Privacy Policy — MINOMO

Who we are

The data controller for personal data collected through MINOMO is AVi Kairos Srl, a company incorporated under Romanian law with its registered office at Strada Lungă 188, Corp C2, Ap. 2, Brașov 500051, România (CUI 52477194 · J08/68/2025 · EUID ROONRC.J2025068492002).

For any request relating to the protection of personal data — exercising GDPR rights, reporting an incident, or questions about this Policy — write to [email protected]. How to exercise your rights is explained at minomo.io/en/legal/data-request/.

Privacy contact and Data Protection Officer. AVi Kairos Srl has not appointed a Data Protection Officer (DPO) under Art. 37 of Regulation (EU) 2016/679 (GDPR). Data protection questions are handled by an internal privacy contact, reachable at [email protected]. Municipalities and their own DPOs can use the same address.

What MINOMO does

MINOMO is a proximity digital infrastructure that connects citizens, merchants, municipalities, and local curators (City Agents) through a direct channel, without advertising. The product comprises:

• a consumer application (PWA at app.minomo.io, and native iOS/Android apps) through which you can follow merchants, events, and places in your city;
• public Bio Pages for merchants and City Agents, indexable by search engines and AI assistants;
• push notifications from merchants to their followers and, in broadcasting mode, to an entire city;
• MINA, a conversational assistant powered by generative artificial intelligence for local discovery and itinerary planning;
• digital loyalty cards with points, rewards, and redemption codes;
• events with RSVP and push reminders;
• MINOMO Atlas, an editorial directory of local European life, publicly accessible;
• services for municipalities: messages and urgent alerts (MINOMO Alert), public consultations, issue reports, and a public city page;
• panels for merchants, City Agents, Country Managers, distributors and municipalities.

This Policy covers the processing of personal data by AVi Kairos Srl across all these services, accessible through the domains minomo.io, app.minomo.io, admin.minomo.io, cdn.minomo.io, mina.minomo.io, the native applications distributed via the App Store and Google Play, and the public pages of municipalities that MINOMO runs on the municipalities’ own domains. The municipal services have dedicated appendices: MINOMO Alert, Public consultations, Issue reporting and Municipal pages.

Who this Policy applies to

• Consumer citizens: adults who register to follow merchants, events, and places in their city;
• Merchants: businesses, professionals, or sole traders who have a page on MINOMO. For merchants we collect identification data required by Art. 30 of Regulation (EU) 2022/2065 (Digital Services Act, DSA);
• City Agents, Subagents, Country Managers and distributors;
• Representatives of municipalities who use the municipal panel;
• Visitors to minomo.io, public merchant pages (/m/{slug}), City Agent pages (/a/{slug}), events, MINOMO Atlas and municipal pages;
• People who write to us through the contact form.

This Policy does not cover processing that a third party carries out independently (for example, a merchant who contacts you outside MINOMO, or a municipality that handles your report in its own archives). In those cases, the third party’s own privacy policy applies.

What data we process

We collect only what is needed to run the services you use. It depends on your role.

If you have an account in the app

• Account: email address (the only contact detail we ask for), display name, language, the reference city you declare, country. To sign in you use a one-time code sent by email, a sign-in link, or Google or Apple. There are no passwords. The code and the email linked to it are stored only in hashed form.
• Sign in with Google or Apple: if you choose it, we receive from Google your name, verified email, an identifier and the address of your Google profile picture, which we save in your profile; from Apple an identifier and, if you allow it, your email (which may be a private Apple relay address).
• Device: a technical identifier generated by the app, the push notification token, the device name or browser type sent when you enable notifications, your notification preferences.
• Security: IP address, browser or app type, date and time of sign-ins and failed attempts.
• Use of the service: merchants and pages you follow, event RSVPs, loyalty cards and points, offers you tap, notification opens.
• Conversations with MINA: see the dedicated section.
• Civic services: your preferences on municipal communications, your participation in consultations (never your vote), the reports you submit and the confirmations you give. See the appendices.

Location

The app uses your device’s location only while it is open (never in the background) and only if you have granted permission:

• in Explore, to show where you are on the map and, if you tap “Near me”, to search what is around you: the coordinates reach our servers for the search; we do not save them in your profile or in a dedicated archive, but they may appear in the servers’ technical logs (for example in request addresses);
• on the home screen, if the permission is already granted, to suggest nearby content (same rules: the coordinates reach our servers, we do not save them in your profile or in a dedicated archive, and they may appear in the technical logs);
• when you update your city in your profile, the coordinates used are kept for 90 days, together with your IP address, in your account’s security log; your profile keeps only the city;
• with MINA, to start from where you are: the coordinates are sent to the AI provider together with your request (see “MINA”) and are saved on your device so that the app can find them next time;
• in issue reports, to centre the map and to calculate how far you were from the reported spot (we keep only the distance, not your position);
• on the events page, to find the name of your locality through the OpenStreetMap Nominatim service.

