Data Protection Notice (KVKK)

1. Data Controller

Seller: Berat Ölekli (sole proprietorship, trading as ComicPad)

Phone: +90 542 667 88 86

Email: info@comic-pad.com

Tax office / number: Dikimevi / 6540515879

Website: https://comic-pad.com

2. Personal Data We Process

Account: username, email address (if you save your account), a one-way hash of your password, profile photo and bio, invite code, device identifier.

Content: stories you create, text you enter, photos you upload, generated images and audio, comments and likes.

Purchases: for purchases on the website, your name, email, phone and billing address; the pack bought, amount, date and payment reference. We do not process card details.

Security: IP address, transaction records, records of AI requests and error logs.

Connected accounts: if you connect Twitch or Kick, the account ID, display name and profile picture.

3. Why We Process It

To create and run your account; to generate stories, images and audio with AI; to handle token sales, payments, invoicing and refunds; to provide live-stream features; to keep the service safe and prevent abuse; to answer your requests and complaints; to meet our legal obligations; and to improve the service.

4. Legal Grounds

We process your data under KVKK Article 5(2): (c) to form and perform a contract, (ç) to meet our legal obligations (for example tax and invoicing rules), (e) to establish, exercise or protect a right, and (f) for our legitimate interests, provided this does not harm your fundamental rights and freedoms. Where none of these applies, we ask for your explicit consent.

5. Who We Share It With

We do not sell your personal data. We share it only as needed to run the service, with:

Elekse Ödeme Kuruluşu A.Ş.: processing payments made on the website (Turkey).

Hetzner: hosting for our servers, database and file storage (Germany).

Google: AI generation (Gemini API) and Android purchases (Google Play).

Apple: in-app purchases on iOS.

Resend: sending account emails (verification, password reset).

TikTok: advertising measurement in the mobile app (with your permission on iOS).

Twitch and Kick: when you connect these accounts and during live streams.

Authorities: when required by law.

Some of these parties process data abroad (EU and US). Transfers abroad follow the conditions in KVKK Article 9.

6. How We Collect It

Through the mobile app and the website: from the information you enter and the records created as you use the service, by automatic or partly automatic electronic means.

7. How Long We Keep It

Account and content data are kept while your account exists and permanently deleted when you delete your account. Sales and invoice records are kept for the period required by tax law (10 years); security logs for the period required by the relevant law.

8. Your Rights

Under KVKK Article 11 you can: learn whether your data is processed and request information about it; learn the purpose of processing and whether it is used for that purpose; know the third parties it is transferred to; ask for incomplete or inaccurate data to be corrected; ask for it to be deleted or destroyed under the conditions in Article 7, and for these actions to be passed on to the third parties it was transferred to; object to a result against you that comes solely from automated analysis; and claim compensation if you suffer damage from unlawful processing.

9. How to Apply

To use your rights, email info@comic-pad.com. We answer free of charge within 30 days at the latest. You can also delete your account and data yourself at any time in the app or on the website (Profile → Delete My Account).