Privacy Policy

1. Who we are

D Lulu is operated by QuantumShieldAI Pte. Ltd. (“D Lulu”, “we”, “us”, “our”), a company incorporated in Singapore (UEN 202650970C). For the purposes of the EU and UK GDPR and similar laws, QuantumShieldAI Pte. Ltd. is the controller of your personal information.

You can reach us about privacy, including our Data Protection Officer, at support@dlulu.app.

2. Scope of this policy

This policy applies to the D Lulu mobile application (iOS and Android), the website at dlulu.app (including the waitlist, the demo at /try and the business and ambassador portals), and any related services we operate (together, the “Service”). It does not apply to third-party services you may reach from the Service — those are governed by their own policies. The demo at /try runs in your browser with sample data; nothing you do in it is sent to us.

3. Information we collect

We collect only the information we need to run the Service. The categories are summarised below.

3.1 Information you give us

• Account identifiers — what you sign in with: a mobile phone number (we text you a code), an email address (we email you a 6-digit code), or your Google or Apple account (see Section 3.4). You need one of these; none of them is required on its own. You can add an email address later in Settings, which you can then also sign in with, and in countries where we offer it you can verify a phone number in Settings. If you add a passkey, your device keeps the private key; we store only its public key.
• Profile information — display name, date of birth (captured as birth month + year, used to enforce our 18+ minimum), gender, optional profession, bio text, and interests (up to 10, picked from our list — see Section 4.1).
• Photos — the profile photos you upload, photos you add for date cards, and the short live capture the app takes when you verify your face. Your face-verification capture and the photos we check against it are used to generate face embeddings (see Section 6).
• Optional private video intros — where this feature is offered, if you choose it and give its separate in-app consent, a 10–20 second recording made in the app, with audio only if you enable it. See the feature notice below.
• User-generated content — activities you publish (Hangout Now, Hangout Plan and Live), the place and time you choose for them, requests to join, check-ins, messages you send, reviews, answers, and reports you submit. Records from features no longer offered for new use (“Encounters”, Sealed Notes and the in-app AI assistant) are also covered where they still exist; see also Section 3 of our Terms of Service.
• Block lists — users, phone numbers, email addresses, or faces that you block.
• Your activity with businesses — the verified businesses you follow and your alert settings, whether you allowed a business to invite you, the invitations and announcements you receive and any you report, your place on a waitlist, and your answers to a business’s joining questions. See Section 7.1.
• Programmes, the waitlist and business accounts — see Sections 4.4 to 4.6.
• Support correspondence — the contents of any message you send us.

Optional private video intros

Feature notice: September 18, 2026. Where it is offered, this optional feature has a separate, unchecked consent control before recording. We compress your recording and extract five image samples to compare against your existing verified identity and run image-content checks. These checks do not create a new identity anchor, grant verification, review every video frame or analyse speech. They are not a guarantee that a person is safe or that a recording is live.

Your intro is not published on your profile or activity. Another person can watch only after you both explicitly agree to exchange the current intros for that activity. Depending on the selected mode, access begins before the meetup decision or after acceptance. Agreeing to an intro exchange does not itself accept an activity or reveal a hidden venue. A shared intro reveals your face and, if included, voice even when your profile photo is hidden or blurred. A viewer may record what they see; we cannot recall copies made outside the app.

You can replace or delete your intro, or stop sharing it for an activity. Replacing or deleting either intro, withdrawal, cancellation or blocking ends the corresponding access. Access also ends 24 hours after the activity. Playback already buffered on a device may remain briefly visible while access is rechecked.

Intro media is stored privately in our existing encrypted Amazon S3 storage. Original uploads are scheduled for permanent removal after processing; rejected, replaced and deleted media is also queued for permanent removal, including stored object versions. The current approved intro and its thumbnail remain until replacement, deletion or account erasure. Processing records for removed intros are deleted after 30 days once their media has been purged. Video-frame embeddings used for comparison are not added to your account.

