Privacy Policy

DWELLFI PRIVACY POLICY

DwellFi offers comprehensive fund management solutions to private equity, real estate, venture capital, hedge funds, fund administrators, and limited partners through our state-of-the-art AI and blockchain technologies.

This Privacy Policy describes how DwellFi, its affiliates and subsidiaries (collectively, “DwellFi”, “we”, “us” or “our”) collect, use, store, share and protect your information when you use our platform (”Services”), visit the DwellFi Website (“Website”) and what we do with such information.

This Privacy Policy provides a general overview of our privacy practices regarding your information. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions, and which may be applicable to you when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. You can learn more about certain jurisdiction-specific information in the applicable sections at the bottom of this Privacy Policy.

By using or accessing the Website and the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the manner outlined below.

I. PURPOSE OF THIS PRIVACY POLICY

We know how important privacy is to our users, which is why this Privacy Policy explains how we collect and use data.

1. The Data We Collect about You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the attributes to identify an individual have been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

Identity Data includes first name, middle name, maiden name, last name, title, identity document number, nationality and any other information contained in any identification documents you provide to us (e.g., your passport or driver’s license).
User Content includes information contained in the inputs, file uploads or feedback that you provide while using the Services
Transaction Data includes details of your activity using the Services, such as the amount, date, time, and recipient for each transaction.
Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website and portal.
Profile Data includes your username or similar identifier, password, and your communication preferences.
Usage Data includes information about how you use our Website and Services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third-party vendors and your communication preferences.
Survey and Customer Feedback Data includes information you provide in any survey or feedback forms on Services.

We DO NOT collect any special categories of personal data about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

2. Know-your-customer & Anti-Money Laundering Verification

When you register for a DwellFi account or otherwise use our Website, we perform certain verification or compliance checks, in accordance with applicable know-your-customer and anti-money laundering regulations, through our “empaneled third-party vendors”. We carry out these checks in order to detect or prevent any unlawful or fraudulent acts and to comply with our legal and ethical obligations.

3. If you fail to provide Personal Data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e., to provide our Services to you). In this case, we may have to close your DwellFi Account or limit or restrict your access to our other services, per DwellFi’s Terms of Service, but we will duly notify you if this is the case at the time.

II. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your identity, contact, financial, transaction, profile, usage, marketing and communications and location data by filling in forms or by corresponding with us by post, email, or otherwise. This includes personal data you provide when:
- you create or use your DwellFi Account;
- you request us to build a custom AI agent;
- you update information about a wire transfer to your DwellFi Account;
- we need to request more information to verify your identity or to meet our legal obligations;
- you request marketing material to be sent to you;
- you participate in a survey; or
- you give us some feedback.
Automated technologies or interactions. When you interact with our Services, we may automatically collect usage and technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.

III. HOW WE USE YOUR PERSONAL DATA

We collect all of the information in Section II above so that we can provide you with the Services. The information we collect allows us to:

Deliver the full functionality of the Services;
Keep in touch with you – whether it be for providing customer service, notifying you of new features or updates to the Services, or providing security notices or information;
Verify your identity so that we can prevent fraud or unauthorized activity, and to comply with applicable laws; and
Fulfill any other purpose for which the information was collected.

We will never share, sell, or rent your personal data to third parties. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, as well as our content and advertising.

1. Your personal data will only be used for our Legitimate Interests

We will only use your personal data for our legitimate interests. ‘Legitimate interest’ means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting support@dwell.fi.

2. Change of Purpose

We will only use your personal data in accordance with the purposes described in this Privacy Policy and as provided for under applicable law for the purposes for which we collected it. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at support@dwell.fi.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

3. Third-Party providers and links

When you interact with AI agents, your information may be processed by third-party Large Language Model (LLM) providers, depending on which AI model powers the agent you’re using. In such cases, we ensure that these providers adhere to our privacy and security standards and that your data is protected in accordance with this Privacy Policy.

Third-party data processing: We may connect to third-party LLMs when you submit data to an agent, that information is transmitted to the relevant LLM provider for processing. We require our AI service providers to use your information only for the purpose of providing our Service and we do not allow those providers to train their AI models using your data. The input data is deleted once a response is generated and sent back to our platform.
Protected transmission: We ensure secure transmission of your data to these providers through encryption. We encourage users to be mindful of the types of information shared with agents, especially for sensitive personal data and inform us of any particular concerns before using our Services.

The Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. If you click on such links, you will leave our secure platform, and we are not responsible for the data collection and processing practices of the third party. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

4. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional Offers from Us: You will receive marketing communications from us if you (i) have requested information from us; (ii) use our Services; or (iii) provided us with your details when you registered for a promotion and you have not opted out of receiving that marketing.
Opting Out: You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting support@dwell.fi at any time.

Please note that when you opt-out of receiving these marketing messages, it will not apply to personal data provided to us as a result of your use of the Services, a product/service experience, or other transactions with our Website. Opting out will also not opt you out of receiving non-marketing information such as account statements and updates to this Privacy Policy or our user agreement.

5. Cookies

“Cookies” are small text files stored in your computer or other electronic devices when you visit our Website or use our Services for record-keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the Website or use our platform, your browser will read the cookie and relay the information back to the Website or element that originally set the cookie.

