Privacy Policy
Last Updated: October 23, 2026
Introduction
Welcome to Entergram! This Privacy Policy explains how we handle your data while using our Telegram CRM platform ("Service"), including the Entergram web application and the Entergram apps for mobile and desktop, and while using our public website.
For personal data relating to your own account and use of the Service, the data controller is Entinel Technologies OÜ, a company registered in Estonia (reg. no. 17485993) with its legal address at Pärnu mnt. 139b - 14, Tallinn, 11317, Estonia, operating under the Entergram brand. For personal data of third parties that you process through the Service (such as your leads' or contacts' metadata), you are the data controller and we act as your data processor; see our Terms of Service for details.
1. How We Handle Your Telegram Messages
Entergram is a CRM for your Telegram accounts, so the Service has to handle the content of your Telegram messages in order to work. We handle message content only to provide the Service to you and your workspace:
Displaying and relaying messages. When you or an authorized member of your workspace opens a chat, Entergram fetches the messages from Telegram and displays them, and it sends the messages you write to Telegram. Messages are shown only to workspace members who are allowed to see that chat under your workspace's permissions.
No message history in our database. We do not store your Telegram message history in our database. To keep the app fast, we use short-lived caches that expire automatically and are cleared when they go out of date. When a cache is empty, messages are fetched live from Telegram again.
Notifications. We process message content to deliver notifications about new messages, as described in Section 3.
AI assistants you connect (MCP). Entergram does not run AI over your message content on its own initiative, and we never use your messages to train a model, ours or anyone else's. We do offer an MCP connector that you can switch on so an AI assistant you choose, such as Claude or ChatGPT, can work with your Telegram data. Once you authorise it, that assistant can read and act on the data the scopes you granted cover, which includes message content, and from that point the data is handled by the AI provider under its own terms and privacy policy, not ours. The connection does not exist until you create it, it reaches only the Telegram accounts on your own seat, and you can revoke it at any time in Settings → Workspace → Connectors → MCP. See Section 4.
Content you choose to keep. The chat list stores a short preview of each chat's most recent message together with the chat's metadata. When you create a ticket from a message or write a broadcast or template, that content is stored as part of your CRM data until you or your workspace delete it.
Telegram secret chats are end-to-end encrypted and tied to the device where they were started, so they are not available to Entergram. We do not sell message content or use it for advertising.
2. Metadata We Collect
To provide CRM features like tags, tickets, filters, dashboards, and analytics, we also store non-content data exposed by Telegram's API, including:
Chat IDs, group/channel names, and usernames
Timestamps, sender IDs, message counts, and deletion flags
Any tags, notes, custom fields, or tickets you create in Entergram
Technical session information needed to keep your Telegram account connected
Usage analytics (e.g., messages per hour/day) for dashboards and product improvements
We keep this metadata for as long as your account is active, and delete it when you or your workspace delete the record or when your account is deleted, as described in Section 9. Notification records and message previews follow the shorter periods in Section 3, and short-lived message caches expire on their own.
On our public website, if you choose to subscribe to the newsletter, we collect your email address and a record of your consent.
3. Mobile and Desktop Apps, and Browser Notifications
When you use an Entergram app on a phone, tablet, or computer, we process the following additional data:
Push notification tokens. If you allow notifications, your device's push service issues a token that lets us send notifications to that device: Apple Push Notification service (APNs) on Apple devices, or Firebase Cloud Messaging (FCM) on Android. We store this token in encrypted form, linked to your account and to the workspaces you receive notifications for.
Installation identifiers. Each app installation gets a random identifier generated for Entergram, together with the platform and push service it uses. We use it to deliver notifications to the right device and to stop delivery when you sign out. It is not an advertising identifier, and we do not use it to track you across other apps or websites.
Apple and Google as processors. Notifications are delivered through Apple (APNs) and Google (FCM), which act as our processors for push delivery. They receive the push token and the notification content described below, only to deliver the notification to your device.
