Privacy policy

1. Who is responsible

The person responsible for your data is Christian Winckler, an individual, Santiago, Chile. For any question about your data or this policy, write to contacto@minoa-notes.app.

Christian Winckler is also the data protection officer (encarregado, under Brazil’s LGPD) and the point of contact for authorities and for individuals (EU Digital Services Act), at the same email: contacto@minoa-notes.app.

2. What data we use

• Your account: you sign in with Google, so we receive your name, email, profile photo and a user ID. We never see your Google password. If you prefer to sign in with email and password, we keep your email and only a hash of your password (never the password itself), plus the list of your open sessions (device type, browser and date of last activity), which you can see and close in Settings.
• Your content: notes (text, handwriting, drawings, photos and audio), tasks, folders, tags and settings.
• Audio: the voice recordings you make inside a note are saved in your account (encrypted if the note is in a private folder) and you can delete them whenever you want. If you record other people, you are responsible for having their permission.
• Use of the AI mode: how many credits you used in the month and the cost of each call. We do not keep a copy of what was sent to the AI.
• Problem reports, only if you send them: your description, a screenshot if you attach one, and technical data about the device (browser, screen size, recent app errors and the last screens you visited).
• Website contact form: the name, email and message you write.
• Reminders: if you turn notifications on, an identifier of your device to send them to.
• Minimal technical data: sign-up date, last activity, and server logs to fix errors and protect the service.

We do not show ads, we do not sell data, and we do not use third-party analytics or tracking tools.

3. What we use it for

Each purpose has its legal basis (GDPR art. 6, LGPD art. 7 and their equivalents in other countries). Primary purposes are those needed to give you the service; secondary purposes are all the others.

Primary purposes:

• Providing the service: saving and syncing your notes and tasks across your devices and applying your plan’s limits. Basis: contract (the service you accept when you create your account).
• Answering your messages and fixing the problems you report. Basis: contract.
• Keeping the app secure: preventing abuse, controlling costs and detecting failures. Basis: legitimate interest.
• Responding to a competent authority when the law requires it. Basis: legal obligation.

Secondary purposes:

• The AI mode, when you ask for it (see section 5). Basis: consent.
• Sending you reminders, if you turn notifications on. Basis: consent.
• Problem reports with a screenshot, if you attach one. Basis: consent.
• Improving MINOA with aggregated usage data (for example, how many people use a feature), never by reading your content. Basis: legitimate interest.

You can object to the secondary purposes at any time by writing to contacto@minoa-notes.app, and you will not lose the service. If you withdraw a consent, only that feature stops working.

4. Private folders

The content of a private folder is encrypted on your own device before it is saved (256-bit AES-GCM, with a key derived from your password). Neither we nor Google can read it without your password or your recovery phrase.

For that same reason, if you lose both, we cannot recover that content. Some things are not encrypted so the app can work: the folder’s name, and tasks created from a private note.

Shortcuts and API: if you create a personal token (Settings → Shortcuts & API), we keep only its fingerprint (a hash), the name you gave it and the dates it was created, last used and revoked; never the token itself, which you see only once. The token can only create notes in your account. Notes that arrive through a shortcut are saved unencrypted, in the “External Notes” folder, which is never private: the server does not have your key. We also keep your time zone to read the dates you dictate.

5. AI mode (Google Gemini)

The AI mode uses Gemini, a Google model, through Google Cloud’s Vertex AI. It only runs when you ask for it, and the app tells you how many credits it will use first.

When you use it, only what is needed is sent to Google: the note’s text and a picture of each sheet with handwriting, drawings or photos and, if you use the AI tidy drawing, the text you write to correct the description of the drawing. The connection is encrypted. Google processes that content to answer and, under its Google Cloud terms, does not use it to train its models. We do not keep a copy of what was sent either: only the result you decide to keep (the tasks, the summary or the tidy drawing) and the record of credits used.

If you use the transcription of an audio, the audio is sent to Google (Vertex AI) to turn it into text, like the rest of the AI mode; we do not keep a copy of what was sent beyond the audio already in your account.

If you write your handwriting under “Your handwriting” or correct a reading, those handwriting samples are stored in your account, are only used to read your notes, are sent to Vertex AI with each reading, and you can delete them whenever you want.

If the note is in a private folder, the app warns you before sending it, because for the AI to read it, it has to leave your device decrypted for that reading.

The AI can make mistakes. Always check what it suggests before keeping it. We do not make automated decisions about you with these results.

6. Who we share data with

We do not sell or hand over your data. We only work with providers that give us technical services, and only with what each one needs:

• Google (Firebase and Google Cloud): sign-in, database, photo storage, the app’s servers, notifications and the AI mode (Vertex AI). Also Gmail, where the emails you send to contacto@ and soporte@ arrive.
• Resend: sending the app’s emails (problem report alerts, contact messages, the administrator’s access code, the codes to sign in with email and password and the notices to people who ask to delete their account).
• ImprovMX: forwarding emails sent to contacto@ and soporte@ to Christian Winckler’s inbox.

