Moscow
Latest Version dd. February 10, 2026
This Personal Data Processing Policy (hereinafter referred to as the “Policy”) has been drafted in accordance with the requirements of Federal Law No. 152-FZ of July 27, 2006, “On Personal Data” (hereinafter referred to as “FZ-152”).
This Policy establishes the procedure for the processing of personal data and the measures to ensure the security of personal data at JSC “PO “TYAZHPROMMASH” (hereinafter — the Operator) with the purpose of protecting the rights and freedoms of a person and a citizen during the processing of his or her personal data, including the protection of the rights to privacy, personal and family secrets.
This Policy also applies to all information that is located on the domain name https://po-tpm.com/ (hereinafter — the Website) and may be obtained about a User during the use of the Website, the Operator’s programs and products.
The following basic terms are used in this Policy:
1) personal data — any information relating to an identified or identifiable natural person (the subject of personal data);
2) operator means a state body, municipal body, legal entity, or natural person organizing and/or executing the processing of personal data independently or jointly with other persons, and also determining the purposes of personal data processing, the set of personal data subject to processing, and the actions (operations) performed with the personal data;
3) personal data processing means any action (operation) or a set of actions (operations), performed using automation means or without them, with personal data, including collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (distribution, provision, access), anonymization, blocking, deletion, or destruction of personal data;
4) automated personal data processing means the processing of personal data using automated means of computation;
5) personal data dissemination means any action aimed at disclosing personal data to an unspecified circle of persons;
6) provision of personal data means actions aimed at disclosing personal data to a specified person or a specified circle of persons;
7) personal data blocking means the temporary cessation of personal data processing (except where processing is necessary for the clarification of personal data);
8) personal data destruction means actions resulting in the irreversible destruction of personal data, making it impossible to further restore the content of the personal data in the personal data information system, and/or the destruction of the material carriers of the personal data;
9) personal data anonymization means actions that, without the use of additional information, make it impossible to determine the attribution of personal data to a specific subject of personal data;
10) personal data information system means a set of personal data contained in databases and the information technologies and technical means ensuring their processing;
11) cross-border transfer of personal data means the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign natural person, or a foreign legal entity;
12) User means a person who has access to the Website via the Internet and uses the Website.
The Company shall publish or otherwise ensure unrestricted access to this Personal Data Processing Policy in accordance with Part 2 of Article 18.1 of Federal Law No. 152-FZ.
Article 1. GENERAL PROVISIONS1. The User’s use of the Website constitutes consent to this Privacy Policy and to the terms of processing of the User’s personal data.
2. If the User does not agree with the terms of the Privacy Policy, the User must cease using the Website.
3. This Privacy Policy applies only to the Website. The Operator does not control and shall not be liable for third-party websites to which the User may navigate via links available on the Website.
4. Personal data permitted for processing under this Privacy Policy are provided by the User by completing the registration form on the Website and include the following information:
User’s surname, first name and patronymic;
User’s phone number;
e-mail address.
Article 2. PURPOSES OF COLLECTION AND PROCESSING OF USERS’ PERSONAL INFORMATION1. The Website collects and stores only such personal data as are necessary for the provision and delivery of services (for the performance of agreements and contracts with the User).
2. The Website may use the User’s personal information for the following purposes:
2.1. Identification of a party within the framework of agreements and contracts with the Website;
2.2. Provision of personalized services to the User;
2.3. Communication with the User, including the sending of notifications, inquiries, and information concerning the use of the Services, the provision of services, as well as the processing of requests and applications from the User;
2.4. Improvement of quality, convenience of use, and development of services;
2.5. Targeting of advertising materials;
2.6. Conducting statistical and other research based on anonymized data.
Article 3. PRINCIPLES OF PERSONAL DATA PROCESSING1. The Operator processes personal data on the basis of the following principles:
Lawfulness and fairness;
limitation of personal data processing to the achievement of specific, predetermined and lawful purposes;
prohibition of processing personal data incompatible with the purposes for which the personal data were collected;
prohibition of combining databases containing personal data processed for purposes that are incompatible with each other;
processing only such personal data as correspond to the purposes of their processing;
correspondence of the content and scope of the processed personal data to the declared purposes of processing;
prohibition of processing personal data that are excessive in relation to the declared purposes of their processing;
ensuring the accuracy, sufficiency and relevance of personal data in relation to the purposes of personal data processing;
destruction or anonymization of personal data upon attainment of the purposes of their processing or in case of loss of necessity to attain such purposes, and in the event that the Operator is unable to eliminate violations committed with respect to personal data, unless otherwise provided by federal law.
