legal document

Application Privacy Notice

Effective date: 3 October 2026
Version: 3.0

1. About this Notice

This Notice explains how Comers processes personal data in connection with applications for free access to Comers, the qualification of applications, application review waves, granting access to the Free plan, organisational communication, the newsletter, and the use of Comers under the Free plan.

Public self-service registration is not open yet. Companies and individuals currently obtain access to Comers by applying for free access; accepted applicants receive access to the Free plan.

Comers is an independent technology startup developed and operated by its founder, Damian Nosowicz. For data protection purposes, the founder acts as the data controller. In this document, we simply use “Comers”, “we” and “us” when referring to Comers and its operations.

Privacy contact: privacy@comers.app
General and access contact: hello@comers.app

This Notice replaces version 2.0 dated 30 September 2026.

2. What this Notice covers

This Notice covers data processed in connection with:

submitting an application for free access to Comers,
reviewing and qualifying applications,
contacting an applicant,
granting an applicant access to the Free plan,
keeping applications for later application review waves,
organisational communication related to the application and access to Comers,
voluntary newsletter sign-up,
the use of Comers under the Free plan as a contact person or user.

This Notice does not describe in detail data of customers, contractors, orders, shipments, messages, products, integrations, or other business data that a user may later enter into Comers after receiving access.

Such processing may require separate terms, including a data processing agreement or another document concerning data entered into the application.

3. What data we may process

In connection with the free access application form, we may process in particular:

email address,
selected language version,
first name,
information on whether the application is submitted as a business, an individual, or someone just exploring Comers,
company name, if the application is submitted as a business,
role, for example business owner, e-commerce manager, marketplace seller, warehouse manager, customer support, developer/integrator, agency/consultant, or another role,
sales channels, for example eBay, Amazon, Allegro, WooCommerce, Shopify, PrestaShop, Magento/Adobe Commerce, Etsy, Kaufland Marketplace, Empik Marketplace, own online store, or other channels,
monthly order volume,
planned number of Comers users,
areas of interest, for example orders, multi-channel selling, products, warehouse, shipping, customer messages, support, AI agent, automations, analytics and reports,
currently used solutions, for example BaseLinker, Sellasist, Apilo, Subiekt, enova365, Comarch ERP, SAP, Odoo, Excel, custom solution, no system, or other solutions,
preferred way of using Comers, for example SaaS, self-hosted, or not decided yet,
location or region,
country entered by the user,
preferred way of using the Free plan,
additional open text answer,
confirmation of applying for free access to Comers (Free plan),
preference to receive the newsletter,
country technically detected by Cloudflare, if available,
a full copy of the data submitted in the form, technically stored as raw_json,
application creation date.

The scope of data may vary depending on the current version of the form.

4. Which data is required

In the current application form, the following data is required:

email address,
information on who is submitting the application,
company name, if the application is submitted as a business,
role,
monthly order volume,
planned number of Comers users,
preferred way of using Comers,
confirmation of applying for free access to Comers (Free plan).

Other fields are optional, unless the current form states otherwise.

5. Technical data and form protection

The form uses Cloudflare Turnstile to protect against bots, spam, and abuse. The form may also include a hidden anti-spam field; if it is filled in, the submission may be treated as automated or suspicious.

In connection with form operation and infrastructure, technical data may be processed, such as IP address, browser and device information, submission time, basic security data, and information needed to properly handle the request.

6. Why we process data

We process data for the following purposes:

receiving and storing an application for free access,
manually reviewing applications,
selecting applications in current and later application review waves,
contacting an applicant or a Free plan user,
sending a decision or information about granting access to the Free plan,
keeping applications for later application review waves,
organising and operating controlled access to the Free plan,
providing organisational information about access to Comers,
collecting feedback from Free plan users,
ensuring security of the form, the website, and infrastructure,
preventing spam, bots, and abuse,
developing Comers and analysing product interest,
creating aggregated, statistical, or anonymised analyses of interest in Comers,
sending the newsletter, if the user voluntarily subscribes,
establishing, pursuing, or defending against possible claims.

7. Legal bases for processing

Depending on the purpose, data may be processed based on:

taking action at the request of the data subject before any potential terms of use are entered into,
Comers’ legitimate interest in operating controlled access to Comers, qualifying applications, securing infrastructure, developing the product, handling communication, and protecting against abuse,
consent, in particular for voluntary newsletter sign-up,
a legal obligation, where applicable,
a legitimate interest in establishing, pursuing, or defending against claims.

8. Manual qualification of applications

Applications for free access are reviewed manually.

When selecting applications, we may consider, among other things:

fit with Comers’ current product, onboarding, and operational needs,
type of business activity,
sales channels,
scale of sales or operations,
country or market,
readiness to provide feedback,
diversity of the user group,
available onboarding and support capacity,
technical, organisational, or product risk.

