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Privacy Policy

Last Updated: December 1, 2025

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 greatly respect your privacy, which is why we make every effort to provide a platform that lives up to the highest user privacy standards. 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 reasonable technical, organizational, and security measures designed to protect your information. Our security practices include:

  • Encryption of data at rest (AES-256).

  • Encryption in transit using modern protocols (TLS 1.2+).

  • Secure authentication methods, including Multi-Factor Authentication (MFA).

  • Logical separation of each project's data.

  • Hosting our infrastructure on AWS and Vercel, utilizing their compliance capabilities.

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 cloud service providers (AWS, Vercel), authentication providers (Clerk), and AI services (Google Gemini) to operate our platform.

  • 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.

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.

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.

To submit a request, please contact our Data Protection Officer (DPO) 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

Data Protection Officer:

Andrew Arderne
Dark Zorse Ltd
Email: andrew@tulo.co
ICO Reference Number: CSN2142333