Privacy Policy

Published and last updated: 02.08.2026

This Privacy Policy (the “Policy”) sets out how personal data of users of the Dulty.app service (the “Service”, “Dulty”) is processed. The operator of the Service and the data controller is the owner of Dulty.app (the “Operator”, “we”). By using the Service, the user (“you”) confirms acceptance of this Policy.

1. Legal basis

Personal data is processed in accordance with Federal Law No. 152-FZ of 27 July 2006 “On Personal Data” and other applicable legislation of the Russian Federation.

2. Data we collect

  • Account data: name, email address, Google sign-in data.
  • Usage data: training session results, skill scores, history of dialogues with the AI fan, actions in the interface.
  • Payment data: subscription plan, payment amount and status, payment gateway transaction id. Card or wallet credentials are never transmitted to or stored by the Operator — payment is handled on the payment provider's side.
  • Technical data: IP address, device and browser type, cookies required for the sign-in session.

3. Purposes of processing

  • Providing access to the Service and operating the trainer.
  • Processing payments and tracking the team's plan.
  • Producing reports and scores for the user and their team.
  • Technical support and communication with the user.
  • Improving the Service and preventing abuse.

4. Sharing with third parties

To operate the conversational AI assessment, session text is transmitted to a third-party language model provider solely to generate replies and score observable behavior. Payment identifiers, amount, currency, plan, and workspace reference are transmitted to Platega; Dulty does not receive or store card or wallet credentials. We do not sell personal data.

5. Data retention

Data is stored for the lifetime of the account and for as long as required to achieve the purposes of processing or to comply with legal requirements, after which it is deleted or anonymised.

6. Your rights

You may request access to your personal data, its correction or deletion, or withdraw your consent to processing by contacting support as set out in section 8. Deleting your account may result in loss of access to session history and to a paid plan.

7. Cookies

The Service uses technical cookies to maintain the sign-in session. Disabling cookies in your browser may make the Service unusable.

8. Contact

For any questions about personal data processing, contact us on Telegram: @Dulty_support.

9. Changes to this Policy

The Operator may amend this Policy. The current version is always available at /privacy. Continued use of the Service after changes are published constitutes acceptance of the updated Policy.

10. Age restriction

The Service is intended for persons over 18 years of age and involves 18+ material within simulated messaging.