Privacy Policy

Effective Date: March 2, 2026

Last Updated: April 3, 2026

1. Introduction

Welcome to Doughy, a product of Secondly Homes LLC (doing business as “Secondly”) (“Company,” “we,” “our,” “us”). Your privacy is important to us. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our services, including:

• Doughy — our mobile and web application for real estate investors and landlords, including deal management, portfolio tracking, call coaching, CRM, SMS communications, automated briefings, draft generation, and approval workflows

By using any of our services, you consent to the data practices described in this policy.

2. Information We Collect

Information You Provide Directly

• Account information: Name, email address, phone number, and password when you create an account.

• Property data: Property addresses, financial details, mortgage information, and related documents you enter into our platform.

• Contacts and leads: Names, phone numbers, email addresses, and notes about your real estate contacts and leads.

• Communications: SMS messages, email content, and chat messages sent or received through our platform.

• Call recordings and transcripts: Audio recordings and AI-generated transcriptions of calls made through Doughy, subject to your recording settings.

• Form submissions: Property details, contact information, and offer requests submitted through our website.

Information Collected Automatically

• Device information: Device type, operating system, browser type, and unique device identifiers.

• Usage analytics: Pages visited, features used, time spent in the application, and interaction patterns.

• Cookies: Browsing behavior on our website (see Section 12).

Information from Third-Party Services

• Authentication data: Information from our authentication provider used to verify your identity.

• SMS metadata: Delivery status, timestamps, and carrier information for text messages sent through our platform.

3. How We Use Your Information

We use the information we collect to provide, maintain, and improve our services. Specific uses include:

• Managing deals, properties, contacts, and leads; providing AI-powered analysis and suggestions; tracking portfolio performance; and facilitating property management.

• Recording and transcribing calls (with consent), providing call coaching insights, sending and receiving SMS messages, managing CRM contacts, and generating call summaries.

• Classifying user intent from incoming messages, generating daily briefings from your data, drafting reply suggestions, creating approval workflows for AI-composed messages, and routing communications across channels.

• Processing property inquiries and offers, responding to contact form submissions, and sending service notifications via our website.

We do not sell or rent your personal information to third parties.

4. AI and Automated Processing

Our platform uses artificial intelligence to provide features including:

• Call transcription and summarization

• Intent classification for incoming messages

• Daily briefing generation from your deals, leads, and communications

• Draft reply suggestions for SMS and email

• Deal analysis and coaching recommendations

Important: We do not use your data to train AI models. Your data is processed by AI solely to provide our services to you. All AI-generated outbound messages (SMS, email) require your explicit approval before being sent — the AI drafts content, but a human always approves the final message.

AI-generated content is clearly identified within our applications, and you retain full control over whether to act on AI suggestions.

5. SMS/Text Messaging

When you provide your phone number through our application or website and consent to receive text messages, we may send you SMS messages related to our services.

How We Collect Consent

Consent to receive SMS messages is collected through multiple channels:

• In-app: When users create an account and add contacts with phone numbers in the Doughy application, a consent disclosure is displayed. Users acknowledge that SMS messages may be sent on their behalf.

• Existing business relationships: Tenants who provide their phone numbers as part of lease agreements or property management onboarding consent to receive service-related text messages.

• Website: Property owners who submit their phone number and inquiry through doughy.app or secondlyhomes.com consent to receive follow-up communications.

Types of Messages

• Service notifications and account alerts

• AI-generated daily briefings summarizing your deals and leads

• Draft reply suggestions for your review and approval

• Call summaries and follow-up reminders

• Property management updates and maintenance coordination

• Responses to your inquiries

Message Frequency

Message frequency varies based on your account activity and settings. You can control messaging preferences within the application settings.

Opting Out

Reply STOP to opt out of text messages at any time. Reply HELP for support.

Costs and Carrier Liability

Message and data rates may apply. Carriers are not liable for delayed or undelivered messages. Not all carriers are supported.

We will not sell, share, or transfer your mobile phone number or any mobile information to third parties or affiliates for marketing or promotional purposes.

SMS consent is not a condition of purchase or use of any of our services. You may use our application without opting into text messages.

6. Information Sharing

We do not sell or rent your personal information. We may share your data with the following categories of third parties solely to provide our services:

• Communication providers: SMS message delivery and phone services.

• Cloud infrastructure providers: Database hosting, authentication, and file storage.

• AI providers: AI processing for call transcription, briefings, and draft generation.

