Personal Data Processing Policy

1. General Provisions

This Personal Data Processing Policy made up in accordance with the requirements of Russia's Federal Law of 27 July 2006 No.152-FZ on Personal Data (hereinafter referred to as the Law on Personal Data) determines the procedure for processing personal data and measures to ensure the security of personal data taken by UK RM Rail LLC (hereinafter referred to as the Data Controller).

1.1. The Data Controller sets the observance of the rights and freedoms of individuals and citizens in processing their personal data, including protection of right to personal and family privacy, as its overriding priority and condition for the implementation of its activities.

1.2. The Data Controller's policy for processing personal data (hereinafter referred to as the Policy) applies to all information that can be obtained by the Data Controller about https://eng.engineering.rmrail.ru website visitors.

2. Definitions Applied to the Policy

2.1. “Automated Processing of Personal Data” is processing of personal data using computer aids.

2.2. “Blocking of Personal Data” means temporary suspension of personal data processing (unless the processing is required for personal data refinement).

2.3. “Website” is a set of graphic and information materials, as well as computer programs and databases providing their Internet accessibility at https://eng.engineering.rmrail.ru.

2.4. “Personal Data Information System” is an array of personal data contained in databases plus information technologies and hardware providing for their processing.

2.5. “Anonymization of Personal Data” means actions that make it impossible to link personal data to a specific User or other Data Subject without the use of additional information.

2.6. “Personal Data Processing” means any computer-aided or non-computer-aided action (operation) or a set of such actions (operations) performed with personal data, including collection, recording, systematization, accumulation, storage, refinement (update, modification), retrieval, utilization, transfer (dissemination, provision, access), anonymization, blocking, deletion, destruction of personal data.

2.7. “Data Controller” is a governmental authority, municipal authority, legal or physical entity, which, independently or jointly with other entities, organizes and (or) implements Personal Data Processing and determines the purposes of personal data processing, the composition of personal data to be processed, the actions (operations) performed with personal data.

2.8. “Personal Data” means any information relating directly or indirectly to an identified or identifiable User of https://eng.engineering.rmrail.ru website.

2.9. “Personal Data Permitted by a Data Subject for Dissemination” are personal data access to which is granted to the general public as authorized by the Data Subject by giving a consent to the processing of personal data, permitted by the data subject for dissemination as prescribed by the Law on Personal Data (hereinafter – “Personal Data Permitted for Dissemination”).

2.10. “User” is any visitor to the website https://eng.engineering.rmrail.ru.

2.11. “Provision of Personal Data” means actions intended to disclose personal data to a certain person or a certain group of people.

2.12. “Dissemination of Personal Data” means actions intended to disclose personal data to an indefinite number of people (Transfer of Personal Data) or make them familiar to the public at large, including publishing personal data in the media, placing them in information and telecommunication networks or providing access to personal data in any other way.

2.13. “Cross-Border Transfer of Personal Data” is transfer of personal data to the territory of a foreign state to authority of a foreign state, a foreign individual or a foreign legal entity.

2.14. “Destruction of Personal Data” means any actions as a result of which personal data is irretrievably destroyed so that the content of personal data cannot be later restored in personal data information system, and (or) physical data carriers are destroyed.

3. Fundamental Rights and Obligations of Data Controller

3.1. The Data Controller has the right to:

– obtain reliable information and/or documents containing Personal Data from the Data Subject;

– in the event that the Data Subject withdraws his consent to processing of personal data, the Data Controller is entitled to continue Personal Data Processing without the Data Subject’s consent if there are grounds specified in the Law on Personal Data;

– independently determine the composition and list of measures necessary and sufficient to ensure fulfillment of the duties provided for by the Law on Personal Data and regulatory acts adopted in accordance with it, unless otherwise provided by the Law on Personal Data or other federal laws.

