Privacy Policy

Effective Date: November 4, 2026

To download and/or print this Privacy Policy ("Privacy Policy"), click the Download PDF button above.

Welcome! Thank you for visiting our online services (e.g., website, software, other online services, our call centers and customer care services, and certain texts and email programs) including those that post a link to, or otherwise reference, this Privacy Policy, owned or operated by Hillpointe, LLC and Hillpointe Corporate Management, LLC ("Hillpointe", "Company", "we", or "us" or "our") (the "Service").

This Privacy Policy will provide you with information as to how Company collects, uses and discloses information about you, including the choices Company offers with respect to that information, and applies to your use of any Service, regardless of how you access or use it. It does not apply to Company's data collection activities offline or otherwise outside of the Service (unless otherwise stated below or at the time of collection). For certain Services, there may be additional notices about information practices and choices. Please read those additional privacy disclosures to understand how they apply to you.

By visiting or otherwise using the Service, you agree to the Service's Terms of Use and consent to Company's data collection, use and disclosure practices and other activities as described in this Privacy Policy, and any additional privacy statements that may be posted on an applicable part of the Service. If you do not agree and consent, please discontinue use of the Service.

1. Information We Collect.

A. Information About You that You Provide.

Company, and/or its Service Providers (defined below), may collect information you provide directly to Company and/or its Service Providers via the Service. For example, Company collects information when you use or register for the Service, create an account, subscribe to notifications, post on the Service, participate in promotional activities or communicate or transact through the Service. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties.

Information Company, its Service Providers and/or Third-Party Services may collect may include: (1) Personal Information, which is information that identifies you personally, such as your first and last name, email address, phone number and address ("Personal Information"); and (2) demographic information, such as your gender, age, zip code, interests and recent and upcoming transactions ("Demographic Information"). Except to the extent required by applicable law, Demographic Information is "non-Personal Information" (i.e., data that is not Personal Information under this Privacy Policy). In addition, Personal Information, including, without limitation, Company-Collected Personal Information (defined below), once "De-identified" (i.e., the removal or modification of the personally identifiable elements, or the extraction of non-personally identifiable elements) including through anonymization, pseudonymization and/or hashing is also non-Personal Information and may be used and shared without obligation to you, except as prohibited by applicable law. However, we do not make assurances that De-identified data is not capable of re-identification. To the extent any non-Personal Information, or Personal Information collected outside of the Service, is combined by or on behalf of Company with Personal Information Company itself collects directly from you on the Service ("Company-Collected Personal Information"), Company will treat the combined data as Company-Collected Personal Information under this Privacy Policy. The definition of "personal information" under certain state laws differs from the definition of Personal Information used in this Privacy Policy; provided, however, we currently do business only in Florida, Georgia and South Carolina and have determined that we are not subject to so-called consumer privacy laws of other states.

Our Service Providers and Third-Party Services on the Service may collect, monitor, record, and otherwise process your Personal Information, such as your voice, texts, emails, messages, and other information you submit to us.

B. Information Collected Automatically.

Company, its Service Providers and/or Third-Party Services may also automatically collect certain information about you when you access or use the Service ("Usage Information"). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the Service and data regarding network connected hardware (e.g., computer or mobile device). Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of Company with Company-Collected Personal Information, Company does not consider Usage Information (including, without limitation, unique device identifiers) to be Personal Information or Company-Collected Personal Information.

The methods that may be used on the Service to collect Usage Information may include:

• Log Information: Log information is data about your use of the Service, such as IP address, browser type, Internet service provider, referring/exit pages, operating system, date/time stamps and related data, and may be stored in log files.
• Information Collected by Cookies and Other Tracking Technologies: Cookies, web beacons (also known as "tracking pixels"), embedded scripts, location-identifying technologies, device recognition technologies, device and activity monitoring and other tracking technologies now and hereafter developed ("Tracking Technologies") may be used to collect information about interactions with the Service or emails, including information about your browsing and purchasing behavior.