You can deny or revoke the permission at any time in your device settings: the app keeps working with the city you declared.

If you are a merchant

Account data and, for the traceability of traders required by Art. 30 DSA: legal name, registered and operating address, VAT or tax number (checked against public registers: ANAF for Romania; in Italy, confirmation by the City Agent), customer contact details (email and telephone), and a self-declaration of compliance. Legal name, address and public contact details appear on your page; tax data does not. What you publish on your page (description, photos, opening hours, offers) is public by your choice. We may enrich your business description automatically with an artificial intelligence system that consults public sources on the web: see “Other uses of artificial intelligence”.

If you are a City Agent, Subagent, Country Manager or distributor

Contact and identification data for the contractual relationship, assigned territory, commissions and payments, operational notes. City Agents and Subagents do not have access to the personal data of citizens in their territory: they see only aggregated figures and public merchant data. The same applies to the Country Manager — see “City Agents and Country Managers”.

If you are a municipality’s responsible officer

Name, institutional email, municipality and role; the messages you send (which stay associated with you as author); and your choice whether to show your name on the municipality’s public page. See “Services for municipalities”.

If you write to us through the contact form

See “Contact requests”.

If you visit the site or public pages without an account

IP address, browser type, referring page, date and time, in the logs of our servers and of Cloudflare, for security. See also “Usage statistics (Matomo)” and the Cookie Notice.

Purposes and legal bases

Purpose	Data involved	Legal basis
Service delivery: account, sign-in, push notifications, RSVPs, loyalty cards, MINA, merchant page, wallet	Data for your role	Art. 6(1)(b) GDPR — performance of a contract
Security, anti-fraud, anti-abuse	IP, browser, access logs, failed attempts	Art. 6(1)(f) — legitimate interest
Legal obligations: invoicing, accounting, authority requests, DSA	Billing data, DSA data of merchants	Art. 6(1)(c) — legal obligation
Transactional emails (codes, receipts)	Email, language, the triggering event	Art. 6(1)(b) — performance of a contract
Usage statistics (Matomo)	See the dedicated section	Art. 6(1)(f) — legitimate interest
Municipal communications and alerts	Declared city, preferences, push token	Art. 6(1)(f) — legitimate interest, with the right to object by switching them off
Replying to contact requests	Form data	Art. 6(1)(b) — pre-contractual steps at your request
Exercising or defending a right	Data relevant to the dispute	Art. 6(1)(f) — legitimate interest

We do not use your data for behavioural marketing or advertising profiling, and we do not sell it.

What we DON’T do

• No advertising. We do not sell advertising space and do not receive payments from advertisers.
• No behavioural targeting. We do not build advertising profiles.
• No sale or transfer of your personal data to third parties, for any purpose.
• No third-party trackers such as Google Analytics, Meta Pixel, LinkedIn Insight Tag, TikTok Pixel, Hotjar or Mixpanel. The only analytics tool we use is Matomo, which we host ourselves.
• No advertising use of push content: we do not read notifications to profile you (see “How push notifications travel”).
• No exposure of your personal data to the merchants you follow. They know how many followers they have and can send you notifications, but they cannot see your name, email, phone number or location.
• No third-party profiling cookies: the few technical cookies we use are described in the Cookie Notice.

Usage statistics (Matomo)

To know how many people use our pages and app, and which content works, we use Matomo, an open-source tool that we host ourselves at matomo.minomo.io: the data does not go to Google or to any other third party.

• No cookies, no identifier stored on your device for statistics: Matomo runs with cookies disabled (disableCookies).
• Aggregate statistics: pages viewed, links tapped, approximate country or region, whether you come from the web or from the apps. We do not give Matomo your account identifier, so we do not link visits to your account and do not follow you across devices.
• Do Not Track is not applied. Matomo measures visits even if your browser sends a Do Not Track signal; because we do not use cookies or identifiers, this measurement is limited to the aggregate statistics described above.

Legal basis: our legitimate interest (Art. 6(1)(f) GDPR) in measuring and improving the service. You can object at any time by writing to [email protected]. More detail is in the Cookie Notice.

