Dualy Privacy Policy

Introduction

Dualy is a Communal Media platform (“Dualy,” “we,” “us,” or “our”) that lets creators connect with fans through synchronized dual-camera video, Ticketed Rooms™, tipping, Dualy Coins™, and Social Posting, and lets creators get paid before they go viral™. This Privacy Policy describes how we collect, use, disclose, and safeguard information when you use our website, mobile applications, and related services (collectively, the “Service”), whether you use Dualy as a fan, a creator, or both.

1. Scope of This Policy

This Policy applies to all users of the Service worldwide. Where local law provides additional or different rights — for example under the EU/UK General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”), or other U.S. state privacy laws — the applicable sections below describe those rights and how to exercise them.

2. Information We Collect

2.1 Information You Provide Directly

• Account Information: Name, email address, phone number, date of birth, profile picture, username, and password.
• Identity Verification Information: For creators and anyone participating in monetized features, we (or our identity-verification vendors) collect government-issued identification, a selfie or short video for liveness/identity matching, and date of birth, to confirm you are who you say you are and that you meet the age requirements described in Section 10.
• Content: Videos, images, chats, comments, and other content you create, post, or share through Dualy, including content shared during live sessions and Ticketed Rooms.
• Creator and Payout Information: If you register as a creator, we collect information needed to enable monetization and pay you, such as your legal name, address, tax identification information (e.g., a W-9, W-8BEN, or local equivalent), and bank or payment account details. This information is collected and processed on our behalf by our payment processing partners.
• Agency and Talent Representation Information: If you are represented by a talent or management agency (for example, through an agency partnership on Dualy), we may collect information confirming that representation and information needed to calculate and pay agency commissions.
• Communications: Information you provide when you contact customer support, respond to surveys, or otherwise communicate with us.

2.2 Information We Collect Automatically

• Device Information: Device type, operating system, IP address, browser type, mobile network information, and device identifiers.
• Usage Data: How you interact with the Service, such as features used, profiles visited, sessions joined, referral source, and time spent on the app.
• Monetization Activity: Information about your use of paid features, including Ticketed Rooms sessions joined or hosted, seat rotations, Dualy Coins purchased, gifted, or redeemed, tips sent or received, and subscription tier.
• Location Information: Approximate location derived from your IP address, and precise location if you enable location services and grant permission.
• Cookies and Similar Technologies: Information collected via cookies, SDKs, pixels, and similar tracking technologies, described further in our Cookie Policy where applicable.

2.3 Biometric Information

Because Dualy's core “See What I See™” synchronized dual-camera experience and Ticketed Rooms involve live video of your face and voice, some jurisdictions (including Illinois under the Biometric Information Privacy Act, Texas, and Washington) classify certain identifiers derived from that video — such as facial geometry used for identity verification or content moderation — as biometric identifiers or biometric information. Where this applies:

• We collect and use biometric identifiers only for identity verification, account security, fraud prevention, and content moderation (for example, detecting impersonation or policy violations).
• We do not sell, lease, trade, or otherwise profit from biometric identifiers or biometric information.
• We do not disclose biometric identifiers to third parties except to identity-verification and content-moderation vendors acting on our behalf, or as required by law.
• We retain biometric identifiers only as long as necessary to fulfill the purpose for which they were collected, or as required by law, and we permanently destroy them within a reasonable time (and no later than any applicable statutory deadline) after that purpose has been satisfied or your account is closed, whichever comes first.

If you are located in a jurisdiction with a specific biometric privacy law, we will provide any additional required notice and obtain any required written consent before collecting your biometric identifiers.

2.4 Information from Third Parties

• Social Media: If you link your account to social media platforms, we may collect your profile information.
• Service Providers: Data from third-party tools used to analyze or enhance the Service, including our payment processing, identity verification, and payout partners.
• Talent Agencies and Partners: If you are onboarded to Dualy through a talent agency or partner program, we may receive information about you from that agency or partner in connection with your account setup and commission arrangements.

3. Legal Bases for Processing (EEA/UK Users)

If you are located in the European Economic Area or United Kingdom, we rely on the following legal bases to process your personal data:

• Performance of a contract: to create your account, provide the Service, and process payments and payouts.
• Legitimate interests: to secure the Service, prevent fraud, moderate content, and improve our products, balanced against your rights and interests.
• Consent: for optional cookies, certain marketing communications, and biometric processing where consent is the applicable legal basis.
• Legal obligation: to comply with tax, financial, and other regulatory requirements.

4. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve the Service, including Ticketed Rooms, Social Posting, and Dualy Coins features.
• Verify identity and eligibility to use monetization features.
• Customize your experience and recommend content or creators.
• Process payments, calculate and issue creator payouts, and apply applicable platform and agency fees.
• Communicate with you, including sending updates, support messages, and promotional materials.
• Moderate content and enforce our Community Guidelines and Terms of Service, including detecting and removing content that violates our policies.
• Ensure the security of the Service and prevent fraud, including fraudulent Ticketed Rooms or Dualy Coins activity, chargebacks, and account takeovers.
• Comply with legal obligations, including tax reporting obligations related to creator earnings, and respond to lawful requests from public authorities.

5. How We Share Your Information

We may share your information as follows:

• With Your Consent: When you agree to share your information with third parties.
• Payment and Payout Processors: With third-party payment processors that facilitate purchases, subscriptions, and creator payouts, including Stripe and regional payout partners such as Startbutton.africa, Cashfree, and dLocal, depending on your location.
• Identity Verification Vendors: With vendors who verify identity and age on our behalf.
• Talent Agencies and Brand Partners: With a creator’s talent agency or authorized brand partners solely as needed to administer agency agreements, commissions, and brand partnerships the creator has entered into.
• Service Providers: With trusted third parties that provide services on our behalf, such as hosting, analytics, and customer support, under contractual confidentiality and data-protection obligations.
• Legal, Safety, and Law Enforcement: When required by law, subpoena, or court order, or when we believe in good faith it is necessary to protect the rights, property, or safety of Dualy, our users, or the public, including reporting content that may involve child exploitation, threats of violence, or other illegal activity to appropriate authorities such as the National Center for Missing & Exploited Children (NCMEC), as legally required.
• Business Transfers: In the event of a merger, acquisition, financing, or sale of assets, your information may be transferred as part of that transaction.

We do not sell your personal information for money. As described in Section 8, certain uses of cookies and similar technologies may be considered a “sale” or “share” under some state laws, and you can opt out as described below. We do not share a creator’s payout, tax, or verification information with other users of the Service.

6. Data Retention

We retain personal information for as long as necessary to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements. As a general matter:

• Account and profile information is retained for as long as your account is active. After a verified account deletion request, we hide the account and deactivate access promptly. You can reactivate it by logging in during a 30-day recovery period. If you do not reactivate it, permanent deletion or irreversible anonymization begins after that period and is ordinarily completed promptly.
• Payout, tax, and financial records are retained for the period required by applicable tax and financial recordkeeping laws (typically several years after the relevant transaction).
• Identity verification records are retained only as long as necessary for verification, fraud prevention, and legal compliance purposes.
• Biometric identifiers are retained and destroyed as described in Section 2.3.
• Content associated with your account is hidden during the recovery period and then deleted or irreversibly anonymized as part of terminal account deletion, except where limited preservation is required for an active safety, fraud-prevention, legal, or regulatory matter.

When personal information is no longer needed for these purposes, we delete or anonymize it in accordance with our internal retention schedules.

7. Your Privacy Rights

7.1 General Rights

• Access and Update: You can access or update your account information at any time.
• Data Deletion: You can request deletion of your account and associated data through Dualy Settings or our account deletion page. You can also request deletion of specific data without closing your account through our data deletion page.
• Marketing Opt-Out: You can opt out of receiving promotional emails by following the unsubscribe link in those emails.
• Cookie Preferences: Adjust your browser or device settings, or use our cookie preference tool, to limit or block non-essential cookies.

7.2 Deleting Your Account

You can request account deletion from the Settings page in the Dualy app or at our public account deletion page. We verify that the requester controls the account before acting on the request. Do not send us your password, one-time code, or payment credentials.

After verification, we hide the account and deactivate access promptly. You can cancel deletion by logging in during the 30-day recovery period. If you do not reactivate the account, permanent deletion or irreversible anonymization of associated profile information, uploaded content, social connections, messages, and app activity begins after that period and is ordinarily completed promptly. Deletion cannot be reversed after terminal processing begins.

We may retain narrowly limited records for the period required by tax, accounting, fraud-prevention, safety, dispute, or other legal obligations. Retained records are restricted to those purposes and are not used to continue providing the account.

7.3 California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to:

• Know what personal information we have collected, used, disclosed, and (if applicable) sold or shared about you, and the categories and sources of that information.
• Delete personal information we have collected from you, subject to certain exceptions.
• Correct inaccurate personal information.
• Opt out of the “sale” or “sharing” of your personal information, including sharing for cross-context behavioral advertising through cookies and similar technologies.
• Limit the use and disclosure of sensitive personal information (such as precise geolocation or government ID) to purposes necessary to provide the Service.
• Not receive discriminatory treatment for exercising any of these rights.
• Designate an authorized agent to make a request on your behalf.

To exercise these rights, contact us using the details in Section 18, or use the “Do Not Sell or Share My Personal Information” link described in Section 8. We will verify your request using information associated with your account before responding.