3.2 Information collected automatically

• Location — your device’s location, when you allow it: when you sign in, when the app updates your position (for example when you open it), and when you publish an activity, go Live, check in or share your live location. We keep your latest position on your account, with the city and area it falls in — not a history of your movements. Activities keep the place and the area you chose for them. When you go Live, nearby members see an approximate position (offset by about 70 metres). Check-in compares your location with the other person’s at that moment; we keep only how far apart you were, not the coordinates. If you share your live location through “Share my plan”, we keep only the latest point, and delete it when sharing ends.
• Device information — device model, operating system version, app version, language, timezone, and an identifier the app creates for each installation.
• Device checks — when you verify your face, the app may ask Apple (App Attest) or Google (Play Integrity) to confirm that the request comes from the genuine D Lulu app on a real device. We keep the result and the key needed to check later requests, not anything else about your device.
• Log data — IP address, request timestamps, API endpoints called, error codes, and crash reports.
• Activity interaction counts — for each activity, how many times you tapped it, asked to join it or dismissed it in the app (views don’t count). These counts are used only to tell when to end the first-feed boost (see Section 4.1) and are deleted with your account.
• App usage statistics — which screens and features you use, for how long, and key steps such as saving a card or sending a plan, together with your plan, platform, app version and country, so we can see what works and fix what doesn’t. They never include what you type or your messages. They are kept on our own servers, except screen views and a few key steps (such as sign-up and subscriptions) that Google Firebase Analytics processes for us.
• Push notification tokens — the token Google Firebase Cloud Messaging gives your device (on iPhone, through Apple’s push service), so we can send you notifications you have opted in to.
• Purchase records — the fact that you subscribed to Plus or Premium, the product, its dates and the App Store or Play Store transaction identifier. We do not receive or store your payment card details — those remain with Apple or Google.

3.3 Biometric identifiers

When you verify your face, the app takes a short live capture of you while you follow a few on-screen steps. On our own servers we check that the capture shows a live person and use the AuraFace face-recognition model to turn it into a 512-number vector (a “face embedding”). That embedding becomes your verified face: the reference we compare your photos with, and the entry we use to keep to one account per person (see Section 6). We also compute embeddings from your main profile photo and from other photos we check against your verified face. The captured frames are not stored; we keep the embedding and the scores of the check. An embedding is a mathematical representation, not a photograph — it cannot be reversed into a recognisable image. See Section 6 and our standalone Biometric Data Consent.

3.4 Information from third parties

• Google and Apple sign-in — if you choose Sign in with Google or Sign in with Apple, that company tells us an identifier for your account, your email address and whether it has been verified, and your name if you choose to share it. Apple may give us a private relay address that forwards to your real email; we treat it like any other email address. We use your name only to suggest a display name, which you confirm or change, and we do not store it separately. We never receive your Google or Apple password. If you sign in with Apple, we may also receive a token that lets us cancel your Sign in with Apple authorisation when you delete your account; we store it encrypted and use it for nothing else.
• Age signals from Apple and Google — where your device supports it, the app asks Apple (Declared Age Range) or Google (Play Age Signals) whether you are an adult and sends us only the outcome (for example “adult”, “under 18” or “not shared”), its kind and the platform. We never receive your birthday or age range from them. See Section 4.3.
• Twilio delivers our SMS one-time passcodes and returns delivery status to us.
• Apple and Google confirm your subscription purchases, renewals and refunds.
• Firebase Crashlytics sends us crash stack traces if the app unexpectedly exits.
• Businesses on D Lulu — the staff of a business whose activity you joined can record at the door whether you arrived (see Section 7.1).
• Other members — for example when someone reports you, reviews a business activity you hosted, or invites you with their code.

4. How we use your information

We do not use your personal information for cross-context behavioural advertising, we do not sell it, and we do not run third-party advertising networks inside the app. Places marked “Sponsored” are paid for by businesses, not targeted using your personal profile. We also do not use your photos, messages, or any other user-generated content to train, fine-tune, or evaluate AI models — neither our own nor any third party's. See Section 8.1 below.

