Privacy Policy

1. Who we are and what this covers

This policy explains how Kobolu LLC (“Kobolu,” “we”) handles personal information in the Kobolu mobile app and on kobolu.com, including the waitlist. Money transmission is provided through licensed partners. [PARTNER DISCLOSURE — PENDING LEGAL REVIEW.]

2. Information we collect

Account and contact information: your email address, verified phone number, name, and optional profile photo, managed through our authentication provider (Clerk). Passwords and sign-in secrets are handled by Clerk; we never see or store them.

Profile and preferences: your app language and your consent choices (each consent is recorded with its version and time).

Recipients and payment methods: recipient names, country, and payout-card references, and your saved debit-card references. We store only the card brand, the last four digits, and a token from the payment provider — never full card numbers or security codes.

Transfers: amounts, currencies, exchange rate, fees, purpose, status history, and timestamps for each transfer, kept as an unchangeable record.

Identity verification: when verification launches it will be performed by a specialist provider (Sumsub). Your ID documents and selfie will be collected and held by that provider; we store the verification result and status, not the documents.

Assistant conversations: if you enable the assistant, we store your messages and its replies so you can continue your conversations; you can delete conversations in the app.

Waitlist: your email address and any optional details you choose to submit (name, preferred language, personal or business interest).

Security and diagnostics: an audit log of security-relevant account events (such as consent changes, deletion requests, and sign-out of sessions), and crash/performance diagnostics described in section 5.

3. What we deliberately do not collect

We never store full card numbers or CVV codes. Your app passcode never leaves your device (only a salted, one-way verifier is kept in your device's secure storage), and Face ID / Touch ID processing stays on your device. We do not access your contact list, we do not use advertising or analytics SDKs, and we do not sell personal information.

4. How we use information

To provide the Service: create your account, verify your identity where required, generate quotes, process the transfers you authorize, show your history, and support you.

To meet legal obligations: identity verification, sanctions and fraud screening, recordkeeping, and responding to lawful requests.

To keep the Service safe and reliable: security auditing, rate limiting, and crash and performance diagnostics.

With your consent only: generating assistant replies (section 6) and sending optional product news (marketing). Transfer and security notices are part of the Service and are not marketing.

5. Diagnostics and telemetry

We use Sentry for crash and performance monitoring. Before any report leaves the app, we strip account identity fields and request contents and redact email-, phone-, and card-shaped text. If you use the assistant, redacted excerpts of assistant conversations are included in our AI diagnostics so we can find and fix failures; card-like numbers are removed before your message ever leaves the app.

6. The assistant and AI data sharing

The assistant is optional and off until you consent. With your consent, the messages you send and the transfer details needed to answer (such as recipient names, amounts, and statuses) are shared with our AI provider (Anthropic) to generate replies. Card numbers, security codes, one-time codes, passwords, and sign-in tokens are never sent. You can withdraw consent at any time in Profile → Assistant and AI privacy, which stops all AI requests; the rest of the app keeps working.

7. Who we share information with

Service providers that operate parts of Kobolu under contract: Clerk (accounts and sign-in), Neon (database hosting), Anthropic (assistant replies, consent-based), Sentry (diagnostics), and Vercel (website hosting). At launch: Sumsub (identity verification), Moov (US card payments), and our payout partner (delivering funds to recipients).

Authorities and others where the law requires it, such as recordkeeping, sanctions, or fraud obligations.

We do not share personal information with advertisers or data brokers, and we do not sell it.

8. How long we keep information

Account information is kept while your account is active. When you delete your account, your profile, recipients, saved cards, conversations, and preferences are deleted; records of completed transfers must be retained under US financial regulations for five years, with restricted access, and your remaining profile record is reduced to what those records require.

Data exports you request are automatically deleted after 7 days. Waitlist entries are kept until launch outreach is complete or you ask us to remove yours.

9. Your choices and rights

In the app you can: update your email and phone (with verification), change your language, grant or withdraw the assistant and marketing consents, sign out other devices, download a copy of your data (Profile → Download my data), and delete your account (Profile → Delete account). Deletion is blocked only while money is still moving, and we tell you why.

Depending on where you live you may have additional legal rights (such as access or correction). Contact us at support@kobolu.com to exercise them.

10. Security

Information is encrypted in transit; payment destinations are tokenized; access to production data is restricted; security-relevant actions are logged; and sensitive actions in the app (like deletion or data export) require re-authentication on your device. No system is perfectly secure — tell us immediately if you suspect a problem with your account.

11. Children

The Service is not directed to children and may not be used by anyone under 18. We do not knowingly collect information from children.

12. International transfers of data

We are US-based and our providers store data primarily in the United States. Recipient details are shared with payout partners in the destination country to deliver a transfer.

13. Changes and contact

We will update this policy as the Service evolves and give notice of material changes in the app or by email. Questions or requests: Kobolu LLC, support@kobolu.com.