Effective Date: July 3, 2025
Last updated: Oct 30, 2025

s Privacy Policy describes how Thuli Studios, Inc. (“Thuli Studios,” “DYLA,” “we,” “us,” or “our”) collects, uses and discloses information about you when you use our website (https://www.dyla.ai) (the “Website”) and our related mobile application (the “App”). The Website and any content, tools, features and other functionalities offered on or through our Website and App are collectively referred to as the “Services” and “you” and “your” means you as the user of the Services. For the purposes of this Privacy Policy, we are the controller in respect of any personal information processed in connection with the Services. 

Please read this Privacy Policy carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not understand or agree to this Privacy Policy, please do not use or access the Services. 

1. CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Policy. If we make material changes to how we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Website or App or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Policy, please do not continue using or accessing the Services.

2. COLLECTION AND USE OF INFORMATION

When you use or access the Services, we collect certain categories of information about you from a variety of sources. In addition to the specific uses discussed below, we may use this information to provide and improve the Services and to maintain our business relationship, including by enhancing the safety and security of our Services, providing customer support, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting our rights and the rights of our employees, users, or other individuals.

A. Information You Provide to Us

Some features of the Services require you to directly provide certain information, including information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services is processed in order to perform our contract with you and includes:

• Contact information, such as your name, phone number, and email address.

• Account information, such as account handle and other information you add to your account.

• Payment and subscription information, handled via the app store and not stored by us.

2.A. Photos, Selfies, and Face Data (“Face Twin” Images)

To enable DYLA’s virtual jewelry try-on and personalization features, we collect photos or selfies that you upload or capture through the app’s camera. These images are used to generate your personalized AI face twin — a digital likeness that allows you to preview jewelry realistically on your face.

What we collect:
Only the images you voluntarily upload or capture through the App. DYLA does not extract or store biometric identifiers, facial geometry templates, depth maps, or 3D scans, and does not analyze face data for identity verification or authentication.

How we use this data:

• To create and maintain your AI face twin.

• To display jewelry accurately in virtual try-ons.

• To improve realism and personalization of your user experience.

This data is not used for identity verification, advertising, analytics unrelated to try-on, or tracking across other apps.

Sharing and storage:
Your face images are not shared with advertisers, analytics vendors, or data brokers.
They are stored securely on encrypted servers hosted by trusted cloud-infrastructure providers (Google Cloud Platform, AWS, or equivalents) located in the United States and India.
These providers operate under strict confidentiality and data-protection obligations.

Retention and deletion:
We retain your face images and generated AI face twin in the app only while your account remains active. If you delete your account or email us hello@thuli.studio to request deletion, your photos and AI face-twin data will no longer appear in the app. They will also be permanently deleted from all our systems within 30 calendar days of your request.

Summary:

Purpose - Personalized virtual jewelry try-on; realism and fit accuracy

Shared with - Only secure cloud providers (no advertisers or brokers)

Stored in - Encrypted storage on Google Cloud / AWS (U.S. & India)

Retained - While account active; deleted upon user request or account deletion

This section corresponds to Sections 4 (Disclosure of Information), 8 (Data Retention), and 11 (Contact Us) for further details.

B. Information Collected Automatically

We and third parties also automatically collect certain information about your interactions with the Services, including through cookies and other tracking technologies. Where required by applicable law, we obtain your consent to process this information. This information is collected and used to tailor your experience with the Services (such as to recommend different products and help you discover brands that you may like), run analytics, and better understand user interactions with and improve the Services. Such information includes: 

• Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.

• Location information, such as approximate location based on your IP address and, if you choose to provide it, precise geolocation of your device when you access the Services. 

• Other information regarding your interaction with the Services, such as products and brands that you express an interest in, links that you click on and other clickstream data, log data, date and time stamps, browser type, interactions with marketing communications, and ad impressions. 

For more information on certain tracking technologies, including cookies and pixels, see the section below, Cookies and Other Tracking Technologies. 

C. Information Collected From Other Sources

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes: 

• Information we receive from login integration partners, such as when you access the Services through Facebook or Google, which we use to maintain your account and login information. These partners provide information such as your name, email address, and additional account information that is publicly accessible. 

• Business partners, including clothing merchants or fashion brands that you may use the Services to access or purchase products from. These partners may provide confirmation that you made a purchase of their product and provide other basic information about your order (such as the value of it and the product purchased), but we do not receive or handle any of your payment information. We use this information to manage our relationship with users and business partners, to help us make more informed product recommendations, and to better understand user interactions with the Services. 

• Information we receive from social media platforms, such as when you interact with us on Instagram or TikTok, which we use to communicate with you and personalize our Services. 

Any information we receive from outside sources will be treated in accordance with this Privacy Policy. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third-Party Websites and Links.

D. De-identified Information

Finally, we may deidentify your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been deidentified), and we may use such deidentified information for any purpose.

