Confidentiality Policy

SUMMARY

Welcome to the Confidentiality Policy page of Public Joint Stock Company «Research and production corporation «United Wagon Company» (short company name: PJSC “RPC UWC”; hereinafter also referred to as the Company). This section describes procedures implemented by PJSC “RPC UWC” to collect and use personal data through its website www.uniwagon.com (the “Site”).

This Confidentiality Policy (the “Policy”) is a legally binding and enforceable agreement made between the website users (“you”) and PJSC “RPC UWC”. The Company collects and processes your personal data (where applicable) in accordance with the provisions of the GDPR. According to the provisions of the GDPR, the Company is a controller of your personal data meaning that the Company determines the purposes and means of processing of personal data. Using this website implies that you accept the terms and conditions of this Policy. This Policy is only addressed to our website users.

Terms and definitions:

1. Website means www.uniwagon.com, an online source of information about PJSC “RPC UWC”, its goals, activities, products, etc.
2. Services means features of www.uniwagon.com that allow, by filling in special forms, to send purchase orders or contact the company’s employees by e-mail.
3. Website user means a visitor of www.uniwagon.com.
4. Personal data (personal information) means any information relating to an identified or identifiable natural person ('data subject') which can be identified, directly or indirectly; in particular by reference to an identifier such as a name, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person (as stipulated in Art. 4 GDPR).
5. Anonymised data means such website visitor's personal data the processing of which does not allow to specifically identify this natural person.
6. PJSC “RPC UWC” means Public Joint Stock Company «Research and production corporation «United Wagon Company» (Principle State Registration Number (OGRN) 1147746600539), and entities belonging to the same group of entities as PJSC “RPC UWC” under Russian antimonopoly laws.
7. GDPR means a General Data Protection Regulation adopted by the European Union (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), and published under No. L 119/1 in the EU's Official Journal on 04 May 2018.

The basic rights of the website’s visitors for the purposes of personal data processing are listed below:

• Persons visiting the website shall unless they wish to be provided with the Services not be obligated to make any disclosures to PJSC “RPC UWC”.
• Visitors shall be entitled to know which personal data are collected and processed by PJSC “RPC UWC” when they are using the website.
• They are entitled to send to PJSC “RPC UWC” a written request to provide them in a computer-readable format their personal data collected by PJSC “RPC UWC”. PJSC “RPC UWC” shall provide them such information (right of access).
• If the website user’s personal data is untrue or incomplete, they may request PJSC “RPC UWC” to update it accordingly (right to rectification).
• Persons visiting the website may, by using the contact form, request from PJSC “RPC UWC” where certain criteria (as set out in the provisions of the GDPR) are met, to delete (right to erasure) or limit (right to restriction of processing) or object to the use of their personal information, this right is stipulated by the legislation in force and may affect their access to PJSC “RPC UWC”’s website.
• Website users have the right lodge a complaint with the competent authority at any time.

WEBSITE VISITOR’S DATA

All visitor’s data collected by PJSC “RPC UWC” fall into two categories:

1. non-identified and non-identifiable data related to website visitors, or data that may be available to PJSC “RPC UWC” or collected automatically by using services (anonymised information). The website uses Yandex-Metrica, a web analytics that allows PJSC “RPC UWC” to improve website’s usability. PJSC “RPC UWC” collects visitors’ personal data with the Yandex-Metrica tool when they are using the website. This is the data PJSC “RPC UWC” obtains from devices used by persons to navigate its website (including mobile devices). This data may include: a device ID or a unique ID, a device type, an operating system version, an ad ID, any location data, including location data from a visitor’s mobile device, a referral URL address, users’ IPs, and a watch history. When using the website for the first time, visitors are requested to accept the rules of data collecting and processing in a cookie-alert window pursuant to this Policy. If they refuse to accept the rules, they must stop using the Company’s website. Such anonymised data does not allow PJSC “RPC UWC” to identify the website visitors it was collected from. Anonymised data collected by PJSC “RPC UWC” usually includes technical or summarised details of using PJSC “RPC UWC”’s services. Service providers placing cookies or using other means of tracking through PJSC “RPC UWC”’s services may apply their own policy to regulate data collection and processing. The Confidentiality Policy by PJSC “RPC UWC” does not apply to their activities, nor PJSC “RPC UWC” controls these activities.
2. Individual identifying information (Personal Data), specifically, data identifying a natural person (personal data). Personal data collected by PJSC “RPC UWC” mainly consists of contact details gathered by using web forms, or through contact means available on the website (e-mails or telephone numbers, contact information such as first name, last name, business telephone, fax number, e-mail address, country of residence), payment details (name and actual address for invoicing purposes, payment methods and details of transactions), detailed data relating to a working session or a service experience (IP addresses, location and/or individual device identifier), details of connected user accounts in other web resources (for example, an e-mail address or user name for PayPal, Google or Facebook accounts), scanned copies of ID documents provided to PJSC “RPC UWC” (such as an ID card, driver’s licence, passport or the company’s official constituent documents), correspondence (including that effected by or uploaded to PJSC “RPC UWC”’s services) and any other personal data provided to PJSC “RPC UWC” by persons visiting the website and/or using the services.

