*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.*

# Privacy Policy
###### Version 1.04 dated March 15, 2026

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

The 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 the event of discrepancies between the text on the Website and in the Application, the version hosted within the Application shall prevail and be legally binding.

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

1.2. **Application** — the tgCrew mini-app 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 endorsed by it, and is not legally or organizationally affiliated with it. The Application's functionality is available only after the acceptance of the Terms of Use and the Privacy Policy.

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

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 the acceptance of the Terms of Use within the Application.

1.5. **Privacy Policy** — this document, governing the procedure for collecting, storing, and processing User data (including personal data) entered during registration, use of the Application, and other data. It is an integral appendix 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 inside the Application.

1.6. **Developer** — Individual Entrepreneur Martyshkin Alexey Alexandrovich (IE Martyshkin A.A.), OGRNIP 318774600262084, INN 366316608346 (Russian Federation).

1.7. **User** — a natural person, individual entrepreneur, legal entity, or their authorized representative who has accepted the conditions of the Terms of Use and the Privacy Policy by 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 Member** — 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 for Users;
  - monitoring and making payments of remuneration to the Developer for the use of the Application.

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

1.13. **Use of the Application** — actions performed by the User to view and/or use the available functionality of the Application via 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 as instructed by the Developer.

1.15. **Personal Data (or PDn)** — any information relating to a directly or indirectly identified or identifiable natural person (data subject) (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 or without the use of automation tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and 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 natural person who independently or jointly with others organizes and/or performs the processing of personal data, as well as determines the purposes of processing personal data, the scope of personal data to be processed, and the 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 computing 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** — transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign natural person, 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 the material 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 governs the relationship between the Developer and the User. It cannot govern 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 drafted 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 "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 during the Processing of 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 completion of the acceptance procedure by activating (checking) the corresponding interactive element (checkbox) in the Application interface next to the text: "I give my Consent for Personal Data Processing 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. If the User does not agree with the terms of the Privacy Policy, they must 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, it is necessary to 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 User data, which may be defined as Personal Data:

a) Data provided by Telegram via API: name (Name, including first_name and last_name), pseudonym (Username), user identifier (ID), profile image identifier (used to display the 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 of request receipt by the Application server, requested URL, HTTP response code of the Application server, response size in bytes, User-Agent (browser and operating system information), 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. In the Admin Panel, the Administrator may specify data for each member of a Connected Chat, which may be defined as Personal Data:
  - full name (surname, first name, patronymic);
  - contact phone number;
  - email address;
  - employment details (organization name, 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 providing the personal data of Users in accordance with applicable legislation (in the case of providing real data).
The provision of said information about a User in the Application, which may be defined as Personal Data, to other Users is carried out only for Users who share a 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. When contacting the Developer (for example, when requesting technical support for the Application), Users are entitled to provide any of the following data, which may be defined as Personal Data:
  - full name (surname, first name, patronymic);
  - contact phone number;
  - email address;
  - employment details (organization name, structural unit, position, and/or functional role).

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

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

4.5. The Application stores data entered by Users in the Application, including:
  - project data (name, description, logo, etc.),
  - company data (name, address, contact phone, website, etc.),
  - task and meeting data (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).
Responsibility for the choice of a third-party storage service, compliance with its terms of use and privacy policy, as well as 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 said third-party services and is not responsible for their availability, data safety, or information security incidents on the part of the cloud service providers.
When the Administrator connects third-party storage services (Yandex Disk or Google Drive), the interaction of the Application with these services is carried out exclusively through the APIs of the respective services. The Developer does not request, collect, or store authorization data for 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 may be defined as Personal Data, except as specified in clause 4.2, nor does it perform analysis of information available to it in chats.

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

5.2. The Developer undertakes to collect and use User data only for the purposes stated above, except in cases where data collection and use are necessary for other purposes compatible with the original purpose of data collection, or where 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 is obliged to notify the User and explain the legal grounds for such collection.

5.3. The Processing of Personal Data of Users is carried out by the Developer using automation tools.

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

6.2. These measures include, among others, 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 for cases of providing data to courts and/or state bodies and/or law enforcement agencies in cases where required by the laws and regulations of the Russian Federation.

7.3. The Developer guarantees to the User that it will not sell, trade, or transfer your data (including PDn) 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 performed.

## 8. User Rights
8.1. The main rights of the User as a Personal Data subject include:
  - **Right of access to Personal Data.** The User may request from the Developer a copy of their Personal Data to which the Developer has access. The Developer shall provide information to the User within 10 (ten) business days from the receipt of the request. This period may be extended by no more than 5 (five) business days if the Developer sends a reasoned notification to the User regarding the reasons for the extension.
  - **Right to rectification of Personal Data.** The User may demand that the Developer 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 us directly. The Developer reserves the right to refuse personal assistance in cases where the correction of Personal Data is available through the Application's functionality or with the help of the Administrator.
  - **Right to erasure of Personal Data.** The User may demand that the Developer 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 transfer it to third parties, except as provided by law. The Developer may be unable to fulfill the User's deletion request due to legal obligations, which will be communicated to the User if relevant grounds exist (e.g., if processing is necessary to achieve goals provided by law, to execute a court act, or to exercise the 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 may withdraw their consent at any time. This will not affect the lawfulness of any processing 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, meaning they must generally 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 PDn) no longer than is necessary for the purpose of its collection or processing (followed by deletion).

9.2. Generally, the Developer stores data (including PDn) 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 PDn) for a longer period if required by relevant laws and regulations. The Developer may retain some User data (including PDn) 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, and to fulfill the Developer's legal obligations.

## 10. Changes to the Privacy Policy
10.1. This Privacy Policy may be revised, updated, and/or amended 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 encouraged to independently and regularly monitor changes to the Privacy Policy by reviewing the current version of the Privacy Policy on the Website or in the Application.

10.3. Following the publication of an 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 explain its provisions. To do this, contact the Developer at the email address [support@tgcrew.ru](mailto:support@tgcrew.ru).

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

## 12. Developer Contact Information and Details
Individual Entrepreneur Martyshkin 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)