PRIVACY POLICY

Last updated August 21, 2026

This privacy notice for Team Beluga Pte. Ltd. (doing business as Kondo) ("we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

  • Visit our website at https://app.trykondo.com, or any website of ours that links to this privacy notice

  • Use our Chrome browser extension ("Kondo Extension") available on the Chrome Web Store, or our desktop application

  • Connect the Kondo MCP server to a third-party AI assistant or other client of your choosing

  • Engage with us in other related ways, including any sales, marketing, or events

Kondo is a client for messaging accounts that belong to you. It connects to third-party messaging platforms that you choose to connect (each, a "Messaging Service"). References in this notice to a Messaging Service apply to whichever platforms you have connected.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at [email protected].

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice. You can find more detail on any of these topics in the section named after each key point.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. See the section on the information we collect.

Do we process any sensitive personal information? We do not ask you to provide sensitive personal information. We do not store the content of your messages on our servers — it is retrieved by your device and held in a local cache there. Some features send message content elsewhere, such as voice transcription and any integrations you enable, which are described below.

Do we collect information about people other than you? To show you your inbox, we process information about the people you correspond with, such as their names and profile details from the Messaging Services you connect. We do this on your behalf, only to provide the Services to you, and we do not sell that information or use it to train models. See the section on information we process about your contacts.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. See the section on how we process your information.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. See the section on when and with whom we share your personal information.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. See the section on how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. See the section on your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by emailing us at [email protected], or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • email addresses

  • the contents of support requests and other correspondence you send us

  • Sensitive Information. We do not ask you to provide sensitive information. Sensitive information may nonetheless be present in the messages you view through Kondo. We do not store message content on our servers — it is held in a local cache on your device — except where you use a feature that sends it elsewhere, such as voice message transcription or an integration you have configured. Both are described below.

  • Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is handled and stored by Stripe. We do not store full payment card numbers on our systems. You may find Stripe's privacy notice here: https://stripe.com/privacy.

  • Sign-In Data. You may sign in to Kondo using Google or Microsoft, or with a single-use code emailed to you. This is how you access your Kondo account, and is separate from connecting a Messaging Service, which is described below. Where you sign in through an identity provider, we receive limited profile information from that provider, as described in the section called "HOW DO WE HANDLE SIGN-INS TO YOUR KONDO ACCOUNT?" below.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information collected through the Kondo Chrome Extension

In Short: When you install and use the Kondo Chrome Extension, we access LinkedIn data using your existing LinkedIn session to provide our messaging client features. No data is collected until you sign in to Kondo and consent to data collection.

Kondo is an independent product. We are not affiliated with, endorsed by, sponsored by, or otherwise connected to LinkedIn, Meta, Apple, or any other operator of a Messaging Service. The names and marks of those services belong to their respective owners and are used only to identify the platforms Kondo works with.

This notice describes what we do with your information. It does not describe what a Messaging Service does with your information. Your use of each Messaging Service continues to be governed by that platform's own terms and privacy policy, and we have no control over — and accept no responsibility for — how a Messaging Service collects or uses your data, or what it decides to do with your account on its platform. Connecting a third-party account to any external client carries risk, including the risk that the platform restricts or terminates your account. Please read our Terms of Service before connecting a Messaging Service to Kondo.

The Kondo Extension is a LinkedIn messaging client that enhances your LinkedIn inbox experience. To provide this service, the extension accesses the following data from your LinkedIn account using your existing LinkedIn session credentials:

LinkedIn Messaging Data. We access your LinkedIn conversations, messages, and message metadata (such as timestamps, read status, and conversation participants) to display and manage your LinkedIn inbox within the Kondo interface.

LinkedIn Profile Data. We access publicly available LinkedIn profile information of your contacts and conversation participants, including names, profile pictures, headlines, locations, and connection status, to display contact information within the Kondo interface.

