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, 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
- 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 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
- Maintaining login sessions
- Security
Analytics Cookies
- Analyzing service usage patterns
Functional Cookies
- 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
- Creating accounts
- User authentication and login
Service Functionality
- Providing content generation features
- Content storage
Payment and Billing
- Subscription management
- Payment processing
- Refund processing
Service Improvement
- Error analysis
- Performance improvement
- User experience enhancement
Security and Abuse Prevention
- Preventing account misuse
- Preventing fraudulent activity
Customer Support
- Responding to inquiries
- Providing service assistance
Marketing and Notifications
- Event notifications
- 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.
- 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
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:
- When the user has provided consent
- When required by law
- 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:
- Cloud hosting and server operation
- Payment processing services
- Log analysis and error tracking
- Email delivery services
- 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
- 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
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.
- Payment records
- Legally required records
- Security-related logs
9. User Rights
Users have the following rights.
- Request access to personal information
- Request correction of personal information
- Request deletion of personal information
- Request restriction of processing
- 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:
- 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 or service operations.
Important changes will be notified through the Service or by email.
13. Contact
Data Protection Officer
Han Jung (CEO)
comitia2025@gmail.com