Privacy Policy
Effective Date: May 11, 2026
This Privacy Policy explains how Presage42 ("ComicGPT - Manga Manhwa Maker," "we," "us," or "our") collects, uses, stores, discloses, and otherwise processes personal data in connection with the ComicGPT - Manga Manhwa Maker mobile application for iPhone and iPad, related legal or support pages, and any related services we provide (collectively, the "Service"). By using the Service, you acknowledge that your personal data may be processed as described in this Privacy Policy.
1. Who We Are and Our Role
The Service is provided by:
Presage42
Email: hello@presage42.com
Address: Taşucu Mahallesi, Taşucu Toki Konutları, 86. Sokak, FG-1, 1-B, Daire 1, Mersin/Silifke, Türkiye
For purposes of applicable privacy laws, Presage42 is generally the controller, or data controller / veri sorumlusu, of personal data processed through the Service. Our service providers may process personal data on our behalf or according to their own applicable terms, policies, and legal obligations, depending on the service.
If you have any questions about this Privacy Policy or our data practices, you may contact us at hello@presage42.com.
2. Scope of This Privacy Policy
This Privacy Policy applies to personal data we collect when you access or use the Service, create an account, sign in, use AI-powered comic generation features, submit prompts, upload or select reference images, create or save characters, generate comics, manage subscriptions or in-app purchases, contact us, or otherwise interact with us.
The Service is currently intended for iPhone and iPad. We do not currently operate a web app that allows users to sign in, generate comics, or manage user content through a browser. If we launch a web app or add website-based tracking, cookies, web analytics, or similar technologies in the future, we will update this Privacy Policy as appropriate.
The Service may not be available in all countries or regions. We may limit, restrict, suspend, or decline access to the Service in certain jurisdictions for legal, regulatory, sanctions-related, security, operational, provider-availability, or business reasons.
3. Eligibility and Children’s Privacy
The Service is intended for users who are 18 years of age or older. The Service is not directed to children or to users under 18.
We do not knowingly collect personal data from children or users under 18. If you believe that a child or user under 18 has provided personal data to us, please contact us at hello@presage42.com, and we will take appropriate steps to delete or address the information where required by applicable law.
4. Personal Data We Collect
We may collect and process the following categories of personal data.
A. Account and Authentication Information
When you create an account or sign in to the Service, we may process:
Email address
Full name or display name, where provided by the authentication provider and processed or stored by the Service
Authentication provider, such as Apple or Google
Authentication user ID
Supabase user ID
Supabase authentication and session identifiers
Local app account ID used for account, billing, customer mapping, or device-to-account continuity where applicable
Avatar selection, avatar URL, profile image, or account image where provided by supported authentication providers or avatar services and processed or stored by the Service
Account status, deletion status, ban or suspension status, and related account records
The Service does not currently support custom user-uploaded profile photos inside the app. Where available, the Service may automatically use account information, avatar information, profile image information, or image URLs provided by supported authentication providers or configured avatar services.
Where enabled, the Service may generate a hashed version of your email address to look up a profile avatar from Gravatar, operated by Automattic. This sends a one-way hash of your email address to Gravatar’s servers for avatar retrieval only.
The Service may use Apple’s iCloud key-value storage to synchronize a limited local account identifier across Apple devices signed into the same Apple ID. This limited data is managed by Apple according to Apple’s iCloud terms and privacy policy.
B. User Content
The Service allows users to create, upload, store, process, generate, export, and manage comic-related content. We may process User Content including:
Story prompts, story descriptions, and other text submitted for comic generation
Style selections, genre selections, language choices, quality-tier selections, and other creative settings
Character information, character descriptions, character images, and character library data
Reference images uploaded or selected by users
Generated comic pages, panels, images, stories, and related outputs
Exported or downloadable comic content, including PDF and image files, where applicable
Other content users create, upload, save, or process through the Service
User Content is used to provide the Service, preserve user libraries, support consistent comic and character generation, and enable users to access, continue, restore, or export their projects.
