Disclosures

At Investors Brokerage of Texas, Ltd. (IBOT), we are committed to protecting your privacy and the confidentiality of your personal and financial information.  The measures we take to keep your personal information private and secure are outlined below.

How We Protect Confidentiality

IBOT and its clearing firm, Hilltop Securities, Inc. (HTS) use procedural, physical and electronic system safeguards to store and secure information about you in compliance with federal standards.  Our systems protect your information from unauthorized access, alteration, and destruction.  Access is permitted only to those individuals within our organization who need the information to perform their job responsibilities.

When we enter into agreements with other companies to provide services to us or to make products and services available to you, we include a confidentiality clause.  Under such an agreement, these companies may receive information about you, but they may only use it for the intended purpose – to benefit you.

Persons Covered by the Privacy Policy

The IBOT Privacy Policy applies to anyone who is a current or former IBOT brokerage client, including those customer accounts of mutual fund companies and life and annuity companies with IBOT listed as the broker/dealer of record.  We provide you with a copy of this policy when you open an account, and we send you annual notifications thereafter.  If we change our policy regarding the sharing of information, we will notify you in advance and give you the opportunity to “opt out” of such disclosure.

How We Obtain Information About You In the normal course of business, we collect, retain and use information about you to serve your financial needs, administer your account(s) and inform you of products and services that may be of interest.  This data, known as non-public personal information (e.g., name, assets, income), may be collected from several sources, including: applications and other forms you file with us, records of transactions with us, our affiliates, and non-affiliated third parties.

Because we strive to provide you with the best possible service, we check the accuracy and completeness of your personal information regularly to ensure that it is correct.  Please contact your account representative if you need to correct or update your personal information.

Sharing Information – With Whom and Why 

IBOT does not sell your personal information to anyone.  We restrict the types of information we share and the types of entities with whom we share it.  The primary reason for sharing information about you is to increase your convenience in transacting business with us and to give you more financial service choices.

We do not disclose your personal information to non-affiliated third parties, unless one of the following exceptions applies: We disclose personal information to service providers that assist us in processing your transactions or servicing your account(s).  An example would be the company that prints and mails your account statements.

We disclose or report personal information in limited circumstances when we believe in good faith that disclosure is required or permitted under law.  For example, we would provide information in cooperation with securities regulators or law enforcement authorities, to resolve consumer disputes, or to perform credit evaluations and authenticate checks.

Investors Brokerage of Texas, Ltd., is a subsidiary of Insurors.com, Inc.  Since IBOT and  Insurors.com, Inc. are affiliated, they work with one another and may work together to service your financial needs.  The sharing of information among our parent company enables us to serve you more efficiently and makes it more convenient for you to do business with us.  We are permitted by law to share information with our parent company about your account history and your experiences with us. Our parent company follows similar privacy policies.

Internet Security 

We do not retrieve account or personal information from visitors who browse the public (pre-logon) areas of our Web site.  Clients who have the ability to access their accounts online are required to log on with their user name and individually selected password.  Your password is known solely to you, the client, and should never be shared with anyone.  You may change your password as often as you wish.

When you access your account online, it is through a Secure Socket Layer-encrypted session between your browser and the server of our clearing firm, Hilltop Securities, Inc. To ensure the highest
level of security, HTS has installed VeriSign Global Server Ids on each server.  HTS will continue to enhance security procedures as new technologies become available.  Each time you access your account please don’t forget to log off when you are finished. This will prevent someone else from accessing your account if you leave your computer and your session hasn’t automatically shut down.

Investors Brokerage of Texas, Ltd. employees utilize information about you to respond to your needs and to provide you with information about specific products in which you may have an interest.  We instruct our employees to use strict standards of care in handling the personal, confidential information of customers and remind them on a regular basis of their obligations with regard to the confidentiality of customer information.

Option to Opt Out and Change Notices 

If for any reasons at any time in the future, we find it necessary to disclose any of your personal information in a way that is inconsistent with this policy, we will give you advance notice of the proposed change and the opportunity to opt out of such disclosure.

If you have questions or concerns, please contact us at (254) 759-3714 or (800) 833-3376.

To help the government fight the funding of terrorism and money laundering activities, federal law requires financial institutions to obtain, verify, and record information that identifies each person who opens an account.  This notice answers some questions about the Investors Brokerage of Texas, Ltd Customer Identification Program.

