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Imaginary — Privacy Policy

Last updated: 22 April 2026

1. About this policy and who is responsible

1.1 This Privacy Policy explains how Loomi Hong Kong Company Limited ("Imaginary", "we", "us", "our") — Company Registration No. 78760412, registered office Unit 2004-06, 20/F Strand 50, 50 Bonham Strand, Sheung Wan, Hong Kong — collects, uses, discloses and protects your personal data when you use the Imaginary platform and related services (the "Services").

1.2 We handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the "PDPO") and its Data Protection Principles. This policy forms part of, and should be read together with, our User Agreement.

1.3 "Personal data" has the meaning given in the PDPO — broadly, data relating to an identifiable individual.

2. What data we collect

  • Account data — for example your name or username, email address, password (stored in hashed form), and account settings.
  • Billing data — your plan, credit balance and transaction history. Card payments are handled by third-party payment processors; we do not store full card numbers.
  • Content data — the prompts, text, images, audio, video and other material you upload or submit ("Input"), and the content the Services generate for you ("Output").
  • Usage and device data — log data such as IP address, browser and device type, the pages and features you use, timestamps, and diagnostic/error reports.
  • Communications — messages you send us, such as support requests.

We collect this directly from you, automatically as you use the Services, and from our service providers (for example, a payment processor confirming a transaction). Providing personal data is voluntary, but without certain data (such as your email or payment details) we cannot provide the Services.

3. How we use your data

We use personal data to:

  • create and administer your account and provide the Services;
  • process payments, credits, subscriptions and refunds;
  • route your Input to Third-Party AI Providers to generate your Output;
  • operate, secure, maintain and troubleshoot the Services, and detect and prevent fraud, abuse and breaches of our terms or the law;
  • provide customer support and respond to your enquiries;
  • send you service and transactional messages (for example about your account, billing, security, or changes to our terms); and
  • comply with our legal obligations and enforce our terms.

We do not use your Input or Output to train, fine-tune or develop our own AI models.

4. Cookies and similar technologies

We use cookies and similar technologies that are necessary to run the Services (for example, to keep you signed in and remember your preferences) and, where used, to measure performance and usage. You can control cookies through your browser settings; disabling some may affect how the Services work.

5. Direct marketing

We will only use your name and contact details to send you marketing about our own products and features where permitted by law and, where the PDPO requires, with your consent. You can opt out of marketing at any time, at no cost, using the unsubscribe link or by emailing support@imaginary-ai.com. We do not provide your personal data to third parties for their own direct marketing.

6. Who we share your data with

We share personal data only as needed, with:

  • Third-Party AI Providers — when you generate content, your Input and Output are sent to the provider performing the generation (for example Google, BytePlus/Seedance, Alibaba, Kling, OpenAI, MiniMax and others, which may change over time). They process it under their own terms and privacy policies. See Section 8 on overseas transfers.
  • Service providers (processors) — vendors that host and run the platform (cloud hosting and storage), process payments, send email, and provide analytics and error monitoring, acting on our instructions.
  • Legal and safety — authorities, regulators or other parties where we believe in good faith that disclosure is required by law, or reasonably necessary to protect our rights, our users or the public, or in connection with a corporate transaction such as a merger or sale of assets.

We do not sell your personal data.

7. How long we keep it

We keep personal data only for as long as needed for the purposes above or as required by law. Content data is retained while your account is active and is deleted when you delete it or close your account, except for (a) copies we must keep to comply with law, resolve disputes or enforce our terms, and (b) routine backups, which we delete on our normal schedule. Output already sent to Third-Party AI Providers is also subject to their own retention practices.

8. Overseas transfer of data

Imaginary relies on providers and infrastructure located outside Hong Kong (including in the United States, mainland China and elsewhere). When you use the Services — in particular when you generate content — your personal data and content may be transferred to and processed in those locations by our providers under their own terms. We take reasonable steps to require our service providers to protect personal data in a manner consistent with this policy and applicable law.

9. Security

We use reasonable technical and organisational measures to protect personal data against unauthorised access, loss or misuse, including encryption in transit and access controls. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Your rights under the PDPO

Under the PDPO you have the right to:

  • access the personal data we hold about you; and
  • request correction of personal data that is inaccurate.

To make a data access or correction request, email support@imaginary-ai.com. We may need to verify your identity, and we may charge a reasonable fee for a data access request as permitted by the PDPO. You may also ask us to delete your data or close your account. If you have concerns about how we handle your personal data, you may complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong (www.pcpd.org.hk).

11. Children

The Services are intended for users aged 18 and over. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us personal data, contact us and we will delete it.

12. Changes to this policy

We may update this policy from time to time. We will post the updated version with a new "Last updated" date and, for material changes, give reasonable notice (for example by email or in-product). Continuing to use the Services after a change takes effect means you accept the updated policy.

13. Contact us

For questions, requests or complaints about privacy, contact support@imaginary-ai.com, or write to: Loomi Hong Kong Company Limited, Unit 2004-06, 20/F Strand 50, 50 Bonham Strand, Sheung Wan, Hong Kong.

Loomi Hong Kong Company Limited · Imaginary Privacy Policy · Last updated 22 April 2026