Privacy Policy

TwoDwell PBC and TwoDwell Funding Inc. and their respective affiliates (collectively, “TwoDwell,” “we,” “us,” or “our”) provide software and related services that help professionals analyze and plan Accessory Dwelling Unit (“ADU”) projects. The Services are used by ADUExperts™ (paid professional subscribers) and Homeowners (free, non-subscribing users who request or receive ADU Ready Reports). We collect different types and amounts of information depending on your user type, as described below. This Privacy Policy explains the types of information that we collect and how we collect, use, disclose, and protect information in connection with twodwell.com and our related products and services (collectively, the “Services”).

1. Information we collect

We may collect the following types of information from you directly (collectively, User Content):

• Account information such as name, email address, password, company name, company affiliation, and other contact details that you provide when you create an account or request access to Services.
• Professional information such as license or certification details (for ADU professionals), organization name, and related profile data.
• Project data including property addresses, zoning inputs, ADU feasibility parameters, and other project information that you submit through the platform.
• Payment information such as billing address and limited payment details (processed via our third-party payment processor(s); we do not store full credit card numbers).
• Support and communications including messages, feedback, and other information that you send us via email, chat, or otherwise, as may be necessary or helpful for us to provide the Services or offer you assistance or support.
• AI interaction data: questions, prompts, and conversations you submit to Lottie, our AI-powered ADU assistant, and the responses generated. By submitting questions or prompts to Lottie, you consent to the processing, storage, and use of your inputs and the responses generated for the purpose of providing the Services and improving Lottie’s functionality. Lottie interactions may be recorded and retained in accordance with Section 6 of this Privacy Policy. If a third-party AI provider processes your Lottie inputs, that provider acts as a service provider to TwoDwell under a contract that prohibits the provider from using your data for any purpose other than performing services on TwoDwell’s behalf. The current third-party AI providers are Anthropic (Claude) for conversational responses and OpenAI for embeddings.
• CRM data (ADUExperts only): leads, contacts, client information, and pipeline notes you enter into the Pro CRM feature.
• Homeowner information: if you are a Homeowner requesting an ADU Ready Report, we may collect the property address and, optionally, your name and contact information to deliver the report. Homeowners do not create accounts.

Some of the types of information listed above may be provided by third parties rather than from you directly. Not all User Content constitutes personally identifiable information; information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household is considered “Personal Information”.

We may also collect usage data including IP address, device and browser type, operating system, pages viewed, links clicked, time spent, and other persistent identifiers or analytics data about how you use the Services.

2. How we collect information

We collect information:

• Directly from you, including when you create an account, fill out forms, upload project data, or communicate with us. By providing your User Content and Personal Information, you consent to our collection, processing, storage, and sharing of your User Content and Personal Information for the purposes described in this Privacy Policy.
• Automatically through cookies (a small text file placed on your device to store data, preferences and activity), pixels (a tiny, embedded image that tracks visits, clicks and other activities), and similar technologies when you access or use the Services. Non-essential tracking technologies are not activated until you provide consent as described in Section 4.
• From third parties, such as payment processors, analytics providers, or integration partners that you connect to TwoDwell.

3. How we use information

We use the information we collect to:

• Provide, operate, and maintain the Services, including generating ADU analyses and reports.
• Create and manage your account, process transactions, and provide customer support.
• Improve and develop the Services, including troubleshooting, data analysis, testing, and research.
• Communicate with you about updates, security alerts, billing, support, and administrative messages.
• Send you marketing communications as permitted by law and your preferences (you can opt out at any time).
• Comply with legal obligations or address compliance needs and to defend or resolve legal claims, including without limitation, to enforce our Terms of Service, policies, and contractual rights.

We may de-identify and/or aggregate data for analytics, benchmarking, and product improvement. Aggregated/de-identified data does not identify you personally.

4. Cookies and similar technologies

When you first visit our website, we will ask for your consent before activating non-essential cookies, pixels, or similar tracking technologies. Essential cookies required for the basic functioning of the Services (such as session management and authentication) do not require consent.

