1. Who we are
Telesuber is software that lets creators sell paid access to their Telegram channels and groups. A creator connects their own Telegram bot and their own payment account; the bot shows the plans, takes the payment and lets the buyer into the channel, renews the subscription when it falls due and removes people when they stop paying. The same software sends broadcasts and automated messages, answers common questions through an optional AI support bot, imports subscriber lists from other tools, reports on what has been sold, and lets a creator invite colleagues to help run the workspace.
The Service is operated by Telesuber (“we”, “us”, “our”). In this policy, “the Service” means the Telesuber application, our website at https://telesuber.com, and the checkout pages we host for creators at https://telesuber.com/buy/ and their sub-pages.
You can reach us about anything in this policy by email at no-reply@telesuber.com, or through the help chat inside your dashboard. Our full contact details are in section 20.
We have not appointed a data protection officer. Privacy questions and requests are handled by the people who run the Service, at the contact details in section 20.
1.1 Other documents
This policy sits alongside the rest of our legal pages, which are listed at /legal:
- the Terms of Service, which govern your use of the Service;
- the Acceptable Use Policy, which says what may not be sold or sent through the Service;
- the Refund & Cancellation Policy, for the fees you pay us;
- the Data Processing Addendum, which applies when we handle subscriber data for a workspace;
- the Subprocessors page, which names the companies we currently rely on to run the Service;
- the Cookie Policy, which lists every cookie we set.
2. Who this policy covers, and our two roles
Telesuber is used by two very different groups of people, and the law treats our responsibility to each of them differently. It is worth being clear about which one you are, because it decides who you should ask when you want something done.
2.1 Account holders and visitors — we are the controller
If you own a workspace, have been invited to help run one, are signing up for one, are a member of our own staff, or are simply reading our website, we decide why and how your personal information is used. In the language of the European and UK General Data Protection Regulation we are the controller, and this policy is our notice to you.
2.2 Subscribers and workspace content — we are a processor
If you bought access to a channel from a creator, the creator’s workspace decides why and how your information is used. They chose to sell access, they set the plans and the wording, they decide who to message and who to remove, and they decide how long to keep their own records. They are the controller. We supply the software and hold the data on their behalf, which makes us their processor. What we may and may not do with that data is set out in our Data Processing Addendum, which forms part of the contract between us and every workspace.
The practical consequence is in section 5: if you are a subscriber, the creator you bought from is the right first point of contact, and their own privacy notice — not this one — describes what they do with your information.
One thing worth knowing up front: money never passes through us. Subscribers pay the creator’s own Stripe, PayPal, Skrill, NOWPayments or OKX account. We are told that a payment happened so the right channel can be opened, but we never see or hold a card number.
3. What we collect about account holders
This section covers workspace owners, the team members they invite, people part way through signing up, and our own staff. Almost all of it is information you type in yourself; the rest is generated by the software as you use it.
3.1 Your account
- your first and last name, and your email address;
- the country you are based in, which you choose when you sign up and can change in your account settings;
- a profile photo, if you add one — we keep only a small square copy we make from it, never the file you uploaded or anything written inside it, such as where it was taken;
- a Telegram username, if you add one, so our team can reach you there;
- when you last changed your password;
- your password — stored only as an Argon2id hash, never as text we could read or recover;
- whether your email address has been confirmed;
- a counter of failed sign-in attempts and, if too many fail in a row, the time until which the account is locked;
- your preferences: light or dark appearance, your time zone (which decides where your day starts on every chart and report you see), and whether you want tips and offers from us by email.
3.2 While you are signing up
Signing up is a short sequence of questions, and each answer is saved as it is given so that you can close the tab and come back. Before an account exists we hold: your name and email address, the workspace name, the country you are based in, what you sell (either topics you pick from a list or your own words), where you heard about us, the size of your audience or your existing paying membership, a hashed copy of the six-digit confirmation code we email you, and how far through you are. No password is kept until you choose one at the end, which is also the moment the account is actually created.
