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Saleh Kayyali

Last Updated: June 2026 Effective Date: June 2026

Overview

Comma is a privacy-first EPUB and PDF reader for iOS. I believe your reading habits, notes, and personal data should remain private. This Privacy Policy explains how Comma handles your information.

The Short Version: Comma does not collect, sell, or share your personal data, and uses no analytics or tracking. Your books and reading data stay on your device — and, only if you turn on iCloud Sync, in your own private iCloud account. I have no servers and cannot see your data.

Data Collection

What I DON’T Collect

Comma does not collect, store on servers, or transmit:

  • ❌ Your name, email, or contact information
  • ❌ Your reading history or book titles
  • ❌ Your highlights, notes, or excerpts
  • ❌ Your device identifiers or advertising ID
  • ❌ Your location data
  • ❌ Analytics or usage statistics
  • ❌ Crash reports or diagnostics
  • ❌ Any personal information whatsoever

Our App Store privacy disclosure is “Data Not Collected.” I operate no servers that receive your data.

Your Reading Data

The following is created and controlled by you. It is stored locally on your device, and — if you enable iCloud Sync (see below) — also kept in your private iCloud account:

  • 📚 Your Library: imported EPUB and PDF files and generated covers
  • 📖 Reading Progress: your position in each book
  • ✏️ Highlights & Notes: text you highlight (with colors) and notes you add
  • 💬 Excerpts: memorable passages you save
  • ⚙️ Reading Preferences: theme, font, size, margins, and other settings
  • 🏷️ Categories: built-in and your own custom categories, and bookshelves

iCloud Sync (Comma Pro)

Comma offers optional iCloud Sync as part of Comma Pro. When enabled, your reading data syncs across your devices using Apple’s CloudKit in your private iCloud database.

  • Synced data (book files, covers, reading position, highlights, notes, excerpts, categories, bookshelves, reader settings) is stored in your personal iCloud account, governed by Apple’s iCloud terms and Privacy Policy — not on servers. I cannot read it.
  • iCloud Sync requires you to be signed in to iCloud with your own Apple ID. I never receive or store your Apple ID or credentials.
  • Comma uses a silent background notification from iCloud to keep devices up to date. This does not require notification permission and shows you nothing.
  • Turning it off: disabling iCloud Sync stops further syncing. To remove already-synced data, delete the items in the app (which removes them from your iCloud), or manage app data via Settings → [your name] → iCloud on your device.

This is different from iCloud Backup (below), which is Apple’s device-wide backup feature.

Apple Intelligence Features

On-Device AI Processing

Comma uses Apple Intelligence (Apple Foundation Models) for the following, on supported devices:

  • Automatic Book Categorization: suggests a category from book content
  • Chapter Summaries: generates summaries of chapters
  • Text Explanation: explains selected passages

Privacy Guarantees

✅ All AI processing happens on your device ✅ No book content is sent to me or to external servers for these features ✅ Apple Intelligence operates locally using on-device models

Device Requirements

Apple Intelligence features require a supported device with Apple Intelligence enabled. If your device doesn’t support it, Comma still works fully — you simply won’t see AI-powered features.

Data Storage

On Your Device

  • SQLite database (book metadata, reading positions, highlights, notes, excerpts, categories, preferences)
  • iOS file system (imported EPUB/PDF files, extracted/custom covers)
  • UserDefaults (app settings, default reading preferences, UI state)

In Your Private iCloud (only if iCloud Sync is on)

  • The same reading data, stored via CloudKit in your private iCloud database (see “iCloud Sync” above).

iCloud Backup

If you have iCloud Backup enabled on your device, Comma’s local data may be included in your device backup to your personal iCloud account. iCloud backups are controlled and encrypted by Apple; I have no access. You can exclude Comma from iCloud Backup in iOS Settings.

Third-Party Services

What I DON’T Use

  • ❌ Analytics services (Google Analytics, Firebase, etc.)
  • ❌ Advertising networks
  • ❌ Social media SDKs
  • ❌ Third-party cloud storage
  • ❌ Tracking or attribution services

Apple Services I Rely On

  • Apple iCloud / CloudKit — only if you enable iCloud Sync; stores data in your private iCloud (see above).
  • Apple App Store / StoreKit — processes in-app purchases (see “In-App Purchases”).

