Privacy Policy

This privacy notice describes how Hill Technologies Inc. and its affiliates — including Hill Securities LLC, our SEC-registered broker-dealer and member FINRA/SIPC (CRD #338653), together with our investment adviser and fund management and general partner entities (collectively, "Hill," "we," "us," or "our") — collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you (a) visit our website at https://hill.com, or any website of ours that links to this privacy notice; (b) open an account and use the Hill platform and brokerage services; or (c) engage with us in other related ways, including any sales, marketing, or events.

Hill Securities is a financial institution. Our handling of the nonpublic personal financial information of individuals who use the Services for personal, family, or household purposes is also described in the U.S. Consumer Privacy Notice (Gramm-Leach-Bliley Act) in Section 11 below.

Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at legal@hill.com.

1. What information do we collect?

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

Information you provide to us

When you register, open an account, verify your eligibility, or invest, we collect personal information you provide, which may include:

• Identifiers and contact details — name, email address, phone number, and mailing address;
• Identity-verification information — date of birth, Social Security number or other taxpayer identification number, government-issued identification (such as a passport, driver's license, or national ID), a photograph or selfie, and citizenship or residency information, which we collect to verify your identity and to meet our customer-identification, know-your-customer, and anti-money-laundering obligations. Where you complete our identity-verification flow, our identity-verification service provider — currently Persona Identities, Inc. ("Persona") — processes biometric information derived from your selfie and identification document (such as facial geometry used to match your selfie to your ID and to confirm liveness) on our behalf;
• Financial and investor-qualification information — bank account and payment information, income, net worth, assets, and other information used to confirm your status as an accredited investor, qualified client, and/or qualified purchaser, and to assess suitability;
• Transaction information — orders, subscriptions, holdings, and related transaction and settlement records;
• Tax information — IRS Form W-9 or W-8 and related tax certifications;
• Account credentials — username and password; and
• Communications — information you provide when you contact us, respond to surveys, or otherwise communicate with us.

Information collected automatically

As you use the Services, we automatically collect certain information, such as your IP address, device and browser information, and usage and log data, including through cookies and similar technologies. See Section 9.

Information we collect from third parties

To operate the Services and meet our legal and regulatory obligations, we may receive information about you from third parties, including identity-verification and sanctions and politically-exposed-person screening providers; bank, payment, and financial-data providers; consumer-reporting, fraud-prevention, and anti-money-laundering data sources; and public and company data sources.

Identity verification. Our identity-verification providers are currently Persona Identities, Inc. and Plaid Inc. By accepting this notice, you confirm that you are authorized to provide the personal information you give us, and you agree that Hill Technologies Inc. and Hill Securities LLC may disclose that information to those providers so they can verify your identity. They check it against records held by document issuers, government and other official record holders, and credit reporting agencies. This is an identity check, not an application for credit — your credit scores will not be affected. Verifying your identity is something Hill Securities is required to do under its customer-identification and anti-money-laundering obligations, so we cannot open or maintain a brokerage account for you without completing it. We may add or change identity-verification providers over time; where we do, they are engaged as service providers under this notice and may process your information only for the purposes described here.

Sensitive information

To provide brokerage services and comply with applicable law, we process certain sensitive information, such as your Social Security or taxpayer identification number, government-issued identification, biometric information used for identity verification, and financial account information. The verification documents you provide may also reveal characteristics of protected classifications, such as your sex, age, national origin, or citizenship status. We use this information for identity verification, eligibility and suitability determinations, and legal and regulatory compliance; we do not use it for marketing, and we handle it as described in this notice.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. How do we process your information?

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To provide and operate the Services and the Hill platform, and to facilitate account creation, authentication, and management.
• To provide brokerage services, and to process, execute, settle, and record your orders, subscriptions, and funding.
• To verify your identity and perform customer due diligence, know-your-customer, anti-money-laundering, and sanctions and politically-exposed-person screening.
• To determine your eligibility (including your accredited investor, qualified client, and/or qualified purchaser status) and to assess suitability.
• To comply with applicable laws and regulations, including the federal securities laws and the rules of FINRA, and to satisfy our books-and-records and reporting obligations.
• To detect, prevent, and address fraud, security incidents, and other misuse.
• To respond to your inquiries and provide support.
• To send you marketing and promotional communications in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
• To save or protect an individual's vital interest, such as to prevent harm.

3. What legal bases do we rely on to process your information?

We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

EU/UK Residents

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. This is the basis on which we verify your identity, including where that verification involves a facial-geometry scan: identity verification is required of Hill Securities by law and is not something we ask you to consent to, so you cannot withdraw it and continue to hold a brokerage account.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

Canada Residents

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

Identity verification in Canada. If you reside in Canada, you consent to Hill Securities collecting, using, and disclosing your personal information to its third-party identity-verification providers in order to verify your identity and to meet its obligations under Canada's Proceeds of Crime (Money Laundering) and Terrorist Financing Act. You understand that your information may be checked against records held by document issuers, government and other official record holders, and credit reporting agencies, and you consent to those checks. This is an identity check, not an application for credit — your credit scores will not be affected. Because verifying your identity is a legal requirement, withdrawing this consent means we cannot open or continue to maintain a brokerage account for you.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example, for investigations and fraud detection and prevention; for business transactions provided certain conditions are met; if we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse; or if disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records.

