Slava Tech Privacy Policy

Slava Tech Privacy Policy

Version: 1.0

Effective Date: 2026-08-01

Version History

1. Introduction

Slava Tech ("we," "our," or "us") is committed to protecting your privacy and handling your personal information responsibly.

This Privacy Policy explains:

• What information we collect.

• Why we collect it.

• How we use it.

• When we share it.

• How we protect it.

• The choices and rights available to you regarding your personal information.

Our goal is to collect only the information reasonably necessary to provide our educational services, operate our platform securely, comply with legal obligations, and improve the customer experience.

2. Scope

This Privacy Policy applies to personal information collected through:

• The Slava Tech website.

• Student accounts.

• Course purchases.

• Educational services.

• Customer support interactions.

• Administrative platform functions.

• Related online services operated by Slava Tech.

This Privacy Policy does not apply to third-party websites or services that maintain their own independent privacy policies.

3. Privacy Principles

Slava Tech is guided by the following principles:

• We collect only the information reasonably necessary to operate our Services.

• We use personal information only for legitimate business purposes.

• We do not sell customer personal information.

• We protect customer information using appropriate technical and organizational safeguards.

• We retain information only for legitimate business, legal, accounting, security, and operational purposes.

• We respect applicable privacy laws and customer privacy rights.

Privacy protection is incorporated into the design and operation of the Slava Tech platform wherever practical.

4. Information We Collect

Depending on how you use our Services, we may collect the following categories of information.

Account Information

When you create an account, we may collect information such as:

• Email address.

• Authentication credentials.

• Display name or profile information that you choose to provide.

• Account status information.

Passwords are securely managed through our authentication provider and are never stored in plain text by Slava Tech.

Educational Information

To provide access to purchased educational content, we may maintain records including:

• Purchased Courses.

• Course entitlements.

• Course version assignments.

• Access periods.

• Student account status.

• Educational progress information where supported by the platform.

Activity Information

To protect the platform, administer customer access, and maintain operational records, we may collect information regarding your use of the Services, including:

• Account sign-in and sign-out activity.

• Access authorization events.

• Course entitlement activity.

• Administrative account actions affecting your account.

• Security-related operational events.

Where platform features support them, activity records may also include educational interactions such as course access, download activity, or media playback events.

Communications

When you contact Slava Tech, we may retain records of communications necessary to:

• Respond to your inquiry.

• Provide customer support.

• Resolve technical issues.

• Improve our Services.

• Maintain appropriate business records.

Information We Do Not Collect

Slava Tech does not intentionally collect personal information that is unnecessary for providing our educational Services.

In particular:

• We do not store complete payment card information.

• We do not sell customer personal information.

• We do not collect sensitive personal information unless required by law or voluntarily provided by you in connection with customer support or legal obligations.

Payment information is processed by our authorized payment provider and is subject to that provider's own privacy practices.

5. Information Collected Automatically

When you use the Services, certain technical information may be collected automatically to support authentication, platform security, service reliability, and normal platform operation.

Depending on platform functionality, this information may include:

• Authentication session information.

• Device and browser information.

• Technical diagnostic information.

• Security and authorization records.

• Required browser storage used to maintain secure authenticated sessions.

This information is used only for legitimate operational, security, and service-delivery purposes.

6. How We Use Your Information

Slava Tech uses personal information only for legitimate business purposes related to providing and improving our educational Services.

Depending on how you use the Services, your information may be used to:

• Create and manage your customer account.

• Authenticate your identity and maintain secure access.

• Deliver purchased Courses and educational resources.

• Manage course entitlements and access periods.

• Process purchases and related transactions.

• Respond to customer support requests.

• Maintain platform security and prevent unauthorized access.

• Detect fraud, abuse, or misuse of the Services.

• Maintain audit and operational records.

• Comply with applicable legal and regulatory obligations.

• Improve the reliability, security, and functionality of the platform.

We do not use your personal information for automated decision-making that produces legal or similarly significant effects.

7. Legal Basis for Processing

Where required by applicable privacy laws, Slava Tech processes personal information only when an appropriate legal basis exists.

Depending on the circumstances, processing may be based upon:

• Performance of a contract with you.

• Compliance with legal obligations.

• Our legitimate interests in operating, securing, and improving the Services.

• Your consent, where consent is required by law.

Where processing is based on your consent, you may withdraw that consent at any time when legally applicable. Withdrawal of consent does not affect processing that occurred before consent was withdrawn.

