Comictopia — Privacy Policy
Last updated: 23 July 2026
This Privacy Policy explains how Comictopia ("Comictopia," the "App," "we," "us," or "our") collects, uses, and protects personal data when you use our mobile application. Comictopia is a storytelling app for children and families, and we take the privacy of children and their families seriously.
We are based in the United Kingdom, and we handle personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Who We Are (Data Controller)
The data controller responsible for your personal data is:
Comictopia United Kingdom Email: Comictopia@orstudios.co.uk
If you have any questions about this Policy or your personal data, you can contact us using the details above.
2. A Note for Parents and Guardians
Comictopia is designed to be used by children together with, or under the supervision of, a parent or guardian. Accounts are created and managed by the adult who signs in. We do not knowingly ask children to provide personal data directly, and we encourage parents and guardians to supervise their child's use of the App and to review the information entered when generating stories.
If you believe a child has provided us with personal data without appropriate consent, please contact us and we will take steps to delete it.
3. What Personal Data We Collect
We aim to collect as little personal data as possible. The data we handle falls into the following categories:
a) Account information (Sign in with Apple)
When you create an account, you sign in using Sign in with Apple. Depending on your Apple settings, we receive your name and an email address (which may be Apple's private relay email that forwards to you). We use this to create and secure your account and to identify you when you sign in.
b) Story inputs
When you use the Custom Story Generator, you provide inputs such as character names, a chosen world, and an age range. These inputs are used to generate a personalised story. Story inputs may include a child's first name if you choose to enter one — we recommend using first names or nicknames only. See Section 5 for how these inputs are processed.
c) Subscription status
To provide access to the App's content, we keep a record of your subscription (membership) status and your remaining story-generation allowance. Payment itself is handled entirely by Apple — we do not collect or store your card or payment details.
What we do not collect
We do not use third-party analytics, advertising, or tracking tools. We do not build advertising profiles, and we do not sell your personal data.
4. How We Use Your Data and Our Lawful Bases
Under UK GDPR, we must have a lawful basis for processing personal data. We use your data as follows:
| Purpose | Data used | Lawful basis |
|---|---|---|
| Create and secure your account; sign you in | Account information | Performance of a contract (our Terms of Service) |
| Generate personalised stories | Story inputs | Performance of a contract |
| Provide and manage access to Comics and generation; enforce membership limits | Subscription status | Performance of a contract |
| Keep the App secure and prevent misuse | Account and subscription data | Legitimate interests (keeping the service safe and functioning) |
| Comply with legal obligations | As required | Legal obligation |
5. AI Story Generation and Third-Party Processing
When you generate a custom story, the story inputs you provide are sent to a third-party AI provider that processes them to generate the story text on our behalf. This provider acts as a data processor for this purpose. We use established AI providers and may change providers over time; you can request the identity of our current AI provider(s) by contacting us using the details in Section 13.
We only send the inputs needed to generate the story. We do not send the AI provider your Apple account details or payment information. The provider processes this data in accordance with its own terms and privacy commitments applicable to its service.
Because story generation involves sending inputs to a third-party AI provider, we again recommend that you avoid entering sensitive personal details and use first names or made-up names where possible.
6. Who We Share Data With
We do not sell your personal data. We share data only with:
- Apple — for sign-in, app distribution, and processing all payments and subscriptions.
- Our third-party AI provider(s) — to generate custom stories from your inputs, as described in Section 5.
- Our hosting/backend infrastructure — to store your account and subscription records and operate the service.
- Legal and regulatory bodies — where we are required by law to disclose information.
We do not allow these parties to use your data for their own marketing purposes.
7. International Transfers
Some of our service providers (including our third-party AI provider) may process data on servers located outside the United Kingdom. Where personal data is transferred outside the UK, we take steps to ensure it is protected by an appropriate safeguard recognised under UK data protection law, such as UK-approved standard contractual clauses or an adequacy decision.
8. How Long We Keep Data
We keep your personal data only for as long as necessary:
- Account information — for as long as your account remains active. If you delete your account, we will delete or anonymise your account data within a reasonable period, except where we must retain it to comply with a legal obligation.
- Story inputs — story inputs are used to generate stories and are not retained by us for longer than needed to provide the feature and the resulting story.
- Subscription status — retained while your membership is active and for a reasonable period afterwards for record-keeping and legal compliance.
9. Data Security
We use reasonable technical and organisational measures to protect personal data, including secure authentication (Sign in with Apple) and encrypted connections to our servers. No method of transmission or storage is completely secure, but we work to protect your data and to keep our practices up to date.
10. Your Rights
Under UK GDPR, you have the right to:
- access the personal data we hold about you;
- request correction of inaccurate data;
- request erasure of your data ("right to be forgotten");
- restrict or object to certain processing;
- request portability of your data;
- withdraw consent where processing is based on consent.
To exercise any of these rights, contact us at Comictopia@orstudios.co.uk. You also have the right to lodge a complaint with the UK's data protection regulator, the Information Commissioner's Office (ICO) — www.ico.org.uk.
11. Children's Privacy
Comictopia is intended for use by families, with children using the App under the supervision of a parent or guardian who holds the account. We design the App to collect as little data as possible and do not use children's data for advertising, profiling, or marketing. We follow the principles of the ICO's Age Appropriate Design Code (Children's Code) in operating the App.
If you are a parent or guardian and wish to review, correct, or delete data associated with your account, please contact us.
12. Changes to This Policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, notify you within the App. We encourage you to review this Policy periodically.
13. Contact Us
If you have any questions or concerns about this Privacy Policy or how we handle your data, contact us at:
Comictopia Email: Comictopia@orstudios.co.uk