4. When and with whom do we share your personal information?

We may share your personal information in the following situations. Sharing of the nonpublic personal financial information of individuals is also subject to the U.S. Consumer Privacy Notice in Section 11.

• Affiliates. We may share your information among the Hill entities — companies related to us by common ownership or control, including our broker-dealer, investment adviser, and fund management and general partner entities — to operate the Services, provide brokerage services, administer the Funds (the special purpose vehicles through which investments are made) and offerings, and for our everyday business purposes.
• Service providers. We share information with vendors and service providers that perform services on our behalf, including identity-verification and sanctions and politically-exposed-person screening providers (currently Persona Identities, Inc. and Plaid Inc.); bank, payment, and financial-data providers; settlement and records providers; cloud hosting and infrastructure providers; analytics and communications providers (including Clerk for authentication and PostHog for product analytics, as described in Section 9); and professional advisors. We require these third parties to maintain appropriate safeguards and to use your information only for the purposes for which it was provided.
• Issuers, Funds, and their administrators. We may share information with the issuers, Funds, fund sponsors and general partners, fund administrators, and transfer agents as necessary to effect and administer your investments. These recipients are permitted to use your information only to manage and administer the investment for which it was provided. They may not sell it, and they may not use it to market to you.
• Regulators and legal authorities. We may share information with the U.S. Securities and Exchange Commission, FINRA, SIPC, and other regulators, self-regulatory organizations, and law enforcement, and as otherwise required to comply with applicable law, respond to legal process, or exercise or defend legal rights.
• Business transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. If such a transaction takes place, any successor's use of your personal information will remain subject to the then-current version of this privacy notice, we will notify you via email and/or a prominent notice on the Services, and we will tell you about any choices you may have. Records of Hill Securities are transferred only as permitted by applicable broker-dealer recordkeeping rules.

5. How long do we keep your personal information?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless a longer retention period is required or permitted by law. Because Hill Securities is a broker-dealer, we are subject to books-and-records and recordkeeping requirements under the federal securities laws and FINRA rules (for example, SEC Rule 17a-4), which require us to retain certain records relating to your account and transactions for specified periods after your account is closed or the relevant record is created.

Biometric information. Verifying your identity involves creating a scan of your facial geometry from the selfie you provide and comparing it to the photograph on your identification document. That scan is a biometric identifier. It is created and processed by our identity-verification provider on our behalf, and Hill does not store it. It is collected for one purpose — confirming that you are the person shown on the identification document you submitted — and is used for no other purpose, is never sold, leased, or traded, and is not used for marketing. The provider destroys it once that purpose has been satisfied, and in no event later than 30 days after your verification outcome is determined. Your identification document images and the record of your verification are retained by the provider for five years. Your identification document details, the verification method, and the outcome are not facial-geometry scans, and we retain those under the recordkeeping rules described above, including SEC Rule 17a-4 and our customer-identification obligations.

When we have no ongoing legitimate business need or legal obligation to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. How do we keep your information safe?

We aim to protect your personal information through a system of organizational and technical security measures. As a broker-dealer, Hill Securities maintains written policies and procedures reasonably designed to safeguard customer information, consistent with the safeguards requirements of the U.S. Securities and Exchange Commission's Regulation S-P.

We also maintain an incident-response program designed to identify, respond to, and remediate unauthorized access to or use of customer information. Where required by applicable law or regulation, including Regulation S-P, we will notify affected individuals of certain security incidents involving their information within the time periods and in the manner required.

However, despite our safeguards, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that unauthorized third parties will not be able to defeat our security. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk.

7. Do we collect information from minors?

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at legal@hill.com.

8. What are your privacy rights?

In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.

Withdrawing your consent: If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us at legal@hill.com. This will not affect the lawfulness of the processing before its withdrawal.

Opting out of marketing communications: You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in our emails, or by contacting us at legal@hill.com. We may still communicate with you to send service-related messages that are necessary for the administration and use of your account.

Account Information

If you would at any time like to review or change the information in your account, or terminate your account, you can contact us at legal@hill.com. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal and recordkeeping requirements (see Section 5).

9. Cookies, analytics, and tracking technologies

We use cookies and similar technologies to operate the Services. These include essential cookies set by our authentication provider, Clerk, which are necessary to create your session, keep you signed in, and protect your account; and product analytics performed with PostHog, which collects usage events, pages viewed, device and browser information, and IP address on our behalf so that we can understand how the Services are used and improve them. We do not use third-party advertising cookies, and we do not permit third parties to collect information on the Services for cross-context behavioral advertising.

You can configure your browser to refuse or delete cookies. If you disable essential cookies, parts of the Services — including signing in — may not function.

