Personal Data Processing Policy
1. General Provisions
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 the “Data Protection Law”), and defines the procedure for processing personal data and the measures taken by JSC “PO “TYAZHPROMMASH” (hereinafter referred to as the “Operator”) to ensure the security of such data.
1.1. The Operator’s paramount goal and a mandatory condition for its activities is the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy, and personal and family secrets.
1.2. This Policy regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain from visitors to the website: https://po-tpm.com/
2. Key Definitions Used in the Policy
2.1. Automated Personal Data Processing means the processing of personal data using automated means of computation.
2.2. Personal Data Blocking means the temporary cessation of personal data processing (except where processing is necessary for the clarification of personal data).
2.3. Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the network address: https://po-tpm.com/
2.4. Personal Data Information System means a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. 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 User or any other subject of personal data.
2.6. 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.
2.7. 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.
2.8. Personal Data means any information relating directly or indirectly to a specified or identifiable User of the website https://po-tpm.com/
2.9. Personal Data Authorized for Dissemination by the Subject means personal data whose access by an unlimited circle of persons has been granted by the subject of personal data by giving consent to the processing of personal data authorized for dissemination by the subject of personal data in the manner prescribed by the Data Protection Law (hereinafter referred to as “Data Authorized for Dissemination”).
2.10. User means any visitor of the website https://po-tpm.com/
2.11. Provision of Personal Data means actions aimed at disclosing personal data to a specified person or a specified circle of persons.
2.12. Personal Data Dissemination means any action aimed at disclosing personal data to an unspecified circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in mass media, posting in information and telecommunication networks, or providing access to personal data by any other means.
2.13. 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.
2.14. Personal Data Destruction means any action 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.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
3.2. The Operator is obligated to:
4. Key Rights and Obligations of Personal Data Subjects
4.1. Subjects of Personal Data have the right to:
4.2. Subjects of Personal Data are obligated to:
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another subject of personal data without the latter’s consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing personal data incompatible with the purposes of personal data collection is not permitted.
5.3. The combination of databases containing personal data processed for purposes incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of their processing shall be subject to processing.
5.5. The content and volume of processed personal data shall correspond to the declared purposes of processing. Excessive processing of personal data relative to the declared purposes of its processing is not permitted.
5.6. During personal data processing, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure their adoption for the deletion or clarification of incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the subject of personal data, no longer than required for the purposes of processing personal data, unless the data retention period is established by federal law, a contract, where the subject of personal data is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or in case the necessity for achieving these purposes is lost, unless otherwise stipulated by federal law.
6. Purposes of Personal Data Processing
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the subject of personal data for the processing of their personal data.
7.2. 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.
7.3. 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.
7.4. 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.
7.5. 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.
7.6. 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.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary for the full execution of the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the preservation of personal data and takes all possible measures to exclude unauthorized access to the personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of identifying inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address (info@po-tpm.com) marked “Personal Data Update.”
8.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different term is established by a contract or current legislation. The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator via email to info@po-tpm.com marked “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data acknowledges and agrees with the terms of the aforementioned documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions on the transfer (other than access provision), as well as restrictions on the processing or conditions for processing personal data authorized for dissemination, established by the subject of personal data, shall not apply in cases of personal data processing in the public, social, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows the identification of the subject of personal data, no longer than required for the purposes of processing personal data, unless the data retention period is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. The cessation of personal data processing may be triggered by the achievement of the personal data processing purposes, the expiration of the period of consent granted by the subject of personal data, the withdrawal of consent by the subject of personal data or a request to cease processing, as well as the detection of unlawful processing of personal data.
9. Set of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such transfer.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such transfer (such notification shall be sent separately from the notification regarding the intention to process personal data).
10.2. Prior to submitting the aforementioned notification, the Operator must obtain relevant information from the authorities of a foreign state, foreign natural persons, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise stipulated by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding issues of interest concerning the processing of their personal data by contacting the Operator via email at info@po-tpm.com.
12.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at the address: https://po-tpm.com/personal data.
1. General Provisions
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 the “Data Protection Law”), and defines the procedure for processing personal data and the measures taken by JSC “PO “TYAZHPROMMASH” (hereinafter referred to as the “Operator”) to ensure the security of such data.
1.1. The Operator’s paramount goal and a mandatory condition for its activities is the observance of the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy, and personal and family secrets.
1.2. This Policy regarding the processing of personal data (hereinafter referred to as the “Policy”) applies to all information that the Operator may obtain from visitors to the website: https://po-tpm.com/
2. Key Definitions Used in the Policy
2.1. Automated Personal Data Processing means the processing of personal data using automated means of computation.
2.2. Personal Data Blocking means the temporary cessation of personal data processing (except where processing is necessary for the clarification of personal data).
