Privacy policy

Last updated 11 September 2026

This policy explains how Average Joe Technology OÜ(“we”, “us”) processes personal data when you use BottBuddy. BottBuddy is a product of Average Joe Technology. Creating an organisation also enters the processor terms in section 12.

1. Who we are

Average Joe Technology OÜ, registry code 17309776, VAT EE102895812, Narva mnt 5, 10117 Tallinn, Harju County, Estonia. Email: [email protected].

2. Scope

This policy covers the marketing site on this host, the admin application on app.*, tracked-link redirects on links.*, Telegram webhooks on webhooks.*, and the BottBuddy service behind them.

Telegram is a separate platform. Telegram’s own privacy policy applies to data you send through Telegram’s apps and servers.

3. Roles

• Organisation (controller) for Contact data. The organisation that connects a bot decides why Contacts are messaged, which Flows and Campaigns run, and how long to keep inbox history. A Contact is a Telegram end-user subscribed to that bot — not an OrgMember.
• We (processor) for Contact data. We store and process Contact data only on the organisation’s documented instructions (this policy, the Terms, and the product itself).
• We (controller) for account and site data. We decide how to process OrgMember accounts, billing records, security logs, and any message you send us at [email protected].

4. Data we process

Contact data (processor)

Telegram identifiers, display name and username if Telegram sends them, conversation content, Flow session state, tags, custom field values, campaign recipient rows, and engagement events (for example delivered or clicked). BottBuddy cannot tell whether a Contact read a message. There is no “viewed” metric.

OrgMember and billing data (controller)

Name of the organisation, member email, password hash, role, session cookies on app.*, optional TOTP secrets, IP addresses on security events, and messages you send us on the contact form (name, email, organisation name, message). A copy of those contact-form messages is posted to the operator’s private chat channel. Creating an organisation stores a pending signup (email, org name and slug, password hash, and a hashed verification token) until you confirm the mailbox; we then send a one-time link by transactional email. Bot tokens are envelope-encrypted at rest and are not written to logs or queue names.

Marketing site (controller)

This host sets no first-party cookies and keeps no session. We do not run third-party analytics on these pages. An informational cookie notice may write one localStorage key so we do not show it again. The web server may record standard request logs (IP, user agent, path) for security and operations, then drop them on a short rotation.

5. Lawful bases

• Contract — to create your organisation, run the service, and take payment.
• Legitimate interests — to keep the service secure, prevent abuse, and operate transactional bot replies after a Contact messages the bot.
• Consent — marketing broadcasts to Contacts who chose to talk to the bot (the organisation must honour /stop and Telegram rules). You may also consent when you write to us.
• Legal obligation — tax and accounting records, including VAT EE102895812.

6. How we use data

To run Flows, Campaigns, the support inbox, analytics that stop at “delivered”, exports, GDPR erasure, billing, and abuse prevention. We do not sell personal data. We do not use Contact content to train a public AI model.

7. Subprocessors and Telegram

We use these processors (or separate controllers, where named) to run BottBuddy:

• Telegram — Bot API and message delivery. Telegram is an independent platform. See telegram.org/privacy.
• Hetzner Online GmbH — EU hosting for the Kubernetes cluster and databases.
• Cloudflare, Inc. — DNS and edge proxy in front of public hosts. Cloudflare may set a security cookie when those protections are on.
• Transactional SMTP. Registration verification email is sent through generic SMTP we configure (Vault). We will name the provider here when that path is live. Email is not sent through Telegram or our bot send queues.

Export files and database backups stay on EU-hosted object storage we operate or on an EU-region S3-compatible bucket we configure. We will update this list when a processor changes.

8. Location and transfers

We host BottBuddy in the EU. Telegram may process data outside the EU under its own terms and, where required, Standard Contractual Clauses or an adequacy decision.

9. Retention

• Organisation and member accounts: until the owner deletes the organisation or the member.
• Raw analytics events: 18 months (then aggregates may remain without Contact identifiers).
• Closed conversations and messages: 24 months, unless the organisation deletes them sooner.
• Audit logs: 36 months.
• Export files: 24 hours after the job finishes.
• Database backups: 30 days. Erasure from the live database is immediate; backups age out.
• Invoices and tax records: as Estonian bookkeeping law requires.

10. Your rights

Under the GDPR you may request access, rectification, erasure, restriction, portability, or object to processing, and you may withdraw consent where we rely on it.

Contacts should ask the organisation that runs the bot first. Owners and admins can export or erase a Contact in the admin product. If the organisation is gone or does not respond, write to [email protected] and we will help as the processor.

OrgMembers may write to [email protected] or use in-app account tools. You may complain to the Estonian Data Protection Inspectorate (AKI).

11. Cookies

The marketing site sets no first-party cookies. The admin host sets a session cookie (necessary, SameSite Strict) so you stay signed in. Tracked links on links.* record a click event and redirect; they are not an advertising cookie wall. Google Search Console verification does not set cookies on visitors. The full inventory is on /cookies.

12. Data processing terms (Art. 28)

This section is the data processing agreement between the organisation (controller) and Average Joe Technology OÜ (processor) for Contact data. Creating an organisation accepts it.

• Subject. Hosting and processing Contact and conversation data so the organisation can run Flows, Campaigns, inbox, analytics, and exports.
• Duration. For as long as the organisation uses BottBuddy, then until deletion or the retention windows above.
• Nature and purpose. Storage, transmission to Telegram on the organisation’s instruction, segmentation, broadcast fan-out, human inbox, and erasure.
• Types of data. Section 4, Contact data.
• Data subjects. Contacts (Telegram end-users of the organisation’s bots).
• Instructions. We process only as the product and these terms provide, or as EU/Estonian law requires. The organisation is responsible for a lawful basis toward Contacts and for Telegram’s rules.
• Confidentiality and security. Encrypted transport, encrypted bot tokens, org-scoped access with RLS, audit logs. We do not use Contact data for our own marketing.
• Subprocessors. Section 7. Further subprocessors that process Contact data will be added here. You may object by deleting the organisation if you do not accept a change.
• Assistance. In-app export and erasure; we will help with DPIAs and authority requests where reasonable.
• Breach. We will notify the organisation without undue delay after becoming aware of a personal-data breach affecting its Contacts.
• Deletion. Contact erasure hard-deletes the Contact and related messages, nulls identifiers on aggregate rows, and leaves backups to expire in 30 days.
• Audits. On written request we will provide security documentation reasonably sufficient for Art. 28. We are not obliged to grant live production access that would risk other tenants.

13. Children

BottBuddy is not directed at children under 16. Do not create an organisation if you are under 16. If we learn we hold an account for a child under 16, we will delete it.

14. Changes

We will post updates on this URL and change the date above. Material changes to processor terms will also be noted in the admin product when we can.

15. Contact

Average Joe Technology OÜ, Narva mnt 5, 10117 Tallinn, Harju County, Estonia. [email protected].