legal document

Public Beta Privacy Notice

Effective date: 6 July 2026
Version: 1.0

1. About this Notice

This Notice explains how Comers processes personal data in connection with public beta applications, the waiting list, candidate qualification, organisational communication, the newsletter, and participation in the beta program.

Comers is an independent technology startup currently being built and developed 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 the project and its operations.

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

2. What this Notice covers

This Notice covers data processed in connection with:

signing up to be notified when public beta applications open,
submitting a public beta application,
reviewing and qualifying applications,
contacting a candidate,
inviting a candidate to participate in the beta,
maintaining the waiting list,
organisational communication related to the program,
voluntary newsletter sign-up,
participation in the public beta as a contact person or participant.

This Notice does not describe in detail data of customers, contractors, orders, shipments, messages, products, integrations, or other business data that a participant 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 form used to receive a notification when public beta applications open, we process in particular:

email address,
selected language version,
country technically detected by Cloudflare, if available,
date of creation and update of the sign-up.

In connection with the public beta 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,
information about willingness to actively participate in beta testing,
additional open text answer,
preference to remain on the waiting list,
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 joining the Comers Beta waiting list.

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

5. Technical data and form protection

Forms use Cloudflare Turnstile to protect against bots, spam, and abuse. Forms 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 a public beta application,
receiving and storing a request to be notified when applications open,
sending confirmation of notification sign-up,
manually reviewing applications,
selecting participants for future public beta waves,
contacting a candidate or participant,
sending a public beta invitation,
maintaining the waiting list,
organising and operating the beta program,
providing organisational information about the beta,
collecting feedback from participants,
ensuring security of forms, 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 participation terms are entered into,
Comers’ legitimate interest in running the beta program, qualifying candidates, 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 candidate qualification

Public beta applications are reviewed manually.

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

fit with the features currently being tested,
type of business activity,
sales channels,
scale of sales or operations,
country or market,
readiness to provide feedback,
diversity of the test group,
technical, organisational, or product risk.

Submitting an application does not guarantee acceptance into the public beta. We do not use solely automated decision-making in this process that would produce legal effects concerning the candidate or similarly significantly affect them.

9. Waiting list

If a candidate confirms that they want to remain on the waiting list, we may keep their data and contact them about future public beta waves, availability, invitations to the program, or organisational information about the beta.

A candidate may ask to be removed from the waiting list at any time 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 a public beta application.

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 a candidate does not subscribe to the newsletter, we may send messages directly related to their application or participation in the public beta, such as:

confirmation of notification sign-up,
information about application status,
invitation to the public beta,
organisational information about the program,
messages related to access to Comers,
notices about important changes, restrictions, or the end of the beta.

Such messages are not a newsletter; they are communication related to the application or participation in the program.

12. Where we store data

Public beta applications are handled through the comers.app website running on Cloudflare infrastructure. Data from forms is stored in a Cloudflare D1 database.

Data is stored in tables covering notification sign-ups and full beta applications. For a full 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 the program is 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 on the project if needed to handle the public beta, develop the product, support participants, or ensure security. Access will be granted only to the extent needed for these purposes.

14. Technology providers

In connection with the public beta, 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 candidate or participant data.

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 project 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 participant story will be possible only after a separate agreement with the relevant participant.

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 data of public beta candidates for the duration of the public beta and subsequent waves of the program, because a candidate may be invited at a later stage.

After the public beta ends, data may be kept for a reasonable period needed to close the program, handle communication, analyse results, develop the product, and establish, pursue, or defend against possible claims.

Data of people on the waiting list is kept until the purpose of the waiting list ends, the person withdraws their wish to remain on the list, or the data is erased upon request, unless there is another basis for further processing.

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 a public beta application.

21. Changes to this Notice

Comers is developing dynamically. We may update this Notice if the form, beta handling process, technology providers, access model, or legal requirements change.

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