2.3. Website means a set of graphic and informational materials, as well as computer programs and databases, ensuring their accessibility on the Internet at the network address: https://po-tpm.com/
2.4. Personal Data Information System means a set of personal data contained in databases and the information technologies and technical means ensuring their processing.
2.5. 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 User or any other subject of personal data.
2.6. 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.
2.7. 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.
2.8. Personal Data means any information relating directly or indirectly to a specified or identifiable User of the website https://po-tpm.com/
2.9. Personal Data Authorized for Dissemination by the Subject means personal data whose access by an unlimited circle of persons has been granted by the subject of personal data by giving consent to the processing of personal data authorized for dissemination by the subject of personal data in the manner prescribed by the Data Protection Law (hereinafter referred to as “Data Authorized for Dissemination”).
2.10. User means any visitor of the website https://po-tpm.com/
2.11. Provision of Personal Data means actions aimed at disclosing personal data to a specified person or a specified circle of persons.
2.12. Personal Data Dissemination means any action aimed at disclosing personal data to an unspecified circle of persons (transfer of personal data) or at familiarizing an unlimited circle of persons with personal data, including the publication of personal data in mass media, posting in information and telecommunication networks, or providing access to personal data by any other means.
2.13. 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.
2.14. Personal Data Destruction means any action 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.
3. Key Rights and Obligations of the Operator
3.1. The Operator has the right to:
- Receive authentic information and/or documents containing personal data from the subject of personal data;
- In the event the subject of personal data withdraws consent for personal data processing, or submits a request to cease processing personal data, the Operator is entitled to continue processing personal data without the subject’s consent if grounds specified in the Data Protection Law exist;
- Independently determine the composition and list of measures necessary and sufficient to ensure compliance with the obligations stipulated by the Data Protection Law and regulatory legal acts adopted in accordance with it, unless otherwise stipulated by the Data Protection Law or other federal laws.
3.2. The Operator is obligated to:
- Provide the subject of personal data, upon request, with information regarding the processing of their personal data;
- Organize the processing of personal data in the manner established by the current legislation of the Russian Federation;
- Respond to appeals and requests from subjects of personal data and their legal representatives in accordance with the requirements of the Data Protection Law;
- Notify the authorized body for the protection of the rights of personal data subjects of any required information within 10 days from the date of receipt of such a request;
- Publish or otherwise ensure unrestricted access to this Personal Data Processing Policy;
- Take legal, organizational, and technical measures to protect personal data from unlawful or accidental access, destruction, modification, blocking, copying, provision, distribution, as well as from other unlawful actions concerning personal data;
- Cease the transfer (dissemination, provision, access), cease processing, and destroy personal data in the manner and cases stipulated by the Data Protection Law;
- Fulfill other obligations stipulated by the Data Protection Law.
4. Key Rights and Obligations of Personal Data Subjects
4.1. Subjects of Personal Data have the right to:
- Receive information concerning the processing of their personal data, except in cases provided for by federal laws. Such information shall be provided to the subject by the Operator in an accessible format and shall not contain personal data relating to other subjects of personal data, unless there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Data Protection Law;
- Require the Operator to clarify their personal data, block it, or destroy it if the personal data is incomplete, outdated, inaccurate, unlawfully obtained, or not necessary for the declared purpose of processing, and to take measures provided by law to protect their rights;
- Set a condition for prior consent when processing personal data for the purpose of marketing goods, works, and services;
- Withdraw consent for personal data processing, as well as submit a demand to cease personal data processing;
- Appeal unlawful actions or inaction of the Operator in processing their personal data to the authorized body for the protection of personal data subjects’ rights or through the courts;
- Exercise other rights stipulated by the legislation of the Russian Federation.
4.2. Subjects of Personal Data are obligated to:
- Provide the Operator with accurate data about themselves;
- Inform the Operator about the clarification (updating, modification) of their personal data.
4.3. Persons who have provided the Operator with unreliable information about themselves, or information about another subject of personal data without the latter’s consent, shall be liable in accordance with the legislation of the Russian Federation.
5. Principles of Personal Data Processing
5.1. The processing of personal data shall be carried out on a lawful and fair basis.
5.2. The processing of personal data shall be limited to achieving specific, predetermined, and lawful purposes. Processing personal data incompatible with the purposes of personal data collection is not permitted.
5.3. The combination of databases containing personal data processed for purposes incompatible with each other is not permitted.
5.4. Only personal data that meets the purposes of their processing shall be subject to processing.
5.5. The content and volume of processed personal data shall correspond to the declared purposes of processing. Excessive processing of personal data relative to the declared purposes of its processing is not permitted.
5.6. During personal data processing, the accuracy of personal data, its sufficiency, and, where necessary, its relevance to the purposes of processing shall be ensured. The Operator shall take necessary measures and/or ensure their adoption for the deletion or clarification of incomplete or inaccurate data.
