Legal · Review draft
Privacy Policy
Draft prepared 6 September 2026. Not yet effective.
1. Who is responsible
Juice d.o.o., Croatia, operates Amy and is the controller for personal information used to manage Amy accounts, service communications, security, and its own business administration. Registered address: Prolaz Marije Krucifikse Kozulić 1, 51000 Rijeka, Croatia. Privacy contact: [TO CONFIRM]. Where a customer decides why and how personal data is used in its project or app, that customer will generally be the controller and Juice may act as its processor. Contact that app’s operator for its own privacy notice and requests about its processing.
2. Information Amy handles
Account information includes your name, email address, password hash, and authentication information. Project content can include conversations, uploaded files, intent models, proposals, versions, collaboration details, imported repository material, and app records. Execution and model-call records may include inputs, prompts, replies, actions, checks, timing, model identifiers, and usage or cost estimates. Connected-service information can include credentials and repository or account identifiers. Support correspondence and operational request information may also contain personal information. Pending: verify deployed infrastructure logs and any invoicing information actually collected.
3. Where information comes from
Information comes from you, your use of Amy, people who invite you or manage your workspace, and services connected with authorization. An app operator may supply an app user’s email and role. Repository imports and connected agents can supply content containing information about others. The relevant customer must establish permission and provide required notices for information it contributes.
4. Why information is used
Account and requested service processing is intended to perform our contract with an individual customer, or take requested steps before entering it. For organizational users, administration and communication may rely on legitimate interests in serving the organization. Security, abuse prevention, and resolving support issues may rely on legitimate interests in operating a reliable service, balanced against individuals’ rights. Applicable legal obligations may require business-record retention or disclosure. Optional processing requiring consent must use a separate consent mechanism. Pending: validate these purposes and bases against actual operations, including analytics and any marketing; this notice itself does not request consent.
5. AI processing
Amy sends relevant requests and context to the provider selected or configured for the operation. This may include conversation history, intent files, current app records, and other context needed to compose a turn or interpret an operation. The code supports Google, OpenAI, and Anthropic; actual recipients depend on enabled configurations. Prompts and replies can also be stored in Amy’s history and logs. A personal API key does not keep the request inside Amy. Pending: confirm the providers actually used, account-level training settings, provider retention, and whether Juice uses any customer content for model training. No no-training or zero-retention promise is made in this draft.
6. Who can receive information
Authorized workspace members, project collaborators, app operators, and connected developers or agents may receive information within the access granted to them. Service suppliers process information needed for hosting, storage, transactional email, analytics, and AI functionality. Juice uses DigitalOcean in Frankfurt, Germany, to host Amy and its database, Brevo for transactional email, and Simple Analytics for marketing-site analytics. We may disclose information where required by law or necessary to address legal claims. Publicly published content can be accessed and copied by others. Pending: confirm any payment provider and the applicable processor agreements, recipient entities, and subprocessor details.
7. International transfers
Amy and its database are hosted on DigitalOcean in Frankfurt, Germany, within the European Economic Area. This does not establish the location of processing by AI providers, email and analytics suppliers, connected integrations, or their subprocessors. Some of those recipients may process information outside the European Economic Area. Publication blocker: confirm processing locations, recipient entities, and the applicable transfer arrangements, such as a relevant adequacy decision or contractual safeguards with any necessary additional measures. The final notice must explain how to obtain information about those safeguards. This draft does not assert that a particular supplier’s transfer arrangement has been verified.
8. Cookies, local storage and analytics
Amy uses the aimie_token cookie for workspace sign-in and aimie_app for sign-in to individual apps. They authenticate sessions; they are not advertising cookies. The app-user session is configured for up to 30 days. Browser storage may remember interface preferences. The marketing pages load Simple Analytics with a setting to respect Do Not Track. Pending: verify the full deployed cookie/storage inventory, workspace-session duration, actual analytics collection and retention, and whether any optional trackers require consent. Do not add advertising or optional tracking under this draft without updating the notice and relevant controls.
9. Retention and deletion
Project content is kept to support ongoing work, history, and configured app operation. Deleting an individual file or record may leave version or execution history. Project deletion removes multiple associated content collections, but that alone does not establish deletion of account records, independent usage records, backups, or provider-held information. Publication blocker: approve specific retention periods or sufficiently clear criteria for accounts, content, model traces, security/usage logs, support records, billing records, and backups; confirm closure and deletion procedures. Do not promise immediate or complete erasure until those procedures are verified.
10. Security
The implementation hashes passwords, uses HTTP-only authentication cookies, and supports encryption of stored model-provider keys. Access restrictions separate projects and app users. Production protection also depends on deployment configuration and supplier controls. No system is completely secure. Pending: validate production configuration, backup protection, access reviews, incident response, and the process for meeting applicable breach-notification duties.
11. Your choices and rights
Depending on the processing and applicable law, you may request access, correction, erasure, restriction, or portability, and object to processing based on legitimate interests. Where processing relies on consent, you may withdraw it without affecting earlier lawful processing. Some rights have legal exceptions. Send requests to the confirmed privacy contact; proportionate identity verification may be needed. Requests concerning customer-controlled app data should go to that operator, with Juice assisting where it acts as processor. You can complain to a competent supervisory authority, including Croatia’s AZOP. Pending: establish the request-handling channel and workflow before publication.
12. Automated decisions and children
Amy uses agents to generate content, compose interfaces, and interpret operations. Customers may configure workflows affecting individuals and must assess their own legal obligations, including any restrictions on solely automated decisions with significant effects. Pending: confirm whether Juice itself makes such decisions about users and disclose their operation and safeguards if applicable. Also confirm age eligibility and the handling of information about children; this draft does not claim an age-verification system exists.
13. Changes and contact
The final policy should state its effective date and describe how material changes are communicated. Privacy information is a notice about processing, not blanket consent to every use of information. Contact: [CONFIRMED PRIVACY EMAIL AND POSTAL ADDRESS REQUIRED]. A separate data processing agreement is needed where Juice processes personal information on a customer’s behalf.
Drafting references
General Data Protection Regulation · EU consumer distance-selling guidance · Croatian supervisory authority