Community Standards

1. Scope and applicability

These Standards apply to anyone who uses MINOMO: citizens who follow merchants and places, merchants who manage their public page (/m/{slug}), City Agents who curate editorial content and city postcards (/a/{slug}), event organisers with RSVP, and anyone who interacts with MINA, MINOMO's AI assistant.

MINOMO is an online platform within the meaning of Regulation (EU) 2022/2065 (Digital Services Act, "DSA"), because it hosts information provided by recipients of the service and makes it available to the public. We are not a very large online platform ("VLOP"), which means the minimum DSA obligations for online platforms apply. We comply with these rules in substance, not merely on paper.

The platform operator and the party responsible for enforcing these Standards is AVi Kairos Srl, Strada Lungă 188, Corp C2, Ap. 2, Brașov 500051, România (CUI 52477194 · J08/68/2025 · EUID ROONRC.J2025068492002). To use MINOMO you must be at least 18 years of age.

These Standards complement the Terms of Service and the Privacy Policy, which remain valid in parallel. In the event of a conflict between this document and the Terms of Service, the more restrictive text shall prevail in the interest of the user.

2. What MINOMO does not tolerate

MINOMO is built on trust: the trust a citizen places in the places of their city, and the trust a merchant puts into a direct relationship with their customers. The content described below breaks that trust irreparably. Each category also explains why the rule exists, not just what is prohibited.

2.1 Illegal content or content harmful to human dignity

You may not publish content on MINOMO that violates applicable law in Romania, the European Union, or the country in which the content produces its effects. This includes, without limitation:

• incitement to violence or to the commission of criminal offences;
• defamation, libel or false attribution of statements to real persons;
• direct or indirect threats against individuals or groups;
• breach of professional secrecy or of confidential documents protected by law;
• content that constitutes a criminal offence in at least one EU country, regardless of its legality in the sender's country of origin.

The reason is simple: MINOMO is not a neutral space. Everything you publish is associated with a physical place in your city. The dignity of the people who inhabit that place takes precedence over unlimited freedom of expression.

2.2 Exploitation and protection of minors — zero tolerance

MINOMO applies zero tolerance towards any content that exploits, harms or puts minors at risk. The following are prohibited without exception:

• child sexual abuse material or content that depicts persons under the age of 18 in a sexual manner (CSAM), in any form — images, video, text, or AI-generated content;
• communications or behaviour aimed at the grooming of minors;
• any content that promotes physical or digital access to minors for the purposes of abuse;
• content that normalises, justifies or minimises harm to minors.

Such content is removed immediately, without any prior notice procedure. The account is suspended. The material is reported to the competent authorities pursuant to applicable legal obligations, including Regulation (EU) 2021/1232 and the relevant national transposition provisions. There is no internal appeal for this category.

2.3 Fraud, spam and manipulation

The MINOMO community functions because the information circulating within it is reliable. The following are prohibited:

• unsolicited bulk communications ("spam") sent to followers or other users;
• phishing techniques: links or pages that mimic legitimate websites in order to steal credentials or personal data;
• fraud: offers, promotions or prices that you know to be false at the time of publication;
• artificial manipulation of follower rankings or engagement statistics (purchase of followers, bots, click farms);
• use of MINA or other platform tools to generate content designed to deceive at scale.

2.4 Prohibited or strictly regulated goods and services

On MINOMO you may not advertise, sell or facilitate the sale of:

• illegal narcotic substances or regulated chemical precursors;
• firearms, ammunition, untraceable weapon components (including those 3D-printable);
• prescription medicines without an appropriate licence or warning;
• counterfeit materials or materials in breach of EU customs regulations;
• live animals protected under CITES or sold in breach of animal welfare legislation;
• services or products that deliberately circumvent EU CE safety requirements (e.g. electrical devices lacking a required CE marking).

Certain legally regulated products (alcohol, tobacco, gambling, over-the-counter medicines) may appear on merchant pages provided they comply with national advertising regulations and are properly declared during profile configuration. MINOMO reserves the right to request supporting documentation.

