Privacy Policy of JSC “Ukrainian railways”
- General provisions
- Joint Stock Company “Ukrainian railways” (hereinafter referred to as JSC “Ukrainian railways”), legal address: 03680, Kyiv, 5 Jerzy Giedroyc St., processes personal data of individuals – subjects of personal data and is the owner of this personal data.
- The Privacy Policy of JSC “Ukrainian railways” (hereinafter referred to as the Policy) is an internal regulatory document developed to inform personal data subjects on the purpose of collection, grounds, composition of collected personal data, processing procedure, transfer of personal data and their rights pursuant to the requirements of the Law of Ukraine “On Personal Data Protection” (hereinafter referred to as the Law) when carrying out activities defined by the Charter of JSC “Ukrainian railways”.
- This Policy is mandatory to be used by JSC “Ukrainian railways” when processing personal data.
- This Policy is published on all official web resources of JSC “Ukrainian railways”.
- This Policy shall be approved in accordance with the procedure established by JSC “Ukrainian railways” and comes into force on the date of the decision of the Manahement Board of JSC “Ukrainian railways”on its approval, unless otherwise specified in this decision. Amendments and additions to this Policy shall be made on the initiative or as agreed with the authorized structural unit of the management apparatus of JSC “Ukrainian railways”, that carries out activities to organize work on the protection of personal data while processing of the above-mentioned data in JSC “Ukrainian railways”.
- In case of the adoption of new regulatory legal acts of Ukraine in the field of personal data protection, this Policy must be immediately revised, and until then, it shall be valid only to the extent not inconsistent with the legislation of Ukraine.
- Basic terminology
- In this Policy, the following terms are used in the following meaning: subjects of personal data – individuals whose personal data are processed – existing and potential consumers, service customers, users of electronic service channels, including for the processing of electronic travel/transport documents and additional railway services of JSC “Ukrainian railways”, persons who contacted the information line or sent an e-mail, persons who contacted JSC “Ukrainian railways” in the manner prescribed by the laws of Ukraine “On Citizens' Appeals”, “On Access to Public Information”, “On the Bar and Advocacy”; ; electronic customer service channels are websites and mobile application of JSC “Ukrainian railways”, which are used in the provision of services to individuals while implementing activities specified in the Charter of JSC “Ukrainian railways”; website is a software placed on the Internet and used to inform users and to provide services in particular, but not limited to, on issuing and returning electronic travel/transport documents and additional services, obtaining information and reference services, other operations related to passenger service, ordering such services online; mobile application is a software allowing users to make reservations, purchase and return electronic travel/transport documents, order additional services, and obtain reference information, ensuring the functioning of Android and iOS operating systems on mobile devices using official distribution channels (repositories); user is an individual who accesses all websites and mobile applications of JSC “Ukrainian railways” and uses for its intended purpose.
- Other terms used in this Policy shall be construed in accordance with the Law and the Standard Procedure for Processing Personal Data, approved by the Order of the Ukrainian Parliament Commissioner for Human Rights “On Approval of Documents in the Field of Personal Data Protection” dated 08.01.2014 No. 1/02-14.
- Purpose and grounds for processing personal data
-
JSC “Ukrainian railways” collects personal data for the purpose
of carrying out the activities specified in the Charter of JSC
“Ukrainian railways”.
- Provision of services for the issuance/return of electronic travel/transport documents in passenger traffic by rail in domestic and international traffic and provision of other services through electronic customer service channels, in particular: creation by subjects of personal data of accounts on the website and in the mobile application for issuing electronic travel/transport documents; providing users with access to the website and mobile application for issuing electronic travel/transport documents; ordering and processing services, managing orders for the provision of services via the website and mobile application; using feedback functions on the website and mobile application; ensuring the exchange of information from the website, mobile application via email; ensuring user participation in surveys and promotions within the loyalty program of JSC “Ukrainian railways”; conducting research and analysis to improve the quality of passenger services; improving the website and mobile application; providing information on services (newsletters, information about promotions, loyalty program); sending a travel/transportation document to the email address specified at registration by the subject of personal data.
- Provision of services for the transportation of cargo, luggage, freight and mail by rail in domestic and international traffic.
- Performance of contractual obligations to connect to the electricity distribution system networks.
