KUDO LEGAL

Privacy Policy

I. General provisions and definitions

1. 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 and video conferencing and communication services (the “Services”). For the purposes of this Privacy Policy, users include anyone who accesses the Services (“User”, “you” or “your”). This Privacy Policy, along with our Terms of Service, 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. Defined terms not otherwise defined herein shall have the same meaning as in our Terms of Service.

2. This Privacy Policy explains KUDO’s practices when we process your “personal data,” which is information that relates to an identified or identifiable individual. To “process” or “processing” means any use of personal data including, transferring, collecting, recording, storing, using, analyzing, combining, disclosing or deleting it.

3. KUDO acknowledges the privacy of natural persons and makes efforts to protect them against any unlawful processing of their personal data. KUDO applies the relevant technical and organizational measures to protect the personal data of natural persons in accordance with the effective legislation.

4. 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”)), that is, as the party that determines what data to collect and why. You provide some of this data directly, and we get some of it by collecting data about your interactions, use, and experiences with the Services. The data we collect depends on the context of your interactions with KUDO and the choices you make, including the products and features you use.

5. When you provide your personal data to KUDO through KUDO’s website (www.Kudoway.com), KUDO is considered a data controller of that information. All requests with respect to such information should be directed to KUDO using the contact information provided below. When, however, you provide your personal data in connection with using our video conferencing and communication services (for example, when you provide personal data in the course of a meeting hosted on KUDO’s Core Platform), KUDO is not the controller of that data. Rather, KUDO is acting solely in its capacity as a data processor, as that term is defined under the GDPR. The controller of that personal data is the KUDO account holder through whose account the video conferencing and communication services are being provided. If you provided your personal data in connection with KUDO’s video conferencing and communications services and you are not a KUDO account holder, you must direct all your questions and privacy requests to that account holder, and not to KUDO. That account holder will then contact KUDO if necessary.

II. What Personal Data We Collect

6. We will only process your personal data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below. In some cases, we process personal data based on the consent you expressly grant to us at the time we collect such personal data. From time to time, we may also need to process personal data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other Users, or if it is necessary for a task carried out in the public interest.

7. KUDO collects personal data from user registrations, requests for information, surveys, mailing lists subscriptions, contact forms, emails and other means of communications.

8. When you register for a KUDO account, we collect information such as your name, email, phone, User IDs, password, and profile picture. KUDO may collect any information contained in any correspondence between us. For example, if you contact us using a form on our site or by email, telephone, or otherwise, we may keep a record of that correspondence. When an interpreter registers on the KUDO Core Platform or KUDO Marketplace, we also collect the information that the interpreter decides to provide when registering, such as their work history, degrees and educational history, city and country where the interpreter is located, time zone, date of birth, gender, languages spoken, and hourly rates or other methods of compensation.

9. KUDO may also collect certain technical and usage information when you visit our website (www.kudoway.com) about which pages you visit, how long you visit certain pages, and how you arrived at our website among other things. This might include your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), browser type, referral source, length of visit to the website, number of page views, the search queries you make on the website, and similar information.

10. Cookies: The Services may deploy cookies. A cookie is a unique text file that a website sends to your browser software. Cookies may collect personal data to enable a website to tailor information presented to you based on your browsing preferences. We deploy cookies on our Services, and some cookies may be placed by our third-party service providers on your computer or device and provide information about your browsing habits (such as your visits to our website and the pages you have visited). To learn more about our cookies’ practices, please visit our Cookies Policy.

11. Meeting Content: Meeting Content is the “in-session” information you give us directly through your use of the Services, such as meeting recordings (i.e., video and audio), files, your votes, chat logs and transcripts, and any other information uploaded while using the Services. Moreover, Meeting Content includes a list of meeting participants, translations of the meeting into different languages as requested by the KUDO account holder and participants’ names and IP addresses.

12. When you use the Services through a KUDO account holder, such as your employer, the processing of your personal data is determined and administered by that account holder under its privacy policies. If you have questions about how and why your personal data is collected, the legal basis for processing, or requests regarding your personal data, please refer to the account holder’s privacy statement and direct your inquiries to the account holder or its administrator.

