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 — the dedicated point of contact is [email protected] or the form at minomo.io/en/legal/data-request/.

AVi Kairos Srl does not fall within the cases of mandatory appointment of a Data Protection Officer under Art. 37 of Regulation (EU) 2016/679 (GDPR). We have nonetheless designated an internal privacy contact reachable at the address above.

What MINOMO does

MINOMO is a proximity digital infrastructure that connects citizens, merchants, municipalities, and local curators (City Agents) through a direct channel — free from algorithmic intermediaries and 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, indexable by search engines and AI assistants;
• end-to-end encrypted 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 (multi-merchant digital wallet) with points, rewards, and redemption codes;
• events with RSVP and automated push reminders;
• MINOMO Atlas, an editorial directory of local European life, publicly accessible;
• MINOMO Identity Shield (at id.minomo.io): a privacy-first federated identity service that masks your real email from partners and propagates data erasure to them with a single click;
• tools for municipalities and for City Agents — the local consultants who editorially curate MINOMO’s presence in a given city.

This Policy covers the processing of personal data by AVi Kairos Srl across all the services listed above, accessible through the domains minomo.io, app.minomo.io, cdn.minomo.io, admin.minomo.io, id.minomo.io, and the native applications distributed via the App Store and Google Play.

Who this Policy applies to

The rules described below apply to everyone who comes into contact with MINOMO. In particular:

• Consumer citizens: adults who register to follow merchants, events, and places in their city;
• Followers: users who have chosen to follow one or more merchants, City Agents, or MINOMO pages;
• 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, and Country Managers: local consultants who editorially curate the MINOMO network in a given area;
• Representatives of municipalities and public bodies who use MINOMO for civic communications;
• Visitors to the MINOMO marketing site minomo.io, public merchant pages (/m/{slug}), City Agent pages (/a/{slug}), events, and MINOMO Atlas.

This Policy does not cover the processing of personal data carried out independently by third parties (for example: a merchant who chooses to contact a follower outside of MINOMO). In those cases, the third party’s own privacy policy applies.

Categories of data we collect

We collect only the data strictly necessary to run the services you have chosen to use. The categories differ depending on your role.

All registered users (consumers, merchants, City Agents):

• Account data: email address, hashed password (never the password in plain text), preferred language, time zone.
• Technical identifiers: device ID, authentication token, identifiers of active sessions.
• Access logs: IP address, user-agent, login timestamp, failed login attempts (for security and anti-fraud purposes).
• Analytics identifier (Matomo, pseudonymous): to recognise that your account is the same across devices and platforms (web, iOS app, Android app — all of which load the same PWA), our self-hosted Matomo analytics receives a salted SHA-256 hash of your account ID, never your raw account ID, email, or any other personal identifier. This hash cannot be reversed to identify you and is not an advertising identifier.
• Service communications: transactional emails (account verification, forgotten password, receipts, OTPs).

Consumer users (citizens, followers):

• Account and contact: your email address. It is the only contact detail we ask of you and is used to sign in, recover your profile, and find it again when you connect from another device. We do not ask for your phone number.
• Profile: display name, language, reference city declared at registration.
• Avatar: profile picture (if uploaded).
• Geolocation: City anchor (the city you declared, stored server-side) and Precise location (GPS) — used only when you turn on location-based features such as “Near me” in Explore or MINA’s guided tours. We read it only while you are actively using these features (not in the background); you can deny or revoke the permission at any time from your device settings.
• Follow graph: the list of merchants, City Agents, and pages you have chosen to follow.
• Push subscriptions: your device token for notification delivery (FCM on Android, APNs on iOS, Web Push on PWA) and your opt-in/opt-out preferences by category.
• Interaction history: push notification opens (technical opt-in tracking, never content-based), offer clicks, event RSVPs, loyalty card activations.
• Loyalty cards: for each loyalty programme you have activated, the points balance and transaction history with that merchant.
• Conversations with MINA: the prompts you send to the AI assistant and the responses you receive, retained as explained in the MINA section.
• Identity Shield alias: if you access a third-party service via our identity provider, we store the mapping between your MINOMO identity and the alias generated for that partner.

