Privacy Policy

Last updated: 15 June 2026

1. Who we are

Kult ("Kult", "we", "us", "our") provides a real-time, voice-first AI companion for video games. You speak to the assistant while you play, and it answers questions about games using a knowledge base built from public sources combined with live web search.

This policy explains what personal data we collect when you use our website, app, and voice assistant (together, the "Service"), how we use it, who we share it with, and the rights you have over it.

For the purposes of UK and EU data protection law, the data controller is:

  • KULT AI LIMITED
  • Registered in England and Wales, company number 16973445
  • Registered address: Apartment 302, 2 Wood Crescent, London, England, W12 7GJ
  • Privacy contact: privacy@joinkult.ai

2. The short version

We've written this in plain English. The essentials:

  • You talk, we help. When you use the voice assistant, your microphone audio is sent to AI providers that turn your speech into text and generate answers.
  • We keep your questions, not your voice for long. We delete raw audio quickly after it's processed. We keep the text of what you asked and the answers we gave so the Service works and improves.
  • We do not create a "voiceprint". We do not use your voice to identify you, and we do not build a biometric profile of your voice.
  • We do not sell your personal data.
  • We use trusted third parties (Google, OpenAI, and speech and search providers) to run the Service. Some are in the United States.
  • You're in control. You can access, correct, or delete your data, and contact us at privacy@joinkult.ai any time.

The rest of this policy is the detail.


3. Information we collect

3.1 Information you give us

DataExamplesWhen
Account dataEmail address, username, display name, password (stored hashed)When you sign up
Profile & preferencesFavourite games, skill level, settingsWhen you set them
Voice inputAudio of what you say to the assistantDuring a voice session
Text inputQuestions you type, feedback you sendWhen you use the Service
CommunicationsMessages you send us (support, email)When you contact us

3.2 Information we collect automatically

DataExamples
Usage dataGames you view, queries you make, features you use, session length
Device & technical dataIP address, browser/OS type, device identifiers, app version
Session activity (analytics)Pages visited, clicks, and — where enabled — session replay (a recording of how you interact with the web app). See §11.
Cookies & similar technologiesSee §11.

3.3 Information from third parties

If you sign in through a third party or we receive limited technical data from our hosting and analytics providers, we may combine it with the above. We do not buy personal data about you from data brokers.


4. Voice and audio data (please read this)

Because Kult is a voice product, this gets its own section.

  • What we capture. When you start a voice session, audio from your microphone is captured and streamed in real time to operate the assistant. We capture audio only while the assistant is active in a session, not in the background.
  • How it's processed. Audio is sent to third-party speech-to-text providers to transcribe what you said, to AI model providers to generate a response, and to text-to-speech providers to speak the answer back. These providers are listed in §6.
  • Other people's voices. If other people are speaking near you, their voice may be picked up. Please only use the assistant where you and anyone nearby are comfortable with that.
  • Raw audio retention. We retain raw audio only as long as needed to process your request and operate the session, and delete it shortly afterwards (within 30 days), except where we must keep it to investigate abuse, security, or to comply with law.
  • Transcripts. We keep the text transcript of your questions and the assistant's answers for longer, to provide the Service (e.g. conversation context), to maintain a cache of answers, and to improve quality. See §7 and §8.

We do not create voiceprints. We process your voice to convert speech to text and to operate the assistant. We do not create, store, or use a biometric "voiceprint" or voice template, and we do not use your voice to identify or authenticate you. Because of this, we do not treat your voice audio as special category (biometric) data under UK/EU GDPR. If we ever introduce voice-recognition features, we will update this policy and obtain your explicit consent first.


5. How we use your information, and our legal bases

Under UK/EU GDPR we must have a lawful basis for each use of your data.

What we doWhyLawful basis (UK/EU GDPR)
Create and manage your accountTo let you sign in and use the ServiceContract (Art. 6(1)(b))
Run the voice assistant (capture audio, transcribe, generate and speak answers)This is the core Service you asked forContract
Store your questions and answers to provide conversation context and a response cacheTo make the Service work and respond fasterContract / Legitimate interests
Improve and develop the Service (quality, accuracy, reliability)To make Kult betterLegitimate interests (Art. 6(1)(f)) — see §8
Analytics and session replayTo understand usage and fix problemsConsent (where required by cookie law) + legitimate interests
Security, abuse prevention, debuggingTo keep the Service safe and workingLegitimate interests / Legal obligation
Send you service messagesTo tell you about important changesContract / Legitimate interests
Send you marketing (if any)To tell you about featuresConsent
Comply with law / respond to legal requestsLegal complianceLegal obligation

Where we rely on legitimate interests, we have balanced our interests against your rights. You can object to this processing — see §13. Where we rely on consent, you can withdraw it at any time.


