Telegram · Telegram Privacy Policy · View original document ↗

International Data Transfers to BVI and Dubai Group Companies

High severity Unique · 0 of 343 platforms
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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

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

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.

Consumer impact (what this means for users)

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.

How other platforms handle this

Zendesk Medium

Where Zendesk transfers personal data outside of the European Economic Area, the United Kingdom, or Switzerland, we rely on appropriate transfer mechanisms, including Standard Contractual Clauses approved by the European Commission, to ensure that your personal data receives an adequate level of pro...

Cohere Medium

Cohere is headquartered in Toronto, Canada, and has offices and infrastructure in various locations around the world. Personal information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws ma...

Synthesia Medium

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA) or United Kingdom, including the United States. Where we transfer your data internationally, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by th...

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▸ View Original Clause Language DOCUMENT RECORD
"
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

Applicable regulations

GDPR
European Union

Provision details

Document information
Document
Telegram Privacy Policy
Entity
Telegram
Document last updated
May 5, 2026
Tracking information
First tracked
April 18, 2026
Last verified
May 9, 2026
Record ID
CA-P-002914
Document ID
CA-D-00174
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
379a11aff9a58881ad90b36de1e9479fc26a4085619c34a3087b3bd91bfdaaa1
Analysis generated
April 18, 2026 10:46 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Telegram
Document: Telegram Privacy Policy
Record ID: CA-P-002914
Captured: 2026-04-18 10:46:01 UTC
SHA-256: 379a11aff9a58881…
URL: https://conductatlas.com/platform/telegram/telegram-privacy-policy/international-data-transfers-to-bvi-and-dubai-group-companies/
Accessed: June 17, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
High
Categories

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Frequently Asked Questions

What does Telegram's International Data Transfers to BVI and Dubai Group Companies clause do?

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.

How does this clause affect you?

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.

Is ConductAtlas affiliated with Telegram?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Telegram.