Komi Privacy and Cookie Policy
Last updated: June 2025
Welcome to Komi
We are committed to respecting your privacy and protecting your personal data. This
Komi Privacy and Cookie policy (“Policy”) sets out the basis on which any personal data
we collect from you, or that you provide to us through our website or applications
(https://komi.io/) (together, “Komi”) or otherwise in connection with our business will be
processed by us. This Policy applies to all users of Komi, including “Creators” who use
Komi to offer their content, products, events, tickets, experiences, subscriptions, gifting
capabilities and other services (“Creator Services”), general visitors to Komi (“Fans”),
as well as staff of our business partners (e.g. suppliers or customers). Please read the
following carefully to understand our views and practices regarding your personal data
and how we will handle it.
We will only collect and process information about you in accordance with this Policy and
in accordance with applicable data protection laws, including the General Data Protection
Regulation (“GDPR”), the UK Data Protection Act, the EU Privacy and Electronic
Communications Directive, local laws implementing these laws, and the privacy laws of
US States, including the California Consumer Privacy Act (“CCPA”).
This Policy also sets out the various rights you may have in connection with the
processing of your personal data under these laws.
1. WHO IS KOMI & WHAT IS OUR ROLE WHEN PROCESSING PERSONAL DATA?
1.1 Komi and the Komi services are provided by Komi App Limited, a private company
incorporated and registered in England with company number 12268875 whose registered
office is at 35 Ballards Lane, London N3 1XW, United Kingdom (“we”, “us” or “our”).
1.2 Where we decide the purposes and means for the processing of your personal
data, we are the “controller” or a “business” for the purposes of applicable privacy laws.
This means we are generally a controller or business for the processing of:
1.2.1 Creator personal data in connection with the operation, hosting and management
of Creators’ Komi accounts and provision of Komi’s services to Creators;
1.2.2 personal data of people who contact us via our support email address, sign up for
the Komi waiting list or Komi newsletter / marketing / update communications, or use the
Komi website (https://komi.io/);
1.2.3 personal data of staff of our business partners and contacts; and
1.2.4 personal data of Fans who visit Komi, where we do so on our own behalf and not
on behalf of a Creator.
1.3 If you are a Fan, then there will be many instances where Creators decide the
purposes and means for the processing of your personal data (e.g. when you sign up to a
Creator newsletter, click on links to purchase Creator Services, or interact with a Creator
on their page), and we simply process your personal data according to the Creator’s
instructions and on the Creator’s behalf. In such circumstances we are the “processor” or
“service provider” and the Creator is the “controller” or “business”.
1.4 On the other hand, we may also process Fans’ personal data when they visit any
Komi page. We may use this data for our own purposes, e.g. improvement and
development of Komi services, analysis of and insights into trends, behaviours,
preferences, attitudes and sentiment, and tailoring of advertising according to what we
infer may be your interests and preferences. In this case we are a controller/business and
fully responsible for our processing of your data.
1.5 This Policy primarily addresses the processing of personal data that we undertake
as a controller or business. Please refer to each Creator’s own privacy policy – available
from within the Creator’s profile page – for further details of the processing of your
personal data by that Creator as a controller/business.
1.6 While we contractually oblige Creators to comply with all applicable data
protection laws, each Creator as a controller/business is solely responsible for their
handling of personal data, and we do not accept any responsibility or liability regarding
how they do so.
2. How we collect and use your personal data
2.1 The table below explains what data we may collect, how we use it, and how it may
be shared:
Your data
How we use it
Recipients
Creators: Contact information
(information provided by you
when creating and using an
account on Komi)
● Full name
● Age
● Gender
● Country
● Company (if applicable)
● Username and password
● Contact details (email,
address, phone number)
● Billing information
including card details and details
relating to your payment for
Komi services (including
subscriptions where relevant)
● Komi services you make
use of
● Social media and website
usernames, URLs and/or
handles
● Information you include
on your Komi account profile
including the Creator Services
you make available on your
account, the third party links
you add to your account, the
qualifications, experience and
biographical information you
choose to provide to us, and
pictures and audiovisual
material you upload into Komi,
such as your account profile
picture
● Participation in surveys
or provision of feedback
We process this information to
provide our services to you, and
to facilitate your access to Komi,
for example to:
● register your account;
● manage your account;
● send service-related emails
(e.g. password reset links or
information re service incidents);
● ensure our services
function properly and deliver the
agreed features.
