Privacy Policy
Application: Telegram Channels & Groups Hub
Platform: iOS (Apple App Store)
Developer: Stepa Mobile FZE LLC
Effective date: 24 November 2023
Last updated: 7 July 2026
This Privacy Policy (the “Policy”) describes how Stepa Mobile FZE LLC (“Stepa Mobile”, “we”, “us” or “our”) collects, uses, discloses and protects information in connection with your download, installation and use of our iOS application Telegram Channels & Groups Hub (the “App” or the “Service”). The App is a commercial application that helps you discover, browse and search a directory of publicly available Telegram channels and groups, and it may offer paid features, in-app purchases and subscriptions. We are committed to protecting your privacy and to being transparent about the data we and our partners process when you use the App. Please read this Policy carefully so that you understand our practices and the choices available to you.
1. Introduction and Acceptance
This Policy applies to all users of the App worldwide and forms part of, and should be read together with, our Terms of Use. By downloading, installing, accessing or using the App, you acknowledge that you have read and understood this Policy and you agree to the collection, use and disclosure of information as described here. If you do not agree with any part of this Policy, you should not download, install or use the App and should remove it from your device. Your continued use of the App following any update to this Policy will be deemed to constitute your acceptance of the revised terms.
2. Who We Are (Data Controller)
For the purposes of applicable data protection laws, the controller responsible for your personal data collected through the App is Stepa Mobile FZE LLC, a company established in the United Arab Emirates. Where the App integrates software from third parties (for example, providers of advertising, analytics, subscription management, crash reporting and platform services), those third parties may act as independent controllers or as our processors with respect to the data they handle, as described in this Policy and in their own privacy policies. Our contact details are provided at the end of this Policy in the “Contact Us” section.
3. Scope of This Policy
This Policy covers only the information collected in connection with the App. It does not apply to any third-party websites, platforms, stores, advertisements or services that may be linked to or accessible from within the App, nor to any information you provide directly to those third parties. In particular, it does not apply to the Telegram messaging service or to any channels, groups or accounts you open, join or interact with through Telegram. We do not control, and are not responsible for, the privacy practices of any third party. We encourage you to review the privacy policies of every third-party service you interact with, including Telegram and the Apple App Store, because those policies will govern how those parties handle your information.
4. Summary of Key Points
This summary is provided for convenience only and does not replace the full Policy. In short: the App is an independent directory that helps you find and open publicly available Telegram channels and groups, and it is not affiliated with, endorsed by or operated by Telegram. The App does not ask for your Telegram login, phone number or password, and it does not access the contents of your Telegram account, chats or contacts. We and our partners collect technical, usage, advertising and diagnostic data to operate, secure, monetise and improve the App. Purchases and subscriptions are processed by Apple, not by us. We do not sell your personal data for money, and you have privacy rights that you can exercise by contacting us. Please read the full Policy below for the complete details.
5. Relationship with Telegram (No Affiliation)
The App is an independent, third-party application developed by Stepa Mobile. It is not created, sponsored, endorsed by, affiliated with or otherwise connected to Telegram Messenger, Telegram FZ-LLC, Telegram Group Inc. or any of their affiliates. The names “Telegram”, the Telegram logo and related marks are the property of their respective owners and are used within the App for identification and descriptive purposes only. The App does not require you to sign in to Telegram, does not request your Telegram credentials, phone number, verification code or password, and does not read, store or transmit your Telegram messages, chats, contacts or account information. When you choose to open a channel or group, the App simply hands the relevant link over to the Telegram app or to your browser, after which your interaction is governed by Telegram’s own terms and privacy policy.
6. Information You Provide to Us
The App is designed to be used without creating an account, and it does not require you to submit your name, postal address or similar direct identifiers in order to function. The main circumstance in which you actively provide information to us is when you choose to contact us – for example, when you email our support address to request assistance, report a problem, report or suggest a channel or group, send feedback, or exercise a privacy right. In those cases we receive whatever information you decide to include, such as your email address and the content of your message. If the App offers a feature that lets you submit, suggest or report a channel or group for the directory, we receive the information you choose to send for that purpose, such as a link or username and any accompanying description. We use this information solely to respond to you, to review submissions and reports, and to maintain and improve the App and its directory.
