Kuulo Privacy Policy

Version

This version of Kuulo Privacy Policy was revised on 07.09.2026.

The previous version of Kuulo Privacy Policy was published on 28.08.2026.

Introduction

CL3 Holdings Ltd, a private limited company incorporated in England and Wales under company number 16504597 and whose registered office is at 167–169 Great Portland Street, London, England, W1W 5PF, trading as Kuulo, referred to as “Kuulo”, “we”, “us”, or “our”, respect and realise the importance of protecting your privacy. Kuulo is committed to protecting your privacy rights to the fullest possible extent.

Protecting your data and using it only in ways you expect is our highest priority. This Privacy Policy is designed to inform you about the processing of your personal data and your rights regarding this processing in accordance with applicable data protection laws, including the General Data Protection Regulation and the Data Protection Act 2018.

We are the controller of your personal data, which means we are the organisation legally responsible for deciding how and for what purposes your personal data is used, and therefore for the data processing described herein.

By using this website, you acknowledge that you have been informed about the processing of your personal data as described in this Privacy Policy. This statement also applies in other cases where we make specific reference to it, including when we first communicate with you by email or other means, or when you use Kuulo products and services.

Personal data we collect

We may collect information that you voluntarily provide to us via email, contact forms, meeting bookings, support requests, or other direct contact. This may include your name, email address, company, role, the contents of your message, and records of our communications with you.

We may collect information from your use of our website, subject to your cookie choices, and information obtained from publicly available sources. This may include your IP address, browser and device information, operating system, approximate usage information, pages visited, and the date and time of access.

Purpose of collecting your personal data

We use your personal data for several purposes, including:

• to communicate with you, including responding to your enquiries or requests;
• to provide customer and technical support;
• to improve the user experience of our website and products;
• to diagnose crashes and understand aggregate website usage, where you have consented;
• to administer and manage contractual relationships; and
• to comply with our legal obligations and protect our rights.

Your personal data may be stored in secure internal systems, databases, and service-provider systems used to operate our website and products.

Lawful bases for processing

We process your personal data on the following lawful bases and for the following purposes:

Marketing communications

Where you have opted in to receive marketing communications from us, we may use your personal data to send you emails or messages about Kuulo services, features, or offers. In doing so, we rely on your consent as the lawful basis for processing.

Any marketing email sent to you will include information on how to opt out of receiving such notifications in the future. We do not sell your personal data or use it for targeted advertising.

Safety of your personal data

We implement appropriate organisational, technical, and security measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include access controls, encryption in transit and at rest where appropriate, and limiting access to people and providers who need it for legitimate business purposes.

Personal data processed for any purpose will not be kept longer than necessary for that purpose, including to comply with legal requirements. If you withdraw consent, we may retain certain personal information for the period required by applicable law, to resolve disputes, and/or to enforce our rights and agreements.

Data transfer

It may sometimes be necessary for us to share your personal data with service providers or business partners located internationally. In such cases, we will comply with applicable laws designed to protect your personal data.

We transfer personal data internationally only where an adequacy decision, an International Data Transfer Agreement, an Addendum to the EU Standard Contractual Clauses, or another legally approved safeguard applies. If we are unable to rely on one of these mechanisms, we will not make the transfer unless an alternative mechanism permitted by data protection authorities is available.

Sharing of your personal data

We may share your personal data with professional advisers, third-party service providers, partners, contractors, and employees, for the purposes described in this Privacy Policy or otherwise notified to you.

We engage service providers which help us operate, support, and develop our business and website. These services include cloud hosting, content delivery, customer and technical support, email delivery, meeting scheduling, security, analytics, and infrastructure services. We share personal data with these service providers only as necessary to enable them to provide their services to us.

Mixpanel may process pseudonymised website usage data only after you have consented to analytics cookies. We configure Mixpanel to use its European data endpoint.

We may also share your information with competent law enforcement bodies, regulatory or government agencies, courts, or other third parties where such disclosure is necessary to comply with a legal obligation, or to protect your vital interests or those of another person.

We do not sell your personal data to any third party for any purpose.

