🔒 Privacy Policy — Free plan
Effective Date: May 2, 2026
1. Controller
The controller of personal data is Sebastian Pietrasiak, ul. Patriotów 3A, 32-593 Żarki, Poland, email: info@comio.studio (the Operator).
2. Main rule
ComIO.Studio is a desktop application. Most working data stays on your device.
In the Free plan, the Operator does not normally receive your serial port data, terminal buffers, logs, macros, local settings, local files, local history, AI prompts, AI responses, or API keys.
The Operator receives data only where it is needed for the website, Free session registration, updates, product analytics, the information or promotional panel, support, security, abuse prevention, or voluntary contact.
3. Data that normally stays on your device
Unless you send it yourself, the Operator does not receive:
- serial port sessions or device data;
- terminal buffers and logs;
- macros and local settings;
- files opened or sent by you.
The AI Assistant, triggers, Lua scripts, and MCP server are not available in the Free plan by default. The Operator does not receive data from those features during normal Free plan use.
4. Data processed by the Operator
Most data processed by the Operator is provided by you, generated by the Application for the Free session or analytics, or related to website and service security.
| Data | Purpose | Legal basis |
|---|---|---|
| Device or installation ID, Free session token, plan status, Free customer identifier | Free session registration, keeping plan status, restoring the session, updates, abuse prevention, service continuity | contract, legitimate interest |
| App version, OS, language, approximate country or region, launch dates | product analytics, compatibility, updates, choosing panel content, measuring interest in paid plans | legitimate interest |
| Technical data for the information or promotional panel, such as content version, language, basic display or click events | displaying the panel, measuring message performance, limiting abuse, improving the product | legitimate interest |
| Support messages and voluntary diagnostics | answering requests and fixing issues | contract, consent, or legitimate interest |
| Website and service security data | security, rate limiting, bot protection, abuse detection | legitimate interest |
The Free plan does not require payment or a subscription. In the Free plan, the Operator does not collect payment or billing data unless you provide it yourself when contacting the Operator or enter a separate paid-plan checkout process.
5. Information and promotional panel
The Free plan may include an information, promotional, or similar panel inside the Application.
The panel may show Operator content about the product, updates, paid plans, promotions, technical messages, or other information related to ComIO.Studio.
Panel content may be selected based on technical data such as language, app version, plan, approximate region, or basic Application usage information.
The panel may display advertisements provided by third-party ad networks and providers, and may use related tracking mechanisms (ad tracking). To display, measure, and personalize ads, the Application may share certain data with third-party providers (such as IP addresses, technical identifiers, or basic device information). Where required by law, ad personalization and tracking rely on your consent obtained via an appropriate mechanism inside the panel.
6. Recipients
The Operator may use service providers only where needed, for example:
- Cloudflare for hosting, security, and website or service infrastructure;
- email or support tools if you contact the Operator;
- analytics providers, content delivery networks, and third-party ad networks supporting the promotional panel.
The Operator does not sell personal data.
7. Storage time
| Data | Storage time |
|---|---|
| Free session and plan status data | active period plus up to 1 year, unless longer storage is needed for security, abuse prevention, or legal claims |
| Product analytics | active period plus up to 1 year, then deleted or anonymized |
| Information or promotional panel data | up to 1 year, unless anonymized earlier or longer storage is needed for security or legal claims |
| Support messages | until the issue is resolved plus the claim limitation period, unless law requires longer storage |
| Voluntary diagnostics | until the purpose is fulfilled or consent is withdrawn |
Anonymized data may be kept longer because it no longer identifies a person.
8. Your rights
Where GDPR applies, you may request access, correction, deletion, restriction, portability, objection, or consent withdrawal.
Send requests to info@comio.studio.
You may also complain to your data protection authority. In Poland this is the President of the Personal Data Protection Office: https://uodo.gov.pl.
9. Cookies and local data
The desktop application does not use regular browser cookies in the way a website does.
The Application may store local settings, local history, macros, logs, configuration, and the session token on your device.
The comio.studio website may use Cloudflare cookies and similar technologies needed for security and operation. Details are in the Cookie Policy.
10. User age
ComIO.Studio is intended for users who are at least 18 years old. The Operator does not knowingly collect data from persons under 18.
11. Security
The Operator uses reasonable technical and organizational measures to protect personal data.
No internet service or software can be guaranteed as fully secure.
12. Contact
Email: info@comio.studio
Address: Sebastian Pietrasiak, ul. Patriotów 3A, 32-593 Żarki, Poland