You may withdraw your consent at any time through our cookie preferences tool (powered by CookieBot), accessible via the link in the footer of any page on twodwell.com. We use the following categories of tracking technologies:

• Essential cookies: required for the Services to function (e.g., login session, security tokens). These cannot be disabled.
• Analytics tools: Google Analytics 4 to understand how users interact with the Services, including pages viewed, clicks, time spent, and navigation paths. These tools may collect IP addresses, device identifiers, and browser type. Analytics tools do not fire until you provide consent.
• Mapping and property data: Google Maps (or equivalent provider) loads when you use property visualization features and may set its own cookies subject to Google’s privacy policy.
• Payment processing: Stripe sets cookies necessary to process transactions securely.
• Behavioral messaging: Customer.io sets cookies and collects session data on twodwell.com, including page URL, page title, referrer, timestamp, anonymous visitor ID, browser information, device type, operating system, screen size, language, and session information. This data is used to trigger automated email communications based on your interactions with the Services (such as account verification, onboarding reminders, and subscription notifications). Customer.io tracking does not fire until you provide consent through our cookie preferences tool.
• Advertising and measurement: Meta Pixel and Google Ads conversion tracking are used to measure the effectiveness of our advertising campaigns. These tools may collect IP addresses, device identifiers, cookie data, and information about your interactions with our ads and website. Advertising pixels do not fire until you provide consent through our cookie preferences tool. When we detect a Global Privacy Control (GPC) signal from your browser, advertising pixels are suppressed.

We do not use session replay tools (such as FullStory, Hotjar, or Microsoft Clarity) that record your keystrokes, mouse movements, or screen activity. We do not use fingerprinting or identity resolution tools. If we add any new category of tracking technology in the future, we will update this Privacy Policy and, where required, obtain your consent before activation. You can control cookies through your browser settings, but disabling essential cookies may affect certain features of the Services.

5. How we share information

We may share User Content and Personal Information as follows:

• Service providers: with trusted third-party vendors, including Stripe (payments), Railway and Vercel (hosting), Google Maps or equivalent mapping provider (property data), Circle.so (community platform), Customer.io (behavioral messaging), and VistaPrint (sign rider fulfillment), who process data on our behalf under appropriate safeguards. The specific providers we use may change; a current list is available upon request.
• Our contracts with service providers include provisions that prohibit them from using Personal Information for any purpose other than performing services on TwoDwell’s behalf, and from selling, sharing, or retaining Personal Information beyond what is necessary to provide the contracted services, as required by the CCPA.
• Business transfers: in connection with a merger, acquisition, financing, or sale of all or a portion of our business or assets.
• Legal and safety: when required by law or in response to valid legal requests, or to protect the rights, property, or safety of TwoDwell, our users, or others.
• Financing partners: when you initiate a financing inquiry through ADU Advantage™, basic property and contact information may be shared with Professional Mortgage Group, Inc. dba ProMortgage, TwoDwell’s joint venture partner and the licensed mortgage broker that originates loans under the ADU Advantage program. Any loan application data (including Social Security numbers and financial documentation) is collected and processed by ProMortgage directly on ProMortgage’s systems, subject to ProMortgage’s own terms and privacy policy. TwoDwell does not collect or store this data.
• Community platform: if you participate in TwoDwell’s member community, your profile information (including name, email address, username, profile photo, bio, location, website, and social media links) is shared with Circle.so, the third-party platform that hosts the community. Circle.so processes this data as a service provider to TwoDwell under a contract that limits its use to operating the community on our behalf.

6. Data retention

We retain Personal Information for as long as necessary to provide the Services and fulfill the purposes described in this Privacy Policy. When you delete your account or we terminate your access, we will delete your Personal Information within sixty (60) days, except where retention is required by law, necessary for accounting or tax purposes, or where we have a legitimate business need to retain aggregated or de-identified data. You may request deletion of your Personal Information at any time by contacting us at privacy@twodwell.com, subject to the exceptions described in Section 11.

For Homeowners who do not have accounts, we retain property addresses and contact information for ninety (90) days following delivery of the ADU Ready Report, after which it is deleted unless retention is required by law or reasonably necessary to fulfill a request or resolve a dispute.

7. Your rights and choices

Depending on your jurisdiction, you may have rights to:

• Access the personal information we hold about you.
• Request correction or deletion of your personal information.
• Object to or restrict certain processing.
• Opt out of marketing communications.

You can exercise some of these rights by logging into your account or contacting us at privacy@twodwell.com with your request.

8. Security

We use reasonable administrative, physical and technical safeguards (such as encryption in transit, access controls and monitoring) intended to protect against the loss, misuse, or unauthorized access, acquisition, alteration or destruction of information that we collect through physical and automated means. We also communicate our privacy and security practices to our employees and suppliers. No system is completely secure, and we cannot guarantee the absolute security of information transmitted to or stored by the Services.

9. Children’s privacy

The Services are designed for real estate professionals and property owners and are not directed at children. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, please contact us so we can take appropriate action.

