Privacy Policy of @tg_smart_feed_bot

2026-10-04 · v1.4

This version is no longer in force. Current version: https://pay.riadov.systems/legal/tg_smart_feed/privacy?lang=en

Permanent address of this version: https://pay.riadov.systems/legal/tg_smart_feed/privacy/1-4?lang=en

1. Who processes your data

This Policy describes which personal data are processed by the Telegram bot @tg_smart_feed_bot and the related autoposting service (the "Service").

The controller of personal data is:

Riadov Systems Vladyslav Riadov NIP: 6972395549 · REGON: 526790012 Address: ul. Jana Ostroroga 1a/28, 64-100 Leszno, Polska Email: [email protected] Telegram: @Riadov_Systems

Payments for the Service are handled by the payment service pay.riadov.systems of the same controller; the dashboard where you pay for the Service and manage your subscription is its page. The bot and the dashboard are parts of one Service, not a third party.

Personal data are processed in accordance with EU Regulation 2016/679 (GDPR) and the applicable law of the Republic of Poland.

2. What data we store

• Account — when you press /start: your Telegram ID, username and name from Telegram (if any), the language of your Telegram, the selected bot language, the account creation date and the date of your last interaction with the bot.

• Channels and groups to which the bot was added: chat identifier and type, title, public name (username), Telegram ID of the person who added the bot, the bot's status and rights, dates of adding and of the last change. If you added the bot to a channel or group at another person's request, your Telegram ID is stored in the record of that chat, while the chat itself belongs to that person in the Service.

• "Someone else will add it" requests: identifier, type, title and public name of the channel or group you selected, dates of creation, expiry and connection.

• Invitations to connect a channel or group: Telegram ID of the recipient and of the administrator who sent it, dates of creation, delivery and expiry.

• Plan and limits from the dashboard — a copy from the payment service: stage (setup paid or completed, subscription), plan, subscription status, publication limits, billing period, validity of the copy, the time you last opened the dashboard; the number of publications used in the period.

• Technical logs: event time and type, Telegram ID, chat identifier and technical identifiers of Telegram updates.

• After account deletion: a fingerprint of your Telegram ID computed with a secret key (HMAC-SHA256), the deletion date and a note of who initiated it — you or the automatic deletion after a year of inactivity. The Telegram ID itself is not stored.

The bot does not store the texts of your messages to the bot, your phone number, contacts or files — neither in the database nor in the logs.

The bot does not store payment data. The payment service stores: your Telegram ID within the project, the dashboard language, the time you last opened the dashboard, the Stripe customer identifier; the selected plan, the dates the setup was paid and completed; subscription status (plan, number of extensions, billing period, cancellation flag); unfinished payment sessions; payments (type, amount, currency, status, payment identifiers in Stripe); consents before payment (type, version number of the Terms, time). We do not collect or store invoice details (company name or your name, tax number, address) during payment.

Bank card data, e-mail and whatever Stripe asks for to pay by card are entered on the Stripe page — they are processed by Stripe, and neither the bot nor the payment service stores them.

3. Why and on what legal basis

• Account, channels, groups, requests and invitations — to provide the Service: connect your channels and groups, publish content in them, deliver invitations and talk to you in the selected language. Legal basis — performance of a contract (Art. 6(1)(b) GDPR).

• Plan, limits and publication counters, payments and subscription — to provide the paid Service and show you its status in the dashboard. Legal basis — performance of a contract (Art. 6(1)(b) GDPR).

• Records of payments and of consents before payment — accounting, tax obligations and proof of the consent given. Legal basis — compliance with legal obligations (Art. 6(1)(c) GDPR).

• Invoice — on your request via support: the details you send for it are used only for the invoice and accounting.

• Technical logs — security and stable operation of the Service, investigation of failures. Legal basis — the controller's legitimate interest (Art. 6(1)(f) GDPR).

• Fingerprint after deletion — proof that your deletion request has been fulfilled. Legal basis — the controller's legitimate interest (Art. 6(1)(f) GDPR).

The bot does not make automated decisions about you that have legal effects. Riadov Systems does not sell or transfer personal data to third parties for marketing purposes.

4. Who receives the data

• Telegram — the platform on which the bot runs. Telegram processes data as a separate controller under its own privacy policy: telegram.org/privacy.

• Payment service pay.riadov.systems — part of the Service of the same controller, not a third party: the bot sends it your Telegram ID and the number of publications used, and receives your plan, limits, payment status and the time you last opened the dashboard; on your /my_data or /delete_account request — a copy of your data held there or its deletion.

• Hosting provider — the servers are physically located in the European Union (Germany).

• Stripe (Stripe, Inc. / Stripe Payments Europe, Ltd.) — payment processing in the payment service: stripe.com/privacy.

• inFakt — accounting only for an invoice you request, from the details you send to support (an accountant may have access).

5. How long we keep the data

• Account — until you delete it with the /delete_account command or until a year passes without your interaction with the bot and the dashboard and without an active subscription: then the account is deleted automatically together with the data in the payment service.

• Channels and groups connected to your account — until the account is deleted.

• Your Telegram ID in the record of someone else's channel or group to which you added the bot — until its owner deletes their account or until you delete yours.

• Records of channels and groups not linked to an account in the bot — until deleted at your request via /support.

• "Someone else will add it" requests — 30 days from creation if the channel or group is not connected; connected ones — until the account is deleted.

• Invitations — up to 30 days from creation.

• Plan and limits from the dashboard (a copy in the bot) and publication counters — until the account is deleted.

• Technical logs — 30 days.

• Fingerprint after account deletion — indefinitely: it is only a fingerprint, without the Telegram ID.

• Data in the payment service: dashboard account, setup and subscription — until the account is deleted; records of payments and consents — 5 years from the end of the year in which the tax payment deadline passed, regardless of account deletion and unlinked from you after deletion.

6. Your rights

Under the GDPR you have the right to:

• access your data and receive a copy (right to data portability) — the /my_data command sends a file with the data of your account, channels, groups, requests, invitations, plan and limits, as well as your data in the payment service; technical log data — on request via /support;

• request deletion — the /delete_account command immediately deletes your account in the bot and in the dashboard, channels, groups, requests, invitations and payment data (an active subscription is canceled; records of payments and consents remain unlinked from you); if the payment service is unavailable, nothing is deleted — try again later; technical logs disappear after their retention period (30 days);

• request rectification — your name, username and Telegram language are updated automatically when you press /start; the bot language is changed with the /language command;

• restrict processing or object to it — via /support or [email protected];

• lodge a complaint with a supervisory authority — in Poland, this is Urząd Ochrony Danych Osobowych (UODO), uodo.gov.pl.

We respond to requests sent via support within one month.

7. Security and age

The controller applies appropriate technical and organisational measures to protect personal data against unauthorised access, loss and destruction. The bot exchanges data with Telegram over the secure HTTPS protocol.

The Service is intended for persons aged 18 and over. Persons under 18 must not use the Service.

8. Changes to the Policy

Riadov Systems may change this Policy. Each new version has a new number and date, stated at the beginning of the document. The current version is always available with the /privacy command.

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