Privacy Policy

1. Who we are

My Comic Series ("the App") is developed and published by Dijital Kafa Bilişim ve Danışmanlık A.Ş. ("we", "us", "our"), Gülnihal Sokak Atatürk Mahallesi No: 1/6, Ataşehir, İstanbul, Turkey.

We are the data controller for the processing described in this policy, including under the EU and UK General Data Protection Regulation (GDPR) and the Turkish Personal Data Protection Law No. 6698 (KVKK). This policy explains what information the App handles, where it goes, how long it is kept and what choices you have.

In this policy, Settings in bold followed by a menu name means the Settings tab inside the App; iOS Settings means your iPhone's Settings app.

2. What stays on your device

The App keeps the following in its private storage on your device:

• Your comics: the comic pages, thumbnails, the story you wrote, the dialogue you edited, category, style and favorites.
• Your characters: their names, relationship labels and tags, character portraits and the short visual description written for each character.
• The photos you pick for a character: kept so the character can be drawn again.
• Drafts: up to three unfinished comics.
• Settings: for example the theme and your AI processing choice.

iCloud. If you are signed in to iCloud with iCloud Drive turned on, the App also copies your comics (pages, thumbnails and their details, including the story text) and your characters (portraits and their details) to the App's private storage in your own iCloud account. This lets the App bring them back when you reinstall it or use another device. Apple stores this copy under your iCloud account, and we cannot access it. The photos you picked and your drafts are not copied there, but like other app data they may be included in your device backups (iCloud Backup or a backup on your computer), which your Apple settings control.

Deleting a comic or character in the App deletes it from your device and from your iCloud account. Comics you saved to your photo library or shared with others are not affected.

3. Your account

The App has no sign-in. The first time you open it, it creates an anonymous account ID on our backend (Supabase). We do not ask for your name, email address or phone number.

The App keeps the key to this account in your device's secure keychain. iOS keeps the keychain when you delete the App, so if you reinstall the App on the same device, the same account (with its credits and purchases) comes back. Deleting the App does not delete your account. To delete it, use Delete my data (Section 10).

On our backend we store only what is needed to run your account:

Your credit balance itself is kept by RevenueCat (Section 6.3).

4. AI processing and your consent

Turning your photos into characters and your stories into comics requires sending some of your content to AI providers. The App does this only after you agree on the in-app screen that names the providers, by tapping Continue. It asks before you add your first photo, and before you create a comic if you have not agreed yet. This section describes in full what is sent.

4.1. What is sent, to whom and when

Your character portraits are sent again each time you create a comic. Your original photos are sent only to fal.ai, and only when a portrait is drawn.

4.2. What the providers do with it

• fal.ai (Features & Labels, Inc., USA) runs the image model. Google's image model is reached through fal.ai, so fal.ai passes the request to Google to generate the image, and Google may keep it for a limited time to detect misuse. We ask fal.ai, with every request, not to keep the request contents in its request history. Under its terms with us, fal.ai does not use this content to train models; its terms allow it to use de-identified or aggregated usage data to improve its services.
• Anthropic (Anthropic, PBC, USA) does not use this content to train its models. It deletes inputs and outputs within 30 days, unless its automated safety systems flag a request as violating its usage policy (then it may keep it for up to 2 years) or the law requires it to keep them longer.
• We do not use your photos, stories or comics to train AI models.

4.3. What we do not keep

Your photos, portraits, stories and generated comics pass through our backend only while a generation is running. We do not save them in our database or storage. The exceptions are described in this policy: the temporary delivery link (Section 4.4), the short reason kept when a story is blocked (Section 3), content you report (Section 6.6) and diagnostic logs (Section 6.8).

4.4. Delivering your results

When a portrait or comic is ready, our backend stores a temporary link to the images, and your device downloads them directly from fal.ai's content delivery network. The link is removed from our backend as soon as your device has downloaded the result, and in any case within about 8 days. We ask fal.ai to delete the generated images 7 days after they are created. Until then, anyone with the link could open the image; the links are long and random, and we do not publish them. If your device does not download a result within 7 days, it may be lost.

4.5. Withdrawing your consent

You can withdraw your consent at any time in Settings > App Info > AI photo processing by turning it off. After that, the App sends no new photos, portraits or stories to the AI providers, and you cannot add photos or create comics until you turn it back on. A generation that has already started will finish. Your characters and comics stay on your device and in your iCloud account. Withdrawing does not affect processing that happened before.

