Privacy Policy

1. Introduction

This Privacy Policy describes how Superapp Labs Teknoloji A.Ş. ("Superapp Labs", "we", "us", or "our") collects, uses, and protects your personal data when you use Comics AI.

Superapp Labs is the data controller for the personal data described in this Policy, within the meaning of the Turkish Personal Data Protection Law No. 6698 ("KVKK"), the EU and UK General Data Protection Regulation ("GDPR") and other applicable data protection laws.

2. Information We Collect

• App Identifier: When you first open the app, we create an anonymous account for you and assign it an app identifier, so that your library, characters, coins and subscription status can be kept and restored. You do not need to provide your name or email address to use the app.
• Usage Data: App interactions, logs, crash reports, and device identifiers (IP address, IDFA, IDFV, Android Advertising ID). On iOS, we access the IDFA only if you allow tracking through Apple's App Tracking Transparency prompt.
• Payment Information: Subscription and transaction details processed by Apple App Store or Google Play Store, including purchase, renewal, cancellation, refund and chargeback notifications. We do not store your payment card or banking information.
• Coin and Transaction Records: Your coin balance and a record of coins granted, purchased, spent and refunded.
• Content Data: Text prompts, narrative inputs, character settings, photographs you upload for character creation, and the comics, characters and covers generated for you ("Generated Content").
• Notification Data: A push notification token, if you allow notifications.
• Deletion Feedback: If you delete your account, the reasons you select and any comment you write. This is stored separately, is not linked to your app identifier, and is used only to improve the app.

Before you upload a photo for the first time, you will be presented with a disclosure screen explaining how your photo is processed and identifying the AI service providers involved. By proceeding, you provide explicit consent for the photo to be transmitted to our AI processing services.

3. Use of Information

We use your data to:

• provide and operate our services, including generating comics, characters and covers from your inputs;
• keep your library, characters, coins and subscription status linked to your app identifier;
• process subscriptions and coin purchases, apply coin refunds for failed generations, and adjust coin balances after store refunds or chargebacks;
• send you notifications, for example when a generation is complete;
• customize your experience and test different versions of app screens, such as onboarding and subscription offers, to improve the app;
• analyze usage and fix crashes and errors;
• check prompts, photos and Generated Content for prohibited material, as described in Section 5;
• deliver customer support; and
• protect against fraud and abuse and comply with legal obligations.

4. Legal Bases for Processing

Where KVKK, GDPR or similar laws apply, we process your personal data on the following bases: performance of our contract with you (providing the app and your subscription); our legitimate interests (security, fraud prevention, content safety, analytics and product improvement); compliance with legal obligations; and your consent (sending photos and prompts to third-party AI providers, tracking for advertising measurement where required, and push notifications). You may withdraw your consent at any time, without affecting processing carried out before withdrawal.

5. Character Photos and Content Safety

When you upload a photo to create a comic character, the photo is stored and linked to the character profile you create. You can delete your character and its photo at any time from within the app. We do not use your photos to identify you, for identity verification, advertising, or AI model training.

To keep the service safe, prompts, uploaded photos and Generated Content are checked by automated systems for prohibited material, such as sexual content, content involving minors, deceptive impersonation of real people, objectionable content and copyrighted material. These checks are used only to enforce our Terms of Use. If content is flagged, the generation may be blocked or the content removed.

6. Sharing of Information

We do not sell your personal information. We share data only with service providers supporting our operations, payment processors, and when required by law.

Sharing with Third-Party AI Services

Certain features are powered by third-party AI services. The following applies:

• What data is sent: Photographs, text prompts, and associated content data. We do not transmit account credentials, payment information, or device identifiers to AI providers.
• Who the data is sent to: Fal.AI (image generation) and Google Cloud (infrastructure and AI processing). These providers are contractually prohibited from using your data for any other purpose.
• Consent: An explicit consent prompt is displayed before your data is first transmitted. You may decline AI data sharing. If you decline, features that require AI processing, such as creating comics and characters, will not be available, while other parts of the app remain accessible.

Other Service Providers

• Google Firebase: app identifier and authentication, database, crash reporting and push notifications.
• Google Cloud: hosting and storage of your content.
• Adapty: subscription management, purchase validation, and testing of subscription screens.
• Apple App Store and Google Play Store: payment processing.

7. Third-Party Analytics and Attribution

We use Firebase Analytics for usage analytics and crash reporting, Mixpanel for product analytics, and Adjust for attribution and campaign measurement. These services may collect usage data and device identifiers in accordance with their respective privacy policies. You can limit ad tracking through your device settings, and on iOS through the App Tracking Transparency prompt.

8. International Data Transfers

Some of our service providers, including our AI providers, are located outside Turkey and outside your country, including in the United States. Where we transfer personal data abroad, we do so in accordance with applicable law, relying on your explicit consent or on appropriate safeguards such as standard contractual clauses.

9. Data Retention and Account Deletion

We retain your data as long as necessary to provide our services and comply with legal obligations. Photos, character profiles and Generated Content are retained until you delete them or delete your account. Coin and transaction records are kept as long as required for accounting, fraud prevention and legal purposes.

You can delete individual characters and their photos at any time from within the app. You can delete your account at any time from the Settings screen in the app. This permanently deletes all data linked to your app identifier, including your comics, characters, photos and coin balance, and cannot be undone. You may also request deletion at any time by contacting us using the details in Section 14.

Upon deletion, your data will be erased or anonymized within thirty (30) days, except as described below. Your subscription remains linked to your App Store or Google Play purchase through our subscription provider, so you can restore it after deleting your account. We keep purchase and transaction records, and a record that the deletion took place, without your content, for accounting, fraud prevention and legal purposes. Data held by our analytics and attribution providers is deleted or anonymized according to their own retention periods. Data sent to AI providers is kept by them only as long as needed to process your request.

10. Security

We protect your data using TLS/HTTPS encryption, role-based access controls, and two-factor authentication. In the event of a data breach, we will notify affected users and the relevant authority as required by law.

11. Your Rights

You have the right to access, correct, delete, restrict, or port your personal data, to object to processing based on our legitimate interests, and to withdraw your consent. If you are in Turkey, you also have the rights listed in Article 11 of KVKK. You may lodge a complaint with your local data protection authority, including the Turkish Personal Data Protection Authority. To exercise these rights, contact us at the details below. We will respond within thirty (30) days.

12. Children's Privacy

Our services are not directed to individuals under 13. We do not knowingly collect personal information from children under 13. Where local law requires a higher age for consent to data processing, users below that age may use the services only with the consent of a parent or legal guardian. If we learn that we have collected data from a child in violation of this Section, we will delete it.

13. Changes to This Policy

We may update this Policy at any time. Changes will be posted within the application with an updated "Last Updated" date.

14. Contact Information

• Company Name: Superapp Labs Teknoloji A.Ş.
• Address: EGS Business Park Blok D:251, No: 12, Yeşilköy Mahallesi, Atatürk Caddesi, Bakırköy, Istanbul, Turkey
• Email: support@superapplabs.co
• Phone: +90 212 909 17 35