1.1. This Personal Data Processing Policy (hereinafter referred to as Policy) was adopted by the Joint-Stock Company «Agency VTN» in accordance with the requirements of the current legislation of the Russian Federation in the field of personal data, including the Federal Law of 27.07.2006. 152-FZ «About personal data», in order to ensure the protection of the rights of subjects of personal data processed by the Operator in the framework of business activities, keeping them confidential and the security of their processing processes.
1.2. This Policy outlines the basic principles and rules used by the Operator in the processing of personal data, including the purposes, legal grounds, conditions and methods of such processing, categories of personal data subjects, the personal data of which are processed by the Operator, also contains information about the performance of the Operator’s duties in accordance with the requirements of the legislation of the Russian Federation and information about the requirements of the Operator to protect the personal data processed.
1.3. This Policy applies to all personal information that the Operator may obtain about visitors to the Site on the Internet at: wwww.vneshtrans.com during the use of the Site, its services, programs and products.
1.4. The Policy is a public document declaring to any interested persons the basis of the Operator’s activity in processing personal data in the specified cases and is to be made publicly available on the Site at: wwww.vneshtrans.com.
1.5. The use of the services and materials of the Site and the provision of its personal data means the User’s unconditional consent to this Policy and the processing conditions specified therein, Storage and use of his personal information in accordance with the Federal Law of 27.07.2006. 152-F3 «On personal data», as well as their acceptance without exceptions and reservations.
In case of disagreement with these conditions, the User must refrain from using services and materials.
1.6. This Policy applies only to the information on the Site. Operator does not control or take responsibility for third-party sites to which the User can access links available on the Site.
2. Key concepts used in the Policy
In this Policy, concepts and definitions are used in accordance with the Federal Law of 27.07.2006. 152-F3 «On Personal Data» and other legislation in force in the field of personal data protection, including the following:
1) Operator - a public authority, a municipal body, a legal entity or a natural person, independently or jointly with other persons, organizing and (or) processing personal data, as well as defining the purposes of processing personal data, the composition of personal data, to be processed, actions (transactions) performed with personal data.
Within the framework of this Policy, the Operator is the Joint Stock Company «Agency PTN», OGRN 1027802713707, INN 7805142699.
2) Personal data means any information related to the directly or indirectly defined or identified User of the Site:
- personal information which the User provides himself or herself at his or her discretion in the process of using the services of the Site, including his or her personal data;
- data that are automatically transferred to the Site’s services in the course of their use by means of software installed on the User’s device, including the IP address, cookie data, information about the User’s browser (or other program by which services are accessed), technical characteristics of equipment and software used by the User, date and time of access to services, addresses of requested pages and other such information.
3) Processing of personal data - any action (transaction) or set of actions (transactions) performed with or without the use of an automation tool with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, modify), retrieve, use, transmit (distribute, provide, access), anonymise, block, delete, destroy personal data.
4) Automated processing of personal data - processing of personal data by computer.
5) The provision of personal data - actions aimed at the disclosure of personal data to a certain person or a certain number of persons.
6) Blocking of personal data - temporary discontinuation of processing of personal data (except if processing is necessary to clarify personal data).
7) The destruction of personal data - actions that make it impossible to restore personal data content in the personal data information system and (or) the result of which is the destruction of personal data tangible data carriers.
8) The site is a set of graphics and information materials, as well as computer programs and databases providing their availability on the Internet at www.vneshtrans.com (hereinafter - Site).
9) Personal Data Information System - a set of personal data contained in databases and information technologies and technical tools for processing them.
10) User - any visitor to the Site.
3. Purposes of processing personal data
3.1. The site processes only personal information that is necessary to provide services or execute agreements and contracts with the User in accordance with the requirements of the current legislation of the Russian Federation.
3.2. The purposes of processing the User’s personal data are: to conclude, execute and (or) terminate civil law contracts at the initiative of the User; to provide the User with access to the services, information and (or) materials contained in wwww.vneshtrans.com; to receive consultations on the initiative of the User; to provide feedback to the Users of the Site, including receiving their opinions, questions on the information of the Site and the Operator’s information products, and to send them replies.