When you are signed in, User Content, including projects, characters, generated comic pages, and related data, may be automatically synchronized with our cloud infrastructure to enable account functionality, multi-device access, backup, and restoration. Synchronization may occur periodically while the app is in use.
C. Reference Images and Images of People
Users may upload or select reference images to help generate comic content. Reference images may include personal data, including images, likenesses, visual characteristics, or other information relating to identifiable people.
We do not use reference images for biometric identification, face recognition, identity verification, or to determine a person’s real-world identity. The Service may process reference images as visual inputs for AI-powered comic generation and consistency features.
Users are responsible for ensuring that they have the rights, permissions, and legal authority necessary to upload, submit, process, and use any reference images they provide to the Service.
D. Sensitive Personal Data
We do not intentionally request sensitive personal data, such as health information, precise government identity information, religious beliefs, political opinions, biometric identifiers for identification, or other sensitive categories of personal data.
Because the Service allows users to submit prompts and reference images, users may choose to include sensitive personal data in User Content. You should not submit sensitive personal data unless it is necessary for your use of the Service and you have the right and legal authority to do so.
E. AI-Related Data
When you use AI-powered features, we may process:
Story prompts and text inputs
Reference images
Style selections and creative settings
Character information
Generated comic outputs
Generation history and related context
Error, safety, moderation, abuse-prevention, or operational information related to generation requests
AI-related data may be sent to third-party AI service providers as described in Section 7.
F. Subscription, Purchase, and Credit Data
If you purchase a subscription, buy credits, or use paid features, we and our service providers may process:
Subscription status
Purchase history
Product IDs
Transaction-related metadata
Entitlement status
Credit balance
Credit purchases and usage
Generation counts and usage limits
Refund, chargeback, cancellation, or revocation status
Paywall interactions
Conversion events
Adapty customer ID and related purchase analytics or diagnostic data
Store-related subscription and purchase metadata
Payments made through the Apple App Store are processed by Apple, and Apple may process payment information according to its own terms and privacy policies. We do not receive full payment card details from Apple.
G. Technical, Security, and Usage Information
We and our service providers may collect technical, security, and usage information such as:
IP address
User-agent information
App/session identifiers
Authentication identifiers
Supabase authentication/session information
Local account identifiers
App activity related to account use, generation activity, credit usage, purchase status, and feature access
Security logs
Backend, proxy, hosting, and operational logs
Information used for country or region availability enforcement, including IP-based country resolution where applicable
Error, operational, or diagnostic logs generated by our infrastructure or service providers
IP addresses and related logs may be stored by our backend, proxy, hosting, security, or operational infrastructure and may be used for security, abuse prevention, troubleshooting, legal compliance, and country or region availability enforcement.
We do not currently use third-party crash reporting SDKs such as Firebase Crashlytics or Sentry. If we add such tools in the future, we will update this Privacy Policy as appropriate.
H. Communications and Support Information
If you contact us, including through hello@presage42.com, we may process:
Your email address
The content of your message
Support request details
Attachments or screenshots you choose to provide
Records of our communications with you
We currently expect support communications to be handled through our email inbox. If we add a dedicated support platform in the future, we will update this Privacy Policy where appropriate.
5. Device Permissions, Local Storage, and Access
The Service may request add-only access to your photo library so you can save generated comic pages or related outputs to Photos.
Reference images for character creation or comic generation may be selected through Apple’s system photo picker or similar system-provided selection tools. These tools allow you to choose specific images to share with the Service without granting broad photo-library access.
The Service does not currently request access to your camera, microphone, precise location, contacts, or files outside the images you choose to share.
The Service does not read from your clipboard. Certain user-initiated actions, such as copying a prompt, account ID, or other text, may write to the clipboard.
We may store data locally on your device, including preferences, account information, cached content, draft data, and generated or downloaded media, to provide account continuity, offline access, faster loading, and improved performance.
We only process images that you choose to upload, select, save, or submit to the Service.