Provided we have the right to do
so, we may also process certain of
this information (such as your
name, and the Creator Services
you make available on Komi) in
Komi marketing and promotional
materials.
Finally, we may process such
information in order to monitor
and enforce compliance with our
Creator terms and usage rules,
and to investigate potential
breaches or infringements of our
usage rules.
Legal basis
We process this information for
the performance of our contracts
with you. For example, we need
your contact details to create your
account and to process payments
you make for Komi services.
Additionally, we rely upon our
legitimate interests for this
The information that
you upload to your
Creator profile on Komi
will be publicly available
to view. Similarly, to the
extent we use certain of
your (limited) personal
data in our marketing
and promotional
activity, this will be
publicly available to
view.
Information also needs
to be provided to
service providers who
assist us in the
provision of our services
– please see Section 4
below.
Your data
How we use it
Recipients
● Preferred language
processing activity, in promoting
the success of our business by:
(a) providing you with a quality
service, (b) understanding the
users of our services; and (c) (in
the case of processing in
connection with our marketing
and promotional activity)
attracting new Creator users to
our business.
Where we process this information
to monitor and enforce
compliance with, and investigate
breaches of, our Creator terms
and usage rules, we do so on the
basis of our legitimate interests of
ensuring that Komi remains a safe
and friendly environment for all
users.
We may also need to process
information in order to comply
with our legal obligations, e.g. in
relation to tax, accounting, and
recordkeeping.
Creators: Newsletter, SMS and
marketing messages
(information provided by you if
you have signed up to Komi
newsletters or commercial
communications)
● Name
● Email address
● Mobile number
● Other information you
provide when signing up to our
newsletter, marketing or feature
update communications
We process your data to make
suggestions and
recommendations to you and
other users of Komi about: (a)
news and updates relating to us,
our partners, Creators, products,
services and content; (b) content,
goods, services, experiences and
other offerings available in or
from Komi; and (c) other
promotional activity and events
we think may be of interest.
Legal basis:
In some instances (such as with
our existing Creators who have
not opted out, or where Creators
are incorporated as a business)
the law may permit us to process
your personal data in order to
send marketing information to you
that we think are of interest for
you and/or your business on the
basis of our legitimate interests in
promoting our activities and
expanding and developing our
business and Komi, content,
products and services. In other
cases, we send this information
where you have consented to
We may share your
data with email and
marketing message
vendors to assist us in
sending marketing
communications and
newsletters.
Your data
How we use it
Recipients
receive it.
If the information is not of
interest to you, you can opt-out at
any time by contacting us using
the details outlined in each
communication or the ‘Contact Us’
section below.
Creators: Support / enquiry
information (information we
receive when you get in touch
with us for support)
● Name
● Contact details (email,
address, phone number)
● Other personal data you
choose to provide to us
● Mailing preferences
We process this information to
respond to your support requests
and other enquiries.
Legal basis
We process this information:
● for the performance of our
contract with you for provision of
our services;
● in pursuit of our legitimate
interests including: (a) our
interest in responding to enquiries
to ensure smooth operation of our
business and Services; and (b)
our interest in understanding our
users and improving our services,
by taking onboard your feedback.
We may share this
information with
vendors who assist us
with managing
customer services
enquiries.
Creators, Fans, and Komi
visitors: Website Analytics
(collected from your device and
interaction with Komi)
● How often you use Komi
● Which content, pages
and application screens you go
to and which features you use,
● Your IP address, and
device identifiers communicated
by your device or browser
● Device and browser
operating system, version, make
and model
Please note that in addition to
our processing, Creators may
process your personal data
using analytics tools they place
on your devices via their Komi
homepage. Please refer to the
Creator’s own privacy or cookie
policies for further information.
Komi does not control such
Creator analytics tools or access
information collected by each
Creator as a controller/business.
We may process this information
(on its own or together with your
account information) so that we
can: (a) understand usage of our
services and improve our
services; (b) identify and solve
problems or bugs; and (c) develop
new services or content we think
will be of greatest interest.
Legal basis
Where required by applicable
laws, we will obtain your prior
consent before undertaking this
processing. Otherwise, we will
process this data based on our
legitimate interests in
understanding use of and
improving our services.
