Personal Data Processing Policy

This personal data processing policy was developed in accordance with para.2 Article 18.1 of the Federal Law dated 27.07.2006 No.152-FZ “On Personal Data” and is applied for all personal data processed by the processor – JSC “Power machines”.

1. Information about data processor:

Name: Joint-Stock Company “Power machines – ZTL, LMZ, Electrosila Plant, Energomachexport” (JSC “Power machines”).

Registered office: 3A Vatutina Str., St. Petersburg, 195009, Russia

2. Legal basis for personal data processing:

Personal data processing is performed in the amount and within the terms specified in regulatory legal acts of the Russian Federation:

As well as by consent to process personal data.

3. Purposes for personal data processing.

3.1. Personal data processing is performed to achieve the following purposes:

3.2. JSC “Power machines” has the right to define other purposes for personal data processing within the legislation of the Russian Federation.

4. Categories of the data processed, their sources and terms of processing.

4.1. JSC “Power machines” processes the following categories of personal data:

4.2. JSC “Power machines” does not process personal data related to ethnicity, nationality, political opinions, religious and philosophical beliefs and intimate life.

4.3. JSC “Power machines” processes personal data related to health only to the extent permitted by the legislation of the Russian Federation.

4.4. Terms of personal data processing are determined:

JSC “Power machines”, as a personal data processor, determines a three-year processing term for personal data to reply to requests obtained via the corporate website or by other means.

5. General principles of personal data processing.

5.1. When processing personal data JSC “Power machines” complies with the principles established by Article 5 of the Federal Law dated 27.07.2006 No. 152-FZ “On Personal Data”.

5.2. JSC “Power machines” carries out cross-border transfer of personal data in accordance with the procedure established by the legislation of the Russian Federation.

5.3. JSC “Power machines” created publicly available sources of personal data (address directory of the corporate mailing system, telephone directory). Personal data are included in such sources on the basis of a written consent of personal data subjects.

5.4. Processing of personal data shall be ceased, and personal data shall be destroyed in the following cases:

6. Information about third parties involved in personal data processing.

6.1. JSC “Power machines” protects the confidentiality of personal data and neither transfers personal data, nor provides access to them to third parties without consent of personal data subjects, unless otherwise provided for by the legislation of the Russian Federation.

6.2. JSC “Power machines” transfers personal data (provides access to them) to public authorities of the Russian Federation in accordance with their competence and to the extent provided for by the legislation of the Russian Federation.

6.3. JSC “Power machines” transfers personal data to other third parties subject to an agreement or instruction to processing which establish the following:

7. Assurance of personal data security.

7.1. JSC “Power machines” takes all necessary organizational and technical measures to guarantee confidentiality of personal data when they are processed by the Company divisions:

7.2. JSC “Power machines” determines at its own discretion the content and list of measures which are necessary and sufficient to ensure fulfillment of obligations vested in it, unless otherwise provided for by legal instruments of the Russian Federation.

8. Rights of personal data subjects.

8.1. Personal data subject has the right:

8.2. The rights of personal data subject, specified in clause 8.1. hereof, may be restricted to the extent provided for by the legislation of the Russian Federation.

8.3. In order to exercise all the above rights the personal data subject has the right to submit the relevant request to JSC “Power machines”.

9. Contact information.

Contact information for personal data subjects, contractors and other third parties:

Corporate website of JSC “Power machines”

HR Department +7 (812) 336-26-19

Information Security Department +7 (812) 336-24-72