Public Offer

Date of entry into force: April 17, 2026

1. General Provisions

1.1. This document is the official proposal (public offer) of the Individual Entrepreneur Solomein Evgeny Sergeevich, OGRNIP 321774600494241, INN 421713484462 (hereinafter referred to as the Offeror), to conclude a contract for the provision of paid services with any capable individual or legal entity (hereinafter referred to as the User).

1.2. This document is a public offer in accordance with Articles 435 and 437 of the Civil Code of the Russian Federation.

1.3. Full and unconditional acceptance of this offer is recognized as the User performing one of the following actions:

• registration or authorization in the Personal Account on the website https://my.slonprivacy.app/ (including via Telegram, Google, Yandex or other available methods);

• purchasing any Subscription through the Telegram bot @slon_privacy_bot or through the Personal Account;

• payment for the selected tariff (including trial) by any available method;

• receiving or using technical data (account credentials) to connect to the Service;

• participation in the Referral Program (generation of a referral link, request for withdrawal of rewards and other actions in the Bot or Personal Account).

1.4. Acceptance of the offer means the User’s full and unconditional acceptance of all terms of this Agreement.

1.5. The Offeror has the right to change the terms of this offer at any time. The new version comes into force from the moment of its publication in the Telegram bot or on the Offeror’s website. Continued use of the Service after publication of the new version means acceptance of the changes.

1.6. The Services are not intended and are not advertised as a means of bypassing access restrictions to information established by authorized bodies of the Russian Federation. The Offeror does not provide information on methods of bypassing blocks and is not responsible for the purposes of the User’s use of the Services.

2. Terms and Definitions

Service — provision to the User of access to the Offeror’s software and hardware complex, which ensures the establishment of a secure data transmission channel between the User’s device and the Offeror’s server infrastructure.

Subscription — provision of the Service for a limited period on a paid basis (including trial periods).

Telegram bot (Bot) — a software interface in the Telegram messenger through which interaction between the User and the Offeror is carried out @slon_privacy_bot

Personal Account — a web interface for managing the Subscription, payments, connections, referral program and other functions of the Service, located at https://my.slonprivacy.app/ (hereinafter also referred to as the Website or Account).

Account credentials — unique connection parameters (login, password, access key or other identifiers).

Tariff — the cost and conditions for the provision of the Service.

Referrer — a User who has attracted a new User (Referee) using their referral link or promo code generated in the Telegram bot or Account.

Referee — a new User who has for the first time purchased and paid for a Subscription using the Referrer’s referral link or promo code.

Referral Program — the Offeror’s program providing for the accrual of rewards to the Referrer for attracting Referees.

Referral balance — the User’s internal balance in the Telegram bot to which monetary rewards are credited.

3. Subject of the Agreement

3.1. The Offeror undertakes to provide the User with access to the Offeror’s infrastructure for establishing a secure channel for transmitting network traffic.

3.2. The User undertakes to pay for the Service in accordance with the selected Tariff.

3.3. The Service is exclusively technical in nature and consists of providing access to the Offeror’s infrastructure.

3.4. The Offeror does not provide:

• access to specific Internet resources;

• third-party content;

• guarantees of bypassing access restrictions to Internet resources.

3.5. The Service is not intended for use for the purpose of violating the legislation of the Russian Federation or the legislation of other states.

3.6. The Service is not intended for access to information resources blocked by authorized bodies of the Russian Federation, or for the deliberate search/receipt of extremist materials (within the meaning of the current legislation of the Russian Federation). The User bears sole responsibility for such actions in accordance with the norms of the Russian Federation.

4. Procedure for Concluding the Agreement

4.1. The Agreement is considered concluded from the moment of acceptance of this offer.

4.2. Acceptance is carried out in accordance with clause 1.3 of this offer.

4.3. After payment, the User receives Account credentials for connection.

4.4. The User confirms that they have reached the age of 18 or have full legal capacity.

5. Rights and Obligations of the Parties

5.1 The Offeror undertakes

• provide access to the Service in the volume of the selected tariff, taking into account the provisions of this Offer

• take reasonable measures to ensure the functioning of the infrastructure

• comply with the requirements of the legislation on personal data

5.2 The Offeror has the right

• change the technical parameters of the Service

• change tariffs

• limit the connection speed

• limit the volume of traffic

• suspend access in case of violation of the offer terms

• transfer information to state authorities in cases provided for by the legislation of the Russian Federation

5.3 The User undertakes

• use the Service exclusively for lawful purposes

• not to transfer Account credentials to third parties

• independently ensure the security of their device

• not to use the Service for the deliberate obtaining of access to prohibited information included in the registers of Roskomnadzor or the Ministry of Justice of the Russian Federation. Not to use the Services to obtain access to information whose distribution or access is restricted by a court decision or authorized body that has entered into legal force (including, but not limited to, the register of prohibited information of Roskomnadzor), as well as for searching, obtaining or distributing extremist materials or other prohibited information.