3.3. In addition, the Operator has the right to notify the User about new products and services, special offers and various events. The user can always refuse to receive information messages by sending a letter to the Operator at the e-mail address: vtn@vneshtrans.com with the mark «No notifications about new products and services, and special offers».
3.4. Anonymised User data collected through Internet Statistics services serve to collect information on Users' actions on the site, to improve the quality of the Site and its content.
4. Legal grounds for processing personal data
4.1. The operator processes the personal data of the User exclusively in the amount of data submitted by the subject itself within the feedback form located on the Site containing the condition of the subject’s confirmation of its consent to such processing.
By filling out the relevant forms and (or) sending his personal data to the Operator, the User agrees to this Policy.
4.2. Operator handles anonymised data about User in case it is allowed in User’s browser settings (included saving of files «cookie» and use of JavaScript technology).
The Operator receives the Site’s attendance data in anonymised form and uses it for statistical purposes to analyze the user’s interest in the Site’s materials without passing them on to third parties.
4.3. The operator carries out his activities in the field of personal data processing on the basis of the Statute and in accordance with the requirements of the current legislation of the Russian Federation, including the following:
- The Constitution of the Russian Federation;
- Civil Code of the Russian Federation;
- Federal Law of 27.07.2006, No. 152-FZ "On digital data";
- Federal Law of 08.02.1998 N14-FZ "On Limited Liability Companies";
- Federal Law of December 26, 1995 N208-FZ "On Joint Stock Companies".
5. Amount of personal data of the User processed by the Operator
(If provided by the User at his discretion):
- Full Name;
- Phone number;
- E-mail address.
In addition, the Site collects and processes anonymised data about visitors (e.g. files «cookie») with the help of Internet statistics services (Yandex Metrica and Google Analyst and others).
6. Principles, procedures and conditions for processing personal data
6.1. The operator in his activity ensures compliance with the principles of processing of personal data in accordance with the Federal Law of 27.07.2006. 152-F3 «On personal data», including the following:
- The processing of personal data is legal and fair;
- The processing of personal data is limited to specific, predetermined and legitimate purposes;
- Processing of personal data incompatible with the purposes of personal data collection is not permitted;
- The content and volume of personal data processed are appropriate for processing purposes;
- Personal data must be stored in a form that allows the identification of the subject of personal data, no longer than the purpose of the processing of personal data requires, unless a time limit for the storage of personal data is established by federal law, a treaty to which: The beneficiary or guarantor of which is the subject of personal data;
- The personal data to be processed must be destroyed or anonymised when the purposes of processing have been achieved, or if it is no longer necessary to achieve those goals, unless otherwise provided by federal law.
6.2. The security of personal data, which is processed by the Operator, is ensured through the implementation of legal, organizational and technical measures necessary for the full implementation of the requirements of the legislation in force in the field of personal data protection.
6.3. The operator shall protect personal data and take all possible measures to prevent access to the personal data of unauthorized persons.
6.4. The operator is under an obligation not to disclose or distribute personal data to third parties without the consent of the subject of personal data, unless otherwise provided by federal law.
6.5. In case of errors in personal data, the User can update them independently by sending a notification to the Operator’s e-mail address: vtn@vneshtrans.com with the mark «Updating personal data».
6.6. The user may at any time withdraw his consent to the processing of personal data by sending a notification to the Operator via e-mail to the Operator’s e-mail address: vtn@vneshtrans.com with the mark «Revocation of consent for processing personal data».
6.7. The operator is obliged to provide the User with information on the processing of his personal data on request in accordance with the procedure established by the legislation in force in the Russian Federation.
7. Final provisions
7.1. The user can get any clarifications on the questions concerning the processing of his personal data by contacting the Operator via e-mail: vtn@vneshtrans.com.
7.2. Any changes in the Operator’s personal data processing policy will be reflected in this document. The policy is in force indefinitely until replaced by a new version.
7.3. The current version of the Policy is freely available on the Internet at: wwww.vneshtrans.com.
7.4. Issues related to the processing of personal data of Users which are not expressly provided for in this Policy are regulated in accordance with the legislation in force in the Russian Federation.