An unfinished sign-up can be finished for 7 days after you start it. If you stop part way we may send you up to two reminder emails with a link back to where you left off. We never send those reminders to an address on our do-not-email list, and never to an address that already has an account.
Our team can see a sign-up that was not finished — your name and email address, the name you gave your workspace if you got that far, how far you got, when you started and when you last answered, whether you confirmed the address, how many reminders went, and whether the address is on our do-not-email list — so that we can help if something went wrong, such as a code that never arrived. Somebody on the team may write to you about it from their own mailbox. It is never added to a mailing list, and it never becomes an account unless you finish. It is deleted 30 days after you started, or sooner if you write to no-reply@telesuber.com from that address — you need no account to ask.
3.3 Security information
- if you switch on two-step verification, the secret your authenticator app is built from — stored encrypted — and one-time recovery codes, stored only as hashes, so that even we cannot read them back;
- password-reset links, stored as hashes and valid for one hour;
- sign-in challenges — the short-lived step between your password and your two-step code — which last 5 minutes.
3.4 Sessions and devices
For each device you are signed in on we keep the IP address it connected from, a trimmed copy of the browser user agent string, when the session started and when it was last seen. The “last seen” time is updated at most once every 5 minutes, so it is a rough record of activity rather than a log of each page you open. You can see the list of your own devices in your account settings and sign any of them out.
An approximate location — a city and a country — appears beside a session only if the operator of this installation has configured an IP geolocation service. That is off by default, deliberately: the address you sign in from is yours, and sending it to a third party is not a decision we make for you. Where it is switched on, the lookup happens once per sign-in, in the background after the sign-in has already succeeded, and private or local network addresses are never sent anywhere.
3.5 Your workspace and what you set up in it
A workspace holds the configuration of your business, and much of it is not personal information at all. What we hold includes:
- the workspace name, what it sells, the size of your audience and where you came from;
- your plan with us, billing status, trial dates and renewal dates;
- the bots you connect, the channels and groups they manage, your plans and prices, coupons, storefront branding and logo, the wording your bot uses, automations, broadcasts, your support knowledge base and your tags or segments;
- credentials you connect so that the software can act for you: Telegram bot tokens, payment provider API keys and webhook signing secrets, and AI provider API keys. These are stored encrypted and are never displayed back to you once saved.
3.6 Your team
When you invite a colleague we record the email address you invited, the role you gave them, who sent the invitation and when. An invitation link expires 30 minutes after it is created. Once your colleague accepts, they become an account holder in their own right and everything in this section applies to them.
3.7 Messages you send us
We keep the messages you and your team send us from the Help page in the dashboard, together with our replies. If we have switched on our own AI help assistant, its replies are kept in the same conversation. Each conversation has a subject and stays on your Help page, so earlier messages stay visible to us and to you.
3.8 Billing for the fees you pay us
For your subscription to Telesuber we hold the plan, amounts, currency, dates, the payment provider’s reference identifiers and the event payload the provider sends us when something happens. Invoices show your workspace name and the owner’s email address. Card details are typed into the payment provider’s own fields — on its hosted page, or in Stripe’s card fields on the card step of our own checkout — and never reach us. The free trial — currently 1 day — starts when a card is added, and the card goes to the payment provider like any other: we hold the dates and the provider’s reference for the subscription, never the card.
3.9 The audit log
The Service keeps a record of account and security events so that questions like “who changed this, and when” have an answer. It covers:
- sign-ins and failed sign-ins, two-step verification changes and password resets;
- team invitations and membership changes, including the invited email address;
- workspace changes such as connecting a bot or a channel, creating or editing plans and coupons, running imports and sending broadcasts;
- refunds, cancellations and payments applied;
- actions our staff take on a workspace — for example opening its profile or emailing one of its members.
The audit log is append-only: it cannot be edited or deleted through the application, by you or by us. That is the point of it. It is kept indefinitely for security, fraud prevention and resolving disputes, and it is the one record that survives a deletion request (see sections 14 and 16).