13. We collect operation and technical information from KUDO’s software or systems hosting the Services, and from the systems, applications and devices that are used to access the Services, such as:

  • Configuration Data: information about the deployment of the Services and related environment information.
  • Meeting metadata: metrics about when and how meetings were conducted.
  • Feature Usage Data: information about if and how Service features were used.
  • Performance Data: metrics related to how the Services perform.
  • Service Logs: information on system events and states.

III. How We Use Your Personal Data

14. KUDO may use your information for the following purposes:

  • Access to our website/app: To improve your user experience through the customization of content and layouts of various pages, (including sharing your information with our website hosts and developers, and website manager) (on the basis of our legitimate interest to ensure our website is presented in an effective and optimal manner).
  • Registration of your account: When you sign up to use our Services, we will use the details provided on your account registration form. Such information allows us to enroll you in the Services, display your username and picture to meeting participants, provide you with support, send marketing communications, where permitted, provide announcements related to Services updates, upgrades, and system enhancements, (on the basis of performing our contract with you).
  • Meeting Content: KUDO uses Meeting Content only in connection with providing the Services. We do not monitor, sell or use Meeting Content for any other purposes.
  • Relationship management and marketing: To respond to your requests for information and keep you informed about new features and services that we offer along with any content that we provide through our newsletters, provided that we have the requisite permission to do so (either on the basis of your consent where we have requested it, or, alternatively, our legitimate interests to provide you with marketing communications where we may lawfully do so) and provided that you have not asked us to not contact you. You can opt-out of our marketing communications at any time.
  • User and customer support: To provide customer service and support (on the basis of our contract with you), deal with inquiries or complaints about the Services and share your information with our third-party service providers as necessary to provide customer support (on the basis of our legitimate interest in providing the correct products and services to our website users).
  • Operation data: Such information allows us to facilitate the delivery and optimization of the Services, monitor performance of our data centers and networks, provide account dashboards and reports, provide support, maintain the security of our infrastructure and Services, administer our disaster recovery plans and policies, detect, investigate and stop fraudulent, harmful, unauthorized or illegal activity (“fraud and abuse detection”), confirm compliance with contractual obligations, comply with legal obligations, and create anonymized and/or aggregated data to improve our products and for other lawful business purposes.

15. We will not use your personal data for purposes other than those purposes we have disclosed to you, without your permission.

16. We do not control the actions of anyone with whom you or any other User may choose to share information. Therefore, we cannot and do not guarantee that any Meeting Content you or any User provides to the Services will not be viewed by unauthorized persons. Nor can KUDO control the content or security of information a User may choose to share during a meeting. Although KUDO account holders can set privacy options that limit access to certain areas of the Services, please be aware that no security measures are perfect or impenetrable and that we are not responsible for circumvention of any security measures contained in connection with the Services. You should be cautious about the access you provide to others when using the Services, and the information you choose to share when using the Services.

IV. How We Share Personal Data

17. We only share personal data with companies, organizations or individuals outside of KUDO when one of the following circumstances applies:

  • With consent: We may share personal data with companies, organizations, individuals outside of KUDO and others when we have consent from an individual (as applicable).
  • With KUDO partners: If we received your personal data from a third-party partner and you become a User, we may disclose select personal data to that partner or their designee for the purpose of the partnership agreement; for example, to reward a referral partner from a co-sponsored event. KUDO’s partners have contractually agreed to comply with appropriate privacy and security obligations.
  • For corporate transactions involving KUDO: We may share personal data with actual or prospective acquirers, their representatives and other relevant participants in, or during negotiations of, any sale, merger, acquisition, restructuring, or change in control involving all or a portion of KUDO’s business or assets, including in connection with bankruptcy or similar proceedings.
  • For business purposes: We provide personal data to vendors and services providers to help us provide the Services and for KUDO’s business purposes. Examples include public cloud storage vendors, carriers, payment processor, and service provider for managing customer support tickets. KUDO contractually prohibits such vendors from using the personal data for any reason other than to provide the contracted-for services and KUDO contractually requires its vendors to comply with all appropriate privacy and security requirements. The full list of our service providers is available upon request to Privacy@kudoway.com.
  • For legal reasons: We share personal data with companies, organizations or individuals outside of KUDO if we believe that access, use, preservation or disclosure of the information is reasonably necessary to:
    • meet any applicable law or respond to valid legal process, including from law enforcement or other government agencies.
    • enforce applicable Terms of Service, including investigation of potential violations.
    • detect, prevent, or otherwise address fraud, security or technical issues.
    • protect against harm to the rights, property or safety of KUDO, our Users or the public as required or permitted by law, including to help prevent the loss of life or serious injury of anyone.

