📋 Data Processing Note

Effective Date: May 2, 2026

1. Purpose

This note explains whether a separate Data Processing Agreement applies to ProBaud BYOK.

2. Main rule

In ProBaud BYOK, the Operator does 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, the Operator does not act as a processor for AI data under the default ProBaud BYOK model.

3. Data processed by the Operator as controller

The Operator may process installation, license, billing, support, security, and website data as an independent controller.

That 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 the Operator separately provides a service where it processes personal data on behalf of the User as a processor.

That is not the default ProBaud BYOK model.

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 the Operator processes data for its own purposes, such as licensing, payments, analytics, support, and security.

6. Contact

Email: info@comio.studio

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