, telephone number, information about your professional experience, etc.
Processing – all activities performed relating to your personal data. For example: collecting, retaining, updating, sending messages to you, deleting data.
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).
II. Information about GlobalLogic – the data controllerThis information applies to companies of the GlobalLogic group. The list of the companies along with their contact details is provided at the end of this document. Notwithstanding, please remember that you can contact us anytime at firstname.lastname@example.org.
As a rule, each of the companies independently decides about the purposes and methods of personal data processing, which means that each of them is a separate data controller – depending on which company you contact, conclude a contract with, run business relations with etc., this company, usually, will be the data controller of your personal data.
It may also happen that a particular company performs activities for another company from the GlobalLogic group, e.g. related to marketing – in this case, the company that performs such activities does not become the data controller of your personal data, but processes it on the basis of a data processing agreement concluded with the data controller.
III. What personal data do we gather? What is the purpose and legal basis of processing?We can process your personal data in the following situations:
- when you are our prospective or actual client, supplier or contractor;
- when you are interested in our activities (e.g. as the media);
- when you are acting on behalf of one of the persons/entities mentioned above, including when you are its employee or associate.
- when you have provided us with your personal data through various communication channels (e.g. by sending an inquiry/ offer via e-mail, telephone or form on our website);
- as a part of our cooperation when signing or performing a contract, including when your personal data have been disclosed to us as a contact for the purpose of execution of a contract;
- when we have obtained your personal data from other sources (e.g. from the company which you cooperate with and which is our contractor/ client, including from another company of the GlobalLogic group, during events, or from publicly available sources/ websites).
- it primarily encompasses the content of documents, our correspondence/ communication, along with other information we have obtained from publicly available sources (e.g. LinkedIn). These data include in particular:
- identification data, including first name and last name,
- information regarding professional activity, including place of employment, position and/or department, qualifications;
- contact details, including correspondence address, telephone number, e-mail address or other contact information.
If you are contacting us on your own behalf, for example, you have given us your business card with a request to send you particular information, we process your data in order to respond to your query and for the purpose of further correspondence/ contact in this matter. The legal basis for the processing of your personal data in accordance with this purpose will be your consent (Art. 6(1)(a) GDPR).
If you are acting on behalf of our client, supplier, or another entity, we process your data in the context in which you are acting in the name of the third party, as well as for the conclusion and/or processing of a contract with that third party and/or carry out a joint project. The legal basis for processing of your personal data in accordance with this purpose will be our legitimate interest (Art. 6(1)(f) GDPR) – building and maintaining relations with the third party in whose name you are acting, including the conclusion and performance of relevant contracts with that party, as well as the intention of building a positive image of GlobalLogic.
Regardless of the foregoing, your personal data, that is, in particular, your first name and last name, as well as correspondence address and/or e-mail address, can be used by us in order to contact you from time to time (for example, to say thank you, send holiday season greetings, or to promote GlobalLogic’s services). The legal basis for the processing of your personal data in accordance with this purpose will be our legitimate interest (Art. 6(1)(f) GDPR) – maintaining relations, building a positive image of GlobalLogic and marketing of GlobalLogic’s products and services.
Additionally, with regard to the processing of your personal data in order to:
- defend against potential claims, as well as for the purpose of potential directing claims – the legal basis for the processing of your personal data will be our legitimate interest (Art. 6(1)(f) GDPR);
- fulfill legal obligations of the data controller (e.g. tax, accounting) – the legal basis for the processing of your personal data will be the necessity for compliance with a legal obligation to which the controller is subject (Art. 6(1)(c) GDPR).
- technical information, including the IP address used to connect the computer to the Internet, logging information, the type and version of web browser, time zone settings, types and versions of browser plugins, operating system and platform;
- information about your visit, including full URL, click path to, around and from our website (including time and date), services you browsed or searched for, response times, errors in downloading, duration of visit on some pages, information about interactions on the page (scrolling, clicking, mouse movements), methods used to exit the page, telephone number and/or social media used.
IV. Your imageFrom time to time GlobalLogic may organize a promotional event, e.g. a conference, fairs, lecture (“Event”), which you may attend e.g. as a guest, speaker, host, etc. (“Participant”). Events are usually recorded on videos or photographs, therefore your image, including voice (e.g. comment/ speech) (“Image”) may be recorded and used in materials informing about the Event and for promotional purposes of GlobalLogic.
To the extent permissible by law, where for the above activities of GlobalLogic the applicable law requires a consent of the person whose image has been recorded, participation in the Event is equivalent to each Participant granting free of charge consent to the use and multiple dissemination – without limitations in terms of territory, medium, time and number of copies – of their Image recorded during the Event on photographs or in audio-visual materials by GlobalLogic or third parties acting on its behalf, for informational and promotional purposes of GlobalLogic or entities from GlobalLogic group (“Authorization”). The Authorization is given voluntarily and may be revoked at any time.
The use and dissemination of the Image will consist, without limitations, of its publication in the original form or in a processed form (i.e. edited), including on the website of GlobalLogic, entities from the GlobalLogic group, GlobalLogic’s partners, on the intranet, in social media (Facebook, YouTube, Vimeo, LinkedIn, etc.), sending via e-mail, newsletter, use in public speeches, on conferences, fairs, in a way allowing it to be seen by a group of people not specified in advance.