What a notification contains. By default, a notification contains only generic text (for example, that you have a new message) and no message content. If you turn on Show message previews, a notification may also include the sender's name, which of your connected Telegram accounts received the message, and a short excerpt of the message. Previews may be unavailable where your workspace's security settings restrict them.
Retention. We keep a record of the notifications we send you so they can be shown in the app. Read notifications are deleted after 7 days, and all notifications are deleted after 30 days. Message previews used to build notifications are held only in an in-memory cache for up to 1 hour. Push tokens and installation identifiers are kept until you sign out of the app, turn off notifications, or delete your account, or until Apple or Google reports that the token is no longer valid.
How to turn it off. Turn off Show message previews in Entergram's notification settings to receive generic notifications only. To stop notifications completely, turn them off for Entergram in your device's system settings or in Entergram's notification settings. Signing out of the app removes that device's registration.
Browser notifications. If you allow notifications for Entergram in your web browser, including when you install it as a web app, your browser gives us a push subscription: an endpoint address at your browser vendor's push service and the keys used to encrypt notifications for it. We store it linked to your account, together with basic browser and device information so you can recognise it in your settings. Notifications are delivered through the push service operated by your browser's vendor (for example Google, Mozilla, or Apple). By default, a browser notification contains only generic text and no message content. If you turn on Show notification previews, it may also include the sender's name, which of your connected Telegram accounts received the message, and a short excerpt of the message, unless your workspace's security settings restrict previews. A subscription stops being used when you turn browser notifications off or the push service reports that it is no longer valid, and it is deleted when you delete your account.
4. Third-Party Services
We use trusted third-party services to operate and improve Entergram:
Google Analytics, analytics used across entergram.com and app.entergram.com only if you accept analytics cookies. Your choice is shared across these subdomains, the script is not loaded at all until you accept, and Google's advertising features remain disabled.
Stripe, secure payment processing.
Supabase, authentication and account management for the application (app.entergram.com).
Cloudflare, network security, bot protection, and content delivery for both websites.
Sentry, technical error reporting, so we can detect and fix faults in the application. Reports reach Sentry through our own domain, so your browser never contacts Sentry directly, and they are scrubbed before they are sent: email addresses, tokens, message content, phone numbers, and long identifiers are removed or masked. For a small share of sessions in which an error occurs, a report may include a short reconstruction of the screen with all text masked and all media blocked, so that we can reproduce the fault. We do not record your screen outside that error path, and we never use screen recording for analytics, marketing, or profiling. Our Cookie Policy describes this in more detail.
Brevo, subscription management and delivery of the newsletter you request. Brevo acts as our data processor for this purpose.
Affonso (ZASolution, Germany), referral attribution and our Partner Program dashboard. If you open the partner dashboard, we send Affonso your account identifier, name, email address, and avatar if you have one, so it can show you your own affiliate account. Affonso acts as our data processor under an Article 28 agreement. See our Cookie Policy for details.
Apple Push Notification service and Firebase Cloud Messaging, delivery of push notifications to the Entergram apps (see Section 3).
Browser push services, operated by your browser's vendor (for example Google, Mozilla, or Apple), delivery of browser notifications (see Section 3).
Hosting, our public website and application run on dedicated infrastructure that we manage and are delivered through Cloudflare.
A network connectivity provider, named below only by role. Each Telegram account you connect reaches Telegram over a dedicated network route we rent for that account, so your accounts do not share an address. This provider carries the encrypted traffic between Entergram and Telegram. It acts as our sub-processor, it is bound by contract, it is not permitted to inspect, store, or use what passes through, and it holds no key that would let it read anything.
HubSpot and Zendesk, where you connect them, so that the chats and tickets you choose can be synchronised with your account on those services. See the note on integrations below.
This is the one supplier we do not name on this page, and we would rather say that plainly than leave it vague. Publishing which network provider sits behind our customers' Telegram accounts would make those accounts easier to single out and target, which is the opposite of what the arrangement is for. Everyone else we rely on is named above. Business customers who need the name for their own compliance can obtain it under our Data Processing Agreement, in confidence, and we will tell DPA customers before we change it. Everything else is listed at entergram.com/subprocessors.
