Velinoya Privacy Policy for Telegram
Status: Approved by the Operator on 5 October 2026
Version:
privacy-p0-2026-10-05-invitationEffective date: 5 October 2026
This Policy describes data processing by the Velinoya Telegram bot and Telegram Mini App (the “Service”).
Operator: Savelenko Vasilii (Савеленко Василий Викторович), an individual based in Russia. Correspondence address: 22 Kerey Zhanibek khandar Street, Office 315, Yesil District, Astana, Republic of Kazakhstan. This address does not identify the processing location. The Operator also serves as Data Protection Officer (DPO); data-protection contact: privacy@velinoya.com.
1. Independence from Telegram
Velinoya is an independent service, unaffiliated with and not endorsed by Telegram. Telegram independently processes platform data under its Privacy Policy. This Policy concerns data obtained and processed by the Operator.
2. Sources of data
We receive data from Telegram when you use the bot and Mini App, directly from your messages and actions, when you access the server, from Telegram Stars transactions, and through palm processing and pairing. Do not send passwords, login codes, bank-card details or information unnecessary for your inquiry.
3. Data we process
3.1. Profile and authentication
To verify a login, the Mini App sends Telegram-signed initData to the server. Depending on the launch, this may include your identifier, name, username, language, avatar URL, Telegram Premium status, permission to message you, launch parameters and context, and authentication date. The Service verifies the signature and permitted authentication age.
We persist the Telegram user ID, public first and last name, username, language, avatar URL and local avatar copy, and bounded Mini App platform and version values. Your chosen nickname, language, time zone and onboarding state are stored separately. Telegram Premium status, messaging permission, launch context, separate authentication date and arbitrary launch fields are not retained in the profile. The raw initData string is not intended for storage in the database or ordinary logs.
3.2. Photos and messages
When you send your own palm in a private chat with the bot, we receive the message and technical identifiers, Telegram file ID, image, its type, size and dimensions, and your selected flow. The bot transfers the photo to the server; temporary photo bytes in the bot stay in memory. The original photo and derived files are stored to process and redisplay the result in your history. The current version does not permit another person's palm.
Ordinary accepted bot-update content is retained for no longer than 24 hours for processing and retries. Payment records follow a separate period. Group, channel and unsupported updates are not stored in the bot database for Service operation.
3.3. Results and pairs
We store processing tasks and status, palm features, automatically generated interpretations, results and history, forecasts, invitation links and tokens, pair participants, shared compatibility results and visibility settings. Internal balances and referral relationships are also stored when those features are used. Results are entertainment content, not established facts about health, feelings or personality.
3.4. Telegram Stars
For Velinoya Premium, we process the offer and invoice, price in XTR, subscription period, payer identifier, payment identifiers and events, transaction date, status, paid period, renewal, cancellation and refund. We retain the Terms and Policy versions, language and time of the user's confirmation. We do not receive the bank-card number or details of the method used to buy Stars themselves.
3.5. Support and technical information
We process inquiries through /support, /paysupport, support@velinoya.com and privacy@velinoya.com, sender addresses, content, attachments and replies. Servers receive IP addresses, browser information, request times, errors and technical identifiers. Operational logs may contain masked user identifiers, task, request and pair identifiers, and image sizes. Photos, passwords, tokens, raw initData, Telegram file URLs and secret payment identifiers are not intended for ordinary logs.
First-party product analytics is enabled for testing. It measures entry, result views, invitations, created pairs and return visits. Advertising SDKs and cookies for advertising profiling are not used. Fields, purposes, retention, export and deletion of analytics records are described in the analytics notice below. Necessary Mini App local state continues to support sessions, preferences and tracking a deletion request.
See the analytics notice for details of enabled first-party product analytics.
4. Purposes
A pretrained machine learning model is used to analyse the photo. The model is not trained on your photos.
We use data to authenticate you and connect the bot with the Mini App, process your palm, store and display history, provide requested compatibility results and forecasts, deliver paid access, verify payments, cancellations and refunds, provide support, fulfil data requests, prevent duplicate operations and abuse, maintain security and meet applicable legal obligations.
We do not sell Telegram data, collect group or channel content for datasets, or use palms, results or other user data to train or evaluate models. Training is outside current processing. Product analytics is described in section 3.5 and the separate notice. Changes of purpose require prior updated notice and separate permission where required; this Policy does not automatically authorise future processing.