6. How the AI works, and who we share data with

To run the Service we use trusted third-party "sub-processors". They process your data on our behalf, under contracts that require them to protect it and use it only to provide their service to us. Our current sub-processors include:

ProviderRoleWhat it processes
Google (Gemini / Vertex AI)Real-time voice model + reasoning modelsAudio and/or text of your queries
OpenAIAlternative voice model; text embeddingsAudio and/or text of your queries
Deepgram, Cartesia, ElevenLabs, GradiumSpeech-to-text and text-to-speechAudio and transcripts
CohereSearch result re-rankingQuery text
Tavily, Linkup, Parallel, You.comLive web searchQuery text
SupabaseDatabase and authentication hostingAccount data, transcripts, preferences
Google Cloud PlatformApplication hosting and infrastructureMost data, in transit/at rest
LiveKitReal-time audio transportAudio stream
VercelWebsite hostingTechnical/usage data
PostHog (EU)Product analytics and session replayUsage and interaction data
LangfuseAI observability (tracing AI calls to debug and improve)Query/answer text

We keep our list of sub-processors up to date and will update it as our providers change.

We may also share data:

  • With professional advisers (lawyers, accountants, auditors) under duties of confidentiality;
  • In a business transfer (merger, acquisition, financing, or sale of assets);
  • To comply with law, enforce our terms, or protect the rights, safety, and property of Kult, our users, or others.

We do not sell your personal data, and we do not share it for cross-context behavioural advertising.


7. AI providers and your data

When your audio or text is sent to the AI providers above, it is processed to generate your answer. We use these providers under their standard API terms, which do not permit them to use your content to train their own models, and they retain it only as needed to provide the service to us.


8. Using your data to improve Kult

We may use the text of your questions and the assistant's answers, together with usage data, to evaluate and improve the quality, accuracy, and reliability of the Service — for example, to fix wrong answers and improve our knowledge base.

  • We do not use raw voice audio to train models by default.
  • Where we use your content for improvement, we minimise and, where practical, aggregate or de-identify it.
  • You can ask us not to use your content to improve the Service by emailing privacy@joinkult.ai.

9. International data transfers

Some of our providers (including Google and OpenAI) are based in, or process data in, the United States and other countries outside the UK and European Economic Area (EEA).

When we transfer your data outside the UK/EEA, we rely on appropriate safeguards, which may include:

  • transfers to providers certified under the UK Extension to the EU–US Data Privacy Framework, where available; or
  • the UK International Data Transfer Agreement (IDTA) / the EU Standard Contractual Clauses with the UK Addendum, together with a transfer risk assessment.

You can request a copy of the safeguards we use by contacting us.


10. Data retention

We keep personal data only as long as we need it:

DataRetention
Account dataWhile your account is active; deleted within 90 days of account closure (minus anything we must keep by law)
Raw voice audioUp to 30 days, usually much less; deleted after processing
Transcripts (questions & answers)Up to 24 months, or until you delete them / your account
Cached answers (response store)Until superseded or cleared; not linked to your identity where avoidable
Analytics dataUp to 24 months
Support communicationsUp to 24 months

When we no longer need data, we delete or anonymise it.


11. Cookies, analytics, and session replay

We use cookies and similar technologies. Some are strictly necessary (e.g. to keep you signed in) and don't need consent. Others — including analytics and session replay (PostHog) — are non-essential and are used only with your consent, which we ask for via our cookie banner.

You can accept or reject non-essential cookies, and change your choice at any time. Rejecting is as easy as accepting. Our cookie banner lists each technology, its purpose, provider, and duration. We mask sensitive fields (such as passwords) in session replay.


12. Children

The Service is intended for adults aged 18 and over. It is not directed at, and must not be used by, anyone under 18.

We do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has provided us with personal data, contact privacy@joinkult.ai and we will delete it and close the account.


13. Your rights

Under UK/EU GDPR you have the right to:

  • Access the personal data we hold about you;
  • Rectify inaccurate or incomplete data;
  • Erase your data ("right to be forgotten");
  • Restrict or object to processing (including processing based on legitimate interests, and direct marketing);
  • Data portability — receive your data in a portable format;
  • Withdraw consent at any time, where we rely on consent;
  • Not be subject to solely automated decisions with legal or similarly significant effects (we do not make such decisions about you).

To exercise any right, contact privacy@joinkult.ai. We'll respond within one month. Using these rights is free, and we won't discriminate against you for it.

Complaints. If you're unhappy with how we handle your data, you can complain to the UK Information Commissioner's Office (ico.org.uk) or, if you're in the EEA, to your local data protection authority. We'd appreciate the chance to address your concern first.


14. Your California privacy rights

If you are a California resident, you have rights under the CCPA/CPRA to know, access, delete, and correct your personal information, and to opt out of any "sale" or "sharing" of it. We do not sell or share your personal information as those terms are defined under California law. Voice data may be treated as "sensitive personal information"; we use it only to provide the Service and do not use it to infer characteristics about you. To exercise your rights, contact privacy@joinkult.ai. We will not discriminate against you for exercising them.


15. Security

We use appropriate technical and organisational measures to protect your data, including encryption in transit, access controls, secrets management, and hosting with reputable providers. No system is perfectly secure, but we work to protect your data and will notify you and the relevant authority of a breach where the law requires.


16. Changes to this policy

We may update this policy from time to time. If we make material changes, we'll notify you (e.g. by email or an in-app notice) before they take effect. The "Last updated" date at the top shows the current version.


17. Contact us

Questions or requests about privacy: privacy@joinkult.ai

Postal: KULT AI LIMITED, Apartment 302, 2 Wood Crescent, London, England, W12 7GJ