Merchants (Bio Page, add-ons, payments):

For merchants we collect, in addition to account data, the information required by Art. 30 of the DSA Regulation to ensure traceability of professionals towards consumers:

• Legal name of the business or sole trader;
• Address of the registered office and of the commercial premises;
• Tax identification number / VAT number (CUI in Romania, P.IVA in Italy), validated in real time via public registry services;
• Support contact (email and telephone);
• Self-declaration of compliance of the products or services offered with applicable EU rules.

Some of this data — legal name, business address, public contact — is publicly disclosed on the merchant’s Bio Page (/m/{slug}), as required by the DSA. Strictly fiscal data is not public and remains accessible only to AVi Kairos Srl and the merchant themselves.

City Agents, Subagents, Country Managers: For local consultants we collect account data, identification and contact data required for the contractual relationship, the assigned territory, the history of commissions earned and payments made, and internal operational notes. City Agents do not have access to the personal data of followers in the territory they manage: they see only aggregated statistics and public data about merchants in their area.

Unregistered visitors: When you browse MINOMO’s public pages without being registered, we collect only: IP address, user-agent, referring page, and timestamp. These data remain in server logs for 12 months and are used exclusively for security purposes, abuse prevention, and anonymous aggregate statistics.

For anonymous aggregate audience measurement (pages viewed, links clicked, approximate location) we use Matomo, an open-source analytics tool that we self-host at matomo.minomo.io — a first-party tool, never a third party. It runs cookieless (no cookies or device fingerprint are set) and your IP address is anonymised server-side before storage. See “Analytics: Matomo” below for full detail. On MINOMO’s public pages there is no Google Analytics, Meta Pixel, LinkedIn Insight Tag, TikTok Pixel, or any other third-party tracking tool.

Purposes and legal bases

We process your personal data only for specific, legitimate purposes, each of which rests on a legal basis under the GDPR.

Purpose	Data involved	Legal basis
Service delivery: creating and managing your account, publishing the Bio Page, delivering push notifications, event RSVPs, loyalty point redemption, conversations with MINA, wallet payments.	All data collected for your role.	Art. 6(1)(b) GDPR — performance of a contract.
Security, anti-fraud, anti-abuse: detecting suspicious access, blocking brute-force attempts, preventing spam.	Access logs, failed attempts, IP, user-agent.	Art. 6(1)(f) GDPR — legitimate interest.
Compliance with legal obligations: invoicing, accounting records, responding to authority requests, DSA reports, GDPR rights requests.	Billing data, DSA identification data for merchants, transaction history.	Art. 6(1)(c) GDPR — compliance with a legal obligation.
Service communications: transactional emails (account verification, OTPs, receipts, system notifications).	Email, preferred language, the event that triggered the communication.	Art. 6(1)(b) GDPR — performance of the contract.
Personalisation of MINA: adapting the AI assistant’s responses to your city’s context and explicitly expressed preferences.	Reference city, language, conversations with MINA.	Art. 6(1)(b) GDPR for basic operation; Art. 6(1)(a) — consent — for any advanced conversational memory features.
Anonymous aggregate statistics: number of followers per merchant, notification trends by city, category popularity.	Aggregate data derived from usage, without personal identifiers.	Art. 6(1)(f) GDPR — legitimate interest.
Exercising or defending a right: responding to disputes, handling complaints, legal proceedings.	All data relevant to the dispute.	Art. 6(1)(f) GDPR — legitimate interest.

We do not use your data for behavioural marketing, advertising profiling, or sale or transfer to third parties.