PJSC “RPC UWC” does not collect and deletes any information that is knowingly false, excessive for processing purposes, or comes from underage persons (if evidenced).

PJSC “RPC UWC” uses no data coming from online electronic services that is anonymous or aggregate or was obtained by means of web analytic tools, to identify a specific natural person. Such data are ignored in combination with other data, or otherwise, for the purposes of identifying a data subject.

Anonymised data that refer or are related to personal data (for example, to improve services offered by PJSC “RPC UWC”) is deemed and treated by PJSC “RPC UWC” as personal data as long as such reference or relation persist.

PERSONAL DATA COLLECTION AND DISCLOSURE

PJSC “RPC UWC” processes the personal data of website users (as and where applicable) for the purposes of (i) meeting our obligations under our business relationship and/or agreement including for the provision of the Services (including the Company’s online services,; (ii) operation, management and control of the affairs of our business and its purposes; (iii) general planning and organisation of our business; (iv) maintaining our IT systems administrative and management systems, processes and policies; (v) complying with any requirement of law and/or regulation and/or of any competent authority or professional body (where applicable) of which PJSC “RPC UWC” is a member.

PJSC “RPC UWC” collects and processes personal data of website users for the purposes mentioned above on the lawful basis that (i) the processing is necessary for the performance of an agreement which the website user has entered into with us and in order to take steps at the website user’s request prior to entering into the said agreement(s); (ii) the website user has given consent (if and where applicable); and (iii) the processing is necessary for the purposes of the legitimate interests pursued by us.

Such legitimate interests include, inter-alia, our business and/or commercial interests and the management, operation and marketing of our business and/or our exercise or defence of legal claims and/or the prevention of fraud and money laundering activities and/or to disclose information to other data recipients such as our service providers and/or to comply with obligations or internal policy requirements of our business, and/or to monitor and improve our relationships with you and/or to keep our internal records and/or to monitor communication to/from you using our systems and/or to protect the integrity of our IT systems.

In case personal data is processed by virtue of the consent of the website user, PJSC “RPC UWC” requests persons visiting its website to give such unambiguous consent when filling in the feedback form.

When a person visiting the website contacts PJSC “RPC UWC” by e-mail, they are requested to read this Policy and fill in the feedback form to confirm their acceptance of this Policy.

Website users may revoke their consent at any time by using contact forms or e-mail, but this will not affect the legality of processing personal data prior to the revocation.

The provision of additional personal data is voluntary, though it may be compulsory to use some of PJSC “RPC UWC”’s services such as the sale or purchase of products and/or for contracting purposes.

Where PJSC “RPC UWC” processes data on grounds of legitimate interest, such processing of data of website users does not affect their interests, fundamental rights or freedoms.

PJSC “RPC UWC” uses no data coming from online electronic services that is knowingly false, anonymous or aggregate or was obtained by means of web analytic tools, to identify a specific natural person. Such data are ignored in combination with other data, or otherwise, for the purposes of identifying a data subject.

PJSC “RPC UWC” may request website users to provide some additional information whether prior to the execution of the contract, or under existing contractual relations, where such information constitutes:

• Identification data such as a name, address, telephone numbers or e-mail address.
• Information required for contracting purposes.
• Information contained in submitted online forms.
• Extra information necessary to identify website users or check any data provided by website users (as required by the applicable laws of Russia or another country being such website user’s county of citizenship).

PJSC “RPC UWC” discloses the personal data of website users to other member companies of the group and/or affiliated entities of the PJSC “RPC UWC”, its business partners and affiliates, IT service providers and public authorities/organizations (where applicable) for the purposes described above. When PJSC “RPC UWC” transfers personal data to recipients established in countries outside of the EEA PJSC “RPC UWC” carries out such transfers to a recipient (i) who is in a country which provides an adequate level of protection for personal data or (ii) under appropriate safeguards pursuant to the provisions of applicable data protection laws.

If website users intend to disclose or disclose to PJSC “RPC UWC” any personal data of third parties, they may do so only upon the consent to such disclosure of the data subjects whose data are disclosed. Website users shall notify such third parties that PJSC “RPC UWC” collects, uses, discloses and keeps personal data in accordance with its Confidentiality Policy.

PERSONAL DATA STORAGE TIME LIMIT

PJSC “RPC UWC” processes and stores personal data of its website users for.as long as it is necessary to provide Services to website users or to for the purposes of our legitimate interests in case PJSC “RPC UWC” needs to comply with its legal obligations, in the case of any legal process or to meet the contractual obligations of PJSC “RPC UWC.

Once keeping personal data of website users becomes no longer necessary for PJSC “RPC UWC”, the company eliminates such data in a safe way complying to its personal data storage and elimination policy.

SECURITY

PJSC “RPC UWC” process personal data which is adequate, relevant and limited to what is necessary in relation to the purposes mentioned above and implement appropriate technical and organizational measures to ensure an adequate level of security appropriate to the applicable risk. Such measures aim to prevent unauthorised or unlawful processing, accidental loss, destruction or damage of personal data and include inter-alia, pseudonymization and encryption of personal data.

CONTACT DETAILS

If you have any comments or questions relating to this Policy, please do not hesitate to contact us through the contact form on our website or e-mail address: info@uniwagon.com