legal document

Privacy Policy

Effective date: 6 July 2026
Version: 1.0

1. About this Policy

This Privacy Policy explains how Comers processes data in connection with the use of the comers.app website, the forms available on the website, and communication with the project.

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 contact: hello@comers.app

2. What data we process on the website

When you use comers.app, we may process technical data related to displaying the website, security, and proper operation of the service. This may include in particular:

IP address,
browser and device information,
date and time of the request,
basic network traffic information,
technical information processed by Cloudflare infrastructure,
information related to protection against abuse, bots, and spam.

The website may also remember the selected language version so that the right language can be displayed on your next visit.

3. Forms on the website

The website may include forms where users knowingly provide data. Currently, this mainly concerns:

the form used to receive a notification when public beta sign-ups open,
the public beta application form,
optional newsletter sign-up, if such an option is made available.

Detailed information about data processing related to public beta applications is available in a separate document: “Public Beta Privacy Notice”.

4. Why we process data

We process data for the following purposes:

displaying and maintaining comers.app,
ensuring website security and protecting against abuse,
remembering the user’s language preference,
handling forms available on the website,
sending organisational messages that the user signed up for or that are related to their application,
handling communication addressed to Comers,
developing the project, analysing interest in Comers, and planning the next stages of the product,
establishing, pursuing, or defending against possible claims.

5. Legal bases for processing

Depending on the situation, we process data based on:

the need to take action at the user’s request, for example to handle an application or contact request,
Comers’ legitimate interest, for example ensuring website security, maintaining infrastructure, analysing interest in the project, and protecting against abuse,
the user’s consent, for example in the case of voluntary newsletter sign-up,
legal obligations, where applicable.

6. Cloudflare, hosting, and security

The comers.app website runs as an Astro application hosted on Cloudflare infrastructure, in particular using Cloudflare Workers. Forms may use Cloudflare Turnstile, which helps protect the website against bots, spam, and automated abuse.

Cloudflare may process the user’s technical data to deliver the website, handle requests, secure traffic, and ensure the proper operation of the infrastructure.

7. Cookies, localStorage, and similar technologies

Comers does not use cookies or similar technologies for advertising tracking.

The website may use localStorage, sessionStorage, cookies, or a similar technology to remember the selected language version. This means the user does not have to select the language again on every visit.

If we introduce analytics, additional cookies, advertising pixels, or similar technologies in the future, we will update this Privacy Policy and, where required, ask the user for the appropriate consent.

8. Analytics

At the moment, Comers does not use external analytics tools such as Google Analytics, Plausible, PostHog, or advertising pixels.

This does not exclude technical data processing by Cloudflare as part of domain, hosting, security, and infrastructure operations.

9. Email and communication

We may use transactional email providers, such as Mailgun, to send emails. This may include confirmation messages for notification sign-ups, organisational information, beta invitations, or other messages related to Comers.

If a user voluntarily subscribes to the newsletter, their data may be processed using a newsletter tool such as Mailchimp.

Data may be processed by service providers that support Comers technically or organisationally, in particular:

infrastructure and hosting providers, including Cloudflare,
security service providers, including Cloudflare Turnstile,
transactional email providers, including Mailgun,
newsletter tool providers, if the user subscribes to the newsletter,
administrative tools used to handle applications and communication,
entities authorised under applicable law, if required.

We do not sell users’ personal data.

11. Transfers outside the EEA

Some technology providers may process data outside the European Economic Area or use global infrastructure. 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.

12. How long we keep data

Technical data related to the operation of the website is kept for the period resulting from infrastructure, security, and technical log configuration.

Data submitted through forms is kept for the period needed to handle the relevant purpose, for example contact, notification about the start of sign-ups, handling a beta application, or communication related to the project.

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

Data may be kept longer if needed to establish, pursue, or defend against claims, ensure security, or comply with legal obligations.

13. User rights

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 a user voluntarily subscribes to the newsletter, we may send information about the development of Comers, new features, product availability, educational materials, research, surveys, product communication, and commercial information related to Comers.

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

15. Changes to this Policy

Comers is a dynamically developing project. We may update this Privacy Policy when website features, forms, technology providers, the beta program, or legal requirements change.

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