🔒 Privacy Policy
Effective Date: June 15, 2026
1. Controller
The controller of personal data is Sebastian Pietrasiak, ul. Patriotów 3A, 32-593 Żarki, Poland, email: info@comio.studio. In these documents we refer to ourselves as “we” (or “us”).
2. Main rule
ComIO.Studio is a desktop application. Most working data stays on your device.
We do not normally receive your serial port data, terminal buffers, logs, macros, triggers, scripts, local settings, local files, local history, AI prompts, AI responses, API keys, or provider account sessions.
We receive data only where it is needed for the website, session registration and license activation, updates, product analytics, support, security, abuse prevention, voluntary contact, and — depending on your plan — payments or the information and promotional panel.
3. Data that normally stays on your device
Unless you send it yourself, we do not receive:
- serial port sessions and device data;
- terminal buffers and logs;
- macros, triggers, scripts, and local settings;
- files opened or sent by you;
- where your plan includes them: AI prompts and AI responses, your AI provider API key, or a local provider session.
4. Data we process
Most data we process is provided by you, generated by the Application for the session or analytics, or related to website and service security.
| Data | Purpose | Legal basis |
|---|---|---|
| Device or installation ID, session token, plan status, customer identifier | 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 | legitimate interest |
| Technical data for the information or promotional panel, such as content version, language, basic display or click events (Free plan) | displaying the panel, measuring message performance, limiting abuse, improving the product | legitimate interest |
| Email, name or alias, country, currency, payment method (ProBaud BYOK plan) | payment, support, billing, fraud prevention | contract, law, legitimate interest |
| Support messages and voluntary diagnostics | answering requests and fixing issues | contract, consent, or legitimate interest |
| Diagnostic and remote support data (incl. error logs and results of internal technical operations retrieved at our request) | technical support, diagnostics, security, abuse prevention, service continuity | 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, we do not collect payment or billing data unless you provide it yourself when contacting us or enter a separate paid-plan checkout process. On ProBaud BYOK, payment data is processed mainly by the payment provider shown at checkout.
5. Information and promotional panel (Free plan)
The Free plan may include an information, promotional, or similar panel inside the Application.
The panel may show our 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. ProBaud BYOK and AI data
In ProBaud BYOK, AI traffic goes from your device to the AI provider or local provider tool selected by you.
During normal BYOK use, we do not route, read, store, or bill AI prompt content, AI responses, API keys, provider sessions, or token usage.
The selected AI provider applies its own terms and privacy policy.
7. Recipients
We 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 us;
- on the Free plan: analytics providers, content delivery networks, and third-party ad networks supporting the promotional panel;
- on ProBaud BYOK: the payment provider used for checkout and billing.
We do not sell personal data.
8. Storage time
| Data | Storage time |
|---|---|
| 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 (Free plan) | up to 1 year, unless anonymized earlier or longer storage is needed for security or legal claims |
| Paid license and billing data (ProBaud BYOK plan) | paid access period plus time required for tax, accounting, support, fraud prevention, 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 |
| Diagnostic and remote support data | up to 1 year from collection, unless longer storage is needed for security, incident handling, or legal claims |
Anonymized data may be kept longer because it no longer identifies a person.
9. 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.
10. 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, scripts, 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.
11. User age
ComIO.Studio is intended for users who are at least 18 years old. We do not knowingly collect data from persons under 18.
12. Security
We use reasonable technical and organizational measures to protect personal data.
No internet service or software can be guaranteed as fully secure.
13. Contact
Email: info@comio.studio
Address: Sebastian Pietrasiak, ul. Patriotów 3A, 32-593 Żarki, Poland