Public Offer

PUBLIC OFFER

Effective Date: March 06, 2026

1. General Provisions

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

1.2. This document constitutes 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 by the User performing one of the following actions:

• signing up for any Subscription through the Telegram bot @slon_privacy_bot;
• paying for the selected tariff;
• receiving or using technical data to connect to the Service.

1.4. Acceptance of the offer means full and unconditional acceptance of the terms of this Agreement by the User.

1.5. The Offeror may change the terms of this offer at any time. The new version comes into effect from the moment of its publication in the Telegram bot or on the Offeror’s website.

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

2. Terms and Definitions

Service — providing the User with access to the Offeror’s software and hardware complex, ensuring 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.

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

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

Tariff — the cost and conditions for providing the Service.

3. Subject of the Agreement

3.1. The Offeror undertakes to provide the User with access to the Offeror’s infrastructure to establish a secure network traffic transmission channel.

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

3.3. The Service is purely 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 for 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 independent 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 Credentials for connection.

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

5. Rights and Obligations of the Parties

5.1 The Offeror undertakes

• to provide access to the Service in the volume of the selected tariff, taking into account the provisions of this Offer;
• to take reasonable measures to ensure the functioning of the infrastructure;
• to comply with the requirements of personal data legislation.

5.2 The Offeror is entitled to

• change the technical parameters of the Service;
• change tariffs;
• limit connection speed;
• limit traffic volume;
• suspend access upon 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

• to use the Service exclusively for lawful purposes;
• not to transfer Credentials to third parties;
• to independently ensure the security of their device;
• not to use the Service for the deliberate receipt of access to prohibited information included in the registries of Roskomnadzor or the Ministry of Justice of the Russian Federation. Not to use the Services for access to information, the distribution of or access to which is restricted by a court decision or an authorized body (including, but not limited to, the Roskomnadzor registry of prohibited information), as well as for searching for, receiving, 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.

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 is entitled at any time to refuse the Service (terminate the agreement) by notifying the Offeror through the Telegram bot. The Offeror returns funds for the unused Subscription period minus actually incurred expenses (infrastructure, payment system commissions, etc.). The amount of expenses is calculated by the Offeror and communicated within 5 working days. Refund — within 10 working days after agreeing on the amount.

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

7. Liability of the Parties

7.1. The Offeror is not responsible for:

• the impossibility of using the Service for reasons depending on the User’s equipment;
• actions of third parties;
• interruptions in the operation of communication networks;
• restrictions on access to Internet resources.

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

7.3. The User independently bears responsibility for all actions performed using their Credentials.

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

7.5. The Offeror is not responsible for the blocking or restriction of access to its servers by authorized bodies of the Russian Federation (Roskomnadzor, etc.), as well as for any consequences of such blockings for the User.

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

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

7.8. The Offeror is not responsible for the actions of third parties in posting links, information, or advertisements about the Service and the Telegram bot without the Offeror’s consent in the media, the Internet, social networks, or on any media. The Offeror does not control or approve such postings.

8. Confidentiality and Personal Data

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

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

• Telegram identifier;
• technical identifiers (Telegram ID);
• information about payments.

8.3. The Offeror does not store the content of the User’s network traffic.

8.4. Technical connection logs (session time, fact of connection, traffic volume) may be kept for the functioning of the service without analysis of the data content. Technical logs are kept exclusively to ensure the functioning of the service and fulfillment of the requirements of the legislation of the Russian Federation and do not contain the content of the transmitted data.

8.5. The Offeror does not transfer Personal Data to third parties, except for cases directly provided for by the legislation of the Russian Federation, including requirements from authorized state bodies.

8.6. A detailed privacy policy (including the current list of processed data and technical logs) is posted in the Telegram bot and/or on the Offeror’s website and is an integral part of this offer.

9. Term of the Agreement

9.1. The Agreement is effective from the moment of acceptance until the end of the paid Subscription period.

9.2. The User is entitled to stop using the Service at any time.

9.3. The Offeror is entitled to terminate the agreement upon violation of the offer terms by the User; paid funds are not refundable.

10. Disclaimer of Warranties

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

10.2. 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 authorities, and temporary failures are not considered a violation of the offer terms.

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

11. Acceptable Use Policy

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

• network attacks;
• distribution of malware;
• sending spam;
• distribution of prohibited information;
• copyright infringement;
• unauthorized access to systems;
• violating the legislation of the Russian Federation or other states;
• other actions specified in this Offer.

The Offeror is entitled to immediately restrict access upon detection of violations.

12. Technical Restrictions of the Service

The Offeror is entitled to:

• limit connection speed;
• set traffic limits;
• disconnect server nodes;
• carry out technical maintenance.

Such actions may be carried out without prior notice.

13. Limitation of the Number of Devices

13.1. The User is entitled to use the Service simultaneously on no more than the devices provided for by the tariff.

13.2. The Offeror is entitled to limit the number of connections upon detection of abnormal activity.

14. 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.

15. Right to Block Access

The Offeror is entitled to restrict or terminate the User’s access:

• upon violation of the offer;
• upon suspicious activity;
• upon receipt of complaints (abuse reports).

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

16. Infrastructure Changes

The Offeror is entitled to:

• change the number of servers;
• change IP addresses;
• change the geography of servers;
• disconnect or add locations.

Such changes are not considered a violation of the agreement.

17. 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.

The refusal of third-party services to serve users of the Services is not a violation of the agreement on the part of the Offeror.

18. Force Majeure

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

18.2. The party for which the fulfillment of obligations became impossible must notify the other party within a reasonable time.

19. Resolution of Disputes

Disputes are resolved through negotiations.

Claims are sent in writing through the “Tech Support” section of the Offeror’s Bot or to the email address info_slonprivacy@proton.me

The period for considering a claim is 10 working days.

If an agreement is not reached, the dispute is considered in a court at the place of the Offeror’s registration.

20. Details

Individual Entrepreneur Evgeniy Sergeevich Solomein
OGRNIP 321774600494241
INN 421713484462
Email address: info_slonprivacy@proton.me