Comic Release Privacy Policy

1. Who we are

Registered as Biz Group FZ-LLC (also referred to as “Biz Group”, “we”, “our,” or “us”) and operating from Dubai Production City (DPC), formerly the International Media Production Zone (IMPZ). Our address is Unit D56, Dubai Production City, Dubai, United Arab Emirates. For the purposes of the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021, "PDPL"), Biz Group FZ-LLC is the data controller for the personal data described in this policy.

2. Scope

Comic Release is a teambuilding activity delivered exclusively within teambuilding events and facilitated sessions approved by Biz Group and is not offered as a public consumer product. Participant(s) (also referred to as “participating user”, “you”, “your”, or "yourself") must use device(s) approved or provided by Biz Group while accessing this cloud hosted platform for Comic Release. We do not guarantee the privacy of your data when this platform is accessed on a personal device, or on a device provided by a participating user, your third-party event organizing company, or your employer.

3. What we collect

Comic Release activities are session based, using a session identifier rather than a persistent login account. During such sessions, we store the uploaded images, Artificial Intelligence (AI) generated images, details of your team’s comic strip, the prompts used to create saved images, and a record of your given consent (Section 5) required for the technical operation of the platform.

During a session, participants may:

• Upload text or images to be used in generating AI processed text or image responses
• Add preferred text relevant to the comic strip

We also automatically receive standard technical data generated by using the platform (such as IP address, browser type, technical logs, and session timestamps) through our hosting and infrastructure providers, consistent with normal web operation.

Where your session uses team slots, we also receive the name you enter when you join. When you accept the AI Studio notice, we save a record of that agreement containing the session, your team slot, the name you entered, this device identifier, and the time you agreed. This record does not contain your IP address.

Stored in your browser, Some information, such as the device identifier described above, your AI Studio chat history, your image library and your comic in progress, is kept in your browser's local storage on the device you use, rather than on our servers.

4. How we use this data

We use the data described above to:

• Generate the AI-assisted text or image outputs that is the core aim of the session
• Maintain image style consistency within a single session
• Display and share session outputs in real time between participants and facilitators
• Maintain the security and technical operation of the platform
• Use outputs in Biz Group's marketing and promotion, where the organization that booked the session agrees (see our Terms of Use)

5. Consent and Legal basis for processing

In addition to the short notice that asks for your consent before your first request, we treat uploading a photo or entering a text prompt as a deliberate, voluntary act and as your consent to process that text or image for the purpose of generating the requested output. This applies to every request made by you and your team. Where optional identifying details are provided, the same basis applies.

• Your choices, Uploading a photo is optional. Though encouraged by facilitators for you and your team to be in the pictures and the final comic strip, participants who prefer not to use their own photo can create characters from a written description instead, and can choose not to appear in a photo.
• Facial and sensitive data, We do not create facial templates, face prints or any other biometric identifiers, and we do not use photos to identify people or to infer sensitive characteristics such as ethnicity, religion or health. Photos are sent to the AI model only as images, to produce the requested output.
• Abuse monitoring, The AI models apply their provider's safety filters, which block requests for harmful, sexual, copyright, or offensive content. To detect abuse, the AI model provider may keep prompts and outputs for a limited period, as described in Section 6. AI images appear in a comic only when the participating user chooses to add them, both the participating user and facilitators can remove any image from the browser session.
• Withdrawing consent, You can withdraw your consent at any time, you may inform the facilitator during the session, contact the event manager or us after the event with the details in Section 14. We will then remove your images and content from the session as per your request. Withdrawing consent does not apply to any technical processing that took place before the withdrawal.

Technical data such as IP address, browser type, technical logs, session timestamps, and a randomly generated device identifier is collected as part of normal platform operation and security. Where such data could identify an individual, we process it as necessary to operate and secure the platform, consistent with our obligations under this policy

6. AI processing and how it works

Comic Release uses AI models to transform uploaded images into AI generated images based on your input and prompts. Every AI request is routed through either one of the two parallel layers based on their technical performance at the time of request:

• Vercel AI Gateway, configured with Zero Data Retention (ZDR) enabled. Under ZDR, the Gateway only routes requests to underlying model providers that have a negotiated zero-retention agreement in place. Prompts, images, and outputs are not stored by the Gateway and are not used to train any model.
• OpenRouter, which classifies Google's Gemini models as Short Data Retention (SDR). Prompts, images, and outputs are not stored by OpenRouter and are not used to train any model, but Google may keep them for a limited period, solely to detect abuse, as described below.

In short: uploaded photos and inputted text are used only to produce the immediate output of your session, and are not used to train any AI model. Google, which provides the Gemini models, may keep prompts and outputs for a limited period, solely to detect abuse and violations of its usage policies. Google's current terms are set out in its Vertex AI abuse monitoring policy.

AI-generated text and images can be inaccurate, incomplete, or unexpected. Please review them before adding them to your comic.

7. How we protect your data

We use the following third-party providers to operate this platform used for Comic Release. Each processes data on our behalf under their own security and data protection commitments:

We do not sell participant data to any third party, and we do not permit these providers to use session data for their own marketing or training purposes. You may contact us through details provided in Section 14 to request more information on the third-party providers. Requested details will be shared with our verified clients only, provided these details do not compromise the security, source code, or any other sensitive details of our technical infrastructure.

8. Retention

Uploaded photos and AI-generated artwork are automatically deleted 90 days after the session, as part of our platform-wide image retention commitment.

Any additional data described in section 3 with the exception of technical logs collected alongside a session is retained for the same 90-day period unless a shorter period is requested by you, your third-party event organizing company, or your employer. Technical Logs are exempt from this retention period for the sole purpose of error logging and maintenance of the platform.

The record of your consent described in section 3, including the device identifier and name it contains, is not a technical log and is deleted after the same 90-day period.

Outputs that the organization which booked the session approves for Biz Group's marketing are kept for as long as they are used for that purpose, and are not subject to the 90-day deletion.

Deletion removes data from our live systems. Copies held in our providers' backups, and any prompts and outputs Google keeps to detect abuse (Section 6), are removed on those providers' own schedules.

9. International data transfers

Our infrastructure providers, including our hosting, database, network security, realtime content delivery, and AI routing providers, process data outside the UAE as part of their global infrastructure. Where this occurs, we rely on the contractual and technical safeguards those providers maintain, including their standard data protection agreements. Relevant details of each provider's data handling can be provided on request.

10. Your rights

Under the PDPL, you have the right to:

• Request access to personal data we hold about you
• Request correction of inaccurate data
• Request erasure of your data, including uploaded photos or generated artwork
• Object to or request restriction of processing
• Request data portability, where technically feasible given the session-based nature of this platform

To exercise any of these rights, contact us at teambuilding@bizgroup.ae

You also have the right to lodge a complaint with the UAE Data Office. Contacting us first does not affect that right.

11. Children's privacy

Comic Release is intended for use by adult participants in corporate and professional event settings. It is not directed at, or knowingly used by, individuals under 18. If you believe a minor has provided personal data (including an uploaded photo) through this platform, please contact us using the details in Section 14 so it can be removed.

12. Security

We apply reasonable technical and organizational measures to protect uploaded images and session data, including encryption in transit, encryption at rest for stored data, and access authentication on our backend and administrator systems.

13. Changes to this policy

We may update this policy from time to time to reflect changes in our platform or legal obligations. The effective date at the top of this document will be updated accordingly.

14. Contact us

Biz Group FZ-LLC | Email: teambuilding@bizgroup.ae