Biometric Data Consent

This Biometric Data Consent is a standalone document that, together with our Privacy Policy, explains how QuantumShieldAI Pte. Ltd. (UEN 202650970C), which operates D Lulu (“D Lulu”, “we”) handles biometric identifiers and biometric information. It is our written policy and retention schedule for biometric data, and it is intended to meet the disclosure and consent requirements of laws such as the Illinois Biometric Information Privacy Act (BIPA, 740 ILCS 14), the Texas Capture or Use of Biometric Identifier Act (CUBI), the Washington biometric identifiers law (RCW 19.375), Article 9 of the EU and UK GDPR, and the Singapore Personal Data Protection Act 2012.

1. What we collect and how

When you verify your face, the app takes a short live capture of you while you follow a few on-screen steps (such as blinking, smiling or turning your head). On our own servers we check that the capture shows a live person rather than a photo, screen or mask, and run the AuraFace face-recognition model over it. The model outputs a floating-point vector of 512 numbers (a “face embedding”), which becomes your verified face. The captured frames are processed in memory and are not stored; we keep the embedding and the scores of the check (how likely the capture was live, and how closely it matched your photo).

We also run the model over your main profile photo, over other photos you add to your profile while we check them, and over photos you add for date cards, to check that each is of you. An embedding is a mathematical summary of the face — it is not a photograph and cannot be reversed into a recognisable image.

We treat embeddings as “biometric identifiers” under BIPA, “biometric information” where combined with identifying data, “biometric data” under Art. 9 GDPR, and “sensitive personal information” under the CPRA. The photos themselves are stored only to show them in the app as you choose; they are not used for any identification purpose other than generating their embeddings and checking them against your verified face.

We do not collect voiceprints, fingerprints, iris or retina scans, gait data, or any other biometric identifier. If you record an optional private video intro, we compare a few still frames from it with your verified face as described in our Privacy Policy; those frame embeddings are not added to your account.

2. Purposes of processing

We process your face embeddings for the following specific, limited purposes:

1. Face verification and same-person checks. When you verify, we check that the capture is of a live person and matches your main photo. When you set a new main photo or add a photo that must show you, we compare it against your verified face. If they do not match, we ask you to verify again or refuse the photo — this helps prevent account takeover and catfishing.
2. One person, one account. When you verify your face, we compare your verified face with the verified faces of other real accounts on D Lulu, including accounts that are suspended or banned, to stop duplicate accounts and people returning after a ban. Test and automated accounts are left out, both ways. If your face clearly matches another account, or comes close to a banned account, verification is refused and your face is not added. If it is close but uncertain, verification goes ahead and our staff see a review flag showing the two accounts and how similar the faces were; they decide what, if anything, to do. We never tell you, or anyone outside our staff, which account a face matched.
3. Face blocks made before face blocking was withdrawn. Face blocking — blocking someone by uploading a photo of their face — is no longer offered. Face blocks created before it was withdrawn are still stored and, where they were made with our current face model, still applied: a match hides the matched account from the blocker and the blocker from the matched account. We do not notify the blocked person.

We do not use your face embedding for advertising, for training machine-learning models, for demographic analysis, for estimating your age, for emotion or sentiment analysis, for law-enforcement matching outside a valid legal process, or for any other purpose than those listed above.

What verification does not do. Face verification does not check an identity document and does not confirm anyone’s name, age, background or intentions. A verified mark means only that the account passed the checks above. See Section 9 of our Terms of Service.

3. How we obtain consent

Before any biometric processing occurs, we present an in-app consent screen that:

• describes the purposes above;
• summarises how long we keep the data;
• links to this document, which names QuantumShieldAI Pte. Ltd., the operator of D Lulu, as the party collecting and using the data and sets out the full retention schedule in Section 4; and
• requires your affirmative tap to proceed.

By tapping to agree, you give your written consent (a written release, for the purposes of BIPA) to the collection, storage and use of your biometric data as described here. If you decline, we do not extract or store any embedding and you cannot verify your face. You can still browse and use features that do not depend on face matching. Note that a new account that does not complete face verification within 7 days is deleted, after one reminder (accounts created before 15:42 UTC on October 11, 2026, accounts that have ever been verified, and business owners and staff are not affected).

When we add a new purpose, as we did with one person, one account in version 1.1, we ask for your consent again before your next face scan.

4. Retention and deletion schedule

Deletion removes the stored values from our systems. We keep a record that a deletion ran, which does not contain any biometric value.

5. No sale, no lease, no profit

D Lulu does not and will not sell, lease, trade, share for valuable consideration, or otherwise profit from your biometric identifiers or biometric information. We do not license biometric data to advertising networks, data brokers, insurers, employers, or governments.

6. Limited disclosure

We disclose biometric identifiers only in the following circumstances:

• To you. On request we will provide a machine-readable copy of the embeddings we hold for you.
• To our hosting provider. Our servers, databases and backups run on infrastructure we rent from Amazon Web Services (AWS), which stores the data on our behalf under its terms and does not use it for its own purposes. The face-recognition model runs on our own server; we never send your face embeddings to anyone else, and we do not use an outside face-recognition service.
• When required by law. In response to a valid subpoena, court order, warrant, or other legally binding request. Where the law permits, we may tell you before we comply.
• With your consent for a specifically described purpose, or to complete a transaction you have requested or authorised.

We do not permit any third party to use biometric data for their own purposes.

7. Technical safeguards

We store, transmit and protect biometric data using a reasonable standard of care, at least as protective as the way we treat our other most sensitive information. This includes:

• Our own servers. Face processing runs on servers we control; capture frames are processed in memory and discarded.
• Encryption in transit. The app reaches our servers only over encrypted connections (TLS).
• Encrypted backups. Database backups are encrypted at rest.
• Restricted access. Embeddings are used only by the parts of our system that need them, and only a small number of authorised staff can access production systems. Staff actions in our admin tools are logged.

No system is perfectly secure. If a breach affects your biometric data, we will notify you and the authorities as the law requires.

8. Your rights and how to revoke consent

You may, at any time, and without giving a reason:

• Know what biometric data we hold for you and how we use it — email support@dlulu.app;
• Get a copy of your embeddings — we will send you a machine-readable copy on verified request;
• Correct your main-photo embedding by uploading a new main photo (your verified face stays as it was captured — write to us if you believe it is wrong);
• Delete your main-photo embedding by removing your main profile photo, or all of your face data by deleting your account in Settings;
• Withdraw consent by deleting your account (which removes all of your face data at once) — see below. Withdrawal does not affect the lawfulness of processing before withdrawal.

Deleting your main profile photo removes that photo’s embedding but keeps your verified face; to remove all of your face data, delete your account. Without a verified face you cannot verify new photos, and a new account that is never verified is deleted after 7 days as described in Section 3.

9. Changes to this consent

We may update this document, for example if we change a biometric feature, a retention period or a provider. We will publish the new version on this page with a new date. Before we use your face data for a new purpose, we will ask for your consent again.

10. Contact