###### Version 1.05 dated April 15, 2026

This document is an English adaptation of «Политика конфиденциальности» originally drafted in Russian. In the event of any disputes subject to resolution in courts of the Russian Federation, the Russian-language version shall prevail.

In this Privacy Policy, the Developer provides information on the scope of collection of data (including personal data) of Users in the Application, explains the reasons for its collection and the ways of its use.

Current versions of the Terms of Use and the Privacy Policy are available within the Application interface. Information posted on the Website is for reference purposes only. In case of discrepancies between the text on the Website and in the Application, the version placed in the Application shall have legal force.

## 1. Terms and Definitions
1.1. **Bot** — an account named @tgCrewBot and located at [https://t.me/tgCrewBot](https://t.me/tgCrewBot) in the Telegram messenger, managed programmatically by the Developer via API (Application Programming Interface). The Bot provides access to the Application and can be used for basic interaction from the text string (inline-mode).

1.2. **Application** — the tgCrew mini-application operating within the Telegram messenger environment as part of the Telegram Mini Apps (TMA) ecosystem and accessible through interaction with the Bot. Although the Application uses the Telegram platform for its functioning and distribution, it is developed and provided exclusively by the Developer. The Application is not a product of the Telegram messenger development company, is not supported by it, is not approved by it, and is not associated with it legally or organizationally in any way. The functionality of the Application is available only after acceptance of the Terms of Use and the Privacy Policy.

1.3. **Website** — the website located at [https://tgcrew.ru](https://tgcrew.ru), where information about the Application and its documentation is posted.

1.4. **Terms of Use** — this document, the current version of which is posted in the Application and on the Website at [https://tgcrew.ru/terms-of-use](https://tgcrew.ru/terms-of-use). Contractual relations between the Developer and the User arise only after acceptance of the Terms of Use within the Application.

1.5. **Privacy Policy** — a document regulating the procedure for collecting, storing, and processing data (including personal data) of the User entered during the registration procedure, use of the Application, as well as other data. It is an integral annex to the Terms of Use. The current version of the Privacy Policy is posted in the Application and on the Website at [https://tgcrew.ru/privacy-policy](https://tgcrew.ru/privacy-policy). Consent for data processing within the framework of the Privacy Policy is provided by the User within the Application.

1.6. **Developer** — individual entrepreneur Martynshkin Alexey Alexandrovich (IP Martynshkin A.A.), OGRNIP 318774600262084, INN 366316608346 (Russian Federation).

1.7. **User** — an individual, individual entrepreneur, legal entity, or their authorized representative who has accepted the terms of the Terms of Use and the Privacy Policy by their explicit confirmation within the Application interface.

1.8. **Administrator** — a User of the Application who manages the Application using the Admin Panel.

1.9. **Administrator Account** — the account through which the Administrator authenticates to access the Admin Panel.

1.10. **Chat Participant** — a participant of a Connected Chat who may not be a User of the Application.

1.11. **Admin Panel** — the Application interface for managing the Application, including the following functions:
  - connecting chats to the Application (see clause 1.12 – Connected Chat);
  - entering additional information data for Users;
  - controlling the payment of the License Fee to the Developer for using the Application.

1.12. **Connected Chat** (to the Application) — a chat in Telegram to which the Bot has been added with the necessary access rights. Information is available in the Application only from Connected Chats.

1.13. **Use of the Application** — the User performing actions to view and (or) use the available functionality of the Application through reproducible online interfaces on the screen of the User's device.

1.14. **Developer's Representatives** — the circle of persons engaged by the Developer within the framework of development and support of the Application, acting on behalf of and (or) on the instructions of the Developer.

1.15. **Personal Data (or PData)** — any information relating to a directly or indirectly identified or identifiable individual (subject of personal data) (according to Federal Law No. 152-FZ, Chapter 1, Article 3, Clause 1).

1.16. **Processing of Personal Data** — any action (operation) or set of actions (operations) performed with personal data using automation tools or without using such tools, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data (according to Federal Law No. 152-FZ, Chapter 1, Article 3, Clause 3).

1.17. **Operator** — a state body, municipal body, legal entity or individual, independently or jointly with other persons organizing and (or) performing the processing of personal data, as well as determining the purposes of processing personal data, the composition of personal data subject to processing, and actions (operations) performed with personal data (according to Federal Law No. 152-FZ, Chapter 1, Article 3, Clause 2).

