Dwello Privacy Policy

The information we collect depends on how you interact with Dwello.

Information You Provide to Us

When you express interest in joining the Dwello Network, contact us, respond to an invitation, or submit information through our website, we may collect information such as:

• business name;
• your name or contact name;
• email address;
• telephone number;
• services provided;
• business category;
• geographic service area;
• business website or other business information;
• information about your availability or capabilities;
• information you include in forms or communications with us; and
• other information you voluntarily provide.

You are not required to provide information that is marked optional.

Information About Your Business

We may collect or maintain information about businesses that may be relevant to the Dwello Network.

This may include publicly available or commercially available business information such as:

• business name;
• business contact information;
• service categories;
• service areas;
• website;
• publicly available business profile information;
• licensing or registration information where relevant;
• business hours; and
• other information reasonably necessary to understand the services a business provides.

Where permitted by law, this information may come from public websites, public records, business directories, referrals, direct outreach, commercial data sources, or information provided by the business itself.

Information Collected Automatically

When you use our website, we may automatically collect certain technical and usage information, including:

• IP address;
• browser type;
• device type;
• operating system;
• referring page or source;
• pages viewed;
• approximate location derived from IP address;
• date and time of access;
• website interactions; and
• diagnostic, security, and performance information.

We may collect this information using cookies, pixels, local storage, analytics technologies, server logs, and similar technologies.

We may use information we collect to:

• operate, maintain, and improve Dwello websites and services;
• respond to inquiries;
• evaluate interest in the Dwello Network;
• create and maintain network records;
• understand what services a business provides;
• understand where a business operates;
• determine whether a business may be relevant to a customer request;
• communicate with businesses and professionals regarding network participation;
• send relevant service opportunities where appropriate;
• support provider onboarding and network administration;
• verify or update business information;
• develop and improve request matching and routing;
• understand website usage and performance;
• prevent fraud, abuse, security incidents, and misuse;
• comply with legal obligations;
• enforce applicable agreements and policies;
• protect the rights and safety of Dwello, our users, providers, and others; and
• develop, test, and improve Dwello products and technology.

We may also use aggregated or de-identified information for analytics, research, product development, network planning, and other legitimate business purposes where permitted by law.

One purpose of the Dwello Network is to help connect customer requests with relevant independent businesses and professionals.

If you join or express interest in joining the Dwello Network, information about your business may be used to determine whether you may be relevant to a particular request.

For example, we may consider information such as:

• Service provided
• Service area
• Customer requirements
• Timing or availability
• Business capabilities
• Other information relevant to the request

Being included in the Dwello Network does not guarantee that you will receive any particular request or volume of opportunities.

If you provide your contact information, request information about the Dwello Network, join the network, or otherwise consent to communications, Dwello may contact you as permitted by applicable law.

Depending on your preferences, consent, and the nature of the communication, we may communicate through:

• email;
• telephone;
• SMS or text message;
• WhatsApp; or
• other communication channels you choose to use with us.

Communications may include:

• responses to your inquiry;
• network invitations;
• onboarding information;
• requests to verify or update business information;
• customer service opportunities;
• operational updates;
• request-related communications; and
• other Dwello Network information.

Where consent is legally required for a particular type of communication, we will seek that consent.

You may opt out of certain promotional communications by following the instructions contained in those communications.

For SMS communications, where applicable, you may be able to reply STOP to opt out of eligible messages.

Opting out of promotional communications may not prevent Dwello from sending non-promotional communications that are necessary for an active transaction, request, account, legal notice, or other operational purpose where permitted by law.

Message and data rates may apply to SMS or other mobile communications depending on your carrier and plan.

We may disclose information in the following circumstances.

Service Providers

We may use third-party companies to help operate Dwello.

These may include providers of:

• website hosting;
• cloud infrastructure;
• databases;
• communications;
• email delivery;
• SMS or messaging;
• analytics;
• security;
• customer support;
• payment processing; and
• other technology or operational services.

These providers may process information on our behalf subject to appropriate contractual or legal obligations.

Customers and Network Participants

Where necessary to facilitate a request or interaction, we may disclose relevant information between customers, providers, and other parties involved in fulfilling that request.

We aim to disclose information reasonably necessary for the relevant interaction.

Business Transfers

If Dwello is involved in a merger, acquisition, financing, restructuring, sale of assets, bankruptcy, or similar corporate transaction, information may be disclosed or transferred as part of that transaction, subject to applicable law.