3.10 Notes our staff write
Our support staff can write internal notes about a workspace — the context that makes the next conversation shorter. These notes are about the workspace and are not shown to it. They are ordinary personal information where they concern an identifiable person, and the rights in section 16 apply to them.
3.11 Communication preferences
If you unsubscribe from our product emails, or if an address bounces or is reported as spam, we keep that address on a do-not-email list so that we do not write to it again. Keeping the address is what makes the suppression work; removing it would simply let the next message through.
3.12 Where this information comes from
Nearly all of it comes from you. The rest comes from your browser or device (IP address, user agent), from Telegram when you connect a bot, from the payment provider that charges you our fees, and from the email delivery service when a message bounces or is reported. We do not buy personal information, and we do not enrich your account from data brokers, social networks or public records.
4. What we process on behalf of workspaces
Everything in this section is data a workspace collects about its own subscribers. We hold it as the workspace’s processor, act on its instructions, and do not use it for our own purposes. It is listed here so that everyone can see what the software actually stores.
4.1 From Telegram
When somebody uses a workspace’s bot or is a member of one of its channels, Telegram tells the bot: the Telegram user id, the username if one is set, the first and last name as entered on that account, the language code of the app, whether the person has blocked the bot, and join and leave events for the channel.
4.2 From a checkout page
- the name and email address the buyer types;
- a Telegram username, if they choose to type one;
- the plan chosen and any coupon code used;
- if they use “Continue with Telegram”, the identity Telegram signs and sends back — the Telegram user id, first and last name and username. The link to the profile photo is not stored. Signing in this way also means the workspace’s bot can message the buyer, which is how access is delivered.
4.3 Purchases and subscriptions
- amounts, currency, status (including refunds and disputes), and dates;
- the tax country and tax amount reported by Stripe, where Stripe reports them;
- the payment provider’s reference identifiers and the full event payload it sends for each event, which is what lets a disputed or missing payment be reconstructed;
- subscription status and the period it is paid up to;
- channel membership state and every invite link issued to that person;
- coupon redemptions and checkout attempts, including ones that were never completed.
4.4 Support conversations
Messages between subscribers and the workspace’s support bot or its team are kept in the workspace’s inbox. An AI provider is called only if the workspace has switched its AI support bot on; what is sent in that case is described in section 12.
4.5 Messaging records
Which broadcasts and automated messages went to which subscriber, and whether Telegram accepted the delivery. A workspace needs this both to avoid sending the same thing twice and to find out why somebody did not receive something.
4.6 Imports
If a workspace moves across from another tool it can upload its existing list. Whatever the file contains is processed: Telegram ids, usernames, email addresses, plan names, expiry dates and any other columns present. The uploaded file itself is kept until the import is applied.
4.7 Tags, notes and refunds
The tags or segments a workspace applies to its subscribers, notes it writes about them, and refunds it issues — including the reason typed by the workspace.
A workspace decides what goes into its own Service. We ask every workspace not to put information into Telesuber that it does not need — and never to put special-category information, such as health or political details, into a subscriber note or tag. The Data Processing Addendum and the Acceptable Use Policy set out the rules.
5. If you bought access from a creator
You bought from the creator, not from us. They decide what they collect, how they use it and how long they keep it, and their own privacy notice is the document that describes it. Telesuber is the software they use to run their channel.
So if you want a copy of your data, want it corrected or deleted, want to stop receiving messages, or want to know why you were removed from a channel, ask the creator first. They can do all of those things from their dashboard, immediately, without involving us.
If you contact us instead, we will pass your request on to the workspace concerned where we can identify which one it is, and tell you that we have done so. We will help that workspace to answer you, as our Data Processing Addendum requires. What we will not do is change or delete a workspace’s records on our own initiative — the data is theirs to answer for, and acting behind their back would break exactly the promise that makes us safe to use.
Two things we can always do directly, whoever asks: tell you what this policy says, and stop our own marketing emails to you (we do not market to subscribers at all — see section 9).