We may employ cookies and other technologies as follows:

Tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;
To better tailor our Services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;
Collating information on your search and browsing history;
When you interact with us on our Website, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the Website, the browser used by a visitor, the operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (which may including, for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page);
Making our Website and Services easier to use. For example, cookies may be used to help speed up your future interactions with our Website and Services; and
We use cookies that are necessary to enable our Website and Services to operate, for example, cookies that enable you to log onto secure parts of our Website and Services.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

6. Do Not Track

“Do Not Track” is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. Our Website does not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Website or the Services and after you leave.

IV. When applying for a position with us

If you submit an application to us as a candidate for employment, internship or partnership, we collect, use, disclose and process your profile for management and evaluative purposes, including, without limitation, processing your employment application, conducting pre-recruitment checks, and/or providing or obtaining employee references or other references where relevant for background screening or vetting after being selected for the relevant position.

V. SECURITY

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls and information access authorization controls.

Sometimes in order to better secure your information and use it for the purposes contemplated by this Privacy Policy, certain personal data may be stored with our third-party partners and service providers.

VI. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfill the purposes for which we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

VII. CHILDREN’S PRIVACY

If you’re under 18, you can’t create a DwellFi account or use or interact with other DwellFi products. We do not knowingly solicit or collect information from anyone under 18. If you believe that we may have collected personal data from someone under the age of 18 without proper parental or guardian consent, please let us know by contacting support@dwell.fi and we will take appropriate measures to investigate and address the issue promptly.

VIII. NOTICE TO CALIFORNIA RESIDENTS

This Notice under the California Consumer Privacy Act of 2018 (Cal. Civ. Code § 1798.100 et seq.) (“CCPA”) Notice, including the description of our Privacy Practices and your Privacy Rights, applies only to California residents whose interactions with us are limited to:

visiting our Website; and
signing up for email alerts.

This CCPA Notice does not apply to the personal information we collect, use or disclose about:

individuals who provide information to us to initiate or complete the process of interacting with our Services, which are subject to the notice set forth in the “How We Collect Your Personal Data” and “How We Use Your Personal Data” sections of this Policy,or
representatives of businesses that seek to obtain our products or services, or to provide products or services to us”.

A. Privacy practices

We do not “sell” the personal data we collect (as such term is defined in the CCPA) for monetary value. If you would like to learn how you may opt out of our use of cookies and other tracking technologies, please review the instructions provided in our “Marketing-Opting Out” and “Cookies” section of this Policy.

B. Privacy rights

The CCPA grants individuals the following rights:

Information. You can request information about how we have collected, used and shared your personal data during the past 12 months. For details about the personal data we have collected over the last 12 months, including the categories of sources, please see the “Purpose Of This Policy” and “How We Collect Your Personal Data” sections of this Policy.
Access. You can request a copy of the personal information that we maintain about you.
Deletion. You can ask us to delete the personal information that we collected or maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. We will also respond to requests for information and access only to the extent we are able to associate with a reasonable effort the information we maintain with the identifying details you provide in your request. If we deny your request, we will communicate our decision to you. You are entitled to exercise the rights described above free from discrimination.

C. How to submit a request

To request access to or deletion of personal information, please write to support@dwell.fi.

D. Identity verification

The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We will ask you to verify your identity when you submit a request.

E. Authorized agents

California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.

IX. ADDITIONAL DISCLOSURES FOR INDIVIDUALS IN EUROPE

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data, and this section applies to you.

1. Legal basis for processing

When we process your personal data, we will do so in reliance on the following lawful bases:

to perform our responsibilities under our contract with you (e.g., providing the Services you requested).
when we have a legitimate interest in processing your personal data to operate our business or protect our interests (e.g., to provide, maintain, and improve our products and services, conduct data analytics, and communicate with you).
to comply with our legal obligations (e.g., to maintain a record of your consent and track those who have opted out of marketing communications).
when we have your consent to do so (e.g., when you opt-in to receive marketing communications from us). When consent is the legal basis for our processing of your personal data, you may withdraw such consent at any time.

2. Complaints

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside. Contact details for your Data Protection Authority can be found using the links below:

For individuals in the European Economic Area: https://edpb.europa.eu/about-edpb/board/members_en
For individuals in the UK: https://ico.org.uk/global/contact-us/
For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

X. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may change this Privacy Policy from time to time. When we do make updates, we’ll let you know by changing the date at the bottom of this Privacy Policy. If it is a more extensive or significant update, we’ll send you a notification or post a notice on our website. If you ever have any questions about changes made to the Privacy Policy, just reach out to us at support@dwell.fi.

It is important that the personal data we hold about you is accurate and current. If you need to add or change any information, you can just log in to your DwellFi account and make the change in your settings. If you cannot make the change on your own, just reach out to support@dwell.fi and we will take care of it. Please keep us informed if your personal data changes during your relationship with us.

XI. QUESTIONS

If you have any questions about this Privacy Policy, feel free to email support@dwell.fi and we will try to address your concerns at the earliest.

Version: 2.5

Last updated on: June 27, 2025