Privacy policy

Clemzoo LLC publishes Botgram, a service that lets its customers have automated assistants reply on Telegram. Two audiences are concerned by this page, and their rights are not exercised in the same place.

• Customers, who open an account and run agents. For their data, the publisher is the controller: this page describes what it does with it, and requests are addressed to the publisher directly.
• Contacts, the people an agent exchanges messages with on Telegram. For their data, the customer decides the purposes and the means: they are the controller, and the publisher acts only as processor, on their instructions. A request for access or erasure therefore goes to the business that made contact, not to the publisher (see clause 11).

For account management, the following are processed:

Account

email address, display name, password (stored as a hash, never in clear text), profile picture, date the terms were accepted, date the email address was verified

Sign-in

IP address, browser identifier, and the creation, expiry and last-used dates of each session

Google sign-in

where the customer chooses this method, the only information received from Google is their email address, name and profile picture

Billing

balance movements, detailed usage, top-up receipts

Connected Telegram accounts

phone number, name, public handle, profile picture, and the Telegram sign-in session, stored encrypted

These activities rest on performance of the contract, on the publisher's legitimate interest in securing its service, and on its accounting obligations.

When an agent exchanges messages with someone on Telegram, the service records, on the customer's behalf:

• the contact's public Telegram identity: technical identifier, username, first name, last name, profile picture;
• the content of messages exchanged in both directions, the reactions posted, and the characteristics of any media sent;
• information the contact volunteers during the conversation, which the agent may retain to use later;
• their position in the sales journey defined by the customer, along with any scheduled follow-ups;
• where applicable, an approximate location (city, country and coordinates), inferred from available information and used for the customer's traffic statistics.

The publisher decides neither who is contacted, nor why, nor what is retained. Those choices belong to the customer, who must have a lawful basis, inform the people concerned and answer their requests.

To produce a reply, the service sends a language model provider what it needs: the agent's instructions, the documents the customer has provided, and the recent history of the conversation, message content included.

These calls pass through OpenRouter, which routes them to the provider of the selected model. Where the customer uses their own access key, the contractual relationship with the provider is theirs, and that provider's terms apply to their exchanges.

The customer chooses the model and, through that choice, the provider these contents are sent to. It is for them to check that the provider suits the sensitivity of the information their agents handle.

The service can produce voice messages. Recordings uploaded to create a voice, and the text to be spoken, are sent to fish.audio, a voice synthesis provider.

A voice is biometric data where it allows a person to be identified: the customer warrants that they hold the written consent of the person whose voice they have reproduced. The resulting audio files are not retained by the publisher beyond their delivery.

Data is neither sold, rented nor shared for advertising purposes. It is accessible to the following technical providers, each for its own part:

Vercel (United States)

hosting of the website and dashboard

HostMyServers (France)

application server

Supabase (Singapore)

database

Cloudflare (United States)

network, domain names, file storage, anti-bot protection of forms

OpenRouter (United States)

routing to language model providers

fish.audio

voice synthesis and cloning

Resend (United States)

sending the service's emails

Telegram

message delivery, by the very nature of the service

Databox

aggregated activity metrics, with no personal data

Several of these providers are established outside the European Union, notably in the United States and Singapore. Data may therefore be processed there.

Those transfers are covered by the safeguards provided for under European law, in particular the European Commission's standard contractual clauses, or any adequacy decision applicable to the provider concerned.

Customer account

for the life of the account, then erased on closure, subject to the statutory periods below

Sign-in sessions

deleted automatically seven days after they expire

Password reset links

deleted automatically one day after they expire or are used

Webhook log

deleted automatically after thirty days

Conversations and messages

kept for as long as the customer does not delete them and their account exists. No automatic erasure is applied: control over this period belongs to the customer

Accounting records

kept for the period required by the applicable accounting rules, including after the account is closed

Passwords are stored as irreversible hashes. Telegram sign-in sessions and provider access keys are encrypted. Traffic to the service is encrypted in transit, and access to data is partitioned by account.

An administrator of the publisher may access a customer's workspace for support and diagnosis. That access is restricted to authorised staff and leaves a server-side trace.

A password change, an account suspension or a deletion immediately ends every open session.

Every customer has the right of access, rectification, erasure, restriction, objection and portability over the data concerning them, as well as the right to give directions on what becomes of it after their death.

These rights are exercised at contact@botgram.app. A reply is given within one month. Proof of identity may be requested where there is serious doubt.

Anyone who believes their rights are not being respected may lodge a complaint with the data protection authority of their country of residence.

A person contacted by an agent should approach the business that contacted them, not the publisher: that business decided to make contact, holds the context, and answers for the processing.

Where that business cannot be identified, a request may be sent to contact@botgram.app: the publisher will pass it to the customer concerned and, on their instruction, carry out the erasure requested.

The site uses neither advertising cookies nor audience measurement. Details are set out in the cookie policy.

This policy may be updated to reflect changes to the service or to the law. The date of last update appears at the top of the page, and any substantial change is notified to customers.