We use:
Google Analytics
(https://support.google.
com/analytics/answer/6
004245?hl=en)
to help us understand
how our services are
used.
We may share this
information with our
service partners as
required for the
provision of our
services, and with
Creators in an
aggregated and
non-personally
identifiable form.
Please see our Cookie
Policy for more
information about our
use of cookies and
similar technologies.
Creators, Fans: purchase and
We may process this information
We may share this
Your data
How we use it
Recipients
engagement information
(collected from your device and
interaction with Komi)
● Purchases of or
subscriptions to content,
merchandise and Creator
services through Creator pages
● Payment status and
processing information
Please note that in addition to
our processing, Creators may
process your personal data
using analytics tools they place
on your devices via their Komi
homepage. Please refer to the
Creator’s own privacy policies
for further information. Komi
does not control such Creator
analytics tools or access
information collected by them as
a controller/business.
(on its own or together with your
account information) so that we
can: (a) provide the Komi services
which include supporting Creators
with sales of merchandize or other
Creator Services; and (b) permit
Creators to view, evaluate and
create reports on Creator
Services.
Legal basis
For the performance of our
contracts with Creators; or for our
legitimate interests in
understanding how our services
are used and relevant trends and
preferences.
information with our
service partners as
required for the
provision of our
services, and with
Creators.
Fans and Komi visitors:
marketing-related information
(collected from your device and
interaction with Komi)
● How often you visit Komi
● Which content, pages
and application screens you go
to and which features you use,
● Your IP address, and
device identifiers communicated
by your device
● Device and browser
operating system, version, make
and model.
We may process this information
(on its own or together with your
account information) and share it
with our advertising technology
partners and other third parties in
order to provide advertising
tailored to what are inferred to be
your interests and preferences.
Legal basis
Where required by applicable
laws, we will obtain your prior
consent before undertaking this
processing. Otherwise, we will
process this data based on our
legitimate interests in undertaking
marketing and advertising
activities.
We may share this
information with our
service partners and
customers in order to
provide targeted
advertising services.
Please see our Cookie
Policy for more
information about our
use of cookies and
similar technologies.
Creators: Account Analytics
(collected from your device and
from you when you interact with
your Komi account)
● Your use of your account:
when you are active on your
account, devices used to
access your account, country
from which you access your
account.
● Conversion analytics:
whether you signed up for your
We process all other account
analytics data so that we can: (a)
understand and improve usage of
our services and marketing; (b)
identify and solve problems or
bugs; and (c) develop new
services and marketing content
we think will be of greatest
interest.
Legal basis
Where required by applicable
laws, we will obtain your prior
consent before undertaking this
We use:
● Google Analytics
(https://support.google.
com/analytics/answer/6
004245?hl=en)
● Segment
(Privacy Tools Overview
Segment
Documentation
https://segment.com/d
ocs/privacy/)
Your data
How we use it
Recipients
account having seen a Komi
advertisement, whether you
convert your free trial of Komi
into paid subscription
processing. Otherwise, we will
process this data based on our
legitimate interests in
understanding use of and
improving our services.
● Mixpanel
(Mixpanel: Event
Analytics for Mobile,
Web & More
https://mixpanel.com/h
ome/)
to help us understand
how our services are
used.
Creators / Fans: Competition
and promotion related entry
information (information we
receive when you enter a
competition / prize promotion
with us such as over email or
over social media):
● Name (and/or your social
media unique user name)
● Contact details so we can
process your entry (such as
email, address, phone number
if we need to send you a prize)
● Information submitted as part
of your entry
We process this information for
the purposes of managing and
fulfilling the purposes of the
competition and promotion.
Legal basis
The processing is necessary for
the performance of the contract
with participants governing the
competition / promotion.
Information also needs
to be provided to
service providers who
assist us in the
provision of our services
– please see Section 4
below.
Creators: Push notifications
(when your device sends you a
notification of an activity in
Komi applications, such as about
new functionality available for
use on your profile)
● Device identifiers
communicated by your device
● Push notification preferences
Where required by law, we will
obtain your prior consent before
sending you push notifications
through our applications.
In some cases, you may provide
the foregoing consent at a ‘device
level’ and/or the option for you to
consent to the notifications may
be prompted through your device
rather than our application.
