Privacy Policy
Last updated: 16 October 2026
This Privacy Policy explains how Chebellagiornata Srls handles personal information in connection with the ComiGami iOS application, the website comigami.com, and related support services (together, the “Service”). ComiGami was previously released under names including “Comic AI: Comics Generator” and “Comics AI: Comix Generator”; references to ComiGami in this Policy include those earlier versions where relevant.
For the rules governing subscriptions, credits, user content and use of the Service, please read our Terms of Use. This Privacy Policy is an information notice. Accepting the Terms or requesting a comic does not, by itself, authorize model training, advertising use or any other optional reuse of your content.
Key points: your saved characters, environments, drafts and downloaded comics are primarily kept on your iPhone. When you choose to create a comic, selected photographs, material information and your scene description are uploaded to our backend and sent to OpenAI through its API to produce the requested comic page. We do not perform facial recognition or biometric identification, and we do not use your photographs, prompts or generated comics to train our own AI models. Temporary server copies are subject to the retention periods described in Section 8.
1. Who is responsible for your information?
The data controller is Chebellagiornata Srls, with registered office at Via San Crispino 106, 35129 Padova, Italy, VAT number IT04962980282.
For privacy questions or requests, email info@chebellagiornata.com or write to our registered office, marked “ComiGami Privacy”.
2. Information we process and where it comes from
Anonymous identity and session information
ComiGami does not require a conventional email-and-password registration for its normal iOS flow. The App creates and uses an anonymous Firebase authentication identifier, session tokens and related security information so that requests can be associated with the correct user and protected from unauthorized access. We may also maintain an internal commercial identifier used to connect the same installation or user to purchase, credit and support records.
Anonymous does not mean that the information is necessarily anonymous under data-protection law. An identifier can remain personal information when it can be linked to a device, purchase, request or other record.
Characters, environments and other creative materials
You may add photographs of people, places or objects and provide a name, description or other details for each saved material. You may select multiple characters, an optional environment, an art style, a scene description and optional exact dialogue. The App also stores your current draft, selections and editing state so you can continue later.
Please upload only content you are entitled to use. Avoid unnecessary documents, contact details, medical information, precise financial information, government identifiers or other sensitive information. Requirements concerning another person’s image, including a child’s image, are explained in the Terms of Use.
Generated comics and local History
When generation succeeds, the completed comic page and related metadata can be downloaded and saved in the App’s local History. You can open, zoom, export to Photos or share a saved comic. We do not operate a public gallery or community feed as part of the current Service. Sharing through iOS or another platform is initiated by you and is then subject to the recipient platform’s privacy terms.
Free creation, credits, subscriptions and purchases
We process the identifiers and records needed to determine eligibility for the one-time free creation, maintain credit balances, reserve and consume credits, prevent duplicate charges, recover interrupted jobs, and show the next Premium allocation. These records may include credit-ledger entries, free-use status, job identifiers, timestamps, balance changes and the reason for each movement.
Apple, RevenueCat and our backend process product identifiers, transaction and purchase identifiers, subscription status, renewal, expiry, cancellation, refund or revocation information, entitlement status, purchased credit packs and related reconciliation events. Apple processes your payment method. We do not receive your full payment-card number or security code.
Technical, security and support information
We and our service providers process technical information needed to operate and protect the Service, such as IP address, app and operating-system version, device and locale information, timestamps, request and job identifiers, authentication results, network status, error codes, moderation or safety outcomes, model and configuration used, processing duration, token or usage information, estimated provider cost, rate-limit events and security records.
Operational logs are designed not to contain uploaded photographs or the full text of your story. A limited excerpt or technical payload may nevertheless be processed when reasonably necessary to investigate a specific failure, safety event or support request. Access is limited to what the investigation requires.
When you contact us, we process your contact details, message, support identifier, purchase information and any material you choose to send so we can respond. Please do not email photographs or sensitive information unless we specifically ask for what is necessary to resolve your request.
Website information
When you visit comigami.com, our website and hosting providers may process IP address, browser and device information, requested pages, timestamps, referral information, security events and cookie choices. If you submit a form or contact us, we process the information you provide. Optional website analytics are described in Section 10.
3. Local storage, Camera and Photos
Saved materials, thumbnails, drafts, preferences and downloaded comics are primarily stored in the App’s private storage on your device. Adding or editing a material does not, by itself, upload that photograph to our server. The App prepares optimized local copies so that very large images do not need to be transmitted unchanged.