- Fulfillment of conditions and obligations under agreements concluded by JSC “Ukrainian railways” with individuals with regard to the provision of other services provided for by the Charter.
- Implementation of the rights of individuals to receive information pursuant to the procedure established by the Laws of Ukraine “On Citizens' Appeals”, “On Access to Public Information”, “On the Bar and Advocacy”.
- The legal grounds for processing personal data of JSC “Ukrainian railways” are: consent of the subject of personal data to process personal data; performance by JSC “Ukrainian railways” of obligations defined by the Laws of Ukraine “On Citizens' Appeals”, “On Access to Public Information”, “On the Bar and Advocacy”; conclusion and execution of transactions to which an individual is a party, or which are concluded for the benefit of an individual; implementation of the legitimate interests of JSC “Ukrainian railways” or a third party, except in cases where the needs to protect the fundamental rights and freedoms of subject of the personal data in connection with the processing of his data prevail over such interests.
-
JSC “Ukrainian railways” collects personal data for the purpose
of carrying out the activities specified in the Charter of JSC
“Ukrainian railways”.
- Composition of personal data collected and processed by JSC
“Ukrainian railways”
-
JSC “Ukrainian railways” collects and processes the following
personal data:
- When issuing electronic travel/transport documents in passenger traffic and providing services through electronic customer service channels: full name, mobile phone number, email address, data from the document certifying the right to a privilege, which are used when issuing preferential travel documents.
- When ordering a car carrier: full name, mobile phone number, email address, vehicle type.
- When ordering group travel documents: full name, mobile phone number, email address.
- When placing an order for a station assistant: full name, mobile phone number, email address, data from a document certifying the right to a benefit.
- When placing a special order for travel documents for military personnel: full name, mobile phone number, email address.
- When ordering a special rail car: full name, mobile phone number, email address, data from a document certifying the right to a benefit, a scanned copy or photo of a document certifying the right for a benefit.
- When ordering a lounge: name, mobile phone number, email address.
- When ordering a service for finding lost items: name, mobile phone number, email address.
- When filing a claim form for the return of travel documents: full name, mobile phone number, email address, date of birth, place of residence, taxpayer registration identification card number (RNOKPP), IBAN account number, photo or scanned copy of a document confirming the circumstances of the claim return.
- When providing feedback via electronic customer service channels: information contained in any messages that the subject of personal data sends to JSC “Ukrainian railways”, including the content of the message and metadata.
- When drawing up contracts for the provision of services related to the standard connection of electrical networks of distribution systems, non-standard connection of electrical networks of distribution systems with the design of the linear part of the connection to be done by the consumer: full name, place of birth, series, number, date of issue of the passport, place of registration, taxpayer registration identification card number (RNOKPP), data on the right of ownership or use of the real estate object, mobile phone number, email address.
- Data of telephone calls of the subject of personal data to service numbers of JSC “Ukrainian railways”: the start and end time of the call, conversation recording, phone number.
- Data from chatbot chats: date and time of the request, name of the subject of personal data in the chat, phone number, content of the session.
- Data from SMS requests from subjects of personal data: time of request, phone number, content of response to request.
- Data when creating accounts for electronic customer service channels: full name, photographic data, mobile phone number, email address, date and time of entry to electronic customer service channels, information on the device, in particular, but not limited to (IP address, type and version of browser and operating system) used by the subject of personal data.
- Data of persons applying pursuant to the procedure specified by the Laws of Ukraine “On Citizens' Appeals”, “On Access to Public Information”, “On the Bar and Advocacy”: full name (if available); place of residence; availability of benefits that are the basis for priority consideration of the application; information on communication means; other data related to the person and provided by this person for consideration of the application, request.
-
JSC “Ukrainian railways” collects and processes the following
personal data:
- Use of cookies
- JSC “Ukrainian railways” uses cookies to optimize the operation of electronic customer service channels and improve service provision quality.
- Cookies store information on a computer or mobile device when the subject of personal data starts using them.
- By selecting the “Accept and close” option, personal data subject consents to the processing of personal data that may be obtained from cookies.
- By selecting the “Reject and close” option, the personal data subject does not consent to the processing of personal data that may be obtained from cookies.