What we DON’T do

The most important part of this Policy is what does not happen on our systems:

• No advertising. We do not sell advertising space, we do not receive payments from advertisers, we do not sponsor third-party content.
• No behavioural targeting. We do not build advertising profiles based on your activity, your inferred interests, or your social connections.
• No sale or transfer of your personal data to third parties. Ever. For any purpose. We do not rent it, swap it, or share it with data brokers.
• No third-party trackers on public pages or in the app: no Google Analytics, no Meta Pixel, no LinkedIn Insight Tag, no TikTok Pixel, no Hotjar, no Mixpanel. The only analytics tool we use is Matomo, which we self-host as a first-party service — see “Analytics: Matomo” below.
• No reading of push notification content on our part: the payload is end-to-end encrypted.
• No exposure of your personal data to merchants who you follow. When you follow a merchant, they can send you notifications and they know their total follower count, but they cannot see your name, email, phone number, precise location, or any other personal data.
• No third-party profiling cookies: the few technical cookies we use are described in the Cookie Notice.

These limitations are not mere statements of intent: they are technical architecture decisions.

Analytics: Matomo (self-hosted, cookieless)

To understand how MINOMO’s pages and app screens are used — page views, link clicks, approximate geographic origin, and whether traffic comes from the web, the iOS app, or the Android app — we use Matomo, an open-source analytics tool that we self-host at matomo.minomo.io. Matomo is a first-party tool: it runs on our own infrastructure, it is not operated by a third party, and it is not Google Analytics.

• Cookieless. Matomo runs with cookies disabled (disableCookies): it does not write or read any cookie or device fingerprint. Because nothing is stored on or read from your device, this does not require a consent banner under the GDPR/ePrivacy framework.
• IP address anonymised. Your IP address is anonymised server-side before any data is stored.
• Pseudonymous account stitching. If you are signed in, we let Matomo recognise that the same account is being used across devices and platforms — web, the iOS app, and the Android app, all of which load the same PWA — by passing it a salted SHA-256 hash of your account ID. This hash is a one-way pseudonym: it is never your raw account ID, your email, or any other personal identifier, it cannot be reversed to identify you, it is not an advertising identifier, and it enables no cross-app or cross-site tracking outside MINOMO.
• Data collected: pages viewed, links clicked, approximate location derived from the anonymised IP, browser/user-agent, referrer, and a custom “platform” dimension (web/iOS/Android).
• No Google Analytics, no third-party trackers. We do not use Google Analytics, Meta Pixel, or any other third-party analytics or advertising tool anywhere on MINOMO.

Legal basis: legitimate interest (Art. 6(1)(f) GDPR) in measuring and improving the service in a privacy-preserving way. Retention: raw analytics data is kept for 26 months, after which it is anonymised. Full technical detail — including the cookie/storage inventory and the legal basis for the absence of a consent banner — is in the Cookie Notice.

End-to-end encrypted push notifications

The push notifications you receive on MINOMO travel end-to-end encrypted between the merchant’s device and your device. This means:

• the message content — text, title, image, link — is encrypted with a key derived from your device;
• our servers cannot read the payload in plain text: we see only operational metadata (who is sending, to how many recipients, at what time, with what priority);
• the third-party gateways responsible for physically transporting notifications (Google FCM for Android, Apple APNs for iOS, standard Web Push for the PWA) receive the payload already encrypted and cannot read it;
• only your device, upon receipt, decrypts the content and displays it to you.

The metadata that remains on our servers is used for reliable delivery, anti-abuse purposes, and merchant wallet billing, and is retained for the minimum time necessary.

MINA — AI assistant

MINA is a conversational assistant powered by generative artificial intelligence, currently available within the PWA at app.minomo.io. Pursuant to Art. 50 of Regulation (EU) 2024/1689 (AI Act), we explicitly inform you that when you interact with MINA you are interacting with an artificial intelligence system, not a human operator.

When you send a question to MINA, the following happens:

1. your prompt is sent from our servers to a third-party artificial intelligence service provider with whom we have a data processing agreement;
2. the third-party provider processes the prompt, generates a response, and returns it to our servers;
3. we optionally enrich the response with public MINOMO data (POIs, events, merchants in your city) before presenting it to you.

What we retain: Prompts and responses are retained for the time necessary to provide you with a conversational experience (recent history) and to improve service quality on aggregated data. We do not use your conversations to train third-party artificial intelligence models. Our agreements with AI providers explicitly exclude the use of MINOMO prompts for training.