4.1 Your interests

You can pick up to 10 interests from our list. Interests typed in your own words are no longer kept: when this change went live, they were matched to our list where possible and the rest were deleted. We use your interests only to:

• Show them to other members — on your profile, to a host reviewing your request to join and on your hidden-identity profile, each in the reader’s language — and to you in the preview of your own activity. They are no longer sent with feed cards, map cards or activity details.
• Send Nearby hangouts alerts, only if you switch them on: notifications about activities near you that match your interests, what is active near you, and an evening summary.
• Rank your first feed — until you have 10 interactions of your own (taps, join requests and dismissals; views don’t count), activities that match your interests rank a little higher in your feed and lead “For you”. After that, what you do ranks your feed instead.
• Mark activities “For you” in the activity picker.

Your interests are not used for advertising, not shared outside D Lulu, and not used to decide who may join an activity — that is set by each host’s “Who can join” rules.

4.2 Activity creator rewards

The rules are in Section 7g of our Terms of Service. To run them:

• Who started a name. When your public activity is the first to use a new activity name, we record you as its creator, with the name, the date and that first activity.
• Counting. About once a day we count other members’ public activities that use your activity name where a guest checked in with the host. For each host and guest we check the conditions in the Terms: whether they verified their face with a live capture and are on their first D Lulu account, and whether either is an automated or test account, banned, suspended or being deleted. These checks read the result of earlier face verification; no new face scan or comparison is made. We store the totals (how many people, how many uses) and the reward levels reached, not who made each use.
• Issuing rewards. When a level is reached, we check that you can receive it and that you have not had 3 reward months in the past 12, then add a banked pass to your account and send you a notification. We also send one notification when you are halfway to Plus.
• Who sees what. Your progress is shown only to you. We do not name you publicly as an activity’s creator. Our staff see activities that reach the Plus level, with their creator and counts, to review them as possible official activities. Members whose activities count are never told whose activity they used, and you are never told who used yours.
• Deletion. When you delete your account, your reward passes are deleted, and the link to you and to your first activity is removed from any activity you started. The name, its date and its counts stay, because other members still use the activity.

4.3 Age checks

D Lulu is for adults only. You give us your birth month and year when you create your profile; we refuse anyone under 18, and the date cannot be changed later. Where your device supports it, the app also asks Apple or Google for an age signal and sends us only the outcome. If the outcome says you may be under 18, or you choose not to share it where we ask, we restrict your account until a later signal confirms you are an adult; a restriction for being under 18 also closes your live activities, requests and chats. We keep the latest outcome, its kind, the platform and when it was checked, and use them only to keep D Lulu adults-only and to meet our legal obligations — never for advertising or analytics.

4.4 Launch waitlist

If you join the waitlist on our website, we keep your email address, your country, when you joined and when you confirmed, and, for the launch offer, your place in line and whether you claimed it (see Section 7i of our Terms). We use them to confirm your address, email you once at launch, and run the offer. We do not keep your IP address with your entry. Every waitlist email has a link to leave the list, which deletes your entry; unconfirmed entries are deleted after 30 days. If we remove an entry for abuse, we keep it with the reason so it cannot take part in the offer.

4.5 Referrals, ambassadors and payouts

• Referrals. When you join with someone’s invite code, we record who invited whom and whether the conditions for a reward were met (such as a qualifying first meetup and face verification). To stop the same phone number earning a reward twice, we keep a one-way digest of the identity it was earned with (such as a phone number) for up to 400 days after the account is deleted.
• Ambassadors. If you apply to be an ambassador, we keep your application, the terms you accepted, your offers, targets and progress. For revenue share we calculate earnings from the Premium months of members who joined with your code; you see them only as anonymous entries (such as “Friend #1”) with their status, never their name or contact details.
• Payouts. To pay you, we keep the payout details you give us (legal name, country, bank details or PayNow ID, and optionally a tax ID), stored encrypted and visible only to our finance staff, and records of your earnings and payouts. We keep earning and payout records as long as tax and accounting law requires, also after you delete your account, without your name.