For most mobile and tablet
devices, push notifications can be
disabled in your device settings.
Information also needs
to be provided to
service providers who
assist us in the
provision of our services
– please see Section 4
below.
Representatives of customers or
suppliers (or potential
customers or suppliers) and/or
media, PR or other business
contacts:
Business contact information,
e.g.:
• name
• employer
• work address
• work email
• work phone
To provide customers with
information, products and support
To evaluate, obtain and pay for
supplies
To carry out our obligations and
enforce our rights arising from our
customer or supplier contracts
To invoice and collect accounts
payable
Information also needs
to be provided to
service providers who
assist us in the
provision of our services
– please see Section 4
below.
Your data
How we use it
Recipients
• title
• qualifications / business
interests
• contractual information
To promote and develop our
business
To notify interested parties about
changes to our services
To keep records for accounting,
tax, or legal compliance purposes
Legal basis
For the performance of our
contracts with our customers and
suppliers
That it is necessary for our
legitimate interests in managing
our business
To comply with our legal
obligations
3. Your Rights In Relation To Your personal data
3.1 You have the following rights in respect of your personal data:
● To ask us for access to the personal data we are processing about you;
● To ask us to correct inaccuracies in your personal data;
● To ask us to erase or delete your personal data;
● If not erased, then to ask us to restrict its processing;
● To object to its processing for specific purposes, e.g. for direct marketing;
● To ask for a copy to take to another service provider.
● (Where we rely on your consent to process your personal data) to withdraw your
consent at any time;
● To make a complaint to a data protection regulator or Supervisory Authority;
● To know what personal data we have collected about you, whether it is sold or shared,
and to access a copy of it;
● To opt out of sales or sharing of that personal data (please also see Section 11);
● To limit the use or disclosure of your sensitive personal data;
● Not to be discriminated against for exercising any of your rights under applicable
privacy legislation (for example we would not deny you service, charge you a different price, or
provide you a different quality of service for doing so).
3.2 To make a request in relation to any of the aforementioned rights, you (or your
authorized agent) can send your request to us here: [email protected]. If you make such
a request, including through an authorized agent, we reserve the right to verify your
identity and the agent’s authorization. However, we may not be able to respond to your
request if it is not permitted or foreseen under applicable laws. We aim to comply without
undue delay, and at the latest within the time periods set by applicable privacy laws, in
response to any requests submitted by you to us in connection with your rights.
4. Disclosure Of Your Personal Data
4.1 We sometimes need to provide information to different service providers who
assist us in the provision of our services, some of which are identified in Section 2 above.
We may also disclose your personal data to:
4.1.1 Our group. We keep your personal data confidential, but may disclose it to any
member of our corporate group, our personnel, or contractors insofar as it is reasonably
necessary for the purposes set out in this Policy.
4.1.2 Suppliers and service providers. We may use a range of suppliers and service
providers to operate our business, including technical service providers (for purposes such
as customer support, analytics, email and targeted advertising delivery, or database
management), and professional services providers (such as payment service providers
and security, insurance, legal, and accounting services), that require access to data for
these purposes.
4.1.3 Enforcement. We may also disclose your personal data to third parties in order to
enforce or apply the terms of our agreements, to investigate potential breaches, collect
fees, or to protect the rights, property or safety of us, our personnel or customers, or
others.
4.1.4 Law enforcement / government authorities. In addition, we may disclose your
personal data where we receive an official request (which may include to government
bodies and law enforcement agencies); in connection with any legal proceedings or
prospective legal proceedings; and to establish, exercise or defend our legal rights
(including providing information to others for the purposes of fraud prevention).
4.1.5 Potential acquirers or investors. If we are involved in a merger, acquisition, or sale
of all or a portion of our business or assets, personal data we hold may be shared.
5. INTERNATIONAL DATA TRANSFERS
5.1 We use servers and service providers located in multiple jurisdictions, including
our main cloud servers in the USA.
5.2 Where we use service providers which are outside the United Kingdom, the EU
and the European Economic Area, or outside other places that are officially considered to
have adequate data protection laws, we have agreements in place to ensure that
personal data is processed using appropriate safeguards that meet the requirements of
data protection laws. Such appropriate safeguards may include standard data protection
clauses adopted by a data protection regulator and approved by the UK Data Protection
Regulator and/or European Commission.