1.18. **Automated Processing of Personal Data** — processing of personal data using computer technology (according to Federal Law No. 152-FZ, Chapter 1, Article 3, Clause 4).

1.19. **Provision of Personal Data** — actions aimed at disclosing personal data to a specific person or a specific circle of persons (according to Federal Law No. 152-FZ, Chapter 1, Article 3, Clause 6).

1.20. **Cross-border Transfer of Personal Data** — the transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity (according to Federal Law No. 152-FZ, Chapter 1, Article 3, Clause 11).

1.21. **Destruction of Personal Data** — actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which physical carriers of personal data are destroyed (according to Federal Law No. 152-FZ, Chapter 1, Article 3, Clause 8).

## 2. General Provisions
2.1. This Privacy Policy exclusively regulates the relationship between the Developer and the User. It cannot regulate the relationship between the Telegram messenger (hereinafter - Telegram) and its users and does not replace the Telegram Privacy Policy.

2.2. This Privacy Policy is drawn up in accordance with the requirements of:
  - Federal Law dated July 27, 2006 No. 152-FZ "On Personal Data".
  - Requirements of section "4. Privacy" of the document "Telegram Bot Platform Developer Terms of Service" by Telegram FZ-LLC (the developer of the Telegram messenger).

2.3. The Developer acts as the Operator when Processing personal data of Application Users.

## 3. Acceptance of the Terms of this Privacy Policy
3.1. Evidence of full and unconditional acceptance of the terms of this Privacy Policy (acceptance) is the performance of the procedure for accepting the Privacy Policy by activating (checking) the corresponding interactive element (checkbox) of the Application interface next to the text: "I give Consent for the processing of my personal data and accept the terms of the Privacy Policy" on the relevant screens in the Application.

3.2. Use of the Application signifies the User's consent to the collection and processing of information from Connected Chats in accordance with the Privacy Policy (see clauses 4.2-4.4).

3.3. In the event that the User does not agree with the terms of the Privacy Policy, they are obliged to immediately leave the Application and not start/cease the Use of the Application.

## 4. Data Collection and Processing
4.1. To provide the User with access to the Application, the User must provide the Developer with access to important information about themselves.

4.2. Personal Data Collected by the Application

4.2.1. The Application automatically collects the following data of Users, which may be defined as Personal Data:

a) Data provided by Telegram via API: user name (Name, including first_name and last_name), pseudonym (Username), user identifier (ID), profile image identifier (used to display an avatar without saving copies of files on the Developer's servers), Telegram client language settings, as well as Telegram Stars transaction data (for the Administrator only).
b) Data on the User's interaction with the Application servers (technical data): IP address from which the request is made, date and time the request was received by the Application server, requested URL, HTTP response code of the Application server, response size in bytes, User-Agent (information about the browser and operating system of the client), Referrer (URL of the page from which the request was made, if available).

4.2.2. The Administrator provides:
  - email address, if authentication in the Application is performed using it.

4.2.3. The Administrator in the Admin Panel can specify data for each participant of the Connected Chat, which may be defined as Personal Data:
  - surname, first name, patronymic;
  - contact phone number;
  - email address;
  - information about the place of work (name of the organization, structural unit, position and (or) functional role).

The Developer is not responsible for the correctness and accuracy of the specified data, but as the Operator ensures the legality of its processing. The Administrator is obliged to ensure the existence of legal grounds for the provision of personal data of Users in accordance with applicable legislation (in the case of specifying real data).
The provision of specified data about a User in the Application, which may be defined as Personal Data, to other Users is carried out only for Users who have a common Connected Chat. By accepting this Privacy Policy, the User consents to such provision of their data. If necessary, the user may contact the Administrator to delete or change the above data.

4.2.4. Users, when contacting the Developer (for example, when requesting technical support for the Application), are entitled to provide any following data, which may be defined as Personal Data:
  - surname, first name, patronymic;
  - contact phone number;
  - email address;
  - information about the place of work (name of the organization, structural unit, position and (or) functional role).

4.3. When creating and maintaining an http connection, the Application uses HttpOnly cookie files, which are inaccessible from JavaScript via Document.cookie API properties and are used to reduce the risk of XSS (Cross-Site Scripting). Other cookie files are not set or used.

