Comitia Privacy Policy
1. Overview
Comitia (“Company,” “we,” or “us”) provides digital comic creation and related services and values the protection of users’ personal information.
This Privacy Policy explains the types of personal information collected, the purposes for which such information is used, how it is stored, how advertising and AI-related data processing may occur, and the rights of users when using the Comitia service (“Service”).
The Service may be provided to users worldwide, and applicable privacy laws of the user’s country or region may apply.
2. Information We Collect
2.1 Information Provided Directly by Users
Account Information
- Email address
- Password stored in encrypted form
- Nickname and profile information
Payment Information
- Payment method identifier
- Payment history
- Billing address when required
Customer Support
- Inquiry content
- Attachments
- Support records
Content Input Information
- Prompts
- Character settings
- Story settings
- Uploaded images
- Generated content
2.2 Automatically Collected Information
The following information may be automatically collected when using the Service.
- IP address
- Access date and time
- Browser and device information
- Operating system information
- Language settings
- Estimated country or region
- Service usage logs
- Page visits, clicks, and interaction records
- Advertising interaction data where advertisements are displayed
2.3 Cookies and Similar Technologies
We may use cookies or similar technologies to provide, secure, improve, analyze, and personalize the Service.
- Essential cookies: maintaining login sessions and security
- Analytics cookies: analyzing service usage patterns and improving performance
- Functional cookies: saving language and user preference settings
- Advertising cookies: serving, measuring, limiting frequency of, and improving advertisements where advertisements are displayed
Users may refuse or delete cookies through browser settings. However, disabling cookies may affect certain features of the Service.
2.4 Advertising Cookies and Google AdSense
Comitia may display advertisements through Google AdSense or other advertising partners.
Third-party vendors, including Google, may use cookies, web beacons, IP addresses, device information, or similar technologies to serve advertisements based on a user’s prior visits to Comitia or other websites.
Google’s use of advertising cookies enables Google and its partners to serve personalized or non-personalized advertisements to users based on their visit to Comitia and/or other sites on the Internet.
Users may opt out of personalized advertising through Google’s Ads Settings. Users may also manage or disable cookies through their browser settings. Where required by applicable law, including for users in the European Economic Area, the United Kingdom, and Switzerland, Comitia will request consent before using cookies or personal data for personalized advertising.
3. Purpose of Processing Personal Information
We use personal information for the following purposes.
- Service provision and account management, including account creation, login, and authentication
- Service functionality, including content generation features and content storage
- Payment and billing, including subscription management, payment processing, and refund processing
- Service improvement, including error analysis, performance improvement, and user experience enhancement
- Security and abuse prevention, including preventing account misuse, fraudulent activity, spam, and system abuse
- Customer support, including responding to inquiries and providing service assistance
- Marketing and notifications, including event notifications and service announcements with user consent
- Advertising operations, including ad serving, ad measurement, frequency control, fraud prevention, and advertising personalization where permitted by law
3.1 Legal Basis for Processing Personal Information
| Processing Purpose | Legal Basis |
|---|---|
| Account creation and login | Contract performance |
| Content generation services | Contract performance |
| Payment and subscription management | Contract performance |
| Service security and abuse prevention | Legitimate interest |
| Service improvement and error analysis | Legitimate interest |
| Customer support | Contract performance |
| Marketing and event notifications | User consent |
| Advertising personalization where required by law | User consent |
| Non-personalized advertising, ad measurement, and fraud prevention | Legitimate interest or consent where required by applicable law |
We may also process personal information to comply with legal obligations where required by applicable laws.
4. AI Function Operation and Data Usage
Comitia may process user prompts, settings, and generation requests to provide AI-based features within the Service.
The following data are not used as AI training data without explicit user consent.
- Uploaded images
- Text prompts
- Character settings
- Story settings
- Generated outputs
These data are processed only for the following purposes.
- Processing content generation requests
- Delivering generated outputs
- Ensuring service stability
- Error analysis
- Safety review, abuse prevention, and policy enforcement where necessary
Comitia does not use users’ creative content for AI model training without explicit user consent. AI-generated outputs may sometimes resemble existing content due to the statistical nature of AI systems.
5. Sharing Personal Information with Third Parties
We do not provide users’ personal information to third parties without consent, except in the following cases.
- When the user has provided consent
- When required by law
- When requested by law enforcement authorities through lawful procedures
- When necessary to operate the Service through service providers acting on our behalf
5.1 Advertising Partners
When advertisements are displayed on the Service, advertising partners such as Google may collect or process certain information through cookies, web beacons, IP addresses, device identifiers, or similar technologies for ad serving, ad measurement, fraud prevention, and personalization where permitted by law.
Comitia does not provide Google with information that directly identifies users, such as passwords, private account credentials, or payment card numbers.
6. Outsourcing of Personal Information Processing
We may outsource certain tasks to external service providers to operate the Service.
- Cloud hosting and server operation
- Payment processing services
- Log analysis and error tracking
- Email delivery services
- Customer support services
- Advertising, analytics, and fraud prevention services
Service providers process personal information only within the scope necessary to provide the Service or the applicable outsourced service.
7. International Data Transfers
Personal information may be processed or stored on servers located outside the Republic of Korea, including the United States. We apply appropriate safeguards in accordance with applicable laws.
8. Data Retention and Deletion
Retention Period
- Account information: until account deletion
- Payment records: up to 5 years as required by applicable laws
- Security logs: up to 1 year for service security and operation
- Customer support records: up to 3 years for service improvement and dispute resolution
- Advertising and analytics logs: retained only as long as necessary for ad measurement, fraud prevention, analytics, and legal compliance
When a user deletes their account, personal information will be deleted within a reasonable period. However, payment records, legally required records, and security-related logs may be retained for a certain period.
9. User Rights and Advertising Choices
Users may have the following rights depending on applicable law.
- Request access to personal information
- Request correction of personal information
- Request deletion of personal information
- Request restriction of processing
- Withdraw consent
- Object to certain processing activities
- Manage cookie settings through browser settings
- Opt out of personalized advertising through Google’s Ads Settings or other applicable industry opt-out tools
Requests may be submitted through the contact information below.
10. Children’s Privacy
The Comitia Service is not intended for children under the age of 13. If we become aware that personal information has been provided by a child under 13, such information will be deleted.
11. Security Measures
We implement reasonable security measures to protect personal information.
- HTTPS encryption
- Access control management
- Security log monitoring
- Security vulnerability assessments
12. Policy Changes
This Privacy Policy may be updated due to changes in laws, advertising partner requirements, or service operations. Important changes will be notified through the Service or by email.
13. Contact
Data Protection Officer: Han Jung (CEO)
Email: comitia2025@gmail.com