2.5 Hate speech, harassment and extremist content

MINOMO exists to reconnect people with their own city. Harassment and hate speech destroy this mission by making the space hostile to the very people who are most vulnerable. The following are prohibited:

• content that incites hatred, discrimination or violence on the basis of ethnicity, national or geographical origin, religion, gender, sexual orientation, gender identity, disability, or age;
• direct harassment — messages, comments or repeated tagging aimed at intimidating or harming a specific person;
• digital stalking: the systematic collection of information about an individual with the intent to cause them harm;
• content that glorifies, promotes or recruits for terrorist or violently extremist organisations as defined under EU law (Directive 2017/541/EU);
• symbols, slogans or iconography of terrorist or Nazi organisations prohibited by law.

2.6 Disinformation and the integrity of democratic processes

We are not a general news platform, but content published by merchants and City Agents reaches real citizens in real physical spaces. Accordingly:

• the deliberate dissemination of false information about events, products or services that may cause harm to users is prohibited (including false emergencies, false evacuations, false health alerts);
• the use of the platform for coordinated operations to manipulate public discourse is prohibited (astroturfing campaigns, inauthentic coordination, fake engagement);
• publishing content that interferes with electoral processes through deliberate disinformation about voting procedures, candidates or results is prohibited.

This section does not prohibit legitimate political criticism, civic debate or the expression of personal opinions, provided they are clearly presented as such.

2.7 Violation of others' privacy

On MINOMO you may not publish information about other people without their consent where such publication may harm them. In particular, the following are prohibited:

• disclosure of third parties' personal data without consent (doxing): home addresses, private telephone numbers, identity documents, banking details;
• sharing images or videos depicting persons in private contexts without consent, including intimate images (image-based sexual abuse), prohibited under Legislative Decree 196/2003 as amended and Romanian law;
• publishing third parties' medical, mental health or sexual orientation information without explicit consent.

2.8 Infringement of intellectual property

You may only publish content on MINOMO for which you hold the rights or a valid licence. The following are prohibited:

• unauthorised reproduction of copyright-protected works (texts, photographs, music, video, software);
• unauthorised use of third-party registered trademarks in a manner that creates confusion as to the origin of a product or service;
• infringement of the moral rights of authors pursuant to Romanian Law No. 8/1996 and Directive 2019/790/EU.

If you receive a violation notice and believe it is an error or a case of lawful use (quotation, parody, critical use), you may submit a counter-notice through the reporting form, indicating the "Challenge a removal" section.

2.9 Sexually explicit content

MINOMO is not an adult platform. Sexually explicit content — photographs, video, text or AI-generated images depicting sexual acts in explicit form — is prohibited without exception, regardless of the declared age of the persons depicted. Images featuring artistic or contextual nudity (e.g. photography from a museum, body art) are assessed on a case-by-case basis; if in doubt, refrain.

2.10 Shock and violent content

It is prohibited to publish content whose sole or primary purpose is to shock, disgust or traumatise recipients. This includes images of extreme violence, mutilation, serious accidents, torture or death presented gratuitously and without a legitimate informational purpose. Content covering news or documenting violent events — where necessary for the informational context and presented with an appropriate warning — is assessed according to the principle of proportionality.

2.11 Self-harm and incitement to suicide

MINOMO follows the WHO guidelines on responsible reporting on suicide. The following are prohibited:

• content that glorifies, instructs or encourages acts of self-harm or suicide;
• direct communications to other users aimed at pushing them towards self-harmful behaviour.

Content that addresses these topics seriously for informational, awareness-raising or psychological support purposes is permitted and indeed encouraged, provided it complies with responsible communication guidelines.

2.12 Accounts: impersonation, abusive multi-accounts, squatting

• Impersonation: you may not create an account or page that purports to be another person or another organisation (an individual, a business, a public institution, a public figure), except where the use is manifestly satirical and clearly indicated as such.
• Abusive multi-accounts: you may hold only one personal consumer account. Creating additional accounts to circumvent a suspension, manipulate statistics or exceed usage limits is prohibited.
• Slug squatting: registering merchant or City Agent pages with slugs that mimic real brands or persons solely in order to block them or sell them on is prohibited.

3. Additional rules for merchants

Those with a page on MINOMO are speaking directly to their customers — often individuals purchasing for personal use, and therefore consumers protected by EU legislation. These rules reflect the obligations of the DSA, Directive 2005/29/EC (unfair commercial practices) and the Italian Consumer Code (Legislative Decree 206/2005), where applicable to Italian recipients.

