Privacy Notice
Effective date: effective date
1. Who is responsible for your data
Adgenious s.r.o., Světova 523/1, Libeň, 180 00 Praha 8, Czech Republic, IČO 19103999, VAT CZ19103999, is the controller of personal data processed for ToonyHub at https://toonyhub.com. For privacy enquiries and requests, email support email or write to our registered office marked "Privacy".
This Notice covers visitors, account holders, customers and people who contact us or submit reports. It explains processing under the EU General Data Protection Regulation (GDPR) and applicable Czech data protection legislation.
2. Data, purposes and legal grounds
We obtain data from you, your use of the service, transaction providers and, where you choose one, an external sign-in provider. A complainant or rights holder may also provide information relevant to a report. The information processed depends on the features you use.
| Purpose | Personal data involved | GDPR legal basis |
|---|---|---|
| Creating and operating your account | Account email, authentication information, selected profile details, account settings and sign-in records | Performance of the account contract |
| Supplying purchases and maintaining your library | Subscription status, purchases and saved reading progress | Performance of the purchase contract |
| Processing payments and recurring charges | Billing details, transaction identifiers, amount, currency, payment status and payment-method references | Performance of the purchase contract; legal obligations for required accounting and tax records |
| Answering requests and handling complaints | Contact details, correspondence, relevant transaction or content information and supporting evidence | Performance of the contract for service requests; legal obligations where applicable; legitimate interests in resolving other enquiries and protecting legal rights |
| Protecting accounts and the service | IP address, device and browser information, access logs, suspicious events and relevant account activity | Legitimate interests in preventing fraud, abuse and unauthorised access; legal obligations where applicable |
| Complying with law and handling legal claims | Records necessary for tax, accounting, regulatory requests and the establishment, exercise or defence of legal claims | Legal obligations; legitimate interests in protecting legal rights where processing is not legally required |
| Optional analytics and advertising, where used | Device identifiers, consent choices and usage events described in the Cookies Notice | Consent for the optional processing described at the time of collection |
| Sending marketing messages, where offered | Contact details, preferences and consent or opt-out records | Consent, or legitimate interests for our own similar products only where electronic-marketing law permits it with an opt-out |
Payment providers and the payment information received or stored directly by ToonyHub: payment providers and data handling.
Age-verification processing, including whether an external provider is used, the data involved, legal basis and retention: age verification details.
Details of any recommendation profiling or automated decisions with legal or similarly significant effects, including the logic, consequences and available human review where relevant: profiling and automated decision details.
We do not treat ordinary contractual necessity as permission to process special-category data. If a feature requires such processing, we will identify the additional legal condition and provide the relevant information before it occurs.
3. Required and optional information
Information needed to create an account, identify a purchase or complete payment is necessary for the corresponding service. If it is not supplied, we may be unable to provide that service. Mandatory fields are identified when collected. Optional profile information, optional cookies and marketing consent are not a condition of purchasing a subscription.
Please provide only information relevant to your request. Do not send passwords, full card numbers or unnecessary identity documents through ordinary support correspondence.
4. Recipients
We disclose information as necessary to providers that host and deliver the website, operate authentication and communications, process payments, provide support tools, or protect the service. Optional analytics and advertising recipients are identified in the cookie information and consent interface where those tools are used. Providers acting on our instructions are subject to appropriate data-processing arrangements; payment providers and other recipients may also act as independent controllers for their own legal purposes.
We may disclose relevant records to professional advisers, courts, regulators, competent authorities or parties to a dispute where legally required or necessary to protect legitimate rights. In a business restructuring or transfer, relevant data may be disclosed under appropriate confidentiality and data-protection safeguards. This does not authorise unrelated uses of your data.
Actual service providers, their processing roles and privacy information: service providers and roles.
Sale or sharing of personal data for advertising purposes, and any applicable opt-out arrangements: advertising disclosures and choices.
5. International transfers
Where processing involves a transfer outside the European Economic Area, the transfer must have an applicable legal mechanism, such as a European Commission adequacy decision or appropriate contractual safeguards with any necessary supplementary protections. A provider's location alone does not establish that it is covered by an adequacy decision.
Transfer destinations, relevant recipients and safeguards used: international transfers and safeguards.
You can contact support email for information or a copy of applicable transfer safeguards, with unrelated confidential information redacted where appropriate.
6. Retention
We retain data only for as long as needed for the purpose for which it is processed or for a lawful retention requirement. Account information and reading records are retained while needed to operate the account. After account closure, data no longer needed is deleted or anonymised, subject to necessary transaction records and legal holds.
Accounting and tax records are kept for the periods required by Czech law. Contract and complaint records are retained for relevant limitation periods and, where necessary, until an actual dispute ends. Security records are retained for the time needed to detect and investigate incidents. Consent records are kept as needed to demonstrate the choices made; minimal suppression information may be retained to respect an opt-out.
Operational deletion and backup cycles, security-log periods and any separate analytics or marketing retention periods: retention periods and deletion cycles. Cookie lifetimes appear in the Cookies Notice.
7. Your rights and choices
Subject to the GDPR's conditions, you may request access to and a copy of your personal data, correction, erasure, restriction of processing, and portability of data processed by automated means on the basis of consent or contract. You may object to processing based on legitimate interests for reasons relating to your particular situation. You may object to direct marketing at any time, including related profiling.
Where processing relies on consent, you may withdraw that consent at any time without affecting the lawfulness of earlier processing. Use the unsubscribe link in a marketing email, the relevant cookie controls, or contact support email. Essential account or billing messages are separate from marketing.
Send data-rights requests to support email. We may request proportionate information if needed to verify identity. We respond without undue delay and ordinarily within one month. Where the GDPR permits an extension for complexity or the number of requests, we explain it within the initial month. Requests are normally free, subject to the limited exceptions allowed by law.
You may complain to the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů), Pplk. Sochora 27, 170 00 Praha 7, Czech Republic: uoou.gov.cz. You may also use another competent supervisory authority, including in your EU place of residence, work or the alleged infringement. You do not have to contact us before exercising that right.
Processing in the context of our Czech establishment is subject to the GDPR even where a user lives outside the EU. Additional rights under another applicable privacy law remain available.
8. Security, children and updates
We use technical and organisational safeguards appropriate to the processing risks. No internet service can guarantee absolute security. Report a suspected account or data incident to support email.
ToonyHub is intended for adults. If we learn that a person below the permitted age has an account, we will restrict access and address the associated data in accordance with applicable law. Contact us to report an age-related concern.
We may update this Notice to reflect our actual practices or changes in law. The effective date identifies the current version. We provide additional notice or obtain consent where required; continued use alone is not consent to a new consent-based purpose.