6. Visitors to our website
Our public pages — the home page, pricing, how to start, and the blog — and the checkout pages we host for creators can all be read without an account, and without our learning who you are.
6.1 No tracking of any kind
We use no analytics, advertising or tracking tools whatsoever. There are no third-party fonts, no embeds, no social buttons and no tracking pixels anywhere on our pages, and no third-party scripts but Stripe’s, on one page: the card step of our own checkout, where a workspace pays us for its plan by card. There Stripe’s script shows Stripe’s own card fields, so that the card number goes straight from your browser to Stripe and never reaches us; to stop card fraud it also looks at the browser and the device and sets Stripe’s fraud-prevention cookies (see the Cookie Policy), under Stripe’s own privacy policy. Our emails contain no tracking images, which means we cannot tell whether an email we sent you was opened. This is enforced technically as well as by policy: every page is sent a content security policy that allows no third-party code to run, except that one page’s, which allows Stripe’s script and nothing else — so a tracker could not load even if one were added by mistake.
6.2 Cookies for anonymous visitors
Reading a public page sets no cookie at all. The first one appears only when you do something that needs it: opening a sign-in, sign-up or password form sets the security cookie that protects those forms against cross-site request forgery, and starting to sign up sets one that links this browser to your unfinished sign-up. On a creator’s checkout page a buyer is given a cookie only when they go on to pay — it holds the keys to what they bought, so that their receipt opens again — or choose to continue with Telegram. Every cookie we set is strictly necessary, and so are Stripe’s on the card step of our own checkout, which are there to stop card fraud. Section 7 and the Cookie Policy cover this in full.
6.3 Server and application logs
Like any web service, we keep logs. Our web server records, for each request: the IP address, the browser user agent, the address requested including its query string, the time, and the response. The application separately logs each request’s path without the query string, its result and how long it took, together with a request identifier and, for signed-in requests, which workspace it belonged to. These logs exist to keep the Service secure and working — to investigate errors, abuse and unauthorised access attempts — and for no other purpose. We rely on our legitimate interest in the security and proper operation of the Service.
6.4 Rate limiting
To stop password-guessing and bulk automated sign-ups, the Service counts recent requests per IP address in front of the sign-in, sign-up, checkout and token endpoints. Those counts are held briefly in memory and are not written to the database.
8. Why we use information, and our legal bases
Under the EU and UK GDPR, every use of personal information needs a legal basis. The table below gives ours. Where we rely on legitimate interests, we have considered whether our interest is outweighed by your rights, and you can object at any time (section 16).
| What we do | Why | Legal basis |
|---|---|---|
| Create and run your account and workspace, and provide the Service | To give you what you signed up for | Performance of a contract |
| Run the sign-up sequence, confirm your email address, send reminders if you stop part way, and let our team see where a sign-up stopped | So that an account is only created for somebody who controls the address, so that a half-finished sign-up is not simply lost, and so that we can help somebody who got stuck | Steps taken at your request before a contract; legitimate interests (preventing false accounts, helping people finish what they started) |
| Secure accounts: password hashing, two-step verification, lockouts, session records, rate limits | To protect you and us from unauthorised access | Legitimate interests (security); legal obligation where applicable |
| Keep the audit log | Security, fraud prevention, and resolving disputes about what was done and by whom | Legitimate interests; legal obligation where applicable |
| Take payment for our fees, issue invoices and keep accounting records | To be paid, and to meet tax and accounting rules | Performance of a contract; legal obligation |
| Send service emails: sign-up codes, sign-up reminders, password resets, team invitations and receipts | These are part of running your account and cannot sensibly be switched off | Performance of a contract; legitimate interests |
| Send product news and tips to workspace owners | To tell existing customers about the product they are paying for | Legitimate interests — you can opt out at any time from the link in every such email |
| Answer support requests in the help chat or by email | To help you use the Service | Performance of a contract; legitimate interests |
| Improve and fix the Service using aggregate counts | To find what is slow, broken or confusing | Legitimate interests |
| Comply with law and respond to lawful requests; establish or defend legal claims | Because we must, and to protect our rights | Legal obligation; legitimate interests |
| Process subscriber data inside a workspace | Because the workspace has instructed us to, as its processor | The workspace’s own basis; our role is set by the Data Processing Addendum |
Where we ask for consent — which today is limited to cases the law specifically requires — you can withdraw it at any time, and withdrawing it does not affect anything done before you did.