When you use the Camera, the App uses the camera only to capture the photograph you request. When you choose an existing photograph, the native iOS picker provides the selected item rather than giving ComiGami unrestricted access to your entire photo library. Saving a comic to Photos requires the relevant iOS permission. The current creation flow does not need your microphone, contacts or precise location.
Deleting a material or comic through the App removes the corresponding local copy managed by ComiGami, subject to normal device and backup behavior. Deleting the App may remove local data. Depending on your iOS and backup settings, Apple may retain a device backup outside our control. ComiGami’s server result is temporary and is not a permanent cloud backup of your local History.
4. AI processing, photographs and face data
What is sent
When you press the creation button, the selected optimized photographs, material names and descriptions, scene text, selected style, dialogue instructions and necessary technical metadata are uploaded through our backend and transmitted to OpenAI through its API. The photographs are used as visual references so that people, places and objects can be reinterpreted in the selected comic style.
Before the first external AI upload, the App presents an explanation of this processing and asks you to confirm that you wish to continue. Declining prevents that new AI generation; it does not remove comics already stored locally or prevent you from exercising your privacy rights. You can withdraw that in-app confirmation for future uploads through the available Settings control, where implemented.
Faces and likenesses
Uploaded photographs may contain a human face. We use the image only to provide the visual transformation requested by you, operate safety controls and support the resulting job. ComiGami does not use the photograph to identify a person, verify identity, create a facial-recognition database, derive a biometric template, infer sensitive traits or track a person across services.
You must have the permission and rights necessary to use another person’s likeness. We may reject or restrict content where consent, safety or legality is in doubt. Special rules apply to images of minors; see Section 13 and the Terms of Use.
Training and OpenAI retention
We do not use your uploaded photographs, prompts or generated comic pages to train our own models, and we do not opt in to sharing ComiGami API content with OpenAI for general model training. OpenAI states that API inputs and outputs are not used to train its general models by default unless the API customer opts in.
OpenAI may generate abuse-monitoring logs that contain API inputs, outputs or derived safety information. Under its standard API controls, those logs may generally be retained for up to 30 days, with longer retention where required by law or reasonably necessary to protect OpenAI, its services or third parties. Endpoint-specific application-state retention can differ. We do not promise that ComiGami has Zero Data Retention at OpenAI. See OpenAI’s API data controls.
Safety review
Requests and outputs may be automatically checked for fraud, abuse, child-safety risks, unlawful content and other policy violations. A request may be refused or referred for proportionate review. We do not use this review to identify the people shown in your photographs.
5. Why we process information and our legal bases
Where the GDPR applies, we rely on the following legal bases:
- Providing the Service and performing our contract: creating and protecting the anonymous session, storing your local draft, receiving the materials you select, generating and recovering a comic, maintaining History, applying free-creation and credit rules, providing Premium features, restoring purchases and responding to support requests. This is necessary to perform our contract with you or take steps you request before entering it, under Article 6(1)(b) GDPR.
- Security, fraud prevention and operational reliability: preventing duplicate or unauthorized generations, protecting credits and purchases, applying reasonable rate and concurrency limits, diagnosing failures, reconciling uncertain jobs, measuring service reliability and maintaining proportionate records. We rely on our legitimate interests under Article 6(1)(f), balanced against your rights and expectations.
- Legal compliance: keeping records required by tax, accounting, consumer, payment and data-protection law; responding to lawful requests; and handling rights requests and legal claims, under Article 6(1)(c) and, where appropriate, Article 6(1)(f).
- Optional website technologies: non-essential analytics or marketing cookies rely on consent under Article 6(1)(a) and applicable electronic-communications rules. Refusing them does not prevent use of the core Service.
Device permissions and the in-app confirmation before an AI upload are separate from the GDPR legal basis. Granting Camera or Photos access does not authorize advertising, model training or unrelated reuse.
6. Who receives information?
We disclose information only as needed for the purposes described above. Relevant recipients and processors include:
- Railway: hosting of our API, PostgreSQL database, private temporary input and result storage, health monitoring and infrastructure logs. See Railway’s Privacy Policy.
- Google Firebase: anonymous authentication, token verification and associated security or service data. Using Firebase Authentication does not by itself mean that Firebase Analytics is enabled. See Firebase privacy and security information.
- OpenAI: external AI processing of selected photographs, scene instructions and related inputs, including safety controls. See OpenAI’s API data controls.
