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
- Minno runs a face liveness check for a business that integrates it. That business, not Rook, decides to run the check and must get your consent first.
- Rook does not store your face. No images, video or biometric templates are kept by Rook. The check is performed by our cloud provider (Amazon Web Services), which deletes the capture under its own terms.
- Rook keeps a record that a check happened, its result and when, so the business can be billed. Not what you look like.
- We don't sell personal information, we don't build face databases, and we don't use checks for anything other than running the service.
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
| What | Why | Kept |
|---|---|---|
| Name, company, work email, password hash or sign-in codes | Run your account, secure it | While the account is open, then 30 days |
| API key hashes, key names, per-key limits | Operate the API, enforce plans | While the key exists, then 30 days |
Usage records per key and per reference tag | Metering and billing | 7 years (tax and accounting records) |
| Billing contact and invoices; payment details held by our payment provider | Charge you, issue invoices | 7 years |
| Support messages | Help you | 3 years |
| Security logs (IP address, request metadata) | Detect abuse, investigate incidents | 12 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
- Amazon Web Services: performs the liveness and comparison; receives the capture stream from the end user's device and any ID portrait you submit. United States or the region you choose.
- Cloudflare: network delivery and security for our site and API; sees traffic passing through.
- Payment provider (Stripe, once metered billing is live): billing contact and payment details.
- Email provider: sends account and invoice emails.
- Professional advisers, authorities and successors: when the law requires, to protect rights or safety, or in a merger or sale (your data stays under this policy).
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