General Provisions
1. The policy for processing personal data at TMK Logistic LLC (hereinafter referred to as the Policy), developed in accordance with the Federal Law “On Personal Data”, establishes the goals, basic principles and rules for processing personal data and determines the main measures to ensure their security.

2. This Policy has been developed for the implementation in TMK Logistic LLC of the requirements of the legislation of the Russian Federation in the field of personal data, as well as ensuring the protection of the rights of individuals when processing their personal data.

3. The provisions of this Policy are the basis for the development and updating of administrative and organizational and legal documents (hereinafter - regulatory documents) of TMK Logistic LLC, regulating the processing of personal data of various categories of personal data subjects, as well as the procedure for implementing measures to protect the processed personal data ...

The development of these regulatory documents is carried out by subdivisions of TMK Logistic LLC in accordance with the established procedure.

4. The provisions of this Policy are binding on employees of TMK Logistic LLC who have access to personal data.

II. Basic concepts
5. The following concepts are used in this Policy:
security of personal data - the state of protection of personal data, characterized by the ability of users, technical means and information technologies to ensure the confidentiality, integrity and availability of personal data when they are processed in information systems;
biometric personal data - information that characterizes the physiological and biological characteristics of a person, on the basis of which it is possible to establish his identity and which are used by TMK Logistic LLC to establish the identity of the subject of personal data;
protection of personal data - activities aimed at preventing leakage of protected personal data, unauthorized and unintentional influences on protected personal data;
information system - a set of information (personal data) contained in databases and information technologies and technical means ensuring its processing;
confidentiality of personal data is a mandatory requirement not to disclose to third parties and not to allow the dissemination of personal data without the consent of the subjects of personal data or other legal grounds;
processing of personal data - any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data;
personal data - any information relating directly or indirectly to a specific or identifiable individual (subject of personal data);
user of the services of TMK Logistic LLC - a passenger, consignor, consignee or other natural or legal person using the services provided by TMK Logistic LLC;
personal data subjects - users of TMK Logistic LLC services, employees of TMK Logistic LLC and their close relatives, candidates for employment (jobseekers), pensioners registered with TMK Logistic LLC, and their representatives, and other persons whose personal data became known by virtue of the provision of social benefits, guarantees and compensations to them by TMK Logistic LLC, or the performance of functions and tasks assigned to TMK Logistic LLC;
special categories of personal data - personal data of subjects of personal data concerning race, nationality, political views, religious or philosophical beliefs, health status, intimate life and convictions;
cross-border transfer of personal data - transfer of personal data to the territory of a foreign state to the authority of a foreign state, a foreign individual or a foreign legal entity;
destruction of personal data - actions as a result of which it becomes impossible to restore the content of personal data in the information system and (or) as a result of which material carriers of personal data are destroyed.

III. Purposes of processing personal data
6. The processing of personal data by TMK Logistic LLC is carried out in order to:

execution of contracts for carriage and provision of additional services during carriage;

ensuring transport security;

improving the quality of service and the availability of railway transportation, including through the implementation of additional incentive programs for users of TMK Logistic LLC services;

providing information on the services provided, the development of new products and services, as well as on the services provided by the subsidiaries and affiliates of TMK Logistic LLC;

collection and development of ideas aimed at improving the management of the transportation process;

examination of start-up projects with innovative solutions;

conducting promotions, surveys, marketing, statistical and other research activities;

execution of contracts concluded with individuals who are in contractual and other civil law relations
with TMK Logistic LLC;

conducting personnel work, including attracting and selecting candidates for work at TMK Logistic LLC, subsidiaries and affiliates of TMK Logistic LLC;

fulfillment of contractual agreements with employees;

provision of social benefits, guarantees and compensations from TMK Logistic LLC;

implementation and implementation of functions, powers and duties assigned by the legislation of the Russian Federation to TMK Logistic LLC, as well as to achieve the goals stipulated by international treaties of the Russian Federation or laws.

IV. Principles and rules for the processing of personal data
7. The processing of personal data at TMK Logistic LLC is carried out in compliance with the following principles and rules:

processing is carried out on a legal and fair basis;

processing is limited to the achievement of specific, predetermined and legitimate purposes;

personal data that meet the purposes of processing are subject to processing, with the obligatory compliance of their volume and content with the stated purposes of processing;

it is not allowed to combine databases containing personal data, the processing of which is carried out for purposes incompatible with each other;

during processing, the accuracy and sufficiency of personal data and, if necessary, relevance in relation to the purposes of processing are ensured with the adoption of measures to remove or clarify incomplete or inaccurate data or ensure the adoption of such measures;

storage of personal data is carried out in a form that makes it possible to determine the subject of personal data, no longer than the purpose of processing personal data requires, if the storage period of personal data is not established by federal law, an agreement to which the subject of personal data is a party, beneficiary or guarantor;

the processed personal data is destroyed or depersonalized upon achievement of the processing goals or in case of loss of the need to achieve these goals, unless otherwise provided by the legislation of the Russian Federation.

8. The processing of personal data in TMK Logistic LLC is carried out with the consent of the subject of personal data, unless otherwise provided by the legislation of the Russian Federation.

