In due righe
Your vote is separated from your identity: we record that you took part, not what you chose. No table links the two, not even for us. Results are published only in aggregate and sealed in a verifiable way.
This is an appendix: it applies in addition to the Privacy Policy and the Terms of Service, not instead of them. It covers only what the Public consultations service handles beyond the rest of MINOMO.
What it is, and what it is not
A MINOMO public consultation is a tool a municipality uses to gather citizens’ opinions on a local matter.
It is not an election and has no legal force. It does not replace referendums, official consultations or any other procedure established by law. It is a listening tool: the outcome does not bind the administration.
Your vote is separated from your identity
This is the part that matters, and it is worth explaining how it works rather than merely promising it.
When you take part, the system writes to two different places:
- a participation register records that you took part in that consultation;
- a tally register records that an option received one more vote.
No link exists between the two. There is no table, identifier or key that allows anyone to go from you to your choice: not for the municipality, not for MINOMO staff, and not even for someone with full access to the database. This is not an organisational promise, it is how the system is built.
Of the moment you took part we keep only the hour, not the minute or the second. This is a deliberate precaution: with a precise timestamp, in a consultation with few participants, one could infer the choice by cross-referencing the two registers. Rounding to the hour makes that impossible.
Why record that you took part at all? For one reason only: to prevent the same person from voting twice. It also lets us show you that you have already participated, so you do not try again.
Who handles your data
As with the other civic services, there are two separate controllers, each for their own part.
AVi Kairos Srl — Strada Lungă 188, Corp C2, Ap. 2, Brașov 500051, Romania, [email protected] — is the controller for the infrastructure, your account, enforcing the one-vote rule, and data retention.
The municipality calling the consultation is an independent controller for: how the question is worded, the decision to publish the results, and what it does with them. MINOMO does not interfere.
Who can take part
The municipality sets the requirements before opening the consultation: typically a verified MINOMO account, with the reference city set to that municipality, and a minimum account age.
These requirements are captured at the moment of publication and cannot be changed afterwards: this prevents the rules from shifting while the consultation is open, once it starts becoming clear which way it is going.
The results
They are published in aggregate form only: how many votes each option received. Never per person, never for groups so small that someone in them could be recognised — there is a minimum participant threshold below which a breakdown is not shown at all.
The municipality decides whether and when to make the results public.
The verifiable seal
When a consultation closes, the results are sealed: a signed certificate is generated that fixes their content and makes them verifiable by anyone, independently, without having to trust us.
The certificate contains aggregate data only — tallies and summaries — and no personal data. No information concerning an individual leaves MINOMO in this form.
You can verify a certificate from the consultation’s public page. The technical procedure is described on the methodology page.
Notifications
If the municipality publishes a consultation in your city and you have consented to civic notifications, you receive an alert. You can turn them off at any time in the app settings without losing the ability to take part: the notification is a reminder, not the way in.
How long the data stays
The participation register is needed while the consultation is open, to prevent double voting. The aggregate tallies and the certificate remain indefinitely: they are the public result of the consultation and contain no personal data.
If you delete your account, your participation is removed. The aggregate tally does not change — and could not: we do not know which option you chose, so there is nothing to subtract. Your vote stays in the total, forever separated from you.
Legal basis
The municipality processes the data for the performance of a task carried out in the public interest (Art. 6(1)(e) GDPR).
MINOMO processes the data for its own legitimate interest (Art. 6(1)(f) GDPR) in ensuring one vote per person and the integrity of the consultation. For sending civic notifications the basis is your consent (Art. 6(1)(a) GDPR), which you can withdraw at any time.
Your rights
The rights under Articles 15-22 GDPR apply in full. How to exercise them is explained in Data request, or write to [email protected].
One necessary clarification: the right of access cannot return which option you chose, because that data does not exist anywhere. It is the price — and at the same time the guarantee — of ballot secrecy.
You may lodge a complaint with the competent supervisory authority: the Garante per la protezione dei dati personali in Italy, ANSPDCP in Romania.