Do-Not-Track

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

10. U.S. state privacy rights

Depending on the U.S. state in which you reside, you may have specific rights regarding your personal information. Certain information we process in connection with the brokerage services is subject to the Gramm-Leach-Bliley Act and may be exempt from some state privacy laws; the rights below apply to the extent required by applicable law.

California

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA), provides you the right to know about the personal information we collect and how we use and share it; to request access to and deletion or correction of your personal information; and to opt out of the "sale" or "sharing" of personal information and to limit the use of sensitive personal information. We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We will not discriminate against you for exercising these rights. The CCPA/CPRA exempts personal information that we collect and process subject to the Gramm-Leach-Bliley Act, which covers most of the information we handle in providing brokerage services; the rights described above apply to personal information we process that is not subject to that Act. To exercise your rights, contact us at legal@hill.com.

Virginia

Under the Virginia Consumer Data Protection Act (CDPA), if you are a Virginia resident acting in an individual or household context, you have the right to be informed whether we are processing your personal data; to access, correct, and delete your personal data; to obtain a copy of the personal data you previously shared with us; and to opt out of the processing of your personal data for targeted advertising, the sale of personal data, or certain profiling. Hill has not sold, and will not sell, personal data to third parties for business or commercial purposes. To exercise your rights, contact us at legal@hill.com. We will respond within forty-five (45) days, subject to extension as permitted by law. If we decline to act, you may appeal by emailing legal@hill.com; if your appeal is denied, you may submit a complaint to the Virginia Attorney General.

Vermont and Nevada

If your Hill account has a Vermont mailing address, we will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information to nonaffiliated third parties to market to you, other than as permitted by Vermont law — including disclosures necessary to effect, administer, or enforce a transaction you request — unless you authorize us to make those disclosures. If your Hill account has a Nevada mailing address and you prefer not to receive marketing calls from us, contact us at legal@hill.com with "Nevada Marketing Notice" in the subject line.

11. U.S. Consumer Privacy Notice (Gramm-Leach-Bliley Act)

This Consumer Privacy Notice applies to you if you are an individual who resides in the United States and uses Hill Securities' services for your own personal, family, or household purposes. Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information.

What we collect. The types of personal information we collect and share depend on the product or service you have with us. This information can include your Social Security number and income; account balances and transaction history; and assets and investment experience.

How financial companies share. All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information; the reasons Hill chooses to share; and whether you can limit this sharing.

We provide this Consumer Privacy Notice when you open an account and annually thereafter for as long as you remain a customer, and we deliver it electronically in accordance with your electronic-delivery consent (for example, via the Services or email).

How to limit our sharing. To ask questions about our sharing practices or to exercise any right to limit sharing that applies to you, contact us at legal@hill.com. Please note that we may continue to share your information as permitted by law. We will not disclose your nonpublic personal information in ways that expand on the sharing described in this notice without first providing you a revised notice and, where required, an opportunity to opt out.

Definitions. Affiliates are companies related by common ownership or control, including our broker-dealer, investment adviser, and fund management and general partner entities. Nonaffiliates are companies not related by common ownership or control. Joint marketing is a formal agreement between nonaffiliated financial companies that together market financial products or services to you.

How we protect your information. To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings.

12. International data transfers

Hill is based in the United States, and we process and store information in the United States. If you access the Services from outside the United States, your information will be transferred to, and processed in, the United States and other countries, which may have data-protection laws that differ from those in your country. Where we transfer personal information outside its country of origin, we implement appropriate safeguards designed to ensure that such transfers are lawful and that your data remains protected, including, where applicable, the European Commission's Standard Contractual Clauses. To the extent permitted by applicable law, by using the Services you consent to the transfer of your information as described above.

13. Do we make updates to this notice?

Yes. We may update this privacy notice from time to time. The updated version will be indicated by an updated "Last updated" date and will be effective as soon as it is accessible. If we make material changes, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification, and we may ask you to accept the updated notice before continuing to use the Services. We encourage you to review this privacy notice frequently.

Exactly one version of this notice is in effect at any given time, and each version carries the effective date shown above. We keep a record of which version you accepted and when. Superseded versions are retained, and you may request a copy of the version you accepted by contacting us at the address in Section 14.

14. How can you contact us about this notice?

If you have questions or comments about this notice, you may email us at legal@hill.com, or write to us at Hill Technologies Inc., 501 2nd Street, Suite 575, San Francisco, CA 94107. For questions about the brokerage services provided by Hill Securities LLC, you may also call +1 (888) 971-5999.

15. How can you review, update, or delete the data we collect from you?

Based on the applicable laws of your country or state, you may have the right to request access to the personal information we collect from you, change that information, or delete it, subject to our legal and regulatory recordkeeping obligations. To request to review, update, or delete your personal information, please email us at legal@hill.com.

We may need to verify your identity before acting on a request, and we will use information you provide for verification only to respond to your request. Applicable law may allow or require us to decline or only partially fulfill a request — for example, where broker-dealer recordkeeping rules require us to retain certain records — and if we decline or narrow a request, we will explain the reason in our response.