- RevenueCat: paywall presentation, product and entitlement information, purchase validation, subscription status, restoration, transaction events and reconciliation. See RevenueCat’s Privacy Policy.
- Apple: App Store purchases, renewals, refunds, subscription management, device permissions, native photo selection and associated platform services. See Apple’s Privacy Policy.
- Website hosting and technical providers: hosting, WordPress delivery, security, backups, consent management and support functions necessary to operate comigami.com.
- Google Analytics 4 and Google Tag Manager, where enabled after consent: optional measurement of website visits and interactions. Google Tag Manager deploys configured tags; it does not make those tags automatically necessary or consent-exempt. See Google’s Privacy Policy.
Authorized personnel and professional advisers may access information only where necessary for support, security, accounting, legal compliance or the establishment, exercise or defence of claims.
We do not sell your photographs, prompts, generated comics, purchase history or credit information. We do not disclose that content to advertising platforms to build advertising audiences, and we do not use your creative content for cross-context behavioural advertising.
Information may be disclosed to public authorities where lawfully required or to a successor in a merger, acquisition or business transfer, subject to applicable confidentiality and data-protection requirements.
7. International processing
We are based in Italy. Our providers and their authorized subprocessors may process information in the European Economic Area, the United States and other countries. Selecting an Amsterdam or other European hosting region does not mean that every support, security, purchase or AI-processing activity occurs exclusively in the EEA.
For transfers restricted by the GDPR, we rely on an applicable adequacy decision or appropriate safeguards, such as the European Commission’s Standard Contractual Clauses and supplementary measures where necessary. The applicable mechanism depends on the provider and transfer. You may contact us for information about safeguards relevant to your information, subject to necessary redactions.
8. How long we retain information
Local materials, drafts and History
Local characters, environments, other materials, drafts and saved comic pages remain on your device until you delete them, remove the App or the device storage is otherwise erased. Ending Premium does not by itself delete local content. Local content is not a complete cloud-synced library, and we may be unable to recover it after device loss, deletion or backup failure.
Temporary server inputs and results
Selected photographs and other generation inputs placed in our private server storage are configured for deletion within 24 hours of upload. A generated result is configured to remain recoverable in private server storage for up to 7 days. Temporary download links normally expire after approximately 5 minutes; link expiry does not itself delete the underlying result before its retention period ends.
These periods support interrupted-job recovery and are separate from OpenAI’s own retention described in Section 4. Deletion schedules can be delayed where necessary to investigate an active security incident, comply with law, preserve evidence or complete a deletion or recovery operation. Restricted backups, where used, follow their own rotation cycle and are not restored for ordinary product use after a valid deletion request.
Job, credit, purchase and operational records
We retain job metadata, idempotency records, free-use status, credit reservations and ledger entries, subscription and purchase events, refund or revocation records, security events and limited diagnostics for as long as reasonably necessary to provide and reconcile the Service, prevent duplicate benefits or fraud, answer disputes, comply with accounting and legal obligations and establish or defend claims. Deleting a local comic does not restore credits or automatically erase these separate records.
Support and legal records
Support correspondence is retained for the time needed to resolve the request and for a proportionate period afterward. Transaction, tax and legal records may be retained for the statutory period. Independently held Apple records are governed by Apple’s rules.
Deletion requests
You can delete individual materials, drafts and comics using the App’s local controls. To request access to or deletion of server-side identity, job, credit or support information, email info@chebellagiornata.com. Because the App normally uses an anonymous identity, we may ask for the ComiGami support identifier, purchase reference or other proportionate information needed to locate and protect the correct records.
Some records may be retained where required by law or necessary to protect purchases, prevent duplicate free benefits or credits, resolve disputes or maintain security. We will explain an applicable exception when responding. Deleting local or server data does not automatically cancel an Apple subscription; cancellation is handled separately through Apple.
9. Diagnostics, analytics and service improvement
We use limited operational events and aggregate measurements to understand whether onboarding, the free creation, generation, recovery, paywalls, purchases and support functions work. These measurements are designed to use pseudonymous identifiers, status codes and counters rather than uploaded photographs or full story text.
Operational diagnostics do not authorize us to build a reusable training dataset from your identifiable photographs, descriptions or generated comics. Any future programme to reuse identifiable creative content for model training, evaluation, promotion or another materially different purpose would require a separate assessment, updated information and any consent required by law. Acceptance of the Terms, use of free credits or purchase of Premium is not consent to that reuse.