9. Emails we send
There are two kinds, and we keep them separate on purpose.
9.1 Service emails
Your sign-up confirmation code, reminders about an unfinished sign-up, password reset links, team invitations and receipts for the fees you pay us. These carry information you need in order to use or keep your account, so they are not marketing and cannot be switched off while your account is open. Unsubscribing from product news never stops them.
9.2 Product news and tips
Occasional messages to workspace owners about the product. Every one of them carries an unsubscribe link in its body and in its headers, so that one click in your mail client is enough. We send no marketing at all to subscribers who bought from a creator — they are not our customers, and their relationship is with the creator.
9.3 What we can and cannot see
Our messages contain no tracking images or tracking links, so we cannot tell whether one was opened or read. We do know whether the email delivery service accepted a message and whether it bounced or was reported as spam, because that is what tells us to stop writing to an address.
10. Automated decisions and artificial intelligence
We make no automated decisions that produce legal effects concerning you or similarly significantly affect you, and we do not profile you. Nothing in the Service scores you, ranks you or decides anything important about you without a person involved.
Two things are automated, and neither is a decision of that kind:
- Security limits. Repeated failed sign-ins temporarily lock an account, and repeated requests from one address are slowed down. These are ordinary security measures, and they lift by themselves.
- The AI support bot. A workspace can switch on a bot that answers its subscribers’ questions using only the knowledge that workspace has written. It is instructed to answer from that knowledge and nothing else, and to say so when it cannot. It cannot change anybody’s subscription, refund anything or remove anybody from a channel.
We do not use workspace or subscriber data to train AI models, and we do not allow the AI providers we use to do so for us. An AI provider is contacted only in the two situations described in section 12.6.
11. We do not sell or share personal information
To be unambiguous about it:
- We do not sell personal information, and have never done so, for money or for anything else of value.
- We do not share personal information for cross-context behavioural advertising, and we do not run advertising of any kind.
- We do not disclose personal information to data brokers.
- We do not use workspace or subscriber data to train AI models.
- We do not read subscriber lists or conversations for our own purposes. Our staff see summaries — counts and dates — not subscriber lists or message contents, there is no “sign in as this customer” feature, and when a staff member opens a workspace it is written to the audit log.
The companies listed in section 12 receive information in order to perform a service for us or for a workspace, under a contract that forbids them from using it for their own purposes. Under California law that is a service-provider relationship, not a sale.
13. Where information is processed
The Service runs on servers in one place, but the providers listed in section 12 may process personal information in countries other than your own, including the United States. Telegram, Stripe, PayPal, Skrill (Paysafe), NOWPayments, OKX, Groq and Anthropic all operate internationally.
Where personal information protected by European or UK law is transferred outside the European Economic Area or the United Kingdom, we rely on an appropriate safeguard: usually the European Commission’s Standard Contractual Clauses (with the UK International Data Transfer Addendum where UK data is involved), or a finding of adequacy for the country concerned. You can ask us for details of the safeguard that applies to a particular transfer using the contact details in section 20.
