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*This document is an English translation of the original Russian-language "Consent to Personal Data Processing" (Version 1.01 dated 15.08.2025). In the event of any disputes, the original Russian version shall take precedence, particularly for matters resolved within the jurisdiction of the Russian Federation.*
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*This document is an English adaptation of «Согласие на обработку персональных данных» 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.*
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# Consent to Personal Data Processing
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###### Version 1.01 dated 15.08.2025
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# Consent for Personal Data Processing
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###### Version 1.04 dated March 15, 2026
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Pursuant to Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data", acting freely, by my own will and in my own interest, and hereby confirming my legal capacity, I (hereinafter – the **User**) grant my consent to Alexey Alexandrovich Martyshkin, Individual Entrepreneur (OGRNIP 318774600262084, INN 366316608346) (hereinafter – the **Operator**) for the processing of my personal data under the following terms.
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In accordance with the requirements of the Federal Law dated July 27, 2006, No. 152-FZ "On Personal Data," acting freely, of my own will and in my own interest, and confirming my legal capacity, I (hereinafter — the **User**) hereby give my consent to Individual Entrepreneur Martyshkin Alexey Alexandrovich (OGRNIP 318774600262084, INN 366316608346) (hereinafter — the **Operator**) for the processing of my personal data under the conditions set forth below.
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The following terms and definitions apply in this Consent:
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The following terms and definitions are used in this Consent:
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**Bot** – An account named @tgCrewBot with URL [https://t.me/tgCrewBot](https://t.me/tgCrewBot) in the Telegram messenger, programmatically managed by the Operator via API (Application Programming Interface). The Bot provides access to the Application and supports basic interaction via inline mode.
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**Bot** — an account named @tgCrewBot with the address [https://t.me/tgCrewBot](https://t.me/tgCrewBot) in the Telegram messenger, programmatically managed by the Operator 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).
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**Application** – The tgCrew mini-app operating within the Telegram messenger environment as part of the Telegram Mini Apps (TMA) ecosystem, accessible through interaction with the Bot. While the Application utilizes Telegram's platform for functionality and distribution, it is exclusively developed and provided by the Operator. The Application is not a product of Telegram Messenger LLP, nor is it endorsed, supported, or legally affiliated with Telegram Messenger LLP.
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**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 Operator. 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.
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**Personal Data (PD)** – Any information relating to an identified or identifiable natural person (data subject) (per Federal Law No. 152-FZ, Chapter 1, Article 3, Clause 1).
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**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).
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**Administrator** – A User of the Application who manages it through the Admin Panel.
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**Administrator** — a User of the Application who manages the Application using the Admin Panel.
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**Administrator Account** – An account used by the Administrator to authenticate access to the Admin Panel.
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**Administrator Account** — the account through which the Administrator authenticates to access the Admin Panel.
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**Admin Panel** – The Application interface for management functions, including:
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- Connecting chats to the Application (see §1.12 – Connected Chat)
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- Adding supplementary User information
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- Monitoring and processing Developer remuneration payments for Application usage.
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**Admin Panel** — the Application interface for managing the Application, including the following functions:
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- connecting chats to the Application (within the meaning of the term Connected Chat);
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- entering additional information for Users;
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- monitoring and making payments of remuneration to the Developer for the use of the Application.
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**Connected Chat** – A Telegram chat where the Bot has been added with necessary access rights. The Application only processes data from Connected Chats.
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**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.
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1. This Consent is specific, informed, conscious, and unambiguous.
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1. This consent is specific, informed, conscious, and unambiguous.
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2. The User consents to the Operator's processing of their Personal Data (using automated means), including:
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a) Collection, recording, systematization, accumulation
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b) Storage for the duration of the Administrator Account's existence, but no less than required by Russian law. Data is deleted upon Administrator Account closure, except where legally mandated (e.g., fraud prevention or court order execution)
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c) Updating (modification, correction)
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d) Retrieval, usage
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e) Transfer (provision, access) to state authorities, courts, or law enforcement agencies exclusively upon official request under Russian law
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f) Transfer (provision, access) to other Application Users within the same Connected Chat, limited to Application functionality requirements
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g) Blocking, deletion, destruction
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h) Other lawful processing activities under Russian legislation
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2. Consent is given to the Operator for the processing of the User's personal data (using automation tools), including the following actions:
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3. Consent covers processing of the following User Personal Data, which may be:
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- Provided directly by the User
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- Entered by the Application Administrator (if User participates in a Connected Chat)
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- Automatically collected by the Application:
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a) Full name (surname, given name, patronymic)
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b) Email address
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c) Contact phone number
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d) Employment details (organization, department, position/functional role)
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e) Telegram account data: Display name (First/Last name), username, user ID, profile picture, Telegram client language settings; and for Administrators: Telegram Stars transaction data (user ID, amount, transaction ID, timestamp) transmitted automatically via Telegram API
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f) Server interaction data (technical): Request IP address, request timestamp, requested URL, HTTP response code, response size (bytes), User-Agent, Referrer URL (if available)
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a) Collection, recording, systematization, accumulation.
