KUDO Legal

Privacy Policy

I. General provisions and definitions

KUDO Inc. (“KUDO”, “we” “our” or “us”) recognizes the importance of protecting the privacy of information we may receive from users of our website, mobile application, video conferencing and communication services, and other language-related professional services (the “Services”). For the purposes of this Privacy Policy, users include anyone who accesses the Services (“User”, “you” or “your”). This Privacy Policy addresses User’s personal data that we process to operate our website, to deliver the Services, for support, quality assurance and analytics, to support the development and enhancement of language and communication technologies, and for marketing purposes. This Privacy Policy, along with our Terms of Use, describes the information we collect from Users, how we may use it and with whom we may share that information, the safeguards we use to protect such information and the choices you may make with respect to your personal data.
This Privacy Policy explains KUDO’s practices when we process your “personal data,” which is information that relates to an identified or identifiable individual. “Process” or “processing” means any operation performed on personal data including, collecting, recording, organizing, storing, adapting, transferring, using, making available, analyzing, annotating, combining, disclosing, de-identifying, deleting, or otherwise handling this data.
KUDO respects the privacy of individuals and is committed to processing personal data in accordance with applicable law. KUDO implements appropriate technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, loss, misuse, and other unlawful processing.
This Privacy Policy applies to the personal data we process as a data controller (as defined in the EU’s General Data Protection Regulation “GDPR”, or equivalent concept under applicable data protection laws), that is, when KUDO determines the means and purposes for processing personal data.

KUDO acts as a controller in connection with certain activities, including operating our public website, managing relationships with current and prospective customer, users, contractors and vendors, administering accounts and contracts, providing and improving our Services where permitted, maintaining security, conducting sales, marketing, and business development activities, and carrying out related business operations. In addition, when permitted by our Customer and applicable law, KUDO may also process personal data generated in connection with the Services, for:(a) analyzing meeting-related content to evaluate and improve language interpretation and multilingual communication capabilities, where Customer has expressly authorized such processing in writing; and (b) generating aggregated, anonymized, de-identified, pseudonymized, or other derived datasets and materials for analytics, service development, product improvement, and other authorized purposes. Where KUDO carries out such processing, KUDO acts as controller for that processing and relies on the legal bases described in this Privacy Policy.

All requests relating to personal data processed by KUDO as controller should be directed to KUDO using the contact information provided below.

Except as set forth in the preceding section, when personal data is processed solely to provide KUDO’s video conferencing and language communication services on behalf of aCustomer, KUDO acts as a data processor and processes such personal data only on the Customer’s instructions. In those cases, the Customer is the data controller and is responsible for responding to privacy requests and exercising data subject rights. For purposes of this Privacy Policy, “Customer” means the individual or organization that purchases, subscribes to, administers, or otherwise controls access to the Services and on whose behalf KUDO provides the Services. If you have questions or requests regarding such personal data, please contact the relevant Customer directly. The Customer may involve KUDO as necessary to support the response.

II. Personal Data We Collect

The personal data we collect depends on your relationship with KUDO, the Services you use, the features you enable, and your interactions with us. Some information is provided directly by you, while other information is collected automatically through your use of the Services.

We collect personal data from a variety of sources, including when you create an account, register as an interpreter or contractor, organize or participate in meetings, request information, subscribe to communications, complete surveys, contact us, visit our website, or otherwise interact with the Services.

We collect information you provide directly to us, including:

Account and profile information, such as name, email address, telephone number, user ID, password, and profile image;
Communications and correspondence, including information contained in emails, forms, support requests, surveys, requests for information, webinar participation, in-person meetings, trade shows, business cards, sales and business development interactions, and other communications with KUDO;
Meeting and service content, including information created, submitted, uploaded, transmitted, spoken, displayed, or otherwise made available in connection with the Services. Depending on the Services used and applicable settings, this may include meeting-related content and communications, such as audio, video, recordings, transcripts, captions, chat messages, interpretation content, translated content, shared files, glossary terms, meeting metadata, participant information, meeting titles and descriptions, date and time, and other content generated during or relating to meetings;
Interpreter and contractor information, including information submitted to KUDO directly or through the KUDO Platform or Marketplace, such as work history, professional credentials, educational background, city and country, time zone, languages spoken, compensation preferences, and other information voluntarily provided.