Article 4. CONDITIONS FOR PERSONAL DATA PROCESSING1. The Operator conducts the processing of personal data where at least one of the following conditions exists:
1.1. Personal data processing is carried out with the consent of the subject of personal data for the processing of their personal data;
1.2. Personal data processing is necessary for achieving the purposes stipulated by an international treaty of the Russian Federation or by law, or for the fulfillment of functions, powers, and duties vested in the Operator by the legislation of the Russian Federation;
1.3. Personal data processing is necessary for the administration of justice, the execution of a judicial act, an act of another body, or an official, subject to execution in accordance with the legislation of the Russian Federation on enforcement proceedings;
1.4. Personal data processing is necessary for the execution of a contract to which the subject of personal data is a party, or for which the subject is a beneficiary or guarantor, as well as for concluding a contract at the initiative of the subject of personal data or a contract under which the subject of personal data will be a beneficiary or guarantor;
1.5. Personal data processing is necessary to exercise the rights and legitimate interests of the Operator or third parties, or to achieve socially significant goals, provided that the rights and freedoms of the subject of personal data are not violated thereby;
1.6. Processing of personal data, access to which has been granted by the subject of personal data to an unlimited circle of persons or at their request (hereinafter referred to as “Publicly Available Personal Data”), is carried out;
1.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
Article 5. WAYS AND TIMELINES OF PROCESSING PERSONAL INFORMATION1. The processing and storage of the User’s personal data shall be carried out for an unlimited period, by any lawful means, including in personal data information systems using automated means or without the use of such means.
2. The User’s personal data may be transferred to authorized state authorities of the Russian Federation only on the grounds and in the manner established by the legislation of the Russian Federation.
Article 6. CONFIDENTIALITY OF PERSONAL DATA1. The Operator and other persons who have obtained access to personal data are obliged not to disclose to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise provided by federal law.
2. The Operator shall adopt the necessary organizational and technical measures to protect the User’s personal information from unlawful or accidental access, destruction, alteration, blocking, copying, dissemination, as well as from other unlawful actions of third parties.
Article 7. PUBLICLY AVAILABLE SOURCES OF PERSONAL DATA1. For the purposes of informational support, the Operator may create publicly available sources of personal data of data subjects, including directories and address books. With the written consent of the data subject, his/her surname, first name and patronymic, date and place of birth, position, contact telephone numbers, e-mail address and other personal data provided by the data subject may be included in publicly available sources of personal data.
2. Information about a data subject shall be removed from publicly available sources of personal data at any time upon the request of the data subject or by decision of a court or other authorized state bodies.
Article 8. SPECIAL CATEGORIES OF PERSONAL DATA1. The Operator’s processing of special categories of personal data concerning race, national origin, political opinions, religious or philosophical beliefs, health status, or intimate life is permitted in cases where:
1.1. the personal data subject has given written consent to the processing of his/her personal data;
1.2. the personal data have been made publicly available by the data subject;
1.3. processing of personal data is carried out in accordance with legislation on state social assistance, labor legislation, and the legislation of the Russian Federation on state pension provision and on labor pensions;
1.4. processing of personal data is necessary to protect the life, health or other vital interests of the data subject or to protect the life, health or other vital interests of other persons and obtaining the data subject’s consent is impossible;
1.5. processing of personal data is carried out for medical and preventive purposes, for the establishment of a medical diagnosis, or for the provision of medical and medico‑social services, provided that the processing of personal data is performed by a person professionally engaged in medical activity and obliged, in accordance with the legislation of the Russian Federation, to preserve medical confidentiality;
1.6. processing of personal data is necessary for the establishment or exercise of the rights of the data subject or of third parties, as well as in connection with the administration of justice.
2. The processing of special categories of personal data shall be terminated without delay if the grounds on the basis of which such processing was carried out have ceased to exist, unless otherwise established by federal law.
3. The processing of personal data relating to convictions and offences may be carried out by the Operator exclusively in cases and in the manner determined in accordance with the federal laws.
Article 9. BIOMETRIC PERSONAL DATAInformation that characterizes the physiological and biological features of a person by virtue of which their identity can be established — biometric personal data — may be processed by the Operator only in the presence of the data subject’s consent in writing.
Article 10. TRANSFER OF PERSONAL INFORMATION TO THIRD PARTIES1. The Website shall have the right to transfer the User’s personal information to third parties in the following cases:
1.1. The User has given his/her consent to such actions;
1.2. The transfer is necessary in the course of the User’s use of a particular Service or for the provision of a service to the User;
1.3. The transfer is provided for by Russian or other applicable law in accordance with the procedure established by such law;
1.4. Such transfer occurs in connection with the sale or other transfer of the business (in whole or in part), in which case the purchaser shall assume all obligations to comply with the terms of this Policy with respect to the personal information received by it;
1.5. For the purpose of ensuring the possibility of protecting the rights and legitimate interests of the Website or third parties in cases where the User violates the User Agreement of the Site’s services.
2. In processing the Users’ personal data, the Website is guided by the Federal Law of the Russian Federation “On Personal Data.”
