Privacy Policy

This policy explains what happens to your personal data when you use personalizedcomicbook.com (Personalized Comic Book). The controller under the General Data Protection Regulation (GDPR) is:

Lumond GmbH, Kolonnenstraße 8, 10827 Berlin, Germany. Email: [email protected]. More company details are in the Imprint.

• Book content: the photos you upload of the people who become characters in your comic (and, if you add them, of pets or objects), the names, ages and other details of the characters (for example job, hobbies or a favorite saying), the answers you give in the book creator, and the texts and pictures created for your book.
• Contact details: your name, email address, country and, if you enter it, your phone number, which we use to contact you about your order, for delivery questions and for up to three SMS reminders if you do not finish an order, and for the emails and up to two SMS about the printed edition of an eBook you bought (section 9). For printed products also the delivery address.
• Orders: the products you order, the amounts, and the order and payment status. Your card or account details never reach us: payment is handled by Stripe.
• Account: if you sign in, your email address. An account is optional.
• Technical data: IP address, browser and device, language, the pages and steps you visit, the page you came from, the ad click identifier and campaign parameters.
• Emails: which emails we sent you, and whether you unsubscribed.

• To create, show and deliver your book, process your order and payment, send the order confirmation and the link to your book, and answer your questions: performance of the contract (Art. 6 (1) (b) GDPR).
• To illustrate the comic from your photos with the help of AI services: performance of the contract (Art. 6 (1) (b) GDPR). By uploading the photos you confirm, as our terms say, that you have the right to use them and that the people shown agree, and that you upload a photo of a minor only as their parent or guardian or with the permission of a parent or guardian. If you ask us to delete the photos, we can no longer change or redraw the book.
• To keep invoices and order records: legal obligation (Art. 6 (1) (c) GDPR).
• To keep the site secure, prevent abuse and fix errors: our legitimate interest in a safe and working service (Art. 6 (1) (f) GDPR).
• To measure how the site is used and how our ads perform: our legitimate interest in improving the site and our advertising (Art. 6 (1) (f) GDPR). You can object at any time, see section 7.
• To send reminder emails about an order you started but did not finish, or about items left in your cart, and up to three emails about the printed edition of an eBook you bought, some with a time-limited offer: our legitimate interest in helping you complete an order you began with us and in telling customers about our own similar products (Art. 6 (1) (f) GDPR). You can object at any time free of charge, with the unsubscribe link in every reminder. The same applies to the SMS (up to three reminders, and up to two about the printed edition) to the phone number you entered in the order form; every SMS has a link to stop them.

We need the photos and the details of the story to make your comic, and on the website your email address to deliver it (in the apps the email address is optional, section 13). Without them we cannot fulfill an order. We do not make automated decisions with legal effect about you (Art. 22 GDPR).

Your photos are uploaded over an encrypted connection and stored on our servers at our hosting provider in the EU.

To create your comic, the photos and the details you entered are sent to the providers of the AI models that write the texts and draw the pictures: mainly Google (Gemini models), either straight through Google's API or through OpenRouter, Inc. (USA), a gateway that passes the request on to the model's provider. When Google's model cannot draw a picture, an OpenAI model (OpenAI, USA) draws it, through OpenRouter.

These requests, which contain your photos, go to Google under the terms of its paid API, which do not allow Google to use them to train its models, and through OpenRouter with a setting that only allows providers that do not use the content to train their models and do not keep it beyond the short period needed to process the request.

To check the quality of a finished comic, its pages (never your photos) are also sent to TypeSafe AI (USA), together with the main character's name and the description of their looks (age, hair, skin tone) and what the picture should show. Its AI model answers questions about them, for example whether the main character looks the same on every page.

We use your photos only to illustrate your own comic book. We do not sell them.

Your comic opens through a private link. Anyone you give this link to can read it.

We use the following service providers. Each receives only the data it needs for its task.

• Hetzner Online GmbH (Germany / Finland): hosting of the site, the database and the files.
• Cloudflare, Inc. (USA): domain name service (DNS) and the network in front of the website that delivers its pages (CDN and proxy); it sees your IP address and the requests your browser makes. It also counts page views (section 7).
• Google (Gemini API) and OpenRouter, Inc. (USA) with, through it, Google and OpenAI: creating texts and pictures (section 4).
• Stripe Payments Europe, Ltd. (Ireland): payment. Stripe receives the payment details you enter, the amount, your email address and, for printed products, the delivery address. If you pay with PayPal or Klarna, that provider receives the data needed for the payment and processes it under its own privacy policy.
• Amazon Web Services (Amazon SES, USA): sending our emails.
• Google Firebase Authentication (Google): signing in to your account with a link sent to your email address.
• Our print partner in the EU and the carrier: they receive the print files and the delivery details in order to print and ship your order.
• Google Fonts (Google): when you open a comic, its fonts are loaded from Google's servers, which receive your IP address. The basis is our legitimate interest in showing the book in its chosen fonts (Art. 6 (1) (f) GDPR).
• Google, Meta, Microsoft and AppLovin for analytics and advertising (section 7).
• GatewayAPI (OnlineCity.IO ApS, Denmark): sending our SMS reminders. It receives the phone number and the text of the message.
• TypeSafe AI (USA): checking the finished pages of a comic, with the main character's name and the description of their looks, never your photos (section 4).

Some of these providers process data in the USA. For these transfers we rely on the EU-US Data Privacy Framework where the provider is certified, and otherwise on the standard contractual clauses of the European Commission. You can ask us for a copy of these safeguards at [email protected].

The following tools are active as soon as you open the site. The site has no cookie banner and we do not ask for your consent beforehand. Except Cloudflare Web Analytics, the tools use cookies and similar storage in your browser.