Google and Resend are United States companies; ImprovMX forwards emails from servers in the European Union. Each one receives only what it needs for its task.

We could also hand over data if a competent authority requires it under the law.

7. International transfers

Your data is stored and processed outside your country, mainly in the United States (the app’s servers are in Google Cloud’s us-east4 region).

To protect those transfers we use, as applicable: the EU-U.S. Data Privacy Framework, when the provider is certified (Google is), and the European Commission’s standard contractual clauses. For people in Latin America, we look for safeguards equivalent to what each country’s law requires.

By using MINOA you accept those transfers only as far as needed to give you the service. When your country’s law requires it (for example, in Argentina or Colombia), your consent is the supplementary basis for the transfer.

8. How long we keep it

• Your account and content: as long as your account exists. If you ask us to delete it, you have 30 days to cancel: we email you when you ask and 5 days before it is erased; after that it is erased, except what the law requires us to keep.
• What you delete in the app is removed from our servers. It may stay briefly in your own device’s memory.
• Problem reports: up to 90 days after you send them.
• Contact messages: up to 12 months, to be able to follow up the conversation.
• Server technical logs: as long as the platform keeps them, normally up to 30 days.

9. Your rights

At any time you can ask us for:

• Access: to know what data of yours we hold.
• Rectification: to correct any that is wrong.
• Erasure: to delete it, including your whole account.
• Objection: to stop processing it for a given purpose.
• Restriction: to limit its use while a request is resolved (in Chile, blocking).
• Portability: to receive your data in a format you can take to another service.
• Information: to know who we share your data with (see section 6).
• Withdrawing your consent whenever you want, for example by no longer using the AI mode or turning notifications off.
• Not being subject to automated decisions: we do not make decisions about you by automated means alone, and you review and decide on the AI mode’s results.

Exercising your rights is free.

To ask, write to contacto@minoa-notes.app from your account’s email. We answer within the time set by your country’s law and, at most, within 30 calendar days (in Colombia, 10 business days for queries and 15 for claims; in Peru and other countries, the time in their law if shorter). If we need more time and the law allows it, we will let you know.

ARCO procedure (Mexico): you can exercise your rights of access, rectification, cancellation and objection by writing to contacto@minoa-notes.app from your account’s email. Include your name, your account’s email, the right you want to exercise and a clear description of the data or of what you ask (if you ask for rectification, which data and what the correct value is). We will answer at the same email, within the time set by Mexican law and, at most, within 30 calendar days, telling you whether your request is granted and how we carry it out.

10. Where to complain

If you are not satisfied with our answer, you can file a complaint with the data protection authority of your country:

• Chile: Agencia de Protección de Datos Personales (Personal Data Protection Agency).
• European Union and European Economic Area: the data protection authority of your country.
• United Kingdom: Information Commissioner’s Office (ICO).
• Brazil: Autoridade Nacional de Proteção de Dados (ANPD).
• Argentina: Agencia de Acceso a la Información Pública (AAIP).
• Mexico: the authority competent in personal data protection (since 2025, the Secretaría Anticorrupción y Buen Gobierno).
• Colombia: Superintendencia de Industria y Comercio (SIC).
• Peru: Autoridad Nacional de Protección de Datos Personales.

For Argentina: The AGENCIA DE ACCESO A LA INFORMACIÓN PÚBLICA (Agency for Access to Public Information), as the Control Body of Law No. 25,326, has the authority to handle the reports and complaints filed by those whose rights are affected by non-compliance with the personal data protection rules in force.

11. United States

We do not sell or "share" personal data (in the sense of California’s CCPA/CPRA) and we do not do targeted advertising. We honor the Global Privacy Control signal; since we do not sell or share data, it changes nothing for you, but we say so.

If you live in California or another state with a privacy law, you have the right to know what data of yours we process, to delete it, to correct it, and not to be discriminated against for exercising these rights. Ask at the same email: contacto@minoa-notes.app.

12. Security

Everything travels encrypted over HTTPS. Each person can only read and write their own data, and the server checks this on every operation. Administrative access is limited and protected with additional verification. The admin tools show usage figures, not the content of your notes.

No system is infallible. If we detect an incident affecting your data, we will let you know, and notify the authority when required.

13. Cookies and local storage

We only use the cookies and browser storage the app needs to work: keeping you signed in, remembering your language and theme, opening the last note you had, and keeping a local copy so the app works offline. We do not use advertising or tracking cookies.

14. Minors

MINOA is not aimed at children under 16, and we do not knowingly collect data from children under 13 (COPPA). If you believe a minor gave us data, write to us and we will delete it.

15. Changes to this policy

If we change this policy, we will update the date above. If the change is significant, we will let you know in the app or by email before it takes effect.