Some information about your use of the Service and certain other online services may be collected using Tracking Technologies across time and services and used by Company and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the Service and certain other online services.

C. Information Company Collects from Other Sources.

Company may also obtain information about you from other sources, including Service Providers and Third-Party Services, and combine that with Company-Collected Personal Information. Notwithstanding anything to the contrary, except to the extent such data is combined by or on behalf of Company with Company-Collected Personal Information, this Privacy Policy is not intended to limit Company's activities regarding such third-party-sourced, or non-Service-sourced, information (including Personal Information), and such data will only be treated as Company-Collected Personal Information to the extent it is combined with Company-Collected Personal Information. Company is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices.

2. How We Use the Information We Obtain.

Company may use information about you, including Company-Collected Personal Information and other Personal Information, for any purposes not inconsistent with Company's statements under this Privacy Policy, or otherwise made by us in writing at the point of collection, and not prohibited by applicable law, including, without limitation, the following:

• Allow you to participate in the features we offer on the Service;
• Facilitate, manage, personalize and improve your experience;
• Process your registration, manage your account and/or upload your User Generated Content ("UGC");
• Transact with you, provide services or information you request, respond to your comments, questions and requests, serve you content and/or advertising and send you notices;
• Improve the Service and for any other business purposes;
• Tailor our content, advertisements and offers;
• To send you phone calls, texts, SMS, and email messages, including marketing and transactional messages.
• Fulfill other purposes disclosed at the time you provide Personal Information or otherwise where we are legally permitted or are required to do so;
• Determine your location and manage digital content rights (e.g., territory restrictions); and
• Prevent and address fraud, breach of policies or terms and threats or harm.

3. Information We Share With Third Parties.

Except as restricted by applicable law, this Privacy Policy or any other representation Company makes to you, Company may share non-Personal Information, and Personal Information that is not deemed Company-Collected Personal Information hereunder (provided that Company is aware of no restrictions of Company's use, if any), with third parties or Company affiliates ("Affiliates") for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your Personal Information, including Company-Collected Personal Information, to non-Personal Information, including without limitation through hashing it or substituting a unique identifier for the Personal Information, and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. Company's sharing of Company-Collected Personal Information (other than with our Affiliates) is, however, subject to the following:

• Marketing: Subject to your communications choices explained further below, we may use your Personal Information to send you marketing communications. Company may disclose your Company-Collected Personal Information with its Affiliates, and with third parties we think you might be interested in, for their own marketing purposes, only if we obtain your consent or give you the opportunity to opt-out.

  We do not share your text messaging originator opt-in data and consent with third-parties except to provide you with text messages or where we are required or permitted to disclose such information by law. We do not share your text messaging originator opt-in data and consent with third-parties for their own marketing purposes.

• Your Disclosure or Consent: Your activities on the Service may, by their nature, result in the sharing of your Company-Collected Personal Information (as well as your other Personal Information and your non-Personal Information) with third parties, and by engaging in these activities, you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not Company.

Company may also share any information about you (including, without limitation, Company-Collected Personal Information) for any purposes not inconsistent with this Privacy Policy, or our written statements at the point of collection, and otherwise not prohibited by applicable law, including, without limitation:

• Company's agents, vendors, consultants and other service providers (collectively "Service Providers") may receive, or be given access to, your information, including, without limitation, Personal Information, Demographic Information and Usage Information, in connection with their work on Company's behalf, provided however, Company does not authorize its Service Providers to use Company-Collected Personal Information provided by Company to the Service Providers to send you direct marketing messages other than related to Company and Affiliates absent your consent;
• To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
• If Company believes your actions are inconsistent with Company's Terms of Use, user agreements, applicable terms or policies or to protect the rights, property, life, health, security and safety of Company, the Service or its users, or any third party.

