Personal Data Processing Policy
The personal data controller pursuant to Article 4(7) of the GDPR is:
Matyáš Hrubý
ID No.: 19468091
Registered office: K Holyni 150/7, 154 00 Prague 5 – Slivenec, Czech Republic
Registered in the Trade Register maintained by the Prague 16 Municipal Authority, Trade Licensing Department
Email: mhruby@justimagaine.com
(hereinafter referred to as "we," "Controller," or "Just ImagAIne")
We take the protection of personal data seriously. This policy explains what personal data we process, why, how, on what legal basis, for how long, to whom we may transfer it, and what your rights are.
If you have any questions about the protection of personal data, please contact us by email at mhruby@justimagaine.com or in writing at our registered office.
How we approach personal data protection
We only process personal data that is necessary for the provision of Services and related communication. Our procedures comply with GDPR standards. If you entrust us with your personal data, we undertake to handle it in accordance with the legal regulations that apply to you.
Processing may be adapted to specific regulations in the country where the Services are provided, but the minimum standard is always the GDPR.
Use of artificial intelligence (AI)
In justified cases, we use artificial intelligence (AI) to provide Services (e.g., an AI chatbot that provides information and assists with queries).
We do not use AI for automated individual decision-making or profiling within the meaning of the GDPR, in particular Article 22. All processing is subject to human decision-making, and AI does not make decisions about you on its own.
Position of controller and processor
Given the nature of the Services, we may be:
Role of Personal Data Controller
In relation to Users, JustImagAine acts as a Personal Data Controller. This means that we process the personal data that you provide to us, such as your name or email address. A specific overview of the personal data processed, including the purposes and legal grounds for its processing, is provided in the following sections of this document. If you have any questions or concerns, you can contact us at any time at mhruby@justimagaine.com.
Processor (for our clients' customers)
If we provide a Service to our customers and its purpose is to communicate with and assist their users through an AI assistant, we may be in the position of a processor in relation to this data. Processing in this role is carried out on behalf of and according to the instructions of our customer and is governed by a data processing agreement (DPA).
What personal data we process
We process personal data to the extent necessary, comply with technical and organizational rules, and the process is automated, without profiling.
We process in particular:
First and last name, date of birth (ID number) and address, if applicable
Contact details (especially email, phone) and other data that you voluntarily provide in the user interface
Data in a query sent by a customer or other person
Data on the use of the AI assistant (e.g., data in trial use, time of registration, date of last profile update)
Billing information and bank details (for accounting and payments)
Information communicated during communication (questions/answers, communication with you)
IP address, activity data (including device/OS)
Operational data (especially AI assistant error statuses – time and address of the incident)
6. When and how we process personal data
We process personal data mainly if you are a website visitor, contact us, or are a customer. We only process data for as long as necessary; the periods below are approximate, depending on the nature of the purpose and legal obligations.
6.1. Website users
6.2. Customers
7. Legal basis for processing
We process personal data in a lawful manner, primarily on the basis of:
consent (e.g., newsletter subscription),
performance of a contract (provision of services),
compliance with a legal obligation (e.g., accounting, requirements of authorities),
legitimate interest (e.g., informing customers about news).
Personal data processing is carried out on the basis of:
Article 6(1)(b) of the GDPR – performance of a contract or negotiations for its conclusion,
Article 6(1)(c) of the GDPR – compliance with a legal obligation (e.g., accounting),
Article 6(1)(a) of the GDPR – consent to processing (when submitting a form).
Who are our processors
We only use verified processors with contractual arrangements and appropriate safeguards. Below is an overview (purposes and entities retained):
What measures we have taken to protect personal data
Our customers can influence the scope of processing within the provision of the Service through their own settings.
9.1. Technical measures
We regularly back up data,
update antivirus systems,
encrypt data transmission using SSL/TLS,
we use the secure https protocol,
we develop technology with privacy by design in mind,
access passwords and permissions are managed at the individual level.
What are your rights and how to exercise them
Contact for exercising your rights: mhruby@justimagaine.com or by mail to our registered office.
We will respond within 1 month at the latest. In justified cases, we may verify your identity. If providing information would jeopardize the rights of others or be disproportionate, we may not fully comply with the request. For repeated requests, a reasonable fee may be charged for a copy of the data.
Right + What it means
Right of access - We will confirm whether we process your data and provide information about the purposes, categories, recipients, processing time, and a copy of the data (unless this affects the rights of other persons).
Right to rectification - We will correct inaccurate data; some can be edited in your profile (if available).
Right to erasure - If there is no other reason for further processing, we will erase or anonymize the data.
Right to restriction of processing - If you believe that the processing is incorrect, you can request a restriction.
Right to notification of correction/erasure/restriction - We will inform you of the result; sometimes this may not be possible (e.g., non-functional email).
Right to portability - We will transfer the data you have provided to you or another controller in a structured, machine-readable format.
Right to object - If we process on the basis of a legitimate interest (e.g., newsletter to customers), you may object; if justified, we will terminate the processing.
Right to withdraw consent - Consent can be withdrawn at any time (especially for marketing).
Automated decision-making/profiling - We do not perform profiling; personal data may be processed automatically, but without making decisions about you within the meaning of Article 22.
11. Supervisory authority
If you are not satisfied, you can file a complaint with:
Office for Personal Data Protection
Pplk. Sochora 727/27, 170 00 Prague 7 – Holešovice
www.uoou.cz
or with another supervisory authority in your place of habitual residence.
12. Final provisions
These principles may only be changed in writing. You will be informed of any changes via the website, so please check it regularly. By continuing to use the Services, you acknowledge the changes.
If you have any questions, please contact us at mhruby@justimagaine.com.
This policy is effective as of December 18, 2025.
