DWELLO MOBILE APPLICATION

PRIVACY POLICY

Last updated July 21, 2025

This privacy notice for Dwello App ("Company," "we," "us," or "our"), describes how and why we

might collect, store, use, and/or share ("process") your information when you use our services

("Services"), such as when you:

Download and use our mobile application (Dwello), or any other application of ours that links to

this privacy notice; or

Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights

and choices. If you do not agree with our policies and practices, please do not use our Services. If you

still have any questions or concerns, please contact us at ryanserrano61@gmail.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details

about any of these topics by using our table of contents below to find the section you are looking

for.

What personal information do we process? When you visit, use, or navigate our Services, we may

process personal information depending on how you interact with Dwello App and the Services, the

choices you make, and the products and features you use.

Do we receive any information from third parties? Yes. We do receive information from third parties.

In what situations and with which parties do we share personal information? We may share

1information in specific situations and with specific third parties.

How do we keep your information safe? We have organizational and technical processes and

procedures in place to protect your personal information. However, no electronic transmission over the

internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise

or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat

our security and improperly collect, access, steal, or modify your information.

What are your rights? Depending on where you are located geographically, the applicable privacy law

may mean you have certain rights regarding your personal information.

How do you exercise your rights? The easiest way to exercise your rights is by contacting us. We

will consider and act upon any request in accordance with applicable data protection laws.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

5. HOW LONG DO WE KEEP YOUR INFORMATION?

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

7. DO WE COLLECT INFORMATION FROM MINORS?

8. WHAT ARE YOUR PRIVACY RIGHTS?

9. CONTROLS FOR DO-NOT-TRACK FEATURES

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

11. DO WE MAKE UPDATES TO THIS NOTICE?

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

21. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us.

3In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining

information about us or our products and Services, when you participate in activities on the Services, or

otherwise when you contact us. When accessing or using the Services, you may provide Personal Information

about yourself to us. “Personal Information” means information relating to a person that can be used to

identify that individual. This may include your name, address, telephone number, email address, age, gender,

religion, and professional information. Personal Information does not include: (1) anonymous information;

(2) any publicly available information about you or any other user; (3) information about you that is provided

by third parties; or (4) information that is posted to publicly accessible areas of the Services. Examples of

Personal Information we collect include information that you provide when you (a) create or update your

Dwello account, (b) communicate with us, (c) purchase services from us, (d) contact or recommend a real

estate agent or other user, and (e) submit recommendations or endorsements.

Application Data. If you use our application(s), we also may collect the following information if you choose

to provide us with access or permission:

Geolocation Information. We may request access or permission to track location-based

information from your mobile device, either continuously or while you are using our mobile

application(s), to provide certain location-based services. If you wish to change our access or

permissions, you may do so in your device's settings.

Mobile Device Access. We may request access or permission to certain features from your mobile

device, including your mobile device's camera, and other features. If you wish to change our access or

permissions, you may do so in your device's settings.

Push Notifications. We may request to send you push notifications regarding your account or certain

features of the application(s). If you wish to opt out from receiving these types of communications, you

may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s),

for troubleshooting, and for our internal analytics and reporting purposes.All personal information

that you provide to us must be true, complete, and accurate, and you must notify us of any changes

4to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device

characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This

information does not reveal your specific identity (like your name or contact information) but may include

device and usage information, such as your IP address, browser and device characteristics, operating

system, language preferences, referring URLs, device name, country, location, information about how

and when you use our Services, and other technical information. This information is primarily needed to

maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. The

information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance

information our servers automatically collect when you access or use our Services and which we

record in log files. Depending on how you interact with us, this log data may include your IP address,

device information, browser type, and settings and information about your activity in the Services

(such as the date/time stamps associated with your usage, pages and files viewed, searches, and other

actions you take such as which features you use), device event information (such as system activity,

error reports (sometimes called "crash dumps"), and hardware

settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or

other device you use to access the Services. Depending on the device used, this device data may

include information such as your IP address (or proxy server), device and application identification

numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier,

operating system, and system configuration information.

Location Data. We collect location data such as information about your device's location, which can

be either precise or imprecise. How much information we collect depends on the type and settings of

5the device you use to access the Services. For example, we may use GPS and other technologies to

collect geolocation data that tells us your current location (based on your IP address). You can opt

out of allowing us to collect this information either by refusing access to the information or by

disabling your Location setting on your device. However, if you choose to opt out, you may not be

able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with

you, for security and fraud prevention, and to comply with law. We may also process your information for

other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact With our

Services, including:

To send you marketing and promotional communications. We may process the personal

information you send to us for our marketing purposes, if this is in accordance with your

marketing preferences. You can opt out of our marketing emails at any time.

