This Policy supplements the Personal Data Processing Policy and describes customer support provided through the shared Telegram bot, as well as restricted internal functions and notifications related to the website mos-radius.ru.
Controller: Individual Entrepreneur Evgeny Andreevich Kolmakov, Taxpayer Identification Number (INN) 702401389066, Primary State Registration Number of an Individual Entrepreneur (OGRNIP) 318703100089801.
Data controller’s address: Apt. 3, 33 Kalinina Street, Seversk, Tomsk Region.
Person responsible for organising the processing of personal data: Evgeny Andreevich Kolmakov, mos.radius@gmail.com, +7 925 291-30-69.
1. Purpose and access
The shared Telegram bot is used to receive and process customer enquiries, forward them to the duty manager and respond to customers on behalf of Radius Tour Bureau. No additional registration on the website is required: the conversation is linked to the Telegram account from which the user contacted the bot.
The bot’s restricted internal functions are used to prepare website materials, receive notifications and perform operational tasks relating to bookings. Access to these functions and to customer correspondence is granted only to the operator and authorised employees or contractors, according to their roles. Each new enquiry is forwarded to the current duty manager.
2. Data processed
When a user interacts with the bot, Telegram transmits the user and chat identifiers, the user’s name and username where available, the content of messages and commands, photographs, documents, voice, audio and video messages, contacts, geolocation and any other materials submitted, as well as the date and time of the interaction.
The Russian information system retains a copy of the correspondence, the direction of each message, identifiers of related messages, the server time, details of the assigned manager and the manager who responded, the delivery status and the response time. These data are used to continue the conversation, monitor delivery and support quality, investigate errors and protect the rights of the parties.
Depending on the internal workflow, the bot may receive an internal booking number, tour name, date and time, number of participants, pick-up and drop-off addresses, internal comments, the customer's name, information about the amount and payment status, and operational details about the guide, driver and vehicle from a Russian information system. Each message must contain only the information necessary for the relevant action.
Users should not send bank card details, passwords, identity documents, special categories of personal data, criminal conviction data or any other data that are not required to respond to an enquiry or fulfil a booking through the bot.
3. Purposes and legal grounds
Data are processed to receive and respond to enquiries, arrange and fulfil bookings, appoint contractors, monitor payments and service quality, prepare and publish materials, manage internal access, ensure security and investigate errors. The legal bases are the conclusion and performance of a contract with the data subject, compliance with the operator’s legal obligations, consent where required and the legitimate interest in organising support and protecting the workflow while respecting the rights of data subjects.
4. Telegram and cross-border transfers
Telegram is a foreign service. To deliver and store messages, the service and its associated parties receive the information transmitted to the bot in accordance with the Telegram Privacy Policy And Terms for Bot Developers. Telegram states that cloud messages are stored on its servers and that its infrastructure may be located in multiple jurisdictions.
A message sent by a user directly in Telegram is first transmitted through Telegram’s infrastructure, after which a copy is stored in the Russian support database. Data collected directly on the website from citizens of the Russian Federation are initially recorded, and primarily stored locally, in a database located within the Russian Federation. Personal data may be transferred to Telegram only where there is a legal basis and after completion of the mandatory procedure for notifying Roskomnadzor of a cross-border transfer. The current process does not use booking synchronisation with Google Calendar.
5. Storage and protection
Local correspondence records and a separate audit log are stored on the server without automatic deletion or rotation. The specific retention period is determined by the purpose of the enquiry, performance of the contract, mandatory record-keeping requirements, applicable limitation periods and the need to protect the rights of the parties. Once the applicable legal basis ceases to apply, the records must be deleted or anonymised by an authorised administrator. The retention period for copies of messages within Telegram’s infrastructure is determined by Telegram’s settings and rules.
A manager receives only the enquiry assigned to them in a private chat with the shared bot and responds using the Reply function. Access to the internal section is restricted to linked Telegram and WordPress accounts; role verification, a secure connection, activity logging and revocation of access when authorisation ends are used.
6. Rights and requests
To request information, rectification, restriction or deletion of data, withdraw consent or report an erroneous submission, please send a request to mos.radius@gmail.com with the subject line ‘Personal Data in the Telegram Bot’. Please provide information that allows the record and the applicant to be identified. Where processing is necessary for the performance of a contract or compliance with a legal obligation, withdrawal of consent does not in itself terminate such processing.
Version dated 13 September 2026.