Personal data in Telegram

How are bots launched and what data is collected?

There are several ways to launch telegram bots:

  • Via the " START " button, the user initiates the interaction, and the bot receives his Telegram name (username), which allows identifying the user. The Telegram name is personal data.
  • Through deep linking - the user follows a link that launches a bot.
  • Through a mini-landing page - the user launches the bot through a special page.

Is it necessary to place consent to the processing of personal data in the bot description?

If the bot collects data that allows the user to be identified (for example, a Telegram name), it is necessary to take care of the legal basis for data processing.

In case of the "START" button

  • yes, consent to the processing of personal data must be provided;
  • It is best not only to place information about consent in the bot description , but also to duplicate it in the bot's welcome message and/or on an external page with a privacy policy.

Mandatory documents in the bot description

If the bot is not selling (for example, for sending content):

  • consent to the processing of personal data;
  • privacy policy (which discloses what data is collected and how it is used).

If the bot is selling (leads to the sale of goods/services):

  • consent to the processing of personal data;
  • Privacy Policy;
  • offer (if an order or purchase is made through a bot).

Launching a bot via deeplink

When launched via deeplink, the user follows a special link that immediately activates the bot. Already at the moment of the first interaction, the bot can begin to collect personal data (for example, a Telegram name). Username in Telegram is personal data.

The first message from the bot must contain information about consent to the processing of personal data.

Consent may be drawn up in the form of:

  • embedded text in the welcome message (for example: “By clicking the button, you agree to the processing of your personal data”);
  • links to consent file;
  • attached file with the consent text.

A link to the privacy policy is also required. The policy may be:

  • common to all operator processes;
  • separate for a specific bot.

Important: the privacy policy must be available to the user in the current version (link or file).

An offer is only needed if goods or services are sold through the bot. In this case:

  • the offer is provided before the start of the sale;
  • Consent to the processing of personal data does not need to be obtained separately - launching the bot = agreement with the offer.

When to obtain consent for advertising mailings?

If the bot suggests:

  • only advertising mailings - consent to the advertising mailing and consent to the processing of personal data must be obtained before launching the bot (both can be done in one message);
  • sales or distribution of materials - consent for advertising mailings is taken separately, after the bot has been launched (for example, by a separate message requesting consent).

Mini Landing Page

Telegram mini-landing on the BotHelp platform allows adding up to 5 documents, each under a separate checkbox. The user cannot proceed further if he does not agree with each point, that is, does not check the box under each document.

Is it possible to include consent to mailing in the checkboxes of the mini-landing page?

No , unless the bot is intended exclusively for mailings. Why :

  • By law, the user must have the freedom to choose whether to receive advertising or not.
  • Forced consent (for example, without a check mark the user cannot continue) is unacceptable.
  • Therefore, consent to receive advertising mailings cannot be among the “mandatory” checkboxes on which the mini-landing page depends.

If you plan to send out advertising via a bot, the algorithm should be as follows:

On the mini-landing page, collect the required consents:

  • consent to the processing of personal data;
  • agreement with the privacy policy;
  • offer (if the bot sells);
  • other documents required to launch the bot functionality.

After completing the mini-landing page - inside the bot:

  • send a separate message asking for consent to receive advertising;
  • give the user a choice: agree or refuse;
  • Save the confirmation of consent (for example, with a reply button or a separate command).

If the condition for issuing the material was a subscription to the bot, but not consent to the advertising mailing:

  • the material must be issued regardless of consent to advertising;
  • You do not have the right to advertise anything without consent to mailing.

You can invite to a webinar if:

  • this is not an advertisement;
  • there is consent to the processing of personal data for such notifications.

If you have not found the answer to your question, ask us in the chat inside your account or write to BotHelpSupportBot or to hello@bothelp.io

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