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Privacy Policy

Effective Date: April 17, 2026

1. General Provisions

1.1. This Privacy Policy (hereinafter referred to as the “Policy”) defines the procedure and conditions for processing personal data that the Offeror (Individual Entrepreneur Solomein Evgeny Sergeevich, OGRNIP 321774600494241, INN 421713484462, contact email: info@slonprivacy.app) receives from Users when using the Telegram bot @slon_privacy_bot (hereinafter referred to as the “Bot”), the Personal Account on the website https://my.slonprivacy.app (hereinafter referred to as the “Account”), and the provision of Services under the public offer agreement (hereinafter referred to as the “Offer”).

1.2. This Policy is developed in accordance with the requirements of Federal Law No. 152-FZ dated July 27, 2006 “On Personal Data” and other regulatory acts of the Russian Federation in the field of personal data protection.

1.3. The use of the Bot, the Account, authorization in the Account and/or acceptance of the Offer means the User’s unconditional consent to this Policy and the conditions for processing their personal data. If the User disagrees, they must stop using the service.

1.4. The Offeror reserves the right to make changes to this Policy. The new version comes into force from the moment of its publication in the Bot and/or in the Account, unless otherwise specified in the new version. Continued use of the service after publication of the new version means the User’s agreement with its terms.

1.5. The Offeror is the operator of personal data and independently determines the purposes, composition of personal data, and actions (operations) performed with personal data.

2. Principles of Personal Data Processing The Offeror processes personal data based on the following principles:

• legality and fairness;

• limitation of processing to predetermined purposes;

• minimization of the volume of processed data;

• ensuring accuracy and relevance of data;

• limitation of storage periods;

• ensuring confidentiality and security of personal data.

3. Categories of Data Subjects and Composition of Processed Data

3.1. The Offeror processes personal data of the following categories of subjects: Users — individuals who have reached the age of 18.

3.2. The following categories of personal data are processed:

• Telegram user identifier (Telegram ID);

• authorization data through Google and/or Yandex: email address, as well as other data provided by the respective services;

• contact details (email address, if provided by the User);

• payment information in the volume transmitted by payment systems (payment amount, date, transaction identifier), without storing full bank card details;

• technical connection logs (session start and end time, connection fact, volume of transmitted and received traffic);

• technically necessary cookies.

3.3. The Offeror does not collect or store:

• the content of the User’s network traffic;

• browsing history;

• DNS queries;

• IP addresses of end resources;

• any other data that allows determining the content of the User’s internet activity.

3.4. The Offeror does not process special categories of personal data, including information about health, political views, religious beliefs, or other sensitive data.

4. Purposes of Personal Data Processing Personal data is processed exclusively for the following purposes:

• identification of the User and provision of access to the Services;

• authorization in the Account (including via Google and Yandex);

• subscription registration, payment and management;

• confirmation of payments;

• provision of technical support;

• prevention of abuse and unlawful use of the service;

• compliance with the requirements of the legislation of the Russian Federation;

• improving the quality of the service based on anonymized data.

The Offeror does not perform profiling of Users and does not make automated decisions that have legal consequences for the User.

5. Legal Grounds for Processing The processing of personal data is carried out on the following grounds:

• the User’s consent to the processing of personal data (including through actions of authorization and use of the service);

• performance of the contract (public offer);

• fulfillment of obligations provided for by the legislation of the Russian Federation.

6. Procedure and Conditions for Processing Personal Data

6.1. Processing of personal data is carried out by a mixed method — using automation tools and without using such tools.

6.2. The Offeror does not transfer personal data to third parties, except in the following cases:

• payment systems YooKassa and Tribute — to the extent necessary for payment processing;

• Google and Yandex — when authorizing through their services;

• if such transfer is provided for by the legislation of the Russian Federation;

• upon a lawful request from state authorities.

6.3. Data storage periods:

• payment and Subscription data — during the term of the agreement and up to 3 years after its termination;

• technical connection logs — no more than 12 months from the moment of the session;

• other data — until the purposes of processing are achieved or until the User withdraws consent.

6.4. Upon achievement of the purposes of processing, personal data shall be destroyed or anonymized, unless otherwise provided by the legislation of the Russian Federation.

6.5. Within the framework of the service operation, certain technical elements of the infrastructure may be located outside the Russian Federation. In such cases, cross-border transfer of data may be carried out to the extent necessary for the provision of the service.

7. Use of Third-Party Platforms

• The Bot operates on the Telegram platform — the Operator is not responsible for data processing by the Telegram platform itself.

• Authorization through Google and Yandex is governed by their own privacy policies.

• Payment through YooKassa and Tribute is governed by the policies of the respective services.

8. Measures to Ensure Data Security The Operator takes the necessary organizational and technical measures to protect data, including encryption, access restriction, vulnerability control, and compliance with legal requirements.

9. Rights of the Personal Data Subject In accordance with the legislation of the Russian Federation, the User has the right to:

• receive information about the processing of their personal data;

• request clarification, blocking or destruction of data;

• withdraw consent to the processing of personal data;

• appeal the actions of the Offeror to Roskomnadzor or in court.

Requests should be sent to the email address: info@slonprivacy.app

The deadline for consideration of a request is up to 10 business days (or another period established by law).

Withdrawal of consent does not affect the processing of data carried out before the withdrawal and may result in the impossibility of further provision of the Service.

10. Limitation of Liability The Offeror takes reasonable measures to protect Users’ personal data, but cannot guarantee absolute security of data transmission over the Internet.

11. Final Provisions

11.1. This Policy is a public document and is posted in the Telegram bot @slon_privacy_bot and on the website https://my.slonprivacy.app

11.2. Questions related to the processing of personal data should be sent to the email address info@slonprivacy.app.

12. Details

Individual Entrepreneur
Solomein Evgeny Sergeevich
OGRNIP 321774600494241
INN 421713484462
email: info@slonprivacy.app