5.3 If you would like to find out more about these safeguards or if you have any other
queries or comments in relation to this Policy, please let us know by contacting us by
email: [email protected].
6. DATA RETENTION
6.1 We will only hold data about you for as long as necessary, bearing in mind the
purpose for which that data was collected, or as otherwise described in this Policy.
6.2 To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of harm from
unauthorized use or disclosure of your personal data, the purposes for which we process
your personal data and whether we can achieve those purposes through other means,
and the applicable legal requirements.
7. SECURITY
7.1 We will take commercially reasonable, appropriate technical and organizational
measures to ensure a level of security appropriate to the risk that could be encountered
via the use of Komi taking into account the likelihood and severity those risks might pose
to the rights and freedoms of Komi users.
7.2 In particular, we will take precautions to protect against the accidental or unlawful
destruction, loss or alteration, and unauthorized disclosure of or access to the personal
data transmitted, stored or otherwise processed by us.
8. DO I NEED TO PROVIDE PERSONAL DATA TO KOMI?
8.1 You may be required to provide us with certain information for us to register your
account with us. You cannot use Komi as a Creator user without an account. If the information
is required for the performance of our services contracts with you, then generally we will not
be able to provide some or all services unless you provide all necessary information.
8.2 Where the legal basis for our processing of your data is our legitimate interests, you are
not required to provide us with this information but, if you do not, we may not be able to work
with you or to provide you with particular parts of the Komi services, information of interest or
other benefits such as competition entries.
8.3 Where our legal basis for processing your data is your consent, then you can freely
withhold or withdraw such consent at any time.
9. GENERAL
9.1 Komi may contain links to third party functionality, apps or websites. These third
party functions, apps or websites may have their own privacy policies and we recommend
that you review them. We do not accept any responsibility or liability for the privacy
practices of such third parties and your use of their services and any transactions with
them are at your own risk.
9.2 We may make changes to this Policy in the future, which will be posted on this
page. You should check this page from time to time to ensure you are aware of any
changes. Where appropriate we may notify you of changes by email or pop-up message in
your Komi account.
9.3 Creators may choose to promote YouTube content when using Komi. In such cases
YouTube API services are used to ensure YouTube content is properly displayed. We
recommend you review Google’s privacy policy available in the latest version here to
understand how YouTube may process your data.
10. CONTACT US
All questions, comments or enquiries should be directed to us by email: s[email protected]
11. ADDITIONAL INFORMATION FOR CALIFORNIA CONSUMERS
11.1 Personal Information Collected in the past 12 months
Category
Examples
Source
Business or
Commercial
Purpose
Categories of
third parties
disclosed to
(A) Identifiers
(Creators)
Real name, alias, unique
personal identifier, online
Directly from
Creators
Providing the
Komi services
- Our cloud storage
service providers
identifier, Internet
Protocol address, email
address, account name,
picture, biography
and setting up
and managing
Creator accounts
on Komi,
permitting and
controlling
access to your
account,
providing
customer
service.
