The policy states that personal data may be shared with Telegram's parent company and affiliated entities in the British Virgin Islands and Dubai for service provision and improvement purposes. The stated transfer safeguard is Standard Contractual Clauses approved by the European Commission.
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 that user personal data is shared across Telegram's corporate group, including entities in jurisdictions without an EU adequacy decision, relying on Standard Contractual Clauses as the transfer mechanism. The adequacy of SCCs for transfers to the BVI and UAE requires ongoing assessment under GDPR guidance.
Interpretive note: The adequacy of SCCs for transfers to the BVI and UAE depends on transfer impact assessments and may vary based on current regulatory guidance and enforcement posture.
Under these terms, personal data provided to Telegram may be transferred to group companies in the British Virgin Islands and Dubai. The agreement states that Standard Contractual Clauses are used as the transfer safeguard, which is the standard mechanism for transfers to countries without an EU adequacy decision.
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Your personal information may be transferred to, stored, and processed in the United States or other countries outside of your country of residence, which may have data protection laws that are different from those in your country.
Your 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 may not be as protective as those in your jurisdiction.
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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
1. REGULATORY LANDSCAPE: This provision engages GDPR Chapter V (international transfers), specifically the Standard Contractual Clauses mechanism under GDPR Article 46(2)(c). Transfers to the British Virgin Islands and Dubai require SCCs or another Article 46 mechanism as neither jurisdiction has an EU adequacy decision. The European Data Protection Board has issued guidance on supplementary measures for transfers following the Schrems II decision. EEA national supervisory authorities have enforcement jurisdiction over the adequacy of transfer mechanisms. 2. GOVERNANCE EXPOSURE: Medium. The reliance on SCCs is a standard and legally recognized transfer mechanism, but the Schrems II decision requires a case-by-case transfer impact assessment to verify that SCCs provide effective protection in the destination jurisdiction. The BVI and UAE have different legal frameworks governing government access to data, which may affect the transfer impact assessment outcome. 3. JURISDICTION FLAGS: EEA and UK users have heightened exposure given the GDPR and UK GDPR requirements for international transfer safeguards. UK users should note that post-Brexit UK GDPR applies its own international transfer framework, and the International Data Transfer Agreement (IDTA) may be the applicable UK mechanism rather than EU SCCs. 4. CONTRACT AND VENDOR IMPLICATIONS: Organizations subject to GDPR that rely on Telegram for business communications should assess whether Telegram's intra-group transfer framework satisfies their own data processor obligations and supply chain due diligence requirements. The policy offers to provide further information on the SCC arrangements via the EEA representative. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should request details of the SCC arrangements and any transfer impact assessments from Telegram's EEA representative if required for their own GDPR compliance documentation. The policy provides contact details for EDPO at https://edpo.com/telegram-gdpr-data-request/ for this purpose.
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This provision establishes that user personal data is shared across Telegram's corporate group, including entities in jurisdictions without an EU adequacy decision, relying on Standard Contractual Clauses as the transfer mechanism. The adequacy of SCCs for transfers to the BVI and UAE requires ongoing assessment under GDPR guidance.
Under these terms, personal data provided to Telegram may be transferred to group companies in the British Virgin Islands and Dubai. The agreement states that Standard Contractual Clauses are used as the transfer safeguard, which is the standard mechanism for transfers to countries without an EU adequacy decision.
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