4.6. Photos of other people

You may create characters of the people (and pets) in your life. When you do, you are sharing their photos with us and our AI providers. Add photos of other people only if they have agreed to it. For a child, you must be their parent or legal guardian, or have their parent's or guardian's permission. If someone asks us to stop processing their image, contact us (Section 15).

5. Content rules and safety checks

Before a comic is drawn, Anthropic's model checks the story against our content rules (for example, no sexual content, no sexual or unsafe depiction of minors, no intimate depiction of real people, no hate). If a story breaks these rules, the comic is not created and no credits are used. These checks are automated, and no person reviews your story or images before the result is delivered. People at Dijital Kafa see your images only if you report them (Section 6.6). When we investigate errors, we may see the limited details kept in job records and diagnostic logs (Sections 3 and 6.8).

6. Other data that leaves your device

Like any request over the internet, these requests also reach the receiving service with your IP address and standard technical information, such as your device type and operating system version. Our hosting provider's sign-in service records the IP address of your current session (Section 3), and its request logs may include your IP address for up to 7 days. All requests are encrypted (HTTPS).

6.1. Photos permission

• To pick photos for a character, the App uses the iOS photo picker. It does not need photo library permission: the App receives only the photos you pick.
• When you tap Save, the App asks for permission to add the comic to your photo library. This "add only" permission does not let the App see your photos.
• When you share to Instagram, the App asks for photo library access, saves the comic to your library and opens it in Instagram. The comic stays in your photo library even if you cancel in Instagram.
• You can change these permissions at any time in iOS Settings > Privacy & Security > Photos > My Comic Series.

6.2. Sharing

When you share a comic, you choose the app and the people you share it with, and that app's terms and privacy policy apply. We do not receive a copy. Comics you share, or save from the share screen, carry a small "Made with My Comic Series" line, and comics shared or saved from accounts without a paid purchase also carry a watermark.

6.3. Purchases and credits

Apple processes all payments. We never receive your payment details or your Apple Account name or email address.

We use RevenueCat (RevenueCat, Inc., USA) to manage subscriptions, credit packs and your credit balance. RevenueCat receives your anonymous account ID, your purchase and transaction history from the App Store, your credit balance, your App Store country and currency, the App version and basic device information. RevenueCat also receives the Apple Search Ads attribution token (Section 6.5). RevenueCat's privacy policy: revenuecat.com/privacy.

Refund requests. If you ask Apple for a refund of an in-app purchase, Apple may ask us about it. With your consent, given when you make a purchase (Terms of Use, Section 8.8), we may tell Apple through RevenueCat whether the purchase was delivered, that free content was available before purchase, and our preference regarding the refund. We share this only to answer your refund request, and the decision remains Apple's. You can withdraw this consent at any time by contacting us (Section 15); we will then not share this information for your future refund requests. You can ask Apple about the data Apple holds at privacy.apple.com.

6.4. Analytics (Mixpanel)

We use Mixpanel (Mixpanel, Inc., USA) to understand how the App is used. Our Mixpanel project stores data on Mixpanel's servers in the European Union. The App sends:

• your anonymous account ID,
• events such as "comic created", "paywall viewed", "purchase completed" or "content reported", with details such as the number of panels, style, category, product ID, credit cost and balance, and your plan,
• short error messages when something goes wrong,
• the App version and basic device information, such as the device model and iOS version,
• Apple Search Ads campaign details, if any (Section 6.5).

Mixpanel uses your IP address to estimate your approximate location (country, region and city) and then discards the IP address. The App does not send your story, character names, photos or comics to Mixpanel. The App does not use the advertising identifier (IDFA). We use this information to improve the App and fix errors. You can object to it by contacting us (Section 15). When you delete your data, we ask Mixpanel to delete the data linked to your account ID; Mixpanel may take up to 30 days to complete this. Mixpanel's privacy policy: mixpanel.com/legal/privacy-policy.

6.5. Apple Search Ads attribution

Once per install, the App asks Apple, through Apple's AdServices framework, whether you installed it from an Apple Search Ads ad. If you did, Apple returns the campaign, ad group, keyword, ad and organization IDs, the country, the conversion and claim type and the ad placement. We attach these to your analytics data in Mixpanel, and RevenueCat receives the token too. This does not use the advertising identifier, does not track you across other companies' apps or websites and needs no tracking prompt. The App keeps this information on your device and adds it to your new account if you delete your data.