In addition, Company may share your Company-Collected Personal Information (as well as your other Personal Information and your non-Personal Information), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture or any other type of acquisition or business combination of all or any portion of Company assets, or transfer of all or a portion of Company's business to another company, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding ("Corporate Transactions").

4. Sweepstakes, Contests and Promotions.

Company may offer sweepstakes, contests and other promotions (each, a "Promotion"), including Promotions jointly sponsored or offered by third parties, which may require submitting Personal Information. If you voluntarily choose to enter a Promotion, your information, including Personal Information, may be disclosed to Company, co-sponsors, Service Providers and other third parties, including for administrative purposes and as required by law (e.g., on a winners list). By entering, you are agreeing to the official rules that govern that Promotion, which may include consent to additional or differing data practices from those contained in this Privacy Policy. Please review those rules carefully.

5. Information You Disclose Publicly or to Others.

The Service may permit you to post or submit UGC including, without limitation, written content, user profiles, audio or visual recordings, computer graphics, pictures, data or other content, including Personal Information. We, and our vendors, may monitor, record, and process your UGC. If you choose to submit UGC to any public area of the Service, including your UGC will be considered "public" and will be accessible by anyone, including Company. Notwithstanding anything to the contrary, unless otherwise explicitly agreed by us, Personal Information included in UGC is not subject to Company's usage or sharing limitations, or other obligations, regarding Company-Collected Personal Information or other Personal Information under this Privacy Policy or otherwise, and may be used and shared by Company and third parties to the fullest extent not prohibited by applicable law. Company encourages you to exercise caution when making decisions about what you disclose in such public areas. For more information on how UGC is treated under the Service's Terms of Use.

6. Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics.

The Service may include or link to third-party websites, apps, locations, platforms, code (e.g., plug-ins, application programming interfaces ("API") and software development kits ("SDKs")) or other services ("Third-Party Service(s)"). These Third-Party Services may use their own cookies, web beacons and other Tracking Technology to independently collect information about you and may solicit Personal Information from you.

Certain functionalities on the Service permit interactions that you initiate between the Service and certain Third-Party Services, such as third-party social networks ("Social Features"). Examples of Social Features include: enabling you to send content such as contacts and photos between the Service and a Third-Party Service; "liking" or "sharing" Company's content; logging in to the Service using your Third-Party Service account (e.g., using Facebook Connect to sign-in to the Service); and to otherwise connect the Service to a Third-Party Service (e.g., to pull or push information to or from the Service). If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Service or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Service (e.g., by using a hashtag associated with Company or Affiliates in a tweet or status update), your post may be used on or in connection with the Service or otherwise by Company and Affiliates. Also, both Company and the third party may have access to certain information about you and your use of the Service and any Third-Party Service.

Company may engage and work with Service Providers and other third parties to serve advertisements on the Service and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Service and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as "interest-based advertising" and "online behavioral advertising" ("Interest-based Advertising"), which may include sending you an ad on another online service after you have left the Service (i.e., "retargeting"). We may use Microsoft and Google for advertising services.

Company may use Google Analytics and/or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help Company analyze Service users and how they use the Service. Information generated by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use this information for purposes such as evaluating your use of the Service, compiling statistic reports on the Service's activity and providing other services relating to Service activity and other Internet usage.

Company uses Cloudflare Turnstile to protect the Service's contact form from spam and automated abuse. Turnstile may collect Usage Information, such as your IP address and information about your browser and device, to distinguish people from automated programs. Its processing is described in the Cloudflare Turnstile Privacy Addendum at https://www.cloudflare.com/turnstile-privacy-policy/.

Company is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Service, and encourages you to familiarize yourself with and consult their privacy policies and terms of use.

7. Data Security and Monitoring.

Company takes reasonable measures to protect Company-Collected Personal Information (excluding public UGC) from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and Company does not guarantee the security of your information collected through the Service.