10. Website cookies, analytics and App tracking
Necessary technologies
The website and App use necessary storage and connection technologies for security, session continuity, consent choices, purchase recovery and requested functionality. Blocking necessary storage may prevent parts of the Service from working.
Optional website analytics
Where enabled, Google Analytics 4 may measure website visits and interactions using browser and device characteristics, page views, referral information and online identifiers. Non-essential tags must remain disabled until you make the relevant affirmative choice where consent is required. You can change or withdraw that choice through the website’s cookie controls. The cookie interface should identify the technologies actually active, their purposes and their durations.
iOS App tracking
At the date of this Policy, ComiGami does not use your creative content for advertising and is not designed to use the Apple advertising identifier for cross-app advertising tracking. RevenueCat’s purchase and entitlement reporting and our own operational metrics are used for App functionality, subscription administration, fraud prevention and product reliability; they are not permission to send photographs or prompts to advertising networks.
If advertising or non-essential in-app analytics are introduced later, we will first update the description of the actual data flow and choices and obtain any consent or Apple authorization required. Mentioning a possible future integration does not authorize it.
11. Your privacy rights
Depending on applicable law, you may request access to your personal information, correction, deletion, restriction of processing, or a portable copy of eligible information. You may object to processing based on legitimate interests and withdraw consent at any time where consent is the basis. Withdrawal does not affect processing already carried out lawfully.
Send requests to info@chebellagiornata.com. Please describe the request and provide the support identifier or purchase reference needed to locate the correct anonymous account, without sending unnecessary sensitive information. We may request proportionate verification to protect you and other users.
For GDPR requests, we normally respond within one month. Where the law permits an extension because of complexity or volume, we will explain it within the initial period. Requests are normally free; any legally permitted exception will be explained.
You may complain to the Italian Data Protection Authority (Garante per la protezione dei dati personali) or the competent supervisory authority where you live, work or believe an infringement occurred.
ComiGami does not make legal or similarly significant decisions about you. An automated safety, fraud or access restriction may affect whether a generation can proceed; you may contact us to request review.
12. Additional information for United States residents
Depending on your state and whether the relevant law applies to us, you may have rights to know, access, correct, delete or obtain a copy of personal information; to appeal certain refusals; and to opt out of sale, sharing for cross-context behavioural advertising, targeted advertising or certain consequential profiling.
We do not sell personal information for money. We do not sell or share creative content, purchase records or credit data for targeted advertising. If our website later uses advertising technologies whose disclosure constitutes a “sale” or “sharing” under applicable state law, we will provide the required notice and control and recognize legally required opt-out preference signals, such as Global Privacy Control.
Submit a request using the contact details in Section 11. An authorized agent may act where permitted, subject to appropriate proof of authority. Where you have a right to appeal, reply to our decision or email us with the subject “Privacy appeal”. We do not unlawfully discriminate against you for exercising privacy rights.
13. Minimum age and children’s information
The Service is currently restricted to people aged 16 or older. It is not offered as a child-account service for younger users, and we do not represent that we operate a verified parental-consent process for users under 16. An App Store content rating describes content suitability; it is not proof of age, parental permission, capacity to contract or a legal basis for processing personal information.
Users aged 16 or 17 may still need a parent or legal guardian’s authorization to enter a contract or make purchases under applicable law. Contact us if you believe a younger person has used the Service contrary to this restriction so we can investigate and handle the information appropriately.
Do not upload an image of a minor unless you are the parent or legal guardian or otherwise have lawful authority and the proposed use is appropriate. Content that exploits, sexualizes, endangers, humiliates or otherwise harms a minor is strictly prohibited and may be blocked, preserved where legally required and reported to the competent authorities.
14. Security
We use measures appropriate to the information and risks, including encrypted connections, anonymous authentication, token verification, private storage, owner checks, time-limited download links, rate and concurrency controls, separation of environments, access restrictions and monitoring designed to avoid logging full creative content.
No online service or device storage is completely secure. Protect access to your iPhone and Apple Account, keep the App and operating system updated, and contact us promptly if you suspect unauthorized use. Do not share support identifiers or purchase information publicly.
15. Changes and contact
We may update this Policy to reflect changes to the Service, providers or legal requirements. We will change the date above and provide appropriate notice of material changes before they take effect. Where a new purpose requires consent, publishing an update or continuing to use the Service will not replace that consent.
Contact: info@chebellagiornata.com.