Online Privacy Notice

Effective Date: May 27, 2020

Overview

This Online Privacy Notice (“Notice”) describes how Hilltop Securities Inc. and its subsidiaries and affiliates (“HTS”, “we”, “our”, and “us”) collect, use and otherwise process personal information in connection with our website found at https://www.hilltopsecurities.com/ (together with all sub-domains, and any successor website(s) thereto (the “Site”), our mobile application (“App”), and/or other online services that post or link to this Notice (collectively, the Site, the App and our other online services are called the “Online Services.”)

In this Notice, we’ll use the terms “you” and “your” to refer to you the person whose personal information we collect, use and process in connection with our Online Services. We’ll also use the term “personal information” to mean any information that (i) directly and clearly identifies you, or (ii) can reasonably be used in combination with other information to identify you.

As you review this Notice, here are a few important things to keep in mind:

• Other privacy notices or policies may apply to you depending on how you interact with us. You can access many of these policies using the links at the bottom of this page.
• Our Online Services are not intended for children under 13 years of age. We do not knowingly solicit information online from, or market online to, children under 13 years of age.
• Wireless service providers, Internet service providers, device manufacturers and/or social media platforms may have their own privacy notices that are different from this Notice for the information they may access through your use of the Online Services. We encourage you to read their privacy notices, as their collection, uses and sharing of information may be different than ours.

Contents

Please read this Notice carefully.

1. Personal Information We Collect

When you browse through the Site, submit information through forms on the Site, login to the Site or App, or otherwise interact with our Online Services, we collect various types of personal information. The types of personal information we collect about you depends on how you interact with our Online Services. For example, we may collect personal information, including:

1. 1. Information you voluntarily provide, including, but not limited to, personal information you submit to us via email, forms, applications or other online fields associated with our Online Services, including name, postal or email addresses, telephone, fax or mobile numbers, account numbers, login information (username/password); and other information provided by you during the course of your use of the Online Services;
   2. Information automatically collected when you use our Online Services, including, but not limited to, the Internet protocol (IP) address used to connect your computer or device to the Internet, your device ID, browser type and version, time zone setting, browser plug-in types and versions, device operating system platform, mobile carrier, location or GPS/geo-location;
   3. Information collected by cookies and similar technologies when you use our Online Services; and
   4. Information collected from third parties, including, but not limited to, social media sites, or information provided by fraud monitoring providers, commercial databases, or know your customer providers. In some instances, we create personal information about you, such as records of your interactions with us, and details of your accounts.

2. Use of Personal Information

We will only use your personal information when and as the law allows us to do so. Most commonly, we will use your personal information for the following purposes:

1. 1. To fulfill the specific purpose(s) for which the personal information was collected/provided, including but not limited to the following examples:
      Ex: To provide you with information on our Site;
      Ex. To provide you with the Online Services that you have requested;
      Ex: To respond to your requests for customer or technical support; and
      Ex. To respond to your job application;
   2. To administer and improve our internal business operations, including but not limited to the following examples:
      Ex. To administer and improve our Online Services, and monitor and analyze usage, trends, and activities related to the Online Services;
      Ex. To process your account;
      Ex. To improve and develop HTS’s business;
      Ex. To communicate with you about our Online Services and our other services; and
      Ex. To send you relevant marketing communications;
   3. To perform our contractual obligations;
   4. Legitimate purposes including, without limitation, improving and securing our Online Services and information technology systems, and protecting against malicious, deceptive, fraudulent or illegal activity;
   5. To address our legal and regulatory compliance obligations; and
   6. For any other purpose with your consent.

3. Sharing of Personal Information

HTS may share personal information with the following categories of recipients:

1. 1. Members of our corporate family, which means our affiliates and our ultimate holding company, Hilltop Holdings, Inc., and its subsidiaries;
   2. Contractors, vendors, consultants, professional advisors, and other service providers (including, but not limited to, fraud investigations, site analytics and operations) (collectively, “Service Providers”) who assist us in operating our business, providing the Online Services to you, or providing you with a financial product or service;
   3. Social media sites integrated into Online Services that we offer;
   4. Potential buyers (and their agents and advisors) in connection with any proposed merger, acquisition, or any form of sale or transfer of some or all of our assets (including in the event of a reorganization, dissolution or liquidation), in which case personal information held by us about you will be among the assets transferred to the buyer or acquirer; and
   5. Competent law enforcement bodies, regulatory, government agencies, credit reporting agencies, court or other third parties when we believe that such disclosure is necessary or appropriate to: (i) comply with any court order, a request from any regulatory or law enforcement agency, or any other legal obligation; (ii) enforce or apply the terms of a contract; (iii) protect the rights, property, or safety of you or others. We may only disclose personal information to these recipients for any of the purposes described in section 2, Use of Personal Information. Before we disclose personal information, we ensure there are adequate safeguards in place to protect the processing of that data.

4. We may only disclose personal information to these recipients for any of the purposes described in section 2, Use of Personal Information. Before we disclose personal information, we ensure there are adequate safeguards in place to protect the processing of that data.

