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1. Definitions and Scope
"Minfo Connection Services" means Minfo features that let people connect from media or places to Client Content using Minfo connection options AudioQR, MQR, or SmartLinks through the Minfo Universal App or approved SDK integrations.
"Client Content" means any page, file, stream, offer, coupon, form, tracking tag, or destination that a Minfo connection option opens.
"Laws" includes advertising, consumer, privacy, accessibility, financial promotion, and sector codes in each market where Client Content is accessible. Minfo's privacy and data policies form part of these Terms.
"Client" means the organisation or individual that uses the Services under an order or account.
"End User" means a person who interacts with the Minfo Universal App or a Minfo connection to access Client Content.
"Destination" means any website, app screen, file, or surface opened by a Minfo connection.
"Claim" means any statement, express or implied, about features, pricing, performance, safety, health, efficacy, endorsements, promotions, or legal rights.
"Regulated Content" means content that is subject to specific sector rules, including financial promotions, health and medical claims, alcohol, gambling, age-restricted products, and political or election advertising.
The Services may vary by market. Local advertising and consumer codes apply in each territory.
For the UK: This includes the CAP Code and BCAP Code, ASA guidance, and FCA financial promotion rules.
Client is responsible for localisation and legal review in every territory where Client Content is accessible, including disclosures, language, accessibility, and age-gating requirements.
 
2. Content Standards and Acceptable Use
Client must not use Minfo Connection Services to promote, distribute, or link to:
•    Misleading, false, or deceptive claims
•    Unsubstantiated health, safety, or performance claims
•    Illegal, harmful, or age-inappropriate material
•    Infringing, defamatory, discriminatory, or offensive material
•    Scams, fraudulent schemes, or pyramid selling
•    Unregulated or prohibited financial products or investment schemes
•    Political or election advertising without required notices and local clearance
•    Content that deploys unlawful tracking, fingerprinting, or scraping
Client Responsibilities
Client warrants that Client Content:
•    Complies with all Laws and sector codes and is accurate, truthful, and not misleading
•    Includes required disclosures, disclaimers, and qualification text
•    Meets accessibility standards and applies age gating where required
•    Does not interfere with Minfo measurement or simulate engagements

Regulated Categories
Financial
Obtain required approvals for financial promotions and keep records.
Health
Hold objective and competent substantiation for health claims.
Alcohol, Gambling, and Age-Restricted Products
Implement legal age gates and location filters.
Prize Promotions
Follow applicable rules and supply official terms that match any claims in Client Content. Where Minfo-hosted sweepstakes are used, Minfo's sweepstakes terms apply.
 
3. Monitoring and Enforcement
Definitions in this Section
"Suspension" means a temporary block on one or more Minfo connections, destinations, or features while an issue is reviewed.
"Disconnection" means removal of one or more Minfo connections or destinations from service.
Remedies Ladder
(a) Immediate suspension for high risk or illegality. Minfo may suspend without notice if there is suspected illegality, safety risk, privacy risk, or material reputational harm.
(b) Cure period for non-critical issues. For issues that do not present high risk, Minfo will notify Client and allow 48 hours to cure.
(c) Targeted actions before full disconnection where practical. Minfo may apply targeted removal, destination edits, geo-fencing, or age gating to reduce risk before full disconnection.
Process and Timelines
•    Minfo will acknowledge Client submissions and complaint notices within one business day.
•    For suspensions, Minfo will notify Client without undue delay and will share the reason in writing and the steps to cure when feasible.
•    Client will respond to suspension notices within 24 hours for high-risk issues and within 2 business days for non-critical issues, including substantiation or corrected content.
•    If Client fails to respond within the stated time, Minfo may proceed to disconnection.
Evidence and Logs
Minfo may request substantiation, preserve audit logs and engagement records, and use them as evidence to support decisions. Minfo may share relevant extracts with regulators or dispute bodies when required by law.
Authority to Disconnect
Minfo may disconnect where:
•    Complaints allege misleading, harmful, or illegal content
•    Content breaches these Terms or Client fails to provide evidence within the deadline
•    Content creates legal, safety, privacy, or reputational risk
•    Client fails to cure a non-critical issue within the stated cure period
 
4. Complaints and Appeals
Complaint Handling
When Minfo receives a complaint, Minfo will notify Client, may suspend during review, and will request evidence within 5 business days.
Appeal
Client may appeal disconnection within 10 business days. The appeal must include comprehensive evidence, such as claim substantiation, approvals, certifications, legal opinions, or corrected content.
Decision
Minfo will review appeals within 10 business days. Minfo's decision is final. Minfo is not obligated to reinstate.
 
5. Data, Privacy, and Logs
Roles
Minfo acts as an independent controller when it processes data needed to run, secure, and improve the Services, including service logs, fraud prevention, abuse detection, and aggregated analytics.
Minfo acts as a processor when it processes personal data on behalf of Client within configured campaigns and Destinations. A Data Processing Addendum forms part of these Terms where Minfo acts as processor.
 