When you access our website or use the Services, we may also automatically collect certain technical, operational, and usage information, including:

Device and connection information, such as IP address, browser type, device identifiers, hardware model, operating system, and network information;
Website and usage analytics, including pages visited, referral source, duration of visits, interactions with content, and search activity;
Service usage information, including configuration information, feature usage, meeting metadata, performance metrics, and service logs;
Operational and diagnostic information relating to the functioning, availability, security, and performance of the Services.

Cookies. KUDO also uses cookies and similar technologies to operate, secure, and improve the Services, remember preferences, analyze usage, and support communications and advertising activities where permitted. Cookies may include:

Strictly necessary cookies, which are required for operation of the Services;
Functional cookies, which support preferences and usability;
Analytics or performance cookies, which help us understand how users interact with the Services; and
Advertising or targeting cookies, where applicable.

Certain cookies may be placed by third-party providers acting on our behalf in accordance with their own privacy practices.

You can control cookies through your browser settings or other tools made available through the Services. Blocking certain cookies may affect functionality.

III. How We Use Your Personal Data

KUDO uses personal data for the purposes described below. Depending on the circumstances and applicable law, we rely on one or more legal bases, including performance of a contract, legitimate interests, consent, and compliance with legal obligations:

Provide and Operate the Services. We use personal data to provide, operate, administer, and support the Services, including creating and managing accounts; authenticating users; enabling Users to schedule, host, join, participate in, and administer meetings and events; transmitting audio, video, chat, files, captions, interpretation, transcripts, recordings, and other meeting-related content; creating or applying customized glossary terms; displaying participant information; facilitating interpretation and multilingual communication services; generating meeting outputs, summaries and reports; storing content where enabled; and delivering requested features, functionality, and technical support.
Personalize and Improve the User Experience. We use personal data to improve and personalize the Services and our website, including customizing content and interfaces, understanding how users interact with the Services, improving accessibility and multilingual communication capabilities, and developing and enhancing Service features.
Communications and Relationship Management. We use personal data to communicate with Users, Customers, interpreters, contractors, prospective customers, and business contacts, including responding to requests, providing support, managing relationships, sending service-related communications, and where permitted by applicable law, sending newsletters, product updates, marketing communications, and information about new features and offerings. Users may opt out of marketing communications at any time.
Customer and User Support. We use personal data to provide customer service and technical support, respond to questions and complaints, troubleshoot issues.
Service Analytics, Security, and Operations. We use operational, technical, and usage information to support delivery and optimization of the Services, monitor performance and availability, maintain security, administer business continuity and disaster recovery processes, detect and prevent fraud, abuse, unauthorized access, and other harmful activity, comply with contractual and legal obligations, and maintain the integrity of our systems.
Service Improvement and Product Development. Where permitted by applicable law and, where applicable, authorized by our Customers, KUDO may use personal data and Service-related information to evaluate, develop, improve, and protect the Services, including improving language interpretation and multilingual communication capabilities, conducting analytics, creating aggregated, anonymized, de-identified, pseudonymized, or other derived datasets and materials, and supporting product development, quality assurance, testing, evaluation, annotation, and the development and enhancement of language and communication technologies.
Legal and Compliance Purposes. We may process personal data to comply with legal obligations, protect our rights and interests, enforce agreements, respond to lawful requests, and establish, exercise, or defend legal claims.

Artificial Intelligence and Language Technologies. KUDO offers language and multilingual communication services, and related meeting productivity services, that may incorporate artificial intelligence, machine learning, automated speech recognition, machine translation, and other language technologies, together with human interpreters and human review processes where applicable.

By default, KUDO does not use personal data, Customer data or any meeting-related content, to train foundation models, large language models (LLMs), or other general-purpose artificial intelligence models. Customer data is processed solely in accordance with Customer’s instructions to deliver the requested Services. Any broader use of Customer data requires the Customer’s explicit written authorization under a separate agreement and is entirely optional.

KUDO does not use artificial intelligence or other automated systems to make decisions about individuals without human involvement where such decisions would have legal or similarly significant effects.

Where permitted by applicable law and expressly authorized by the Customer in writing, as well as interpreters where applicable, KUDO may create annotated datasets and related materials from designated meeting-related content and may use such datasets internally or disclose, license, or otherwise make them available to authorized third parties, including research organizations, data annotation providers, and developers of language technologies and artificial intelligence systems. Any such activity will be governed by a separate written agreement specifying the authorized content, purposes, recipients, and applicable safeguards.