3.1 Accuracy of commercial information

The information you publish on your page — business name, address, opening hours, description of products or services, prices — must be accurate and up to date. The DSA (art. 30) requires merchants offering products or services to EU consumers to provide MINOMO with verifiable identifying details. Publishing false information about your business's identity constitutes a breach of both these Standards and applicable law.

In the event of material changes (closure, change of premises, change of registered name), update the page within 30 days of the change taking effect.

3.2 Product compliance

The physical and digital products you offer through MINOMO must comply with applicable EU legislation: CE marking where required, compliance with Directive 2014/35/EU (low voltage), Directive 2014/30/EU (electromagnetic compatibility), Regulation (EU) 2019/1020 (market surveillance), and sector-specific rules. Presenting a product as compliant when it is not constitutes a misleading commercial practice within the meaning of art. 21 of Directive 2005/29/EC.

3.3 Fair commercial practices

Unfair commercial practices within the meaning of Directive 2005/29/EC are prohibited, including:

• presenting a product as a "limited offer" when there is no genuine limitation of quantity or time;
• using "crossed-out" prices that do not correspond to a price genuinely charged previously;
• environmental claims ("eco", "green", "sustainable", "carbon neutral") that are unverifiable or misleading, in line with the forthcoming Green Claims Directive;
• publishing false reviews or paying for non-genuine reviews.

3.4 Promotions and offers: clarity of terms

Every promotion or offer published on MINOMO must clearly state:

• the final price inclusive of VAT;
• the duration of the offer (start and end date, or an indication of "whilst stocks last" with the actual number available);
• any conditions of participation (e.g. "available to followers of loyalty programme X only");
• the right of withdrawal applicable to the consumer, in the cases provided for under Directive 2011/83/EU.

4. Rules for City Agents and editorial content

City Agents editorially curate MINOMO's presence in a city: they publish postcards, events and POIs on MINOMO Atlas, and are the local point of contact for merchants in the area. Their content is editorial rather than purely commercial in nature, but this does not exempt them from certain specific rules.

4.1 Transparency of commercial relationships

If you publish content in which you promote a merchant in exchange for financial consideration, free goods or any other benefit, you must clearly indicate this — even in brief form, such as "Sponsored content" or "In partnership with [Merchant name]". This rule derives from art. 26 of Directive 2005/29/EC and art. 9 of Directive 2018/1808/EU on audiovisual media services, where applicable.

4.2 Editorial independence

MINOMO does not impose an editorial line on City Agents regarding city content, but requires that published content reflects an autonomous and good-faith assessment. The following are not permitted:

• publishing content that presents as genuinely editorial an offer that is in reality entirely conditioned by a commercial arrangement;
• systematically excluding merchants or places from editorial content for reasons unrelated to quality or relevance, but due to undisclosed personal or financial interests;
• publishing information about POIs or events knowing it to be false at the time of publication.

5. How to report and handle violations (DSA)

This section describes the operational mechanism MINOMO has adopted in fulfilment of the obligations under Regulation (EU) 2022/2065 (DSA). If you are a public authority or institutional body, the dedicated point of contact is [email protected] (DSA art. 11). If you are a recipient of the service or a third party who has identified a violation, please use the reporting form (DSA art. 12 and 16).

5.1 Content reporting (DSA art. 16) — Notice and Action

To report content that you believe violates these Standards or applicable law, use the dedicated form at:

minomo.io/en/legal/report-content/

The form requires:

• the URL of the reported content or the account identifier (slug, ID);
• the category of violation you consider applicable (from a drop-down menu that mirrors the structure of these Standards);
• a brief description of the reason for the report;
• a contact address (optional, but required if you wish to receive updates on the status of your report);
• a good-faith declaration: the report is submitted in the genuine belief that the content violates the rules. Reports submitted in bad faith or for harassing purposes may result in the suspension of the reporting account (DSA art. 23).

Anonymous reports are accepted. You may report content even if you are not registered on MINOMO.

5.2 Statement of Reasons (DSA art. 17)

When we take a decision to restrict content or an account — removal, limitation of visibility, suspension, ban — we notify the affected user with a Statement of Reasons: a clear communication indicating:

1. which rule or provision has been breached, with precise reference to the relevant section of these Standards or the applicable legal provision;
2. the facts on which our assessment is based;
3. the nature of the measure taken and its duration (if temporary);
4. the available appeal options and the deadlines for exercising them.