Children’s privacy

Kuulo services and products are not intended for use by children under the age of 13. We do not knowingly collect or solicit personal information from children under 13. If Kuulo becomes aware that personal data of a child has been provided to us, we will delete it from our systems as soon as possible.

If you are between 13 and 16 years old, your use of Kuulo is subject to consent from a parent or guardian where required by applicable data protection law. If you are a parent or guardian and believe that we have collected personal data from your child, please contact us using the details at the end of this Policy.

Information tracking

This website may automatically collect information about you in several ways, including through your IP address, device settings, operating system, date and time, preferences, and saved options, subject to your browser settings and cookie choices. We may use this information to help diagnose server issues, administer the website, and understand aggregate usage.

For more information about cookies and similar technologies, please read our Cookie Policy.

Third-party links

Our website may contain links to third-party websites. CL3 Holdings Ltd is not responsible for the privacy practices or the content of these websites. We recommend that you review the privacy policies and the terms and conditions of any third-party websites you visit.

Automated decision-making

We do not use personal data for fully automated decision-making that produces legal effects or similarly significant effects concerning you. Website analytics is used for aggregate product and service improvement and not to make decisions about individuals.

Data storage

We ensure that your personal data is not retained for longer than necessary for the purposes for which it is processed. To ensure compliance with this principle, we define retention periods applicable to each processing activity, taking into account legal obligations, recommendations of supervisory authorities, best practices, and our operational needs.

Different retention periods may apply to different types of personal data. At the end of the relevant retention period, we will delete or anonymise your personal data, unless we are required to retain it for longer by law.

Your privacy rights

We are committed to ensuring the effective exercise of your rights as a data subject. In most cases, you can exercise these rights free of charge. However, we reserve the right to charge a reasonable fee if we receive a large number of repetitive requests.

Your principal privacy rights include: the right to be informed about the collection and use of personal data; the right to access your personal data; the right to rectification; the right to erasure; the right to restrict processing; the right to object to processing; the right to data portability; the right to complain to a supervisory authority; and the right to withdraw consent.

To exercise any of these rights, please email support@kuulo.ai with “Data Rights Request” in the subject line. Please specify, as far as possible, the scope of your request, the processing concerned, and any information that will help us deal with it efficiently. In cases of reasonable doubt, you may be asked to verify your identity.

We will make every effort to respond as soon as possible and, in any event, within one month of receiving your request, unless a longer period is permitted by applicable law. If your request is complex or numerous, we may extend this period by up to two further months and will inform you of the reason for the delay.

Notice for California residents

If you are a California resident, this Privacy Policy applies to you, subject to the additional information provided below regarding the California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”).

In the preceding 12 months, we may have collected identifiers such as your name, email address, company; enquiry and correspondence records; and internet or network activity such as consented website analytics.

You have the right to know what personal information we collect and how it is used, request access to or deletion of your personal information, request correction of inaccurate information, opt out of sale or sharing, and receive equal treatment for exercising your rights. We do not sell your personal information or share it for cross-context behavioural advertising.

To exercise your California rights, contact us at support@kuulo.ai with “California Privacy Request” in the subject line. We will respond within the period required by applicable law and may need to verify your identity before processing a request.

How to complain

If you are not satisfied with how your personal data is being processed, you have the right to lodge a formal complaint with the Information Commissioner’s Office. The ICO can be contacted via the ICO website or by telephone at 0303 123 1113.

If you are located in the EU or EEA, you may also contact the relevant data protection supervisory authority in the country where you live, work, or believe an infringement occurred.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time at our sole discretion by publishing a new version on this website. Any changes will be posted on the website so that you are always aware of the information we collect, how we may use it, and under which circumstances we may disclose it.

The date of the last modification of this Privacy Policy is stated at the beginning of this document. We encourage you to review the most recent version regularly, as well as each time you visit our website. We will also make reasonable efforts to notify you of any material changes by email, if we have your email address, or by another appropriate means.

Contact us

If you have any questions or concerns about this kuulo privacy policy, please contact us using the details below:

CL3 HOLDINGS LTD (trading as Kuulo)
167–169 Great Portland Street, London, England, W1W 5PF
Company number: 16504597
support@kuulo.ai