8. Third-Party Service Providers

Slava Tech works with trusted third-party service providers to operate and support the Services.

These providers may perform services including:

• Customer authentication.

• Secure hosting.

• Database services.

• Cloud infrastructure.

• Payment processing.

• Educational content delivery.

• Email delivery.

• Security and operational support.

These providers receive only the information reasonably necessary to perform the services they provide.

Each provider is responsible for protecting information under its own contractual obligations and applicable privacy laws.

Where a third-party provider maintains its own independent privacy practices, those practices apply in addition to this Privacy Policy.

9. Payment Processing

Payments for Courses and other Services are processed by an authorized third-party payment provider.

Slava Tech does not receive or store complete payment card information.

The payment provider may collect information including:

• Billing information.

• Payment method information.

• Tax information.

• Transaction details required to process purchases and comply with applicable financial regulations.

Processing of payment information is governed by the payment provider's own privacy policy and legal obligations.

10. Information Sharing

Slava Tech does not sell customer personal information.

We share personal information only when reasonably necessary to operate the Services or when required by law.

Information may be shared with:

• Service providers supporting the operation of the platform.

• Payment providers processing purchases.

• Government authorities where required by applicable law.

• Professional advisers such as accountants, legal counsel, or auditors when necessary for legitimate business purposes.

• Successors in connection with a merger, acquisition, business transfer, or similar corporate transaction, subject to applicable privacy obligations.

We do not permit third parties to use your personal information for their own marketing purposes solely because they provide services to Slava Tech.

11. International Data Processing

The Services may utilize technology providers that process or store information in countries outside the Republic of Serbia.

When personal information is transferred internationally, Slava Tech seeks to work with providers that maintain appropriate safeguards designed to protect customer information in accordance with applicable privacy laws.

The geographic location of data processing may vary depending upon the infrastructure used by authorized service providers.

12. Information Security

Protecting customer information is an important part of operating the Slava Tech platform.

We use reasonable technical and organizational measures designed to help protect personal information against unauthorized access, disclosure, alteration, or destruction.

These measures may include:

• Secure authentication.

• Role-based authorization.

• Encrypted communications.

• Controlled access to customer information.

• Operational monitoring and audit records.

• Security logging.

• Platform access controls.

While we work to protect customer information, no system connected to the Internet can be guaranteed to be completely secure.

Customers are also responsible for maintaining the confidentiality of their account credentials and for promptly notifying Slava Tech if they believe their account has been compromised.

13. Browser Storage and Authentication

The Slava Tech platform uses only the browser storage and technical session information reasonably necessary to provide secure authentication and operate the Services.

These technologies may be used to:

• Maintain secure authenticated sessions.

• Verify customer identity.

• Protect customer accounts.

• Support platform security.

• Improve service reliability.

The platform does not currently use browser storage for advertising or behavioral advertising purposes.

Where additional technologies are introduced in the future, this Privacy Policy will be updated as appropriate.

14. Data Retention

Slava Tech retains personal information only for as long as it is reasonably necessary to:

• Provide the Services.

• Maintain customer accounts.

• Fulfill contractual obligations.

• Comply with legal, accounting, and tax requirements.

• Protect the security and integrity of the platform.

• Resolve disputes and investigate fraud.

• Preserve evidence of customer transactions and policy acceptance.

As part of our normal operational procedures, customer information may be periodically archived from production systems into secure long-term storage.

Archived records may be retained for up to seven (7) years, or longer where required by applicable law or where reasonably necessary to:

• Resolve legal claims.

• Comply with accounting or tax obligations.

• Investigate fraud or security incidents.

• Preserve evidence relating to purchases, refunds, policy acceptance, or other business records.

When personal information is no longer required for these purposes, Slava Tech will securely delete or anonymize the information where reasonably practical and consistent with applicable legal obligations.

15. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• Request access to your personal information.

• Request correction of inaccurate personal information.

• Request deletion of personal information where legally permitted.

• Request restriction of certain processing activities.

• Object to processing based upon legitimate interests where applicable.

• Request a copy of personal information that you have provided to us where required by law.

• Withdraw consent where processing is based upon your consent.

Some requests may be limited where Slava Tech is required to retain information for legal, accounting, security, fraud prevention, contractual, or other legitimate business purposes.

Privacy requests may be submitted using the contact information provided at the end of this Privacy Policy.

16. Policy Acceptance Records

To demonstrate customer agreement with important legal documents governing the Services, Slava Tech may maintain records of policy acceptance.