These services may temporarily handle limited metadata as part of their functionality. Apart from the notification content described in Section 3, they do not receive the content of your Telegram messages.
Integrations you connect. If you connect an integration such as Slack, Notion, or Make.com, Entergram sends it the Telegram messages and data you configure it to receive. That content is then held by the integration under its own terms and privacy policy, and deleting it there is managed in that service.
AI assistants and the MCP connector. If you authorise an AI assistant through our MCP connector, Entergram answers that assistant's requests with the data your granted scopes cover. Depending on those scopes this can include chat lists, contacts, tickets, analytics events, and the content of messages, for the Telegram accounts on your seat only. We do not choose the assistant and we are not its provider: once the data reaches it, the AI provider handles it under its own terms and privacy policy, including whatever that provider says about retention and model training. Treat an MCP connection the way you would treat giving a contractor access to your inbox, and grant only the scopes you need. Connections are listed, and can be revoked, in Settings → Workspace → Connectors → MCP.
The public website may ask the application whether an existing sign-in session is valid so it can label the application button accurately. The application returns only a true/false result; the public website does not receive the session token, email address, user ID, or workspace data, and the result is not stored or used for analytics.
We do not use advertising cookies, ad networks, ad targeting, profiling, or third-party cross-site tracking on either entergram.com or app.entergram.com, and we never sell your personal data. If you consent, app.entergram.com sends limited product events such as account creation, onboarding completion, Telegram connection, trial activation and payment completion to Google Analytics. It never sends Telegram message content, phone numbers, usernames or email addresses. See our Cookie Policy for the full itemised list.
First-touch sign-up attribution. If you accept analytics cookies, entergram.com and app.entergram.com keep a first-party cookie recording how you first reached Entergram: the UTM campaign tags in the link you followed, the host name of the referring website, the path of the page you landed on, and the time of that visit. It contains no IP address or browser details. When you sign up, this record is stored once with your user account so we can understand which channels bring new customers. It is not shared with Google or any other third party, is not used for advertising or profiling, and is deleted together with your account. You can withdraw consent at any time through Cookie settings, and ask us to delete a stored record at hello@entergram.com.
5. How We Use Your Data
The data described above is used only to:
Display, send, and notify you about your Telegram messages
Power dashboards, filters, tags, and tickets
Generate analytics and activity summaries
Maintain security and prevent abuse
Check, where we have reason to, that providing the Service to you is permitted under sanctions and export control law, as described in our Terms. We do this to comply with a legal obligation, we do it on your account and billing details rather than on your messages, and we keep a record of a check only where we must be able to show we made it
Send the newsletter you specifically requested and manage your communication preferences
Comply with legal requirements
6. Legal Bases (GDPR & Similar Laws)
We process your data based on:
Contractual necessity: to provide the CRM service you signed up for
Legitimate interests: security, fraud prevention, and product improvement
Your consent: for optional features you enable (such as push notifications and message previews), for optional analytics and first-touch sign-up attribution (see Section 4 and our Cookie Policy), and for each email subscription you request. You can withdraw consent at any time by using the unsubscribe link in an email or contacting us. Withdrawing consent does not affect processing that occurred before withdrawal.
7. Data Sharing & Disclosure
We do not sell, trade, or rent your personal data, and we do not share it for behavioural advertising. We disclose data only in these situations:
Service providers. The processors named in Section 4, each acting on our instructions, under a contract, and only for the purpose listed there. Our current sub-processors are published at entergram.com/subprocessors, with what each one does, where it processes data, and the transfer safeguard we rely on. Our standard Data Processing Agreement is available on request.
Services you connect yourself. Integrations and AI assistants you authorise, as described in Section 4. You decide whether these exist and what they can reach.
Workspace members. Data in a workspace is visible to the members of that workspace, within the permissions its owner sets.
