This analysis describes what Telegram's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes the mechanism and scope for international data transfers across Telegram's corporate group structure. The authorization relies on European Commission-approved standard contractual clauses as the legal safeguard framework for cross-border data flows.
Users' personal data may be transferred to and processed by Telegram Group Inc. (BVI), Telegraph Inc. (BVI), and Telegram FZ-LLC (Dubai) pursuant to this authorization. The terms apply as written upon continued service use, establishing these group company locations as recipients of personal data processed in connection with service delivery.
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"To provide, improve and support our Services, we may share your personal data with: (1) our parent company, Telegram Group Inc, located in the British Virgin Islands, (2) Telegraph Inc., a group member also located in the BVI; and (3) Telegram FZ-LLC, a group member located in Dubai. We will implement appropriate safeguards to protect the security and integrity of that personal data. This will take the form of standard contract clauses approved by the European Commission in an agreement between us and our relevant group companies.— Excerpt from Telegram's Telegram Privacy Policy
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This provision establishes the mechanism and scope for international data transfers across Telegram's corporate group structure. The authorization relies on European Commission-approved standard contractual clauses as the legal safeguard framework for cross-border data flows.
Users' personal data may be transferred to and processed by Telegram Group Inc. (BVI), Telegraph Inc. (BVI), and Telegram FZ-LLC (Dubai) pursuant to this authorization. The terms apply as written upon continued service use, establishing these group company locations as recipients of personal data processed in connection with service delivery.
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