- Our technical
service providers
(for purposes such
as customer
support, analytics,
email delivery,
database
management, or
payment
processors)
- Our professional
advisers (such as
security, insurance,
legal, and
accounting service
providers)
(A) Identifiers
(Fans, Komi
visitors)
Unique personal
identifier, online
identifier, Internet
Protocol address
Directly from
Fans and Komi
visitors
Managing and
improving Komi,
improving the
browsing
experience for
returning users,
and responding
to your inquiries
or requests
- Our cloud storage
service providers
- Our technical
service providers
(for purposes such
as customer
support, analytics,
email
communications,
database
management)
(A) Identifiers
(Fans, Komi
visitors)
Unique personal
identifier, online
identifier, Internet
Protocol address
Directly from
Fans and Komi
visitors
Sharing for the
purpose of
cross-context
behavioral
advertising
- Our cloud storage
service providers
- Our advertising
technology
partners and
customers
(B) Individual
Records
Name, social security
number, address,
telephone number, other
financial information
Directly from
Creators
Collecting
payments for
Komi services
As above
(D) Commercial
information
Records of personal
property, products
or services purchased,
obtained, or considered,
or other purchasing or
consuming histories or
tendencies
Directly from
Creators, Fans
Providing the
Komi services
which include
supporting
Creators with
sales of
merchandize or
other Creator
Services; and
permitting
Creators to view,
evaluate and
create reports
on Creator
Services
As above
(F) Internet or
other electronic
network activity
information
Information regarding
your interaction with
internet website
applications (e.g. visits
to, interactions with, or
purchases from Creator
Pages)
Directly from
Fans
Providing the
Komi services
which include
supporting
Creators with
sales of
merchandize or
As above
other Creator
Services; and
permitting
Creators to view,
evaluate and
create reports
on Creator
Services
(I) Professional
or
employment-rela
ted information
(Creators and
other business
contacts)
Name, title, business
email, business phone
numbers, business
address, business
interests, employment
information and
education or
qualifications information
Directly from
Creators or
you, or from
your employer
Managing
provision of the
Komi Services,
permitting and
controlling
access to your
account,
providing
customer service
As above
(I) Professional
or
employment-rela
ted information
(potential
Creators,
potential
customers or
suppliers)
Name, title, business
email, business phone
numbers, business
address, business
interests, employment
information and
education or
qualifications information
Directly from
potential
Creators or
you, or from
your
employer; or
from
networking, or
other public
sources (e.g.
trade shows,
professional
websites)
Growing and
managing our
business
As above
(K) Inferences
Inferences drawn from
any of the information
above
From Creators,
Fans, and
processed by
Komi and our
partners
Providing
content or
advertising
tailored to your
inferred
interests and
preferences
As above
COOKIE POLICY
Last updated: April 2025
“Cookies” are data files that are placed on your device or computer by websites that you
visit or applications you use and often include an anonymous unique identifier.
They are widely used in order to make websites work, or work more efficiently, as well as
to provide information to the owners of the site or enable recognition of returning visitors
or serving of more relevant advertising. The table below explains the cookies and
analytics tools we use and why.
For more information about cookies, and how to remove or disable cookies,
visit http://www.allaboutcookies.org.
Please note that Creators may place their own cookies, trackers or analytics tools on your
devices via their Komi page. Such cookies and tools will process your personal data, and
may be used to (amongst other things) serve advertising to you in third party services,
and/or infer details relating to you from your behaviour across channels where they link
to the Creator’s Komi page. Please refer to the Creator’s own privacy policies for further
information on their practices in this regard. Komi does not control such Creator cookies
or access information collected by them as a controller or business (see Komi’s privacy
policy above for further detail as to when Komi acts as a controller/business or
processor/service provider).
Cookie
Duration
Purpose/ Third Party Access
Google Analytics
180 Days
This cookie is used to collect information about
how users use Komi. We use the information
to compile reports and to help us improve our
services. The cookie collects information on
the number of users, where users have come
to the website/Komi from and the webpages
or app screens they visited. We do not
facilitate the merging of
personally-identifiable information with
non-personally identifiable information. We
collect the following information through
Google Analytics: Bounce Rate, Sessions,
Average Pages per sessions, where our users
come from (is it organic, social, referral,
email), Device usage, Age range, User
interests, what else are the users interested
in, Time of day that website is used, Location,
Page Views, Entrances, Exits, Average time on
page, Returning visitors vs
New Downloads, Social Share.
Read Google’s overview of privacy and
safeguarding data here.
Cookie Control
Persistent
This cookie will be set on your device for the
purpose of remembering your cookie consent
preference. This cookie will be set even where
you reject all cookies in the cookie consent
tool, so that we know not to place any other
cookies on your device on your visits to Komi.
Preferences
One month
To remember information about you such as
your preferred language and configuration.
Facebook Connect
Segment.io
Ketch Cloud
Google Tag Manager
Amazon Cloudfront
Amazon Web Services
HOW DO I CHANGE MY COOKIE SETTINGS?
Most web browsers allow some control of most cookies through the browser settings. Find
out how to manage cookies on popular browsers:
● Microsoft Edge cookies information
● Internet Explorer cookies information
● Chrome cookies information
● Firefox cookies information
● Safari cookies information – mobile devices and desktops
● Opera cookies information
To find information relating to other browsers, visit the browser developer’s website.
For information on how to opt out of the collection and use of information for ad targeting
visit http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.