V. Your Rights and Choices

18. Right to correct or update your information: If you would like to correct or update information that you have provided to us, please email privacy@kudoway.com

19. Marketing communications: You may receive marketing email communications from us where permissible. If you would like to stop receiving these communications, you can update your preferences by using the “Unsubscribe” link found in those emails.

20. European privacy rights: If you reside in the European Economic Area (“EEA”), you may have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.

  • Right not to provide consent or to withdraw consent. We may seek to rely on your consent in order to process certain personal data. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
  • Right of access and/or portability. You may have the right to access the personal data that we hold about you and, in some limited circumstances, have that data provided to you so that you can provide or “port” that data to another provider.
  • Right of erasure. In certain circumstances, you may have the right to the erasure of personal data that we hold about you (for example, if it is no longer necessary for the purposes for which it was originally collected).
  • Right to object to processing. You may have the right to request that we stop processing your personal data and/or to stop sending you marketing communications.
  • Right to rectification. You may have the right to require us to correct any inaccurate or incomplete personal data.
  • Right to restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
  • Right to lodge a complaint to your local Data Protection Authority. If you are an EEA resident, you have the right to complain to a data protection authority about our collection and use of your personal data.

21. How to exercise your rights: To exercise any of the rights above, email us at privacy@kudoway.com. You may also submit a request to the following address:

Please identify yourself and specify your request. If you have a password protected KUDO account, we will use your account information to verify your identity. If not, we will ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.

We use commercially reasonable efforts to delete your personal data as required but retain records necessary to comply with a governmental authority or applicable federal, state, or local law. Where legally permitted, we may decline to process requests, including requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.

VI. Retention

22. KUDO will retain your personal data for as long as we have, or need to keep a record of, a relationship with you. KUDO will retain personal data collected from online meetings and conferences held via the KUDO platform for as long as the account holder remains an account holder of KUDO, and for a period of no more than one (1) year after termination or expiration of that account holder’s status as an account holder. Personal data may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights.

VII. Security

23. KUDO is committed to protecting your personal data. We use reasonable and appropriate technical and organizational measures in accord with industry standards to protect personal data from loss, misuse and unauthorized access, hacking, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the personal data. KUDO, however, does not and cannot guarantee that your personal data will be free from security breaches, or that materials uploaded in connection with KUDO’s video conferencing and communications services will not contain viruses, trojan horses, worms, or other forms of malware or malicious code. If you have any questions about the security of your data, please contact our security team at security@kudoway.com.

VIII. International Transfers

24. KUDO operates globally, which means personal data may be stored and processed (for example, stored in a data center) in any country where we or our service providers have facilities or hold events. By using KUDO or providing personal data for any of the purposes stated above, you acknowledge that your personal data may be transferred to or stored in the United States or in other countries around the world. Such countries may have data protection rules that are different and less protective than those of your country.

25. If you are a resident of the EEA, and your personal data is transferred outside of the EEA, we will:

  • Process it in a territory which the European Commission has determined provides an adequate level of protection for personal data; or
  • Implement appropriate safeguards to protect your personal data, including transferring it in accordance with applicable transfer mechanism, including the European Commission’s standard contractual clauses.

IX. Changes to our Privacy Policy:

It is our policy to post any changes we make to our privacy policy on our website. If we make material changes to how we treat our users’ personal information, we will notify through a notice on our website home page or by email to the primary email specified in your account. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our website and this privacy policy to check for any changes.

X. How to Contact Us:

Contact details with KUDO

Contact details with Data Protection Officer (Response person for GDPR)

Last Updated: June 1, 2021

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