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Privacy Policy
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Comitia Privacy Policy

Effective Date: March 6, 2026

Version: 1.0

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, 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

We may collect the following types of personal information.

2.1 Information Provided Directly by Users

Account Information

  1. Email address
  2. Password (stored in encrypted form)
  3. Nickname and profile information

Payment Information

  1. Payment method identifier
  2. Payment history
  3. Billing address (when required)

Customer Support

  1. Inquiry content
  2. Attachments
  3. Support records

Content Input Information

  1. Prompts
  2. Character settings
  3. Story settings
  4. Uploaded images
  5. Generated content

2.2 Automatically Collected Information

The following information may be automatically collected when using the Service.

  1. IP address
  2. Access date and time
  3. Browser and device information
  4. Operating system information
  5. Language settings
  6. Estimated country or region
  7. Service usage logs
  8. Page visits and click records

2.3 Cookies and Similar Technologies

We may use cookies or similar technologies to provide the Service.

Purpose of Cookies

Essential Cookies

  1. Maintaining login sessions
  2. Security

Analytics Cookies

  1. Analyzing service usage patterns

Functional Cookies

  1. Saving language and user preference settings

Users may refuse cookie storage through browser settings. However, some service functions may be limited.

3. Purpose of Processing Personal Information

We use personal information for the following purposes.

Service Provision and Account Management

  1. Creating accounts
  2. User authentication and login

Service Functionality

  1. Providing content generation features
  2. Content storage

Payment and Billing

  1. Subscription management
  2. Payment processing
  3. Refund processing

Service Improvement

  1. Error analysis
  2. Performance improvement
  3. User experience enhancement

Security and Abuse Prevention

  1. Preventing account misuse
  2. Preventing fraudulent activity

Customer Support

  1. Responding to inquiries
  2. Providing service assistance

Marketing and Notifications

  1. Event notifications
  2. Service announcements (with user consent)

3.1 Legal Basis for Processing Personal Information

We process personal information based on the following purposes and legal bases.

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

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.

However, the following data are not used as AI training data.

  1. Uploaded images
  2. Text prompts
  3. Character settings
  4. Story settings
  5. Generated outputs

These data are processed only for the following purposes.

  1. Processing content generation requests
  2. Delivering generated outputs
  3. Ensuring service stability
  4. Error analysis

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.

Exceptions include:

  1. When the user has provided consent
  2. When required by law
  3. When requested by law enforcement authorities through lawful procedures

6. Outsourcing of Personal Information Processing

We may outsource certain tasks to external service providers to operate the Service.

Examples include:

  1. Cloud hosting and server operation
  2. Payment processing services
  3. Log analysis and error tracking
  4. Email delivery services
  5. Customer support services

Service providers process personal information only within the scope necessary to provide the Service.

7. International Data Transfers

Personal information may be processed or stored on servers located outside the Republic of Korea (e.g., the United States).

We apply appropriate safeguards in accordance with applicable laws.

8. Data Retention and Deletion

Retention Period

Account Information

  1. Until account deletion

Payment Records

  1. Up to 5 years as required by applicable laws

Security Logs

  1. Up to 1 year for service security and operation

Customer Support Records

  1. Up to 3 years for service improvement and dispute resolution

Account Deletion

When a user deletes their account, personal information will be deleted within a reasonable period.

However, the following information may be retained for a certain period.

  1. Payment records
  2. Legally required records
  3. Security-related logs

9. User Rights

Users have the following rights.

  1. Request access to personal information
  2. Request correction of personal information
  3. Request deletion of personal information
  4. Request restriction of processing
  5. Withdraw consent

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.

Examples include:

  1. HTTPS encryption
  2. Access control management
  3. Security log monitoring
  4. Security vulnerability assessments

12. Policy Changes

This Privacy Policy may be updated due to changes in laws 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