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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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###### Version 1.05 dated April 15, 2026
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# Consent for Personal Data Processing
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###### Version 1.04 dated March 15, 2026
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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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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, as well as confirming my legal capacity, I (hereinafter — the **User**) hereby give my consent to individual entrepreneur Martynshkin Alexey Alexandrovich (OGRNIP 318774600262084, INN 366316608346, PData operator reg. number 77-25-471585; 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 are used in this Consent:
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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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**Bot** — an account named @tgCrewBot and located at [https://t.me/tgCrewBot](https://t.me/tgCrewBot) in the Telegram messenger, managed programmatically by the Operator 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).
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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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**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 Operator. 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.
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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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**Personal Data (or PData)** — any information relating to a directly or indirectly identified or identifiable individual (subject of personal data) (according to No. 152-FZ, Chapter 1, Article 3, Clause 1).
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**Administrator** — a User of the Application who manages the Application using the Admin Panel.
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@@ -19,54 +16,54 @@ The following terms and definitions are used in this Consent:
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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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- entering additional information data for Users;
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- controlling the payment of the License Fee to the Developer for using the Application.
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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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**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.
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1. This consent is specific, informed, conscious, and unambiguous.
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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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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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b) Storage for the period necessary to achieve the purposes of processing, but no less than the periods established by the Operator's Privacy Policy and the legislation of the Russian Federation.
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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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e) Transfer (provision, access) to state bodies, courts, or law enforcement agencies 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 have a common Connected Chat with the User, in the scope provided by the Application functionality (displaying the first name, last name, avatar, position or role in participant lists, in the description 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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h) Implementation of other actions provided for by the legislation of the Russian Federation.
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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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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 participant of a Connected Chat) and (or) automatically collected by the Application:
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a) Full name (surname, first name, patronymic).
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a) 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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d) Information about the place of work (name of the organization, structural unit, position and/or functional role).
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e) Data of the account in the Telegram messenger: 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 Operator's servers), language settings of the Telegram client, as well as, if the User is an Administrator, Telegram Stars transaction data (user identifier, number of Telegram Stars, transaction identifier, operation timestamp), which are automatically transmitted via the Telegram API. 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 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).
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4. Personal data processing is carried out for the following purposes:
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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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a) Identification and authentication in the Application (sub-clauses 3.b and 3.e).
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b) Provision of technical support and processing of inquiries (sub-clauses 3.a-3.d).
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c) Sending system notifications if the User is an Application Administrator and uses email for authentication (sub-clauses 3.b and 3.e).
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d) Accounting and confirmation of payment transactions via Telegram Stars, in case the User is an Application Administrator (sub-clauses 3.b and 3.e).
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e) Formation of an address book of contacts within Connected Chats (sub-clauses 3.a-3.d).
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f) Ensuring the correct operation of the Application functionality (sub-clauses 3.a-3.d).
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g) Implementation of technical measures aimed at preventing technical failures, identifying errors, and ensuring the information security of the Application (clause 3.f).
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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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5. I express my consent that 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" 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 in public access 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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6. This consent enters into force from the moment it is provided by performing the actions specified in clause 5 of this Consent and is valid until the moment of withdrawal.
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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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7. Withdrawal of this Consent is carried out by clicking on the "Refusal to use the application" button and subsequently clicking the "Confirm" button in the dialog that opens. The "Refusal to use the application" button is located in the Settings section (both for the User part and for the Admin Panel). Also, the withdrawal of Consent can 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 for cases provided for in 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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8. In case of withdrawal of this consent, the Operator has the right 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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9. Contact Information and Details of the Operator
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Individual Entrepreneur Martynshkin 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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