4.4. The Application, with the help of the Bot, monitors events in Connected Chats (such as adding/changing/deleting messages, adding/deleting files, etc.), but only on condition that the Bot is granted Administrator rights to access messages in Connected Chats.

4.5. The Application stores data that Users enter in the Application, including:
  - project data (name, description, logo, etc.),
  - company data (name, address, contact phone, website, etc.),
  - data on tasks and meetings (description, date and time, etc.).

4.6. The Developer does not store or analyze correspondence from Connected Chats on its own computing facilities (servers).

4.7. The Developer does not store files from chats, tasks, and meetings on its own computing facilities (servers). Storage is carried out within Telegram or on third-party cloud storage services connected by the Administrator (Yandex Disk or Google Drive).
The responsibility for choosing a third-party storage service, complying with its terms of use and privacy policy, as well as for the existence of legal grounds for transferring data to such services, lies entirely with the Administrator. The Developer is not a storage operator in relation to these third-party services and is not responsible for their availability, data safety, or information security incidents on the part of cloud service providers.
When the Administrator connects third-party storage services (Yandex Disk or Google Drive), the Application's interaction with these services is carried out exclusively through the API of the respective services. The Developer does not request, collect, or store authorization data of these services. Authorization in such services occurs on the side of the respective providers.

4.8. The Application does not collect any additional information on the User's side that can be defined as Personal Data, except for that specified in clause 4.2, and does not perform an analysis of information that is available to it in chats.

## 5. Purposes and Terms of Data Processing
5.1. Data collection is carried out for the following purposes:
  - Identification and authentication of Users in the Application (clauses 4.2.1.a and 4.2.2).
  - Provision of technical support and processing of inquiries (clauses 4.2.1, 4.2.2 and 4.2.4).
  - Sending system notifications to the Administrator (clauses 4.2.1.a and 4.2.2).
  - Accounting and confirmation of payment transactions via Telegram Stars (clause 4.2.1.a).
  - Formation of an address book of contacts within Connected Chats (clauses 4.2.1.a and 4.2.3).
  - Ensuring the correct operation of the Application's functionality (clauses 4.2 and 4.4).
  - Implementation of technical measures aimed at preventing technical failures, identifying errors, and ensuring the information security of the Application (clauses 4.2.1.b and 4.3).

5.2. The Developer undertakes to collect and use User data only for the above purposes, except for cases when the collection and use of data is necessary for other purposes compatible with the original purpose of data collection, or when provided for by the legislation of the Russian Federation. If the Developer needs to use User data for other purposes not mentioned above, the Developer has the right to notify the User by updating this Privacy Policy.

5.3. The processing of personal data of Users is carried out by the Developer using automation tools.

5.4. Terms of data processing and storage. The Developer processes Personal Data during the term of the Terms of Use.

5.5. The Developer has the right to continue storing data after the termination of the Terms of Use or withdrawal of consent in the following cases:
  - For 5 (five) years in relation to transaction information (according to the tax legislation of the Russian Federation).
  - For 3 (three) years (general statute of limitations) to ensure the possibility of protecting the Developer's interests in court.

5.6. Due to technical characteristics, data may be stored in encrypted backup copies of systems for up to 6 (six) months after its actual deletion from active databases. Such copies are used only for disaster recovery.

## 6. Data Protection
6.1. The Developer has implemented a series of technical, organizational, and administrative measures to ensure the confidentiality, integrity, availability, and inviolability and protection of your data (including PData) from loss, theft, unauthorized access, improper use, modification, or destruction.

6.2. These measures include, among other things, the implementation of modern security technologies: Secure Sockets Layered (SSL) technology to ensure full encryption of User data and its secure transmission over the Internet.

6.3. Only authorized personnel of the Developer have access to Users' Personal Data, and this personnel is obliged to treat Personal Data as confidential. Developer's Representatives do not gain access to User data (including personal data). Security measures may be periodically reviewed in accordance with legal and technical changes.

## 7. Data Transfer
7.1. The Developer does not transfer data received from Users (including technical metrics, project data, and other information) to third parties for marketing, advertising, or other commercial purposes. Data transfer is carried out exclusively to the extent necessary to ensure the functionality of the Application: to the Telegram messenger and cloud storage services (according to clause 4.7) initiated by the Administrator.