7. Information Collected Automatically
When you use the App, certain information is collected automatically by us and by the third-party technologies integrated into the App. This information generally includes technical and device data such as the device model, operating system and version, system language and region settings, screen characteristics, network and connectivity information, and similar configuration details. It also includes usage data, such as the features you interact with, the categories, channels or groups you view or search for within the directory, session frequency and duration, in-app events, the settings you select, and how you interact with advertisements and purchase screens. This information helps us operate the App, understand how it is used, and improve its performance, relevance and stability.
8. Directory Content, Browsing and On-Device Data
The core function of the App is to help you discover and open publicly available Telegram channels and groups through a searchable, categorised directory. The listings shown in the App relate to publicly accessible resources and are provided for informational and discovery purposes. When you browse, search or select an item, that action is used to display the relevant listing and, if you choose, to hand the corresponding link to the Telegram app or your browser so you can open it there. Certain preferences you set inside the App – such as favourites, bookmarks, recent searches or a history of items you have viewed – may be stored locally on your device so that the App can remember them between sessions; where this data stays on your device, we do not collect or receive its contents. We do not access the contents of your Telegram account, and we do not join channels or groups on your behalf. You are responsible for reviewing any third-party channel or group before joining or interacting with it, and for complying with Telegram’s rules and applicable law when you do.
9. Device and Advertising Identifiers
The App and its partners may access certain identifiers associated with your device or installation, such as the Identifier for Vendor (IDFV) and, where permitted, the Identifier for Advertisers (IDFA), as well as other technical identifiers used for analytics, subscription management, fraud prevention and advertising. These identifiers are used to recognise your device across sessions, to measure the performance of the App and of advertising, and to limit how frequently you see the same advertisement. You can reset your advertising identifier and manage tracking through your device settings, as described in the next section.
10. App Tracking Transparency (ATT)
On Apple devices, before we or our partners access the IDFA or otherwise track you across apps and websites owned by other companies, the App will ask for your permission through Apple’s App Tracking Transparency framework. You may grant or deny this permission, and you can change your choice at any time in your device settings under privacy and tracking controls. If you deny tracking, you will still be able to use the App, and any advertising shown to you will be non-personalised or contextual rather than based on cross-app tracking.
11. Subscription and Purchase Information
Because the App is commercial, it offers paid features, which may include one-time in-app purchases and auto-renewable subscriptions. When you make a purchase, the transaction itself is processed by Apple through the App Store, and we do not receive or store your payment card details. We and our subscription-management partner receive information related to your purchases, such as your subscription and purchase status, purchase history, transaction and receipt identifiers, whether a free trial has been used, and renewal or cancellation events. We use this information to provide the paid features, to manage your subscription, to prevent fraud, and to understand and improve our paid offerings.
12. Refunds and Consumption Information
If you request a refund for an in-app purchase, Apple may ask for information that helps it evaluate the request, and we reserve the right to provide Apple with certain “consumption” data relating to that purchase. This data may include: the time elapsed since you installed the App; your total usage time of the App; an anonymous account identifier; whether the in-app purchase being refunded was fully consumed; whether the in-app purchase included a trial period; the total amount you have spent on in-app purchases; and the total amount previously refunded. This information is shared with Apple solely to help assess refund requests and to prevent fraud and abuse, and it does not identify you by name.
13. Log Data and Diagnostic Information
Whenever you use the App, and in particular if the App encounters an error or crash, technical log data may be collected automatically through third-party tools. This diagnostic data may include information such as your device’s Internet Protocol (IP) address, the device state and configuration of the App at the time of the event, the operating system version, the date and time of the event, and other technical statistics. We use log and diagnostic data to detect, investigate and fix technical problems, to improve the stability and reliability of the App, and to protect against fraud, abuse and security incidents.
14. Approximate Location Information
The App does not collect precise GPS location. However, an approximate, coarse location – such as your country or region – may be inferred from your IP address or similar network information by us and by our advertising and analytics partners. This general location information is used for purposes such as delivering region-appropriate content and advertising, understanding the geographic distribution of our users in aggregate, complying with regional legal requirements, and preventing fraud. We do not use this information to track your specific movements or to identify the exact place where you are located.
