The "Talking Tilly" service, offered by Xicoia Ltd, now mandates a face scan for age verification before users can connect to a video call. This process uses Didit, a Spanish identity verification provider, to estimate age from a video selfie. If the estimate is unclear, a government photo ID upload is required as a fallback. Xicoia Ltd states that no faceprint or biometric template is created, and images are not retained after the check, only an approximate age band and reference number.
Beyond the initial age verification, the service continuously analyzes the user's camera feed and tone of voice during every call to infer emotional state. This data is used to allow the AI character to respond in a mood-appropriate manner. The privacy policy explicitly states that this emotional monitoring cannot be disabled for individual calls.
Both the age verification and emotional monitoring features rely on "legitimate interests" as their legal basis, rather than explicit user consent. This change was implemented in September. All calls are recorded, transcribed, and processed live by US providers, with the AI character's responses generated by Google's Gemini model via the conversational video platform Tavus.
The service includes automated safety systems that screen call transcripts for abusive language. If flagged, the recording is withheld. One instance involved a conversation about weather and news being incorrectly flagged for "hateful or abusive language." While human review can release wrongly flagged recordings, all recordings are permanently deleted after 24 hours.
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The "Talking Tilly" AI character service, which allows video calls with an AI actress, implements mandatory face-scanning for age verification and continuous mood detection during calls. These features, added recently to the service's terms, operate without user consent as their legal basis and raise privacy concerns regarding biometric data and emotional surveillance.
The "Talking Tilly" service, which allows users to video call the AI actress Tilly Norwood, now requires a face scan for age verification and continuously monitors user emotions during calls. These requirements, added this month, raise privacy concerns as they cannot be opted out of and rely on "legitimate interests" rather than user consent.