The policy states that message text may be shared with Google LLC or Microsoft Corporation when users request translation, and audio data from voice and video messages may be shared with Google LLC when users request transcription (a Telegram Premium feature). Both are described as user-initiated, restricted-purpose data transfers under agreements that prohibit secondary use by the third parties.
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 discloses that message content and audio data are transmitted to Google LLC and Microsoft Corporation for user-requested features. The policy asserts contractual restrictions on secondary use by those companies, though users depend on Telegram's enforcement of those contractual terms.
Under these terms, when users activate translation or voice-to-text features, message text or audio data is transmitted to Google LLC or Microsoft Corporation. These transfers are described as user-initiated and subject to contractual restrictions that prohibit secondary use, logging of audio, or use for advertising by the receiving companies.
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"Since Telegram may rely on Google LLC or Microsoft Corporation for automatic translation of messages, the text of any message or set of messages that users choose to translate may be shared with Google or Microsoft in order to obtain their translated versions. These third-party companies will only access the data to provide a translation and will not use it for any other products, services, or advertising. Since Telegram may rely on a third party, Google LLC, subsidiary of Alphabet Inc, for voice-to-text conversion, the audio data of voice and video messages that users choose to convert to text may be shared with Google in order to obtain their transcribed versions. Only audio data may be shared for this purpose (no other data, such as the user's IP address or any information about their account is shared). According to the agreement between Telegram and Google, Telegram will pay for the transcriptions on behalf of its users and Google will only access the audio data to provide a transcribed version – it will not log audio data or transcripts, and will not use the data for any other Google products, services, or advertising.— Excerpt from Telegram's Telegram Privacy Policy
1. REGULATORY LANDSCAPE: This provision engages GDPR Article 28 processor obligations, as Google LLC and Microsoft Corporation receive personal data (message content and audio) on behalf of Telegram. The transfers involve data leaving Telegram's infrastructure to US-headquartered processors, which may implicate GDPR Chapter V transfer adequacy requirements and the EU-US Data Privacy Framework. Applicable enforcement authorities include EEA national supervisory authorities and the UK ICO. 2. GOVERNANCE EXPOSURE: Medium. The policy asserts that Google and Microsoft are contractually restricted to providing the specific service requested and may not use the data for other purposes. However, users are dependent on Telegram's enforcement of those contracts and cannot independently verify compliance. Audio data shared for transcription may be particularly sensitive given the nature of voice message content. 3. JURISDICTION FLAGS: EEA and UK users should note that data transfers to Google LLC and Microsoft Corporation involve US-based processors, and the adequacy of transfer mechanisms should be evaluated under current GDPR guidance. California residents may have additional rights regarding data shared with third-party processors under CCPA. 4. CONTRACT AND VENDOR IMPLICATIONS: Telegram's characterization of Google and Microsoft as restricted-purpose processors relies on contractual agreements not published in the policy. Organizations with data handling obligations should assess whether Telegram's processor agreements with Google and Microsoft satisfy their own vendor management requirements. 5. COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the translation and transcription features are enabled by default or require affirmative user action, and ensure that user-facing consent or notice mechanisms adequately inform users before data is transmitted to third-party processors. The policy states these are user-initiated features, which supports an informed consent posture.
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This provision discloses that message content and audio data are transmitted to Google LLC and Microsoft Corporation for user-requested features. The policy asserts contractual restrictions on secondary use by those companies, though users depend on Telegram's enforcement of those contractual terms.
Under these terms, when users activate translation or voice-to-text features, message text or audio data is transmitted to Google LLC or Microsoft Corporation. These transfers are described as user-initiated and subject to contractual restrictions that prohibit secondary use, logging of audio, or use for advertising by the receiving companies.
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