15. Push Notifications
The App may use messaging technology to send you push notifications, for example about new or featured channels and groups, new features, offers or updates. Where required, you will be asked to allow notifications, and you can enable or disable them at any time through your device settings. If you turn notifications off, you will still be able to use the App, but you may not receive certain reminders or announcements delivered through this channel.
16. How We Use Information
We use the information described in this Policy to provide, maintain and operate the App and its directory, browsing and search features; to provide, manage and renew paid features, in-app purchases and subscriptions; to process and evaluate refund requests; to review submissions and reports about channels and groups; to display advertising, including, where permitted, personalised advertising; to measure and analyse how the App is used so that we can improve existing features and develop new ones; to detect, prevent and address technical issues, crashes, fraud and abuse; to respond to your support enquiries and communicate with you about the App; and to comply with our legal obligations, enforce our Terms of Use, and protect our rights and the rights of our users. We only use your information for the purposes for which it was collected or for compatible purposes permitted by law.
17. Advertising
The App may include advertising. We work with advertising partners that may use your identifiers and other technical and usage data to select and display advertisements, to cap how often you see a given advertisement, and to measure whether advertisements are effective. Depending on your region and your choices – including your response to the App Tracking Transparency prompt – advertising may be personalised or non-personalised. Where the law or platform rules require your consent for personalised advertising or tracking, we or our partners will ask for it, and you may refuse or later withdraw it. Purchasing certain paid features, where offered, may reduce or remove the advertisements you see.
18. Analytics and Performance Measurement
We use analytics and performance-measurement technologies to understand how users interact with the App, which features and listings are used most, where users encounter difficulty, and how the App performs across different devices. The information processed for analytics is generally aggregated or used in a way that does not directly identify you, and it helps us make informed decisions about improvements, bug fixes and new features. Analytics providers may set or read identifiers on your device in order to distinguish one session or installation from another and to compile statistical reports for us.
19. Attribution and Marketing Measurement
We may use attribution and marketing-measurement technologies to understand how users discover and install the App – for example, whether an installation resulted from a particular advertising campaign. These technologies help us measure the effectiveness of our marketing, detect fraudulent or invalid installs, and allocate our marketing resources responsibly. Attribution partners may process device and advertising identifiers and related technical signals for these purposes in accordance with their own privacy policies and with your tracking choices.
20. Third-Party Services and SDKs
To provide, monetise, measure and improve the App, we integrate software development kits (SDKs) and services supplied by trusted third parties. Depending on your region and configuration, the App may use the following, each of which processes information in accordance with its own privacy policy:
- Apple App Store and related services (distribution, purchases and subscriptions) – https://www.apple.com/legal/privacy/
- Google AdMob (advertising) – https://policies.google.com/privacy
- Google Analytics for Firebase (analytics) – https://firebase.google.com/support/privacy
- Firebase Crashlytics (crash and stability reporting) – https://firebase.google.com/support/privacy
- Meta (Facebook) – https://www.facebook.com/privacy/policy/
- Unity (Unity Ads) – https://unity.com/legal/privacy-policy
- GameAnalytics (analytics) – https://gameanalytics.com/privacy/
- OneSignal (push notifications) – https://onesignal.com/privacy_policy
- AppLovin (advertising) – https://www.applovin.com/privacy/
- Digital Turbine (formerly AdColony) – https://www.digitalturbine.com/privacy-policy/
- AppsFlyer (attribution and marketing measurement) – https://www.appsflyer.com/legal/services-privacy-policy/
- Adjust (attribution and marketing measurement) – https://www.adjust.com/terms/privacy-policy/
- Yandex AppMetrica (analytics) – https://appmetrica.yandex.com/about/privacy-policy
- Apphud (subscription and purchase management) – https://legal.apphud.com/privacy
AppLovin serves as our advertising mediation layer and may display advertisements from partner networks, including AdColony, ByteDance (Pangle), Meta Audience Network, Fyber, Google AdMob, InMobi, ironSource, Mintegral, myTarget, Unity Ads and Yandex, each of which is subject to its own privacy policy.
