The terms disclose that Telegram's chat translation and voice-to-text transcription Premium features are processed by Google LLC, and Telegram does not guarantee the accuracy or availability of these services.
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 Premium voice transcription and translation features route data through Google LLC infrastructure, which is a material third-party data processing disclosure relevant to privacy assessments and data protection compliance.
Interpretive note: The document references the Privacy Policy for further detail on this data processing but does not describe the legal basis, transfer mechanisms, or scope of data shared with Google LLC within the Terms of Service itself.
Under this clause, users of Telegram's transcription and translation features should be aware that their voice and video message data is processed by Google LLC, and that the Telegram Privacy Policy contains further detail on how this data is handled.
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"The accuracy and availability of these technologies depend on a third party (Google LLC, subsidiary of Alphabet Inc.), and we can not guarantee that they will always be accurate and available.— Excerpt from Telegram's Telegram Terms of Service
(1) REGULATORY LANDSCAPE: The disclosure that Google LLC processes transcription and translation data engages GDPR requirements for data processor agreements (Article 28) and for international data transfers if data is processed outside the EU/EEA. The provision references the Telegram Privacy Policy for further privacy detail, but does not describe the data processing agreement structure or transfer mechanisms in place. (2) GOVERNANCE EXPOSURE: Medium. The disclosure of Google LLC as a data processor is notable for privacy compliance purposes, as it implicates a separate data controller with its own privacy practices. The extent of data sharing and the basis for processing are not described in this document. (3) JURISDICTION FLAGS: EU/EEA users are subject to GDPR requirements for processor agreements and international transfer mechanisms. Users in countries with data localization requirements face additional exposure if Google processes data outside their jurisdiction. (4) CONTRACT AND VENDOR IMPLICATIONS: Organizations using Telegram Premium in regulated industries should assess whether routing voice and message content through Google LLC is consistent with their data classification policies and contractual obligations to their own users or clients. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should review the Telegram Privacy Policy for the description of data flows to Google LLC, assess whether appropriate GDPR Article 28 processor agreements and transfer mechanisms are documented, and determine whether this third-party processing is disclosed adequately to end users at the point of feature activation.
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This provision discloses that Premium voice transcription and translation features route data through Google LLC infrastructure, which is a material third-party data processing disclosure relevant to privacy assessments and data protection compliance.
Under this clause, users of Telegram's transcription and translation features should be aware that their voice and video message data is processed by Google LLC, and that the Telegram Privacy Policy contains further detail on how this data is handled.
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