5. Cookies and Interest-Based Advertising

1. 1. Cookies. We use and allow our Service Providers to use cookies and similar technologies, such as pixel tags, web beacons, clear GIFs, and JavaScript, to enable us to recognize your web browser and tell us how and when you visit and use our Online Services, to analyze trends, and to operate and improve our Online Services.
   2. Interest-Based Advertising. Both the Network Advertising Initiative and the Digital Advertising Alliance (DAA) provide information about and technologies to opt-out of receiving some or all interest-based advertising. You can also opt-out of interest-based advertising by clicking on the appropriate icon within an interest-based ad which will take you to tools to help you manage these choices. These technologies are browser and device specific, so they must be adopted on each device you use. If you block or clear cookies, these technologies may not work. You will continue to see ads on the Site which reflect how you use the Site and our Services.
      If you would prefer not to receive interest-based advertising, you can opt-out of this activity at the DAA website by visiting http://www.aboutads.info/choices/ (for U.S. residents).
   3. Do Not Track Signals. Some web browsers may transmit “do not track” signals to websites. The Site and App do not currently recognize or respond to do not track signals.

6. Data Security, Transfers and Retention

1. 1. Data Security.We endeavor to use appropriate technical and organizational measures designed to assist in maintaining the security of the personal information we collect from you; safeguarding against anticipated threats to the confidentiality, integrity, and availability of personal information; and protecting your personal information against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. These measures include storing personal information in a private database which is accessed by authorized users, and carefully selecting Service Providers who commit to use appropriate protective measures.
      However, whenever personal information is processed, there is a risk that such information could be lost, misused, modified, hacked, breached and/or otherwise accessed by an unauthorized third party. No data transmission over the Internet is completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us over the Internet, so you do so at your own risk. 
   2. Data Transfers: We provide appropriate protections for international data transfers where specified by law. However, our Online Services are controlled and operated by use from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than those of the United States. Information about you may be stored and processed in any country where we have facilities or where Service Providers may store and process data, and, by using the Online Services, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.
   3. Data Retention: The criteria for determining the duration for which we will keep your personal information are as follows:
      • we will retain your personal information no longer than is necessary for the purpose for which it was collected; or
      • where applicable law or regulation requires a longer retention period, we will retain your personal information for the time specified under these requirement unless we must retain such information for a longer time in order to establish, exercise or defend any legal rights.

7. Safeguarding and Updating Your Personal Information.

In addition to the technical and organizational measures that we have in place to protect your personal information, you should use appropriate security measures to protect your personal information, including protecting the security of your login information (username/password). If you use our Online Services to access your account(s) with us, then you should keep your account information accurate and up to date. If your account information is incomplete, inaccurate or not current, and you are not able to update it, please promptly contact us.

8. Your Rights and Choices Regarding Your Personal Information.

Depending on where you reside, you may have certain rights and choices regarding your personal information.

1. 1. Your California Privacy Rights
      If you are a California resident, you have the right to request and receive certain information about disclosure of your personal information to third parties for their direct marketing purposes. Because it is our policy not to disclose your personal information to third parties for their direct marketing purposes without your consent, we are exempt from the requirement to respond to such requests. If you have any questions related to our policy, please contact us using the information provided in the Contact Us section below.
      For information regarding how to exercise your rights as a consumer under the California Consumer Privacy Act, please review our CCPA disclosure. 
   2. Automated decision-making: We do not use automated decision-making without human intervention, including profiling.

9. Other Important Information

1. 1. Terms and Conditions. All use of our Online Services is subject to our Terms and Conditions.
   2. Changes to Notice. This Notice is subject to change.The date at the top of this Notice shows when this Notice was last revised. When we make changes, we will post the revised Notice on this page with a new effective or “last updated” date. In some cases, we may provide you with additional notice (such as by adding a statement to our website homepage or by sending an email notification). We encourage you to review this Notice to stay informed about our information practices and the choices available to you.
   3. Third-party Websites, Applications, and Services. Our Online Services may contain links to third party websites, applications or services. If we provide such links, it does not imply that we endorse the linked websites, applications, or services. Further, this Notice does not address, and we are not responsible for, the privacy, security, or other practices of any third party operating any linked website, application or service to which our Online Services may link.
      Additionally, we are not responsible or liable for the privacy practices of third parties, like Microsoft, Apple, Google, Facebook, LinkedIn, or any other wireless service provider, Internet service providers, device manufacturers and/or social media platform, including with respect to any personal information you disclose to other organizations through or in connection with the Online Services.

10. Contact Us

If you have any questions or comments about this notice, the ways in which we collect and use your information described here, your choices and rights regarding such use, or wish to exercise your rights under applicable law, please do not hesitate to contact us at:

Phone: 1-844-387-6237
Email: info@hilltopsecurities.com
Postal Address:
Hilltop Securities Inc.
C/O Compliance Department
717 N. Harwood Street, Suite 3400
Dallas, TX 75201