Privacy Policy

1. Introduction and Data Controller

This Privacy Policy explains how Smartdigit, Unipessoal Lda, with registered address at Rua Marcelino Mesquita, N.º 9, Loja 4 – Alto de Santa Catarina 2795-134 Linda-A-Velha, tax identification number PT510522130 (“we”, “our”, or “the Company”), collects, uses, shares, and protects the personal data of users (“User”, “you”) of the MyMINIMIX mobile application (“the App”).

By creating an account and using the App, the User confirms having read and understood this Privacy Policy.

This Policy applies solely to the MyMINIMIX App and its associated loyalty services, and does not cover third-party websites or services accessible through links provided within the App.

2. Personal Data We Collect

1. a) Registration and account data. Full name, email address, phone number, and address (stored encrypted).
2. b) Loyalty card data. Personal account identifier / barcode, bonus balance, history of accumulated and used bonuses, and their expiration dates.
3. c) Transaction and purchase data. Date and time of purchase, receipt/document reference, total purchase amount, amount paid, amount of bonus used, and the store where the purchase was made.
4. d) Family sharing data (optional feature). Identification of family members linked to the account, and bonuses/purchases shared between group members, if this feature is enabled by the User.
5. e) Technical and usage data. Device identifier, operating system, App version, error logs for security and service-improvement purposes, and push-notification token (if authorized).
6. f) Data provided when contacting customer support. Any information voluntarily provided by the User in that context.

We do not collect special categories of personal data (e.g. racial or ethnic origin, political opinions, health data, sexual orientation).

3. Purposes of Processing

• Creating and managing the User’s account and authenticating access;
• Issuing and managing the digital loyalty card, including adding it to Apple Wallet;
• Calculating, displaying, and updating the bonus balance by linking in-store purchases to the account;
• Notifying about bonus expiration dates, promotions, coupons, and discounts;
• Providing the family sharing feature, when enabled;
• Responding to customer support requests;
• Ensuring App security and preventing fraud;
• Complying with legal obligations, including tax and accounting requirements;
• Improving the App through aggregated and, where possible, anonymized usage analysis.

4. Legal Basis for Processing

Under Article 6 of the GDPR, processing is based on:

Performance of a contract, for account management, card issuance, and bonus calculation;

Consent, for marketing communications and optional features (family sharing, push notifications), withdrawable at any time;

Legitimate interest, for fraud prevention, security, and service improvement;

Legal obligation, where required by law.

5. Who We Share Your Data With

• Monolith group, the entity responsible for the loyalty programme associated with the App;
• Service providers acting on our behalf (data hosting, notification delivery, technical support), contractually bound to comply with this Policy;
• Family members linked to the account, solely within the scope of the family sharing feature;
• Public or judicial authorities, where required by law.

We do not sell or rent Users’ personal data to third parties for their own marketing purposes.

6. Data Retention

Data is retained while the account remains active. After account closure, data is deleted or anonymized within a reasonable period, unless a longer retention period is required by law (e.g., transaction data for tax and accounting purposes).

7. Data Security

We implement appropriate technical and organizational measures, including encryption of sensitive data and access controls, to protect personal data against unauthorized access, loss, or improper disclosure. No system is completely secure, so we cannot guarantee absolute security.

8. International Data Transfers

If data is transferred outside the European Economic Area, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

9. Your Rights

Under the GDPR, you have the right to: access your data; request rectification; request erasure (“right to be forgotten”); request restriction of processing; object to processing, including for direct marketing; request data portability; withdraw consent at any time; and lodge a complaint with the Comissão Nacional de Proteção de Dados (CNPD) or another competent supervisory authority.

To exercise these rights, contact us via the details in the “Contact” section.

10. Notifications and Marketing Communications

You can manage your push-notification and marketing preferences in the App or device settings, or request their deactivation through our contact channels.

11. Minors

The App is not intended for users under 12 years of age. We do not knowingly collect data from minors without verifiable parental or legal guardian consent.

12. Changes to this Policy

We may update this Policy periodically. Material changes will be communicated through the App, indicating the date of the last update.

13. Contact

Email: support@smartdigit.pt

Address: Rua Marcelino Mesquita, N.º 9, Loja 4 – Alto de Santa Catarina 2795-134 Linda-A-Velha