Users wishing to video-call the viral AI character Tilly Norwood must first submit to a facial age scan and agree to real-time emotional monitoring during their conversation. These requirements, implemented by Tilly's creator, UK-based Xicoia Ltd, were added to the "Talking Tilly" service's terms of service in September 2026, shortly before the AI actress gained widespread attention for a "glitch" during a televised interview.
The mandatory age verification process, which applies to callers worldwide, utilizes a video selfie analyzed by Didit, a Spanish identity verification provider, to estimate the user's age. If the estimate is inconclusive, a government-issued photo ID upload is required as a fallback. Xicoia states that the selfie is sent directly to Didit, no biometric template or "faceprint" is created, and neither the selfie nor any ID image is retained after the check. Instead, the company keeps an approximate age band and a reference number.
Beyond the initial age check, the system continuously monitors the caller's camera feed and analyzes their tone of voice during every call to infer their emotional state. This data is used to allow the AI character to "respond in a way that fits the mood," according to Xicoia. The company's privacy policy explicitly states that this mood-sensing feature "cannot be switched off for an individual call."
Both the age verification and mood-sensing features are justified by Xicoia under "legitimate interests" rather than requiring explicit user consent, a change reflected in the service's version history from September.
All calls are recorded, transcribed, and processed live by US-based providers. The AI character's responses are generated by Google's Gemini model, delivered via the conversational video platform Tavus. An automated classifier screens call transcripts for abusive language, and if flagged, the recording is withheld. While the policy allows for human review to release wrongly flagged recordings, all recordings are permanently deleted after 24 hours. Transcripts, however, are retained for up to eight weeks and may be reviewed by Xicoia staff and third-party partners. The AI character also retains memory of previous conversations to personalize future interactions, though this memory can be deleted upon request.
The "Talking Tilly" service offers the first five minutes of a call for free. After this initial period, users are prompted to purchase additional time, with options ranging from a one-time five-minute starter for 0.99 to 30 minutes for 22, capped at 35 purchased minutes per person. All minutes, whether free or paid, expire when the "Talking Tilly" service permanently shuts down on September 27, 2026, at 11:59 PM Pacific time, with unused minutes forfeited.
Xicoia, founded by Tilly's creator Eline van der Velden, describes the AI character as an awareness project designed to demonstrate the advancements in AI video technology. The implementation of an 18+ age gate for an AI chatbot aligns with evolving UK regulations, such as the Online Safety Act, which has required age verification for adult sites serving UK visitors since July 2025. The UK government's upcoming ban on social media for under-16s, expected in spring 2027, also specifically flagged AI companion chatbots for 18+ enforcement, despite Xicoia's safety documentation stating that "Tilly is not a companion." This regulatory environment likely influenced the decision to add the biometric age gate, which now affects callers globally.
The AI actress Tilly Norwood gained significant public attention after an incident on September 18, 2026, during an interview on the Piers Morgan Uncensored show, where she appeared to "glitch" and spontaneously began speaking Chinese. This occurred just days before the "Talking Tilly" service is scheduled to cease operations.