3.2. The Data Controller is obliged to:

– provide the Data Subject, at his request, with information regarding the processing of his Personal Data;

– organize Personal Data Processing in the manner prescribed by the current legislation of the Russian Federation;

– respond to applications and requests from Data Subjects and their legal representatives in accordance with the requirements of the Law on Personal Data;

– report the required information to the authorized body for protection of Data Subject rights, at the authorized body request, within 30 days from the date of receipt of such a request;

– publish or otherwise provide unrestricted access to this Personal Data Processing Policy;

– take legal, organizational and technical measures to protect Personal Data from unauthorized or accidental access, personal data destruction, modification, blocking, copying, provision, dissemination, as well as from other illegal actions with regard to Personal Data;

– stop the Transfer (dissemination, provision, access) of Personal Data, stop Personal Data Processing and destroy Personal Data in the manner and cases contemplated by the Law on Personal Data;

– perform other duties prescribed by the Law on Personal Data.

4. Fundamental Rights and Obligations of Data Subjects

4.1. Data Subjects have the right to:

– receive information regarding the processing of their Personal Data, except as otherwise provided by federal laws. The information shall be provided to the Data Subject by the Data Controller in an accessible form, and it shall not contain Personal Data of other Data Subjects, unless there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it is established by the Law on Personal Data;

– request the Data Controller to refine their personal data, block or destroy them if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, and to take legal measures to protect their rights;

– lay down the condition of prior consent when Personal Data are processed for the purpose of marketing promotion of goods, works and services;

– withdraw their consent to Personal Data Processing;

– appeal to the authorized body for protection of Data Subject rights or to court against wrongful actions or omissions of the Data Controller when processing their Personal Data;

– exercise other rights provided for by the legislation of the Russian Federation.

4.2. Data Subjects are obliged to:

– provide the Data Controller with reliable data about themselves;

– inform the Data Controller about refinement (update, modification) of their Personal Data.

4.3. Persons who have provided the Data Controller with inaccurate information about themselves or other Data Subjects without the consent of the latter are held responsible as set forth by the legislation of the Russian Federation.

5. The Data Controller is Entitled to Process the Following Personal Data of the User

5.1. Surname, first name, patronymic

5.2. Email address

5.3. Phone numbers

5.4. The website also collects and processes anonymized data about its visitors (including cookies) using web analytics services (Yandex.Metrica, Google Analytics, etc.).

5.5. The aforementioned data are hereinafter collectively referred to as “Personal Data”.

5.6. Processing of special categories of Personal Data relating to race, nationality, political views, religious or philosophical beliefs, intimate life is not carried out by the Data Controller.

5.7. Processing of Personal Data Permitted for Dissemination from among the special categories of Personal Data specified in Part 1 of Art. 10 of the Law on Personal Data is allowed, if the prohibitions and conditions stipulated in Art. 10.1 of the Law on Personal Data are complied with.

5.8. The User's consent to the processing of Personal Data Permitted for Dissemination is documented separately from other consents to his Personal Data Processing. Herewith, conditions stipulated specifically in Art. 10.1 of the Law on Personal Data are to be observed. Requirements for the content of such consent are established by the authorized body for protection of Data Subject rights.

5.8.1 The User gives his consent to the processing of Personal Data Permitted for Dissemination directly to the Data Controller.

5.8.2 The Data Controller is obliged, no later than three working days from the date of receipt of the said User's consent, to publish information on Personal Data Processing conditions, on any prohibitions and terms of the processing of Personal Data Permitted for Dissemination by the public at large.

5.8.3 The Transfer (dissemination, provision, access) of Personal Data permitted by the Data Subject for dissemination must be terminated at any time at the Data Subject request. The request shall include surname, first name, patronymic (if any), contact details (telephone number, e-mail or postal address) of the Data Subject, and a list of Personal Data, the processing of which is subject to termination. Personal Data listed in the request can be processed only by the Data Controller to whom it was sent.

5.8.4 Consent to the processing of Personal Data Permitted for Dissemination ceases to be effective from the moment the Data Controller receives the request mentioned in clause 5.8.3 of this Personal Data Processing Policy.