6. Legal Bases for Processing
Where applicable privacy laws require a legal basis for processing personal data, we rely on one or more of the following legal bases:
Performance of a contract: to create and manage your account, provide the Service, process your prompts and reference images, generate comics, maintain your library, synchronize account data, provide paid features, manage subscriptions, credits, and entitlements, and respond to service-related requests.
Legitimate interests: to secure, maintain, troubleshoot, debug, analyze, and improve the Service; prevent fraud, misuse, abuse, policy violations, and security incidents; enforce our Terms; manage operational logs; and protect the rights, property, and safety of Presage42, users, and third parties.
Legal obligations: to comply with applicable laws, regulations, sanctions requirements, lawful requests, tax, accounting, payment, recordkeeping, and consumer protection obligations.
Consent or user direction: where you grant device permissions, choose to upload or select reference images, save generated content to Photos, contact support, or otherwise direct us to process certain data, and where consent is required by applicable law.
The applicable legal basis may vary depending on your location, the type of personal data, and the specific processing activity.
7. How AI Features Work
The Service uses AI-powered features to help users generate comic content from prompts, reference images, style selections, character information, and related creative inputs.
The current AI processing flow may include:
A user submits a story prompt or creative description.
The prompt may be processed by an AI text provider, such as Anthropic Claude, to analyze the story and transform it into a structured generation plan, which may include page layouts, panel beats, character continuity, and generation-ready prompt construction.
The structured prompt, reference images, style selections, character information, selected quality tier, and related generation data may then be processed by one or more AI image generation providers or model-hosting providers, including providers such as fal.ai, Google/Gemini image generation providers, OpenAI image generation providers, or other providers we may use from time to time.
The generated output may be returned to the Service and stored in the user’s account library, unless deleted by the user or otherwise removed in accordance with this Privacy Policy or our Terms.
The specific provider, model, routing path, or quality tier used for a given generation may depend on the feature selected by the user, the type of content being generated, quality level, availability, cost, safety, performance, or technical requirements. We may update, add, remove, replace, or reroute AI providers and models over time to improve quality, performance, reliability, safety, or cost efficiency. We will update this Privacy Policy where required if such changes materially affect how personal data is processed.
We use AI providers only to provide and support the AI features requested by users, including prompt preparation, image generation, comic generation, consistency, safety, abuse prevention, troubleshooting, and related operational purposes.
We do not use your personal data or User Content to train our own AI models. We do not currently operate our own AI foundation model.
Third-party AI providers process submitted content on our behalf to provide AI features and may handle such data according to their own terms, policies, and data-processing practices. Certain providers may state that API inputs and outputs are not used to train their models by default, subject to provider-specific terms, opt-ins, feedback, safety, security, abuse-prevention, operational processing, and other exceptions. Other providers, including model-hosting or underlying model providers, may process submitted content according to their own provider-specific terms, safety, security, operational, and abuse-prevention practices.
AI-generated output may be inaccurate, incomplete, inconsistent, unexpected, similar to outputs generated for other users, or unsuitable for your intended purpose. You are responsible for reviewing outputs before relying on, publishing, sharing, or using them.
8. How We Use Personal Data
We may use personal data for the following purposes:
To create, authenticate, and manage user accounts
To provide access to the Service
To process prompts, reference images, style selections, character data, and related inputs for AI-powered comic generation
To generate, save, display, restore, manage, and export comic content
To maintain user libraries, character libraries, and generation history
To support consistency across generated comic content and characters
To process subscriptions, in-app purchases, credits, entitlements, refunds, cancellations, and access rights
To operate paywalls and manage purchase-related analytics through Adapty
To monitor usage limits, generation counts, credit balances, and abuse-prevention metrics
To secure, maintain, troubleshoot, debug, and improve the Service
To detect, investigate, prevent, or respond to fraud, misuse, abuse, unauthorized access, policy violations, security incidents, or harmful activity
To enforce our Terms, policies, agreements, and rights
To comply with legal obligations, lawful requests, tax, accounting, and recordkeeping requirements
To respond to support requests, complaints, questions, or other communications
To manage availability, including country or region restrictions where applicable
9. How We Share Personal Data
We may share personal data in the following circumstances.
