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List of Information on Implemented Personal Data Protection Requirements

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Content: List of information about the implemented requirements for the protection of personal data

Personal data is processed by PJSC TransContainer in compliance with the policies and guidelines provided by Federal Law “On Personal Data”, taking into account the need to protect rights and freedoms of personal data subjects, in particular, to protect the right to privacy, personal and family secrets, namely:

  • processing is carried out on legal and fair basis;
  • processing is limited to achievement of specific, pre-determined and legitimate goals. Personal data processing that contradicts its collection goals is prohibited;
  • it is not allowed to consolidate databases containing personal data being processed for incompatible purposes;
  • personal data that meets the processing goals shall be the only subject for processing;
  • content and scope of processed personal data shall meet the declared processing goals. Data processing that is excessive towards the declared goals is prohibited;
  • when processing data, it is necessary to make sure the personal data is precise and sufficient and, if necessary, relevant to the processing goals. PJSC TransContainer takes or procures for taking the efforts to delete or specify incomplete or imprecise data;
  • personal data is stored in the format that enables to determine the personal data subject but not longer than the personal data processing goals allow, unless the personal data storage period is established in the federal law, in a contract, the party, beneficiary or surety to which is the personal data subject;
  • processed personal data is deleted or depersonalized upon achievement of the processing goals or if the need for achievement of these goals lapses, unless otherwise provided by the federal law. 

Provided always that:

1. Personal data is processed with consent of personal data subjects, unless otherwise provided by the laws of the Russian Federation.

2. Personal data may be processed with the use of computers (automated processing) or with direct human involvement without computers (non-automated processing).

3. Those of PJSC TransContainer employees whose job duties include personal data processing are the only persons allowed to process personal data.

These employees are entitled to obtain those personal data as necessary to them to perform their job duties only.

4. Personal data processing is carried out by:

obtaining information containing personal data, orally and/or in writing, directly from personal data subjects;

provision by personal data subjects of originals of the necessary documents;

obtaining document copies certified in the established manner and containing personal data or copying original documents;

obtaining personal data when sending inquiries to governmental authorities, state non-budgetary funds, other governmental institutions, local authorities, for-profit and non-for-profit entities, to individuals in such cases and such manner as provided by the laws of the Russian Federation;

obtaining personal data from public domain;

personal data recording (registration) in books, ledgers, registers and other recording forms;

inclusion of personal data into PJSC TransContainer information systems;

use of other recording means and methods for the personal data obtained as part of business pursued by PJSC TransContainer.

5. Transfer of personal data to third parties (including cross-border transfer) is allowed with written consent of the personal data subjects, except for cases when it is necessary to prevent health and life hazards to personal data subjects, and in other cases provided by the laws.

When transmitting personal data to third parties according to the contracts signed, PJSC TransContainer makes sure the requirements of the laws of the Russian Federation and PJSC TransContainer bylaws on personal data are met.

6. Personal data is transferred to competent executive bodies (Federal Tax Service of the Russian Federation, Pension Fund of the Russian Federation, Federal Statutory Medical Insurance Fund of the Russian Federation, etc.) according to the laws of the Russian Federation.

7. Cross-border personal data transfer in foreign countries being parties to the Convention on Individuals’ Protection during Automated Personal Data Processing (hereinafter the “Convention”), as well as other foreign countries that ensure adequate protection of personal data subjects’ rights, shall be carried out according to Federal Law “On Personal Data” and may be prohibited or limited for protection of the basics of the Russian Federation constitutional system, individuals’ morals, health, rights and legitimate interests, defense of the country and national security.

Cross-border personal data transfer in a foreign country that is not a party to the said Convention shall be carried out according to the laws of the Russian Federation, provided that the laws and regulations and applied personal data safety efforts as applicable in that country conform to the Convention.

8. PJSC TransContainer is entitled to assign personal data processing to another legal entity or individual entrepreneur with consent of personal data subjects based on a contract signed. The legal entity or the individual entrepreneur engaged in personal data processing at PJSC TransContainer assignment are obliged to comply with the personal data processing policies and guidelines provided by the laws of the Russian Federation applicable to personal data.

9. If PJSC TransContainer, based on the contract, transfers or assigns personal data processing to another legal entity or individual entrepreneur, the duty of the said person to keep confidential and ensure security of the personal data during their transfer or processing shall be the essential condition of the contract.

10. Personal data is stored by PJSC TransContainer in such format as to allow to determine the personal data subject, not longer than their processing goals require so. When the processing goals are achieved or if the need for their achievement lapses the personal data shall be deleted.  The personal data storage periods by PJSC TransContainer are determined according to the laws of the Russian Federation and PJSC TransContainer bylaws.