Privacy Policy

At Kulohi, we believe that trust is earned through transparency, respect, and care.

Kulohi exists to help people preserve memories, strengthen relationships, and build lasting legacies through meaningful conversations, stories, photos, and shared experiences. We understand that the information entrusted to us is deeply personal. Protecting that trust is one of our most important responsibilities.

This Privacy Policy explains what information we collect, how we use it, who we share it with, and the choices you have regarding your information.

Gremlin Labs LLC, doing business as Kulohi (“Gremlin Labs,” “Kulohi,” “we,” “our,” or “us”), operates Kulohi.

Depending on how you use Kulohi, we may collect the following information.

Account Information

When you create an account, we may collect:

- Name - Email address - Password credentials handled by our authentication provider. Kulohi does not store your plain-text password. - Membership information - Subscription status - Preferences and settings

Kulohi is preparing an optional passkey sign-in feature. If you choose to create a passkey after that feature is made available, our authentication provider may store the public-key credential record and limited account-security details such as the name you give the passkey, when it was created, and when it was last used. The private key and any biometric check, such as a fingerprint or face check, or device PIN used to approve sign-in remain controlled by your device, security key, or password manager and are not sent to Kulohi.

You may choose to provide:

- Profile photographs - Date of birth - Time zone - Language preferences - Accessibility preferences - Emergency contact information

Providing this information is optional unless required for a specific feature.

Kulohi allows members to interact with Robin through text and voice.

Depending on the features you use, we may process:

- Voice recordings - Speech transcriptions - Text conversations - Conversation timestamps - AI-generated responses - Memory references created from conversations

Robin conversations are used to provide personalized assistance, maintain context between conversations, and improve your experience.

You may choose to save:

- Personal stories - Personal and relationship history - Journal entries - Photos - Documents - Audio recordings - Video recordings - Captions - Tags

You retain ownership of all content you upload.

If you invite people you trust, such as family members, friends, neighbors, or caregivers, into Kindred, we may collect:

- Their name - Email address - Relationship to you - Assigned permission level - Messages shared through Kulohi

Kindred members only receive access that you explicitly grant.

If you choose to use Today or record optional wellness reflections, we may collect information you provide, such as:

- Mood selections - Energy level - Sleep quality - Personal reflections

This information is used to provide the Kulohi features you choose to use and to support any sharing you specifically authorize. Providing wellness reflections is optional.

Kulohi does not diagnose, treat, or monitor medical conditions.

We may automatically collect technical information including:

- Browser type - Operating system - Device type - IP address - Crash reports - Performance metrics - Diagnostic logs

This information helps us maintain and improve the service.

If you choose to enroll in Kulohi text notifications, we collect the phone number you provide, your SMS preference, the date and source of your opt-in or opt-out, the version of the disclosure you accepted, and message delivery or status information supplied by our communications provider.

We use this information to record and honor your choice, deliver recurring informational messages you selected such as account notifications and reminders, troubleshoot delivery, and comply with applicable messaging requirements. Providing a phone number, creating an account, joining Kindred, or allowing push notifications does not by itself enroll you in SMS.

We use information to:

- Provide Kulohi services - Personalize Robin - Remember important information between conversations - Personalize Robin's responses and improve Kulohi's own product experience - Generate reminders - Organize Life Stories - Prepare a Legacy Book from stories and images you approved for Legacy - Provide customer support - Deliver optional transactional SMS notifications and honor messaging preferences - Process memberships and billing - Detect fraud and abuse - Improve reliability and security - Comply with legal obligations

We do not sell your personal information. We do not sell, rent, or share SMS opt-in data or consent with third parties for their own marketing. We may provide limited information to communications providers acting on our behalf solely to deliver messages, service the program, and honor opt-outs.

Some Kulohi features use artificial intelligence provided by trusted technology partners.

