Miniwo Privacy Policy
Effective date: September 28, 2026
Last updated: September 28, 2026
1. Who we are and what this Policy covers
Miniwo is operated by Tuomi Technology (Shanghai) Co. Ltd., a company based in China (“Miniwo,” “we,” “us,” or “our”). We are responsible for the personal information we process to operate our website, application, AI character features, and community. Where applicable data protection law uses that term, we act as a controller.
Contact us about privacy, access, deletion, complaints, or other requests at [email protected].
This Policy explains our practices. Accepting our Terms of Service or acknowledging this Policy does not, by itself, provide consent for every use of personal information. Where a particular activity requires consent, we request that permission separately.
2. Key points about your information
- Miniwo is for adults aged 18 and over.
- We process the photo you select to generate your character. Miniwo deletes the original photo from its systems after generation is completed; the saved character is a separate asset.
- Creating a character or chatting with AI does not automatically publish your photos, conversations, or private context.
- We retain stored chats while your account remains open. Account deletion includes corresponding data in Miniwo’s databases, server logs, and backups, subject to limited lawful exceptions described below.
- External AI providers may hold separate records. Deleting data from Miniwo does not establish simultaneous deletion of every external copy.
- Miniwo does not itself train AI models on your original uploaded photos or private chats. Provider-side processing is addressed separately below.
- We do not sell personal information, share it for cross-context behavioral advertising, or use private chats or emotional profiles for targeted advertising.
3. Information we collect
Account and profile information. We collect information you provide to create and manage your account, such as your email address, account identifier, display name, avatar, and account settings. If you use an available third-party login, we receive the account details supplied through that login with the permissions you grant.
Photos and creation information. This includes selected photos, prompts, character descriptions, generation instructions, generated images, story text, saved characters, and cards. We do not need access to your entire photo library to process a photo you select.
Conversations and context. We process messages, generated responses, character settings, and conversation context used to provide AI interactions. If a feature stores summaries or memories to maintain context, those are personal information when they relate to you; they are not automatically public.
Community information. We process the posts, comments, reactions, and other interactions you make through available features, together with visibility choices, reports, and blocks. The interface identifies information you choose to make visible to others.
Support and safety information. We collect requests, complaints, appeals, relevant evidence, and records needed to investigate and respond. Someone else may provide information about you in a report or rights complaint. We use such information for the relevant review rather than unrelated profiling.
Technical information. Your use of the Service generates information such as IP addresses, device and app details, timestamps, request records, errors, and security events. Website infrastructure providers also process information needed to deliver and protect the website.
Newsletter and waiting-list information. If you subscribe, we process your email address, subscription preferences, and necessary delivery records. A newsletter subscription is separate from a game account.
We do not collect payment-card details for the free public beta. If paid features are introduced, relevant notices will be provided before payment information is collected.
4. Photos, likenesses, and sensitive information
We use the selected photo and instructions to provide the character-generation feature you request. Only upload photos of adults that you have the right and necessary permission to use. A generated character can remain saved after the original photo is deleted.
A photograph may reveal personal information. Whether a particular operation involves legally regulated biometric information depends on what the system actually extracts and how it uses that information, not simply on the presence of a face.
Conversations may reveal information about health, intimate life, religion, politics, or other sensitive matters. Avoid providing information unnecessary for the interaction, and do not provide passwords or payment credentials. This advice does not remove our obligations when we receive personal information.
We do not currently operate an age-verification process. The 18+ rule does not mean that users’ ages have been independently verified. Do not send identity documents or age-check selfies unless a separately explained process specifically requests them.
5. How and why we use information
| Purpose | Relevant information | EU/UK legal basis, where applicable |
|---|---|---|
| Create and operate your account | Account details and essential settings | Performance of our contract, where objectively necessary |
| Generate requested characters and AI responses | Selected inputs, outputs, character settings, and necessary context | Contract for necessary delivery; consent for optional processing or disclosures where required; an additional condition where special-category data is involved |
| Store your creations and chats | Account content and conversation records | Contract for requested storage and continuity, subject to applicable rights |
| Publish and support community interactions | Content you choose to publish, audience settings, and interaction records | Contract for requested community features |
| Protect accounts and address abuse | Security records, reports, relevant content, and review outcomes | Legitimate interests in protecting users and the Service; legal obligation where applicable |
| Provide support and handle appeals | Requests, relevant records, and correspondence | Contract for requested support; legitimate interests in resolving concerns; legal obligation where applicable |
| Deliver newsletters or optional analytics | Subscription information or authorized events | Consent where required, with any other applicable basis explained at collection |
| Meet legal obligations and handle claims | Limited relevant records | Legal obligation or legitimate interests in establishing, exercising, or defending legal claims |
We assess legitimate interests against your rights and reasonable expectations. Contractual necessity is not a basis for unrelated optional uses. Where special-category information is processed under EU or UK law, an appropriate additional condition is required; ordinary contractual necessity or legitimate interests alone is insufficient.