14. How long we keep information
Some of these periods are enforced automatically by the software, which deletes old rows on a schedule. Others depend on how long your account is open.
| What | How long |
|---|---|
| Sessions (devices you are signed in on) | Deleted 30 days after they expire or are signed out |
| Sign-in challenges | Deleted 1 day after they expire |
| Password-reset links | Deleted 7 days after they expire |
| Codes for changing your email address | They work for 15 minutes, and are deleted 1 day after they expire |
| Sign-ups | One that is not finished can be finished for 7 days after it starts, and is deleted 30 days after it starts. One that is finished becomes your account, and the sign-up itself is deleted 1 day after its 7 days are up |
| Team invitations | The link expires 30 minutes after it is created |
| Payment-provider event payloads | 90 days once processed; 30 days if rejected; 180 days if they failed, because a failure is the one somebody may still need |
| AI usage counters (counts only, no message content) | 30 days |
| Email delivery counts (counts only, no addresses) | 400 days |
| Audit log | Kept indefinitely |
| Payment, refund and invoice records | As long as needed for accounting, tax and legal purposes |
| Account, workspace and subscriber data | Kept while the account exists; deleted when we delete the workspace or the account, on a verified request |
| Uploaded import files | Kept until the import is applied |
| Do-not-email list | Kept for as long as we send email, because it is what stops us writing to you |
| Backups | Encrypted nightly copies kept on the server for 14 days; where off-site copies are used, they follow that storage’s own retention |
When we delete your data on request, three things survive: records we are required by law to keep (for example accounting records of payments you made), the append-only audit log, and your address on the do-not-email list if it is there. We explain why in section 16.5.
Deleted data can persist in an encrypted backup until that backup rotates out, which takes up to 14 days on the server. We do not restore a backup in order to reinstate deleted data.
15. How we protect information
Security here is mostly architecture rather than promises. The measures below are built into the Service:
- Passwords are hashed with Argon2id. We cannot read them, and neither can anybody who obtains the database.
- Credentials and two-step secrets — bot tokens, payment provider API keys and webhook signing secrets, AI provider keys, two-step verification secrets — are encrypted with AES-256-GCM envelope encryption. Lose the master key and the database is intact and unreadable.
- Tokens — password reset links, recovery codes, confirmation codes — are stored only as hashes, so the stored copy cannot be used to sign in.
- Row-level security in the database separates workspaces from each other, so one workspace’s query cannot return another’s rows even if the application asked it to.
- HTTPS with HSTS on every connection, and cookies that a browser will only send back over HTTPS.
- A strict content security policy that allows no third-party code, fonts, embeds or images from other sites — which is also why we cannot accidentally acquire a tracker. The one exception is Stripe’s script on the card step of our own checkout, so that a card goes straight to Stripe; that page allows it and nothing else.
- Rate limits in front of sign-in, sign-up, checkout and token endpoints, and account lockout after repeated failed sign-ins.
- Optional two-step verification on your account, which we recommend switching on.
- Encrypted backups that are test-restored: the nightly copy is encrypted, decrypted and read back before it is counted as good, and the restore procedure is exercised rather than merely documented.
- Limited staff access. Our staff see what support and billing need: summaries, counts and dates through our admin tools — not subscriber lists and not the contents of conversations. There is no feature that lets a member of staff sign in as a customer, and staff views of a workspace are written to the audit log.
No system is perfectly secure, and anybody who tells you otherwise is selling something. If a personal data breach occurs we will notify the relevant supervisory authority and the people affected as and when the law requires — and, where we are a processor, we will notify the workspace without undue delay so that it can meet its own obligations.
16. Your rights and choices
16.1 What you can ask for
Depending on where you live, you have some or all of these rights over the personal information we hold about you as controller:
- Access — a copy of your personal information, and an explanation of how we use it.
- Correction — to have inaccurate information put right. Most of it you can correct yourself in your account settings, immediately.
- Deletion — to have your information erased, subject to the exceptions in 16.5.
- Restriction — to have us pause using your information while a dispute about it is resolved.
- Portability — to receive the information you gave us in a structured, commonly used, machine-readable format, or to have it sent to another provider where that is technically feasible.
- Objection — to object to processing based on our legitimate interests, including an absolute right to object to direct marketing at any time.
- Withdrawing consent — where we rely on consent, you can withdraw it at any time without affecting what was done beforehand.
- Complaint — to complain to a data protection authority; see 16.6.
