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Privacy Policy

Last updated July 2026

Introduction

At Dark Zorse Ltd (trading as Tulo) ("we", "our", "us", or "Tulo"), protecting your personal data is our priority. This privacy policy ("Privacy Policy") governs how we use, collect, and store personal information that we collect or receive from or about you ("you") in connection with https://tulo.co and the services provided (the "Services").

We take your privacy seriously. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data.

Tulo provides a cryptocurrency accounting subledger platform. We help businesses aggregate blockchain data and integrate it with their accounting systems.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.

Table of Contents

  1. What Information We Collect, Why We Collect It, and How We Use It
  2. How We Protect and Retain Your Personal Information
  3. How We Share Your Personal Information
  4. Your Privacy Rights
  5. Information for Persons Subject to UK & EU Data Protection Law
  6. Contact Us

1. What Information We Collect, Why We Collect It, and How We Use It

(i) We Process the Following Personal Information:

  • Information You Provide Directly to Us: In connection with accessing our Services, we may collect information from you which can be used to identify you ("Personal Information"), such as your name, billing address, email address, phone, username, and password. We collect information when you register or open an account, sign in, pay a bill, purchase a Service, use a Service, call us for support, or give us feedback.

  • Information from Other Sources: Tulo may also obtain information about you from other sources, including publicly or commercially available information, and through third-party data platforms, partners, and service providers such as when you sync a third-party account (e.g., Xero, QuickBooks) or service with your Tulo Service.

  • Automatic Data Collection: We may automatically collect certain information through your use of the Tulo Services, such as your Internet protocol (IP) address, log files, unique device identifiers, pages viewed, browser type, and cookie identifiers.

  • Blockchain Data: If you connect a crypto wallet or we process blockchain addresses and on-chain transaction metadata, please be aware that some blockchain records are inherently public and immutable. They cannot be altered or deleted on the underlying network. However, we can delete or de-link associations within our systems where required by applicable law.

(ii) We process information for the following purposes:

  • To provide you with the Services: Tulo will use your information to provide the Tulo Services.

  • For Administrative Purposes: To respond to your questions, provide support, and generally administer the Tulo Services.

  • To Market the Services: We may use information to notify you about offers and services that may be of interest to you.

  • Security Purposes: To detect and prevent fraud, identify and repair errors, conduct audits, and for security purposes.

  • De-identified and Aggregated Information Use: We may anonymize or de-identify your Information and use it for internal and external purposes, including to analyze and improve the Services.

2. How We Protect and Retain Your Personal Information

Security

We have implemented and maintain appropriate technical and organizational measures designed to protect your information, including encryption of data at rest and in transit, access controls, and hosting with leading, independently audited cloud providers. For more information about our security practices, please see our Security page at https://tulo.co/security.

Retention

We will retain your information as long as necessary to serve you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to retain data where required by applicable regulations and Tulo's records policies to comply with legal obligations.

3. How We Share Your Personal Information

We may share your information as follows:

  • Service Providers: With vetted third-party service providers — including cloud hosting, authentication, and AI service providers — who process data on our behalf to operate our platform. A list of our sub-processors is available to customers on request.

  • Legal Compliance: With regulators, courts, or competent authorities to comply with applicable laws (including AML/KYC regulations).

  • Business Transfers: If we sell or transfer our business, shares, or assets to a third party.

Note on AI: For vendors that provide AI services, we restrict their use of your information to processing on our behalf and do not permit these vendors to use your personal information to train their foundation models.

Data Processing Agreement: For business customers, our Data Processing Agreement (DPA) is available on request — please contact us at hello@tulo.co.

4. Your Privacy Rights

Rights: You can exercise your rights by contacting us at hello@tulo.co. Subject to legal considerations, we will make every reasonable effort to honor your request promptly.

  • Marketing emails – opt-out: You may choose not to receive marketing emails by sending an email with the subject "BLOCK" to hello@tulo.co or using the unsubscribe link in our emails.

  • Data deletion: You may request deletion of your information at any time. We will delete or anonymize personal information, subject to applicable legal obligations (e.g., tax record-keeping requirements).

5. Information for Persons Subject to UK & EU Data Protection Law

We adhere to the UK Data Protection Act 2018 and the GDPR.

Lawful Bases for Processing

  • Contractual Obligations: To provide you with the Services.

  • Legal Obligations: To fulfill retention, tax, and anti-fraud obligations.

  • Legitimate Interest: To monitor usage and ensure security.

  • Consent: For marketing and non-essential cookies.

International Transfers

Some of our service providers are located outside the UK and the European Economic Area (EEA). Where we transfer personal data outside the UK or EEA, we ensure appropriate safeguards are in place, such as transfers to countries covered by adequacy regulations or the use of standard contractual clauses approved for that purpose.

Your Rights

Under the GDPR/UK GDPR, you have the right to Access, Rectification, Erasure, Restriction of Processing, Data Portability, and the Right to Object. You also have the right to lodge a complaint with a supervisory authority — in the UK, this is the Information Commissioner's Office (ICO, ico.org.uk).

To submit a request, please contact our privacy contact using the details below.

6. Contact Us

If you have questions regarding this policy or our use of your Personal Information, please contact us at:

General Inquiries: hello@tulo.co

Privacy Contact:

Dark Zorse Ltd
Email: security@tulo.co
ICO Registration Reference: CSN2142333