(x)
Clause 7.2 notes that credit card information submitted through
payment gateways for premium services is not made available to
Telegram and the said data is not stored.
(xi)
Clause 9.3 notes that minimal data may be required for the
Telegram application to function in a secured manner.
(xii)
Clause 2 provides that the data collected is processed to further
Telegram’s legitimate interest, including for the provision of
effective and innovative services, detection, prevention of
fraudulent activities, and security related concerns.
(xiii)
As per clause 2 of the Privacy Policy, processing of personal data
is done unless the user’s overriding interest is to be protected or
the fundamental rights mandate protection of the personal data.
The relevant clause is as under:
“We process your personal data on the ground that
such processing is necessary to further our
legitimate interests (including: (1) providing
effective and innovative Services to our users; and
(2) to detect, prevent or otherwise address fraud or
security issues in respect of our provision of
Services), unless those interests are overridden by
your interest or fundamental rights and freedoms
that require protections of personal data.”
(xiv)
A section of the Privacy Policy deals with the rights of the user
in respect of personal data under Clause 9.1. If a user wishes to
seek deletion or a copy of the data, amendment of the data, object
to the processing of the data and correct any data or lodge a
complaint with the National Data Protection Authority, a specific
link has been provided for contacting Telegram.
Signature Not Verified
Digitally Signed
By:DEVANSHU JOSHI
Signing Date:31.08.2022
12:12:31
CS (COMM) 282/2020
Page 17 of 51
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