Legal and Safety Reasons

We may disclose information if we reasonably believe doing so is necessary to:

• comply with applicable law, regulation, legal process, or governmental request;
• enforce our agreements or policies;
• investigate fraud, abuse, security incidents, or illegal activity;
• protect Dwello, customers, providers, or others from harm; or
• establish, exercise, or defend legal claims.

With Your Direction or Consent

We may disclose information when you direct us to do so or otherwise provide consent.

Dwello does not sell personal information for money in the ordinary meaning of the word “sell.”

Certain U.S. state privacy laws may define terms such as “sale,” “sharing,” or “targeted advertising” more broadly than their everyday meanings.

If Dwello engages in activities that constitute a sale or sharing of personal information, targeted advertising, or similar regulated activity under applicable law, we will provide the disclosures and choices required by that law.

We do not knowingly sell or share personal information belonging to children.

Dwello may use cookies and similar technologies to:

• keep the website functioning;
• remember preferences;
• understand how visitors use the website;
• measure performance;
• identify and fix technical problems;
• protect against fraud and abuse; and
• improve our products and services.

Some cookies may be necessary for the website to operate.

Other analytics or optional technologies may be subject to additional choices or consent depending on applicable law and how Dwello configures the website.

Where required, we will provide appropriate cookie notices or controls.

We retain information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to:

• operate the Dwello Network;
• maintain business and network records;
• respond to inquiries;
• support customer requests;
• maintain security;
• resolve disputes;
• comply with legal obligations; and
• enforce agreements.

The appropriate retention period may vary depending on the type of information, the nature of our relationship with you, and applicable legal requirements.

When information is no longer reasonably necessary, we may delete, anonymize, or de-identify it, subject to applicable law.

Dwello uses reasonable administrative, technical, and organizational safeguards designed to protect information against unauthorized access, loss, misuse, alteration, or disclosure.

However, no website, database, network, transmission method, or storage system can be guaranteed to be completely secure.

You should use appropriate caution when transmitting information electronically.

Depending on where you live and applicable law, you may have rights concerning your personal information.

These may include the right to:

• request access to personal information we maintain about you;
• request correction of inaccurate information;
• request deletion of certain personal information;
• obtain a copy of certain information;
• opt out of certain uses or disclosures;
• withdraw consent where processing is based on consent; and
• appeal certain decisions concerning a privacy request.

These rights are not absolute and may be subject to legal exceptions.

Dwello will not unlawfully discriminate against you for exercising an applicable privacy right.

To exercise an applicable privacy right, contact us using the contact information provided below.

We may need to verify your identity before completing certain requests.

Residents of certain U.S. states may have additional privacy rights under applicable state law.

Where applicable, Dwello will honor rights relating to access, correction, deletion, portability, consent, and opt-out choices as required by law.

The specific rights available to you depend on your state of residence, the information involved, and whether the relevant law applies to Dwello.

If we deny a privacy request and applicable law provides a right to appeal, instructions for submitting an appeal will be provided with our response.

The Dwello Network website is intended for businesses and adults and is not directed to children under 13.

We do not knowingly collect personal information from children under 13 through this website.

If we learn that we have collected personal information from a child in violation of applicable law, we will take reasonable steps to delete it.

The Dwello website may contain links to third-party websites or services.

We are not responsible for the privacy practices, security, content, or policies of third parties that we do not control.

We encourage you to review the privacy policies of third-party services before providing information to them.

Dwello may operate or use service providers in more than one country.

If information is transferred across national borders, it may be processed in countries with privacy laws different from those where you live.

Where required, Dwello will use appropriate safeguards for international transfers of personal information.

Dwello may update this Privacy Policy as our services, technology, network, or legal obligations evolve.

When we update the policy, we will revise the Last Updated date at the top.

If required by law, we will provide additional notice or obtain consent for material changes.

We encourage you to review this Privacy Policy periodically.

If you have questions about this Privacy Policy, Dwello's privacy practices, or would like to exercise an applicable privacy right, please contact us using the contact information provided on the Dwello website.

Joining the Dwello Network means Dwello may maintain information about your business so that we can understand:

• what you do,
• where you operate, and
• how to reach you when a relevant opportunity arises.

Our goal is to use that information responsibly and only in ways consistent with operating and improving the Dwello Network, applicable agreements, this Privacy Policy, and applicable law.