What types of information will I need to provide?

When you open an account, Investors Brokerage of Texas, Ltd is required to collect information including your name, address, Social Security number or tax identification number, citizenship, age,occupation, bank or other brokerage reference, as well as your financial situation (net worth, income, investments experience, investment objective.

You may need to show your driver’s license or other identifying documents.

A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, employer identification number, certified articles of incorporation, government-issued business license, a partnership agreement, or a trust agreement.

U.S. Department of the Treasury, Securities and Exchange Commission, FINRA, and New York Stock Exchange rules already require you to provide most of this information. These rules may require you to provide additional information, such as your net worth, annual income, occupation, employment information, investment experience and objectives, and risk tolerance.

What happens if I don’t provide the information requested or my identity can’t be verified?

Investors Brokerage of Texas, Ltd may not be able to open an account or carry out transactions for you.  If IBOT has already opened an account for you, we may have to close it.  We thank you for your patience and hope that you will support the financial industry’s efforts to deny terrorists and money launderers access to America’s financial system.

BUSINESS CONTINUITY PLAN

Investors Brokerage of Texas, Ltd. has developed a Business Continuity Plan on how we will respond to events that significantly disrupt our business.  Since the timing and impact of disasters and disruptions is unpredictable, we will have to be flexible in responding to actual events as they occur.  Therefore, we are providing you with this information on our business continuity plan.

Contacting Us – If after a significant business disruption you cannot contact us as you usually do at 254-759-3718 or 254-759-3714 or 254-759-3701, you should call one of our alternative numbers
254-776-3297 or 254-722-2588 for Tim Kohn or 254-235-8722 for Joe Brooks or go to our web site at www.insurors.com.  If you cannot access us through either of those means, you should contact our
clearing firm, Hilltop Securities, Inc., at 214-953-4000 or 800-678-3792 or at their web site www.hilltopsecurities.com for instructions on how Hilltop Securities Inc. may provide prompt access to your funds and securities, enter orders and process other trade-related, cash, and security transfer transactions. 

Our Business Continuity Plan – We plan to quickly recover and resume business operations after a
significant business disruption and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the firm’s books and records, and allowing our customers to transact business.  In short, our business continuity plan is designed to permit our firm to resume operations as quickly as possible, given the scope and severity of the significant business disruption.  Our business continuity plan addresses: data back up and recovery; all mission critical systems; financial and operational assessments; alternative communications with customers, employees, and regulators; alternate physical location of employees; critical supplier, contractor, bank and counter-party impact; regulatory reporting; and assuring our customers prompt access to their funds and securities if we are unable to continue our business.  Our clearing firm, Southwest Securities, Inc., backs up our important records in a geographically separate area. While every emergency situation poses unique problems based on external factors, such as time of day and the severity of the disruption, our clearing firm has advised us that its objective is to restore its own operations and be able to complete existing transactions and accept new transactions and payments within four hours.  Your orders and requests for funds and securities could be delayed during this period.

Varying Disruptions –Significant business disruptions can vary in their scope, such as only our
firm, a single building housing our firm, the business district where our firm is located, the city where we are located, or the whole region.  Within each of these areas, the severity of the disruption can also vary from minimal to severe.  In a disruption to only our firm or a building housing our firm, we will transfer our operations to a local site when needed and expect to recover and resume business within four hours.  In a disruption affecting our business district, city, or region, we will transfer our operations to a site outside of the affected area, and recover and resume business within one business day.  In either situation, we plan to continue in business, transfer operations to our clearing firm if necessary, and notify you through our web site www.insurors.com or our customer emergency numbers, 254-776-3297 or 254-759-3708 how to contact us.  If the significant business disruption is so severe that it prevents us from remaining in business, we will assure our customer’s prompt access to their funds and securities.

For more information – If you have questions about our business continuity planning, you can contact us at 254-759-3714 or 254-759-3718.

COMPLAINT NOTIFICATION Please direct any complaints or grievances to:Timothy R Kohn (254)759-3718 or Brian Bachik (254)759-3713

INVESTORS BROKERAGE OF TEXAS, LTD

Mailing address:PO Box 2683

Physical address:225 S. 5^th Street

Waco, TX 76702-2683