We select our partners with care, but we do not control and are not responsible for their independent data practices. We encourage you to review the privacy policies linked above, as well as the privacy policy of the Apple App Store, to understand how these parties handle your information.
21. Legal Bases for Processing (EEA and UK Users)
If you are located in the European Economic Area or the United Kingdom, we rely on the following legal bases under the General Data Protection Regulation to process your personal data. We rely on your consent for personalised advertising, for tracking under App Tracking Transparency, and for any other processing that requires it, and you may withdraw that consent at any time. We rely on our legitimate interests to operate, secure and improve the App, to serve non-personalised advertising, to prevent fraud, and to understand aggregated usage. We rely on the performance of a contract to provide the App and the paid features you purchase, and on compliance with a legal obligation where processing is necessary to meet legal requirements. Where we rely on legitimate interests, you have the right to object as described below.
22. How We Share Information
We do not sell your personal data for money. We may, however, share or disclose information: with the third-party service providers and partners described in this Policy, so that they can perform advertising, analytics, subscription management, crash reporting and similar functions; where necessary to comply with applicable law, legal process, or an enforceable governmental or regulatory request; where necessary to detect, prevent or address fraud, security or technical issues, or to protect the rights, property or safety of Stepa Mobile, our users or the public; and in connection with a corporate transaction such as a merger, acquisition, financing, reorganisation or sale of assets, in which case any recipient of the data will remain bound by commitments consistent with this Policy. Certain disclosures for cross-context behavioural advertising may be considered a “sale” or “sharing” under some laws, and you can exercise the choices described below.
23. Disclosures to Apple
Because purchases and subscriptions are processed through the Apple App Store, certain information is shared with Apple, and Apple processes that information in accordance with its own privacy policy. In addition, as described in the section on refunds and consumption information above, we may share limited consumption data with Apple to help it evaluate refund requests and prevent abuse. We do not control Apple’s handling of your information, and we encourage you to review Apple’s privacy policy for details of its practices.
24. International Data Transfers
Because we and our partners operate globally, information collected through the App may be transferred to, stored in, and processed in countries other than the one in which you live, including countries outside the European Economic Area, the United Kingdom and the United Arab Emirates. Data protection laws in those countries may differ from the laws of your country. Where we transfer personal data across borders, we take steps to ensure that appropriate safeguards recognised under applicable law – such as standard contractual clauses or transfers to jurisdictions recognised as providing adequate protection – are in place to protect your information consistent with this Policy.
25. Data Retention
We retain information only for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by law. The exact period depends on the type of information and the purpose for which it is processed: purchase, subscription and refund-related records are retained as long as needed to provide the paid features and to meet legal, accounting and anti-fraud obligations; operational and diagnostic data is generally kept for the time needed to run and improve the App and is often held in aggregated or de-identified form; and support correspondence and submissions are kept for as long as needed to handle your request and for a reasonable period afterwards. Because your favourites, bookmarks and browsing history within the App are stored on your device, they remain under your control and can be cleared through the App or your device settings. When information is no longer needed, we take reasonable steps to delete or anonymise it.
26. Security
We use commercially reasonable technical and organisational measures designed to protect information against unauthorised access, disclosure, alteration and destruction, including access controls, the use of reputable service providers, and reliance on encrypted transmission where offered by the underlying platforms. Nevertheless, no method of transmission over the Internet, and no method of electronic storage, is completely secure, and we cannot guarantee the absolute security of your information. You are also responsible for taking reasonable steps to protect your own device and to keep its operating system and security features up to date.
27. Your Privacy Rights (EEA and UK)
If you are located in the European Economic Area or the United Kingdom, you have certain rights over your personal data, subject to applicable law. These include the right to access the personal data we hold about you; the right to request correction of inaccurate or incomplete data; the right to request erasure of your data; the right to restrict or object to certain processing, including processing based on legitimate interests and processing for direct marketing; the right to data portability; and the right to withdraw any consent you have given at any time without affecting the lawfulness of prior processing. You also have the right to lodge a complaint with the data protection authority in your country. To exercise any of these rights, please use the contact details in the “Contact Us” section below, and we will respond as required by law.