A. Service Providers
We may share personal data with vendors and service providers that help us operate, provide, secure, and improve the Service. These may include providers for:
Authentication and backend infrastructure
Database and cloud storage
Account synchronization and local account continuity
AI prompt processing, story decomposition, and image generation
Subscription management, paywall operation, purchase validation, and entitlement management
Security, operational logging, and abuse prevention
App distribution, in-app purchases, and platform services
Customer support and communications
Examples of third-party providers we may use include:
Supabase for authentication, backend, database, cloud storage, and multi-device synchronization
Anthropic or similar AI text providers for story prompt processing, structuring, and decomposition
fal.ai or similar AI model-hosting and generation infrastructure providers
Google or Google/Gemini image generation providers for image generation functionality and Google Sign-In, where applicable
OpenAI or similar AI image generation providers for image generation functionality, where applicable
Gravatar, operated by Automattic, for avatar image lookup based on a hashed email identifier, where enabled
Adapty for paywalls, subscriptions, purchase validation, entitlements, and purchase-related analytics
Apple for App Store distribution, Sign in with Apple, in-app purchases, subscriptions, iCloud key-value storage, Photos integration, and related platform services
We may update, add, remove, or replace service providers over time to improve quality, performance, security, reliability, safety, or cost efficiency. We will update this Privacy Policy where required if such changes materially affect how personal data is processed.
B. Legal, Safety, and Compliance Purposes
We may disclose personal data if we believe disclosure is reasonably necessary to:
Comply with applicable law, regulation, legal process, sanctions requirements, or governmental request
Enforce our Terms, agreements, policies, or rights
Protect the rights, property, safety, and security of Presage42, the Service, our users, third parties, or the public
Detect, investigate, or prevent fraud, abuse, security incidents, illegal activity, or technical issues
Respond to copyright, intellectual property, privacy, publicity, or other legal claims
C. Business Transfers
We may disclose or transfer personal data in connection with a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, or similar business transaction.
D. With Your Direction or Consent
We may share or disclose personal data when you direct us to do so or where you otherwise provide consent, such as when you export content or choose to share generated comics outside the Service.
10. Public Sharing and Exporting
The Service does not currently provide a public gallery, public feed, public web link, public profile, social-media-style sharing feature, or community sharing feature that makes user-generated content publicly visible to other users through the Service.
Users may export or download their generated content. Once content is exported or shared outside the Service by the user, we are not responsible for how that content is used, stored, copied, modified, or distributed by the user or by third parties.
11. Advertising, Tracking, and Sale of Personal Data
We do not currently display third-party advertisements in the Service.
We do not currently use the Apple Identifier for Advertisers (IDFA), and our Adapty configuration is intended to disable IDFA collection.
We do not currently use third-party advertising SDKs, Meta SDK, AppsFlyer, Firebase Analytics, Google Analytics for Firebase, Sentry, or Firebase Crashlytics.
We do not sell personal data. We do not act as a data broker. We do not share personal data for cross-context behavioral advertising.
We may use Apple App Store tools and Adapty for subscription, purchase, entitlement, paywall, conversion, and limited operational analytics.
If we add advertising, tracking, attribution, or additional analytics tools in the future, we will update this Privacy Policy and make any required disclosures or consent requests.
12. Data Storage and Security
We use reasonable technical and organizational measures designed to protect personal data.
However, the Service is not described as end-to-end encrypted, and we do not currently claim that prompts, reference images, generated comics, or other User Content are encrypted using a special application-level encryption system controlled by us.
Authorized personnel may access stored data where necessary for service operation, support, troubleshooting, security, abuse prevention, legal compliance, or enforcement of our Terms.
No method of transmission, storage, or processing is completely secure, and we cannot guarantee absolute security.
13. Data Retention
We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Service, maintain user accounts, preserve user libraries, support consistent generation, manage subscriptions and purchases, comply with legal obligations, resolve disputes, prevent abuse, enforce our agreements, and maintain the security and integrity of the Service.
