Privacy policy

Last Updated: 30.05.2026

This Privacy Policy explains how EXA Agency FZ-LLC (“Company,” “we,” “us,” or “our”) collects, uses, discloses, stores, and protects personal information when you visit our website, purchase our digital products, use our services, communicate with us, or interact with our marketing.

Our main product is currently marketed under the brand Pulls InstaOS™. We may also offer related optional services, including the InstaOS Launch Check™, profile review, online support, and future coaching or consulting services.

We are a company incorporated in the United Arab Emirates.

Company: EXA Agency FZ-LLC
Licence No.: 17002184
Address: FDAM0301, Compass Building, Al Shohada Road, Al Hamra Industrial Zone-FZ, Ras Al Khaimah, United Arab Emirates
Contact Email: info@getpulls.co

By using our website, purchasing our products, or communicating with us, you acknowledge that you have read this Privacy Policy.

1. Who This Privacy Policy Applies To

This Privacy Policy applies to personal information we collect from:

• visitors to our website;
• customers who purchase Pulls InstaOS™ or related products;
• customers who purchase or request a profile audit, review, or personalized feedback;
• people who contact us by email, WhatsApp, social media, forms, or other communication channels;
• subscribers to our email marketing or post-purchase communications;
• applicants or customers for future coaching or consulting services.

Our services are intended for adults only. You must be at least 18 years old and legally considered an adult in your country, state, or jurisdiction of residence to use our products or services.

Our services are not intended for minors.

2. Nature of Our Services

We provide digital educational content, online resources, profile improvement materials, and optional personalized feedback or coaching related to online presentation, profile optimization, and communication skills.

We do not provide:

• matchmaking services;
• dating platform services;
• introductions to third parties;
• access to third-party profiles;
• adult services;
• escort services;
• account management services;
• guaranteed matches, dates, replies, relationships, or romantic outcomes.

This Privacy Policy should be read together with our Terms of Service, Refund Policy, and any product-specific terms presented at checkout.

3. Personal Information We Collect

We collect personal information in different ways depending on how you interact with us.

3.1 Information You Provide Directly

You may provide us with:

• name;
• email address;
• billing address;
• country, state, or region;
• phone number or WhatsApp contact, if you choose to communicate with us there;
• purchase details;
• support requests;
• survey or form responses;
• profile username or public profile handle, if you choose to provide it for an audit;
• screenshots, photos, bio text, or profile materials that you voluntarily submit for review;
• messages, comments, or communications you send to us;
• information you provide if you apply for coaching or consulting.

3.2 Payment Information

Payments are processed through third-party payment providers such as Shopify Payments, and potentially Stripe, PayPal, Apple Pay, Google Pay, or other payment processors.

We do not directly store your full payment card number. Payment information is processed by the relevant payment provider according to its own privacy policy and security practices.

We may receive limited payment-related information, such as:

• payment status;
• transaction ID;
• billing details;
• last four digits of a card;
• payment method type;
• fraud or risk signals;
• refund and chargeback information.

3.3 Information Collected Automatically

When you visit our website, we and our service providers may automatically collect:

• IP address;
• device type;
• browser type;
• operating system;
• referring URL;
• pages viewed;
• time spent on pages;
• clicks and interactions;
• approximate location;
• checkout activity;
• cart activity;
• purchase events;
• cookie identifiers;
• advertising identifiers;
• analytics and attribution data.

We may use cookies, pixels, tags, scripts, SDKs, and similar technologies.

3.4 Information from Advertising and Analytics Tools

We may use tools such as:

• Meta Pixel;
• Shopify analytics;
• Google Analytics;
• TikTok Pixel;
• email marketing platforms;
• advertising platforms;
• conversion tracking tools;
• attribution tools;
• fraud prevention tools.

These tools may collect or receive information about your interactions with our website and advertising campaigns, including page views, purchases, cart activity, and other events.

Some privacy laws may consider certain advertising or analytics activities to be a “sale,” “sharing,” or “targeted advertising” use of personal information, even if we do not sell your personal information for money.