- Procedure for processing personal data
- Personal data processing at JSC “Ukrainian railways” shall be carried out in accordance with the legislation on personal data protection.
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Way of personal data collection
- The collection of users' personal data through the electronic customer service channels of JSC “Ukrainian railways” shall be made automatically when creating accounts, authorizing himself/herself (electronic authentication) in the electronic customer service channels, sending emails, and any other information containing personal data.
- Collection of personal data of persons applying to JSC “Ukrainian railways pursuant to the procedure specified by the Laws of Ukraine “On Citizens' Appeals”, “On Access to Public Information”, “On the Bar and Advocacy” shall be carried out by such persons providing their personal data, information in applications and requests for information, and lawyer requests.
- The provided personal data is accumulated and stored in the data centers of the Branch “Main Informational and Computing Centre” of JSC “Ukrainian railways” on the territory of Ukraine.
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Making changes, personal data removal or destruction.
- Changes to personal data are made on the basis of: a motivated written request of the subject of personal data; an order of the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or officials designated by him of the Secretariat of the Commissioner for Human Rights of the Verkhovna Rada of Ukraine; an appeal from other parties to a relationship related to personal data, if there is the consent of the subject of personal data; a court decision that came into effect.
- Personal data shall be subject to deletion or destruction in the following cases: expiration of the specified period of storage of personal data; termination of legal relations between the subject of personal data and JSC “Ukrainian railways”, unless otherwise provided by law; issuance of a relevant order of the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or officials designated by him of the Secretariat of the Commissioner for Human Rights of the Verkhovna Rada of Ukraine;
- Personal data shall be deleted or destroyed in a manner that excludes the further possibility of restoring of such personal data.
- Personal data protection measures
- JSC “Ukrainian railways” takes measures aimed at the security of personal data processing at all stages of its processing through organizational and technical measures.
- JSC “Ukrainian railways” takes technical measures to protect personal data in order to ensure integrity, availability and confidentiality.
- Processing of personal data in information (automated) systems of JSC “Ukrainian railways” is carried out taking into account the requirements of legislation in the field of information protection in information and communication systems.
- JSC “Ukrainian railways” manages the employees’ level of access to personal data. Each employee has access only to those personal data (parts thereof) of personal data subjects that are necessary for him / her in connection with the performance of his official and labor duties.
- To control access to information systems through which personal data is processed in JSC “Ukrainian railways”, authentication and authorization, including the use of complex passwords, are applied.
- Employees of JSC “Ukrainian railways” who have access to personal data sign an obligation not to disclose personal data that has been entrusted to them or that has become known to them in connection with the performance of their official or labor duties.
- JSC “Ukrainian railways” provides regular training for employees who work with personal data at least once a year.
- Facts of violations of the process of personal data processing and protection are documented and reported to Chairman of the Management Board for necessary measures to be taken.
- JSC “Ukrainian railways” is not responsible for the accuracy and content of the personal data specified by the user when registering an account and ordering services through the electronic customer service channels.
- JSC “Ukrainian railways” is not responsible for accidental or unlawful destruction, loss, change, unauthorized disclosure of personal data or access to personal data that occurred as a result of the user’s active actions or omissions.
- Terms of personal data processing
- Personal data is processed in a form that allows identification of an individual to whom it relates for no longer than is necessary in accordance with the purpose of its processing, unless otherwise provided by law.
- Personal data may be stored after the purpose of processing specified in this Policy has been achieved in cases: when required by the legislation of Ukraine; to exercise or protect the legal rights and interests of JSC “Ukrainian railways”.
- JSC “Ukrainian railways” stores personal data: collected using the electronic customer service channels – for a period of 3 years from the moment of the user’s last action in such a service; in the event of a claim or lawsuit against JSC “Ukrainian railways” – until not needed anymore – for the period necessary to satisfy / refuse to satisfy the claim, consider the filed lawsuit in court; of persons who applied in accordance with the procedure established by the Laws of Ukraine “On Citizens’ Appeals” and “On Access to Public Information”, “On the Bar and Advocacy” – for a period of 5 years;
- For statistical purposes, personal data may be stored in the archive in an anonymized form.
