Privacy Policy
Last updated: November 3, 2026
This Privacy Policy explains how LewdPanels ("we", "us") collects and uses personal data when you visit lewdpanels.com (the "Site"), join our early access list, or contact us. LewdPanels is an 18+ marketplace for adult comics that is currently in pre-launch.
1. Who is responsible for your data
The data controller is Lewd Panels SRL, Romania. You can reach us about privacy at hello@lewdpanels.com.
2. Adults only
The Site is intended only for people aged 18 or older (or the age of majority where they live). We do not knowingly collect data from minors. If you believe a minor has given us personal data, contact us and we will delete it.
3. What data we collect and why
| Data | Purpose | Legal basis (GDPR) |
|---|---|---|
| Email address and whether you are a reader or a creator, when you join the early access list, together with the IP address and browser you signed up from and the dates of signup and confirmation, kept as the record of your consent | To tell you when LewdPanels launches and, for creators, to discuss founding-creator terms | Consent (Art. 6(1)(a)), which you can withdraw at any time |
| Account data: email address, username, your password (stored only as a salted hash) or passkeys, one-time sign-in links we email you, the dates you confirmed you are 18 or older and accepted the Terms, sign-in records, and session data (approximate country derived from your IP address, a short browser and device description, dates) | To create and secure your account and let you sign in | Contract (Art. 6(1)(b)); security: legitimate interest (Art. 6(1)(f)) |
| Reading data: which episodes you opened and how far you read, your library (reading list and favourites), the ratings and reviews you post, reports you make about reviews, the content warnings you chose to hide, and requests to be told when paid episodes open | To save your place, show "continue reading", run community features and count views | Contract (Art. 6(1)(b)) for account features; for guests, legitimate interest (Art. 6(1)(f)) in saving your progress on this device |
| Age confirmation record (when you confirmed you are 18 or older, and the country and region it was made from) | To show adult content only to adults and meet legal obligations | Legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)) |
| Email address you leave on the "not available in your region" page, with the country and region we derived from your IP address at that moment (not the IP address itself) | To email you once when LewdPanels becomes available in your region, and to count how many people are waiting in each region | Consent (Art. 6(1)(a)), which you can withdraw at any time by writing to us |
| Reports and complaints you send through the Site (your email address, the page concerned and your description) | To review and act on them | Legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)) |
| First-party statistics (pages and paywalls viewed, shares, searches, the ad campaign (UTM parameters) you arrived from), with your approximate country | To understand which content and campaigns work | Consent (Art. 6(1)(a)); collected only if you click "Accept" |
| Product statistics about how signed-in accounts use features (signing up and signing in, verifying your email, adding a passkey, adding a series to your library or favourites, rating a series, asking to be told when paid episodes open), linked to your account, with your approximate country | To improve the service and detect abuse | Legitimate interest (Art. 6(1)(f)) |
| Purchases: the coin packs you buy (amount, currency, date, the payment provider's reference; never your card details), your coin balance and its movements, the episodes you unlock, your pre-orders and refunds | To sell coins and episodes, keep your purchases and handle refunds and chargebacks | Contract (Art. 6(1)(b)); keeping accounting records: legal obligation (Art. 6(1)(c)) |
| E-mail preferences: whether you want reading reminders and picks (and when and where you said so), the series you follow for new-episode e-mails, the e-mails we sent you and the links you opened in them, unsubscribes | To send only the e-mails you asked for and to prove your choice | Consent (Art. 6(1)(a)), withdrawn with one click in any e-mail or in your account |
| Signup bonus check: a coded form of the lp_device browser identifier and of the network you signed up from, and whether your e-mail address belongs to a throw-away e-mail service | To give the free signup coins once per person and stop them being farmed | Legitimate interest (Art. 6(1)(f)) in preventing abuse |
| AI character chat (only if you use it): the messages you exchange with a character, stored encrypted, how many messages you used, and the safety labels our moderation gave to messages (kept after you delete the chat or your account, without the message text) | To run the chat, keep it within the comic's world and our rules, and bill message packs | Contract (Art. 6(1)(b)); safety labels: legal obligation (Art. 6(1)(c)) and legitimate interest (Art. 6(1)(f)) |
| Anything you send us by email | To answer your request | Legitimate interest (Art. 6(1)(f)) or steps before a contract (Art. 6(1)(b)) |
| Usage and device data collected by analytics (pages viewed, clicks, scrolling, approximate location from IP, browser and device type, referrer) | To understand how the Site is used and improve it | Consent (Art. 6(1)(a)); collected only if you click "Accept" |
| Technical server logs (IP address, time, requested URL) | Security, preventing abuse, keeping the Site running | Legitimate interest (Art. 6(1)(f)) |
We do not sell your personal data, and we do not use it for targeted advertising.
