Disclaimer

Twin Focus Capital Partners, LLC (“Twin Focus”) is an SEC registered investment adviser located in the Commonwealth of Massachusetts. Twin Focus and its representatives are in compliance with the current notice filing requirements imposed upon SEC registered investment advisers by those states in which Twin Focus maintains clients. Twin Focus may only transact business in those states in which it is notice filed or qualifies for an exemption or exclusion from notice filing requirements. Twin Focus’s web site is limited to the dissemination of general information regarding its investment advisory service to United States residents residing in states where providing such information is not prohibited by applicable law. Accordingly, the publications of Twin Focus’s website on the Internet should not be construed by any consumer and/or prospective client as Twin Focus’s solicitation to effect transactions in securities or rendering of personalized investment advice for compensation over the Internet. Furthermore, the information resulting from the use of tools or other information on this Internet site should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual advise from Twin Focus. Any subsequent, direct communication by Twin Focus with a prospective client shall be conducted by a representative that is either registered or qualifies for an exemption or exclusion from registration in the state where the prospective client resides. For information pertaining to the registration status of Twin Focus, please contact the United States Securities and Exchange Commission on their web site at www.adviserinfo.sec.gov. A copy of Twin Focus’s current written disclosure statement discussing Twin Focus’s business operations, services, and fees is available from Twin Focus upon written request. Twin Focus does not make any representations as to accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to Twin Focus’s web site or incorporated herein and takes no responsibility therefore. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.



The Twin Focus Privacy Policy

Twin Focus Capital Partners, LLC has adopted this policy with recognition that protecting the privacy and security of the personal information we obtain about our customers is an important responsibility. We also know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain certain personal information about you. We want you to know what information we collect and how we use and safeguard that information. Maintaining your trust and confidence is among our highest priorities. We recognize that protecting the privacy and security of our customers is an important responsibility. That’s why we at Twin Focus Capital Partners, LLC want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. We collect certain nonpublic personal identifying information about you (such as your name, address, social security number, etc.) from information that you provide on applications or other forms as well as communications (electronic, telephone, written or in person) with you or your authorized representatives (such as your attorney, accountant, etc.). We also collect information about your brokerage accounts and transactions (such as purchases, sales, account balances, inquiries, etc.). We do not disclose the nonpublic personal information we collect about our customers to anyone except: (i) in furtherance of our business relationship with them and then only to those persons necessary to effect the transactions and provide the services that they authorize (such as broker-dealers, custodians, independent managers etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose. If you decide at some point to either terminate our services or become an inactive customer, we will continue to adhere to our privacy policy, as may be amended from time to time. We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information. Our policy about obtaining and disclosing information may change from time to time. We will provide you notice of any material change to this policy before we implement the change.