3. COOKIES AND OTHER TRACKING TECHNOLOGIES

We and third parties may use tracking technologies, including cookies and pixels, to collect information about your browsing activities on the Website. Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of cookies. If you so choose, you may block or delete certain of our cookies from your browser; however, blocking or deleting cookies may cause some features of the Website, including any portal features and general functionality, to work incorrectly. 
Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our Website is not designed to respond to “Do Not Track” signals received from browsers.

4. DISCLOSURE OF YOUR INFORMATION

We may disclose your information for legitimate purposes subject to this Privacy Policy, including the following categories of third parties:

• Service providers who host and secure the Services (including cloud storage providers for user-uploaded photos and face twin data).

• Analytics, system administration, and communication vendors as necessary to operate and improve the App.

• Business partners such as jewelry brands or merchants only with your consent.

• Affiliates, advisors, or regulators as required by law or legitimate business necessity.

Face images and AI face-twin data are never shared with advertisers, analytics vendors, or data brokers.

We may disclose your information for legitimate purposes subject to this Privacy Policy, including the following categories of third parties: 

• Vendors or other service providers who help us provide the Services in order to perform our contract with you and in our legitimate interests, including for analytics, system administration, cloud storage, security, customer relationship management, marketing communications, and the deployment of Tracking Technologies. 

• Business partners, such as clothing merchants and fashion brands whose products you may access through the Services, with your consent where required by applicable law. 

• Our affiliates or others within our corporate group, in our legitimate interests. 

• Third parties with your consent when you request or direct us to disclose information, such as through your use of login integration. 

• Professional advisors, such as auditors, law firms, or accounting firms in our legitimate interests or where required by applicable law. 

• Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction in our legitimate interests. 

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users. 

The information that we collect from you may be accessed from, transferred to, and stored and used in countries outside the country in which you are located. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy. 

Transfers of data outside the European Economic Area (EEA) or the UK to a country that has not been determined as “adequate” by the European Commission (EC) or UK authorities will be governed by the EC’s standard contractual clauses for the transfer of personal data to third countries or the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses (as applicable). Please contact us at hello@thuli.studio should you wish to examine a copy of the EU standard contractual clauses or UK international data transfer addendum.

5. SOCIAL FEATURES

Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features may include features that allow you to access our pages on third-party platforms, and from there to “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section below, Third-Party Websites and Links.

6. YOUR RIGHTS

Depending on where you live, you may have certain rights in relation to your information: 

• Access. The right to access the information we hold about you, how we use it, and who we share it with. 

• Portability. The right to receive a copy of certain information we hold about you and to request that we transfer it to a third party. 

• Correction. The right to correct your information we hold that is inaccurate. 

• Erasure. The right to delete the information we hold about you. 

• Restriction of processing to storage only. The right to require us to stop processing the information we hold about you, other than for storage purposes. 

• Objection. The right to object to our processing of your information. 

• Objection to marketing. The right to object to marketing at any time by opting-out using the unsubscribe/opt-out function displayed in our communications to you or by emailing hello@thuli.studio. 

• Withdrawal of consent. Where we rely on consent to process your information, you have the right to withdraw this consent at any time by emailing hello@thuli.studio. 

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, if fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, if there are overriding public interests or if we are required by law to retain your information. 

To exercise any of these rights, you can contact hello@thuli.studio. If you think we have infringed data protection laws, you have the right to lodge a complaint with the data protection supervisory authority in the EEA country in which you are based or where you think we have infringed data protection laws, or with the UK Information Commissioner’s Office, as applicable to you. 

7. THIRD-PARTY WEBSITES AND LINKS

We may provide links to third-party websites or platforms, such as clothing merchants or fashion brands. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

8. DATA RETENTION

We retain personal information, including uploaded face images, only as long as your account is active or as needed to provide our Services. Upon account deletion or verified user request, we permanently erase the related data — including photos, AI face-twin, and associated records — from our systems and backups within 30 calendar days. 

Face data is never retained indefinitely. This limited retention period allows us to ensure secure deletion across all systems, including encrypted backups and logs. We may continue to retain de-identified or aggregated data that cannot reasonably identify you.

9. CHILDREN’S PRIVACY

Our Services are not intended for children, and we do not seek or knowingly collect any personal information about children. If we become aware that we have unknowingly collected information about a child, in particular any child under 13 years of age, we will make commercially reasonable efforts to delete such information from our database. If you are the parent or guardian of a child under 13 years of age who has provided us with their personal information, you may contact us using the below information to request that it be deleted.

10. DATA SECURITY

We store face images and all personal information in encrypted form using industry-standard cloud-security protocols (e.g., Google Cloud / AWS). Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information. 

11. HOW TO CONTACT US

For any questions, or to request deletion of your photos, face twin, or other personal information, contact: 📧 hello@thuli.studio