Legal Framework
Processing complies with UK GDPR, the Data Protection Act 2018, and the Privacy and Electronic Communications Regulations on cookies and similar technologies. Where End Users are in the EEA or other regions, the applicable local data protection and ePrivacy rules also apply.
Client Obligations on Destinations
Client will:
•    Implement consent and cookie controls on all Destinations, including a consent management platform that records choices and honours them.
•    Provide a lawful basis for tags, pixels, SDKs, and similar technologies.
•    Obtain valid consent where required and pass consent signals to Minfo and relevant vendors.
•    Publish accurate privacy notices and cookie notices that describe the use of Minfo Connection Services.
•    Remove or disable tags and pixels where consent is not given or a lawful basis is not available.
Special Categories and Minors
Client will not deliberately capture special category data or children's data through the Services without a written agreement that sets the lawful basis, safeguards, and parental consent mechanism.
International Transfers
If personal data is transferred across borders, the parties will implement appropriate safeguards. For UK transfers this may include the International Data Transfer Agreement. For EU to non-EU transfers this may include the European Commission Standard Contractual Clauses. Minfo may use sub-processors and will maintain a list on request. Client consents to such sub-processing and international transfers subject to the same safeguards.

Logs and Retention
Minfo may keep audit logs, time-stamped engagement data, complaint files, and investigation records to support compliance and security. These records are retained only for as long as necessary and proportionate. The normal retention period is 24 months for service and audit logs and 36 months for complaints and investigations, unless law or regulatory inquiries require a longer period.
Data Subject Rights and Cooperation
Each party will handle requests from data subjects for the data it controls. Where Minfo acts as processor, Minfo will assist Client with reasonable technical and organisational measures. Each party will notify the other without undue delay of relevant incidents or regulatory inquiries that relate to the Services.
 
6. Security and Anti-Fraud
Client must not spoof AudioQR triggers, simulate connections, or manipulate metrics. Minfo may use fraud detection, rate limits, and verification checks and may void suspect activity and related billing or incentives. Alignment with Minfo's anti-fraud methods may be required for certain campaigns.
 

7. IP, Licences, and Branding
Client retains rights in Client Content. Client grants Minfo a limited licence to host, test, cache, and display Client Content as needed to provide the services. Use of Minfo marks requires prior written approval and compliance with brand guidelines (currently in development).

 

8. Fees, Pauses, and Removal
Minfo may pause or remove codes or destinations that breach these Terms. Fees remain payable for services delivered prior to pause or removal unless prohibited by law. Client will not set off or withhold any undisputed fees.
 
9. Indemnity and Liability
Client Indemnity
Client will indemnify and hold Minfo harmless from all claims, losses, damages, costs, and expenses, including reasonable legal fees, arising from Client Content, breaches of these Terms, third-party complaints, regulatory actions, or IP infringement.

 

Liability Cap
Except for Excluded Liabilities, Minfo's total aggregate liability in any 12-month period is limited to the greater of: (i) the amounts paid or payable by Client for the Services under the applicable order in the 12 months before the first event giving rise to liability; or (ii) 25,000 GBP.

 

Excluded Liabilities
The cap does not apply to liability for death or personal injury caused by negligence, fraud, wilful misconduct, or to the Client indemnity for IP infringement. Nothing in these Terms limits any liability that cannot be limited by law.

 

Excluded Losses
Minfo is not liable for loss of profits, revenue, goodwill, or data, or for any indirect or consequential loss, including any loss due to suspension or disconnection.
10. Termination
Minfo may terminate an account if multiple codes are disconnected, repeated breaches occur, investigations are obstructed, or fraudulent evidence is submitted. Termination does not affect Client indemnity or any accrued rights.

 

11. Changes, Notices, and Order of Precedence
Minfo may update these Terms on notice. If there is a conflict between these Terms and a signed order, the signed order controls for that order. Notices are sent to the contacts in the order form.

 

12. Governing Law and Venue
These Terms are governed by the laws of England and Wales. The courts of England and Wales have exclusive jurisdiction.
 
13. General Provisions
Force Majeure
Neither party is liable for delay or failure caused by events beyond reasonable control. Fees remain due for Services already delivered.
Assignment
Neither party may assign or transfer these Terms without written consent, except to an affiliate or in connection with a merger, reorganisation, or sale of substantially all assets, provided the assignee assumes all obligations.
Severability
If any provision is found invalid, the remainder remains in effect.
No Waiver
A failure to exercise a right does not waive it.
Entire Agreement
These Terms, the order, and any incorporated documents form the entire agreement and replace all prior communications.
Survival
Sections 5, 6, 9, 10, 11, 12, and 13 survive termination or expiry.
No Set Off
Client will not set off or withhold undisputed fees.
 

Contact Us: For any questions about this Privacy Policy or our privacy practices, please contact us at support@minfo.com or complete the form below.