Comic Release Privacy Policy

1. Who we are

Registered as Biz Group FZ-LLC. 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 used exclusively within corporate events and facilitated sessions delivered in the UAE and wider Middle East region. It is not offered as a public consumer product.

3. What we collect

Comic Release activities are session based, using a session identifier rather than a persistent login account.

During a session, participants may:

• Upload photos or images to be used in generating personalized, comic-style artwork
• 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, and session timestamps) through our hosting and infrastructure providers, consistent with normal web operation.

4. How we use this data

We use the data described above to:

• Generate the AI-assisted comic-style artwork that is the core output of the session
• Maintain 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

5. Legal basis for processing

Uploading a photo to generate comic-style artwork by the teambuilding activity participant is a deliberate, voluntary act, and we treat this as consent to process that image for the purpose of generating the requested output. Where optional identifying details are provided, the same basis applies. Technical data such as IP address, browser type, and session timestamps is collected as part of normal platform operation and security. Where this data is not linked to an identifiable individual, it does not constitute personal data under the PDPL. 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 comic-style artwork. Every AI request is routed through two intermediary layers:

• 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, configured with ZDR enabled at the account level. This restricts routing to endpoints that do not retain prompt, image, or completion content after a request completes, and such endpoints cannot use that data for model training.

In short: uploaded photos and generated artwork are used only to produce the immediate output of your session. They are not retained by the underlying AI model providers once a request has been processed. Our own, separate storage of session content is described in Section 8.

7. How we protect your data

We use the following third-party providers to operate 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.

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 optional identifying data collected alongside a session is retained for the same 90-day period unless a shorter period is requested by the participant or their organizing company.

9. International data transfers

Our infrastructure providers, including our hosting, database, network security, and AI routing providers, may 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. 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

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 10 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 and access controls on our backend 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