These records may include:

• The policy accepted.

• The version accepted.

• The date and time of acceptance.

• The method by which acceptance was provided.

Policy acceptance records are retained as part of our legitimate business records and may be used to demonstrate the terms governing the use of the Services at a particular point in time.

17. Children's Privacy

The Services are intended for individuals who are legally permitted to enter into binding agreements and purchase educational services.

Slava Tech does not knowingly collect personal information from children in violation of applicable law.

If we become aware that personal information has been collected inappropriately from a child, we will take reasonable steps to investigate the matter and, where appropriate, delete the information or otherwise comply with applicable legal requirements.

Parents or legal guardians who believe that a child has provided personal information may contact Slava Tech using the contact information provided in this Privacy Policy.

18. Your Privacy Choices

Customers may choose whether to:

• Create a customer account.

• Purchase educational Services.

• Contact customer support.

• Receive optional marketing communications, where offered.

Certain information is required in order to provide the Services. If you choose not to provide information necessary for account creation, authentication, payment processing, or course access, some or all of the Services may not be available.

Customers may discontinue use of the Services at any time, subject to any continuing contractual or legal obligations that apply.

19. Accuracy of Information

Customers are responsible for providing accurate account information and for keeping that information reasonably up to date.

Maintaining accurate information helps ensure:

• Reliable account access.

• Successful customer communications.

• Accurate purchase records.

• Proper administration of course entitlements.

• Effective customer support.

Where permitted by the platform, customers may update certain account information directly. Other changes may be requested by contacting Slava Tech.

Slava Tech Privacy Policy

Part 4

20. Changes to This Privacy Policy

Slava Tech may update this Privacy Policy from time to time to reflect:

• Changes to our Services.

• Improvements to platform functionality.

• Changes in applicable laws or regulations.

• New third-party service providers.

• Security enhancements.

• Changes to our data processing practices.

When material changes are made, we will update the Version number and Effective Date shown at the beginning of this Privacy Policy.

Where required by applicable law or where changes materially affect your rights, we will provide appropriate notice before the revised Privacy Policy becomes effective.

Your continued use of the Services after the Effective Date of an updated Privacy Policy constitutes acknowledgment of the revised Privacy Policy where permitted by applicable law.

21. Exercising Your Privacy Rights

If you wish to exercise any privacy rights available to you under applicable law, you may contact Slava Tech using the contact information provided below.

Depending upon the nature of your request, we may ask you to verify your identity before processing the request in order to protect your personal information.

We will respond to privacy requests within a reasonable period and in accordance with applicable legal requirements.

In certain circumstances, we may decline or limit a request where permitted or required by law, including where information must be retained for:

• Legal obligations.

• Accounting and tax requirements.

• Fraud prevention.

• Security investigations.

• Contractual obligations.

• Preservation of business records.

• Protection of the rights of Slava Tech or others.

Where a request cannot be fully honored, we will explain the reason unless prohibited by law.

22. Complaints

If you believe that Slava Tech has not handled your personal information in accordance with applicable privacy laws, we encourage you to contact us first so that we have an opportunity to investigate and resolve your concerns.

Where applicable, you may also have the right to submit a complaint to the competent data protection authority responsible for your jurisdiction.

Nothing in this Privacy Policy limits any rights that cannot be excluded under applicable law.

23. Contact Information

Questions regarding this Privacy Policy or requests relating to your personal information may be directed to:

Slava Tech

Email: <u>contactus@slava-tech.com</u>

Website: <u>https://slava-tech.com</u>

24. Severability

If any provision of this Privacy Policy is determined to be invalid, unlawful, or unenforceable by a court or other competent authority, the remaining provisions shall remain in full force and effect.

Any invalid or unenforceable provision shall be interpreted, where possible, in a manner consistent with its original purpose while remaining compliant with applicable law.

25. Relationship to Other Policies

This Privacy Policy should be read together with the following Slava Tech customer policies:

• Terms of Service

• Refund Policy

Each policy serves a different purpose and should be interpreted consistently with the others.

Where another policy specifically governs a particular subject, that policy shall apply to that subject.

Commitment to Privacy

Slava Tech believes that responsible use of technology includes responsible stewardship of customer information.

We are committed to operating our educational platform with transparency, accountability, and respect for customer privacy.

Our objective is to collect only the information necessary to provide high-quality educational services while maintaining appropriate safeguards to protect the information entrusted to us.