Introduction

This Policy applies to Dwello, LLC and its operational affiliates, including Properly Holdings, LLC, and Properly, LLC, and other related entities that support our services (collectively, the “Company”). We may share information across the Company for operational, compliance, data processing, customer support, underwriting, and partner-matching purposes. This Privacy and Data Security Policy ("Policy") explains how we collect, use, disclose, and safeguard personal information across our website, services, and partner network.

Company operates a digital loan and home improvement marketplace, similar to platforms like Bankrate and LendingTree. We connect consumers with third-party lenders and participating merchants. We do not originate or service loans. By using our services, you consent to the practices described in this Policy.

What This Policy Covers

This Policy outlines how Company collects, uses, shares, and protects your data. It is distinct from:

• The GLBA Privacy Notice, which is provided to users at account creation and annually thereafter.
• The Terms of Use, which govern access and usage of our services.

All three documents must be reviewed and acknowledged by every consumer who uses the Company platform.

Information We Collect

We may collect the following categories of information:

• Personal Information: Name, contact details, date of birth, Social Security number (if applicable), and financial data.
• Device & Usage Information: IP address, browser type, device identifiers, access times, and pages viewed.
• Lead Matching Data: Information voluntarily submitted for lender or merchant matching.
• Location Data: Geolocation data if enabled by the user.
• Marketing and Preference Data: Responses to promotions and communication preferences.

We may also collect personal information from third-party sources such as credit bureaus, fraud prevention services, and data providers.

For customers of our home-service and pool maintenance businesses, we may also collect:

• Service appointment information.
• Home address, property details, and pool or equipment specifications.
• Service history, invoices, and work orders.
• Photos or videos taken by technicians to document conditions, repairs, or project scope.
• Communications with technicians or service teams.
• This information is used to provide maintenance, repairs, scheduling, billing, and customer support.

Credit Inquiries

• By using Company, you authorize Company to conduct a soft credit inquiry on behalf of participating lenders. This will not impact your credit score and is used solely for matching purposes.
• However, if you proceed with a loan application, the lender may conduct a hard credit inquiry, which may affect your credit score and will appear on your credit report.

How We Use Your Information

We use the information we collect to:

• Facilitate matching with lenders and merchants.
• Personalize user experience.
• Provide customer support.
• Communicate relevant offers, updates, and disclosures.
• Comply with legal and regulatory obligations.
• Prevent fraud and improve security.

Sharing of Information

We may share personal information, with, among other entities, our strategic partners, participating merchants, home-service providers, and contractors, to:

• Match you with products, promotions, or services you request.
• Verify your eligibility for partner programs.
• Facilitate financing, project estimates, or service offerings.
• Enable co-branded or jointly offered experiences.
• Support merchant or partner decisions regarding whether to offer you financing, services, discounts, or promotions.

We may also share your information:

• With data hosting, analytics, marketing, customer support, and payment processing partners.
• With our parent company, subsidiaries, or other corporate affiliates for operational, compliance, or administrative purposes.
• With legal or regulatory bodies, to comply with applicable law or law enforcement requests.
• As part of business transactions, such as mergers, acquisitions, or asset sales.
• With local operators and service providers, if you request maintenance, repairs, or home-service work, we may share your information with the local subsidiary, branch, or service provider that will perform the work. These businesses may be operated by Properly or by affiliated or acquired entities within the Properly network.
• With your consent, as directed by you.

Note too that information is shared for matching and eligibility decisions, when you submit information through Dwello, you authorize us to share that information with participating lenders, merchants, service providers, and other partners for the purpose of evaluating eligibility, pricing, promotions, financing options, and service availability.

We do not sell personal information in the traditional sense of exchanging data for money, but certain disclosures to lenders, merchants, and partners may be considered a “sale” or “sharing” under applicable privacy laws.

Service, Account, and SMS Communications

By using our platform, requesting a quote, submitting a loan or financing inquiry, creating an account, scheduling a service, or otherwise interacting with the Company, you may receive SMS, email, or phone communications from us. These communications may include, but are not limited to:

• Account verification and security alerts.
• Loan or financing updates, matching notifications, or required disclosures.
• Service confirmations, appointment scheduling, technician-on-the-way alerts, and service updates.
• Project estimates, status updates, approvals, and follow-up communications.
• Marketing or promotional messages if you have opted in to receive them.

You may opt out of non-transactional SMS messages at any time by replying STOP. Standard message and data rates may apply.

Cookies and Tracking Technologies

We use cookies and similar technologies to:

• Understand how users interact with our services.
• Improve functionality and performance.
• Deliver personalized ads (if applicable).

You can manage or disable cookies in your browser settings, though this may affect your experience.

Data Security

We employ industry-standard security measures to protect personal information from unauthorized access, alteration, disclosure, or destruction. These include:

• Encryption of sensitive data.
• Role-based access controls.
• Secure data centers and hosting partners.
• Periodic vulnerability assessments.

Despite these safeguards, no system is 100% secure. Users are responsible for safeguarding their own credentials.

Retention of Data

We retain your data only as long as necessary to:

• Deliver services.
• Comply with legal obligations.
• Resolve disputes.
• Enforce our agreements.

When no longer needed, data is securely deleted or de-identified.

Children’s Privacy

Company does not knowingly collect personal information from children under the age of 13. If we become aware of such collection, we will delete the information promptly.

Changes to This Policy

We may update this Policy periodically. Any changes will be posted on this page with an updated effective date. Continued use of our services constitutes acceptance of the revised Policy.

Joint Marketing and Co-Branded Services

Dwello may partner with lenders, merchants, or service providers to offer co-branded or joint marketing programs. If you choose to participate in these programs, information relevant to your participation may be shared with the applicable partner.

Partner Privacy Practices

Participating merchants, lenders, contractors, and strategic partners have their own privacy practices. Once your information is shared with a partner, their use of your information is governed by their privacy policy, not ours.

Your Privacy Rights (California, Colorado, Virginia, and other states)

Depending on your state of residence, you may have certain rights regarding your personal information, including:

• The right to know what personal information we collect and how we use it.
• The right to request access to the personal information we hold about you.
• The right to request deletion of your personal information.
• The right to request correction of inaccurate information.
• The right to opt-out of certain data sharing or targeted advertising practices.
• The right to non-discrimination for exercising your privacy rights.

You may submit a privacy request by contacting us at: support@dwellolending.com

Contact Information

If you have any questions or concerns, please contact:
Dwello, LLC
1420 Washington Blvd., Suite 301
Detroit, MI 48226
Email: support@dwellolending.com