Article 11. CROSS-BORDER TRANSFER OF PERSONAL DATA1. The Operator shall ensure that the foreign state to whose territory the transfer of personal data is intended to be made provides adequate protection of the rights of personal data subjects prior to the commencement of such transfer.
2. Cross‑border transfer of personal data to territories of foreign states that do not ensure adequate protection of the rights of personal data subjects may be carried out in the following cases:
2.1. the data subject has given their written consent to the cross‑border transfer of their personal data;
2.2. performance of a contract to which the data subject is a party.
Article 12. CONSENT OF THE DATA SUBJECT TO THE PROCESSING OF THEIR PERSONAL DATA1. The data subject makes a decision on providing their personal data and gives consent to personal data processing freely, of their own will and in their own interest. Consent to the processing of personal data may be given by the data subject or their representative in any form that allows confirmation of the fact of its receipt, unless otherwise provided by federal law.
2. The obligation to provide evidence of obtaining the consent of the data subject to the processing of their personal data, or evidence of the existence of grounds specified in Federal Law No. 152‑FZ, rests with the Operator.
Article 13. RIGHTS OF THE DATA SUBJECT1. The data subject shall have the right to obtain from the Operator information concerning the processing of their personal data, unless such right is restricted in accordance with federal laws. The data subject shall have the right to require the Operator to clarify their personal data, to block or destroy them if the personal data are incomplete, outdated, inaccurate, unlawfully obtained, or are not necessary for the declared purpose of processing, by means of a written request to the Operator, including by electronic means of communication to the addresses specified on the Operator’s Website, and to take measures provided by law to protect their rights.
2. The processing of personal data for the purposes of promoting goods, works, or services on the market by means of direct contacts with a potential consumer using means of communication, as well as for the purposes of political campaigning, shall be permitted only on condition of the prior consent of the data subject. Such processing of personal data shall be deemed to have been carried out without the prior consent of the data subject if the Company does not prove that such consent was obtained.
3. The Operator shall immediately cease, at the request of the data subject, the processing of their personal data for the purposes specified above.
4. It is prohibited to make decisions based solely on the automated processing of personal data that produce legal effects in relation to the data subject or otherwise affect their rights and lawful interests, except in cases provided for by federal laws or where the data subject has given their written consent.
5. If the data subject believes that the Operator is processing their personal data in violation of the requirements of Federal Law No. 152‑FZ or otherwise violates their rights and freedoms, the data subject shall have the right to appeal the actions or omissions of the Operator to the authorized body for the protection of the rights of personal data subjects or in court.
Article 14. OBLIGATIONS OF THE PARTIES1. The User shall:1.1. Provide personal data information necessary for the use of the Website.
1.2. Update and supplement the provided personal data information in the event of changes to such information.
2.
The Operator shall:2.1. Use the obtained information exclusively for the purposes specified in this Privacy Policy.
2.2. Ensure that confidential information is kept secret, not disclose it without the User’s prior written permission, and not sell, exchange, publish or otherwise disclose the User’s personal data transmitted to it, except in the cases provided for in Article 10 of this Privacy Policy.
2.3. Take precautionary measures to protect the confidentiality of the User’s personal data in accordance with the procedures customarily used to protect such information in current commercial practice.
2.4. Block the personal data relating to the relevant User from the moment of receipt of a request from the User or their legal representative or an authorized body for the protection of the rights of personal data subjects for the period of verification, in the event of detection of inaccurate personal data or unlawful actions.
Article 15. LIABILITY OF THE PARTIES1. In the event of loss or disclosure of Confidential Information, the Operator shall not be liable if such confidential information:
1.1. Became publicly available prior to its loss or disclosure.
1.2. Was obtained from a third party prior to its receipt by the Website Administration.
1.3. Was disclosed with the User’s consent.
Article 16. DISPUTE RESOLUTION1. Prior to filing a claim in court in respect of disputes arising out of relations between the Website User and the Operator, the submission of a claim (a written proposal for voluntary settlement of the dispute) is mandatory.
2. The recipient of the claim shall, within 30 calendar days from the date of receipt of the claim, notify the claimant in writing of the results of consideration of the claim.
3. If an agreement is not reached, the dispute shall be referred to a judicial authority in accordance with the applicable legislation of the Russian Federation.
4. The current legislation of the Russian Federation shall apply to this Privacy Policy and to relations between the User and the Operator.
Article 17. ADDITIONAL TERMS1. The Operator shall have the right to amend this Privacy Policy without the User’s consent.
2. The new Privacy Policy shall enter into force from the moment it is posted on the Site, unless otherwise provided by the new edition of the Privacy Policy.
3. All proposals or questions regarding this Privacy Policy shall be sent to the following email address:
info@po-tpm.com 4. The current Privacy Policy is posted at
https://po-tpm.com/ 5. Operator’s location: 105005, Moscow, Baumanskaya St., 7, bldg. 1, office 47