4.6 Business accounts

If you register or work for a business on D Lulu, we keep the business’s details (such as its name, legal name, registration number, address, contact email and phone, website and locations), who its owner, managers and staff are, its plan, invoices and payments, and records of its activities, offers, reviews and replies. To verify a business, we may check its registration number with an official business register (such as Singapore’s data.gov.sg or Japan’s National Tax Agency), send a code to its business email, or check its website. Members and the public can see a business’s public page, activities, offers and public reviews.

5. Legal bases (GDPR / UK GDPR)

For users in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under Article 6 GDPR:

Biometric data is a special category under Article 9 GDPR. We process it solely on the basis of your explicit consent, which you give in the app before your first face scan (and again when we add a new purpose). Deleting your main profile photo stops us using that photo’s embedding; deleting your account removes all of your face data, including your verified face, at once (see Biometric Data Consent).

6. Biometric information

Because biometric information is particularly sensitive, we keep the disclosure here brief and point you to our full, standalone Biometric Data Consent, which is our written policy and retention schedule under the Illinois Biometric Information Privacy Act (BIPA), Texas CUBI, Washington’s biometric identifiers law, and comparable laws.

• We extract a 512-dimensional face embedding from your live face-verification capture (your verified face) and from your photos, using the AuraFace model on our own servers. We never send face embeddings to anyone else.
• We use the embeddings to (a) check that the capture is of a live person and that your photos are of you, (b) keep to one person, one account, and (c) apply face blocks created before face blocking was withdrawn. Face blocking (blocking someone by a photo of their face) is no longer offered.
• 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 suspended and banned accounts; 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 are shown a review flag naming the two accounts and how similar they are. We never tell you, or anyone else outside our staff, which account a face matched. Your entry is deleted at once when you delete your account, unless the account is banned.
• Face verification is not an identity check: it does not confirm anyone’s name, age or background.
• We do not sell, lease, trade, or otherwise profit from biometric identifiers.
• We do not disclose them to any third party other than you, except to our hosting provider as our processor, or when required by a valid subpoena, court order or other legal obligation.
• Your verified face and its one-account entry are kept for the life of your account (and, for a banned account, while the ban lasts) and deleted at once when you delete your account. A photo’s embedding is deleted within 30 days after the photo is no longer in use, and at once when you delete your account. The maximum retention period is in any event three (3) years after your last interaction with the Service, as required by BIPA.

7. How we share information

We share your information only as described below.

• With other users, as the features you use require — for example your profile, photos and verification mark are visible to members who see your activities or requests, and while you are Live, nearby members within the reach you chose see your activity and an approximate location. Public reviews, and a business’s public page, can be seen by anyone.
• With people you choose, when you share a plan. “Share my plan” sends a private link to a meetup you are going to. Whoever has the link sees what you see of it — the activity, the time and place, and the other person’s first name and photo — until a few hours after the meetup, until you stop sharing, or until either of you blocks the other or deletes their account. We count how often the link is opened; we keep nothing about who opened it.
• With the hosts of an activity you ask to join. “Host” means the person who created the activity and any co-hosts they accepted. The hosts can see your request and accept or decline it. A private video intro, and a request to join an activity whose creator hides their identity, are seen only by the creator.
• With businesses on D Lulu, only as described in Section 7.1 — never your phone number, email address or any other contact detail.
• With service providers (processors) who run infrastructure on our behalf — see Section 8.
• For safety and legal compliance, where we reasonably believe disclosure is necessary to comply with law or a valid legal request, enforce our Terms, detect fraud, establish or defend legal claims, or protect the rights, property, or safety of D Lulu, our users, or the public — including with law enforcement and child-safety authorities.
• Within our group and in a corporate transaction — with companies under common control with us, and with a buyer or successor in a merger, acquisition, financing, reorganisation or sale of assets, who will be bound to protect your information as this policy describes. Where the law requires it, we will tell you.
• With your consent, or at your direction.