Legal obligations. Where we are required by applicable law, a court order, or a lawful request from a competent authority. We review each request, disclose only what the request actually covers, and tell you about it unless we are legally prohibited from doing so.
Protecting the Service. Where it is necessary to investigate fraud, abuse, or a security incident, or to establish, exercise, or defend legal claims.
Business transfer. If Entergram is involved in a merger, acquisition, reorganisation, or sale of assets, your data may transfer to the acquiring entity. It would remain subject to this policy, and we will notify you before any transfer takes effect and before your data becomes subject to a different privacy policy.
If we ever suffer a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you without undue delay, and we will notify the Estonian Data Protection Inspectorate within 72 hours where the GDPR requires it. Where the breach affects data you process through the Service as a controller in your own right, we will notify you without undue delay so that you can meet your own obligations, as Article 33(2) of the GDPR requires of us as your processor.
8. Security
We protect your data with encryption in transit and at rest, strict access controls on who inside Entergram can reach production systems, encrypted storage of Telegram session data, and secure development practices including code review and dependency monitoring. We review our security arrangements as the Service changes.
Certifications, honestly stated. We do not hold an ISO 27001 certificate or a SOC 2 report today, and we will not imply otherwise until we do. Both are underway. We have engaged Sprinto, a compliance automation platform, to run the programme for each. ISO 27001 is in progress now, and we are not putting a date on it until the audit is booked, because a date we might move is worth less to you than none. SOC 2 is signed and planned, and we expect it during 2027, because we are being honest about what a small team can do well at once rather than promising a date we would miss.
To be precise about what that means: Sprinto helps us operate and evidence the controls, and the ISO 27001 certificate itself is issued by an accredited certification body after it audits us. Until that audit is passed, we are working toward the standard rather than certified against it. When each one completes, this section will say so, with the date and the scope.
In the meantime, we would rather be useful than vague. If you are assessing Entergram for your organisation and need more than this page, email hello@entergram.com and we will provide what your review needs: our Data Processing Agreement, the sub-processor list with transfer safeguards, our security overview, a completed security questionnaire, and the Standard Contractual Clauses or transfer assessments we rely on. We answer vendor assessments from customers on any plan, and we will tell you plainly where a control is not yet in place rather than leaving a box ticked that should not be.
No system is perfectly secure. You can reduce your own risk considerably by using a strong, unique password, enabling two-factor authentication on your Telegram accounts, reviewing your workspace's member permissions, and removing MCP connections and integrations you no longer use.
If you believe you have found a security vulnerability in Entergram, please report it to hello@entergram.com rather than disclosing it publicly, and we will work with you on it.
9. Data Retention & Deletion
We keep service metadata only as long as your account is active. When you delete your account or request erasure, your data is permanently removed within 30 days, except for the limited records below.
CRM data (tags, notes, custom fields, tickets, templates, uploads): until you or your workspace delete it, or until your account is deleted.
Notification records and push registrations: the periods in Section 3 (read notifications 7 days, all notifications 30 days, previews cached up to 1 hour).
Billing and accounting records: 7 years, as required by the Estonian Accounting Act and the Taxation Act. We cannot delete these on request.
Security, server, and error logs: 90 days.
Deletion record (anonymous, no name or email, so we can show a deletion was completed): 3 years.
Blocked-email marker (a keyed hash of the address, not the address, which stops it being reused automatically): 3 years, or until support releases it at your request, whichever comes first.
Backups: deleted data falls out of our encrypted backups within 30 days as older backups expire.
Our account deletion page explains how to delete your account, with or without the app, and which records we keep after deletion.
Subscription contact data is kept until you unsubscribe, withdraw consent, or we stop the relevant update service. After you unsubscribe, we may keep the minimum suppression and consent record needed to honour your choice and demonstrate compliance, for no longer than necessary.
10. Your Rights
You have full control over your data. You can:
Download My Data: export all your data instantly
Delete All My Data: removes your data from your account straight away, so it is no longer visible or usable in the Service, with erasure from our systems and encrypted backups completed within 30 days as older backups expire
Delete your account: in Settings → Profile → Danger Zone, confirmed through a link we email to your account address. If you cannot use the app, email us from your account's email address. See Delete your Entergram account.