5. Grounds and your choices
For processing subject to Singapore's Personal Data Protection Act 2012 (PDPA), we obtain consent or use a specific statutory exception when its conditions are met. Accepting the Terms or reading this Policy is not blanket consent to every processing purpose.
Before the first analysis and after an update to the relevant notice version, the bot requests explicit consent to process photos of your own palm that you voluntarily submit using a pretrained machine learning model and to retain photos and results for history. You confirm using the button below the notice or /accept after the notice is shown. Merely opening the bot, reading this Policy or sending a photo without this confirmation does not start analysis. This consent covers only the stated feature in your private chat with the bot and does not authorise model training or optional analytics.
To withdraw consent, contact privacy@velinoya.com. After reasonable notice, we stop the affected collection, use and disclosure unless otherwise permitted or required by law, and explain the consequences for the relevant feature. Refusing an optional purpose does not remove access to unrelated features.
Opening a new personal invitation link records its author, the actual opener's account, time and internal tokens, and creates mutual participation in compatibility. Once both models are ready, both users can see the shared result, display name, available avatar and Velinoya Premium status. Photos and personal analyses are not disclosed. We do not separately notify the author about the opening. Older ordinary invitations do not create a reverse selection. Earlier private results retain their visibility until a reverse selection or opening a new personal link. Account deletion removes related selections and the shared result.
6. Recipients
| Recipient | Role and data |
|---|---|
| Telegram | Independent platform for messaging, launching the Mini App and Telegram Stars; its own privacy policy also governs its processing |
| DigitalOcean | Application servers and storage, processing queues, logs and encrypted backups; the Service's primary deployment is Singapore (SGP1) |
| Proton Mail (Proton AG, Switzerland) | Support and privacy email: addresses, message content, attachments and delivery data; servers in Switzerland, Germany or Norway |
| Other pair participant | Displayed name, available avatar, Velinoya Premium status, participation information, shared compatibility result and pair forecast |
| Authorities and other lawful recipients | Only information whose disclosure is necessary on an applicable legal basis |
Palm processing runs in the Operator's own containers on DigitalOcean; photos are not sent to an external analysis service. Firebase and RevenueCat are not used for Telegram data in this version. Email processing is described in the Proton Mail Privacy Policy; ordinary email between different providers is not necessarily end-to-end encrypted.
Compatibility and access to its result are described in section 6 of the general Terms. There is no separate confirmation for each person selected. We cannot recall screenshots or messages independently saved by another person.
7. Retention
The periods below are Service commitments, not a statement that the PDPA sets an identical period for each category.
| Category | Period or deletion event |
|---|---|
| Photos, derived files, results, history and profile | While needed for your available history and account operation; after an accepted, confirmed deletion request, removed from active storage within 24 hours; hiding a result does not delete data |
| Shared pair and compatibility | While needed for the feature; deleting either participant's account removes the shared pair and result for both |
| Queues and ordinary raw bot updates | No longer than 24 hours; active copies covered by an accepted deletion request are removed within 24 hours |
| Bot state and document acceptance records | Until account deletion; versions attached to a payment follow the payment-ledger period |
| Minimal payment ledger | 5 years from the transaction date; if missing or invalid, from transfer into the retained ledger; longer only for an active dispute or applicable legal obligation |
| Support and privacy correspondence | Until account deletion or 12 months after the inquiry is closed, whichever comes first; necessary minimum records for an active dispute or legal obligation may be retained longer |
| Ordinary operational logs | No longer than 30 days; necessary information for an active incident or legal obligation is kept separately |
| Application backups | Rotation removes data eligible for deletion no later than 30 calendar days after acceptance of the confirmed request |
| Proton email backups | The provider keeps encrypted offline backups for up to 30 days; after an active message is deleted, a backup copy may remain until that period expires |
| Deletion execution ledger | Separate encrypted identifiers, technical markers and execution information needed for retries, evidence of deletion and preventing data from returning; while that need continues |
Keeping a profile and history does not permit indefinite retention merely because an account has not been deleted. We review necessity, including for inactive accounts, and stop retention when its purpose and legal or business need have ended. The current version does not automatically delete accounts after a period of inactivity.