How push notifications travel

Notifications you receive from a merchant, a City Agent or your municipality are written in the sender’s panel and pass through our servers, which store them in order to deliver, count and bill them. The content (title, text, link, image) is always encrypted in transit (HTTPS/TLS); for the web version of the app it is also encrypted with your browser’s keys under the Web Push standard (RFC 8291), so the web push service cannot read it. MINOMO, which writes and stores the notification, sees it in clear.

To deliver them to phones we use Google services (Firebase Cloud Messaging, for Android and — through the same service — for iOS via Apple Push Notification service): these gateways receive the title and text of the notification and your device token, not your name or email.

We do not read notifications to profile you and we do not use them for advertising. Merchants you follow cannot see who you are: they only receive totals (how many people received, opened, tapped the button).

We keep sent notifications for 90 days, the per-device delivery log for 90 days, and open receipts (a code containing neither your name nor your device) for 30 days.

MINA — AI assistant

MINA is a conversational assistant powered by generative artificial intelligence. Pursuant to Art. 50 of Regulation (EU) 2024/1689 (AI Act), we inform you that when you use MINA you are interacting with an artificial intelligence system, not a person.

What we send to the AI provider. Your questions and the preferences you type, the city and language, and — if you choose to start from where you are, or to search “near me” — the coordinates of your position. We send them to Anthropic, PBC (United States; see Providers and subprocessors). We do not send your name, your email or your account identifier. Please do not tell MINA personal data about yourself or others that the question does not need.

What we keep. The text of your questions and of MINA’s answers, with city, language and date, to run the service, correct errors and produce aggregate statistics. MINA conversations are deleted automatically after 90 days, every night. For walking tours we also keep, linked to your device and not to your name, the places suggested and those you visited, so as not to suggest them again; this history has no automatic expiry today and is deleted on request at [email protected]. If you save a tour, it is saved in your account.

Training. MINOMO does not use your conversations to train artificial intelligence models.

Limits. MINA can be wrong; its answers are not professional advice. It is optional: you can use everything else on MINOMO without ever using MINA.

Other uses of artificial intelligence

Besides MINA, we use artificial intelligence models from Anthropic, PBC to:

• check the text of issue reports before they are shown on the map (offensive language, other people’s personal data, advertising). We send the model only the text and the category, never who wrote them. The check does not decide anything: if it flags a problem, the report stays visible only to its author until a municipal officer reviews it;
• read the event pages that City Agents indicate as sources, to propose events to them;
• write or enrich the descriptions of merchants from public information on the web;
• suggest text to merchants while they fill in their profile at onboarding.

On minomo.io there is also an AI-based chat assistant (InfoPilot). It is loaded only when you click to open it. When you use it you are talking to an artificial intelligence system, not a person, and what you write in the chat is processed by InfoPilot to answer you.

None of these systems takes decisions that produce legal effects on you.

Services for municipalities

Municipalities can use MINOMO to write to citizens (MINOMO Alert), to run non-binding public consultations, to receive issue reports and to publish a public city page. Each service has its own appendix explaining in detail what we process: Municipal messages · Public consultations · Issue reporting · Municipal pages.

In short:

• The municipality does not see who you are. In reports you appear as a “verified citizen”; in consultations your vote is separated from your identity; for messages the municipality only sees how many people it reached.
• What counts is the city you chose and your preferences, not your location.
• Roles. AVi Kairos Srl is the controller for your account, the app, security and retention of data; the municipality is a separate controller for the content it publishes and for handling the cases it receives. The appendices say who decides what.
• Municipal messages are on by default for the city you set in your profile. The legal basis is our legitimate interest in providing you with your city’s civic service, and you can object at any time by switching them off (Account → Communications from my municipality): from then on you receive neither messages nor urgent alerts.

If you are a municipality’s responsible officer. We process your name, institutional email, municipality and role to give you access to the panel (Art. 6(1)(b) GDPR, within the relationship between the municipality and AVi Kairos Srl), and we record you as the author of the messages you send and of your actions on consultations (Art. 6(1)(f): traceability of published acts). Your name appears on the municipality’s public page only if you chose so in the panel; you can change your mind at any time.

For data protection matters concerning civic services, municipal offices and the municipality’s own Data Protection Officer can write to [email protected], stating the municipality’s name in the subject line.

City Agents and Country Managers

City Agents and Subagents are local consultants who look after the MINOMO network in a city, under a contract with the Country Manager of their country or, where there is none, with AVi Kairos Srl. They do not legally represent AVi Kairos Srl and do not see the personal data of citizens.

