Privacy Policy

1. Data Controller

The data controller for Venio is Individual Entrepreneur Vage Oganesyan, registration number 106427723, registered on 20 October 2023 by the LEPL National Agency of Public Registry of Georgia. The registered legal address is Georgia, Tbilisi, Krtsanisi district, Fonichala settlement 3, building 5, floor 4.

For any question about how your personal data is processed, contact privacy@venioapp.com. We reply within 30 days, as required by Article 12 of the General Data Protection Regulation (GDPR).

2. Categories of Personal Data Collected

Venio processes only the minimum data needed to read a caption and return a Google Maps link. The categories are:

• Instagram-scoped user ID (IG PSID): a numeric identifier assigned by Meta that is unique to your interaction with our application. It is used to route the reply to the same Instagram Direct conversation and to honour data-deletion requests.
• Instagram username: displayed in logs for support requests. Not shared publicly.
• Message text: the plain text content of the direct messages you send to @venio_app. For most users this is either a short command (for example, "help", "delete") or a forwarded reel with a caption.
• Forwarded post caption and permalink: when you share a reel or post, we receive the caption text and the post permalink from the Instagram Graph API. We read the caption to identify the place. We do not download the media file itself.
• Extracted place data: the place name, city, and country that our language model identifies in the caption. This is generated transiently and included in the reply URL.
• Event timestamps: the date and time each message was received and processed, used for rate-limiting and abuse prevention.

Venio does not collect biometric data, payment information, precise device location, contacts, photos, or the content of any conversation you have with anyone other than @venio_app.

3. Purposes and Legal Basis

We process the data listed in section 2 for three purposes, each with a distinct legal basis under Article 6 of the GDPR.

Purpose A — Providing the service. Reading a forwarded caption and replying with a Google Maps link is the entire service. Legal basis: your consent under Article 6(1)(a) GDPR. The act of sending the first direct message to @venio_app is a clear affirmative act that signals consent, consistent with European Data Protection Board guidance on consent in messaging contexts. Consent can be withdrawn at any time by blocking the bot in Instagram or by requesting deletion (see section 7).

Within Purpose A, caption text and the post permalink are held in memory on Cloudflare Workers only for the few seconds needed to call the extraction model and send the reply. Venio does not write caption text to any database, cache, log file, or long-term store on its own systems, and does not reuse caption text for any purpose beyond returning the map link for that single request. Retention by the sub-processor that runs the language model (OpenAI) is described separately in section 5.

Purpose B — Abuse prevention and security. We store the Instagram-scoped user ID, timestamps, and rate-limit counters for up to 30 days to detect and prevent abuse (for example, flooding, scraping, prompt-injection attempts). Legal basis: legitimate interest under Article 6(1)(f) GDPR. Our legitimate interest in running a reliable, abuse-free service is balanced against your interest in privacy by the narrow scope of the data stored and the short retention window.

Purpose C — Aggregate service analytics. We use PostHog to record anonymous product events (counts of messages processed, types of errors, extraction success rate). Legal basis: legitimate interest under Article 6(1)(f) GDPR. Events do not contain caption text or username, only a hashed identifier.

Purpose D — Caption content authored by third parties. When a user forwards an Instagram post to @venio_app, the caption of that post may have been written by a different Instagram account — typically the post's author (a venue, a creator, or another user). The forwarding user's consent under Article 6(1)(a) covers their own message, but not the caption of a post they did not author. For the author's caption, Venio relies on legitimate interest under Article 6(1)(f) GDPR.

The Article 6(1)(f) balancing test, conducted in line with European Data Protection Board guidance on legitimate interest and publicly available content:

• Nature of the data. The caption has already been published by its author on a public Instagram post. The author chose public distribution on the Instagram platform when they posted it.
• Minimisation. Processing is limited to a single purpose — extracting the name of a place mentioned in the caption — and produces only a Google Maps search URL. No wider analysis, profiling, or republication of the caption takes place.
• No storage. Venio does not store the caption on its own systems (see Purpose A above). The only residual retention is the sub-processor window documented in section 5.
• Reasonable expectation. An author who publishes a caption on a public Instagram post can reasonably expect that caption to be read by other Instagram users and by tools that help those users act on the content.

Right to object (Article 21 GDPR). If you are an Instagram post author and you do not want captions from your posts to be processed by Venio, email privacy@venioapp.com with your Instagram handle. We will add the account to a blacklist so that any post whose author matches that handle is ignored by the extraction step. We action requests within 30 days, consistent with Article 12(3) GDPR.