7.2. The Developer does not transfer personal data received from Users to third parties, except in cases of providing data to courts and (or) state bodies and (or) law enforcement agencies in cases when required by the laws and regulations of the Russian Federation.

7.3. The Developer guarantees to the User that it will not sell, exchange, or transfer your data (including PData) to third parties without your explicit consent.

7.4. All Application servers are located on the territory of the Russian Federation. Cross-border transfer of personal data is not carried out.

## 8. User Rights
8.1. The main rights of the User as a subject of Personal Data include:
  - **Right to access Personal Data.** The User can request the Developer to provide them with a copy of their Personal Data to which the Developer has access. The Developer provides information to the User within 10 (ten) working days from the moment the request is received. This period may be extended by no more than 5 (five) working days in case the Developer sends a motivated notification to the User about the reasons for the extension.
  - **Right to correct Personal Data.** The User can demand the Developer to correct or update any of their Personal Data. The User can do this using the corresponding functionality of the Application, by requesting the Administrator, or by contacting the Developer directly. The Developer reserves the right to refuse personal assistance in cases where the correction of Personal Data is available through the functionality of the Application or with the help of the Administrator.
  - **Right to delete Personal Data.** The User can demand the Developer to delete their Personal Data, subject to applicable legislation. In some cases, the Application will automatically delete Personal Data upon closing the Account in the Application. If the User closes their Account, the Developer will not use their Personal Data for any further purposes, nor will it transfer them to third parties, except as provided by law. The Developer may be unable to fulfill the User's request for deletion due to legal obligations, which will be communicated to the User if there are appropriate grounds (for example, if processing is necessary to achieve purposes provided for by law, for the execution of a judicial act, for the exercise of rights and legitimate interests of the Developer or third parties).
  - **Right to withdraw consent.** To the extent that the processing of the User's Personal Data is based solely on their consent, the User can withdraw their consent at any time. This will not affect the lawfulness of any processing that was carried out before the withdrawal. Any processing actions not based on the User's consent will remain unaffected.

8.2. None of the rights are absolute, which means that they generally must be weighed against the Developer's own legal obligations, as well as its legitimate interests and the interests of third parties. If a decision is made to reject the User's request, the Developer will inform them of this along with the reasons for such a decision.

## 9. Data Storage
9.1. The Developer stores User data (including PData) for no longer than necessary for the purpose of its collection or processing (with subsequent deletion).

9.2. As a rule, the Developer stores data (including PData) throughout the lifetime of the Administrator Account.

9.3. In cases provided for by applicable law, Personal Data may be stored after the closure of the Administrator Account for the period established by such laws.

9.4. The Developer may store User data (including PData) for a longer period if required by relevant laws and regulations. The Developer may retain some User data (including PData) after the closure of the Administrator Account to prevent fraud, ensuring that persons attempting to commit fraud cannot avoid detection simply by closing an account and opening a new one, as well as to fulfill the Developer's legal obligations.

## 10. Changes to the Privacy Policy
10.1. This Privacy Policy may be revised, updated, and (or) changed at any time without prior notice at the Developer's discretion. If such changes are made, the update date of this Privacy Policy will be displayed on the first page of the Privacy Policy.

10.2. The User is advised to independently and regularly monitor changes to the Privacy Policy by familiarizing themselves with the current version of the Privacy Policy on the Website or in the Application.

10.3. After the publication of the updated version of the Privacy Policy, further use of the Application is considered acceptance of the terms of the updated Privacy Policy.

## 11. Other Provisions
11.1. If any provisions of this Privacy Policy remain unclear, the Developer is ready to clarify its provisions. To do this, contact the Developer at the email address [support@tgcrew.ru](mailto:support@tgcrew.ru).

11.2. The User can use the contact details provided in section 12 for any reason provided for by this Policy.

## 12. Contact Information and Details of the Developer
Individual Entrepreneur Martynshkin Alexey Alexandrovich
Legal address: 111394, Russian Federation, Moscow, Perovskaya street, house 66, building 3, apartment 187
OGRNIP 318774600262084
INN 366316608346
Phone: +7 (916) 439-04-25
Email: [info@tgcrew.ru](mailto:info@tgcrew.ru)