Opt-out: You can use all other MINOMO services without ever interacting with MINA. It is an optional tool, activated only by your explicit input.

MINOMO Identity Shield

Identity Shield is our privacy-first federated identity service, accessible at id.minomo.io. When a partner integrates Identity Shield and you choose to access their services via our identity provider, we generate a unique email alias for that partner and provide it to the partner as “your” email for that relationship. The partner never sees your real email.

Propagated erasure (Art. 17 GDPR as a service): If you decide to end your relationship with a partner, from a single page in your Identity Shield account:

1. we immediately deactivate the forwarding of emails from the alias to your real inbox;
2. we send the partner a formal erasure request under Art. 17 GDPR;
3. we monitor the response: the partner has 30 days to confirm actual erasure or to justify any retention;
4. we display the outcome in your Identity Shield dashboard and contribute to the partner’s public Privacy Score.

In relation to the data it handles, AVi Kairos Srl acts as data controller of the mapping between your MINOMO identity and the aliases generated.

City Agent, Subagent, Municipalities

City Agents and Subagents do not see the individual personal data of followers and citizens in the territory they manage — they see only aggregated metrics and public data about merchants.

The Country Manager, where present, accesses — through the MINOMO platform — the master records of merchants, City Agents and Subagents in their national network (company name, contact person, contact details, tax data, licence status). The Country Manager does not access the individual data of consumers/followers: of these they see only aggregated and statistical data.

With respect to these network records, AVi Kairos Srl and the Country Manager act as joint controllers within the meaning of Article 26 GDPR, limited to the purposes of managing, coordinating and developing the national commercial network. Regardless of this allocation, you may exercise your rights by contacting either of the joint controllers; 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 is designed from the ground up to be anonymous:

• We separate “who took part” from “what was voted”. We record in a participation list only the fact that your account voted in a given consultation — solely to prevent double voting. Your choice is tallied separately as a plain aggregate counter, with no reference to your account.
• At closing we delete the link. The participation list is permanently deleted and 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 closing we publish a cryptographically signed certificate of the aggregate results only.

Recipients and suppliers

To run MINOMO we rely on a small number of specialist suppliers. The complete, up-to-date, and versioned list is available at minomo.io/en/legal/subprocessors/. Suppliers fall within the following general categories:

• Infrastructure: application servers and databases, image and file hosting, content delivery network (CDN), perimeter security services.
• Communications: transactional email delivery (SMTP provider), native push notification gateways (Android and iOS).
• Artificial intelligence: the third-party provider that powers MINA.
• Payments: the Merchant of Record that processes wallet top-ups and associated transactions.
• Social authentication: OAuth providers (Google, Apple) activated if you choose to sign in via one of these services.
• Native app builds: the continuous integration platform that compiles the iOS and Android apps.

We may also disclose your data to competent authorities (law enforcement, judicial authorities, data protection supervisory authorities, DSA supervisory bodies) to the extent and in the manner required by law.

Transfers outside the EEA

Some of our suppliers are based in the United States or in other countries outside the European Economic Area (EEA). Transfers of personal data to those countries are subject to specific legal safeguards:

• United States: where the supplier adheres to the EU-U.S. Data Privacy Framework approved by the European Commission’s adequacy decision of 10 July 2023, the transfer is covered by that decision. In addition, we apply the Standard Contractual Clauses 2021/914/EU, supplemented by a Transfer Impact Assessment (TIA).
• United Kingdom: the transfer is covered by the European Commission’s adequacy decision of 28 June 2021.
• Other non-EEA countries: we apply the Standard Contractual Clauses 2021/914/EU.

You may request a copy of the Standard Contractual Clauses and the Transfer Impact Assessment by writing to [email protected].