3.5 Information from WhatsApp, Email, or Similar Channels

If you contact us through WhatsApp, email, social media, or similar tools, we may collect and retain:

• your contact details;
• your messages;
• attachments you send;
• profile screenshots or materials submitted for review;
• support history;
• delivery or read confirmations where available.

Please remember that WhatsApp, email providers, social platforms, and similar services are operated by third parties and may process your data according to their own privacy policies.

4. Profile Audit and Coaching Materials

If you purchase or request a personalized profile review, audit, or future coaching service, you may choose to send us certain materials.

These may include:

• screenshots of your own profile;
• photos you want reviewed;
• bio text;
• dating-app or social profile content;
• examples of conversations;
• profile usernames or public handles.

You must not send us:

• passwords;
• login credentials;
• access codes;
• intimate or sexually explicit images;
• nude content;
• content involving minors;
• private information of third parties without permission;
• screenshots showing full names, usernames, faces, photos, or identifiable information of other people unless properly blurred or anonymized;
• health, religious, political, biometric, or other sensitive information that is not necessary for the service.

If you send us materials that include third-party information, you are responsible for ensuring that you have the legal right to share those materials with us.

We use audit and coaching materials only to provide the service, support you, maintain records, protect against fraud, handle disputes, and improve our internal processes.

We do not use your profile materials, screenshots, photos, or coaching materials in marketing, testimonials, case studies, or advertising unless you give us separate written permission.

5. Sensitive Personal Information

We do not intentionally require or request sensitive personal information.

Please do not send us information about:

• sexual orientation;
• sexual activity;
• health or medical conditions;
• religion;
• political beliefs;
• biometric identifiers;
• government identification documents;
• financial account passwords;
• private information about other people;
• content involving minors;
• intimate images or explicit content.

If you voluntarily provide information that may be considered sensitive, we will process it only as necessary to provide the service you requested, protect our legal rights, comply with applicable law, or as otherwise permitted by law.

6. How We Use Personal Information

We may use personal information to:

• operate our website;
• process purchases;
• provide access to digital products;
• deliver profile audits, feedback, support, or coaching;
• communicate with you;
• provide customer service;
• send transactional emails;
• send marketing emails where permitted;
• personalize your experience;
• improve our products, funnels, content, and customer experience;
• analyze website and ad performance;
• measure conversions and advertising attribution;
• prevent fraud, abuse, chargebacks, or unauthorized access;
• enforce our Terms of Service;
• comply with legal, tax, accounting, and regulatory obligations;
• protect our rights, customers, business, and payment infrastructure.

7. Marketing Communications

If you purchase from us, subscribe, or otherwise provide your contact information, we may send you:

• onboarding emails;
• product access emails;
• educational emails;
• post-purchase communications;
• offers for related products or services;
• audit or coaching invitations;
• abandoned cart emails;
• customer support messages.

You can unsubscribe from marketing emails at any time by clicking the unsubscribe link in our emails or contacting us at info@getpulls.co.

We may still send you transactional or service-related messages, such as purchase confirmations, product access information, support messages, legal notices, or important account-related communications.

If we use WhatsApp or similar messaging channels, we will use them primarily for service, support, audit delivery, or communications you initiate or request. We do not intend to use SMS or WhatsApp for aggressive unsolicited marketing.

8. Cookies, Pixels, and Tracking Technologies

We use cookies and similar technologies to:

• make the website function properly;
• remember your preferences;
• process checkout activity;
• analyze website performance;
• understand customer behavior;
• measure advertising performance;
• retarget visitors;
• build advertising audiences;
• prevent fraud;
• improve our products and marketing.

These technologies may be set by us or by third-party providers such as Shopify, Meta, Google, TikTok, email marketing platforms, analytics providers, and advertising partners.

You can manage cookies through:

• your browser settings;
• our cookie banner or cookie preference tool, where available;
• platform-level ad settings, such as Meta, Google, or TikTok ad preferences;
• privacy tools provided by your device or browser.

Where required by law, we will ask for your consent before placing non-essential cookies or tracking technologies.