We may process personal data for purposes compatible with those described in this Privacy Policy or as otherwise permitted or required by applicable law. Where required, we will provide additional notice and/or obtain consent before processing personal data for materially different purposes.

IV. How We Share Personal Data

KUDO shares personal data only as described in this Privacy Policy, at the direction of our Customers where applicable, or as otherwise permitted or required by law
We may share personal data in the following circumstances:

With Your Direction or Consent. We may share personal data with third parties where you direct us to do so, or where we have your consent or other authorization where required.
With Customers and Meeting Participants. When KUDO provides Services on behalf of a Customer, personal data and meeting-related content may be made available to the applicable Customer, meeting organizers, administrators, participants, interpreters, or other Users in accordance with the Customer’s configuration of the Services and applicable settings.
With Service Providers and Business Partners. We share personal data with vendors, contractors, hosting providers, cloud infrastructure providers, sub-processors, payment processors, customer support providers, analytics providers, communication providers, and other service providers that support operation, delivery, security, maintenance, and improvement of the Services and related business operations. Where personal data is shared with service providers acting on KUDO’s behalf, KUDO requires such providers to process personal data only for authorized purposes and to implement appropriate privacy and security protections. If we receive personal data from a business partner, referral partner, reseller, event partner, or similar third party and you become a User, we may share limited information with such partner as necessary to administer the applicable relationship, program, or agreement. Information regarding our categories of service providers, our list of sub-processors where applicable, along with our Data Processing Agreement is available upon request to privacy@kudo.ai.
For Corporate Transactions. We may disclose or transfer personal data to actual or prospective purchasers, investors, financing sources, successor entities, professional advisers, and other participants involved in an actual or contemplated merger, acquisition, financing, restructuring, reorganization, bankruptcy, sale of assets, change of control, or similar corporate transaction involving KUDO. Such disclosures may occur for purposes of evaluating, negotiating, completing, or implementing the transaction and may include sharing information during related due diligence activities, where permitted by applicable law.
With Research and Development Partners. Where permitted by applicable law and expressly authorized by the applicable Customer under a separate agreement and, where applicable, interpreters or other contributors, KUDO may share designated meeting-related content and derived translation materials with data annotation providers, research organizations, and developers of language technologies and artificial intelligence systems for purposes of dataset creation, evaluation, training, development, and improvement of language technologies.
With Legal, Security, and Compliance Authorities. We may disclose personal data to advisors, legal counsel, law enforcement, judicial authorities, and other third parties where we believe in good faith that such disclosure is necessary to: i) comply with applicable laws, regulations, legal processes, or lawful governmental requests; ii) enforce agreements and protect the rights, property, or safety of KUDO, our Customers, Users, interpreters, contractors, or others; iii) detect, investigate, prevent, or address fraud, abuse, security incidents, or technical issues; or iv) establish, exercise, or defend legal claims.
Aggregated and Analytical Data. KUDO may create, use, and share aggregated, anonymized, de-identified, pseudonymized, or other derived information and datasets for analytics, research, development, quality assurance, and other authorized purposes. Depending on the applicable authorization, contractual commitments, and intended use, such materials may be transformed, annotated, aggregated, de-identified, or retained in their original form to support language technologies and related services.

The Services are designed to facilitate communications and collaboration among Users, Customers, meeting organizers, participants, interpreters, and other authorized individuals. Information and meeting-related content shared through the Services may be visible to recipients and participants authorized by the applicable Customer or meeting organizer. Customers and meeting organizers may configure access settings and other controls available through the Services. Users should exercise care when deciding what information to share and with whom they choose to share it.
As it relates to SMS communications, KUDO does not share mobile phone numbers with third parties for marketing or promotional purposes. SMS consent and text messaging originator opt-in data will not be sold or shared with third parties.

V. Your Rights and Choices

Depending on your location and applicable data protection laws, you may have certain rights regarding your personal data. KUDO will process requests in accordance with applicable laws and may take reasonable steps to verify your identity before responding.
Subject to applicable law, you may have the right to:

Access your personal data and obtain information about how we process it;
Correct or update your personal data if it is inaccurate or incomplete;
Delete your personal data in certain circumstances, for example where it is no longer necessary for the purposes for which it was collected;
Restrict or object to processing of your personal data in certain situations, including where we process data based on legitimate interests;
Withdraw consent at any time where we rely on consent, without affecting the lawfulness of processing before withdrawal;
Data portability, meaning the right to receive certain personal data in a structured, commonly used, and machine-readable format and request its transfer to another provider;
Lodge a complaint with a supervisory authority or data protection regulator.