6. Cost of Services and Payment Procedure

6.1. The cost of the Service is determined by the tariffs posted in the Telegram bot and/or the Personal Account.

6.2. Payment is made in non-cash form through payment services.

6.3. The moment of payment is considered to be the confirmation by the payment operator.

6.4. The User has the right at any time to refuse the Service (terminate the agreement) by notifying the Offeror through the Telegram bot. The Offeror refunds the funds for the unused period of the Subscription minus the actually incurred expenses (infrastructure, payment system commissions, etc.). The amount of expenses is calculated by the Offeror and communicated within 5 business days. The refund is made within 10 business days after agreement on the amount.

6.5. Changes to tariffs do not apply to the already paid period of the Subscription.

7. Referral Program

7.1. The Offeror provides Users with the opportunity to participate in the Referral Program. Participation is carried out through the functionality of the Telegram bot and/or the Personal Account.

7.2. The Referrer receives a reward in the amount of 30 (thirty) percent of the Referee’s payment amount for the Subscription paid using the Referrer’s referral link or promo code.

7.3. The reward is credited to the Referrer’s Referral balance within 5 (five) business days after confirmation by the payment operator of the Referee’s first payment, as well as the Referee’s connection of the tariff.

7.4. The Referee does not receive any reward or bonuses under the Referral Program.

7.5. Funds from the Referral balance may be used by the Referrer to:

• pay for a Subscription for themselves in accordance with the current tariffs;

• withdraw to their bank details (or other methods available in the bot) provided that the accumulated reward amount is at least 3000 (three thousand) rubles.

7.6. Withdrawal of funds is carried out no more than once a month. A withdrawal request is formed through the corresponding section of the Telegram bot. The Offeror makes the payment within 10 (ten) business days from the moment of receiving correct details, confirmation of the amount, and verification of the Referees’ subscription connections.

7.7. The User independently bears all tax obligations arising in connection with the receipt of rewards under the Referral Program (including personal income tax). The Offeror is not a tax agent and does not withhold taxes from the reward.

7.8. It is prohibited to:

• perform self-referral (attracting oneself, one’s other accounts, family members or persons under one’s control);

• use spam, mass mailing, deception or other unfair methods of attracting Referees;

• transfer one’s referral link/promo code for artificial inflation of rewards;

• perform other illegal actions in accordance with the legislation of the Russian Federation.

In case of detection of violations, the Offeror has the right to cancel the accrued reward in full or in part, block the Referral balance, suspend or terminate the User’s participation in the Referral Program, and also restrict access to the Service without refunding previously paid funds.

7.9. The Offeror has the right at any time unilaterally to change the terms of the Referral Program (including the percentage amount, minimum withdrawal amount, accrual and withdrawal procedure) by publishing a new version in the Telegram bot and/or Personal Account. Changes come into force from the moment of publication and apply to legal relations that arose after such change. Continued participation in the program after publication of the changes means acceptance of the new version.

7.10. Detailed technical conditions and current rules of the Referral Program (including the bot interface) are posted in the corresponding section of the Telegram bot and/or Personal Account and are an integral part of this offer.

8. Liability of the Parties

8.1. The Offeror is not liable for:

• inability to use the Service due to reasons dependent on the User’s equipment;

• actions of third parties;

• interruptions in communication networks;

• restrictions on access to Internet resources.

8.2. The Offeror does not control or analyze the content of transmitted data. The Offeror is not liable for content transmitted or available through third-party resources, including websites, streaming platforms and social networks.

8.3. The User bears sole responsibility for all actions performed using their Account credentials.

8.4. The aggregate liability of the Offeror is limited to the amount of funds paid by the User for the last paid Subscription period.

8.5. The Offeror is not liable for blocking or restricting access to its servers by authorized bodies of the Russian Federation (Roskomnadzor, etc.), as well as for any consequences of such blocks for the User.

8.6. The User bears sole responsibility for compliance with the laws of the country where they use the Service. The Offeror is not liable for the consequences of using the service outside the Russian Federation.

8.7. The Service increases the confidentiality of the connection but does not guarantee complete anonymity of the User. The Offeror is not liable for the disclosure of identity as a result of the User’s own actions or third-party services.