This Authorization covers multiplication of the Image with any currently available techniques and methods, on any image and/or sound storage devices, including saving in computer memory, IT networks, as well as selling, lending or leasing copies of recorded materials. It also covers authorisation to use various types of electronic image processing, framing and composition, to combine Image with images of other people, add text and/or graphics to the Image (including Participant's name and surname), at the discretion of GlobalLogic – without an obligation to accept final product, however, not in a form that may be offensive or is generally deemed to be unethical.
We will process your Image until you object to processing or withdraw the Authorization, however, due to the planned dissemination of photo/video, your Image may be available in the mediums such as the Internet for an indefinite period of time, and the group of recipients of your Image is therefore unlimited.
V. Duration of retention of your personal dataWe will process your personal data only at a time necessary for the purposes for which it was initially collected. After that time, it will be deleted or archived, except for cases in which we are obliged to further processing of such data to meet legal obligations.
As a rule, personal data:
- collected for the purposes of conclusion and performance of a contract – will be processed for the duration of the contract and its settlement;
- processed on the basis of our legitimate interest – will be processed until the objection to the processing or the fulfillment of the purpose for which it has been processed;
- processed on the basis of your consent – will be processed until its possible withdrawal or fulfillment of the purpose for which it was given; unless the law (e.g. regarding archiving, taxation, accounting) obliges us to process such data for a longer period, or in case of potential claims, for such claim’s limitation period specified by law – whichever is the longer. The above periods may be extended, as appropriate, in the event of court proceedings – for the duration of these proceedings and their settlement
VI. Who has access to your personal data?Your personal data will only be accessed by duly authorized GlobalLogic employees or associates, advisors or auditors, as well as subcontractors or providers of solutions/ services – to the extent necessary to perform their duties.
We are a global company, which means that some companies from the GlobalLogic group are located outside the European Economic Area (EEA). In each case of data transmission outside the EEA, we apply all required safeguards, including standard data protection clauses adopted pursuant to decisions of the European Commission. Where it is necessary, we also endeavor to ensure that our partners are covered by appropriate programs such as Privacy Shield. Additionally, in order to protect personal data, both when sending and after receiving it, we apply generally accepted standards. You can obtain a copy of the security measures we apply for the transfer of personal data to third countries by contacting us at privacy@GlobalLogic.com.
GlobalLogic may also be required - if there is a legal basis to do so - to provide certain information to public authorities for the purposes of their investigations.
VII. Your rights related to the processing of your personal dataFor the effective exercise of your rights, please send any requests to the e-mail address privacy@GlobalLogic.com from the contact address you have provided, along with the title “GDPR Request.”, and in the e-mail, please specify which right(s) it is you wish to invoke. Please note that the instructions given in the preceding sentence are only a recommendation, not a requirement. You have the following rights:
VII.1. Access to your personal data – you may ask us at any time to provide detailed information regarding:
- whether we are processing your personal data;
- for what purpose;
- what categories of data we are processing;
- who is the recipient of your data;
- what is the planned duration of processing (if possible), and if we are not able to say, the criteria for determining that duration;
- if the personal data has not been given by you – all available information about the source of the data.
VII.2. Data rectification – if information about you is or has become inaccurate or incomplete, you have the right to demand that data is rectified or made complete.
VII.3. Revocation of consent – you can revoke your consent to the processing of your personal data at any time (if it was given), without affecting the legality of processing performed prior to such revocation.
VII.4. Erasure of data – in certain situations, GDPR gives you the “right to be forgotten.” You can invoke this right if we are still processing your personal data, particularly in the following cases:
- the personal data is no longer vital for the purposes for which it was collected or otherwise processed;
- you revoke consent to the processing of personal data and there is no other legal basis for continuing to process it;
- you object to the processing of your personal data when there are no overriding, legitimate grounds for processing;
- you object to the processing of your personal data for marketing purposes;
- your data is processed in a manner that violates the law;
- the law requires that we erase your data.
- you question the correctness of personal data we are processing – for a period of time that allows us to determine the correctness of that data;
- the processing of your personal data violates the law, but you prefer that processing be restricted rather than the data be erased;
- GlobalLogic no longer needs your personal data for the purposes of processing, but you need it for establishing, pursuing, or defending legal claims;
- you have objected to the processing of your personal data – only until such time as it is determined whether your interests take precedence over our legitimate interests.
- processing is done on the basis of your consent or a contract; and
- processing is done in an automated manner.
- when our processing is based on our legitimate interest;
- when we process your personal data for purposes related to scientific or historical studies, or for statistical purposes.
VII.8. Complaints to the relevant public authority - in connection with our actions as the controller of your personal data, you have the right to file a complaint to the relevant data protection authority. You can find a list of local authorities responsible for data protection across the EU and their contact details at: https://edpb.europa.eu/about-edpb/board/members_en.Of course, we encourage you to first contact us at privacy@GlobalLogic.com.