6.6. Content reports

You can report a comic or character with Report this comic or Report this character in the App. We receive the reason you chose, any note you write, a picture of the reported comic or portrait, the type and in-app ID of the reported item, the App version and your anonymous account ID. We keep reports in private storage that only we can access, review them manually and use them to act on misuse and improve our content rules. Reports and their pictures are deleted automatically after 30 days, or immediately when you delete your data.

6.7. Preventing abuse

• IP fingerprint. For welcome credits, free portraits, character descriptions and reports, our backend computes a salted, one-way fingerprint of your IP address and uses it to limit how many requests one network can make. These records do not contain the IP address itself. The fingerprint is designed so it cannot easily be linked back to your IP address and is deleted about 2 to 3 days after it was last used.
• Apple DeviceCheck. The App sends our backend a temporary token from Apple's DeviceCheck service, and our backend asks Apple to read or set two bits for your device: one meaning "welcome credits were already given on this device", the other meaning "an account with an unpaid credit balance or a restriction was deleted on this device". Apple does not tell us who you are. We do not store the token, only a one-way fingerprint of it for up to about 3 days to stop the same token from being reused. If you think these values are wrong for your device, for example because you bought it used, contact us (Section 15) and we will reset them.

6.8. Diagnostic logs

Our backend functions keep technical logs so we can find and fix errors. Log lines are linked to your anonymous account ID. Logs for comic generation may also contain your character names, short excerpts of the image instructions generated from your story, the short reason a story was blocked and error messages. They do not contain your photos or the full text of your story. Our hosting provider keeps these logs for a limited period (currently 7 days) and then deletes them.

6.9. Notifications

The App can tell you when your comic is ready. It sends notifications only if they are allowed for the App in iOS Settings. The notification goes through Expo's push service (650 Industries, Inc., USA) and Apple Push Notification service, and contains only the text "Your comic is ready! Open the app to see it." and an internal job ID. You can turn notifications off in iOS Settings > Notifications > My Comic Series.

7. What we do not collect

• No sign-in, name, email address or phone number.
• No precise location, contacts, camera, microphone or health data. (Mixpanel estimates your approximate location from your IP address; see Section 6.4.)
• We do not read your photo library. The App receives only the photos you pick.
• We do not use the advertising identifier (IDFA) and do not track you across other companies' apps or websites.
• The App contains no advertising or crash-reporting SDKs and shows no third-party ads.
• We do not sell your personal information or share it for advertising.

If you write to us by email, we receive your email address and what you write, and use them only to answer you.

8. Legal bases (EEA, UK and Turkey)

• Sending your photos, portraits, stories and character names to our AI providers: your consent (GDPR Art. 6(1)(a); KVKK Art. 5(1)). You can withdraw it at any time (Section 4.5).
• Answering Apple's questions about your refund requests: your consent, given when you make a purchase (GDPR Art. 6(1)(a); KVKK Art. 5(1)). You can withdraw it at any time (Section 6.3).
• Running your account, credits, purchases, generation jobs, delivery and notifications: necessary to provide the App to you (GDPR Art. 6(1)(b); KVKK Art. 5(2)(c)).
• Analytics, Apple Search Ads attribution, diagnostic logs, abuse prevention, DeviceCheck and content reports: our legitimate interest in improving the App, measuring our advertising, keeping the service secure and preventing misuse (GDPR Art. 6(1)(f); KVKK Art. 5(2)(f)). You can object at any time (Section 13).
• Records we keep after you delete your data: our legitimate interest in preventing double crediting and abuse, and our legal and accounting obligations (GDPR Art. 6(1)(c) and (f); KVKK Art. 5(2)(ç) and (f)).

9. How long data is kept

10. Deleting your data

You can delete your account and data at any time in the App: Settings > Account > Delete my data.

