This Policy supplements the Personal Data Processing Policy and describes the private internal Telegram bots and notifications associated with 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 bots are used to prepare website content, receive private internal notifications and perform work-related actions on bookings. Access is permitted only to the operator and employees and contractors authorised by the operator. The bot is not intended to accept bookings from the general public.
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 text of messages and commands, button responses, photographs, documents and other submitted materials, as well as the date and time of the interaction.
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.
Bank card details, passwords, special categories of personal data, criminal record information and any other data not required for the work-related action should not be sent via the bot.
3. Purposes and legal grounds
Data is processed to manage access, prepare and publish content, arrange the fulfilment of bookings, assign service providers, monitor payments, handle internal requests, ensure security and investigate errors. The legal grounds are the performance of a contract with the data subject, compliance with the operator's legal obligations, consent where required, and the legitimate interest in organising and protecting a private internal 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.
The initial recording and primary storage of data collected on the website from citizens of the Russian Federation take place in a database located within the Russian Federation. Transfer to Telegram is permitted only where there is a legal basis and after completing 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 records are retained for the periods necessary for the relevant operational purpose, performance of the contract, mandatory record-keeping and protection of the parties' rights. The retention period for copies of messages within Telegram's infrastructure is determined by Telegram's settings and rules. Access to the bot is restricted to a list of authorised users; authorisation checks, a secure connection, logging of significant actions and revocation of access when work-related authority 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.
Revised on 4 September 2026.