The Country Manager, where present, sees through the MINOMO panels the master records of merchants, City Agents and Subagents in their national network (company name, contact person, contact details, tax data, licence status) and the illegal-content notices concerning their country. The Country Manager does not access the individual data of consumers: of these, including conversations with MINA, they see only aggregated statistics.

With respect to the network records, AVi Kairos Srl and the Country Manager act as joint controllers under Art. 26 GDPR, limited to managing, coordinating and developing the national commercial network and handling notices. You may exercise your rights against either of them; our point of contact remains [email protected].

Anonymous civic consultations

Some municipalities use MINOMO to run civic consultations: you are presented with an issue and can express a preference with a single tap. The consultation is non-binding and designed to be anonymous:

• We separate “who took part” from “what was voted”. A participation register records only that your account took part in a given consultation, solely to prevent double voting. Your choice is counted separately as a plain aggregate counter, with no reference to your account.
• The link is deleted when the consultation is sealed. The participation register is deleted at the seal, which is the step with which the municipality certifies the result after the consultation has closed; only the aggregate figure remains.
• Results hidden until closing. Outcomes are not visible during voting.
• Civic notification without tracking. The notification inviting you to take part does not link your device or identity to your vote.
• Publicly verifiable register. At the seal we publish a cryptographically signed certificate of the aggregate results only.

Contact requests

If you write to us through the contact form (as a merchant, a municipality or a prospective City Agent) or from the app to suggest a business, we process the data you enter — name, email, telephone if you give one, organisation or business, role, message and the other fields of the form — together with your IP address and browser type, to reply and follow up on your request. The legal basis is taking steps at your request before a contract (Art. 6(1)(b) GDPR) and, for IP address and browser, our legitimate interest in preventing abuse of the form (Art. 6(1)(f)). We keep this data for as long as it is needed to follow up your request or to carry out a contract that follows; you can ask us at any time to delete it by writing to [email protected].

Providers and recipients

To run MINOMO we rely on a small number of specialist providers. The complete, versioned list is at minomo.io/en/legal/subprocessors/ and forms part of this Policy. The categories are:

• Infrastructure: application servers and databases, image hosting, content delivery network, perimeter security, and the routing of municipal pages on municipalities’ domains;
• Communications: transactional email, push notification gateways (Android and iOS);
• Artificial intelligence: the provider that powers MINA and the other uses described above, and the chat assistant InfoPilot;
• Payments: the Merchant of Record that processes wallet top-ups;
• Sign-in: Google and Apple, if you choose them;
• Maps and geographic services: see the next section;
• Native app builds: the platform that compiles the iOS and Android apps.

We may also disclose your data to competent authorities (law enforcement, judicial authorities, data protection authorities, DSA supervisory bodies) to the extent and in the manner required by law. If a competent authority asks us through the proper channels, we may have to disclose the identity of the author of a civic report.

Maps and third-party services in the app

To show maps the app downloads map images from CARTO and OpenStreetMap: these services receive your IP address and the area of the map you are viewing, which may be centred on your position. For the walking route of MINA tours we send the start and stop coordinates to OSRM; to find the name of your locality on the events page we send your coordinates to OpenStreetMap Nominatim; for the weather on the home screen we ask Open-Meteo for the weather at the city’s coordinates, not yours. The QR code of a loyalty card is generated by a QR image service (api.qrserver.com), which receives the value encoded in the code. These services do not receive your name or your account.

Transfers outside the EEA

Some of our providers are based in the United States or the United Kingdom.

• United States: where the provider adheres to the EU-U.S. Data Privacy Framework (European Commission adequacy decision of 10 July 2023), the transfer is covered by that decision; otherwise we rely on the Standard Contractual Clauses of Decision (EU) 2021/914.
• United Kingdom: the transfer is covered by the European Commission’s adequacy decision of 28 June 2021.

You can ask for a copy of the safeguards applied to a specific provider by writing to [email protected].