Information you choose to share with Robin may be processed by AI systems in order to:

- Understand requests - Generate responses - Summarize conversations - Organize memories - Create reminders - Improve personalization

Kulohi's current Robin response-generation path uses OpenRouter as a controlled gateway. Each request names an approved model, limits routing to code-approved providers, denies provider data collection, requests Zero Data Retention, and requires those routing parameters to be supported. Kulohi does not use OpenRouter's unrestricted automatic model router for Robin.

The separate direct OpenAI path is disabled by default and is not used for ordinary Robin conversations. Request-level provider controls do not mean Kulohi stores no information. Kulohi may retain conversations, memories, and related account information as described elsewhere in this policy so Robin can provide the features a member chooses to use.

Approved backend providers may have different technical systems. A Robin request may proceed only through a route that meets Kulohi's configured privacy restrictions. Kulohi does not claim that every part of its own service has Zero Data Retention.

Other AI, voice, image, or file-processing features may have different technical retention requirements. Kulohi will describe material differences before making those features generally available.

AI-generated responses may occasionally be inaccurate. Members should independently verify important information before relying on it.

We work with trusted service providers that help us operate Kulohi.

These providers may include services for:

- Authentication - Cloud hosting - Secure databases - AI processing - Voice transcription - Voice synthesis - Analytics - Payment processing - Customer support - Email delivery

These providers process information under their applicable agreements, configurations, and privacy terms. The information sent depends on the feature being used. Kulohi seeks to limit that information to what is needed to provide and protect the service, but this policy does not claim that providers receive no service metadata.

We share information only when necessary.

Examples include:

- With Kindred members you authorize - With service providers acting on our behalf - To comply with legal obligations - To protect the safety of members or others - During a merger, acquisition, or business transfer

We do not sell or rent your personal information.

Legal and Law-Enforcement Requests

We may disclose information when required by applicable law or valid legal process, and we may preserve information when legally required to do so. Whether we can notify an affected member depends on the law and the terms of the request. Service providers may separately receive and respond to requests directed to them under their own legal obligations and policies.

Your stories, recordings, photos, and personal memories remain yours.

Creating content within Kulohi does not transfer ownership to Gremlin Labs.

You grant us only the limited rights necessary to store, process, back up, and display your content as required to provide Kulohi services.

If Legacy features are enabled, information may be used to prepare:

- Legacy Books - Memorial experiences - Personal or shared archives

These features are activated only according to your settings and the permissions described in the Legacy Program Policy.

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect your information.

While no online service can guarantee absolute security, we continuously work to improve our security practices.

We retain information only for as long as necessary to:

- Operate Kulohi - Fulfill legal obligations - Resolve disputes - Enforce our agreements - Provide Legacy features when authorized

Retention periods may vary depending on the type of information involved.

Provider retention is separate from Kulohi's own retention. The AI Processing section describes the current request-level storage control and the provider retention that may still apply.

You may have the ability to:

- Access your information - Correct inaccurate information - Download your content - Delete your content - Close your account - Manage Kindred permissions - Adjust privacy settings - Opt out of certain communications

When optional passkey management is available, removing a passkey from your Kulohi account will stop Kulohi from accepting that server-side credential. It may not remove the saved passkey from your device or password manager; you may need to remove that copy separately.

Some information may be retained where required by law or necessary to protect the security and integrity of the service.

Kulohi is intended for adults.

We do not knowingly collect personal information from children under the age required by applicable law without appropriate authorization.

If you access Kulohi from outside the United States, your information may be transferred to and processed in countries where we or our service providers operate.

As Kulohi evolves, we may update this Privacy Policy.

When significant changes are made, we will update the “Last Updated” date and, when appropriate, provide additional notice.

Questions about this Privacy Policy may be directed to:

Gremlin Labs LLC

Legal Department

Email: privacy@kulohi.com

Website: https://kulohi.com

Thank you for trusting Kulohi.

Protecting your stories, your memories, and the people you care about is a responsibility we take seriously.