• Google Tag Manager and Google Analytics 4 (Google Ireland Limited): measure which pages and steps are visited and which orders are placed. Our server also reports purchases to Google Analytics.
• Meta pixel and Conversions API (Meta Platforms Ireland Limited): measure the results of our ads on Meta's platforms such as Facebook and Instagram. For this, visits, steps and purchases are sent to Meta from your browser and from our server, together with your IP address, browser, click identifiers and hashed contact details (email address, name and, where available, phone number, city, postcode and country) and an internal visitor ID.
• Microsoft Clarity (Microsoft): records how the site is used, for example clicks, scrolling and mouse movements, so that we can find and fix problems.
• Google Ads (Google Ireland Limited): measures the results of our ads on Google. The Google Ads tag runs in your browser, and our server reports new contact details and purchases to Google Ads with the ad click identifier, your IP address, your browser, your hashed email address, phone number and name, your country and postcode, and whether you have ordered from us before.
• Microsoft Advertising (Microsoft Ireland Operations Limited): measures the results of our ads on Bing. The Microsoft tag runs in your browser, and our server reports new contact details and purchases to Microsoft with the ad click identifier, your IP address, your browser, your hashed email address and phone number, and an internal visitor ID.
• AppLovin (AppLovin Corporation, USA): measures the results of our ads in the AppLovin network. The AppLovin pixel runs in your browser and sends visits, steps and purchases to AppLovin, with your hashed email address once you have entered it, and our server reports purchases to AppLovin with the ad click identifier, your IP address, your browser, your hashed email address and phone number, your country and postcode, and whether you have ordered from us before.
• Cloudflare Web Analytics (Cloudflare, Inc.): counts page views and how fast pages load, without cookies and without recognizing you across visits. It runs on every page of the website, including the pages opened from our apps.

So purchases made on the website are reported to Google Analytics, Google Ads, Meta, Microsoft Advertising and AppLovin. Purchases made in our apps are not reported to any analytics or advertising service (section 13).

How to object:

• In your browser: block or delete cookies, or use tracking protection or a content blocker.
• Google: the opt-out browser add-on for Google Analytics at tools.google.com/dlpage/gaoptout and your ad settings at myadcenter.google.com.
• Meta: your ad settings at www.facebook.com/adpreferences/ad_settings.
• Write to us at [email protected] to object to this processing.

The site itself stores a few things in your browser that it needs to work: your language, your book in progress, your cart and your sign-in. Stripe sets cookies on the payment form to process payments and prevent fraud. The tools in section 7 set their own cookies.

We email you the order confirmation and news about your order, such as the link to your book. If you enter your email in the order form and do not finish the order, we send up to three reminders about it. Customers who bought an eBook also get reminders about items left in their cart, and up to three emails over about eight days about the printed edition of their book, some with a time-limited offer. Every reminder email has an unsubscribe link, and you can object to these emails at any time. If you also enter a phone number, we may send up to three reminders by SMS within about three days, and, if you entered it under the notice that mentions them, up to two SMS about the printed edition of an eBook you bought. Every SMS has a link that stops further messages to that number, and unsubscribing from the reminder emails stops them too.

Your comics, photos and order data stay stored so that you can open, change and reorder your comic. There is no automatic deletion period. This also applies to comics you started but did not buy.

When you ask us to delete your data, we delete your photos, the content created for your comic and your personal details. Invoices and order records are kept for as long as tax and commercial law requires, which in Germany is 6 to 10 years.

You have the right to:

• be told which data we hold about you (access)
• have incorrect data corrected (rectification)
• have your data deleted (erasure)
• have the processing restricted
• receive your data in a common format (data portability)
• object to processing that is based on our legitimate interests, including processing for advertising
• withdraw a consent at any time with effect for the future

To use these rights, write to [email protected].

You can also complain to a data protection supervisory authority: the Berlin Commissioner for Data Protection and Freedom of Information (Berliner Beauftragte für Datenschutz und Informationsfreiheit) or the authority where you live.

Our service is for adults, and the people in our comics are usually adults too. You may upload a photo of a minor (a person under 18) only if you are their parent or guardian or have the permission of a parent or guardian.

Personalized Comic Book is also available as an app for iOS (App Store) and Android (Google Play). The apps collect the same data as the site: the photos you upload, the names and details of the characters and your answers in the book creator. In the apps your email address is optional: if you enter it, we use it to send you a copy of your comic and to tell you when it is ready. Everything this policy says about the site applies to the apps in the same way, except section 7 (analytics and advertising).

As on the site, your photos and answers are sent to the AI models that create your comic: mainly Google's Gemini models, and OpenAI's image models when Google's cannot draw a picture, through Google's API or the OpenRouter gateway. TypeSafe checks the finished pictures (never your photos) with the main character's name and look. Section 4 explains how.

If you buy an eBook in an app, the payment is processed by Apple (App Store) or Google (Google Play). They share only the purchase and transaction data with us, such as the product, the transaction number, the price and whether it was a test purchase. Your card or account details never reach us. For the payment itself, the privacy policy of Apple or Google applies.

The apps keep the links to your comics on your device, so you can open them again. On iOS these links are also kept in your iCloud key-value storage, and on Android they can be part of your device backup, so they come back on a new device. They are removed when you delete the app and its data, and from iCloud or the backup when you turn these off for the app or delete the backup.

Nothing about the apps goes to analytics or advertising services: sessions started in the apps, purchases made in them, and the pages of our website that you open from an app (or from our emails about a comic made in an app) send nothing to Google Analytics, Google Ads, Meta, Microsoft or AppLovin. The only exception is Cloudflare's page count without cookies, which runs on every page of the website (section 7).

We update this policy when the service or the law changes. The current version is always on this page.