Privacy Policy

SLURM LLC (registered office at 397907, Russian Federation, Voronezh region, Liskinsky district, Liski town, "40 let oktebrya" street, building 83-B office 4; company's ID: 1193668020545) has prepared this data privacy policy ('Policy') to inform its users about how it collects, processes, uses and protects their personal data.

Questions regarding the Policy can be addressed to e-mail:

The Policy applies to users' data processed by SLURM LLC and applies to relations in the field of data processing that arose both before and after the approval of this Policy.

SLURM LLC handles all personal data in line with the applicable legislation, primarily Regulation (EU) 2016/679 of the European Parliament and of the Council, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("General Data Protection Regulation" or "GDPR").

Special rules that clarify the provisions of this Policy, including additional consents, may be contained in the rules, contracts, regulations that determine the conditions for the provision of services.

The use of the websites including registration, ordering, payment or actual use of the Services, entering into a contractual relationship, the actual provision of personal data, and giving consent to processing is subject to the terms of this Policy.
1. General definitions.
Personal Data is any information that allows the identification or is specifically attributable to a person. Personal Data does not include anonymous or aggregated data, i.e. data that cannot help to identify the data subject.

User means an individual whose Personal Data is processed by SLURM LLC (including a customer of services, a user of the Website or a subscriber to marketing materials of SLURM LLC).

Data Controller - In cases when an User provides personal data, for purchasing services, communicating in marketing campaigns, asking questions or making a complaint regarding the services, SLURM LLC deals with him/her from the position of Personal Data controller. As Data Controller, SLURM LLC determines the purpose and means for processing personal data. Data processing involves any operation with personal data, for example their collection, processing, organization, structuring, etc.

As Data Controller, SLURM LLC is concurrently responsible for compliance with all obligations and principles necessary to ensure the lawful use and adequate protection of Personal Data. Should any security breach of Personal Data occur, which nevertheless SLURM LLC naturally seeks to prevent, then will communicate this fact to the competent authority within maximum 72 hours.

If the Personal Data security breach involves a significant risk, SLURM LLC is also undertakes to inform the Users whose Personal Data is affected.

Processing means any operation or set of operations which is performed on Personal Data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Website - and

Service means any of the services that SLURM LLC offers to the Users, including products, services offered online and their promotion.
2. Legal basis for processing Personal Data
SLURM LLC obtains Personal Data from Users and further handle them only in the scope necessary in order to achieve the purposes stated In this Policy. Users provide Personal Data voluntarily, in cases when Processing is based on their consent and erasure of the processed Personal Data may be requested when certain conditions are met.

In certain cases, such as conclusion of an agreement for the acquisition of services, Users need to provide the Personal Data necessary for placing a binding order of service. Without this Personal Data, SLURM LLC will be unable to meet the requirements and conclude the above agreements with Users, due to having to ensure compliance with legislative obligations and protect the legitimate interests of Users.

The principal bases for the processing of Personal Data include the following:

Consent – Users may provide SLURM LLC consent for one or several specific purposes (for example for sending commercial messages).

For obtaining consent regarding Processing of Personal Data, SLURM LLC adheres to the following rules: (i) always collects consent for processing Personal Data from Users individually, meaning that will not require the consent as part of the text of a contract or another arrangement, (ii) the text of the consent will always be comprehensible, iii) consent will always be given as a result of User's active behavior, meaning no boxes will be pre-filled, (iv) for each processing purpose Users will give consent individually.

Compliance with legal obligations - SLURM LLC needs Users' Personal Data for their Processing to comply with legislative obligation.

Execution of the agreement - SLURM LLC obtains the Personal Data of Users to conclude an agreement and for its subsequent execution; or immediately before the conclusion of a contract (for example, for an order prior to the conclusion of the contract).

Legitimate interest – Processing User Personal Data would be necessary for the purposes of SLURM LLC's legitimate interests, except, however, for cases when User's interests or fundamental rights and freedoms prevail over these interests.
3. Purposes of processing Personal Data
Based on the legal grounds for processing Personal Data indicated above, SLURM LLC will most frequently require Users' Personal Data for the following purposes:

Provision of the Services – the legal basis shall be represented by the conclusion and performance of the contract, or performance before the conclusion of the maintenance contract and provision of the service.

Marketing purposes and quality improvement – the legal basis shall be represented by giving consent with the receiving of commercial announcements.

Tax, bookkeeping, archiving - SLURM LLC is subject to various legal requirements and will at times have to process User's Personal Data for purposes such as booking, calculating and filing tax statements, archiving etc.

Direct marketing or protection of legal interests SLURM LLC may Process Personal Data for purposes such as direct marketing and protecting its legal interests in accordance with the law with observing at the same time any overriding interest that the User might have.

4. Categories of Personal Data

4.1. As a Controller SLГRM LLC can process Personal Data of the following categories of Personal Data Users:

Clients and representatives of clients: surname, name, patronymic; date and place of birth; passport data; place of residence or other place for living; contact details; individual taxpayer number; bank details; other Personal Data provided by clients (individuals) necessary for the conclusion and execution of contracts.

Website users: data on technical means (devices), technological interaction with the Website, including the IP address of the host, type of operating system, type of browser, geographic location, parameters of the graphical environment, etc., information automatically obtained when accessing the Website by using cookies, information created and added on the Website (reviews, comments, etc.), if the Website contains appropriate functionalities, generalized analytical information about the use of the Website, such as duration of sessions, traffic routes, etc.