When you confirm:

• On our backend, we immediately delete your anonymous account and everything tied to it: your session record, credit and purchase flags, any credit balance owed, generation job records, push tokens, your AI consent record, request counters and any reports you sent.
• At RevenueCat, we delete your customer record, including your remaining credit balance. Remaining credits cannot be restored.
• At Mixpanel, we ask Mixpanel to delete the data linked to your account ID.
• On your device, the App deletes your comics, characters, photos, drafts and your AI consent choice, and deletes your comics and characters from your iCloud account. If iCloud is not reachable at that moment, remove the App's data from iCloud yourself in iOS Settings > [your name] > iCloud > Manage Account Storage. Comics you saved to your photo library are not affected. If you use the App on another device, delete your data there too.
• The App then starts again with a new anonymous account.

What we keep. So that the same purchase cannot be credited twice, we keep the purchase records described in Section 3: the App Store transaction ID, the product, the number of credits, the date and the former anonymous account ID. They are no longer linked to an existing account. Apple keeps the "welcome credits were already given" bit for your device. If the deleted account had an unpaid credit balance or was restricted, Apple also keeps the second bit for your device (Section 6.7), and new accounts on that device cannot create content until you contact us. Diagnostic logs expire on their own (Section 6.8).

Subscriptions. Deleting your data does not cancel a subscription. Apple keeps billing you until you cancel it in iOS Settings > [your name] > Subscriptions; the deletion screen links there. If you keep your subscription, the App links it to your new anonymous account, so your access, renewals and their credits continue there.

If you cannot use the App, email us (Section 15) and we will delete your data within 30 days. Because there is no sign-in, include the order ID from an Apple purchase receipt for the App if you have one, so we can find your account.

11. International transfers

Our backend (Supabase) stores your data in the European Union (Paris, France), and our Mixpanel project stores data in the European Union. fal.ai, Google, Anthropic, RevenueCat, Expo and Apple process data in the United States and in other countries, and the providers' support and security teams may access data from outside your country. So the data described in this policy may be processed outside your country of residence.

For transfers from the EEA, the UK and Switzerland, Mixpanel is certified under the EU–U.S. Data Privacy Framework and its UK and Swiss extensions, and the data processing terms of Supabase, fal.ai, Anthropic and RevenueCat include the European Commission's standard contractual clauses. Google processes data as a provider to fal.ai.

We share personal data only with the service providers named in this policy and only for the purposes described here. Providers that process data on our behalf may use it only to provide their services to us and must protect it at least as well as this policy describes. Apple processes data for DeviceCheck, Apple Search Ads attribution, push notifications and purchases under its own privacy policy: apple.com/legal/privacy.

12. Security

Data on your device is stored in the App's private storage, protected by iOS app sandboxing and your device's encryption, and your account key is stored in the iOS keychain. All network requests use HTTPS. Our database uses row-level security, so an account can read only its own records, and reports are kept in private storage that only we can access. No method of storage or transmission is completely secure, but we take reasonable measures to protect your information.

13. Your rights

You can view, change and delete your comics and characters in the App at any time, turn off AI processing (Section 4.5) and delete your data (Section 10).

Depending on where you live, you may have the right to:

• access the personal data we hold about you and receive a copy of it,
• have it corrected or deleted,
• restrict or object to its processing,
• withdraw consent at any time,
• complain to a data protection authority.

In Turkey, these include your rights under Article 11 of KVKK. You can also complain to the Personal Data Protection Board (Kişisel Verileri Koruma Kurulu).

California residents: we do not sell personal information or share it for cross-context behavioral advertising. You may ask us what personal information we hold about you and ask us to delete it.

To exercise these rights, contact us (Section 15). Because there is no sign-in, we may ask for information that helps us find your account, such as the order ID from an Apple purchase receipt. We respond within 30 days.

14. Children

The App is not directed at children under 13, or under the age of digital consent in your country, and we do not knowingly collect personal data from them. If you are under the age of majority where you live, use the App only with the consent of a parent or guardian.

Adults may create characters of their children (Section 4.6). If you believe a child has used the App or that a child's photo was used without a parent's or guardian's permission, contact us and we will help remove it.

15. Changes to this policy and contact

When we update this policy, we change the "Last updated" date above. If we make significant changes, for example adding a new AI provider, we will also announce them in the App or in the App Store release notes, and ask for your consent again where required.

Dijital Kafa Bilişim ve Danışmanlık A.Ş.
Email: kafa@dijitalkafa.com
Phone: +90 (216) 504 47 31
Address: Gülnihal Sokak Atatürk Mahallesi No: 1/6, Ataşehir, İstanbul, Turkey
Support: mycomicseries.com/support