4. Analytics and cookies
When you first visit, we ask whether you accept analytics. Our analytics are Matomo, Microsoft Clarity, Google Analytics and our own first-party statistics; all of them run only after you click "Accept". If you click "Reject" or ignore the banner, no analytics scripts are loaded, no analytics cookies are set (those already set are deleted) and no first-party statistics are sent. The only counts we make without your choice are anonymous: how many visits arrive from each ad campaign or site per day, and how many visitors accept or reject the banner. They carry no cookie and no identifier and cannot be linked to you. You can change your choice at any time via Cookie settings, also linked in the footer of every page.
If you accept, we use:
- Matomo, a web analytics tool that we run on our own server (analytics.gazolin-production.com). Data collected by Matomo is not shared with third parties.
- Microsoft Clarity, provided by Microsoft Corporation, which records how visitors interact with pages (clicks, scrolling, mouse movement) as heatmaps and session replays. Clarity masks text you type in form fields. Microsoft processes this data as described in the Microsoft Privacy Statement.
- Google Analytics, provided by Google Ireland Limited, which counts page views and how visitors move through the site: searches, reading (which episode, how far, for how long), sign-ups and sign-ins, coin purchases and episode unlocks, and errors a visitor runs into. We send it the page address without one-time sign-in or confirmation codes, and never your email address or what you type into a form; a search is sent shortened to 50 characters, and not at all when it contains an email address, a link or six or more digits (such as a phone number). Google processes this data as described in the Google Privacy Policy.
| Name | Provider | Purpose | Duration |
|---|---|---|---|
| _pk_id.* | Matomo | Recognises returning visitors | 13 months |
| _pk_ses.* | Matomo | Groups page views into a visit | 30 minutes |
| _pk_ref.* | Matomo | Remembers which site referred you | 6 months |
| _clck | Microsoft Clarity | Keeps the same Clarity user ID across visits | 1 year |
| _clsk | Microsoft Clarity | Groups page views into one session recording | 1 day |
| CLID, MUID, ANONCHK, SM, MR | Microsoft Clarity / Microsoft | Identify the browser across Clarity sessions and sites that use Clarity | Session up to 1 year |
| _ga, _ga_<id> | Google Analytics | Distinguish visitors and keep the session state | 2 years |
First-party statistics (only if you accept): we record which pages and paywalls you view, what you share and select in search, and the ad campaign (UTM parameters) you arrived from. These events are linked to the lp_anon guest identifier below (or to your account when you are signed in); if you accepted, the account you create is linked to the campaign you arrived from. We also store:
- lp_attr (cookie, 13 months): a random identifier that remembers the ad campaign or site you first arrived from, so that a later sign-up is credited to it. Set only after you click "Accept"; deleted when you withdraw your consent.
- lp_utm_sent (session storage): prevents counting the same ad landing twice; it ends with the browser tab session.