LLC "SLURM" does not process biometric and special categories of personal data.

The content and volume of processed Personal Data must comply with the stated processing objectives provided for in this Policy. The processed Personal Data should not be redundant in relation to the stated purposes of their processing.
5. The procedure and conditions for the Processing of Personal Data
Employees of SLURM LLC, whose job responsibilities include the process Personal Data, are subject to confidentiality obligations.

Receiving Personal Data is carried out by:

  • receiving Personal Data orally and in writing directly from subjects of Personal Data on their initiative (filling out registration forms, surveys, subscribing to mailing lists, sending resumes, sending (including a response) letters, chat forms, instant messengers, etc.);
  • obtaining Personal Data from publicly available sources;
  • obtaining Personal Data from other persons on the basis of the consent provided, including as part of the implementation of partnership programs, loyalty programs.
In the case of using the Website, the collection of Personal Data begins from the moment Users access it.
6. Personal Data protection measures

SLURM LLC gives due care to Personal Data protection; for this reason, it adheres to the technical and organizational measures listed below to ensure the security of personal data. These measures include:

Control of physical access – SLURM LLC stores all Personal Data in a manner to protect access to it, meaning that places where Personal Data is stored are secured by technical means such as smart cards, keys, electronically lockable door etc.

Controlled access – access to Personal Data storing systems is subjected to a password or two-factor verification and, thus, data is accessible only to authorized persons.

Access control – measures that prevent unauthorized reading, copying, modification, removal from the system or other dealing with them.

Creation of pseudonyms – processing Personal Data by modifying them into a form in which they are not attributable to a specific person (they are pseudonymised).

Control of the transfer – all dealing with Personal Data in their electronic transfer is protected to prevent unauthorized reading, copying, modification or erasure.
7. Transfer of Personal data
SLURM LLC may transfer Users' Personal Data to the following third parties: Government agencies (on request).

In the case of cross-border transfer of Personal Data to the territory of a foreign state, the specified cross-border transfer must be carried out in compliance with the requirements of the current legislation.

SLURM LLC takes care to ensure that:

  • Sharing Personal Data for a specific purpose (e.g. preparation of a marketing campaign);
  • Transfer of only a clearly defined and necessary scope of personal data;
  • Transfer based on a duly concluded contract for Personal Data processing; and Sharing made in a secured manner (encrypting, pseudonymisation, etc.).
Users' Personal Data shared with countries outside the European Union, European Economic Area based on standard contractual clauses, i.e. template contract issued by the European Commission, and these will include entities based in countries that ensure adequate Personal Data protection according to the resolution of the European Commission.
8. Storage of Personal Data
When collecting Personal Data, including via the Internet, SLURM LLC may provide recording, systematization, accumulation, storage, clarification (updating, modification), extraction of Personal Data of Users using databases located outside European Union, including in the Russian Federation.

SLURM LLC stores Users' Personal Data for as long as they are in a contractual relationship with it and after its termination until the end of the limitation period, including for the purpose of defense in litigation procedures.
9. Rights of Users as a Personal Data subject

Right to access information on Personal Data processing
Entitles Users to obtain information relating to the processing of their Personal Data.

Concurrently, Users are entitled to know the legal basis for processing (e.g. performance of the contract), purpose (e.g. contracts for the purchase of services) or information on the period of Personal Data storage. SLURM LLC undertakes to inform Users on the legal basis and purpose of the Personal Data processing before it start to process them.

Right to access personal data.
Entitles Users to obtain the information whether SLURM LLC process Personal Data and if it does so, in what scope. Concurrently, Users have the right to request a copy of the processed personal data. Upon User's request, SLURM LLC is also obliged to inform User on the purpose of data processing, recipient of processed personal data, or other related information.

Right to rectification
The User can ask SLURM LLC, for example, to update any of its Personal Data provided this has changed (e.g. change in the surname, in address, etc.).

As Data Controller, SLURM LLC is not obliged to actively check whether the Personal Data that it collect is up to date, incorrect or inaccurate, however SLURM LLC is obliged to rectify the Personal Data following a notification from the User.

Right to erasure
Also called the "right to be forgotten" requires SLURM LLC, as the Personal Data Сontroller, to delete Personal Data of Users, in the following cases:

  • the processing purpose no longer exists (e.g. termination of the contract);
  • User withdraw its consent for Personal Data processing and there is no other ground for processing Personal Data (e.g. withdrawal of the marketing consent provided);
  • User objects to Personal Data processing (if allowed and no other legal grounds justify the of processing personal data); and
  • In accordance with the applicable legislation, SLURM LLC is required to erase data (e.g. obligation to delete electronic records).
Right to object

Analogous to the right for withdrawal of consent, this right applies when Personal Data is processed pursuant to a legitimate interest of the Data Controller. Users may also object when their Personal Data is processed for direct marketing. In justified cases, Personal Data will be erased when the objection is acknowledged and SLURM LLC will no longer process them.

Right for data portability
If Users ask SLURM LLC to transfer Personal Data to another controller, SLURM LLC is obliged to do so and transfer them in a structured, commonly used and machine-readable format. Users may exercise this right only when the processing is based on the consent or contract and concurrently it is automated, i.e. processing solely made using technical means based on a pre-determined algorithm and without any human intervention.
10. Updates of the Policy

SLURM LLC has at any time the right to amend this Policy unilaterally by publishing the changes (or amended version) on the Website. All changes apply from the date of publication, unless a later date is indicated.