How are bots launched and what data is collected?
There are several ways to launch Telegram bots:
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Via the “START” button — the user initiates interaction themselves, and the bot receives their Telegram username, which allows identifying the user. The Telegram username is considered personal data.
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Via deeplink — the user follows a link that launches the bot.
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Via mini-landing page — the user launches the bot through a special landing page.
Is it necessary to include consent for personal data processing in the bot description?
If the bot collects data that can identify the user (for example, a Telegram username), it is necessary to have a legal basis for processing this data.
For the “START” button:
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Yes, consent for personal data processing must be provided;
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It’s best to include information about the consent not only in the bot description but also duplicate it in the bot’s welcome message and/or on an external page with the privacy policy.
Required documents in the bot description
If the bot is not selling anything (for example, for content distribution):
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Consent to personal data processing;
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Privacy policy (explaining what data is collected and how it is used).
If the bot is selling goods or services:
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Consent to personal data processing;
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Privacy policy;
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Offer agreement (if orders or purchases are made through the bot).
Launching a bot via deeplink
When launched via deeplink, the user follows a special link that immediately activates the bot. The bot may start collecting personal data (such as the Telegram username) from the first interaction. Username in Telegram is personal data.
The bot’s first message must contain information about consent to personal data processing.
Consent can be given in the form of:
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Embedded text in the welcome message (e.g., “By clicking the button, you agree to the processing of your personal data”);
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A link to a consent document;
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An attached consent file.
A link to the privacy policy is also mandatory. The policy can be:
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General for all operator processes;
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Specific to the particular bot.
Important: The privacy policy must be available to the user in its current version (via link or file).
Offer agreement is needed only if goods or services are sold through the bot. In this case:
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The offer must be provided before the sale starts;
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Separate consent to personal data processing may not be required — launching the bot equals consent to the offer.
When to obtain consent for advertising mailing?
If the bot involves:
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Only advertising mailings — consent for advertising mailing and personal data processing must be obtained before launching the bot (can be combined in one message);
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Sales or content delivery — consent for advertising mailing is obtained separately after the bot launch (e.g., via a separate message requesting consent).
Mini-landing
Telegram mini-landing on BotHelp allows adding up to 5 documents, each with a separate checkbox. The user cannot proceed without agreeing to each point (checking each box).
Can consent for advertising mailing be included in the mini-landing checkboxes?
No, unless the bot is designed exclusively for mailings. Because:
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By law, users must have the freedom to choose whether to receive ads or not.
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Forced consent (e.g., user cannot continue without checking the box) is not allowed.
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Therefore, consent for advertising mailing cannot be among the mandatory checkboxes that block progressing through the mini-landing.
If advertising mailing is planned via the bot, the algorithm should be:
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On the mini-landing, collect mandatory consents:
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Consent to personal data processing;
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Consent to the privacy policy;
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Offer (if the bot sells);
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Other documents required to launch bot functionality.
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After passing the mini-landing — inside the bot:
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Send a separate message requesting consent for advertising mailing;
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Let the user choose to agree or decline;
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Save the consent confirmation (e.g., by reply button or separate command).
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If subscription to the bot was required for material delivery, but not consent to advertising mailing:
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The material must be provided regardless of consent to ads;
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You cannot advertise without consent to mailing.
Invitations to webinars are allowed if:
- It is not advertising;
- There is consent for personal data processing for such notifications.
If you did not find the answer to your question, feel free to contact us in the chat inside your dashboard, message us on Telegram at @BotHelpSupportBot, or email us at hello@bothelp.io.
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