Twellie — Professional User Addendum

Last Updated: April 19, 2026

This Professional User Addendum (the "Addendum") supplements the Terms of Service for users who access the Service as licensed real-estate professionals, including but not limited to:

Real-estate brokers, agents, or salespersons licensed under state real-estate law;
Licensed appraisers (residential, certified, or commercial);
Mortgage loan originators, processors, or underwriters;
Real-estate attorneys;
Licensed home inspectors and general contractors;
Licensed insurance agents, brokers, or claims adjusters;
Institutional investors, iBuyers, or their representatives;
Any other person using Twellie in the ordinary course of a regulated trade or profession.

Collectively, "Professional Users."

Using Twellie in a professional capacity expands your responsibilities and narrows Twellie's scope of liability. Read this Addendum carefully. Continued use of the Service as a Professional User constitutes acceptance.

1. Representations by Professional Users

You represent and warrant to Twellie that:

You hold all licenses, certifications, and registrations required by applicable federal, state, and local law for the services you provide to your clients.
You are in good standing with all governing authorities (state real-estate commission, NMLS, state bar, appraisal board, insurance commissioner, etc.).
You have read and understood the AI Output Disclaimer (https://twellie.com/disclaimer), including the list of prohibited regulated uses.
Your use of Twellie is in addition to, not a replacement for, your own professional judgment and licensed services.
You will comply with the advertising, disclosure, and agency-duty rules of your licensing authority in any use of Twellie outputs.

2. Prohibited Professional Uses

In addition to the prohibited uses in Section 5.9 of the Terms and Section 2.5 of the Acceptable Use Policy, Professional Users shall NOT:

2.1 AVM / Appraisal-Substitute Use

Submit Twellie Reports as, or in lieu of, an Automated Valuation Model ("AVM") to any mortgage lender, bank, GSE (Fannie Mae, Freddie Mac, Ginnie Mae), insurer, or other regulated entity for any purpose that requires AVM-quality standards under OCC, Federal Reserve, FDIC, NCUA, FHFA, or CFPB rules (including the Interagency Appraisal and Evaluation Guidelines and AVM-quality regulations).
Use Twellie Reports as a Uniform Standards of Professional Appraisal Practice ("USPAP") work product.
Use Twellie Reports as a Broker Price Opinion ("BPO") submitted to a lender, insurer, or court (many states have specific BPO licensing rules).
Use Twellie Reports in tax-assessment appeals, eminent-domain proceedings, divorce/probate valuations, litigation, or any proceeding where a licensed appraisal is required.

2.2 Appraiser Independence (Dodd-Frank)

Use Twellie in any way that violates the Truth in Lending Act, the Dodd-Frank Wall Street Reform and Consumer Protection Act appraiser-independence requirements, or the related Regulation Z appraiser-independence rules (12 C.F.R. § 226.42).
Attempt to influence an appraiser's valuation using Twellie outputs.
Provide Twellie Reports to an appraiser with the intent to bias their opinion.

2.3 Anti-Steering

Use Twellie to steer clients toward or away from properties, neighbourhoods, or listings in a way that violates the Fair Housing Act (42 U.S.C. § 3601 et seq.), Equal Credit Opportunity Act (15 U.S.C. § 1691 et seq.), or state anti-discrimination laws.
Use Twellie neighbourhood data to redline or make decisions based on protected characteristics (race, colour, national origin, religion, sex, familial status, disability, or state-law-protected classes).

2.4 Misrepresentation to Clients

Represent to a client that a Twellie Report is an appraisal, CMA, BPO, inspection, title search, or legal advice.
Represent that Twellie has endorsed a specific recommendation, valuation, or offer strategy.
Represent that you or your firm is a Twellie partner, agent, affiliate, or representative without a separate written agreement.
Strip or alter Twellie disclaimers, watermarks, or attribution when sharing Reports with clients.

2.5 Unlicensed Activity

Use Twellie to perform work that requires a license you do not hold. Example: if you are a real-estate salesperson, do not use Twellie outputs to perform an appraisal you are not licensed to perform.

3. Heightened Liability Cap for Professional Users

The aggregate-liability cap in Section 14.2 of the Terms (greater of fees paid in the last 12 months or US$100) applies in full to Professional Users.

By using the Service in a professional capacity, you further agree to the following:

You bear full responsibility for the advice and services you provide to your clients, regardless of any Twellie output that informs them.
You will not assert that Twellie owes a duty to your clients; no such duty is created by your use.
If a client asserts a claim against you that arises from or relates to a Twellie Report, you agree to indemnify and defend Twellie from any third-party claim brought by that client against Twellie, on the same terms as Section 15 of the Terms.

4. Professional Use of AI Output — Required Practices

When you use Twellie in a regulated-professional workflow, you must:

Disclose to your client, before they rely on any Twellie output, that the Report is AI-generated, informational, and not a licensed valuation/inspection/legal opinion.
Independently verify every material figure or conclusion you rely on in your advice — even if the Report appears internally consistent.
Apply your own professional judgment to the conclusion. Twellie outputs are one input, not the answer.
Document your own CMA/BPO/appraisal/inspection workflow separately; do not let a Twellie Report stand in place of your own deliverable.
Preserve the disclaimers in any shared Report — do not crop, white out, or otherwise obscure them.

5. API and Bulk Use

Bulk use of the Service (more than 100 Reports per calendar month, API access, or programmatic scraping) by a Professional User is subject to a separately negotiated commercial agreement. Contact sales@twellie.com to discuss. Unauthorised bulk use violates the Acceptable Use Policy.

6. No MLS / IDX Compliance by Implication

Twellie aggregates listing data from a variety of public and licensed sources. We do not represent or warrant that our data is sourced under any particular MLS's or IDX's rules. If your licensing board or MLS prohibits the use of third-party listing data for any purpose, it is your responsibility to comply; Twellie is not an IDX participant on your behalf.

7. Advertising and Marketing

If you use Twellie outputs in your own marketing (listing brochures, email newsletters, social posts):

Include a disclaimer substantially similar to: "Property analysis provided by Twellie. Informational only — not an appraisal, CMA, or professional opinion. Independent verification required."
Do not represent that the analysis was performed by you personally.
Comply with your licensing authority's advertising rules (state real-estate commission, RESPA 12 U.S.C. § 2607, TCPA, CAN-SPAM, state-specific advertising-substantiation rules).

8. Confidentiality and Client Data

If you submit a client's information (name, contact details, motivations) through Twellie in the course of representing them:

You represent that you have obtained the client's consent to do so and have complied with your own duties under your licensing authority and applicable data-privacy laws.
You are responsible for your client's data as the Controller under GDPR / CCPA — Twellie is your Processor for that data.
Our DPA governs our Processing.

9. No Licensure Transfer

Nothing in this Addendum, the Terms, or the Service transfers any license, certification, or registration from Twellie to you, or from you to any client. You remain the sole licensed party to your client.

10. Termination

Twellie may terminate a Professional User's access — in addition to the termination rights in Section 16 of the Terms — if:

Twellie becomes aware that the Professional User's license is suspended, revoked, or subject to public discipline;
Twellie receives credible information that the Professional User has used Twellie in violation of this Addendum (including regulated uses or discrimination);
A government authority requires termination as part of an enforcement action.

11. Governing Law and Venue

This Addendum is subject to the same governing law, arbitration, and class-action waiver provisions as the Terms of Service. Your professional licensing authority's rules apply to the practice of your profession; this Addendum is not a waiver of any statutory right.

12. Contact

Compliance questions: compliance@twellie.com
Sales / enterprise commercial agreements: sales@twellie.com
General support: help@twellie.com