In short
- Version for Russia. Operator: sole proprietor Alexander Aleshin
- We process your sign-in phone, payment and support data to provide the service
- We use our clients' users' numbers only for verification and anonymise the number after 90 days
- We do not sell data or use it for advertising
- You can access, correct or delete your data — write to privacy@telvera.io
This is a translation for convenience. The Russian text prevails.
1.General provisions
This policy explains what personal data the Telvera service processes, why, for how long, and what rights you have. It has been prepared in accordance with Federal Law No. 152-FZ of 27.07.2006 “On Personal Data” (Law No. 152-FZ) and is published under Article 18.1(2) of that law.
This version applies to clients and users from the Russian Federation. Other countries are covered by a separate version.
The policy applies to the telvera.io website, the app.telvera.io dashboard and the Telvera API. It is publicly available; reading it is your right, not a condition of using the service.
2.Who processes whose data
Telvera handles two kinds of data, and the service's role differs for each.
Our clients' data — we are the operator
These are the companies, sole proprietors and developers who sign up in the dashboard: sign-in phone, payer details for invoices, payments, support requests. We are responsible for this data.
Our clients' users' numbers — we process them on instructions
When a client verifies their user's phone through the API, they pass the number to us. We process it only on the client's instructions (Article 6(3) of Law No. 152-FZ) and only to confirm the number. The client is the operator of this data: they inform the user about the verification and obtain consent where required. The terms of the instructions are set out in the Terms of Service.
3.Purposes, data, grounds and periods
Each purpose is listed separately below. We do not process more data than the purpose requires and do not use it for anything else. We do not process special or biometric categories of personal data.
- Whose data
- Telvera clients
- What data
- Phone number, number to call, time and result of the sign-in, IP address
- Ground
- Performance of the contract with the client (Article 6(1)(5) of Law No. 152-FZ)
- Retention
- While the account exists and 1 year after it is deleted
- Whose data
- Clients' users (on the client's instructions)
- What data
- User's phone number, number to call, call time, verification result
- Ground
- Instructions of the client as operator under the contract (Article 6(3) of Law No. 152-FZ)
- Retention
- 90 days, then the number is anonymised and remains in the client's reports only in masked form (+7 999 9••-••-90)
- Whose data
- Telvera clients
- What data
- Payer details (name, INN, KPP, address — if you provided them), last 4 digits of the card, payment history, receipts and invoices
- Ground
- Performance of the contract; obligations under the Tax Code, Law No. 402-FZ “On Accounting” and Law No. 54-FZ on cash registers (Article 6(1)(2), (5) of Law No. 152-FZ)
- Retention
- 5 years after the end of the year of payment (Article 29 of Law No. 402-FZ)
- Whose data
- Telvera clients
- What data
- Text of requests, correspondence, contact details for the reply
- Ground
- Performance of the contract with the client
- Retention
- 3 years after the request is closed
- Whose data
- Telvera clients and website visitors
- What data
- IP address, browser data, sign-in and API request logs
- Ground
- Legitimate interest of the operator and performance of the contract (Article 6(1)(5), (7) of Law No. 152-FZ)
- Retention
- Request log — 30 days, sign-in log — 6 months
4.How we process data
Processing is automated: collection, recording, systematisation, accumulation, storage, clarification, retrieval, use, transfer (provision, access), anonymisation, blocking, deletion and destruction. We do not take decisions with legal effects based solely on automated processing: the verification status is the technical result of a call, and the decision about the user is taken by the client.
When the retention period ends or the purpose is achieved, data is destroyed or anonymised within 30 days unless the law requires longer storage.
6.Localisation and cross-border transfer
Recording, systematisation, accumulation, storage, clarification and retrieval of personal data of Russian citizens are carried out using databases located in the Russian Federation (Article 18(5) of Law No. 152-FZ): confirm the database is hosted in Russia.
Cross-border transfer is not carried out / is carried out to: …, Roskomnadzor notification of ….
7.How we protect data
- All connections to the website, dashboard and API are HTTPS only
- Only those who need it for their work have access to data, and access is logged
- Clients' users' numbers are shown masked in the dashboard
- API keys are stored only as a hash; the full key is shown once, when it is created
- We notify Roskomnadzor of personal data incidents within 24 hours and of the investigation results within 72 hours (Article 21(3.1) of Law No. 152-FZ)
8.Your rights and how to exercise them
Under Law No. 152-FZ you have the right to:
- Obtain information about the processing of your data: what data, why, on what grounds, who it is shared with and how long it is kept (Article 14) — we reply within 10 business days, free of charge
- Demand that data be clarified, blocked or destroyed if it is incomplete, outdated, inaccurate, unlawfully obtained or not needed for the purpose
- Withdraw consent where processing was based on it
- Appeal our actions to Roskomnadzor (rkn.gov.ru) or to court
How to submit a request
Send the request in writing to the operator's address or as an electronic document to privacy@telvera.io. Include your identity document number, its date and issuing authority, details of your relationship with Telvera (for example, your account phone number) and your signature, as required by Article 14(3) of Law No. 152-FZ.
10.Changes to this policy
If we materially change the policy (purposes, periods, the data processed or how rights are exercised), we notify you in advance in the dashboard. The current version is always available on this page.
Questions?
Write to privacy@telvera.io about personal data or to hello@telvera.io about anything else. We reply within 5 business days.