4. Joint Controllers, Processors, and Third Parties

Venio exchanges personal data with two categories of third party: a joint controller (Meta) and processors acting on our instructions. Sub-processors engaged by those processors are disclosed below.

4.1 Joint Controller — Meta Platforms Ireland Limited

Meta Platforms Ireland Limited, the operator of Instagram, is a joint controller with Venio for the exchange of Instagram direct messages between you and @venio_app, consistent with Article 26 of the GDPR. Meta and Venio each determine, in concert, the purposes and means of that exchange: Meta determines how you authenticate, which identifiers are assigned to you on its platform, and the transport medium (the Instagram Messaging Platform and the Instagram Graph API); Venio determines the content of the reply and the retention of your data on its own systems.

The essential terms of this arrangement, as required by Article 26(2) GDPR, are:

• Meta's responsibilities. Authenticating the Instagram user, assigning and maintaining the Instagram-scoped user ID, routing direct messages to our webhook, applying its own privacy terms to data it holds about you on the Instagram platform, and responding to data-subject requests that concern its platform records.
• Venio's responsibilities. Receiving the forwarded message, generating a reply, retaining the data only as described in section 5, securing the data in transit and at rest, honouring data-subject requests that concern records held by Venio (access, rectification, erasure, restriction, portability, objection), and operating the data-deletion callback endpoint that Meta invokes when you revoke the application.
• Point of contact for data subjects. You may exercise any right under Articles 15 to 22 GDPR against Venio by emailing privacy@venioapp.com. You may exercise those rights against Meta directly at privacycenter.instagram.com. Where a request concerns data held by both parties, we coordinate with Meta through the Instagram Graph API data-deletion callback (see the Data Deletion page).

Meta's own policies at privacycenter.instagram.com apply in full to the data Meta holds about you on its platform, independently of this policy.

4.2 Processors Acting on Our Instructions

The processors below operate under a written data-processing agreement (DPA) and process data strictly on our behalf under Article 28 GDPR.

4.3 Sub-processors

Botpress uses its own sub-processors to deliver the language-model service that extracts a place name from a caption. As of the effective date, this is OpenAI, L.L.C. (United States), operating the gpt-4o-mini model in API mode with "no training" configured. Venio does not contract with OpenAI directly; the DPA chain runs Venio → Botpress → OpenAI. Botpress publishes its list of sub-processors and notifies of changes; you may request the current list at privacy@venioapp.com.

We do not sell personal data, share it with advertisers, or transfer it to any party outside those named in sections 4.1, 4.2, and 4.3.

4.4 No User Profiling or Model Augmentation

Venio does not build user profiles, behavioural models, interest graphs, preference vectors, or any form of personalisation. Each direct message to @venio_app is processed independently and statelessly: the bot reads a single caption and returns a single map link, without reference to the user's prior messages, other users, or any stored attribute about the user.

No data processed by Venio is used to train, fine-tune, or augment any language model, recommendation system, ranking system, or advertising profile. This applies to:

• Venio's own systems. We do not train or fine-tune any model on user data. We do not derive features from user data for any downstream system.
• Meta Platforms (section 4.1). We do not return derived attributes, inferences, audiences, or user segments to Meta. The only data sent back over the Instagram Graph API is the reply message itself.
• Sub-processors (section 4.3). The OpenAI API is used in inference-only mode with the "no training" configuration documented in section 4.3. Botpress is instructed under our data-processing agreement not to use caption text or identifiers to train or tune models on our behalf.

This subsection reflects the restrictions on use of Platform Data in the Meta Platform Terms updated on 3 February 2025, which require explicit user consent before Platform Data may be used to build or augment profiles or to improve recommendation or advertising systems. Venio does not rely on any such consent because it does not carry out those activities.

5. Storage and Retention

We apply the principle of storage limitation under Article 5(1)(e) GDPR.

• Cloudflare KV entries (rate-limit counters, pending data-deletion confirmation codes) are retained for 30 days on a rolling basis, then automatically expire.
• Botpress conversation state (the dialogue memory of your conversation with the bot) is retained for the lifetime of your interaction with @venio_app. It is deleted within 30 days when you request erasure or when Meta notifies us that you have revoked the app.
• PostHog events are pseudonymised at ingestion (the identifier is a hash of the Instagram-scoped user ID, not the ID itself). Events are retained for 12 months, then deleted.
• Language-model request logs. Caption text sent to the language model through Botpress is retained by the sub-processor (OpenAI) for up to 30 days under OpenAI's API data-usage policy, then deleted. Botpress does not retain model inputs beyond their transit through its proxy.