In general:
Story prompts, reference images, generated comics, character information, and related User Content are retained until the user deletes them or deletes their account, unless longer retention is required or permitted for legal, security, abuse-prevention, backup, or operational reasons.
Deleted User Content may be moved to a trash or restore area for up to 30 days. If the user does not restore the content within that period, it may be permanently deleted from active systems.
Certain information may remain in backups, logs, or archival systems for a limited period before being deleted or overwritten according to our backup and operational practices.
Purchase, subscription, refund, chargeback, entitlement, fraud-prevention, tax, accounting, security, abuse-prevention, and legal records may be retained where reasonably necessary or legally required.
Support communications may be retained as necessary to provide support, maintain business records, resolve disputes, enforce our Terms, comply with legal obligations, and protect the Service.
After account deletion, we may retain limited records such as basic technical logs, purchase transaction records, subscription or entitlement records, refund or chargeback records, fraud-prevention records, security records, and legal or tax records for the minimum period required by law or reasonably necessary for fraud prevention, tax or accounting compliance, security, abuse prevention, enforcement of our Terms, and resolving payment disputes.
14. Account Deletion
Users may request deletion of their account and associated personal data through the account deletion functionality made available within the Service or by contacting us at hello@presage42.com.
When you confirm account deletion, we initiate deletion or de-identification of personal data associated with your account from active systems, subject to retention that is necessary or permitted for legal compliance, payment dispute handling, fraud prevention, tax or accounting obligations, security, abuse prevention, backup, enforcement of our Terms, or legitimate business recordkeeping purposes.
The account deletion process may include clearing local app data, deleting or de-identifying account records, removing project metadata, deleting character records, removing profile data, and removing uploaded reference images, character images, project thumbnails, generated comic pages, and related stored media from active storage systems.
Some deletion steps may be processed asynchronously. Some data may not be immediately deleted from backup, archival, logging, payment, security, or legal systems, but it will be handled according to our backup, retention, and legal compliance practices.
15. Your Rights and Choices
Depending on your location and applicable law, you may have rights regarding your personal data, which may include the right to:
Access personal data we hold about you
Request correction of inaccurate or incomplete personal data
Request deletion of your personal data
Request restriction of processing
Object to certain processing
Request data portability, where applicable
Withdraw consent, where processing is based on consent
Lodge a complaint with a competent data protection authority, where applicable
For users located in Türkiye, personal data is processed in accordance with the Law on the Protection of Personal Data No. 6698 ("KVKK"), where applicable. Users in Türkiye may contact us to exercise their applicable rights under KVKK.
To exercise any applicable privacy rights, contact us at hello@presage42.com.
16. International Data Transfers
Your personal data may be processed in countries other than your country of residence, including where our service providers operate. These countries may have data protection laws that differ from those in your jurisdiction.
Where required by applicable law, we will take appropriate steps designed to provide an adequate level of protection for personal data transferred internationally.
17. Third-Party Services
The Service may rely on or integrate with third-party platforms, SDKs, APIs, infrastructure providers, AI providers, authentication providers, payment and subscription providers, avatar providers, and app store platforms.
Third-party services may process personal data according to their own privacy policies, terms, data-processing practices, and legal obligations. We encourage users to review those policies where relevant.
We are not responsible for third-party services that are not controlled by us.
18. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we may provide notice through the Service or by other appropriate means. The Effective Date above indicates when this Privacy Policy was last updated.
Your continued use of the Service after an updated Privacy Policy becomes effective means that you acknowledge the updated Privacy Policy, to the extent permitted by applicable law.
19. Contact Us
If you have questions, requests, or complaints regarding this Privacy Policy or our privacy practices, please contact us at:
Presage42
Email: hello@presage42.com
Address: Taşucu Mahallesi, Taşucu Toki Konutları, 86. Sokak, FG-1, 1-B, Daire 1, Mersin/Silifke, Türkiye
Privacy Policy URL: https://presage42.com/comicgpt-manga-manhwa-maker/privacy-policy