Telegram can share your personal data with its parent company and affiliates in the British Virgin Islands and Dubai, using standard contractual clauses as the legal mechanism for EEA data transfers.
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
Your personal data may be transferred to entities in jurisdictions that do not have EU adequacy decisions, meaning the legal protection depends on the quality and enforcement of the standard contractual clauses in place.
Interpretive note: The adequacy of the standard contractual clauses for transfers to BVI and UAE depends on undisclosed transfer impact assessments and supplementary measures that are not described in the policy, creating uncertainty about practical compliance with GDPR Chapter V.
EEA and UK users' personal data may be shared with Telegram group companies in the British Virgin Islands and Dubai, neither of which has an EU adequacy decision, relying solely on standard contractual clauses as a safeguard that cannot be independently verified by users.
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Protect us, our business, our users, and others, for example to enforce our terms of service, prevent spam or other unwanted communications, and investigate or protect against fraud
we may use, retain or share information with law enforcement or others in circumstances where a person's vital interests require protection, such as in the case of emergencies.
we may share data between our affiliates for the safety and security of our users and may take necessary actions if we believe you have violated these Terms, including banning you from our Services and/or our affiliates' services...
"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 Privacy Policy
REGULATORY LANDSCAPE: This provision directly engages GDPR Chapter V on international data transfers, specifically Articles 44-46.
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Your personal data may be transferred to entities in jurisdictions that do not have EU adequacy decisions, meaning the legal protection depends on the quality and enforcement of the standard contractual clauses in place.
EEA and UK users' personal data may be shared with Telegram group companies in the British Virgin Islands and Dubai, neither of which has an EU adequacy decision, relying solely on standard contractual clauses as a safeguard that cannot be independently verified by users.
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