16.2 How to make a request
There is no self-service export or deletion button in the Service today. Requests are handled by people, which means you should send one to no-reply@telesuber.com or through the help chat inside your dashboard. Tell us what you want and, if it is not obvious from the account you are writing from, which account or workspace you mean.
If you started signing up and never finished, you have no account and no dashboard to write from. Write to no-reply@telesuber.com from the address you signed up with, and we will delete what you typed.
We will:
- Verify who you are before we act. Usually that means writing from the address on the account, or making the request from inside a signed-in session. For a request that would disclose or destroy information we may ask for more — the amount of verification matches the sensitivity of the request. We will not ask you for a copy of an identity document unless there is no other way to be sure.
- Answer within 30 days of verifying your identity. If a request is complex or you have made several, we may extend that where the law allows, and we will tell you before the first 30 days are up, with the reason.
- Charge nothing, unless a request is manifestly unfounded or excessive, in which case we will say so and explain why before doing anything.
- Tell you why if we cannot do what you asked, and what you can do next.
An authorised agent may make a request for you. We will ask for proof that you authorised them, and we may still ask you to confirm it directly.
16.3 What you can do yourself, right now
- Correct your name, email address, country, photo, Telegram username, appearance and time zone in your account settings, and change your password there.
- See every device signed in to your account and sign any of them out.
- Switch two-step verification on or off.
- Stop product emails with the link at the bottom of any of them, or from your account settings.
- Ask us to close your account from your account settings; the request arrives in the help chat.
- As a workspace owner: edit or delete your plans, coupons, automations, broadcasts, subscribers and their notes and tags directly in the dashboard.
16.4 Requests about subscriber data
If your request concerns data inside a workspace — a subscriber’s purchase, a support conversation, a Telegram identity — the workspace is the controller and we are its processor. We will refer you to that workspace where we can identify it, and assist the workspace in answering you, as the Data Processing Addendum requires. See section 5.
16.5 Where we may have to say no, or say not quite
- The audit log. It is append-only by design: it cannot be edited or deleted through the application, which is what makes it worth having as evidence of what was done to an account and by whom. We keep it on the basis of our legitimate interest in security, fraud prevention and dispute resolution, and it is retained after an account is deleted.
- Records we must keep by law. Payment, refund and invoice records are kept for the periods that accounting and tax rules require.
- The do-not-email list. If you unsubscribed or an address bounced, the address stays on that list, because deleting it would simply let the next message through. It is used for nothing else.
- Other people’s information. We will not hand over information that would disclose personal data about somebody else — for example the other members of a shared workspace.
16.6 Complaints
If you are unhappy with how we have handled your information, please tell us first; we would rather fix it. You can also complain to a data protection authority. In the EU that is the authority in the country where you live, work or where the problem happened; in the UK it is the Information Commissioner’s Office. Complaining to an authority does not affect any other legal remedy you have.
16.7 If you live in another US state with a privacy law
Several US states now give residents rights to know about, access, correct, delete and obtain a portable copy of their personal data, and to opt out of targeted advertising, sale, or profiling with legal effects. We do not carry out targeted advertising, do not sell personal data and do not carry out that kind of profiling, so those opt-outs have nothing to act on here. The other rights work exactly as described in 16.1 and 16.2, whichever state you are in. Where the law gives you a right to appeal a refusal, we will tell you how to appeal at the point we refuse, and we will respond to an appeal within the period that law allows.
17. California privacy rights
This section is for California residents and is our notice under the California Consumer Privacy Act as amended by the California Privacy Rights Act. It repeats, in California’s language, what the rest of this policy says.