Strictly necessary: the following cookies and browser storage are needed for the Site to work and are always on:
| Name | Type | Purpose | Duration |
|---|---|---|---|
| lp_session | Cookie (HttpOnly) | Keeps you signed in | Up to 180 days |
| lp_adult | Cookie | Remembers that you confirmed you are 18 or older | 1 year |
| lp_anon | Cookie (HttpOnly) | A random guest identifier that saves your reading progress on this device | 1 year |
| lp_device | Cookie (HttpOnly) | Set when you create an account; stops the sign-up bonus from being claimed again in the same browser (we keep only a coded form of it, deleted after 180 days) | 1 year |
| lp_hide | Cookie | The content warnings you chose to hide (guests) | 1 year |
| lp_consent | Local storage | Your cookie choice | Until you clear it |
| lp_reader_mode | Local storage | Your reader display mode (scroll or paged) | Until you clear it |
| lp_recent_searches | Local storage | Your recent searches; stays on your device and is never sent to us | Until you clear it |
| lp-payment | Session storage | Tracks a checkout in progress | Until the checkout ends or the tab is closed |
5. Who we share data with
We share personal data only with service providers that help us run the Site, under contracts that require them to protect it:
- our hosting providers: Hetzner Online GmbH (EU data centres), which runs the Site, its server logs and the mail server that sends our emails, and Hosting Ukraine LTD, which hosts the server that stores the early access list (see Section 6). We run this infrastructure ourselves; the list is not shared with any third-party email platform;
- Microsoft, for Clarity analytics (only if you accept analytics cookies);
- Google, for Google Analytics (only if you accept analytics cookies);
- our payment provider, which processes your payment for coin packs (it receives the amount and the payment details you enter on its page; we never see your card details). Crypto payments are processed by NOWPayments: it receives the amount, our order reference and your transfer; transfers on a blockchain are public by nature, and we never see your wallet's keys;
- Anthropic PBC, which provides the AI model behind the character chat and receives the chat messages needed to write a reply (only if you use the chat). It does not use them to train its models.
We may also disclose data if required by law or to protect our rights, users or the public.
6. International transfers
Some providers, including Microsoft, may process data outside the European Economic Area or the UK, including in the United States. Where this happens, we rely on appropriate safeguards such as the EU–US Data Privacy Framework or the European Commission's Standard Contractual Clauses.
The early access list is stored on a server we operate in Kyiv, Ukraine, which is outside the EEA and is not covered by a European Commission adequacy decision. The data held there is limited to your email address, whether you are a reader or a creator, the IP address and browser you signed up from, the signup page, and the dates of signup and confirmation. It is processed only by us and, as hosting provider, by Hosting Ukraine LTD (Kyiv, Ukraine). You can ask us for a copy of the safeguards we apply.
7. How long we keep data
- Early access list: until LewdPanels launches and we have sent the launch email, or until you unsubscribe or ask us to delete it, whichever is earlier, and in any case no longer than 24 months.
- "Notify me" list for unavailable regions: until we have sent the one email that LewdPanels is available in your region, or until you ask us to delete it, whichever is earlier, and in any case no longer than 24 months.
- Analytics data: up to 13 months in Matomo; Clarity data is kept according to Microsoft's retention periods; Google Analytics data for 14 months.
- Emails you send us: as long as needed to handle your request.
- Server logs: up to 30 days, unless needed to investigate abuse.
8. Your rights
Depending on where you live, including under the GDPR, the UK GDPR and US state laws such as the California Consumer Privacy Act (CCPA/CPRA), you have the right to:
- access the personal data we hold about you and get a copy of it;
- correct inaccurate data;
- have your data deleted;
- restrict or object to certain processing;
- receive your data in a portable format;
- withdraw consent at any time, without affecting processing before the withdrawal;
- not be discriminated against for exercising your rights.
To exercise any of these rights, email hello@lewdpanels.com. We will reply within 30 days. You also have the right to complain to your local data protection authority.
9. Security
We use reasonable technical and organisational measures to protect personal data, including encrypted connections (HTTPS) and limited access to data. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
10. Changes to this policy
We may update this Privacy Policy, for example when LewdPanels launches accounts and payments. We will change the "Last updated" date above and, for significant changes, tell people on the early access list by email.
11. Contact
Lewd Panels SRL, Romania. Email: hello@lewdpanels.com.