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.
Provision name changed from 'Intra-Group Data Sharing with BVI and Dubai Entities' to 'Intra-Group Data Transfers to BVI and Dubai Entities' (substituting 'Transfers' for 'Sharing') but excerpt content remains identical.
View full change record →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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"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
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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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