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Privacy Evaluation for Telegram Messenger

Last updated February 4, 2021

Overview

Telegram is a messaging app with secret, encrypted options for messaging and public options for messaging. As Telegram explains in its privacy policy, the data a user posts in public communities is encrypted, both in storage and in transit — but everything a user posts in public will be accessible to everyone. The policy notes that they do not require the screen name to be a user's real name. The policy says that the service does not use a user's data or cookies to show the user any ads. While encryption is provided for messages, there is no discussion of data breach notification in the policies. Telegram's policies do not discuss whether or not the product can be used by children or students or provide any protection particularly geared to children.

Telegram can be accessed through its website, and is available for download at the iOS App Store, the Google Play Store, and/or Microsoft. The Privacy Policy and Terms of Use used for this evaluation can be found on Telegram’s website, iOS App Store, the Google Play Store, and/or Microsoft. This evaluation only considers policies that have been made publicly available prior to an individual using the application or service.

Safety

Their policy explains that they do not require your screen name to be the user's real name. In addition to private messages, Telegram's policy also supports public channels and public groups. As Telegram explains in its privacy policy, the data a user posts in public communities is encrypted, both in storage and in transit — but everything a user posts in public will be accessible to everyone. Telegram's policy notes that to prevent phishing, spam and other kinds of abuse and violations of Telegram’s Terms of Service, their moderators may check messages that were reported to them by their recipients. Also, Telegram's policy notes that they may also use automated algorithms to analyze messages in cloud chats to stop spam and phishing.

Privacy

Telegram's policy notes that users must provide their mobile number and basic account data (which may include profile name, profile picture and about information) to create a Telegram account. The policy notes that they do not require the screen name to be a user's real name. Telegram's privacy policy indicates that they only store the data that Telegram needs to function as a secure and feature-rich messaging service. Telegram's policy explains that they use third-party services for bots, payments, and that they share information with affiliates in other countries. The policy says that the service does not use a user's data or cookies to show the user any ads.

Security

Telegram's policy explains that its secret chats use end-to-end encryption, and this means that all data is encrypted with a key that only the user and the recipient know. According to the privacy policy, this information is encrypted in transit and while stored. They delete information when it is no longer used for providing service. However, there is no discussion of data breach notification in the policies.

Compliance

Telegram's policies do not discuss whether or not the product can be used by children or students, or whether it may or may not be used in an educational context. In some cases, Telegram's privacy policy notes, the user may have rights to access or delete their information, and the user can ask the GDPR bot for help on this.

Data Collection
SCORE: 50%

What data does it collect?

  • Personally identifiable information (PII) is collected.
  • The categories of collected personally identifiable information are indicated.
  • Collection or use of data is limited to product requirements.
  • Unclear whether this product collects geolocation data.
  • Unclear whether this product collects biometric or health data.
  • Behavioral data are collected.
  • Sensitive data are not collected.
  • Non-personally identifiable information is collected.
  • Unclear whether opt-in consent is requested from users at the time personal information is collected.
  • Personal information of users is collected by a third party.
Data Sharing
SCORE: 60%

What data does it share?

  • Collected information is shared with third parties.
  • The categories of information shared with third parties are indicated.
  • The purpose for sharing a user's personal information with third parties is indicated.
  • The categories of third parties that receive personal information are indicated.
  • Unclear whether data are shared for analytics.
  • Unclear whether data are shared for research and/or product improvement.
  • Data are shared with third-party service providers.
  • The roles of third-party service providers are indicated.
  • Unclear whether this product supports social or federated login.
  • Unclear whether contractual limits are placed on third-party data use.
Data Security
SCORE: 65%

How does it secure data?

  • A user's identity is verified with additional personal information.
  • Account creation is required.
  • Unclear whether parental controls or managed accounts are available.
  • Two-factor account protection is available.
  • Unclear whether third-party contractual security protections are required.
  • Industry best practices are used to protect data.
  • Employee or physical access to user information is limited.
  • All data in transit are encrypted.
  • All data at rest are encrypted.
  • Unclear whether this product provides notice in the event of a data breach.
Data Rights
SCORE: 65%

What rights do I have to the data?