You also have the right to access your data, to have inaccurate data corrected, to have processing restricted, to receive your data in a portable format, and to object to processing based on our legitimate interests, including our interest in improving the product. To protect your account we may need to confirm who you are before we act, and we will say so if a request is one the law allows us to refuse or charge for, which is rare. Service-account export and deletion controls are available in Settings → Data. For newsletter data, use the unsubscribe link in any email or contact hello@entergram.com to request access, correction, deletion, restriction, portability where applicable, or withdrawal of consent. You may also object to processing based on legitimate interests.
You have the right to lodge a complaint with the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon) or the competent supervisory authority in your country.
We answer requests without undue delay and within one month at the latest, as the GDPR requires. We do not charge for this, and we do not require you to use a form.
If you are in California. You have the right to know what personal information we collect and why, to request its deletion or correction, and not to be discriminated against for exercising those rights. We do not sell personal information and we do not share it for cross-context behavioural advertising, as the CCPA defines those terms, so there is no "Do Not Sell or Share" opt-out for us to offer. Use the same address, hello@entergram.com, for any of these requests.
11. International Transfers
Your data is primarily processed within the European Union. Our own servers are in the EU, and Affonso (Germany) and Brevo (France) process within it. Network connectivity providers route traffic in the region each Telegram account is configured for, which may be outside the EU where you ask us to place an account there; the traffic is encrypted in transit throughout and those providers cannot read it.
Some of our processors are established outside the EU or may process data there. For each of them, this is the safeguard we rely on:
Google LLC (Google Analytics, Firebase Cloud Messaging), United States: EU-US Data Privacy Framework, supported by Standard Contractual Clauses.
Functional Software, Inc. (Sentry), United States: EU-US Data Privacy Framework, supported by Standard Contractual Clauses.
Stripe, United States and Ireland: Standard Contractual Clauses, with EU customers contracting with Stripe's Irish entity.
Apple (Apple Push Notification service), United States and Ireland: Standard Contractual Clauses.
Cloudflare, United States: Standard Contractual Clauses, with traffic served from EU data centres where possible.
Supabase, United States, with our project hosted in the EU: Standard Contractual Clauses.
Where we rely on Standard Contractual Clauses, we assess whether the law of the destination country undermines them before we transfer, and we apply additional measures such as encryption and pseudonymisation where needed. You can ask us for a copy of the clauses, and for our assessment, at hello@entergram.com.
If you authorise an AI assistant through the MCP connector, or connect another integration yourself, data may travel to wherever that provider operates. We are not a party to that transfer, and the provider's own terms govern it.
12. Automated Decisions and Profiling
We do not make decisions about you by automated means that produce legal effects or similarly significantly affect you, and we do not profile you. Entergram sorts, filters, tags, and counts your data because you ask it to, and those are tools you operate rather than decisions we make about you.
13. Children
Entergram is not intended for anyone under 18. We do not knowingly collect data from children.
14. Updates to This Policy
We may update this Privacy Policy occasionally. The new version will always be posted here with an updated 'Last Updated' date.
For major changes (e.g., collecting new data types), we will notify you via email or an in-app notice before the change takes effect.
15. Contact Us
For questions, feature requests, or privacy concerns: hello@entergram.com
Entinel Technologies OÜ (registry code 17485993, VAT EE102977170), Pärnu mnt 139b-14, 11317 Tallinn, Estonia. Email: hello@entergram.com.
Data protection is supervised by the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, aki.ee), and consumer and e-commerce matters by the Estonian Consumer Protection and Technical Regulatory Authority (Tarbijakaitse ja Tehnilise Järelevalve Amet, ttja.ee). Consumers in Estonia may also refer a dispute to the consumer disputes committee (tarbijavaidluste komisjon) at the same authority.
We usually respond within a few hours.