You may receive marketing communications from us where permitted by applicable law. You may opt out at any time by using the unsubscribe link in our emails or by contacting us at privacy@kudo.ai. We may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.
To exercise your rights, please email us at privacy@kudo.ai or as set forth below. Please include sufficient information to identify you and describe your request. Where you have an account, we may use your account credentials to verify your identity. If you do not have an account, we may request additional information to verify your identity.

We will respond to your request in accordance with applicable data protection laws. In some cases, we may be unable to fulfill a request where we are required or permitted to retain certain information, such as for legal compliance, security, fraud prevention, or to complete transactions. We may also decline or limit requests where permitted by law, for

VI. Retention

KUDO retains personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, including to provide and improve the Services, maintain our relationship with Users and Customers, comply with legal obligations, resolve disputes, enforce agreements, and protect KUDO’s rights and interests. Retention periods are determined based on the type of personal data involved, the purposes for which it is processed, applicable contractual commitments, Customer instructions where applicable, operational needs, and legal, regulatory, accounting, and security requirements.

Where KUDO processes personal data on behalf of a Customer, including in connection with meetings and communications conducted through the Services, KUDO generally retains such personal data in accordance with the Customer’s instructions, applicable agreements, and applicable law.

Where appropriate, KUDO may delete, anonymize, aggregate, or de-identify personal data once retention is no longer necessary for the purposes for which it was collected.

VII. Security

KUDO is committed to protecting your personal data. We use reasonable and appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access, taking into account the nature of the personal data, the purposes of processing, and the risks associated with such processing. These measures may include access controls, monitoring, security testing, encryption, business continuity processes, and policies designed to support secure handling of information.

While KUDO implements measures designed to protect personal data, no method of transmission, storage, or processing can be guaranteed to be completely secure. We encourage Users and Customers to use appropriate safeguards when using the Services and sharing information.

If you have any questions about the security of your data, please contact our security team at security@kudo.ai.

VIII. International Transfers

KUDO operates globally and may process personal data in countries other than the country in which the personal data was originally collected, including where KUDO, its affiliates, partners, Customers, service providers, and subprocessors operate or maintain facilities. As a result, personal data may be transferred to, accessed from, stored, or processed in jurisdictions that may have data protection laws different from those in your jurisdiction.
Where required by applicable law, KUDO implements appropriate safeguards designed to protect personal data transferred internationally. For individuals located in jurisdictions that restrict international transfers of personal data (including the European Economic Area, the United Kingdom, and Switzerland), KUDO will transfer personal data only where an appropriate transfer mechanism is available, including:

Transfers to jurisdictions recognized as providing an adequate level of protection under applicable law; or
Implementation of approved contractual safeguards, including where applicable the European Commission’s Standard Contractual Clauses or equivalent transfer mechanisms.

Additional information regarding international transfers and applicable safeguards may be requested using the contact information provided below.

IX. Changes to our Privacy Policy:

KUDO may update this Privacy Policy from time to time to reflect changes in our Services, business practices, legal requirements, or other operational needs. When we make changes, we will revise the “Last Updated” date of this Privacy Policy. We encourage Users and Customers to review this Privacy Policy periodically to stay informed about our privacy practices.

If we make material changes to this Privacy Policy or to how we process personal data, we will provide notice as appropriate under applicable law and the nature of the changes, including on our website, by email to the contact information associated with your account, or by other appropriate means.

X. How to Contact Us:

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or would like to contact KUDO regarding personal data practices, please contact:

KUDO Inc.

Privacy Team / Data Protection Officer privacy@kudo.ai

Telephone: +1 347 943 9056

224 West 35th Street, Suite 500 #781

New York, NY 10001

United States Contact details of EU/EC Representative:

RA Robert Niedermeier

CYBERLEGIS RA-GmbH

Tel.: +49 (0) 89 20 300 6422

niedermeier@cyberlegis.io

Maximilianstr. 13/III
80539 Munich, Germany

Last Updated: September 22, 2026

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