- Rights of personal data subjects
- According to Article 8 of the Law, the subject of personal data has the right to: know about the sources of collection, the location of his / her personal data, the purpose of its processing, the location of the personal data controller or to give an appropriate instruction to obtain this information to persons authorized by him / her, except for cases established by law; receive information about the conditions for providing access to personal data, in particular information about third parties to whom personal data is transferred; access his / her personal data; receive a response no later than thirty (30) calendar days from the date of receipt of the request, except for cases provided for by law, on whether personal data is being processed, as well as to receive the content of such personal data; submit a reasoned request to the personal data controller with an objection to the processing of his / her personal data; submit a reasoned request to JSC “Ukrainian railways” to change or delete his / her personal data if this data is being processed illegally or is inaccurate; protect his / her personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of such data, as well as to be protected from the provision of information that is unreliable or defames the honor, dignity and business reputation of an individual; file complaints about his / her personal data processing to the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or to the court; apply remedies in case of violation of the legislation on personal data protection; make reservations regarding the restriction of the right to process his / her personal data when giving consent; withdraw consent to the processing of personal data; know the mechanism of automated processing of personal data; be protected against automated decision that has legal consequences for the personal data subject.
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To exercise his / her rights, the personal data subject may
contact JSC “Ukrainian railways”:
the “hotline” of JSC “Ukrainian railways”, “Quality and Service” Contact Center:
0-800-503-111;
e-mail: service@uz.gov.ua;
via the mobile application;
in chatbots;
by letter to the address: 03680, Kyiv, 5 Jerzy Giedroyc Street.
- Bodies that protect the rights of personal data subjects
- In Ukraine, control over compliance with the legislation on personal data protection within the limits of the powers provided for by law is carried out by:
• the Commissioner for Human Rights of the Verkhovna Rada of Ukraine;• courts.Address and contact details of the Commissioner for Human Rights of the Verkhovna Rada of Ukraine: 01008, Kyiv, 21/8 Instytutska Street. Hotline: 0800-50-17-20 (free of charge). E-mail: hotline@ombudsman.gov.ua. - Information on the transfer of personal data to third parties
- JSC “Ukrainian railways” does not transfer personal data of personal data subjects to third parties without the consent of the personal data subject, except for cases specified by the legislation of Ukraine or international treaties, the consent to binding nature of which has been provided by the Verkhovna Rada of Ukraine.
- Responsibility and control
- Responsibility for organizing work related to the protection of personal data during its processing in the divisions lies with the heads of these divisions.
- Control over compliance with the requirements of this Policy is entrusted to the Corporate Security Department of JSC “Ukrainian railways”.
Annex to the Privacy Policy of JSC “Ukrainian railways”
- Privacy Notice
- JSC “Ukrainian railways” processes personal data of foreign citizens in order to provide services for the issuance / return of electronic travel / transport documents in passenger transportation by rail in international traffic through the electronic customer service channels.
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Personal data is processed by JSC “Ukrainian railways” for the
purposes of: fulfilling contractual obligations between JSC
“Ukrainian railways” and the personal data subject on the
provision of passenger transportation services; validating the
phone number of the user of the service
https://services.uz.gov.ua for the presence of such an account
in the database of the mobile application of JSC “Ukrainian
railways”;
creating accounts by personal data subjects in the mobile application for issuing electronic travel / transport documents; providing users with access to the mobile application for issuing electronic travel / transport documents; using feedback functions in the mobile application;
ensuring user participation in surveys, promotions in the loyalty program of JSC “Ukrainian railways”;
conducting research and analysis to improve the quality of passenger services;
improving the operation of the mobile application;
providing information about services (newsletters, information on promotions, loyalty program);
sending a travel / transportation document to the personal data subject’s email address specified during registration. -
JSC “Ukrainian railways” collects the following personal
data:
through the service https://services.uz.gov.ua: given name, family name, citizenship, e-mail address, phone number, user photo, user’s passport photo;
through the mobile application: given name, family name, e-mail address, phone number, information contained in messages that the personal data subject sends to JSC “Ukrainian railways”, including the message content, photo (the field is not mandatory to fill in). - Processing of foreign citizens’ personal data by JSC “Ukrainian railways” is necessary for the performance of a public offer agreement on the provision of services for the issuance / return of electronic travel / transport documents in passenger transportation and additional services, to which the data subject is a party, or for taking action at the request of the personal data subject prior to the conclusion of the agreement.