Retention periods

Category	Period	Reason
Active account	For the lifetime of the account	Performance of the contract
Deleted account	Deactivated immediately; deleted or anonymised within 30 days	Abuse prevention
Billing records and wallet transactions	10 years	Art. 25 Romanian Accounting Law no. 82/1991
Access logs and failed attempts	30 days	Security
Account security events (including the coordinates used to update your city)	90 days	Security
Email sign-in codes and expired sessions	No automatic deletion at present	Security
Inactive devices	7 days; without active push notifications, 30 days	Technical clean-up
Sent notifications and delivery log	90 days	Delivery, billing
Notification open receipts	30 days	Aggregate statistics for senders
Loyalty transactions	30 days. Expired cards have a 30-day grace period; then the card and its transactions are deleted	Programme operation
MINA conversations	Deleted automatically after 90 days; when the account is deleted, within the 30 days above, the conversations are anonymised	Service operation and quality
MINA tour history, linked to the device	No automatic expiry; deleted when the account is deleted, within the 30 days above; otherwise deletion on request at [email protected]	Not suggesting the same places again
Issue reports	Author, IP address and device type cleared 12 months after the report is closed	See the appendix
Consultation participation register	Until the consultation is sealed	See the appendix
Merchant DSA Art. 30 data	For as long as the merchant page is active and for six months after it ends (Art. 30(3) DSA), unless accounting law requires a longer period for the same data	DSA traceability
Full database backups	14 days	Recovery after faults or incidents

Your rights

You may exercise the following rights at any time, free of charge, without giving reasons:

• Access (Art. 15): confirmation of processing and a copy of your data.
• Rectification (Art. 16): correct inaccurate or incomplete data.
• Erasure (Art. 17): erasure of your data, within the limits of the law.
• Restriction (Art. 18): temporary suspension of processing in specific cases.
• Portability (Art. 20): receive your data in a structured, commonly used format. There is no export button: we prepare the file by hand after your request.
• Objection (Art. 21): object to processing based on legitimate interest, for example by switching off municipal communications in the app.
• Withdrawal of consent, where processing is based on consent.
• Automated decisions (Art. 22): MINOMO does not take decisions about you that are based solely on automated processing and produce legal effects on you.

How: write to [email protected] from the email address of your account (see Exercise your GDPR rights). We reply within one month, which may be extended by two further months for complex requests, with a reasoned notice.

Deleting your account: you can do it from the app (Account → Permanently delete account) or by following this page. The account is deactivated immediately, and the data linked to it is deleted or anonymised within 30 days.

Complaint to the supervisory authority:

• ANSPDCP (Romania) — dataprotection.ro
• Garante per la protezione dei dati personali (Italy) — garanteprivacy.it
• the authority of the country where you habitually live; the list is at edpb.europa.eu

Minors

MINOMO is intended for persons aged 18 or over. If we become aware of an account registered by a minor, we suspend it and delete the data collected. If you are a parent or guardian and believe a minor in your care has an account, write to [email protected].

Security and data breaches

We protect your data with, among other measures:

• encrypted connections (HTTPS/TLS) on public endpoints;
• two-factor authentication available for panel accounts;
• access to data limited to the people who need it;
• access logs.

If a personal data breach poses a risk to your rights and freedoms, we notify the competent supervisory authority within 72 hours (Art. 33 GDPR) and, where the risk is high, we also tell you directly (Art. 34 GDPR).

Changes to this Policy

When we update this Policy we change the version number and date at the top. If the change is material — it affects your rights, the purposes, the providers or the countries of processing — we notify you with at least 30 days’ notice, by email and in the app. Previous versions are summarised in the change log below.

Change log

Version	Date	Main changes
3.4	7 October 2026	MINA conversations are deleted automatically after 90 days.
3.3	7 October 2026	Aligned the Policy with how MINOMO works today. Corrected: account deletion, retention periods, location, Matomo (no account identifier; Do Not Track not applied), the role of the Country Manager, the legal basis of municipal communications, the moment when the consultation participation register is deleted. Added: privacy contact (no DPO), services for municipalities and the new appendices, contact requests, other uses of artificial intelligence, maps and third-party services in the app. Removed: references to passwords and conversational memory, which do not exist. Added: Google profile picture address, database backups (14 days).
3.2	7 October 2026	Corrected the description of push notifications (how they travel, what MINOMO stores, what Google FCM and Apple APNs receive). Removed the section on a federated identity service that is not offered.
3.1	30 May 2026	Added section on anonymous civic consultations. Added pointer to dedicated account-deletion page. Clarified City Agent–Country Manager contractual chain and joint controllership (Art. 26 GDPR).
3.0	15 May 2026	Complete rewrite aligned with the MINOMO consumer + merchant + City Agent + Municipalities model, introduction of MINA, prepaid wallet, dedicated sections on the DSA and the AI Act.
2.x	up to 14 May 2026	Legacy version inherited from the previous platform, no longer applicable.

Contact

• Privacy: [email protected]
• Exercising your rights: minomo.io/en/legal/data-request/
• Postal address: AVi Kairos Srl — Strada Lungă 188, Corp C2, Ap. 2, Brașov 500051, România
• General contact: [email protected]
• DSA point of contact: [email protected]