Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': 'FTC has jurisdiction over third-party data sharing practices and unfair or deceptive practices under FTC Act Section 5, including inadequate disclosure of data flows to bot developers.', 'complaint_url': 'https://reportfraud.ftc.gov/'}

What is the severity of this clause?

ConductAtlas classifies this Third-Party Bot Data Access clause as high severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Third-Party Bot Data Access — Telegram

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What it is

Third-party bots on Telegram are run by independent developers who are not controlled by Telegram, and they can receive your public account data, messages, IP address, and group membership information when you interact with them.

Consumer impact (what this means for users)

Interacting with any third-party bot on Telegram sends your public profile data, messages, and potentially your IP address to an independent developer whose data practices are outside Telegram's control and may not comply with privacy laws applicable to you.

Cross-platform context

See how other platforms handle Third-Party Bot Data Access and similar clauses.

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Why it matters (compliance & risk perspective)

When you interact with a bot on Telegram, your data is sent to an independent third-party developer whose privacy practices Telegram does not control or guarantee, creating significant unknown data handling risks.

View original clause language

Bots Are Not Maintained by Telegram. The terms of use for certain bots are set by Telegram. No other bots or third-party bot developers are affiliated with Telegram. They are completely independent from us. They should ask you for your permission before they access your data or you make it available to them.

Institutional analysis (Compliance & legal intelligence)

REGULATORY FRAMEWORK: This provision implicates GDPR Art. 13-14 (transparency obligations about third-party data recipients), Art. 26 (joint controllers), Art. 28 (data processors), and Art. 44-49 (international transfers to bot developers in unknown jurisdictions). The FTC Act Section 5 (unfair or deceptive practices) is relevant for US users if material data flows to third parties are not adequately disclosed. COPPA (15 U.S.C. § 6501) applies if minors interact with bots.

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Applicable agencies

FTC

FTC has jurisdiction over third-party data sharing practices and unfair or deceptive practices under FTC Act Section 5, including inadequate disclosure of data flows to bot developers.
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Provision details

Document information

Document

Telegram Privacy Policy

Entity

Document last updated

April 29, 2026

Tracking information

First tracked

April 18, 2026

Last verified

April 18, 2026

Record ID

CA-P-002910

Document ID

CA-D-00174

Evidence Provenance

Source URL

https://telegram.org/privacy

Wayback Machine

View archived versions →

SHA-256

379a11aff9a58881ad90b36de1e9479fc26a4085619c34a3087b3bd91bfdaaa1

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Telegram | Document: Telegram Privacy Policy | Record: CA-P-002910
Captured: 2026-04-18 10:46:01 UTC | SHA-256: 379a11aff9a58881…
URL: https://conductatlas.com/platform/telegram/telegram-privacy-policy/third-party-bot-data-access/
Accessed: May 2, 2026

Classification

Severity

High

Third-Party Bot Data Access