- JSC “Ukrainian railways” does not transfer personal data to third parties without the consent of the personal data subject, except for cases specified by the legislation of Ukraine or international treaties, the consent to binding nature of which has been provided by the Verkhovna Rada of Ukraine. JSC “Ukrainian railways” does not transfer personal data internationally.
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According to Article 8 of the Law of Ukraine “On Personal Data
Protection”, the subject of personal data has the right to: know
about the sources of collection, the location of his / her
personal data, the purpose of its processing, the location of
the personal data controller or to give an appropriate
instruction to obtain this information to persons authorized by
him / her, except for cases established by law;
receive information about the conditions for providing access to personal data, in particular information about third parties to whom personal data is transferred;
access his / her personal data;
receive a response no later than thirty (30) calendar days from the date of receipt of the request, except for cases provided for by law, on whether personal data is being processed, as well as to receive the content of such personal data;
submit a reasoned request to the personal data controller with an objection to the processing of his / her personal data;
submit a reasoned request to JSC “Ukrainian railways” to change or delete his / her personal data if this data is being processed illegally or is inaccurate;
protect his / her personal data from unlawful processing and accidental loss, destruction, damage due to intentional concealment, failure to provide or untimely provision of such data, as well as to be protected from the provision of information that is unreliable or defames the honor, dignity and business reputation of an individual;
file complaints about his / her personal data processing to the Commissioner for Human Rights of the Verkhovna Rada of Ukraine or to the court;
apply remedies in case of violation of the legislation on personal data protection;
make reservations regarding the restriction of the right to process his / her personal data when giving consent;
withdraw consent to the processing of personal data;
know the mechanism of automated processing of personal data;
be protected against automated decision that has legal consequences for the personal data subject.-
Personal data subjects also have the right:
for erasure of personal data (right to be forgotten). The personal data subject has the right to request JSC “Ukrainian railways” to erase his / her personal data;
to restrict the processing of personal data in certain cases;
for personal data portability. The personal data subject has the right to receive his / her personal data, which he / she has provided to JSC “Ukrainian railways”, in a structured, commonly used and machine-readable format and to have the right to transmit such data without hindrance from JSC “Ukrainian railways”;
to object to the processing of personal data for direct marketing purposes. The personal data subject has the right to object to the processing of his / her personal data for such purposes at any time;
not to be subject to a decision based solely on automated processing, including profiling, which creates legal consequences for or similarly significantly affects him / her.
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Personal data subjects also have the right:
- To exercise his/her rights, the personal data subject may contact JSC “Ukrainian railways” via the “hotline” of JSC “Ukrainian railways”:0-800-503-111 or via e-mail: service@uz.gov.ua; by letter to the address: 03680, Kyiv, 5 Jerzy Giedroyc Street.
- In Ukraine, control over compliance with the legislation on personal data protection within the limits of the powers provided for by law is carried out by: the Commissioner for Human Rights of the Verkhovna Rada of Ukraine; courts.
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JSC “Ukrainian railways” does not use cookies when processing
personal data in the mobile application and on the service
https://services.uz.gov.ua.
JSC “Ukrainian railways” does not process personal data for marketing purposes or for profiling on the service https://services.uz.gov.ua.
If the consent of the user of mobile application is obtained, JSC “Ukrainian railways” may send information about offers, goods or services, other information related to the provision of services.
The user of the mobile application may at any time withdraw his consent to the processing of personal data for the specified purposes by independently changing the relevant application settings. -
Personal data is processed in a form that allows identification
of an individual to whom it relates for no longer than is
necessary in accordance with the purpose of its processing,
unless otherwise provided by law.
JSC “Ukrainian railways” stores personal data:
collected on the service https://services.uz.gov.ua – within 30 days, after which such data is deleted;
in the event of a claim or lawsuit against JSC “Ukrainian railways”, personal data may be stored until it is not needed anymore – for the period necessary to satisfy / refuse to satisfy the claim, consider the filed lawsuit in court. - JSC “Ukrainian railways” takes all necessary technical and organizational measures to protect personal data from loss, damage, unauthorized access.
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