If you use automation on Instagram*, for example:
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a user leaves a comment;
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they automatically receive a gift (checklist, PDF, mini-course) in direct messages;
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then they are guided to a webinar or product sale.
Do you need to show documents on Instagram*?
If Instagram* is used only as an “entry point,” and:
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registration for the webinar happens on an external website,
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purchase is made on a separate platform,
then data transfer via Instagram is not considered cross-border, and showing documents in direct messages is not required.
If the sale is made directly through Instagram* (for example, you accept payment or place orders in the chat), then data transfer through Instagram is considered cross-border.
Important: On September 1, 2025, a ban on advertising on Instagram* and other platforms recognized as extremist or blocked in Russia will come into effect. This means any advertising, including commercial and personal, will be prohibited on these resources. The ban covers all types of advertising, including targeted ads, collaborations with bloggers, native integrations, stories and reels, as well as posts with indirect mentions of goods and services. Informing the public by a brand or specialist about their activity, including products, services, and prices, is not considered advertising.
However, directing users from Instagram to other social networks is not advertising. We first redirect, then advertise and sell.
In this case, before the sale, the user must be acquainted with the documents:
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consent to the processing of personal data,
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privacy policy,
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offer agreement (if it is a remote sale).
Instagram* is recognized as an extremist organization in Russia. Using it for business purposes:
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is not directly prohibited for users;
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but may carry 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 through Instagram*, given its status in Russia.
*Owned by Meta, recognized as extremist in Russia.
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