8.8. The Offeror is not liable for actions of third parties in posting links, information or advertising about the Service and the Telegram bot without the consent of the Offeror in the media, on the Internet, in social networks or on any media. The Offeror does not control or approve such placement.

9. Confidentiality and Personal Data

9.1. The processing of personal data is carried out in accordance with Federal Law No. 152-FZ “On Personal Data”.

9.2. The Offeror processes the minimum necessary amount of data:

• Telegram identifier, data obtained during authorization via Google and/or Yandex (email address, name, unique identifier and other data in the volume provided by the relevant services);

• contact details (if any)

• payment information

9.3. The Offeror does not store the content of Users’ network traffic.

9.4. For the functioning of the service, technical connection logs may be maintained (session time, connection fact, traffic volume) without analyzing the content of the data. Technical logs are maintained solely to ensure the functioning of the service and to comply with the requirements of the legislation of the Russian Federation and do not contain the content of transmitted data.

9.5. The Offeror does not transfer Personal Data to third parties, except in cases expressly provided for by the legislation of the Russian Federation, including requests from authorized state bodies.

9.6. The detailed privacy policy (including the current list of processed data during authorization via Telegram, Google, Yandex and technical logs) is posted in the Telegram bot and/or in the Personal Account and is an integral part of this offer.

10. Term of the Agreement

10.1. The Agreement is valid from the moment of acceptance until the end of the paid Subscription period.

10.2. The User has the right to stop using the Service at any time.

10.3. The Offeror has the right to terminate the agreement in case of violation by the User of the offer terms; paid funds are not refundable.

11. Disclaimer of Warranties

11.1. The Service is provided on an “as is” and “as available” basis.

11.2. The Offeror does not guarantee:

• uninterrupted operation of the service

• absence of technical errors

• compatibility with all devices

• availability of any Internet resources

Technical maintenance, interruptions caused by actions of State bodies and temporary failures are not considered a violation of the offer terms.

11.3. Use of the Service is carried out by the User at their own risk.

12. Acceptable Use Policy

12.1. The User is prohibited from using the Service for:

• network attacks

• distribution of malicious software

• sending spam

• distribution of prohibited information

• copyright infringement

• unauthorized access to systems

• violation of the legislation of the Russian Federation or other states;

• other actions specified in this Offer

The Offeror has the right to immediately restrict access upon detection of violations.

13. Technical Limitations of the Service

The Offeror has the right to:

• limit connection speed

• set traffic limits

• disable server nodes

• perform technical maintenance

Such actions may be carried out without prior notice.

14. Limitation on the Number of Devices

14.1. The User has the right to use the Service simultaneously on no more than the number of devices provided for by the selected Tariff.

14.2. The Offeror has the right to limit the number of connections upon detection of anomalous activity.

15. Prohibition of Commercial Use

The Service is provided exclusively for personal use.

The User is not entitled to:

• resell access

• transfer access to third parties

• use the service as part of a commercial product

16. Right to Block Access

The Offeror has the right to restrict or terminate the User’s access:

• in case of violation of the offer

• in case of suspicious activity

• upon receipt of complaints (abuse reports)

The Offeror is not obliged to disclose the reasons for blocking.

17. Changes to the Infrastructure

The Offeror has the right to:

• change the number of servers

• change IP addresses

• change the server geography

• disable or add locations

Such changes are not considered a breach of the agreement.

18. Restrictions on Access to Internet Resources

The Offeror does not guarantee access to individual services, including:

• streaming platforms

• social networks

• banking services

• other Internet resources.

Refusal of third-party services to serve Users of the Service is not a breach of the agreement on the part of the Offeror.

19. Force Majeure

19.1. The Parties are released from liability for non-fulfillment of obligations in the event of force majeure circumstances, including but not limited to: actions of state authorities, changes in legislation, failures in network infrastructure, emergencies.

19.2. The Party for which it has become impossible to fulfill obligations must notify the other Party within a reasonable time.

20. Dispute Resolution

Disputes are resolved through negotiations.

Claims are sent in writing through the Bot and/or in the Personal Account, in the “Technical Support” section of the Offeror or to the email address info@slonprivacy.app

The period for consideration of a claim is 10 business days.

If no agreement is reached, the dispute is considered in court at the place of registration of the Offeror.

21. Details

Individual Entrepreneur Solomein Evgeny Sergeevich

OGRNIP 321774600494241

INN 421713484462

email address: info@slonprivacy.app