To deliver targeted advertising to you. We may process your information to develop and display

personalized content and advertising tailored to your interests, location, and more.

To determine the effectiveness of our marketing and promotional campaigns. We may process your

information to better understand how to provide marketing and promotional campaigns that are most

relevant to you.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following

third parties.

We may need to share your personal information in the following situations:

6Business Transfers. We may share or transfer your information in connection with, or during

negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of

our business to another company.

When we use Google Maps Platform APIs. We may share your information with certain Google

Maps Platform APIs (e.g., Google Maps API, Places API). To find out more about Google’s Privacy

Policy, please refer to this link. We use certain Google Maps Platform APIs to retrieve certain

information when you make location-specific requests. This includes: Location; and other similar

information. A full list of what we use information for can be found in this section and in the

previous section titled "HOW DO WE PROCESS YOUR INFORMATION?". We obtain and store on

your device ("cache") your location. You may revoke your consent anytime by contacting us at the

contact details provided at the end of this document. The Google Maps Platform APIs that we use

store and access cookies and other information on your devices.

Business Partners. We may share your information with our business partners to offer you certain

products, services, or promotions.

Offer Wall. Our application(s) may display a third-party hosted "offer wall." Such an offer wall

allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the

acceptance and completion of an advertisement offer. Such an offer wall may appear in our

application(s) and be displayed to you based on certain data, such as your geographic area or

demographic information. When you click on an offer wall, you will be brought to an external

website belonging to other persons and will leave our application(s). A unique identifier, such as

your user ID, will be shared with the offer wall provider in order to prevent fraud and properly

credit your account with the relevant reward.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We do not use cookies and other tracking technologies to collect and store your information.

We do not use cookies and similar tracking technologies (like web beacons and pixels) to access or store

information.

75. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy

notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this

privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or

other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete

or anonymize such information, or, if this is not possible (for example, because your personal information has

been stored in backup archives), then we will securely store your personal information and isolate it from any

further processing until deletion is possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical

security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed

to protect the security of any personal information we process. However, despite our safeguards and

efforts to secure your information, no electronic transmission over the Internet or information storage

technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,

cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly

collect, access, steal, or modify your information. Although we will do our best to protect your personal

information, transmission of personal information to and from our Services is at your own risk. You

should only access the Services within a secure environment.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

8We do not knowingly solicit data from or market to children under 18 years of age. By using the Services,

you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to

such minor dependent’s use of the Services. If we learn that personal information from users less than 18

years of age has been collected, we will deactivate the account and take reasonable measures to promptly

delete such data from our records. If you become aware of any data we may have collected from children

under age 18, please contact us at ryanserrano61@gmail.com.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal

information, you also have the right to complain to your local data protection supervisory authority.

You can find their contact details here:

https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here:

https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information,

which may be express and/or implied consent depending on the applicable law, you have the right to

withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using

the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?"

below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor,

when applicable law allows, will it affect the processing of your personal information conducted in

9reliance on lawful processing grounds other than consent. If you have questions or comments about your

privacy rights, you may email us at ryanserrano61@gmail.com.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-

Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data

about your online browsing activities monitored and collected. At this stage no uniform technology

standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently

respond to DNT browser signals or any other mechanism that automatically communicates your choice

not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we

will inform you about that practice in a revised version of this privacy notice.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your

personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who

are California residents to request and obtain from us, once a year and free of charge, information about

categories of personal information (if any) we disclosed to third parties for direct marketing purposes and

the names and addresses of all third parties with which we shared personal information in the immediately

preceding calendar year. If you are a California resident and would like to make such a request, please

submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have

the right to request removal of unwanted data that you publicly post on the Services. To request removal of

such data, please contact us using the contact information provided below and include the email address

associated with your account and a statement that you reside in California. We will make sure the data is not

publicly displayed on the Services, but please be aware that the data may not be completely or

comprehensively removed from all our systems (e.g., backups, etc.).

10CCPA Privacy Notice

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and;

(2) every individual who is domiciled in the State of California who is outside the State of California for a

temporary or transitory purpose.

All other individuals are defined as "non-residents."

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your

personal information.

What categories of personal information do we collect?

