If you use automation in Instagram*, for example:
- the user leaves a comment;
- in personal messages he is automatically given a gift (checklist, PDF, mini-course);
- then he is taken to a webinar or product sales.
Do I need to show documents on Instagram*?
If Instagram* is used only as an "entry point" and:
- Registration for the webinar takes place on an external site
- the purchase is made on a separate platform
Then the transfer of data via Instagram is not considered cross-border and there is no need to show documents in the direct message.
If a sale is made directly through Instagram* (for example, in a conversation you accept payment or place an order), then the transfer of data through Instagram is considered a cross-border transfer.
Important: On September 1, 2025, a ban on advertising on Instagram*, as well as on other platforms recognized as extremist or blocked in the Russian Federation, comes into force. This means that the placement of any advertising, including commercial and personal, on these resources will be prohibited. The ban applies to all types of advertising, including targeted advertising, collaborations with bloggers, native integrations, stories and reels, as well as posts with indirect mentions of goods and services. Informing the population by a brand or specialist about their activities, including goods, services, and prices, is not advertising.
But translation from Instagram to other social networks is not advertising. We translate first, and then advertise and sell.
In this case : the user must be familiarized with the documents before the sale:
- consent to the processing of personal data,
- privacy policy,
- offer (if it is a distance sale).
Instagram is recognized as an extremist organization in Russia. Its use for business purposes:
- not directly prohibited for users;
- but may pose legal risks for companies - especially if personal data is collected and processed or services are sold. Roskomnadzor will not approve such cross-border transfer of personal data.
It is advisable to avoid sales via Instagram*, given its status in the Russian Federation.
* Belongs to the Meta organization, recognized as extremist in Russia.
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