The payment ledger supports reconciliation of delivered access, refunds, prevention of duplicate payouts and handling claims. Five years is the selected retention policy, not a statement of a universal Singapore tax obligation. After account deletion, the ledger is minimised and linked to a pseudonymous technical key instead of an active profile. Neither these records nor the deletion ledger become anonymous merely because identifiers are replaced.
Exceptions are applied individually: only necessary data, on a specific basis and for the necessary period. We also delete data without undue delay following a lawful Telegram request, when the Service ends or when the processing need ends.
8. Photos in Telegram and hiding results
Automatic deletion of the palm message by the bot is disabled. You can delete the message or chat using Telegram. This does not delete Velinoya's server copy. Hiding a result or pair changes visibility only; the current version has no separate individual-result deletion action.
9. Access, correction and deletion
The authenticated Mini App profile provides data export and “Delete account and data”. You can export needed information before confirming deletion. Once a confirmed request is accepted, sessions are revoked immediately; deletion may initially appear as in progress. Success is shown after completion, and retries continue without a new login.
Deletion covers the profile and avatar, photos and derived files, history and forecasts, balances and referrals, pairs, bot data, tasks, notifications and queues. The shared pair and result disappear for both participants. Known recurring Stars renewals are cancelled before deletion completes. Minimum exceptions and periods are in section 7; the deletion ledger is not used to reactivate a profile.
For access, correction, deletion when the Mini App is unavailable, withdrawal or recipient information, email privacy@velinoya.com or use /support. We proportionately verify that the request concerns your account without asking for a Telegram password or login code. If your request covers messages from another email address, identify it so we can locate the correspondence; a matching display name alone does not establish identity.
For a PDPA request, you may also ask how your data was used or disclosed during the preceding 12 months. We respond as soon as reasonably possible, subject to lawful exceptions and other people's data. If access or correction cannot be completed within 30 calendar days, we notify you in writing within that period of the expected response date. Any permitted access fee and estimate are explained in advance. The application export does not replace this channel.
Withdrawal does not invalidate lawful past processing. Deleting a Telegram account, message or chat is not itself a request to delete a Velinoya account. You may contact Singapore's Personal Data Protection Commission (PDPC); mandatory rights under applicable law remain available.
10. Security
Transmission to the application uses HTTPS. Primary databases are on an encrypted DigitalOcean Volume; operational objects use encryption with a separate key. Database backups are encrypted and signed. Access is limited to what is needed for operation and support.
A deletion request is retained in a separate signed ledger with encrypted identifiers. During recovery from an older backup, the ledger must be verified and replayed before users are admitted; recovery without the current ledger is blocked. Encryption and other controls reduce risk but do not guarantee absolute security.
For a breach notifiable under the PDPA, we notify the PDPC as soon as practicable, no later than 3 calendar days after the day we determine that it is notifiable. Affected individuals are notified as soon as practicable when required, at the same time as or after the PDPC, subject to lawful exceptions. Incidents are assessed promptly; not every incident requires the same notification.
11. International processing
Primary application servers and storage are in DigitalOcean Singapore (SGP1). The Operator administers the Service and may access necessary data from Russia. Proton email is processed in Switzerland, Germany or Norway. Telegram and cloud providers' subprocessors may process data in other countries; Singapore hosting does not mean Singapore-only processing.
An overseas transfer to another organisation subject to the PDPA requires comparable protection through applicable legally enforceable commitments or another permitted mechanism. We consider onward recipients, security, assistance with requests and incidents, and deletion. The Operator's access from another country while retaining control does not remove the Operator's protection obligations.
12. Age and other people's photos
The Service is only for people aged 18 or older and their own palms. Photos of minors or other people are not permitted. If such data has been submitted, contact privacy@velinoya.com for review and deletion.
13. Changes
A new version is published with an effective date. We give advance notice of material changes when legally required or when they affect a previous choice. A new purpose requiring consent is not applied until that consent is obtained.
14. Contacts
Operator/DPO: Savelenko Vasilii (Савеленко Василий Викторович); correspondence address is at the beginning of this Policy. Data inquiries: privacy@velinoya.com. General support: /support or support@velinoya.com. Payments: /paysupport or support@velinoya.com. Mandatory applicable law takes precedence.