17.1 What we collect, and why
| Statutory category | Do we collect it? | Examples |
|---|---|---|
| Identifiers | Yes | Name, email address, IP address, account and session identifiers; for subscribers, Telegram user id and username |
| Customer records (Civil Code § 1798.80) | Yes | Name and email held with billing records; we never receive card numbers |
| Commercial information | Yes | The plan you bought from us, amounts, dates, invoices; for subscribers, purchases from a workspace |
| Internet or other network activity | Yes | Server and application logs, request paths, sign-in records, the pages of our own site you requested. We do not track you across other websites. |
| Geolocation data | Only if configured | An approximate city and country from a sign-in IP address, and only where the operator has switched on a geolocation service, which is off by default. No precise location, ever. |
| Professional or employment information | Limited | The role a team member holds in a workspace, and what a workspace says it sells |
| Audio, visual or similar information | Limited | Logo and branding images a workspace uploads. No audio, video or biometric information. |
| Sensitive personal information | Account credentials only | See 17.2 |
| Education information | No | — |
| Inferences or profiles | No | We draw no inferences about your characteristics, preferences or behaviour |
The sources of this information are in section 3.12; the business purposes for collecting it are in section 8; and the categories of recipients are in section 12. How long we keep each category is in section 14.
17.2 Sensitive personal information
The only sensitive personal information we handle is account credentials — your email address together with your password, and your two-step verification secret and recovery codes. We use them for one thing: letting you into your own account and keeping everybody else out. We do not use or disclose sensitive personal information to infer characteristics about you, which means the right to limit its use has nothing to act on. We do not ask for government identifiers, financial account numbers, precise geolocation, racial or ethnic origin, religious beliefs, union membership, genetic or biometric data, health information or information about sex life or sexual orientation.
17.3 No sale, no sharing
We have not sold personal information and have not shared it for cross-context behavioural advertising in the last twelve months, and we do not do so today — including the personal information of anybody we know to be under 16. There is therefore no “Do Not Sell or Share My Personal Information” link to offer, because there is nothing to opt out of. Disclosures to the companies in section 12 are made to service providers and contractors for business purposes, under contracts that forbid them to use the information for their own purposes.
17.4 Your California rights
- To know what we collect, use, disclose and why, including the specific pieces of personal information we hold about you.
- To delete personal information we hold about you, subject to the exceptions the statute allows (see 16.5).
- To correct inaccurate personal information.
- To opt out of sale or sharing — which does not arise, as explained in 17.3.
- To limit the use of sensitive personal information — which also does not arise, as explained in 17.2.
- Not to be discriminated against for exercising any of these rights. We will not deny you the Service, charge you a different price or give you a lower quality of service because you asked.
17.5 How to exercise them
Use the same route as everybody else: email no-reply@telesuber.com, or write to us through the help chat in your dashboard. We will verify your identity in proportion to what you have asked for — usually by confirming control of the account email address — and respond within 30 days, which is sooner than the statute requires. Where a request is complex we may take the extension the law allows, and we will tell you before the first 30 days are up. An authorised agent may act for you with written permission, and we may ask you to confirm it and to verify your own identity.
17.6 Shine the Light
We do not disclose personal information to third parties for their own direct marketing purposes, so there is nothing to report under California Civil Code § 1798.83.
18. Children
The Service is not intended for anyone under 18, and we do not knowingly collect personal information from children. You must be 18 or older to create an account or to buy access through a checkout page.
Workspaces must not use the Service to sell to children where the law forbids it, and must comply with any age restrictions applying to what they sell. This is a condition of using the Service — see the Terms of Service and the Acceptable Use Policy.
If you believe a child has given us personal information, tell us using the contact details in section 20 and we will delete it.
19. Changes to this policy
We will update this policy when what we do changes, and when the law does. The date at the top always shows when the current version was published, and the previous version is replaced rather than kept alongside it.
If a change is material — a new purpose, a new category of recipient, a materially different retention period — we will email account owners about it as well as posting it. Where a change requires your consent, we will ask for it rather than assume it.
20. How to contact us
For anything in this policy, including a request under section 16 or 17:
- Telesuber
- no-reply@telesuber.com
- The help chat in your dashboard, which reaches the same people
- Our website: https://telesuber.com
If you are a subscriber who bought access from a creator, please read section 5 first — the creator can almost certainly answer you faster than we can.