  • Users can create or upload content.
  • Unclear whether users retain ownership of their data.
  • Unclear whether this product provides processes to access and review user data.
  • Processes to modify inaccurate data are available.
  • A data-retention policy is available.
  • Processes for the school, parents, or students to delete data are available.
  • A user's data are deleted upon account cancellation or termination.
  • Data are deleted when no longer necessary.
  • Permissions, roles, or access controls are available to restrict who has access to data.
  • Unclear whether this product provides users the ability to download their data.
Data Sold
SCORE: 20%

Is the data sold?

  • Data are not sold or rented to third parties.
  • Unclear whether users can opt out from the disclosure or sale of their data to a third party.
  • Unclear whether user information can be transferred to a third party.
  • Unclear whether users are notified if their information is transferred to a third party.
  • Unclear whether user information can be deleted prior to its transfer to a third party.
  • Unclear whether third-party transfers are contractually required to use the same privacy practices.
  • User information is not shared in an anonymous or deidentified format.
  • Unclear whether the vendor describes their deidentification process of user information.
  • Unclear whether data are shared for research and/or product improvement.
  • Unclear whether contractual limits prohibit third parties from reidentifying deidentified information.
Data Safety
SCORE: 80%

How safe is this product?

  • Users can interact with trusted users and/or students.
  • Users can interact with untrusted users, including strangers and/or adults.
  • Profile information is not shared for social interactions.
  • Personal information is displayed publicly.
  • Users can control how their data are displayed.
  • User-created content is reviewed, screened, or monitored by the vendor.
  • Unclear whether user-created content is filtered for personal information before being made publicly visible.
  • Social interactions between users are moderated.
  • Social interactions of users are logged.
  • Users can report abuse or cyberbullying.
Ads & Tracking
SCORE: 40%

Are there advertisements or tracking?

  • Data are not shared for third-party advertising and/or marketing.
  • Unclear whether this product displays traditional or contextual advertisements.
  • Behavioral or targeted advertising is not displayed.
  • Unclear whether this product allows data collection by third-party advertising or tracking services.
  • Unclear whether this product uses data to track and target advertisements on other third-party websites or services.
  • Data profiles are not created and used for data enhancement, and/or targeted advertisements.
  • The vendor cannot send marketing messages.
  • Unclear whether this vendor provides promotional sweepstakes, contests, or surveys.
  • Unclear whether this product provides users the ability to opt-out of traditional, contextual, or behavioral advertising.
  • Unclear whether this product provides users the ability to opt out or unsubscribe from marketing communications.
Parental Consent
SCORE: 0%

Can I provide parental consent?

  • Unclear whether intended for children under 13.
  • Unclear whether this product collects personal information online from children under 13 years of age.
  • Unclear whether intended for parents or guardians.
  • Unclear whether vendor has actual knowledge that personal information from users under 13 years of age is collected.
  • Unclear whether children's privacy is applicable.
  • Unclear whether this product requires parental consent.
  • Unclear whether this product limits parental consent with respect to third parties.
  • Unclear whether this product allows parents to withdraw consent for the further collection of their child's information.
  • Unclear whether this product deletes children's personal information if collected without parental consent.
  • Unclear whether this product provides parental consent notice and method for submission.
School Purpose
SCORE: 0%

Is the product intended for school?

  • Unclear whether intended for students.
  • Unclear whether personal information or education records are collected from preK-12 students.
  • Unclear whether intended for teachers.
  • Unclear whether this product is primarily used by, designed for, and marketed toward students in grades preK–12.
  • Unclear whether the product creates education records.
  • Unclear whether this product provides notification of a contract or additional rights.
  • Unclear whether this product designates the vendor as a school official.
  • Unclear whether this product transfers parental consent obligations to the school or district.
  • Unclear whether the vendor indicates FERPA parental consent exceptions.
  • Unclear whether this product discloses directory information.

Common Sense Standard Privacy Report (SPR)

The standard privacy report (SPR) displays all the privacy practices from a product's policies in a single, easy-to-read outline. The report shows a green check mark for better privacy practices and an orange alert for risky or unclear practices. This alert indicates that more time should be focused on these particular details prior to use.

About Privacy Evaluations

The privacy evaluations have been designed with the help and support of a consortium of schools and districts across the United States. These evaluations are designed to help educators make informed decisions about the potential privacy implications of educational technology used to support teaching and learning.

Our core evaluation criteria will always be freely available. People are encouraged to read the questions we use and our information security primer. Vendors are encouraged to use our questions and the information security primer to self-evaluate. You can also learn more about our evaluation process. Please be in touch with any questions or feedback.