The notification is sent to the account's email address and, where applicable, via a communication in the platform interface.

5.3 Internal Complaint Handling System (DSA art. 20)

If you believe that a decision affecting you is incorrect, incomplete or disproportionate, you have the right to lodge an internal complaint. The conditions are:

• Deadline: 6 months from the notification of the decision (as provided under DSA art. 20).
• Cost: free of charge.
• How: reply directly to the notification you received, or write to [email protected] with the subject line "DSA Appeal — [report ID or account slug]".
• Human review: every internal complaint is examined by a person, never by an automated system alone. We review the original decision taking into account the arguments submitted.
• Response: we will inform you of the reasoned outcome within a reasonable time, depending on the complexity of the case. For active suspensions we aim to respond within 14 working days.

5.4 Out-of-court dispute settlement (DSA art. 21)

If, following the internal complaint process, you are not satisfied with the outcome, you may refer the matter to a body certified for out-of-court dispute settlement by the Coordinator of Digital Services (ANCOM — Autoritatea Națională pentru Administrare și Reglementare în Comunicații) in Romania, pursuant to DSA art. 21. ANCOM is currently finalising the certification process for ADR (Alternative Dispute Resolution) bodies competent for providers established in Romania. As soon as the certified list is published, we will include here the name and contact details of the body with which we will collaborate.

Recourse to an ADR body does not preclude your right to bring ordinary judicial proceedings, nor your right to submit a complaint to ANCOM itself in its capacity as Coordinator of Digital Services.

5.5 Trusted Flaggers (DSA art. 22)

The DSA provides for the status of "Trusted Flaggers": entities with specific expertise in detecting illegal content, recognised by the Coordinator of Digital Services of the relevant Member State. Reports from recognised Trusted Flaggers are treated with priority over ordinary reports and processed with the utmost promptness.

If your organisation intends to apply for Trusted Flagger status with ANCOM and wishes to coordinate with MINOMO, please write to us at [email protected].

5.6 Anti-abuse measures (DSA art. 23)

The reporting mechanism exists to protect the community, not to punish competitors or adversaries. MINOMO reserves the right to suspend or restrict access to the reporting form — and to the associated account — in respect of anyone who repeatedly submits manifestly unfounded reports, i.e. reports evidently formulated with the intent to harm other users rather than to identify a genuine violation. Equally, we reserve the right to accelerate sanctions against accounts that repeatedly publish manifestly illegal content.

6. Progressive sanctions

MINOMO adopts a proportionate and graduated approach. The aim is not to exclude people, but to keep the platform safe. For this reason, sanctions follow a progression, save for the exceptions indicated below.

Exceptions to the progression: the categories referred to in section 2.2 (exploitation of minors), section 2.1 with respect to terrorist content, and cases of documented systemic fraud may result in an immediate permanent ban upon the first finding, without passing through the preceding levels.

6.1 Data retention following account closure

In the event of a permanent ban, the account's personal data is handled as follows:

• public content is removed from display;
• identifying data and the record of confirmed violations are retained for the time necessary to fulfil legal obligations (defence in judicial proceedings, requests from authorities, DSA reporting obligations), normally not exceeding 5 years;
• data to which you have a right of erasure under GDPR art. 17 is deleted at the end of the legal retention period, as described in the Privacy Policy.

7. Amendments to these Standards

We may update these Standards to reflect the evolution of the platform, new regulatory obligations or newly emerging risks. When we do so:

• we update the version number and date at the top of this document;
• if the amendment is material — meaning it affects your rights, the appeal procedures, or the list of prohibited content in a way that broadens its scope — we will notify you with at least 30 days' prior notice, by email and via a notice in the application;
• previous versions are archived in the change history below.

Change history

8. Contact

For any questions about these Standards, to report content or to exercise your appeal rights:

• Content reporting (DSA art. 16): minomo.io/en/legal/report-content/
• DSA point of contact (for authorities and recipients of the service): [email protected]
• Privacy and personal data: [email protected]
• General enquiries: [email protected]
• Postal address: AVi Kairos Srl — Strada Lungă 188, Corp C2, Ap. 2, Brașov 500051, România