Deletion is triggered by one of: a valid Meta signed_request sent to our data-deletion callback endpoint, or an email to privacy@venioapp.com. See section 7 and the Data Deletion page.

6. International Transfers

Caption text is processed by Botpress's language-model sub-processor (OpenAI, L.L.C.) in the United States. This onward transfer is covered by the Standard Contractual Clauses (SCCs) adopted by the European Commission on 4 June 2021 between Botpress (as processor) and OpenAI (as sub-processor), supplemented by OpenAI's technical and organisational measures as described in its Data Processing Addendum. We carry out a transfer impact assessment before any release that changes this sub-processor chain.

Meta Platforms Ireland Limited, our joint controller under section 4.1, hosts Instagram data on its own global infrastructure under the transfer mechanisms it publishes at privacycenter.instagram.com. Those mechanisms apply independently of this policy.

All processors listed in section 4.2 (Cloudflare, Botpress, PostHog) host the data we send them in the European Union. No data is transferred by Venio to any jurisdiction outside the European Economic Area other than the onward transfer to OpenAI described above.

7. Your Rights Under the GDPR

You have the following rights over your personal data under Articles 15 to 22 of the GDPR.

• Right of access (Article 15). You may ask for a copy of the data we hold about you. Given our minimisation, this is typically a small record or an empty response confirming nothing is retained.
• Right to rectification (Article 16). If any data we hold is inaccurate, you may ask us to correct it.
• Right to erasure (Article 17). You may ask us to delete your data. See the Data Deletion page for two channels: an automatic Meta-triggered flow and a manual email flow.
• Right to restrict processing (Article 18). You may ask us to pause processing of your data while a dispute is being resolved.
• Right to data portability (Article 20). You may ask us to export your data in a machine-readable format. We export to JSON.
• Right to object (Article 21). You may object to processing based on legitimate interests (Purposes B and C in section 3). We will stop unless we demonstrate an overriding legitimate ground.
• Right not to be subject to a solely automated decision (Article 22). See section 8.
• Right to withdraw consent at any time (Article 7(3)). Blocking @venio_app in Instagram withdraws consent. So does sending the word "delete" in a direct message.
• Right to lodge a complaint. You may complain to the Personal Data Protection Service of Georgia (pdp.ge) or to the supervisory authority in your country of residence.

To exercise any of these rights, email privacy@venioapp.com with the phrase "GDPR request" in the subject line. We respond within 30 days, free of charge, as required by Article 12(3) GDPR.

8. Automated Decision-Making

Venio uses a large language model (OpenAI gpt-4o-mini), accessed through our processor Botpress, to classify caption text and extract a place name. This is automated processing under the definition in Article 4(4) GDPR.

The processing does not produce legal effects or similarly significant effects on you under Article 22 GDPR, because the only output is a Google Maps search URL that you may open, ignore, or discard at your discretion. No decision about you, your access to goods or services, your eligibility, or your credit is made by the model.

We disclose the processing in this clause for transparency and to give you the option to object under Article 21 GDPR by ceasing to use the service or by blocking @venio_app in Instagram.

9. Cookies and Tracking on venioapp.com

The pages under venioapp.com (this page, the homepage, the terms, the data-deletion page, and the support page) do not set cookies, do not use LocalStorage, do not fingerprint the browser, and do not load any analytics script on the client. No consent banner is shown because no tracking takes place.

Product analytics (PostHog) is server-side only and applies to the Instagram Direct bot, not to these web pages. See section 4.

10. Children

Venio is not directed at children. Instagram's own terms require users to be at least 13 years old, and we rely on that restriction. Consistent with Article 8 GDPR, we do not knowingly process personal data of children under 16 in the European Union without verifiable parental consent, nor of children under 13 in the United States consistent with the Children's Online Privacy Protection Act (COPPA). If you believe a child under 13 has interacted with Venio, email privacy@venioapp.com and we will delete the data.

11. Contact for Privacy Matters

For any question, request, or complaint related to your personal data, contact:

Individual Entrepreneur Vage Oganesyan
Email: privacy@venioapp.com
Postal address: Georgia, Tbilisi, Krtsanisi district, Fonichala settlement 3, building 5, floor 4

12. Effective Date and Changes

This Privacy Policy is effective as of 2026-04-19.

We may update this policy to reflect changes in the service, in the processors we rely on, or in applicable law. Any material change is announced at least 14 days in advance by updating the "Last updated" date at the top of this page and, where practicable, by a notice in the @venio_app Instagram profile bio. The most current version is always the one on this page.