We never sell personal information as that term is defined under the California Consumer Privacy Act. We do not share it for cross-context behavioural advertising.

7.1 Businesses on D Lulu

Verified businesses host activities on D Lulu. This section explains what we keep, and what a business sees, when you follow one, join its activities or hear from it. A business never receives your phone number, email address or any other contact detail, and cannot export a list of members.

• Following a business. When you follow a verified business, we store that you follow it and your alert settings. The business sees how many people follow it, never who. You can unfollow at any time in Settings › Businesses.
• Invitations from past visits. After you attend a business’s activity, we may ask whether that business may invite you to future activities. Only if you say yes, the business can see your D Lulu name and profile photo, how many of its activities you attended and when, and which ones — never your phone number, email address or any other contact detail — and can send you invitations to its upcoming activities through D Lulu (at most one every 7 days). You can change your answer at any time in Settings › Businesses.
• Announcements. Businesses you follow, and businesses you allowed to invite you, may send you short announcements through D Lulu (at most one a day per business). You can stop them from any announcement or in your notification settings, and report one that is spam, offensive or misleading; D Lulu may review reported or held announcements.
• Joining questions. A business may ask a few questions, or ask you to accept a statement, before you join its activity. Your answers are seen by you and by the staff of that activity only — never by other guests. We check written answers for contact details and links on our own servers; they are not sent to our moderation providers.
• Waitlists. When a business activity is full you can join its waitlist. We keep your place in line and any offer of a place made to you. The business’s staff see the waitlist in order, with the names and photos they would see for people asking to join.
• Attendance at business activities. When you join an activity hosted by a verified business on D Lulu, the business’s staff can mark at the door whether you arrived. If you join a business activity and do not arrive, or you release your place after a cancellation deadline the business published before you joined, we keep a private note of it. Each note counts for 90 days, then half for another 90 days, and then no longer counts at all; it is deleted 365 days after the activity. You can see everything we keep about this, and when each item stops counting, in the app.
• What businesses see. Businesses never see your notes, a count or a score. On the lists of their own activities (their door list, waitlist and guest list), staff see only whether you are marked “reliable” — someone who has attended at least two business activities in the past year without recent misses. Nothing about this appears on your profile or is shown to other members. A business may say that people who did not show up may be declined next time; D Lulu never declines anyone automatically because of it.
• Who marked it. Door marks are recorded with the staff member who set them so the business can correct mistakes.
• LINE (Japan). A business in Japan may show a link to its LINE Official Account. Opening it takes you to LINE, whose own terms and privacy policy apply; D Lulu does not share your data with LINE.
• When you delete your account, we delete your follows, your answers about invitations, the invitations and announcements you received, the reports you made, your waitlist places, your answers to joining questions, your door marks and your attendance notes. If you were a business’s staff member, the marks you set stay with the business without your name.

8. Third-party processors and services

We use a short list of service providers. Processors act on our instructions under their contract or terms with us, which limit their use of your information to providing the service to us. We do not allow any of them to use your photos or messages to train AI models. See Section 8.1.

Maps in the app are shown by Apple Maps or Google Maps on your device, under their own terms. Official business registers we check are run by public authorities.

Chat messages are not end-to-end encrypted. They are encrypted in transit (TLS), but they are stored in a form our systems can read, and before they are sent they pass through an automated check on our own servers that looks for abusive or offensive words (nothing is sent to an outside service). Our authorised staff can access messages where needed for safety, to investigate a report, or when the law requires it. Please do not use D Lulu chat for anything you would not want a moderator to be able to read.