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b) Storage throughout the lifetime of the Administrator Account, but no less than the period required by the legislation of the Russian Federation. Data is deleted upon closure of the Administrator Account, except in cases provided by law (e.g., for fraud prevention or execution of court decisions).
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c) Clarification (updating, modification).
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d) Extraction, use.
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e) Transfer (provision, access) to state bodies, courts, or law enforcement structures exclusively upon official request within the framework of the legislation of the Russian Federation.
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f) Transfer (provision, access) to other Users of the Application who share a Connected Chat with the User, to the extent provided by the Application's functionality (displaying first name, last name, avatar, position, or role in participant lists, in descriptions of meetings and tasks, etc.).
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g) Blocking, deletion, destruction.
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h) Performance of other actions provided for by the legislation of the Russian Federation.
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4. Processing purposes:
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a) Application authentication and identification (§§3b, 3e)
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b) Technical support and request handling (§§3a-3e)
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c) System notifications (for Administrators using email authentication) (§§3b, 3e)
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d) Processing Telegram Stars transactions (for Administrators) (§§3b, 3e)
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e) Generating contact directories within Connected Chats (§§3a-3e)
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f) Ensuring proper Application functionality (§§3a-3e)
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g) Technical maintenance and security (§§3f)
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3. Consent is given for the processing of the following personal data of the User, which may be provided by the User themselves and/or entered by the Application Administrator (if the User is a member of a Connected Chat) and/or automatically collected by the Application:
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5. The User acknowledges that ticking the checkbox adjacent to the text: "I consent to the processing of my personal data and accept the Privacy Policy terms" in the Application interface constitutes a simple electronic signature under Russian law, confirming:
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- Review of this Consent
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- Acceptance of the Operator's Privacy Policy available at: [https://tgcrew.ru/privacy-policy](https://tgcrew.ru/privacy-policy)
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a) Full name (surname, first name, patronymic).
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b) Email address.
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c) Contact phone number.
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d) Employment details (organization name, structural unit, position, and/or functional role).
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e) Telegram messenger account data: 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, and, if the User is an Administrator, Telegram Stars transaction data (user ID, number of Telegram Stars, transaction ID, operation timestamp), which are automatically transmitted via the Telegram API. The processing of biometric personal data is not performed by the Operator.
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f) Data on 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).
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6. This Consent becomes effective upon completion of the action specified in §5 and remains valid until withdrawal.
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4. Personal data processing is carried out for the following purposes:
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7. Withdrawal is performed by:
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- Selecting "Withdraw PD Processing Consent" in Settings (User/Admin Panel)
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- Confirming via "Confirm" in the dialog
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Withdrawal results in cessation of processing and data destruction, except as stipulated in §8.
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a) Identification and authentication in the Application (clauses 3b and 3e).
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b) Providing technical support and processing inquiries (clauses 3a-3e).
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c) Sending system notifications if the User is an Application Administrator and uses email for authentication (clauses 3b and 3e).
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d) Processing payment transactions via Telegram Stars if the User is an Application Administrator (clauses 3b and 3e).
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e) Forming a contact address book within Connected Chats (clauses 3a-3e).
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f) Ensuring the correct operation of the Application's functionality (clauses 3a-3e).
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g) Technical: prevention of technical failures and ensuring security (clause 3f).
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8. Post-withdrawal, the Operator retains the right to continue processing Personal Data without consent where grounds exist under Clauses 2-11(Part 1, Article 6), Part 2(Article 10), and Part 2(Article 11) of Federal Law No. 152-FZ dated 27.07.2006 "On Personal Data".
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5. I express my consent that 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" is recognized by the Operator and the User as an analogue of the User's handwritten signature (simple electronic signature), certifying the fact of familiarization and agreement with the terms of this Consent and the Operator's Privacy Policy, posted in the Application and publicly accessible on the Internet at: [https://tgcrew.ru/privacy-policy](https://tgcrew.ru/privacy-policy).
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6. This consent enters into force from the moment it is provided by performing the actions specified in clause 5 of this Consent and remains valid until it is withdrawn.
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7. Withdrawal of this Consent is performed by clicking the "Stop using the application" button and subsequently clicking the "Confirm" button in the dialog that opens. The "Stop using the application" button is located in the Settings section (for both the User part and the Admin Panel). Additionally, a withdrawal of Consent may be sent to the Operator in writing to the email address [support@tgcrew.ru](mailto:support@tgcrew.ru). Withdrawal of Consent entails the termination of personal data processing and its destruction, except in cases provided for by clause 8 of this Consent.
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8. In the event of withdrawal of this consent, the Operator is entitled to continue processing the User's personal data without their consent if there are grounds provided for by clauses 2-11 of part 1 of article 6, part 2 of article 10, and part 2 of article 11 of the Federal Law dated July 27, 2006, No. 152-FZ "On Personal Data."
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9. Operator Contact Information and Details
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Individual Entrepreneur Martyshkin Alexey Alexandrovich
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Legal Address: 111394, Russian Federation, Moscow, Perovskaya Street, House 66, Building 3, Apartment 187
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OGRNIP 318774600262084
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INN 366316608346
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Phone: +7 (916) 439-04-25
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Email: [info@tgcrew.ru](mailto:info@tgcrew.ru)
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