To help protect you and others, Company and its Service Providers may (but make no commitment to) monitor use of the Service, and may collect and use related information including Company-Collected Personal Information and other Personal Information, for all purposes not prohibited by applicable law or inconsistent with this Privacy Policy, including, without limitation, to identify fraudulent activities and transactions; prevent abuse of, and investigate and/or seek prosecution for, any potential threats to or misuse of the Service; ensure compliance with the Terms of Use and this Privacy Policy; investigate violations of or enforce these documents; improve the Services and your Services experiences and; to protect the rights and property of Company, Affiliates, third parties and other users. Monitoring may result in the collection, recording and analysis of online activity or communications through our Service. If you do not consent to these conditions, you must discontinue your use of the Service.

8. International Transfer.

Company is based in the U.S. and the information Company and its Service Providers collect is governed by U.S. law. If you are located in the European Union (EU), European Economic Area (EEA), United Kingdom and/or Switzerland, please note that Company does not intend to offer goods and services (including the Services) to you. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy.

9. Children's Privacy.

The Service is intended for a general audience and not directed to children less than 13 years of age. You must be the age of majority in the jurisdiction in which you reside to access or otherwise use our Service.

Company does not intend to collect personal information as defined by the U.S. Children's Online Privacy Protection Act ("COPPA") ("Children's Personal Information") in a manner that is not permitted by COPPA. If we obtain knowledge that we have collected Children's Personal Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA.

10. Accessing and Changing Information.

Company may provide web pages or other mechanisms allowing you to delete, correct or update some of the Company-Collected Personal Information, and potentially certain other information about you (e.g., profile and account information). Company will make good faith efforts to make requested changes in Company's then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from Company's databases and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.

11. Your Choices: Tracking and Communications Options.

A. Tracking Technologies Generally.

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Please be aware that if you disable or remove these technologies, some parts of the Services may not work and that when you revisit the Services. Your ability to limit browser-based tracking technologies is subject to your browser settings and limitations. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.

Your browser settings may allow you to automatically transmit a "Do Not Track" signal to online services you visit. Note, however, there is no consensus among industry participants as to what "Do Not Track" means in this context. Some state consumer privacy laws, that we have determined do not apply to us, require site operators to look for and honor so-called "global privacy control" ("GPC") signals. Company currently does not alter Company's practices when Company receives a "Do Not Track" or GPC signal from a visitor's browser.

Some third parties, however, may offer you choices regarding their tracking technologies. For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section. We do not represent that these third-party tools, programs or statements are complete or accurate.

You will need to set preferences on each device that you use to access our Services and clearing cookies on your browser(s) may disable some preference settings.

B. Analytics and Advertising Tracking Technologies.

Company may engage and work with Service Providers and other third parties to serve advertisements on the Services and/or on other online services, including Interest-based Advertising. This may include sending you an ad on another online service after you have left our Online Services (i.e., "retargeting").

You may choose whether to receive some Interest-based Advertising by submitting opt-outs through the Digital Advertising Alliance's ("DAA") Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/. Please be aware that, even if you opt-out of certain kinds of Interest-based Advertising, you may continue to receive other types of ads, including Targeted Advertising. Opting out only means that those selected DAA members should no longer deliver certain Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your DAA browser-based opt-out may not, or may no longer, be effective. Company supports the DAA's Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks Company directly engages to serve you Interest-based Advertising will do so as well, though Company cannot guaranty their compliance.

We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to opt-out of certain Google browser Interest-Based Advertising, please visit: http://www.google.com/settings/ads.

We may also use Microsoft Advertising Services. To learn about the data Microsoft collects and how your data is used by it and to opt-out of certain Microsoft browser Interest-Based Advertising, please visit: https://privacy.microsoft.com/en-us/privacystatement.