An earlier version of this policy described client-side end-to-end encryption (X25519 + AES-256-GCM) for the Encounters and Sealed Notes modules. That mechanism has been removed from the product, because encrypted messages bypassed the very safety checks that protect against doxxing and harassment. No chat in D Lulu is end-to-end encrypted today.

8.1 No AI training on your data

We make this commitment: we do not train, fine-tune, or evaluate AI / machine-learning models on your photos, messages, profile content, location, or any other personal information you provide to D Lulu. We also do not sell, license, or otherwise transfer your photos to any party for the purpose of training or evaluating AI models.

The AI we do use:

• Image-content moderation (AWS Rekognition). Photos are passed to Rekognition’s pre-trained DetectModerationLabels API at upload time for the sole purpose of detecting nudity, violence, hate symbols, and drug content.
• Text moderation and older features (OpenAI). Text you publish is checked with OpenAI’s moderation service before it appears, without your name or account details. Features no longer offered for new use (Encounters and the in-app assistant) also used OpenAI. OpenAI’s API terms state that it does not use API inputs or outputs to train its models. We do not send your photos to OpenAI.
• The face-embedding system used for verification and one account per person (AuraFace). This runs entirely on our own servers; the model is pre-trained, frozen, and not fine-tuned on user data. We never transmit face embeddings to a third party. See our Biometric Data Consent.
• On-device and local models. Some features, such as matching activity names, use models that run on our own servers or on your device.

If we add known-CSAM hash matching (such as Microsoft PhotoDNA or Thorn Safer), or another AI provider that receives personal information, we will update this Section first. We will not use existing user data for a new AI purpose that the law requires your consent for without asking you.

9. International data transfers

Our primary servers are in Singapore (AWS ap-southeast-1), and encrypted backups of our database are kept in Australia (AWS ap-southeast-2). Some of our providers are located in the United States, Europe or elsewhere (see Section 8). When your personal information is transferred outside the jurisdiction in which you are located, we rely on one or more of the following safeguards, as the law where you are requires:

• Standard Contractual Clauses approved by the European Commission (for EU/EEA personal data), as updated from time to time, or an adequacy decision;
• The UK International Data Transfer Addendum;
• For Singapore residents, contractual or other legally enforceable obligations that give a comparable standard of protection to that under the PDPA;
• Where no other safeguard applies, the transfer being necessary to provide the Service you asked for, or your consent.

You can request more information about the safeguard for a transfer by emailing support@dlulu.app.

10. Retention schedule

We keep personal information only as long as we need it for the purposes in this policy. The times below are the latest it can take.

When you delete your account, it disappears from D Lulu at once and your face data is deleted. We keep your account details, chats, meetups, check-ins and reports for 90 days so we can handle safety reports and legal requests, then delete them for good — longer only while a report or legal request involving the account is open. Until then, only our safety staff can see them, and the other person in a chat keeps the conversation read-only, shown as “Deleted account”. Other data this policy says is deleted with your account is also deleted at the end of the 90 days. Deletion cannot be undone; you can make a new account later unless you were banned.

We may keep information longer where the law requires it, to resolve disputes or legal claims, or to protect someone’s safety.

11. Security

We take reasonable and appropriate security measures, including:

• TLS encryption for all data between the app or website and our servers;
• Encryption at rest for stored photos, database backups, ambassador payout details and Sign in with Apple tokens;
• Chat messages encrypted in transit — but not end-to-end encrypted; see Section 8;
• Access controls — only a small number of authorised staff can access production systems, and staff actions in our admin tools are logged;
• Rate limiting, input validation, and monitoring on our APIs;
• One-time-code sign-in (SMS codes are checked by Twilio; email codes are stored by us only as one-way digests), passkeys, or Sign in with Google / Apple, with session tokens kept in Keychain / Keystore on your device.

No system is perfectly secure, and we cannot guarantee the security of information you send us. Keep your device and sign-in methods secure. If we learn of a personal data breach that presents a risk to you, we will notify you and the relevant supervisory authority as required by applicable law.

