Minno Privacy Policy

Version 2026-11-07 · Last updated 7 November 2026

Minno is provided by Rook Industries, Inc., 30 N Gould St Ste R, Sheridan, WY 82801 ("Rook", "we"). This policy explains what we collect, why, how long we keep it and your choices. It is written for three groups: our customers (businesses that integrate Minno), website visitors, and the people whose face is checked inside a customer's product ("end users").

The short version

1. Our two roles

For end users' checks (Session Data): the business that integrated Minno is the controller (or "business" or "private entity" under biometric laws). Rook is its processor. We act only on its instructions under our Data Processing Agreement and Biometric Data Policy. If you were asked to do a liveness check, the notice and consent came from that business, and your questions and rights requests go to it first. We will help it respond.

For customers and visitors: Rook is the controller of account, billing, support and website data.

2. If your face was checked inside a customer's product

What happens. The business's app captures a short video of your face and streams it directly from your device to our cloud provider's liveness service. The provider returns a decision (live or not) and a confidence score. If the business asked for a comparison, it supplies an ID portrait and the provider returns a similarity score.

What Rook receives and keeps. The decision, the scores, timestamps, a session ID, the business's reference tag for its own customer (which may be a pseudonymous ID), and the status of the session. Rook does not receive or store the video, any image, or any biometric template. If the business requests the reference frame, it passes through Rook once to the business and is not retained by Rook.

What the cloud provider does. Amazon Rekognition Face Liveness processes the capture in the United States (or another non-Canadian region chosen by the business). AWS states that it retains liveness session data only for a short period to return results and for service integrity, and that it does not use the data to train or improve its models for Face Liveness without customer opt-in. Rook has opted out of any such use. AWS's practices are governed by its own terms, which Rook has accepted on your behalf as a processor.

How long Rook keeps session metadata. 13 months from the check, so the business can audit and reconcile billing, then deleted. Earlier if the business deletes it or closes its account. See the Biometric Data Policy for the full retention and destruction schedule.

Your rights. Depending on where you live, you may have the right to know, access, correct or delete information, to withdraw consent, or to object. Because the business controls the data, send your request to it. You may also write to privacy@tryminno.com; we will pass the request on and help. We will never ask you for a face image to handle a request.

3. Customers and account holders

WhatWhyKept
Name, company, work email, password hash or sign-in codesRun your account, secure itWhile the account is open, then 30 days
API key hashes, key names, per-key limitsOperate the API, enforce plansWhile the key exists, then 30 days
Usage records per key and per reference tagMetering and billing7 years (tax and accounting records)
Billing contact and invoices; payment details held by our payment providerCharge you, issue invoices7 years
Support messagesHelp you3 years
Security logs (IP address, request metadata)Detect abuse, investigate incidents12 months

4. Website visitors

Standard server logs (IP address, user agent, pages, time) for security and to keep the site running, kept 90 days. No advertising trackers, no third-party analytics cookies. We use only cookies needed to sign you in.

5. Who we disclose information to

We do not sell or share personal information for cross-context advertising. We do not disclose biometric data to anyone except the cloud provider needed to perform the check, as the customer instructs, or as the law requires.

6. Where data is processed

In the United States. Face Liveness has no Canadian region; Canadian customers' end users are processed in the US. Customers outside the US are responsible for the lawful basis of the transfer (the DPA has transfer terms).

7. Security

TLS in transit. API keys stored only as hashes. Device credentials for capture last 15 minutes and allow only the single action of streaming a capture. A key can see only its own sessions. Face images are never written to Rook's disks or databases; our code and tests enforce it. Servers operated by Rook in the United States with no public inbound ports and key-based administrative access. Encrypted backups with restore tests. Report vulnerabilities to security@tryminno.com.

8. Children

Minno is not for anyone under 18. Customers may not use it on children except where the law permits with parental consent, and Rook does not knowingly process children's data.

9. State and regional notices

California (CCPA). Categories collected: identifiers (account email, IP), commercial information (usage, billing), and, for end users as a service provider only, biometric information processed transiently by our cloud provider. Sources: you, your device, our customer. Purposes: as above. We don't sell or share personal information, and we don't use sensitive personal information to infer characteristics. To exercise rights, email privacy@tryminno.com; we don't discriminate for exercising them.

Illinois, Texas, Washington and other biometric laws. Rook's written retention and destruction policy is at tryminno.com/legal/biometric-policy. Rook does not sell, lease or profit from biometric identifiers or information.

EU, UK, Switzerland. For account data our legal bases are contract and legitimate interests (security, billing); for end-user data we act as processor. You have the rights in the GDPR, including to complain to your supervisory authority.

Canada (PIPEDA, Quebec Law 25). Processing occurs in the United States. Our customer is responsible for the privacy impact assessment Quebec requires for biometric systems and for notifying the Commission d'accès à l'information where required.

10. Changes

We will post the new version with its date and email customers about material changes at least 30 days before they take effect.

Contact

privacy@tryminno.com · Rook Industries, Inc., 30 N Gould St Ste R, Sheridan, WY 82801