7.4 Other U.S. State Privacy Rights

If you are a resident of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, or another state with a comprehensive consumer privacy law, you generally have the right to confirm whether we process your personal data, access and obtain a copy of it, correct inaccuracies, delete it, and opt out of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. You may exercise these rights by contacting us as described in Section 18; we will not discriminate against you for exercising them, and you may appeal a denied request using the process we provide in our response.

7.5 EEA/UK Rights (GDPR)

If you are located in the EEA or UK, you have the right to access, correct, delete, restrict, or port your personal data, to object to processing based on legitimate interests or direct marketing, and to withdraw consent at any time where processing is based on consent. You also have the right to lodge a complaint with your local data protection authority.

8. Do Not Sell or Share My Personal Information

We do not sell personal information in exchange for money. Certain advertising and analytics cookies may result in a “sale” or “sharing” of information as those terms are broadly defined under some state laws. You can opt out at any time by using the cookie preference tool in the Service, adjusting your device’s advertising ID settings, or submitting a request to info@dualy.co with the subject line “Do Not Sell or Share My Personal Information.” We will honor recognized opt-out preference signals (such as the Global Privacy Control) where required by law.

9. Content Moderation, Trust & Safety, and Law Enforcement

We review reported content and use automated and human moderation to enforce our Community Guidelines and Terms of Service, including for content involving harassment, non-consensual imagery, impersonation, and other prohibited conduct. We may preserve, review, and disclose account and content information, including in Ticketed Rooms and Social Posting, in response to valid legal process or where we have a good-faith belief it is necessary to prevent harm, and we will report content involving apparent child sexual abuse material to NCMEC or other legally designated authorities as required by law. We may suspend or terminate accounts that violate our policies.

10. Age Verification and Eligibility

Dualy is not intended for children under the age of 13, and creators participating in monetized features must meet the minimum age required by applicable law (generally 18, or the age of majority in their jurisdiction) and complete the identity verification described in Section 2.1. We use identity-verification vendors to confirm age and identity for monetized accounts and may deny, suspend, or terminate access to monetization features if verification cannot be completed or is found to be inaccurate.

11. Data Security

We use appropriate technical and organizational measures to protect your data, including payment, payout, and identity-verification information, which is handled through PCI-compliant and otherwise appropriately certified third-party processors and vendors. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

12. Breach Notification

If we become aware of a security incident that compromises your personal information in a manner requiring notification under applicable law, we will notify you and, where required, relevant regulators without undue delay and in accordance with applicable legal timelines.

13. International Data Transfers

Dualy operates globally, and your information may be transferred to and processed in countries other than your own, including the United States and the countries where our payment, payout, and identity-verification partners operate. These countries may not have the same data protection laws as your jurisdiction. Where required, we use appropriate safeguards, such as Standard Contractual Clauses, to protect information transferred internationally.

14. Children's Privacy

Dualy is not intended for children under the age of 13, and our monetization features are not intended for anyone under the age of majority in their jurisdiction. If we learn that we have collected personal information from a child under 13 without verified parental consent, we will delete that information promptly.

15. In-App Purchases and Creator Monetization

Dualy offers optional in-app purchases and monetization features, including subscription tiers, Dualy Coins, tipping, and Ticketed Rooms. If you make a purchase or participate in monetization on Dualy:

• Payments are processed securely through the Apple App Store, Google Play Store, or our third-party payment processors (including Stripe and regional partners such as Startbutton.africa, Cashfree, and dLocal).
• We do not store your full payment card information; payment credentials are handled directly by the relevant app store or payment processor.
• Subscriptions will auto-renew unless you cancel at least 24 hours before the end of the current billing period.
• You can manage or cancel your subscription through your device’s account settings.
• Creator payouts, including revenue from Ticketed Rooms, tips, and Dualy Coins, are subject to applicable platform fees and, where applicable, agency commission arrangements, and are issued through our payout partners.

Please review the applicable app store's payment and subscription terms, and any applicable creator or agency agreement, for more details on billing, renewal, payouts, and cancellation.

16. SMS Communications

By providing your mobile phone number and opting in, you agree to receive SMS messages from Dualy, which may include:

• Account-related updates
• Transactional notifications (e.g., password resets, payout confirmations)
• Promotional messages and offers

Message and data rates may apply. You can opt out of SMS communications at any time by replying “STOP” to any message or contacting us directly at info@dualy.co.

We do not share your phone number with third parties for marketing purposes without your explicit consent.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect new features such as additional monetization tools or payment partners. We will notify you of material changes by posting a notice on the Service or contacting you directly, and will update the “Last Updated” date above. Your continued use of the Service after changes take effect constitutes your acceptance of the updated policy.

18. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact us at:

California and other state residents may also exercise their rights using the contact method above; authorized agents must include proof of authorization.