5.7. Personal data shall be stored in a form that allows the identification of the subject of personal data, no longer than required for the purposes of processing personal data, unless the data retention period is established by federal law, a contract, where the subject of personal data is a party, beneficiary, or guarantor. Processed personal data shall be destroyed or anonymized upon achievement of the processing purposes or in case the necessity for achieving these purposes is lost, unless otherwise stipulated by federal law.
6. Purposes of Personal Data Processing
Purpose of Processing | Provision of the User with access to services, information, and/or materials contained on the Website |
Personal Data |
- Full Name (Surname, First Name, Patronymic)
- E-mail Address
- Phone Numbers
Legal Basis |
- Charter (founding) documents of the Operator
- Contracts concluded between the Operator and the subject of personal data
Types of Personal Data Processing |
- Collection, recording, systematization, accumulation, storage, destruction, and anonymization of personal data
- Sending informational letters to the email address
7. Conditions for Personal Data Processing
7.1. Personal data processing is carried out with the consent of the subject of personal data for the processing of their personal data.
7.2. 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.
7.3. 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.
7.4. 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.
7.5. 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.
7.6. 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.
7.7. Processing of personal data subject to publication or mandatory disclosure in accordance with federal law is carried out.
8. Procedure for Collection, Storage, Transfer, and Other Types of Personal Data Processing
The security of personal data processed by the Operator is ensured by implementing legal, organizational, and technical measures necessary for the full execution of the requirements of current legislation in the field of personal data protection.
8.1. The Operator ensures the preservation of personal data and takes all possible measures to exclude unauthorized access to the personal data.
8.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to compliance with current legislation or if the subject of personal data has given consent to the Operator to transfer data to a third party for the fulfillment of obligations under a civil law contract.
8.3. In case of identifying inaccuracies in personal data, the User may update them independently by sending a notification to the Operator’s email address (info@po-tpm.com) marked “Personal Data Update.”
8.4. The term for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless a different term is established by a contract or current legislation. The User may withdraw their consent to personal data processing at any time by sending a notification to the Operator via email to info@po-tpm.com marked “Withdrawal of Consent to Personal Data Processing.”
8.5. All information collected by third-party services, including payment systems, communication facilities, and other service providers, is stored and processed by these persons (Operators) in accordance with their User Agreement and Privacy Policy. The subject of personal data acknowledges and agrees with the terms of the aforementioned documents. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.
8.6. Prohibitions on the transfer (other than access provision), as well as restrictions on the processing or conditions for processing personal data authorized for dissemination, established by the subject of personal data, shall not apply in cases of personal data processing in the public, social, and other public interests defined by the legislation of the Russian Federation.
8.7. The Operator ensures the confidentiality of personal data when processing personal data.
8.8. The Operator stores personal data in a form that allows the identification of the subject of personal data, no longer than required for the purposes of processing personal data, unless the data retention period is established by federal law, a contract to which the subject of personal data is a party, beneficiary, or guarantor.
8.9. The cessation of personal data processing may be triggered by the achievement of the personal data processing purposes, the expiration of the period of consent granted by the subject of personal data, the withdrawal of consent by the subject of personal data or a request to cease processing, as well as the detection of unlawful processing of personal data.
9. Set of Actions Performed by the Operator with the Received Personal Data
9.1. The Operator carries out the collection, recording, systematization, accumulation, storage, refinement (updating, modification), extraction, use, transfer (dissemination, provision, access), anonymization, blocking, deletion, and destruction of personal data.
9.2. The Operator carries out automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunication networks or without such transfer.
10. Cross-Border Transfer of Personal Data
10.1. Before commencing cross-border transfer of personal data, the Operator must notify the authorized body for the protection of personal data subjects’ rights of its intention to carry out such transfer (such notification shall be sent separately from the notification regarding the intention to process personal data).
10.2. Prior to submitting the aforementioned notification, the Operator must obtain relevant information from the authorities of a foreign state, foreign natural persons, or foreign legal entities to whom the cross-border transfer of personal data is planned.
11. Confidentiality of Personal Data
The Operator and other persons who have gained access to personal data are obliged not to disclose personal data to third parties and not to disseminate personal data without the consent of the subject of personal data, unless otherwise stipulated by federal law.
12. Final Provisions
12.1. The User may obtain any clarifications regarding issues of interest concerning the processing of their personal data by contacting the Operator via email at info@po-tpm.com.
12.2. Any amendments to the Operator’s Personal Data Processing Policy shall be reflected in this document. The Policy is effective indefinitely until replaced by a new version.
12.3. The current version of the Policy is freely available on the Internet at the address: https://po-tpm.com/personal data.