📋 Data Processing Note

Effective Date: June 15, 2026

1. Purpose

This note explains whether a separate Data Processing Agreement (DPA) applies to ComIO.Studio.

2. General rule

By default, we do not provide a service in which we process personal data on behalf of the User as a processor. The reason for each plan is described below.

Free plan. The Application in the Free plan runs mainly locally on the User’s device. The licensing service may handle the Free session, token, plan status, updates, and security, but these are our own purposes and not processing on behalf of the User. The AI Assistant is not available in the Free plan. For this reason the Free plan does not require a separate Data Processing Agreement.

ProBaud BYOK plan. In ProBaud BYOK, we do not process AI prompt content, AI responses, API keys, provider account sessions, or token usage as a processor for the User. AI traffic goes directly from the User’s device to the AI provider or local provider tool selected by the User. For this reason, we do not act as a processor for AI data under the default ProBaud BYOK model.

3. Data we process as controller

We may process installation, session and license, support, security, and website data as an independent controller. Depending on your plan, this may also include billing data (ProBaud BYOK) or data used to choose content for the information or promotional panel (Free).

This processing is described in the Privacy Policy.

It is not processing on behalf of the User under this note.

4. When a DPA may be needed

A full Data Processing Agreement may be needed only if we separately provide a service where we process personal data on behalf of the User as a processor.

That is not the default model of any current plan.

If a business customer needs a signed DPA for a separate use case, contact info@comio.studio.

5. No change to the Privacy Policy

This note does not replace the Privacy Policy.

The Privacy Policy controls how we process data for our own purposes, such as licensing, payments, analytics, the information or promotional panel, support, and security.

6. Contact

Email: info@comio.studio

Address: Sebastian Pietrasiak, ul. Patriotów 3A, 32-593 Żarki, Poland