LinkedIn Connection Data. We access your LinkedIn connections list, including names, profile identifiers, and connection dates, to enable search and contact management features.

Where you connect another Messaging Service through a different Kondo App, we access the equivalent data from that service — your conversations and message metadata, the profile information of your contacts and conversation participants, and your contact list — for the same purposes. Not every feature described in this notice is available in every Kondo App, and some features operate only in certain clients.

Voice message transcription. Kondo transcribes voice messages so that they can be read and searched. This feature is enabled by default and can be turned off at any time in your settings. While it is enabled, the audio of each voice message you receive is sent from your device to Cloudflare Workers AI as it arrives, so that transcripts are ready when you open the conversation. It is transcribed using an open-source speech-to-text model that Cloudflare hosts on its own infrastructure. Under Cloudflare's published terms for Workers AI, Cloudflare does not make that audio available to its other customers and does not use it, or the resulting text, to train any model or to improve its services. The transcript is returned to your device and cached there; neither the audio nor the transcript is stored in our database. Transcription converts speech into text and does not create a voiceprint or otherwise identify the speaker. If you turn the feature off, no further audio is sent, although transcripts already cached on your device remain until you clear them.

How Kondo connects. Kondo connects to Messaging Services in one of two ways, described below. In both cases Kondo operates from the device you are using: Kondo must be open and running on your device for messages to be retrieved, and we do not maintain a connection to a Messaging Service on your behalf while it is closed. You can disconnect a Messaging Service at any time.

Session-based connections. Some Messaging Services are connected using credentials that already exist in your browser, through the Kondo browser extension. LinkedIn is connected in this way: the extension reads your LinkedIn authentication cookies (such as "li_at" and "JSESSIONID") to authenticate API requests to LinkedIn on your behalf. These cookies are never transmitted to our servers. You can end the connection by signing out of that Messaging Service or removing Kondo from your device.

Linked-device connections. Other Messaging Services, such as WhatsApp, are connected through the Kondo desktop application by scanning a QR code, which registers Kondo as an additional device on your account in the same manner as that platform's own web or desktop client. Because these platforms encrypt messages between devices, a linked device necessarily holds the keys required to take part in your conversations, and Kondo decrypts message content in order to display it to you. Those keys and credentials are held on your device and are not transmitted to or stored on our servers, and decrypted message content is held only in the local cache on your device, except where you use a feature that sends content elsewhere, such as voice transcription, the drafts and notes you author, and any integrations you enable. Those features are described below. You can revoke the connection at any time from the linked-devices screen of that Messaging Service, which takes effect immediately.

The extension requires the following Chrome permissions to function:

  • "cookies" — to read your LinkedIn session cookies for authentication

  • "storage" — to save your extension preferences (such as auto-open and notification settings)

  • "declarativeNetRequestWithHostAccess" — to modify request headers for LinkedIn API compatibility

  • "notifications" — to optionally alert you of new LinkedIn messages

  • Host access to "linkedin.com" — to communicate with LinkedIn’s API on your behalf

Information we process about your contacts

In Short: To run your inbox, we necessarily process information about the people you are corresponding with on the Messaging Services you connect. Those people are usually not Kondo users.

In respect of that contact information, you act as the controller of the data and we act as your processor: we process it on your instructions, for the purpose of providing the Services to you. We do not sell that information or use it to train machine learning models. Some contact information also appears in the diagnostic and analytics records described above, which we use to operate, debug, and improve the Services. You are responsible for ensuring that you have a lawful basis for using Kondo to process information about your contacts, and for responding to requests those individuals make to you about their information.

If you are an individual whose information appears in a Kondo user's account and you wish to exercise your rights, please contact the Kondo user directly where possible. You may also contact us at [email protected] and we will assist that user in responding to your request, or respond directly where we are required to do so by applicable law.

Data synced to our servers

We store the following on our servers, which are hosted on Supabase, in order to enable cross-device access and features such as labels, reminders, and team collaboration.

