29 December 2020

Slushaya Serdtsem (Слушая Сердцем //Listen With Your Heart) develops a mobile app for Documental Location Based Storytelling, which delivers interactive multimedia audio performances to your smartphone, based on your location. The multimedia performances are accessible via our app and our website at These performances are created by professional teams that we hire and inspire for these purposes.

When you use our services, Slushaya Serdtsem collects a limited set of personal information about you. This document describes the way Slushaya Serdtsem handles your personal information.

Who is Slushaya Serdtsem?

Slushaya Serdtsem is a non-profit non-governmental project initiated by Non-profit organization "VPC "Vympel-SPb" which legal registration is:

Autonomous Nonprofit Organization "Military Patriotic Center "Vympel-SPb"
(Автономная Некоммерческая Организация "Военно-патриотический центр "Вымпел-СПб")
194352 , St.Petersburg, Sirenevyi blvd, 10A, app.1
Phone: +7 921 350 08 82

Our official representative on the EU territory:
Mrs. Svetlana Spivak
Germany, Erlangen, Schenkstr.138

Slushaya Serdtsem is the controller for purposes of the General Data Protection Regulation (GDPR).

We Collect, Use, Share and Otherwise Process Information

Slushaya Serdtsem relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  • as necessary to provide the services and fulfill our obligations pursuant to the Terms of Service. For example, we cannot provide the services unless we collect and use your location information;
  • where you have consented to the processing, which you can revoke at any time.
  • where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  • to protect your vital interests, or those of others, such as in the case of emergencies;
  • where you have made the information public;
  • where necessary in the public interest; and
  • where necessary for the purposes of Slushaya Serdtsem's or a third party's legitimate interests, such as those of visitors, content providers or partners.

Our Legitimate Interests

We process your information in furtherance of our legitimate interests, including:

  • providing and improving the services, including any personalized services. We do so as it is necessary to pursue our legitimate interests of providing and developing innovative and tailored offerings to our members on a sustained basis; and
  • keeping the services safe and secure. We do so as it is necessary to pursue the legitimate interests of Slushaya Serdtsem and its users in ensuring the services are secure, and to protect against fraud, spam and abuse, etc.

What information does Slushaya Serdtsem collect and process, and for what purpose?

Slushaya Serdtsem provides its one main service: it delivers multimedia performances to users via their smartphones. We collect different types of data for different purposes, depending on how you use our services, as we discuss further below.

Data collected if you use our mobile Slushaya Serdtsem app
If you want to use our mobile app to listen to multimedia performances, you can do so without creating an account.

The app may offer the option to leave a review about a performance. If so, you will have to provide your name and a short text regarding your experience.

The app may offer the option to create a user account. If so, you will have to provide your name, email address and password. You may alternatively log in using your Facebook or Google account. If so, the Slushaya Serdtsem app will have access to the information stored and/or accessible in these accounts, including your timeline and/or newsfeed, in accordance with the permissions granted to it by you.

Some information is automatically collected when you use the mobile app: your browsing history within the app, location and your mobile device and operating system. This information is collected through Google Analytics (see below for more information on Google Analytics).

Slushaya Serdtsem can use this information to:

  • allow you to use the app;
  • suggest information to you, in particular on the basis of your location;
  • configure the app to your preferences;
  • communicate with you about the app and respond to any complaints and/or questions;
  • communicate with you about Slushaya Serdtsem and/or its products;
  • analyse the use of the app (including by means of Google Analytics); and protect, adjust and update Slushaya Serdtsem's services, in particular the app.
Slushaya Serdtsem may also process information collected via the mobile app to share aggregated information with certain third parties involved in performances. For example, Slushaya Serdtsem may share with a certain premise how long users stayed in their building on average in the past month. It will, however, not be possible for third parties to identify particular users from this aggregated data.

If you use the in-app payment system to donate to our Slushaya Serdtsem non-profit project development, the applicable platform provider (Google or Apple) will collect data on the payment in accordance with its privacy policy. Slushaya Serdtsem will obtain from Google or Apple information on your donation and transfer it to the Fund of New Performances Creation.

Data collected for communicating with you
If you want to stay up-to-date on the developments of Slushaya Serdtsem, you may register for our newsletter on our website at www.слушаясердцем.рф. We will collect your email address for this. Slushaya Serdtsem uses this information to send you our newsletter. If you do not wish to receive emails of Slushaya Serdtsem anymore, you can unsubscribe via an email to Also an opt-out option is provided in every email that Slushaya Serdtsem sends you.

How does Slushaya Serdtsem protect your personal information?

Slushaya Serdtsem takes appropriate technical and organizational measures to protect your (personal) information against loss or any form of unlawful use.

Transfer to third parties

As noted above, Slushaya Serdtsem may provide aggregated data on the use of the mobile app (including location data) and the website to others. This data is sufficiently aggregated so as to be anonymous.

Slushaya Serdtsem may provide your personal data to third parties if Slushaya Serdtsem is obliged to do so on account of national or international laws, case law and/or regulations, and Slushaya Serdtsem considers it necessary to do so in order to defend its own rights.

Other than the cases mentioned above, Slushaya Serdtsem will not transfer your data to third parties or provide third parties access to your data. And just to be clear: this means that Slushaya Serdtsem shall not provide your personal information to third parties for the purpose of direct marketing without your explicit consent.

What happens when I delete my account?

If you have created an end user account, all information you submitted in the course of the creation or administration of this account will be deleted. Please note that we maintain the data we collected about your use of the mobile app, because this allows us to provide aggregated statistics to others (see above about the provision of aggregated statistics). We will, however, ensure that the data does not contain references to your account anymore.

Cookies and Google Analytics

Slushaya Serdtsem uses two types of cookies on its website. Firstly, it uses cookies which are necessary to offer the functionality of our website and to remember your preferences and your cookie settings. Secondly, it uses analytics cookies from Google Analytics, Yandex Metrics and Google Audiences. They are web analysis services and use aggregated statistical information to provide Slushaya Serdtsem with an understanding of how users are using our mobile app and our website.

Viewing, changing and deleting your data

If you wish to know what information Slushaya Serdtsem has collected about you or if you wish to change data that you cannot change yourself through our website or our mobile app, please send a request to:

Transfer of data to countries outside the EU

For technical and operational reasons, it may be necessary for your (personal) data to be transferred to (the servers of) companies affiliated to Slushaya Serdtsem located in the United States or other countries outside of the EU. Slushaya Serdtsem will in this case comply with applicable data protection rules.

May minors use Slushaya Serdtsem?

If you have not yet reached the age of sixteen (16) years, you are obliged to obtain consent of your parents or legal guardian before using our mobile app and our website. By using our mobile app or our website, you guarantee that you are sixteen (16) years old or older or you have permission from your parents/legal guardian to use these services.

Can this privacy policy be changed?

It is possible for this privacy policy to be amended in the future. That would then be mentioned on www.слушаясердцем.рф, so it is recommended to regularly have a look at this page. In case of any amendments we inform all users regarding the updates via email addresses they used to register an end user account.


If you have any questions, please do not hesitate to contact us via