Optional, User-Initiated Actions

These involve external services only when you explicitly choose them:

  1. Book information lookup (“More Info”) — when you open a book’s More Info sheet, the app sends the book’s title and author (only) over HTTPS to Open Library (openlibrary.org) and, if needed, Google Books (googleapis.com) to retrieve a public description and publication details. No book content, reading activity, or identifiers are sent, nothing is stored by me, and each service processes the request under its own privacy policy.
  2. “Search the Web” (book info) — if no description is found, you can tap Search the Web, which opens your browser with a search for the book’s title and author. The search happens in your browser under the search engine’s privacy policy.
  3. Cover image search (manual cover update) — if you search for a book cover, your browser opens an image search for the book’s title under the search service’s own privacy policy. I don’t track or store your searches. Choosing a cover from your photo library involves no network use at all.
  4. Neural voice pack download — if you choose to download an on-device text-to-speech voice pack, the model files are fetched over HTTPS from Hugging Face (huggingface.co). This is a plain file download: no information about you or your books is sent, and all speech synthesis then runs entirely on your device.
  5. iOS Share Sheet — when you share a highlight or excerpt; handled entirely by iOS.
  6. App Store Review — when you tap “Rate Comma”; uses Apple’s native review API.

Permissions

Permissions Comma May Request

  1. File Access (Document Picker) — to import EPUB/PDF files you choose. I don’t browse your file system.
  2. Photo Library Access (optional) — only if you pick a custom book cover from your photos.

Network Use

Comma works fully offline for reading your own files. The network is used only for: iCloud Sync (if enabled) and the optional internet features listed above. I do not transmit data to any servers (I have none).

Permissions I DON’T Request

  • ❌ Camera · ❌ Microphone · ❌ Location · ❌ Contacts · ❌ Calendar · ❌ Bluetooth
  • ❌ Alert/badge notifications (iCloud Sync uses only invisible background notifications)
  • I do not use the Advertising Identifier or track you across apps/websites.

In-App Purchases

Comma offers Comma Pro, a purchase that unlocks premium features (including iCloud Sync and Offload). Purchases are processed by Apple through the App Store. I do not receive or store your payment information. Purchase validation and restoration are handled by Apple’s StoreKit.

Children’s Privacy

Comma does not knowingly collect personal information from anyone, including children under 13 (or the equivalent minimum age in your country). Because I do not collect personal data, none is gathered. Comma complies with COPPA.

Data Security

  • 🔒 Sandboxed storage isolated from other apps
  • 🔒 No developer servers — I never receive your data
  • 🔒 iOS device encryption protects local data (when your device is secured)
  • 🔒 iCloud security protects synced data in your private iCloud
  • 🔒 On-device AI — AI features run locally with Apple Intelligence

Your responsibility: enable a device passcode/Face ID/Touch ID, keep iOS updated, and secure your Apple ID.

Data Deletion

Since you control your data:

  1. Delete individual items — books, highlights, notes, or excerpts in the app (also removes them from your iCloud when Sync is on).
  2. Disable iCloud Sync to stop syncing.
  3. Delete the app to remove its local data from the device.

Your Privacy Rights

  • Access — view all your books, highlights, notes, and excerpts in the app.
  • Portability — books remain standard EPUB/PDF; highlights and excerpts can be exported as text via the iOS Share Sheet.
  • Control — you decide what to import, highlight, save, categorize, sync, and delete.

(For users in the EU/UK and California: because I collect and process no personal data myself, there is no developer-held data to access, port, or erase. Data in your iCloud is controlled by you under Apple’s policies.)

International Users

Comma is available worldwide. I collect no data. If you enable iCloud Sync, your data is stored and processed by Apple within iCloud, which may use servers in various countries; I do not control where Apple stores iCloud data.

Open Source & Transparency

Comma uses these open-source libraries, operating locally with no data collection:

  1. Readium Swift Toolkit (BSD-3-Clause) — EPUB/PDF rendering
  2. GRDB.swift (MIT) — local SQLite database

Changes to This Privacy Policy

I may update this policy to reflect new features or legal requirements. Material changes will be posted here with an updated “Last Updated” date (and noted in-app for significant changes). Continued use after changes take effect constitutes acceptance.

Contact

Questions about this Privacy Policy or Comma’s privacy practices:

Email: mskayyali@me.com Website: https://mskayyali.com I aim to respond within 7 business days.

Governing Law. This Privacy Policy is governed by applicable law. Nothing in it limits your statutory rights as a consumer in your country of residence. Severability. If any provision is unenforceable, the remaining provisions remain in full effect.

Summary — Comma’s Privacy Promise

✅ Zero data collection — I don’t collect anything ✅ Your data, your devices — stored on-device, and (optionally) in your private iCloud ✅ On-device AI — Apple Intelligence runs locally ✅ No tracking — no analytics, no ads, no surveillance ✅ No developer accounts or servers — I never see your data ✅ Complete control — you own your data, always

Your reading is your business. I never see it, never store it, never share it.