Conversation metadata from the Messaging Services you connect, such as conversation identifiers, participants, timestamps, and read state. Contact records for the people you correspond with, such as profile identifiers, names, and connection dates. The organizational data you create in Kondo, such as labels, reminders, and archive status. Content you author in Kondo, such as drafts, notes, and snippets. Your preferences and settings, and, where you use Kondo as part of a team, shared workspace data.

A copy of this data is also held in our data warehouse and reporting infrastructure for internal reporting and analysis, as described in the section on when and with whom we share your personal information.

The messages themselves are not stored on our servers. Message content is retrieved from the Messaging Service by your device and held only in a local cache on that device.

All data is transmitted to our servers over encrypted HTTPS/TLS connections.

Data stored locally. To improve performance and to allow you to read your conversations, Kondo caches data on the device you are using — in your browser’s local storage (via IndexedDB and chrome.storage) when you use the extension, and in local application storage when you use the desktop application. This cache includes message content and conversation data, contact and participant data, voice message transcriptions, and your preferences. It is removed when you uninstall the extension or application, and you can clear it at any time from your browser or application settings.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

We use PostHog, a product analytics service, to collect usage data such as feature interactions, page views, and error reports. Some of these records include details of the action being recorded, which can include search terms you enter, the names of contacts returned by a search, identifiers for conversations and messages, the addresses of requests made to a Messaging Service, and the text of any feedback you submit. This data is used solely to improve and debug our Services and is not shared with third parties for advertising purposes. You can learn more about PostHog’s privacy practices at https://posthog.com/privacy.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service, including accessing and displaying your messages and contacts through the Kondo interface.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

To improve our Services. We may process usage analytics (via PostHog) to understand how users interact with our features, identify issues, and improve the user experience.

To operate integrations you choose to enable. Where you connect Kondo to a third-party client or application, or configure a webhook, we process your information in order to fulfil the requests made through those integrations at your direction.

To transcribe voice messages. Where voice transcription is enabled, we process the audio of voice messages in order to generate a text transcript for you.

To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. See the section on your privacy rights.

Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

  • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

  • For investigations and fraud detection and prevention

  • For business transactions provided certain conditions are met

  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim

  • For identifying injured, ill, or deceased persons and communicating with next of kin

  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse

  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced

  • If the collection is solely for journalistic, artistic, or literary purposes

  • If the information is publicly available and is specified by the regulations

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

We may need to share your personal information in the following situations:

Service Providers. We use the following third-party service providers to operate our Services:

  • Supabase — cloud database hosting for storing account data, conversation metadata, contacts, labels, and user preferences. Supabase's privacy policy: https://supabase.com/privacy.

  • PostHog — product analytics and session recording for understanding feature usage and improving our Services. Session recordings capture how you interact with the Kondo interface, and analytics events may include the details described above. PostHog's privacy policy: https://posthog.com/privacy.

  • Stripe — payment processing. Stripe's privacy policy: https://stripe.com/privacy.

  • Cloudflare — infrastructure and content delivery, the relay infrastructure used by the Kondo MCP server, and AI inference for voice message transcription. Cloudflare's privacy policy: https://www.cloudflare.com/privacypolicy/.

  • Customer.io — email communications, such as onboarding and account-related emails. Customer.io receives your name, email address, and product usage events, but no conversation or contact data. Customer.io's privacy policy: https://customer.io/legal/privacy-policy.

  • Resend — transactional email delivery, used to send the single-use codes you request when signing in and other account emails. Resend receives your email address and the contents of those messages. Resend’s privacy policy: https://resend.com/legal/privacy-policy.

  • Membrane — integration infrastructure, used to operate connections between Kondo and third-party business applications where you choose to enable such an integration. Membrane processes data only for users who have enabled an integration, and its servers are located in the European Union. Membrane's privacy policy: https://getmembrane.com/privacy-policy.