We may also disclose your information if required by law, court order, or government request; to protect the rights, property, or safety of Secondly Homes, our users, or others; or in connection with a merger, acquisition, or sale of assets.

7. Data Storage and Security

Your data is stored in secure cloud databases with workspace-level isolation, ensuring that users can only access their own data. All data is encrypted in transit via TLS. Server-side credentials are stored securely and never exposed to client applications.

Call recordings are stored securely and retention periods are configurable within your settings. We implement appropriate technical and organizational measures to protect your personal information, but no method of transmission over the Internet is 100% secure.

Breach Notification

In the event of a data breach that affects your personal information, we will notify affected users within 72 hours of becoming aware of the breach, in accordance with applicable law. Notifications will be sent via email to the address associated with your account, and we will provide details about the nature of the breach, the data involved, and the steps we are taking to address it.

8. Data Retention

• Account data: Retained while your account is active and for 30 days after account deletion.

• Call recordings: Retained according to your configurable retention settings.

• AI-generated content: Briefings, drafts, and suggestions are retained until you delete them.

• Communication logs: SMS and email records are retained for compliance and service continuity purposes.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal data we hold about you.

• Correction: Request correction of inaccurate or incomplete data.

• Deletion: Request deletion of your personal data, subject to legal retention requirements.

• Portability: Request your data in a portable format.

• Opt-out: Opt out of marketing communications at any time.

Virginia Consumer Data Protection Act (VCDPA): If you are a Virginia resident, you have additional rights under the VCDPA, including the right to opt out of targeted advertising and profiling.

California Consumer Privacy Act (CCPA): If you are a California resident, you have additional rights under the CCPA, including the right to know what personal information is collected, the right to request deletion, and the right to opt out of automated decision making technology. See Section 13 for our ADMT disclosure.

To exercise any of these rights, contact us at hello@doughy.app.

10. Children's Privacy

Our services are intended for users who are at least 18 years of age. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information promptly.

11. Third-Party Links

Our services may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those third parties. We encourage you to read the privacy policies of any third-party services you visit.

12. Cookies and Tracking

Our web application (doughy.app) uses cookies and similar tracking technologies to collect browsing behavior and improve your experience. Our mobile application does not use cookies. You can manage cookie preferences through your browser settings.

13. Automated Decision Making Technology

In accordance with the California Consumer Privacy Act (CCPA) and its regulations regarding Automated Decision Making Technology (ADMT), we provide the following disclosure about how our platform uses automated processing.

How We Use Automated Processing

Our platform uses AI-powered decision support tools to assist with operational tasks related to real estate investing and property management. These automated systems provide suggestions and draft content in the following areas:

• Leasing operations: Automated screening criteria evaluation, application status recommendations, and draft communications for prospective tenants.

• Maintenance coordination: Priority classification of maintenance requests, vendor matching suggestions, and cost estimates.

• Bookkeeping: Categorization of income and expenses, financial summary generation, and budget tracking alerts.

• Communications: Draft reply suggestions for SMS and email, intent classification of incoming messages, and daily operational briefings.

• Deal analysis: Property valuation estimates, comparable sale analysis, and investment return projections.

Human Oversight Requirement

All consequential decisions made through our platform require human approval before taking effect. Our approval system ensures that no automated action with material impact — such as sending communications to contacts, modifying financial records, or changing application statuses — is executed without explicit review and confirmation by an authorized user. The AI provides recommendations and drafts; humans make the final decisions.

Your Right to Opt Out

You have the right to opt out of automated processing of your personal information. If you choose to opt out:

• You may disable AI-powered features in your account settings at any time.

• You may request that your data not be subject to automated analysis by contacting us directly.

• Opting out of automated processing will not affect your ability to use the core features of our platform. Manual alternatives are available for all automated functions.

Requesting Access to ADMT Information

California residents may request additional information about our use of Automated Decision Making Technology, including the logic involved and the intended outcomes. To submit a request, contact us at:

• Email: hello@doughy.app

• Phone: (703) 679-8951

We will respond to verified requests within 45 days, as required by California law. You will not be discriminated against for exercising your rights under the CCPA.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email or through an in-app notification. The updated policy will be posted on this page with a revised effective date. Your continued use of our services after changes are posted constitutes your acceptance of the updated policy.

15. Contact Us

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

Secondly Homes LLC

Email: hello@doughy.app

Phone: (703) 679-8951