📋 Data Processing Note — Free plan

Effective Date: May 2, 2026

1. Purpose

This note explains whether a separate Data Processing Agreement applies to the Free plan.

2. Main rule

In the Free plan, the Operator does not by default provide a service in which it processes personal data on behalf of the User as a processor.

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 the Operator’s 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.

3. Data processed by the Operator as controller

The Operator may process Free session data, installation data, data used to choose content for the information or promotional panel, support messages, and security data as an independent controller.

This processing is described in the Privacy Policy of the Free package.

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 Free plan 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 Free session registration, 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