9. When processing personal data, TMK Logistic LLC observes their confidentiality.
V. Rights of the subject of personal data

10. The subject of personal data has the right:
receive full information regarding the processing of their personal data by TMK Logistic LLC, except for cases provided for by the legislation of the Russian Federation;
demand clarification, blocking or destruction of your personal data if the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing;
require notification of all persons who were previously informed of his incorrect or incomplete personal data about all changes made to them;
withdraw consent to the processing of your personal data;
to appeal against the actions or inaction of TMK Logistic LLC when processing its personal data in accordance with the legislation of the Russian Federation;
exercise other rights provided for by the legislation of the Russian Federation.
Vi. Categories and volume of processed personal data
11. The content and volume of the processed personal data are determined by the purposes of their processing, given in Section III of the Policy, and are indicated in the consent of the subject of personal data to the processing of his personal data, except for cases when the processing of personal data can be carried out without obtaining such consent.
12. The processing of personal data that is redundant in relation to the stated purpose of their processing is not allowed.
13. Special categories of personal data, as well as biometric personal data of personal data subjects are processed by TMK Logistic LLC in the manner prescribed by the legislation of the Russian Federation.
Vii. Organization of personal data processing
14. In order to exercise the rights of subjects of personal data, TMK Logistic LLC when processing their personal data:
takes the necessary measures to fulfill the obligations stipulated by the legislation of the Russian Federation;
explains to the subject of personal data the legal consequences of refusing to provide personal data, if it is mandatory in accordance with the legislation of the Russian Federation;
carries out blocking, clarification and destruction of unlawfully processed personal data, as well as the termination of their unlawful processing;
notifies the subject of personal data about the elimination of the violations committed or the destruction of his personal data;
provides, at the request of the subject of personal data or his representative, information regarding the processing of his personal data, in the manner prescribed by the legislation of the Russian Federation, as well as by the regulatory documents of TMK Logistic LLC.
15. In order to effectively organize the processing of personal data, a person responsible for organizing the processing of personal data is appointed at TMK Logistic LLC, who, in accordance with the established powers, provides:

development and updating of regulatory documents of TMK Logistic LLC on the processing and protection of personal data;
bringing to the attention of employees of TMK Logistic LLC the provisions of the legislation of the Russian Federation, regulatory documents of TMK Logistic LLC on the processing of personal data, as well as requirements for the protection of personal data;

taking legal, organizational and technical measures to protect personal data, including those processed in information systems, from unauthorized or accidental access to them, destruction, modification, blocking, copying, dissemination of personal data, as well as from other illegal actions in relation to personal data ;

internal control over the observance of the requirements of the legislation of the Russian Federation and the normative documents of OOO TMK Logistic in the field of personal data, including the requirements for the protection of personal data, in OOO TMK Logistic;

control over the processing of requests and requests from subjects of personal data or their representatives on the facts of violations of legislation in the field of personal data committed by employees of TMK Logistic LLC;

interaction with government agencies on the protection of personal data.

16. The processing of personal data at TMK Logistic LLC is carried out using computer technology (automated processing) or with the direct participation of a person without the use of computer technology (non-automated processing).

17. The managers of TMK Logistic LLC authorized by the employer, and only those employees of TMK Logistic LLC whose job responsibilities include the processing of personal data, are allowed to process personal data.

These managers and employees have the right to process only those personal data that they need to perform their job duties.

18. The transfer of personal data to third parties (including cross-border transfer) is carried out with the written consent of the subjects of personal data, except for cases when it is necessary in order to prevent threats to the life and health of the subjects of personal data, as well as in other cases established by the legislation of the Russian Federation ...

19. The transfer of personal data to government agencies is carried out in accordance with the requirements of the legislation of the Russian Federation.

20. Cross-border transfer of personal data on the territory of foreign states that are parties to the Council of Europe Convention on the Protection of Individuals with regard to Automated Processing of Personal Data, other foreign states that ensure adequate protection of the rights of subjects of personal data, as well as to the territory of a foreign state that is not a party to the said Convention , is carried out in the manner prescribed by the legislation of the Russian Federation.

21. TMK Logistic LLC has the right to entrust the processing of personal data to another legal entity or individual entrepreneur with the consent of the subjects of personal data on the basis of the concluded agreement, the essential condition of which is the obligation of the contractor to ensure the confidentiality of personal data and their security during processing.

22. When collecting personal data, including using the information and telecommunications network Internet, TMK Logistic LLC provides recording, systematization, accumulation, storage, clarification (updating, modification), extraction of personal data of citizens of the Russian Federation using databases, located on the territory of the Russian Federation, with the exception of cases provided for by the legislation of the Russian Federation.

23. The terms of storage of personal data in TMK Logistic LLC are determined in accordance with the legislation of the Russian Federation and regulatory documents of TMK Logistic LLC.

24. Ensuring the security of personal data, including during their processing in information systems, is carried out in accordance with the legislation of the Russian Federation and the requirements of the authorized body of state power for the protection of the rights of subjects of personal data, the federal executive body authorized in the field of security, and the federal an executive body authorized in the field of countering technical intelligence and technical protection of information.

VIII. Final provisions
25. Responsibility for violation of the requirements of the legislation of the Russian Federation and regulatory documents of TMK Logistic LLC in the field of personal data is determined in accordance with the legislation of the Russian Federation.

26. The Policy is a public document and must be posted on the official website of TMK Logistic LLC.