10. International users

If you access the Services from outside the United States, you understand that your information may be processed in the United States and other countries with different data protection laws than where you live. Your information may also be processed by service providers and contractors located outside the United States, including in the European Economic Area. By using the Services, you consent to such transfers.

11. California residents

This section is provided in the event that we are subject to the California Consumer Privacy Act (“CCPA”). We have received the following categories of consumer Personal Information within the last twelve (12) months:

CCPA provides California residents with certain rights regarding their Personal Information (subject to certain limitations at law). The following paragraphs describe these CCPA rights.

Right to Access and Portability

California residents have the right to request disclosure of certain information about the collection and use of Personal Information over the last twelve (12) months. Once we receive and confirm your verifiable consumer request, we will disclose to you the following:

• The categories of Personal Information collected.
• The categories of sources for the Personal Information collected.
• Our business or commercial purpose for collecting Personal Information.
• The categories of third parties with whom we share that Personal Information.
• The specific pieces of Personal Information collected about you (also called a data portability request).
• If we disclose your Personal Information for a business purpose, identifying the Personal Information categories disclosed.

Right to Deletion

The CCPA allows California residents the right to request the deletion of any Personal Information that we collect and retain, subject to certain exceptions.

Right to Correct

California residents have the right to request correction of inaccurate Personal Information that TwoDwell maintains about them. To exercise this right, please contact us at privacy@twodwell.com.

A request may be denied if retaining the information is necessary to:

• Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, or take actions reasonably anticipated within the context of our ongoing business relationship with you.
• Detect security incidents, or protect against malicious, deceptive, fraudulent, or illegal activity.
• Debug products to identify and repair errors that impair existing intended functionality.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Enable solely internal uses that are reasonably aligned with consumer expectations.
• Comply with a legal obligation and requests from law enforcement agencies.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of the Sale of Your Information

We do not sell your Personal Information. Certain advertising technologies described in Section 4 may constitute ‘sharing’ of Personal Information under the CCPA when activated with your consent. You may opt out of sharing at any time by adjusting your cookie preferences or enabling Global Privacy Control in your browser. We restrict our service providers from selling or sharing Personal Information they receive from us.

Right to Non-Discrimination

TwoDwell will not discriminate against you for exercising any of your CCPA rights. We will not deny you goods or services, charge you different prices, or provide you a different quality of service because you exercised your rights under the CCPA.

Do Not Sell or Share; Opt-Out Preference Signals

TwoDwell does not sell your Personal Information for monetary or other valuable consideration, and has not done so in the preceding twelve (12) months. When you consent to advertising cookies (such as Meta Pixel and Google Ads conversion tracking) through our cookie preferences tool, certain identifiers and browsing activity may be shared with advertising partners for the purpose of measuring ad performance. Under the CCPA, this may constitute “sharing” of Personal Information for cross-context behavioral advertising. These technologies are not activated unless you provide consent.

TwoDwell honors Global Privacy Control (GPC) and other opt-out preference signals recognized under applicable law. When we detect a GPC signal from your browser, we treat it as a valid request to opt out of the sale or sharing of Personal Information associated with that browser, and advertising pixels are suppressed. You do not need to take any additional action.

Our service providers are contractually prohibited from selling or sharing Personal Information they receive from TwoDwell and from using it for any purpose other than performing services on our behalf.

To exercise the access and deletion rights under the CCPA as described above, please submit your request to us as set forth below. A verifiable consumer request may be submitted by a California resident or a person registered with the California Secretary of State that is authorized to act on your behalf. Requests for access can only be made twice during a twelve (12) month period. Requests for access and deletion must:

• Detail sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if your identity or authority to make the request cannot be verified. We will respond to requests from you within forty-five (45) days of receipt. The period of response may be extended to sixty (60) or ninety (90) days if more time is required. In that event, we will inform you of the reason and extension period in writing. We do not charge individuals a fee to process or respond to a verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated policy on this page and update the “Last updated” date. Your continued use of the Services after changes become effective means you accept the updated policy.

13. Reviewing, updating or deleting data

Based on the applicable laws of your jurisdiction, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please contact us at privacy@twodwell.com. We will endeavor to respond to your request within thirty (30) days. For requests submitted under the CCPA, we will respond within forty-five (45) days as described in Section 11.

14. Contact us

If you have questions about this Privacy Policy or our privacy practices, please contact us at:

TwoDwell PBC
490 Post St, Ste 500, PMB 2387
San Francisco, CA 94102
Email: privacy@twodwell.com