Submitting an application does not guarantee access to Comers. We do not use solely automated decision-making in this process that would produce legal effects concerning the applicant or similarly significantly affect them.

9. Later application review waves

If an application is not accepted in a given wave, we may keep it and contact the applicant about later application review waves, available capacity, granting access to the Free plan, or organisational information about access to Comers.

An applicant may ask at any time for their application to be withdrawn and no longer considered by contacting us at privacy@comers.app or hello@comers.app.

If a user voluntarily subscribes to the newsletter, we may send information about Comers, product development, new features, launches, availability, educational materials, commercial information, research, surveys, and questions about user needs.

The newsletter is voluntary. Not subscribing to the newsletter does not prevent submitting an application for free access.

You can unsubscribe from the newsletter at any time by using the unsubscribe link in the email or by contacting us.

We may use Mailchimp to manage the newsletter.

Even if an applicant or user does not subscribe to the newsletter, we may send messages directly related to their application or their use of the Free plan, such as:

information about application status,
a decision or information about granting access to the Free plan,
organisational information about access to Comers,
messages related to access to Comers,
notices about important changes or restrictions concerning the Free plan or access to Comers.

Such messages are not a newsletter; they are communication related to the application or the use of the Free plan.

12. Where we store data

Applications for free access are handled through the comers.app website running on Cloudflare infrastructure. Data from the form is stored in a Cloudflare D1 database.

For each application, data is stored both in dedicated fields and in a technical copy of the form, raw_json, which helps preserve the full history of the application and maintain compatibility with future form changes.

Data may be displayed in the Comers operational panel, for example ops.comers.app, through secured access. Access to applications should be limited organisationally and technically.

We do not plan to export applications to CSV files or synchronise them with a CRM or support system, unless we change the way applications are handled in the future. If there is a material change, we will update this Notice.

13. Who has access to data

Currently, the founder of Comers has access to applications.

In the future, access may be granted to people cooperating with Comers if needed to handle applications and access, develop the product, support Free plan users, or ensure security. Access will be granted only to the extent needed for these purposes.

14. Technology providers

In connection with applications and access to Comers, we may use technology providers, in particular:

Cloudflare — hosting, Workers, D1, security, Turnstile, and infrastructure,
Mailgun — sending transactional and organisational emails,
Mailchimp — newsletter management, if the user subscribes,
other technology providers, if needed for the secure and proper operation of Comers.

We do not sell data of applicants or users.

15. Aggregated, statistical, and anonymised data

We may use data in aggregated, statistical, or anonymised form to analyse interest in Comers, plan the product, research the market, communicate with partners, potential investors, or in Comers materials.

In such cases, we do not share data that directly identifies a specific person, such as first name, email address, or an individual application profile.

Publication of a company name, logo, case study, quote, or user story will be possible only after a separate agreement with the relevant user.

16. Transfers outside the EEA

Some technology providers, in particular global providers of infrastructure, email, or newsletter tools, may process data outside the European Economic Area.

If such a transfer takes place, it should be based on appropriate legal mechanisms, such as standard contractual clauses, adequacy decisions, or other safeguards provided by data protection laws.

17. How long we keep data

We keep applications for as long as they remain relevant for reviewing access to Comers and for subsequent application review waves, because an applicant may be granted access at a later stage.

After access to the Free plan is granted, data may be kept for the period needed to handle that access and the relationship with the Free plan user.

After that, data may be kept for a reasonable period needed to handle communication, carry out analyses, develop the product, and establish, pursue, or defend against possible claims.

Data of an applicant who asked for their application to be withdrawn is kept only as long as another basis for further processing exists, for example to demonstrate compliance or protect against claims.

Newsletter data is kept until the user unsubscribes or withdraws consent, unless longer retention is needed to demonstrate compliance or protect against claims.

18. Rights of the data subject

The person whose data is processed may have the following rights:

the right of access to data,
the right to rectification,
the right to erasure,
the right to restriction of processing,
the right to data portability,
the right to object to processing,
the right to withdraw consent, where processing is based on consent,
the right to lodge a complaint with the competent data protection supervisory authority.

To exercise your rights, you can contact us at privacy@comers.app.

If processing is based on consent, consent may be withdrawn at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

For the newsletter, unsubscribing is possible through the unsubscribe link in the email or by contacting us.

20. Requirement to provide data

Providing data in the application form is voluntary, but some data is needed to receive and review the application. Failure to provide required data may prevent the form from being submitted or the application from being reviewed.

Newsletter sign-up is voluntary and is not a condition for submitting an application for free access.

21. Changes to this Notice

We may update this Notice if the form, the application handling process, technology providers, the access model, or legal requirements change.

The current version of this document will be available on comers.app.