  • Snowflake — data warehouse. Holds a replica of our production database, together with product analytics and billing data, used for internal reporting and analysis. Snowflake’s privacy policy: https://www.snowflake.com/en/legal/privacy-notice/.

  • Fivetran — data pipeline service, used to transfer billing and related records into our data warehouse. Fivetran’s privacy policy: https://www.fivetran.com/legal/privacy-policy.

  • dbt Labs — data transformation tooling, used to run scheduled queries against our data warehouse. dbt Labs’ privacy policy: https://www.getdbt.com/cloud/privacy-policy.

  • DigitalOcean — hosts our internal reporting tools and the process that replicates our database into the warehouse. DigitalOcean’s privacy policy: https://www.digitalocean.com/legal/privacy-policy.

  • Conceptual — product analytics, used to understand how the Services are used. Conceptual receives your account information, including your email address, and product usage events. Conceptual’s privacy policy: https://conceptualhq.com/privacy.

Services that operate within Kondo. Some features rely on third parties in order to work. Where you search for a GIF to send in a conversation, your search text is sent to KLIPY or GIPHY in order to return results. Where you arrive at Kondo through a referral link, Dub records that attribution so we can credit the referral. These providers receive only what the feature requires, and we do not send them your conversations or your contacts.

User-configured integrations. Kondo offers integrations that transmit your data to destinations you choose. We act at your direction when you enable them, and you are responsible for the privacy practices of the receiving service.

  • Webhooks. If you configure webhooks within Kondo, conversation and contact data you select will be sent to the third-party endpoint URLs you specify, which can include the text of your messages.

  • Notion. If you connect Notion, we store your Notion authorization on our servers and use it to write the conversation and contact data you select, which can include the text of your messages, into the specific Notion database or page you have granted access to. We can write only to the locations you authorize, and you can revoke that access at any time from your Notion settings.

  • Kondo MCP server. Kondo makes available a Model Context Protocol (MCP) server that you may connect to an AI assistant or other client of your choosing. If and only if you enable this integration, the client you have connected can request your Kondo data — which may include conversation content, contact information, and notes — and that data will be transmitted to the provider operating that client. Requests and responses pass through relay infrastructure that we operate on Cloudflare on their way between that client and your device. That data is handled in memory while in transit and is not stored on the relay, and your Kondo client must be open for the integration to return anything. We record usage information about relay requests, such as the account making a request and the time it was made. We do not log the content of requests or responses. Kondo does not select that provider, does not control what it does with the data, and does not send your data to any AI provider unless you have enabled this integration. You should review the privacy terms of the client you connect. You can disconnect the integration at any time in your Kondo settings.

  • Business application integrations. If you choose to connect Kondo to HubSpot, Salesforce, Attio, or Clarify, the contact and conversation data you select will be sent to that application. These connections are operated on our behalf by Membrane, an integration provider, so data for these integrations passes through Membrane on its way to the application you have chosen; Membrane retains it briefly for logging and debugging purposes before deleting it automatically. Webhooks you configure yourself do not pass through Membrane and are sent directly to the endpoint you specify. In each case the receiving application is yours, and its handling of your data is governed by your agreement with that provider rather than by this notice.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

5. HOW DO WE HANDLE SIGN-INS TO YOUR KONDO ACCOUNT?

In Short: If you choose to register or log in to our Services using a third-party identity provider, we may have access to certain information about you.

Our Services offer you the ability to register and log in using Google or Microsoft. You may also sign in with a single-use code that we email to you. Where you sign in through an identity provider, we receive limited profile information from that provider, which will typically include your name, email address, and profile picture. We request only the minimum scope necessary to authenticate you; we do not request access to your mailbox, calendar, files, or contacts held by that provider.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your identity provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us

You can request deletion of your personal information at any time by emailing us at [email protected]. On request, we delete your personal information from our servers, including conversation metadata, contact data, labels, snippets, and preferences.