6. Principles of Personal Data Processing

6.1. The processing of Personal Data is carried out on a lawful and fair basis.

6.2. The processing of Personal Data is limited to the fulfillment of specific, predetermined and legitimate purposes. Personal Data Processing incompatible with the purposes of collecting personal data is prohibited.

6.3. It is not allowed to combine databases containing Personal Data, the processing of which is carried out for purposes that are incompatible with each other.

6.4. Only Personal Data that meet the purposes of their processing are subject to processing.

6.5. The content and scope of the processed Personal Data shall correspond to the stated purposes of processing. The redundancy of the processed Personal Data in relation to the stated purposes of their processing is not allowed.

6.6. When processing Personal Data, the accuracy of Personal Data, their sufficiency, and, if necessary, relevance in relation to the purposes of Personal Data Processing, is to be ensured. The Data Controller takes the necessary measures and/or ensures adoption of measures to delete or refine incomplete or inaccurate data.

6.7. The Personal Data are stored in a form that allows to identify the Data Subject, no longer than is required by the purposes of Personal Data Processing, if the Personal Data retention period is not established by federal law, an agreement to which the Data Subject is a party, beneficiary or guarantor. The processed Personal Data is destroyed or anonymized when the purposes of Personal Data Processing are fulfilled or their fulfillment is no longer needed, unless otherwise provided by federal law.

7. Purposes of Personal Data Processing

7.1. The purpose of processing the User's Personal Data is to inform the User by sending e-mails.

7.2. Additionally, the Data Controller is entitled to send to the User notifications about new products and services, special offers and various events. The User can always opt out of receiving informational messages by sending an email to the Data Controller’s address engine@rmrail.ru marked "Opting out of notifications about new products, services and special offers".

7.3. Anonymized data of Users obtained through web analytics services are used to collect information about the Users’ actions on the Website, improve the Website quality and content.

8. Legal Grounds for Personal Data Processing

8.1. Legal grounds for processing of Personal Data by the Data Controller are:

– the Data Controller’s charter and constituent documents;

– federal laws, other statutory instruments in the field of personal data protection;

– Users' consent to the processing of their Personal Data, to the processing of Personal Data Permitted for Dissemination.

8.2. The Data Controller processes the User's Personal Data only if they are filled in and/or forwarded by the User independently through special forms available on the website https://eng.engineering.rmrail.ru or sent to the Data Controller by e-mail. By filling in the relevant forms and/or sending their Personal Data to the Data Controller, the User expresses his consent to this Policy.

8.3. The Data Controller processes anonymized data of the User if it is allowed in the User's browser settings (saving cookies and using JavaScript technology is enabled).

8.4. The Data Subject independently decides on the provision of his Personal Data and gives consent freely, self-willingly and in own interests.

9. Conditions for the Processing of Personal Data

9.1. Personal Data processing is carried out with the Data Subject’s consent to the processing of his personal data.

9.2. Personal Data processing is necessary to fulfill the purposes stipulated by an international treaty of the Russian Federation or by the law, to carry out functions, powers and duties assigned to the Data Controller by the legislation of the Russian Federation.

9.3. Personal Data processing is necessary for the administration of justice, the execution of a judicial act, an act of another authority or official, subject to execution in accordance with the Russian law on enforcement proceedings.

9.4. Personal Data processing is necessary to execute an agreement to which the Data Subject is a party, beneficiary or guarantor, to conclude an agreement on the initiative of the Data Subject or an agreement under which the Data Subject will be the beneficiary or guarantor.

9.5. Personal Data processing is necessary to exercise the rights and legitimate interests of the Data Controller or third parties, or to achieve important social goals, provided that the rights and freedoms of the Data Subject are not violated.

9.6. Processed are Personal Data accessible to the public at large with the Data Subject’s consent or at his request (hereinafter referred to as “Publicly Available Personal Data”).