Retention periods

Category	Period	Reason
Active account data	For the lifetime of the account	Performance of the contract
Account data after erasure	30 days in reversible “soft delete”, then anonymisation or deletion	Account recovery option, abuse prevention
Billing records and wallet transactions	10 years	Fiscal and accounting obligations
Security logs (access, failed attempts)	12 months	Security and anti-fraud
Session authentication tokens	Until explicit revocation or natural expiry	Maintaining the login session
Push subscriptions (device token)	Until app uninstall, revocation, or technical token expiry	Notification delivery
Push notification interaction history (opens, clicks)	13 months rolling, then anonymous aggregation	Operational metrics
Active loyalty cards	For the lifetime of the merchant’s loyalty programme plus up to 24 months after closure	Programme execution, dispute management
Analytics data (Matomo, pseudonymous account hash)	26 months, then anonymised	Legitimate interest in measuring and improving the service
MINA conversations — recent history	90 days	Continuous conversational experience
MINA conversations — anonymous aggregate archive	24 months, in a form not attributable to any individual	Service improvement
Identity Shield aliases	For the lifetime of the relationship with the partner, plus 12 months after propagated erasure	Traceability of the propagated erasure request
Merchant DSA Art. 30 data	For the lifetime of the public page plus 5 years after closure	Traceability under the DSA
Support tickets and correspondence	36 months from ticket closure	Support continuity
Website logs (unregistered visitors)	12 months	Security, aggregate statistics

Your rights

The GDPR grants you a series of rights that you may exercise at any time, free of charge, without having to give reasons for your request:

• Right of access (Art. 15 GDPR): obtain confirmation of processing and a copy of your data.
• Right to rectification (Art. 16): correct inaccurate or incomplete data.
• Right to erasure (Art. 17, “right to be forgotten”): obtain the erasure of your data, within the limits provided by law.
• Right to restriction of processing (Art. 18): request a temporary suspension of processing in specific cases.
• Right to data portability (Art. 20): receive your data in a structured, commonly used, and machine-readable format.
• Right to object (Art. 21): object to processing based on legitimate interest.
• Right to withdraw consent: where processing is based on consent, you may withdraw it at any time.
• Right not to be subject to automated decision-making (Art. 22): MINOMO does not make decisions about you that are entirely automated.

How to exercise them: Via the form at minomo.io/en/legal/data-request/ or by writing to [email protected]. We will respond within 30 days.

Account deletion: If you want to delete your entire account and the associated data, you can do so directly from the app (Account → Delete account) or via the web request page at minomo.io/en/legal/delete-account/.

Complaint to the supervisory authority: If you believe that the processing of your personal data infringes the GDPR, you may lodge a complaint with the competent supervisory authority:

• ANSPDCP (Romanian Data Protection Authority) — dataprotection.ro
• Garante per la protezione dei dati personali (Italian) — garanteprivacy.it
• the supervisory authority in your country of habitual residence; the list of EEA authorities is at edpb.europa.eu

Minors

MINOMO is intended for persons who have reached the age of 18. If we become aware of an account registered in the name of a minor, we suspend it and proceed with erasure of the data collected. If you are a parent or guardian and believe that a minor in your care has created a MINOMO account, please write to [email protected].

Security and data breaches

We have implemented appropriate technical and organisational measures to protect your data, including:

• encryption in transit (HTTPS/TLS 1.2 or higher on all public endpoints);
• encryption at rest for databases and file storage;
• end-to-end encryption for push notification content;
• two-factor authentication available for high-exposure accounts;
• data access limited to authorised personnel on a need-to-know basis;
• security monitoring, automated anomaly detection, and incident response procedures.

If a personal data breach occurs that poses a risk to your rights and freedoms, we will:

1. notify the competent supervisory authority within 72 hours pursuant to Art. 33 GDPR;
2. communicate the incident directly to you, in clear language, where the breach entails a high risk (Art. 34 GDPR).

Changes to this Policy

We may update this Policy over time. When we do:

• we update the version number and date shown at the top of the document;
• if the change is material — meaning it affects your rights, the purposes, the suppliers, or the countries of processing — we will notify you proactively with at least 30 days’ notice, by email and via an in-app notice;
• we retain previous versions in the change log below.

Change log

Version	Date	Main changes
3.1	30 May 2026	Added section on anonymous civic consultations (Civic Polling). 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 Identity Shield, 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

For any question, request, or report relating to the protection of your personal data:

• Privacy email: [email protected]
• GDPR request form: 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]