12. Your rights

Depending on where you live, you may have the following rights:

• Access — a copy of the personal information we hold about you (GDPR Art. 15, CCPA §1798.110, PDPA §21).
• Rectification — correction of inaccurate or incomplete information (GDPR Art. 16, CCPA §1798.106, PDPA §22).
• Erasure — deletion of your personal information (GDPR Art. 17, CCPA §1798.105).
• Portability — a structured, machine-readable copy (GDPR Art. 20, CCPA §1798.100).
• Restriction — limitation of processing in defined circumstances (GDPR Art. 18).
• Objection — to processing based on our legitimate interests (GDPR Art. 21).
• Withdraw consent — at any time, for any processing based on consent (GDPR Art. 7(3)), without affecting processing before you withdrew it.
• Lodge a complaint with a supervisory authority. Singapore users may contact the Personal Data Protection Commission (pdpc.gov.sg). EU users may contact their national data protection authority.

You can see and correct your profile, change your sign-in methods and notification settings, and delete your account in the app. For anything else, including a copy of your data, email support@dlulu.app. Before acting on a request, we verify your identity, for example with a one-time code sent to your phone number or email address, or by asking you to sign in to the app. We respond within the time the law requires (usually one month). These rights have limits set by law: for example, we may keep information we must keep by law or need for a legal claim, and we will not give you information about other people.

13. California and other US states

If you are a California resident, you have the rights listed above and, in addition:

• Right to know the categories and specific pieces of personal information we have collected about you in the preceding 12 months, the sources, business purposes, and the categories of third parties to whom we disclose that information. The categories, sources, purposes and recipients are those described in Sections 3, 4, 7 and 8.
• Right to non-discrimination — we will not deny you services, charge different prices, or provide a different level of quality because you exercised your rights.
• Right to limit use of sensitive personal information. We treat the following as “sensitive personal information” under the CPRA: precise geolocation, account log-in credentials, biometric information processed to identify you, and the contents of your messages. We use these categories only for the purposes set out in Section 4 — not for inferring characteristics about you. You can nonetheless ask us to further limit use by emailing support@dlulu.app.

We do not “sell” or “share” personal information as those terms are defined under the CCPA/CPRA and we have not done so in the preceding 12 months. Residents of other US states with privacy laws (such as Colorado, Connecticut, Texas, Utah and Virginia) have similar rights to access, correct, delete and obtain a copy of their information, and to opt out of sale, targeted advertising and profiling — which we do not do. You or an authorised agent can make a request at support@dlulu.app; if we decline it, you can appeal by replying to our decision, and if you disagree with the outcome you may contact your state attorney general.

14. Singapore residents (PDPA)

Under the Singapore Personal Data Protection Act 2012 you have the right to request access to, and correction of, personal data we hold about you, and to withdraw consent on reasonable notice. You may contact our Data Protection Officer at support@dlulu.app. If you are not satisfied with our response, you may complain to the Personal Data Protection Commission of Singapore.

15. Minors

D Lulu is strictly for users aged 18 and over, and we do not knowingly collect personal information from anyone under 18. We collect month and year of birth at sign-up, refuse anyone under 18, and use age signals from Apple and Google where available (see Section 4.3). If we learn that a user may be under 18 — through an age signal, a report, self-disclosure or otherwise — we restrict the account and may close it and delete its personal information, including any biometric data. Refunds of subscriptions bought through Apple or Google are handled by them under their policies. If you believe someone under 18 is using D Lulu, please report it in the app or email support@dlulu.app.

16. Changes to this policy

We may update this policy from time to time. We will publish the new version on this page with a new “Last updated” date and the date it takes effect. If a change is material, we may also tell you in the app or by email (if you have given us one), and where the law requires your consent to a change, we will ask for it. If you keep using the Service after the effective date, the updated policy applies.

Previous versions are available on request.

17. Contact