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1. Parties and purpose
This Data Processing Addendum (“DPA”) forms part of the Terms of Service between the Customer and TelePong LLC (“TelePong”). It applies whenever TelePong processes personal data on behalf of the Customer in providing the Service, and is intended to satisfy Article 28 of the EU General Data Protection Regulation (GDPR) and the UK GDPR, and equivalent requirements elsewhere.
For that processing the Customer is the controller (or, where the Customer itself acts for a creator, a processor acting on the creator’s instructions) and TelePong is the processor. For data about the Customer’s own users and billing, TelePong is an independent controller as described in the Privacy Policy; that processing is not covered by this DPA.
By accepting the Terms of Service the Customer accepts this DPA. A countersigned copy is available on request.
2. Details of the processing
| Item | Description |
|---|---|
| Subject matter | Operation of a CRM for the Customer’s Telegram and OnlyFans accounts: receiving, storing, displaying and sending messages and media; storing content; recording payments; team workflow; analytics; automated features chosen by the Customer. |
| Duration | The term of the Customer’s use of the Service plus the deletion periods in section 10. |
| Nature | Collection from the Platforms, storage, organisation, retrieval, display, transmission, translation, transcription, analysis, masking, deletion. |
| Purpose | Providing the Service to the Customer as described in the Terms of Service and the documentation; no other purpose. |
| Data subjects | Fans and subscribers who communicate with or purchase from the Customer’s accounts; creators whose accounts are connected; the Customer’s team members; persons who appear in Customer Content; recipients of links and campaigns. |
| Categories of data | Identifiers and profile data from the Platforms (names, usernames, IDs, photos, language, bio); message content and media, including voice and video; payment and purchase records; notes, tags and lists; contact details shared in chat; approximate location and device data from link clicks; voice samples and voice models; team activity and working-time records. |
| Special categories | Message content and media may reveal data about sex life or sexual orientation, health or other special categories. The Customer is responsible for having a lawful basis (for example explicit consent) for processing it; TelePong applies the security measures in section 7 to all content without distinguishing categories. |
3. Instructions
TelePong processes personal data only on the Customer’s documented instructions, which consist of the Terms of Service, this DPA, the settings and actions the Customer and its team members take in the Service, and any further written instructions agreed between the parties — unless the law requires other processing, in which case TelePong informs the Customer before processing (where the law allows). TelePong tells the Customer if it considers an instruction to infringe data-protection law.
The Customer is responsible for the lawfulness of the data it brings into the Service, for giving data subjects the required notices, for honouring their rights, and for ensuring that its use of the Service complies with the Platforms’ rules.
4. Confidentiality
TelePong ensures that persons authorised to process personal data are bound by confidentiality obligations and have access only to the data needed for their tasks. Staff access to Customer data is limited, logged and used only for support, security and incident response.
5. Sub-processors
The Customer gives general authorisation for TelePong to engage the sub-processors below. TelePong imposes data-protection obligations on each of them that are no less protective than this DPA and remains responsible for their performance.
| Sub-processor | Purpose | Location |
|---|---|---|
| Hetzner Online GmbH | Hosting of servers and databases | Germany / Finland (EU) |
| Cloudflare, Inc. | Object storage for media (R2), content delivery, DDoS protection, bot check at sign-in | EU and global edge; USA |
| DeepL SE | Machine translation (when selected or as fallback) | Germany (EU) |
| Anthropic, PBC | Machine translation and language detection (when selected or as fallback) | USA |
| PostHog, Inc. | Product analytics for the application, only after consent | EU cloud |
| Google Ireland Ltd. | Google Analytics 4 for the application, only after consent | EU / USA |
| GIPHY, Inc. | GIF search (search terms only) | USA |
| Telegram and OnlyFans | Not sub-processors: the Customer’s own Platform accounts, which the Service accesses on the Customer’s instructions | — |
| Proxy providers chosen by the Customer | Not sub-processors: engaged and controlled by the Customer | — |
TelePong announces new or replaced sub-processors at least 14 days before they start processing Customer data, in the application or by message to the workspace owner. The Customer may object on reasonable data-protection grounds within that period; if the parties cannot agree on a solution, the Customer may terminate the affected part of the Service and receive a pro-rata credit for the unused term.
6. International transfers
TelePong processes and stores Customer data primarily in the European Union. Where a sub-processor processes data outside the EEA or the UK, TelePong relies on an adequacy decision, the European Commission’s Standard Contractual Clauses (and the UK Addendum where applicable) or another lawful mechanism, with supplementary measures where needed. The Standard Contractual Clauses (module two, controller to processor) are incorporated into this DPA by reference for transfers from the Customer to TelePong where TelePong processes data outside an adequate jurisdiction.
7. Security measures
TelePong implements appropriate technical and organisational measures, including:
- encryption in transit (TLS) for all connections between users, the application, the servers and the Platforms;
- authentication through Telegram Login with an anti-bot challenge, optional passkeys (WebAuthn), short-lived signed requests and device binding;
- role-based access control inside workspaces; masking of Fan contact details from selected roles; per-viewer watermarks and screenshot-attempt signals on protected media;
- isolation of Platform sessions per account; proxies configured per account; removal of location metadata from uploaded images;
- strict Content-Security-Policy and other browser hardening; monitoring and alerting; audit logs of security-relevant actions;
- encrypted backups stored separately from production and rotated on a schedule; tested restore procedures;
- least-privilege, logged staff access; secure development practices and dependency updates.
TelePong may update these measures provided the overall level of protection does not decrease.
8. Personal data breaches
TelePong notifies the Customer without undue delay, and in any event within 48 hours, after becoming aware of a personal data breach affecting Customer data. The notice describes the nature of the breach, the categories and approximate number of data subjects and records concerned, the likely consequences, the measures taken or proposed, and a contact point, and is updated as more information becomes available. TelePong assists the Customer with its own notification obligations. Notification is not an admission of fault.
9. Assistance and data-subject requests
Taking into account the nature of the processing, TelePong assists the Customer with appropriate technical and organisational measures to respond to data-subject requests (the Service provides search, export and deletion tools for that purpose), and with the Customer’s obligations regarding security, breach notification, data-protection impact assessments and prior consultation. If a data subject contacts TelePong directly about Customer data, TelePong forwards the request to the Customer without undue delay and does not respond on the merits unless the law requires it or the Customer instructs it to.
TelePong makes available the information necessary to demonstrate compliance with this DPA and allows for and contributes to audits, including inspections, conducted by the Customer or an auditor mandated by the Customer — at most once a year unless required by a supervisory authority or following a breach, on at least 30 days’ written notice, during business hours, under confidentiality, and at the Customer’s expense. Where a current third-party audit report or certification covers the scope, TelePong may provide it instead.
10. Deletion and return
During the term the Customer can export and delete Customer data through the Service. On termination or deletion of the workspace, TelePong deletes the Customer data from live systems after the grace period described in the Privacy Policy (currently 3 days for a workspace, 30 days for a user account), and from backups when the backups containing it expire. TelePong may retain data where the law requires it, for as long as it requires it, with access restricted.
11. Liability and precedence
The limitations of liability in the Terms of Service apply to this DPA, except where data-protection law does not allow them. Where this DPA conflicts with the Terms of Service on the processing of personal data, this DPA prevails; where it conflicts with the Standard Contractual Clauses, the Clauses prevail.
12. Contact
Data-protection matters, sub-processor objections and audit requests: [email protected].