In Canada, Australia, and other jurisdictions, we obtain the consent or other authority required by applicable law. We do not treat the EU/UK legal-basis table as a substitute for those requirements.
6. AI processing and model training
To provide photo generation and AI chat, we send relevant inputs to third-party AI service partners and model providers. Depending on the feature, these inputs include selected photos, generation instructions, messages, character settings, and necessary context. Required permission must be obtained before the relevant submission.
Miniwo does not itself train AI models on your original uploaded photos or private chats. This statement does not establish the retention, logging, or training practices of every external recipient. A model brand or an API-compatible interface does not, by itself, identify all recipients of your information.
Provider logs, stored conversation context, and model-training effects are different. We do not describe ordinary API processing as permanent model memory. Our feature permissions do not authorize undisclosed training or unrelated uses of your information.
7. Who receives information
Operational providers. We use providers to host and protect the Service, deliver requested AI features, and support communications. Providers receive information relevant to their work. Their access and use must be limited by the applicable arrangements and law.
| Provider or category | Purpose and information involved |
|---|---|
| Third-party AI service partners and model providers | Character generation and AI replies using selected photos, instructions, messages, and necessary context |
| Tencent Cloud | Hosting of Miniwo account content and associated server records; the identified server is in Virginia, United States |
| Cloudflare | Website delivery and security, including necessary request and security information |
| Brevo | Waiting-list and newsletter delivery using subscriber information and necessary delivery records |
Other users. They receive information you make available through your profile, posts, comments, and sharing choices. Review the displayed audience before posting. Original photos and unselected private conversation content are not automatically included in a published story card.
Authorized reviewers. Limited access to content may be necessary for support, reported AI responses, suspected abuse, rights complaints, or legal compliance. A private conversation is not publicly available to other users, but privacy does not mean that necessary provider processing or authorized review is impossible.
Legal and safety recipients. We may disclose limited relevant information to authorities, courts, advisers, or other recipients when required by law or otherwise lawfully necessary to protect rights or safety. We assess requests and do not grant unrestricted access merely because someone requests it.
Business changes. A merger, acquisition, or transfer of operations may require limited disclosure under appropriate confidentiality and purpose restrictions. We provide required notice if responsibility for your information changes. A transaction does not itself authorize incompatible new uses.
We do not disclose private chats, original photos, or private memories to advertisers. Using your content in a Miniwo promotional campaign requires separate permission.
8. International processing
Miniwo is operated by a company based in China and uses a Tencent Cloud server in Virginia, United States. The server’s location does not establish where every AI service, backup, website service, or support operation processes or accesses information. Laws in other countries may differ from those where you live, and authorities may have powers to access information under local law.
Contact [email protected] for information about applicable transfers and safeguards. We remain responsible for our own disclosures and for the provider accountability required by applicable law. This Policy does not ask you to waive cross-border protections.
9. How long we retain information
| Information | Retention approach |
|---|---|
| Original uploaded photos | Deleted from Miniwo’s systems after character generation is completed; not retained as reusable original-photo assets |
| Saved characters and cards | Retained while saved in your account, until deletion through supported controls or account deletion |
| Stored chats and associated Miniwo-held context | Retained while your account remains open and included in account deletion |
| Published posts and comments | Retained until deletion through supported controls, moderation removal, or account deletion |
| Corresponding account data in Miniwo databases, server logs, and backups | Included in the account-deletion workflow; no routine post-deletion backup-retention period is authorized by this Policy |
| Reports, appeals, and necessary evidence | Retained for handling the matter, any applicable appeal, and necessary legal obligations or claims; restricted and reviewed when continued retention is required |
| Newsletter and waiting-list records | Managed separately from game accounts; unsubscribe stops marketing delivery, while a limited suppression record may be needed to respect that choice |
| External provider records | Governed by the verified processing arrangements disclosed for the actual provider, not by an assumption of simultaneous deletion with Miniwo |
Retention must remain necessary for the stated purpose. An open account does not authorize indefinite retention of every incidental record. If we must preserve particular information for a legal obligation or claim, we limit it to what is necessary, restrict access, and review the continued need. Such an exception does not justify keeping an entire account indefinitely.