9. Disclosure of Personal Information

We may disclose personal information to the following categories of recipients:

9.1 Service Providers and Processors

We may share information with companies that help us operate the business, such as:

• Shopify;
• Shopify Payments;
• Stripe;
• PayPal;
• payment processors;
• fraud prevention providers;
• hosting providers;
• email marketing platforms;
• CRM tools;
• analytics providers;
• advertising platforms;
• customer support tools;
• cloud storage providers;
• scheduling tools;
• online meeting providers;
• WhatsApp or messaging providers;
• accountants, lawyers, tax advisors, and compliance consultants.

These providers may process personal information on our behalf or independently according to their own terms and privacy policies.

9.2 Advertising and Analytics Partners

We may share website activity, purchase events, hashed contact information, cookie identifiers, or similar data with advertising and analytics partners to measure performance, optimize campaigns, retarget visitors, and improve ads.

This may include Meta, Google, TikTok, or similar providers.

Some US state privacy laws may treat this as “sharing” personal information for cross-context behavioral advertising or targeted advertising.

9.3 Legal and Compliance Purposes

We may disclose information if necessary to:

• comply with applicable law;
• respond to lawful requests;
• protect our rights;
• enforce our Terms;
• prevent fraud or abuse;
• resolve payment disputes;
• handle chargebacks;
• protect the safety of our users, customers, team, or business.

9.4 Business Transfers

If we sell, merge, reorganize, or transfer all or part of our business, personal information may be transferred as part of that transaction.

10. Selling, Sharing, and Targeted Advertising

We do not sell your personal information for money.

However, some privacy laws define “sale,” “sharing,” or “targeted advertising” broadly. Under those laws, our use of advertising pixels, cookies, retargeting tools, conversion tracking, and similar technologies may be considered a “sale,” “sharing,” or use for targeted advertising.

You may opt out of these activities by:

• using our cookie preference tool, where available;
• contacting us at info@getpulls.co with the subject line “Privacy Opt-Out”;
• using browser or device-level opt-out tools where supported;
• using platform-specific privacy and ad settings.

If required by applicable law, we will honor valid opt-out preference signals, such as Global Privacy Control, where technically feasible..

11. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Different categories of information may be retained for different periods.

11.1 Customer and Transaction Records

We may retain order, payment, refund, tax, accounting, and transaction records for as long as necessary to comply with legal, accounting, tax, audit, and business obligations.

11.2 Marketing Data

We retain marketing data until you unsubscribe, withdraw consent where applicable, or we no longer need the data for marketing and analytics purposes.

11.3 Audit and Coaching Materials

Profile screenshots, submitted materials, photos, conversation examples, and similar audit or coaching materials are retained only as long as needed to provide the service, handle support, protect against fraud, resolve disputes, or comply with legal obligations.

Unless a longer period is necessary for chargebacks, disputes, legal obligations, or legitimate business protection, we aim to delete or anonymize profile audit materials within 90 days after delivery of the related service.

Materials exchanged through WhatsApp, email, or similar communication channels may remain in those channels until deleted according to our internal processes or the relevant platform’s retention settings. You may request deletion of your submitted materials by contacting us at info@getpulls.co, subject to legal, fraud prevention, dispute, or recordkeeping needs.

11.4 Support Communications

We may retain support messages for as long as reasonably necessary to resolve requests, improve service, document customer communications, and protect our legal rights.

12. Security

We use reasonable technical, organizational, and administrative safeguards designed to protect personal information.

These may include:

• access controls;
• limited internal access;
• secure payment processing through third-party providers;
• use of reputable platforms;
• internal confidentiality expectations;
• fraud prevention tools;
• secure storage practices where available.

No method of transmission or storage is completely secure. We cannot guarantee absolute security of personal information.

You should not send us passwords, login credentials, intimate content, or highly sensitive personal information.

13. International Data Transfers

We are based in the United Arab Emirates.

If you are located outside the UAE, your personal information may be transferred to, stored in, or processed in the UAE, the United States, and other countries where our service providers operate.

These countries may have data protection laws that differ from those in your country.

By using our website or services, you understand that your information may be transferred internationally as described in this Privacy Policy.

Where required by applicable law, we rely on appropriate safeguards, contractual measures, consent, necessity for contract performance, or other lawful transfer mechanisms.

14. Your Privacy Rights

Depending on where you live, you may have certain rights regarding your personal information.