Data cached locally on your device is removed when you uninstall the Kondo extension or application, and you can clear it at any time from your browser or application settings.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. All data transmitted between your browser and our servers is encrypted using HTTPS/TLS. Data stored on our servers (hosted on Supabase) is encrypted at rest.

Breach notification. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required by applicable law, affected individuals, without undue delay and within the timeframes set by applicable law.

However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below or updating your preferences.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by Reply with unsubscribe to our emails, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Contact us using the contact information provided.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

If you have questions or comments about your privacy rights, you may email us at [email protected].

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Montana, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

A. Identifiers — YES

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

B. Personal information as defined in the California Customer Records statute — YES

Name, contact information, education, employment, employment history, and financial information (we hold names, email addresses, and billing information for account holders, and employer and job title information that appears in the profiles of your contacts)

C. Protected classification characteristics under state or federal law — NO

Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data

D. Commercial information — YES

Transaction information, purchase history, financial details, and payment information (we hold subscription and transaction records; full payment card details are held by Stripe and not by us)

E. Biometric information — NO

Fingerprints and voiceprints

F. Internet or other similar network activity — YES

Interactions with our Services, such as feature usage, page views, searches you run within Kondo, and actions taken within the Kondo application. We do not collect general browsing history or your interactions with other websites or applications.

G. Geolocation data — YES

Approximate location, at city level, derived from your IP address as part of our product analytics. We do not collect precise geolocation or device GPS data.

H. Audio, electronic, sensory, or similar information — YES

Images and audio, video or call recordings created in connection with our business activities (conversations you view in Kondo may contain images and voice messages, and transcriptions of voice messages may be cached)

I. Professional or employment-related information — YES

Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us (profile headlines and connection information processed on your behalf may include job titles and employers)

J. Education Information — NO

Student records and directory information

K. Inferences drawn from collected personal information — NO

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics

L. Sensitive personal Information — NO

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;

  • Participation in customer surveys or contests; and

  • Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

  • Category A - As long as the user has an account with us

  • Category B - As long as the user has an account with us, and thereafter as required for tax and accounting purposes

  • Category D - As long as required for tax and accounting purposes

  • Category F - As long as the user has an account with us

  • Category G - As long as the user has an account with us

  • Category H — Audio is not retained by us; transcripts are held in the local cache on your device until you clear it

  • Category I — Processed to provide the Services; not retained in our database

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

  • Right to know whether or not we are processing your personal data

  • Right to access your personal data

  • Right to correct inaccuracies in your personal data

  • Right to request the deletion of your personal data

  • Right to obtain a copy of the personal data you previously shared with us

  • Right to non-discrimination for exercising your rights

  • Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

  • Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California's and Delaware's privacy law)

  • Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Oregon's privacy law)

  • Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California's privacy law)

  • Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida's privacy law)

How to Exercise Your Rights

To exercise these rights, you can contact us by emailing us at [email protected].

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at [email protected]. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general

California "Shine The Light" Law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

12. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country you reside in.

Australia

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 (Privacy Act).

This privacy notice satisfies the notice requirements defined in the Privacy Act, in particular: what personal information we collect from you, from which sources, for which purposes, and other recipients of your personal information.

If you do not wish to provide the personal information necessary to fulfill their applicable purpose, it may affect our ability to provide our services, in particular:

  • offer you the products or services that you want

  • respond to or help with your requests

  • manage your account with us

  • confirm your identity and protect your account

At any time, you have the right to request access to or correction of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?"

If you believe we are unlawfully processing your personal information, you have the right to submit a complaint about a breach of the Australian Privacy Principles to the Office of the Australian Information Commissioner.

13. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this privacy notice. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at [email protected], or contact us by post at:

Team Beluga Pte. Ltd.

Data Protection Officer

160 Robinson Rd, #14-04, Singapore 068914

Singapore 068914

Singapore

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please email us at [email protected].