Hilltop—Privacy Policy

Effective as of March 11, 2025

This Privacy Policy explains how Hilltop Application Inc. (“Hilltop,” “we,” “us,” or “our”) collects, uses, and shares information about you through the Hilltop Connect mobile app (“Hilltop Connect” or the “App”) and our services.

By using the App, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service. We encourage you to read this Privacy Policy, and to use the information it contains to help you make informed decisions.

1. Information We Collect or Receive. The App facilitates communications between constituents like you and their Elected Representatives. An “Elected Representative” is an elected official who represents you in the geographical area where you reside, the official’s staff, and any other authorized users of the official’s Hilltop subscription. In the course of operating the App, we will collect and/or receive the following types of information. You authorize us to collect and/or receive such information.

(a) Personal Information We Collect About You. “Personal Information” is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer or household.

In the preceding 12 months, we have collected the following categories of Personal Information:

(i) identifiers such as first and last name, email address, physical address, telephone number, age, and gender; and

(ii) potentially sensitive personal information that constituents have provided in communications sent to their Elected Representatives through the App.

(b) How We Collect Personal Information. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us when creating an account with us, through using the App, via email, or by other means. When you sign up to become a user or contact us, you will be required to provide us with information about yourself. This Personal Information may include your name, email address, physical address, telephone number, age, and gender. We do not collect any Personal Information from you when you use the App unless you provide us with the Personal Information voluntarily.

(c) Log In. If you sign in through Hilltop Connect, you are authorizing us to collect, store, and use, in accordance with this Privacy Policy, any and all information that you agreed that the App would provide to us. Such information may include, without limitation, your first and last name, Hilltop Connect username, unique identifier and access token, physical address, email address, and telephone number.

(d) Other Information. In addition to the Personal Information, we may automatically collect or receive additional information regarding you and your use of Hilltop Connect; your interactions with us; and information regarding your computer and mobile devices used to access the App (collectively, the “Other Information”). Such Other Information may include:

(i) From You. Additional information about yourself that you voluntarily provide to us, such as information that you would like us to communicate to your Elected Representative.

(ii) From Your Activity. We may collect or receive information regarding:

(A) IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific mobile device;

(B) Browser type and language;

(D) Details regarding your activity on the App, such as search queries and other performance and usage data.

(iii) About Your Mobile Device. We may collect or receive information regarding:

(A) Type of mobile device;

(B) Operating system and version (e.g., iOS, Android, or Windows);

(D) Network type (Wi-Fi, 3G, 4G, LTE).

2. How Information Is Used and Shared.

(a) You authorize us to use the Personal Information and the Other Information (collectively, the “Information”) to:

(i) Provide and improve our App;

(ii) Provide our services, including but not limited to:

(A) providing you with information about your Elected Representatives;

(B) delivering messages between you and your Elected Representatives;

(iii) Administer our promotional programs;

(iv) Solicit your feedback;

(v) Helping to ensure the security and integrity of our services; and

(vi) Inform you about our services.

(b) We may share your Personal Information with your Elected Representatives when you use Hilltop Connect to communicate with them. We also may maintain that information in a subscription database which may be accessed by the Elected Representative to whom your communication is directed.

(c) We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, customer service, marketing assistance, and administration of promotional programs. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

(d) In an ongoing effort to better understand our users, Hilltop Connect, and our services, we may analyze certain Information in de-identified, anonymized, and aggregate form to operate, maintain, manage, and improve the App and our services. This aggregate information does not identify you personally. We may share and/or license this aggregate data and our analysis of that data to affiliates, agents, business, and promotional partners, and other third parties. We may also disclose aggregated user statistics to describe the App and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

(e) We may share some or all of your Information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us.

(f) As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.

(g) To the extent permitted by law, we may also disclose the Information:

(i) When required by law, court order, or other government or law enforcement authority or regulatory agency; or

(ii) Whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you and your Elected Representatives.

3. Third Party Privacy Practices. This Privacy Policy does not address the privacy practices your Elected Representatives or of any other third parties that we do not own, control, or that we are not affiliated with.

4. Accessing and Modifying Information and Communication Preferences. If you have provided us any Personal Information, you may access, remove, review, and/or make changes through the App settings. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify anonymized information from our subscription databases. You cannot opt out of receiving transactional e-mails related to Hilltop Connect (e.g., requests for support). We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

5. Opt Out and Deletion of Personal Information. If you would like Hilltop to stop sharing your Personal Information with your Elected Representatives, you may delete your account through the App settings. Upon receiving your request to delete your account, we will use commercially reasonable efforts to process your request and remove your Personal Information from the subscription databases available to your Elected Representatives. Personal Information will be deleted from our internal records after 30 days following your deletion of your account unless an exemption to the right to delete would apply under the California Consumer Privacy Act of 2018, as amended, to some or all of your Personal Information.

6. How We Protect Your Information. We protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of the databases of the third parties , including your Elected Representatives, with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the internet. In particular, email sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via email.

7. Important Notices to Non-U.S. Residents. Hilltop Connect and its servers are operated in the United States and are intended for use by United States residents. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the App, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

8. App Stores; External Websites. Your app store (e.g., the App Store or Google Play) may collect certain information in connection with your use of Hilltop Connect, such as Personal Information, Payment Information, Geolocational Information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

Hilltop Connect may contain links to third-party websites, including but not limited to the websites of your elected representatives. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party Privacy Policy and Terms of Use when visiting any other websites.

9. Children. The App is not directed to children under the age of 18. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 18) not use the App. If a child under the age of 18 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

10. How to Contact Us. If you have questions about this Privacy Policy, please contact us through our website at https://www.hilltop-app.com/contact or mail us at the following address: 2827 Arizona Ave NW, Washington, District of Columbia 20016.