10. Deletion, export, and withdrawal
You may request account deletion or a copy of your information through available account controls or by emailing [email protected]. Use “Account Deletion” or “Privacy Request” as the subject to help us route your message. No particular subject line is required for an otherwise valid request.
Account deletion includes corresponding Miniwo-held account content, chats, characters, cards, comments, and associated data in our databases, server logs, and backups. Where necessary, we verify that the request comes from you or an authorized person before completing it. We explain completion or any lawful exception.
Deleting an original photo does not delete its separately saved character. Deleting Miniwo data does not establish that external providers have simultaneously deleted their records. You may contact us to exercise applicable rights concerning information shared with providers; this distinction does not remove our obligations to assist or take required action.
You may withdraw consent through the available privacy controls or by contacting us. Withdrawing consent stops the relevant consent-based processing going forward; it does not invalidate earlier lawful processing or itself erase all previously stored information. The affected feature may no longer work without the necessary processing.
Copies other people saved outside Miniwo may remain after you delete a post. We still take steps within our control where legally required. Deleting a game account does not automatically cancel a separate newsletter subscription; use the email unsubscribe link or contact us.
11. Cookies, newsletters, and optional choices
We use necessary storage and identifiers to maintain sessions, protect accounts, and remember essential settings. Non-essential tracking or analytics requires any consent mandated by applicable law and an accurate description of the technologies actually used. Where optional consent is requested, declining must not silently enable that activity.
Marketing emails include an unsubscribe option. Necessary security, account, support, and legal communications are distinct from marketing. You can also contact [email protected] to change your email preferences.
We do not sell personal information or share it for cross-context behavioral advertising. We honor applicable legally required opt-out signals. This Policy is not advance permission to introduce materially different advertising or tracking practices.
12. Your privacy rights
Depending on your location and applicable law, you may request access, correction, deletion, a portable copy, restriction, or objection to particular processing. You may withdraw consent and exercise applicable rights concerning sensitive information, targeted advertising, sales, or qualifying automated decisions.
Email [email protected] and explain your request. We verify identity proportionately and request only information reasonably needed. Authorized agents may act where permitted by law. We respond within applicable statutory time limits and explain permitted extensions, limitations, or refusals. We do not unlawfully discriminate against you for exercising your rights.
European Economic Area and United Kingdom. You may complain to your local supervisory authority or the UK Information Commissioner, as applicable. Where a right depends on the legal basis or other conditions, we explain the relevant conditions when responding. You may request information about applicable international-transfer safeguards.
United States. Rights vary by state and by whether a law applies to Miniwo. Where applicable, rights may include access, correction, deletion, portability, and opting out of specified processing. We do not sell personal information, share it for cross-context behavioral advertising, or use sensitive information to infer advertising characteristics. If your state provides an appeal, send it to [email protected]; we explain the outcome and applicable further complaint route. Disclosures required for a statutory lookback period must reflect actual practices during that period.
Canada. You may request access and correction, challenge our compliance, and withdraw consent subject to applicable restrictions that we explain. You may contact the relevant federal or provincial privacy regulator. Additional provincial rights apply where provided by law.
Australia. You may request access or correction and complain to us. We investigate and explain our response. Where applicable, you may take an unresolved concern to the Office of the Australian Information Commissioner. Our account-deletion process is available even where a local law does not provide an identical general deletion right.
13. Automated features, security, and underage accounts
AI generation uses automated processing and can produce errors. Automated tools may assist safety review; you can contest moderation or account decisions at [email protected]. We do not infer vulnerability from private conversations to pressure purchases or manipulate continued engagement.
We use technical and organizational safeguards appropriate to the processing, including access controls and protection of information in transmission. No service can promise absolute security. We assess suspected incidents and provide legally required notifications.
Miniwo is not offered to anyone under 18. If we learn of a potentially underage account, we review eligibility, restrict access as appropriate, and delete or otherwise handle information as required by law. Report concerns to [email protected].
14. Changes and contact
We update this Policy when our practices change. We give appropriate notice of material changes and request new consent where required. Posting an update alone does not authorize incompatible new uses of information already collected.
Privacy requests, complaints, and questions: [email protected].
Related documents: Terms of Service · Community Guidelines · Copyright & Likeness Complaints.