Privacy Policy for Telegram Mini Apps

Effective Date 15.08.2024

This page informs you of our policies regarding the collection, use, and disclosure of personal information when you use our Application.

1. Key Concepts

1.1. Developer: An individual or legal entity that publishes an application on the platform and uses it in accordance with the terms of the platform. Information about the Developer, such as name and other details, can be found in the "Developer Information" section within the app settings.

1.2. Application: A software service published by the Developer on the platform, included in the app catalog.

1.3. User: An individual who has registered and uses the Application.

1.4. Policy: This Privacy Policy outlines how information about Users is processed and protected.

2. General Provisions

2.1. This Policy is an official document of the Developer and defines the procedure for processing and protecting information about individuals using the Applications.

2.2. The goal of this Policy is to ensure the proper protection of information about Users, including their personal data, from unauthorized access and disclosure.

2.3. Relationships related to the collection, storage, distribution, and protection of information about Users are governed by this Policy and other official documents of the Developer, as well as applicable legislation.

2.4. The current version of this Policy, which is a public document, is available to any User on the internet via a hyperlink.

2.5. The Developer has the right to make changes to this Policy. When changes are made, the Developer publishes the new version of the Policy and updates the "Effective Date" at the top of the Policy. It is recommended that Users regularly check the terms of this Policy for changes. Continued use of the Application by the User after changes to this Policy indicates acceptance of and agreement with such changes.

2.6. By using the Applications, the User agrees to the terms of this Policy.

2.7. If the User disagrees with the terms of this Policy, the use of the Applications must be immediately terminated.

3. Conditions for Using the Applications

3.1. By providing services for using the Applications, the Developer reasonably and in good faith believes that the User:

• Has all the necessary rights to enable them to start and use the Applications.
• Provides accurate information about themselves as required for the use of the Applications.
• Understands that information shared while using the Applications may become available to other Users and may be copied and distributed by them.
• Understands that some types of information provided to other Users while using the Applications cannot be deleted by the User themselves.
• Is familiar with this Policy, agrees with it, and assumes the rights and obligations specified in it.

3.2. The Developer does not verify the accuracy of the information received (collected) about Users.

4. Purposes of Processing Information

The Developer processes information about Users, including their personal data, to fulfill the Developer's obligations to the Users regarding the use of the Application.

5. User Information Composition

The Developer processes the following information about Users:

• Personal data provided with the User's consent and necessary for the use of the Applications.
• Additional information about Users provided by the platform administration with the User's consent.
• Information provided by Users while using the Applications.
• Information obtained by the Developer as a result of User actions when using the Applications (e.g., IP addresses, cookies, application usage statistics).

6. Processing User Personal Data

6.1. Processing of personal data is based on the principles of:

• Legality and fairness of personal data processing.
• Correspondence of the purposes of personal data processing to the purposes predetermined and declared during the collection of personal data.
• Correspondence of the volume and nature of processed personal data to the stated purposes of processing.
• Inadmissibility of combining databases containing personal data for incompatible purposes.

6.1.1. Conditions and purposes of personal and other data processing

The Developer processes personal and other data of the User with their consent for providing services related to the use of the Applications.

6.1.2. Collection of personal and other data

Personal data and information are provided by the platform administration with the User's consent upon the first launch and/or use of the Application.

Additional User information is provided by the platform administration with the User's consent via an explicit action (e.g., pressing the "Allow" button) upon the first launch and/or use of the Application.

Information is collected by the Developer with the User's consent upon the first launch and/or use of the Application.

6.1.3. Transfer of personal data

Personal data is not transferred to third parties except as expressly provided for in this Policy. Providing personal data to government authorities is carried out in accordance with the law.

6.2. Information such as the User's name, profile photo, and usage information may be available to other Users of the Application.

6.3. Personal data is stored for the duration of the Application's use and for the period required by applicable law after the Application's use is terminated.

7. User Rights and Responsibilities

7.1. Users have the right to:

• Access information about themselves via the Applications.
• Receive information from the Developer regarding the processing of their personal data upon request.

8. Measures to Protect User Information

The Developer takes technical and organizational measures to ensure the protection of personal data from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unlawful actions. The description of these measures is contained in the Developer's internal regulations.

9. Policy Limitations

This Policy does not apply to the actions and resources of third parties. The Developer is not responsible for the actions of third parties that have gained access to User information due to the nature of the Application's platform, which is accessible to any internet User. Users are advised to carefully consider the amount of information they share.

10. User Inquiries

10.1. Users can send inquiries regarding the use of their personal data to the Developer in writing or in the form of an electronic document signed by a qualified electronic signature.

10.2. Inquiries should include:

• The User's identity document number and issuing authority details.
• Information confirming the User's relationship with the Developer.
• The User's or their representative's signature.

10.3. The Developer will review and respond to the inquiry within 30 days of receipt.

10.4. All correspondence is confidential and will not be disclosed without the User's written consent. Personal data and other information will be used solely to respond to the inquiry or as required by law.