See below for an explanation of personal information we have collected in the past twelve (12) months:

Category Examples Collecte

d

A. Identifiers Contact details, such as real name, alias, postal

address, telephone or mobile contact number,

unique personal identifier, online identifier,

Internet Protocol address, email address, and

account name

YES

B. Personal

information categories

listed in the California

Customer Records

statute

Name, contact information, education,

employment, employment history, and financial

information

NO

11C. Protected classification

characteristics under California

or federal law

Gender and date of birth D. Commercial information

Transaction information, purchase history,

financial details, and payment information E. Biometric information Fingerprints and voiceprints F. Internet or other

similar network activity

Browsing history, search history, online behavior,

interest data, and interactions with our and other

websites, applications, systems, and

advertisements

G. Geolocation data Device location H. Audio, electronic,

visual, thermal,

olfactory, or similar

information

Images and audio, video or call recordings

created in connection with our business activities

I. Professional or

employment-related

information

Business contact details in order to provide you

our Services at a business level or job title, work

history, and professional qualifications J. Education

Information

Student records and directory information K. Inferences drawn

from other personal

information

Inferences drawn from any of the collected

personal information listed above to create a

profile or summary about, for example, an

individual’s

preferences and characteristics

12

NO

NO

NO

NO

YES

YES

YES

NO

NOWe may also collect other personal information outside of these categories through instances where you

interact with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice.

You may contact us by email at ryanserrano61@gmail.com, or by referring to the contact details at the

bottom of this document.

If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized

agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with third-parties, pursuant to a written contract

between us and each service provider. Each service provider is a for-profit entity that processes the

information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal

research for technological development and demonstration. This is not considered to be "selling" of your

personal information.

Dwello App has not disclosed or sold any personal information to third parties for a business or commercial

purpose in the preceding twelve (12) months. Dwello App will not sell personal information in the future

belonging to website visitors, users, and other consumers.

13Your rights with respect to your personal data

Right to request deletion of the data — Request to delete

You can ask for the deletion of your personal information. If you ask us to delete your personal

information, we will respect your request and delete your personal information, subject to certain

exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right

to free speech, our compliance requirements resulting from a legal obligation, or any processing that may

be required to protect against illegal activities.

Depending on the circumstances, you have a right to know:

▪ whether we collect and use your personal information;

▪ the categories of personal information that we collect;

▪ the purposes for which the collected personal information is used;

▪ whether we sell your personal information to third parties;

▪ the categories of personal information that we sold or disclosed for a business purpose;

▪ the categories of third parties to whom the personal information was sold or disclosed for a business

purpose; and

▪ the business or commercial purpose for collecting or selling personal information.

Right to be informed — Request to know

In accordance with applicable law, we are not obligated to provide or delete consumer information that is

de-identified in response to a consumer request or to re-identify individual data to verify a consumer

request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

14We will not discriminate against you if you exercise your privacy rights.

Verification process

Upon receiving your request, we will need to verify your identity to determine you are the same person about

whom we have the information in our system. These verification efforts require us to ask you to provide

information so that we can match it with information you have previously provided us. For instance,

depending on the type of request you submit, we may ask you to provide certain information so that we can

match the information you provide with the information we already have on file, or we may contact you

through a communication method (e.g., phone or email) that you have previously provided to us. We may also

use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make

the request. To the extent possible, we will avoid requesting additional information from you for the

purposes of verification. However, if we cannot verify your identity from the information already

maintained by us, we may request that you provide additional information for the purposes of verifying your

identity and for security or fraud-prevention purposes. We will delete such additionally provided

information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information.

You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict

the processing of the information.

You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny

a request from an authorized agent that does not submit proof that they have been validly authorized to

act on your behalf in accordance with the CCPA.

You may request to opt out from future selling of your personal information to third parties. Upon

receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later

than fifteen (15) days from the date of the request submission.

15ryanserrano61@gmail.com, or by referring to

To exercise these rights, you can contact us by email at the contact details at the bottom of this document. If you have a complaint about how we handle your

data, we would like to hear from you.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated

"Revised" date and the updated version will be effective as soon as it is accessible. If we make material

changes to this privacy notice, we may notify you either by prominently posting a notice of such changes

or by directly sending you a notification. We encourage you to review this privacy notice frequently to be

informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at ryanserrano61@gmail.com mail to:

or by

Dwello App

11617 Leapwood Place

Austin, TX 78759

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT

FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal

information we collect from you, change that information, or delete it. To request to review, update, or delete

your personal information, please submit a request form by contacting us at ryanserrano61@gmail.com.