In addition, we may serve ads on other online services that are targeted to reach people on those services that are also identified on one or more of our data bases ("Matched List Ads"). This is done by using tracking technologies or by matching common factors between our databases and the databases of the other online services. For instance, we may use such ad services offered by Meta (Facebook and Instagram), TikTok, X and other Third-Party Services, which may offer user controls that you can use to limit Matched List Ads. We are not responsible for these Third-Party Services, including without limitation, their security of the data or their failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.

Company may use Google Analytics or other Service Providers for analytics services. These analytics services may use cookies and other tracking technologies to help Company analyze users and how they use the Online Services. Data generated by these analytics services (e.g., your IP address and usage data) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Service Providers may use the data for purposes such as evaluating your use of the Services, compiling statistic reports on the Services' activity and providing other services relating to Services activity and other Internet usage. Company is not responsible for, and makes no representations regarding, the policies or business practices of any third parties, including, without limitation, analytics Service Providers and Third-Party Services associated with the Services, and encourages you to familiarize yourself with and consult their privacy policies and terms of use.

Company is not responsible for effectiveness of, or compliance with, any third parties' opt-out options or programs or the accuracy of their statements regarding their programs.

C. Communications.

You can opt-out of receiving certain promotional communications (emails or text messaging) from us at any time, as applicable.

• Promotional Emails. To opt-out of promotional emails, follow the instructions provided in emails or by clicking on the "Unsubscribe" link, or if available by changing your communication preferences by logging into your account.
• Text Messages. To opt-out of receiving our text messages, text the word "STOP" in response to a text we send you, and follow any other opt-out instructions provided in the text messages we send you.

Please note that your opt-out is limited to the email address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. Even if you opt-out of receiving promotional communications, we may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing or our ongoing business relations.

12. State Notices.

We are not currently subject to state comprehensive consumer privacy laws because we do not meet their applicability thresholds and/or do not currently offer goods or services to residents of applicable states. Our business is currently limited to Florida, Georgia, North Carolina, and South Carolina. If and when privacy laws of any other state(s) become applicable to us, we will update this section as may be required. We believe that we do not conduct business in or direct activities to residents of Nevada or California, however, we are voluntarily providing the following notices for residents of Nevada and California.

A. Nevada Residents.

We believe that we do not conduct business in Nevada. Nevada "consumers" have the right to instruct us not to "sell" "covered information" as those terms are defined by Chapter 603A of the Nevada Revised Statutes. You may contact us as set forth in Section 14 to be verified and learn more about your opt-out rights under that law.

B. Your California Privacy Rights.

We believe that we do not conduct business in California.

We do not share personal information as defined by California Civil Code Section 1798.83 ("Shine The Light law") with third parties for their direct marketing purposes without either obtaining your consent or giving you the ability to opt-out. To opt-out of future sharing with third parties for their direct marking purposes, please contact us via the information in the next two sentences. If you are a California resident, you may request information about our compliance with the Shine the Light law by contacting us by email info@hillpointe.com or by sending a letter to 631 W Morse Blvd., Suite 200 Winter Park, FL 32789 (Attention: General Counsel). Any such request must include "California Privacy Rights Request" in the first line of the description and include your name, street address, city, state and ZIP code. Please note that we are only required to respond to one request per customer each year.

Any California residents under the age of eighteen (18) who have registered to use the Service, and who posted content or information on the Service, can request removal by contacting Company, as set forth in Section 14, detailing where the content or information is posted and attesting that you posted it. Company will then make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished or archived content by search engines and others that Company does not control.

13. Changes to this Privacy Policy.

We reserve the right to change this Privacy Policy prospectively effective upon the posting of the revised Privacy Policy and your use of our Service indicates your consent to the privacy policy posted at the time of use. However, we will not treat your previously collected Company-Collected Personal Information, to the extent it is not collected under the new privacy policy, in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

14. Contact Company.

If you have any questions about this Privacy Policy, please contact Company via email at info@hillpointe.com or at 631 W Morse Blvd, Suite 200, Winter Park, FL 32789 (Attention: General Counsel).