28. Your Privacy Rights (California and Other U.S. States)
If you are a resident of California or of another U.S. state with a comprehensive privacy law, you may have additional rights regarding your personal information, subject to certain exceptions. These may include the right to know what categories of personal information we collect, use and disclose; the right to request access to or deletion of your personal information; the right to correct inaccurate personal information; and the right to opt out of the “sale” or “sharing” of personal information for cross-context behavioural advertising. We do not sell personal information for money, and we do not knowingly sell or share the personal information of individuals we know to be under 16. We will not discriminate against you for exercising any of these rights. You may exercise your rights, or opt out of interest-based advertising, by using the App Tracking Transparency and device controls described above and by using the contact details in the “Contact Us” section below.
29. Other Regional Privacy Rights
Depending on where you live, other data protection laws may grant you similar rights, such as rights to access, correct, delete or obtain a copy of your personal data, and rights to object to or restrict certain processing. We aim to honour valid requests to the extent required by the laws applicable to you. If you would like to make a request, please use the contact details in the “Contact Us” section below, and we will handle your request in accordance with applicable law.
30. Children’s Privacy
The App is intended for a general audience and is not directed to children under the age of 13, or under the equivalent minimum age in your jurisdiction. We do not knowingly collect personal information from children under that age. Consistent with applicable requirements, we take steps intended to avoid delivering interest-based advertising to users who are known to be children. Because the App links to third-party Telegram channels and groups whose content we do not control, some content accessible through Telegram may not be suitable for minors, and parents and guardians should supervise their children’s use accordingly. If you are a parent or guardian and you believe that a child under the applicable age has provided us with personal information, please use the contact details in the “Contact Us” section below so that we can take reasonable steps to delete such information. For users in the European Economic Area, we do not knowingly process the data of children below the age required for consent in their country, which may be up to 16.
31. Cookies and Similar Technologies
As a mobile application, the App does not rely on browser cookies in the way that a website does. However, the App and the third-party technologies integrated into it may use device identifiers, local storage, software development kits and similar technologies to store and read information on your device for purposes such as remembering your settings and favourites, measuring usage, managing subscriptions, enabling advertising, and preventing fraud. Where these technologies require consent under applicable law, you will be asked for it, and you can manage certain of them through your device settings.
32. Links to Other Sites
The App and any advertisements displayed within it may contain links to third-party websites or services that we do not operate or control, including links that open the Telegram app or Telegram web resources. If you follow such a link, you will be taken to a destination governed by the relevant third party’s own terms and privacy policy, not by this Policy. We are not responsible for the content, security or privacy practices of any third-party site or service, and the inclusion of any link does not imply our endorsement. We strongly encourage you to review the privacy policy of every third-party destination you visit.
33. Do Not Track and Global Privacy Controls
Some browsers and devices offer “Do Not Track” signals or other global privacy control mechanisms. Because there is not yet a universally accepted standard for how mobile applications should respond to such signals, the App may not respond to them in a consistent way. We do, however, honour the tracking and advertising choices you make through the App Tracking Transparency prompt and your device settings, and we support the rights described in the sections above.
34. Third-Party Payment Processing
All payments for paid features, in-app purchases and subscriptions are processed by Apple through the App Store, and not directly by us. As a result, your payment information is provided to and handled by Apple in accordance with its terms and privacy policy, and we do not receive or store your full payment details. Any billing questions relating to the processing of a payment may need to be directed to Apple, although you can also contact us using the details below and we will try to help.
35. Changes to This Privacy Policy
We may update this Policy from time to time to reflect changes in our practices, in the App, or in legal requirements. When we make changes, we will revise the “Last updated” date at the top of this page and post the updated Policy in the same location. If the changes are material, we may provide additional notice as appropriate. We encourage you to review this Policy periodically. Your continued use of the App after the updated Policy takes effect constitutes your acceptance of the changes.
36. Contact Us
If you have any questions, concerns, requests or complaints regarding this Policy or the way your information is handled, or if you wish to exercise any of your privacy rights, please contact us using the details below, and we will do our best to assist you.
Stepa Mobile FZE LLC
United Arab Emirates
Email: [email protected]