9.7. Processed are Personal Data subject to publication or mandatory disclosure in accordance with federal law.

10. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing

The security of Personal Data processed by the Data Controller is ensured through the implementation of legal, organizational and technical measures necessary to fully comply with the requirements of the current legislation in the field of Personal Data Protection.

10.1. The Data Controller ensures integrity of Personal Data and takes all possible measures to exclude access to personal data by unauthorized individuals.

10.2. The User's Personal Data will never be transferred to third parties, except in cases related to the implementation of existing laws or if the Data Subject has given the Data Controller his consent to transfer Personal Data to a third party for fulfillment of obligations under a civil law contract.

10.3. Should any inaccuracies be found in Personal Data, the User can update them directly, by sending notification to the Data Controller’s email address engine@rmrail.ru marked "Personal Data Update".

10.4. Time period for Personal Data processing is determined by the fulfillment of the purposes for which the Personal Data are collected, unless a different period is established by the contract or existing laws.

The User may at any time withdraw his consent to the processing of Personal Data by sending notification to the Data Controller’s email address engine@rmrail.ru marked “Withdrawal of consent to personal data processing”.

10.5. All information collected by third-party services, including payment systems, means of communication and other service providers, is stored and processed by these entities (Data Controllers) in accordance with their User Agreement and Privacy Policy. The Data Subject (the User) is obliged to directly familiarize himself with these documents in a timely manner. The Data Controller is not responsible for the actions of third parties, including service providers mentioned in this clause.

10.6. The Data Subject’s prohibitions on transfer (except for granting access), processing or processing conditions (except for gaining access) of Personal Data Permitted for Dissemination, do not apply in cases when Personal Data are processed in state, community and other public interests determined by Russian Federation laws.

10.7. When processing Personal Data, the Data Controller ensures the confidentiality of personal data.

10.8. The Data Controller stores Personal Data in a form that allows to identify the Data Subject, no longer than is required by the purposes of Personal Data Processing, if the Personal Data retention period is not established by federal law, an agreement to which the Data Subject is a party, beneficiary or guarantor.

10.9. Personal Data Processing can be terminated on one of the following conditions: fulfillment of Personal Data Processing purposes, expiration of the Data Subject’s consent or withdrawal of the Data Subject’s consent to Personal Data Processing, and detection of unlawful processing of Personal Data.

11. List of Actions Performed by the Data Controller with the Acquired Personal Data

11.1. The Data Controller performs collection, recording, systematization, accumulation, storage, refinement (update, modification), retrieval, utilization, transfer (dissemination, provision, access), anonymization, blocking, deletion and destruction of Personal Data.

11.2. The Data Controller performs Automated Processing of Personal Data with the receipt and/or transmission of the acquired information via information and telecommunication networks or without it.

12. Cross-Border Transfer of Personal Data

12.1. Before starting Cross-Border Transfer of Personal Data, the Data Controller must make sure that the foreign state whereto the Personal Data is supposed to be transferred provides reliable protection of the Data Subject’s rights.

12.2. Cross-Border Transfer of Personal Data to the territory of foreign states that do not meet the above requirements can be carried out only in case of the Data Subject’s written consent to the Cross-Border Transfer of his Personal Data and/or execution of an agreement to which the Data Subject is a party.

13. Confidentiality of Personal Data

The Data Controller and other entities who have gained access to Personal Data shall not disclose to third parties and disseminate Personal Data without the the Data Subject’s consent, unless otherwise provided by federal law.

14. Concluding Provisions

14.1. The User can get answers to any questions regarding the processing of his personal data by contacting the Data Controller via e-mail engine@rmrail.ru.

14.2. This document will reflect any changes in the Personal Data Processing Policy made by the Data Controller. The Policy remains in force without limit of time until it is superseeded by a new version.

14.3. The current version of the Policy is freely available on the Internet at https://eng.engineering.rmrail.ru/politika-konfidentsialnosti/.