These may include the right to:

• request access to your personal information;
• request correction of inaccurate information;
• request deletion of personal information;
• request a copy of your personal information;
• object to or restrict certain processing;
• opt out of marketing communications;
• opt out of sale, sharing, or targeted advertising where applicable;
• withdraw consent where processing is based on consent;
• appeal a denied privacy request where applicable.

To submit a privacy request, contact us at:

info@getpulls.co

Please include:

• your name;
• email address used for purchase or communication;
• your country and state of residence;
• the type of request;
• enough information for us to verify your identity.

We may need to verify your identity before processing your request.

We will respond within the time required by applicable law.

15. California and US State Privacy Notice

This section applies to residents of California and other US states that provide similar privacy rights, to the extent applicable to us.

15.1 Categories of Personal Information We May Collect

In the past 12 months, we may have collected the following categories of personal information:

15.2 Purposes for Collection and Use

We collect and use these categories for:

• providing products and services;
• processing payments;
• delivering digital content;
• conducting profile audits or coaching;
• customer support;
• marketing and advertising;
• analytics;
• fraud prevention;
• legal compliance;
• dispute resolution;
• business operations.

15.3 Categories of Personal Information Disclosed

We may disclose the categories above to:

• payment processors;
• Shopify and e-commerce providers;
• email and CRM providers;
• advertising platforms;
• analytics providers;
• cloud storage and communication tools;
• professional advisors;
• legal or regulatory authorities where required.

15.4 Sale or Sharing

We do not sell personal information for money.

We may share personal information with advertising and analytics partners in a way that may be considered “sharing” or “targeted advertising” under some US state privacy laws.

You may opt out by using our cookie tools, browser controls, or by contacting us at info@getpulls.co.

15.5 Sensitive Personal Information

We do not use sensitive personal information for purposes that would require a right to limit use under applicable California law, unless otherwise disclosed.

Please do not send us sensitive personal information unless strictly necessary for the service you requested.

15.6 Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

However, some information may be necessary to provide our services. If you request deletion of information needed to deliver a product or service, we may no longer be able to provide that product or service.

15.7 Authorized Agents

Where applicable, you may designate an authorized agent to submit a privacy request on your behalf. We may require proof of authorization and may still ask you to verify your identity directly.

16. Users Outside the United States

Our services are primarily intended for customers in the United States.

If you access or purchase our services from outside the United States, additional laws may apply depending on your country of residence.

Where applicable, we may process your personal information based on:

• performance of a contract;
• consent;
• legitimate business interests;
• compliance with legal obligations;
• protection of legal rights;
• fraud prevention and security.

If you are located in a jurisdiction with specific privacy rights, you may contact us at info@getpulls.co to exercise those rights.

We reserve the right to restrict, block, or refuse purchases from jurisdictions where we are not prepared to offer our services or where additional regulatory obligations apply.

17. Children and Minors

Our products and services are intended only for adults.

We do not knowingly collect personal information from minors.

You must be at least 18 years old and legally considered an adult in your country, state, or jurisdiction of residence to use our website, products, or services.

If we learn that we have collected personal information from a minor, we will take reasonable steps to delete it.

If you believe a minor has provided us with personal information, contact us at info@getpulls.co.

18. Third-Party Websites and Services

Our website, emails, or communications may contain links to third-party websites, platforms, or services.

These may include:

• Shopify;
• payment processors;
• WhatsApp;
• Meta platforms;
• Google services;
• TikTok;
• scheduling tools;
• video call platforms;
• social media platforms.

We are not responsible for the privacy practices, content, or security of third-party services. You should review their privacy policies before using them.

19. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we may notify you by posting the updated policy on our website, updating the “Last Updated” date, or using other reasonable methods.

Your continued use of our website or services after the updated Privacy Policy is posted means you acknowledge the updated policy.

20. Contact Us

If you have questions about this Privacy Policy, your personal information, or your privacy rights, contact us at:

EXA Agency FZ-LLC
FDAM0301, Compass Building
Al Shohada Road
Al Hamra Industrial Zone-FZ
Ras Al Khaimah
United Arab Emirates

Email: info@getpulls.co