IMPORTANT DISCLOSURES

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.

The contents at the sites linked through TwinFocus.com are intended for the use of non-U.S. investors only and are not intended for distribution to, or use by, any person or entity in any jurisdiction or country where such distribution or use would be contrary to local law or regulation. By clicking on a link to a non-U.S. TwinFocus page, you acknowledge that you are leaving the U.S. TwinFocus.com website and acknowledge that you entering another jurisdiction that has differing applicable securities laws that must be followed. TwinFocus makes no representation that the contents of the site are appropriate for use in all locations, or that the transactions, securities, products, instruments or services discussed at this site are available or appropriate for sale or use in all jurisdictions or countries, or by all investors or counterparties. All persons and entities accessing this site do so on their own initiative and are responsible for compliance with applicable local laws and regulations. Nothing on this site shall be considered the provision of investment advice, or a solicitation to buy or an offer to sell a security to any person in any jurisdiction where such offer, solicitation, purchase or sale would be unlawful under the securities laws of such jurisdiction.

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 is for informational purposes only and should not be construed, in any manner whatsoever, as the receipt of, or a substitute for, personalized individual financial, investment, retirement planning, insurance, legal, accounting, or tax advice from Twin Focus. Decisions based on information contained in this website are the sole responsibility of the user. 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. This web site contains certain forward looking statements, due to known and unknown risks there is no guarantee these statements will come to pass.

We are neither your attorneys nor your accountants and no portion of this material should be interpreted by you as legal, accounting or tax advice.
This website should not be used or relied upon by you as a substitute for your independent research or professional advice. You should consider your own investment objectives and any investment’s risks, charges, and expenses carefully before investing.

Case studies included on this website may not be representative of the experiences of other TwinFocus clients.

The website is provided on an “as is” and “as available” basis. You acknowledge and agree that to the full extent permitted under applicable law, TwinFocus and its affiliates, subsidiaries, directors, officers, employees, agents, licensors, and any third-party information providers and vendors expressly disclaim all warranties, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, and all warranties regarding security, currency, correctness, quality, accuracy, completeness, reliability, performance, timeliness, or continued availability, with respect to (1) the website; (2) any materials, products or services available on or through the website; (3) use of the website, materials, products, or services; and (4) the results of the use of the website, materials, products, or services.

Further, TwinFocus and its affiliates, subsidiaries, directors, officers, employees, agents, licensors, and any third-party information providers and vendors expressly disclaim all warranties with respect to any delays or errors in the transmission or delivery of any materials, products, or services available through this website.

Except as provided by law, neither TwinFocus nor its third-party information providers and vendors has any responsibility to maintain the materials, products, or services offered on the website or to supply corrections, updates, or releases for the same. Some states do not allow the disclaimer of certain warranties, so the foregoing disclaimers may not apply to you.

Reference to any products, services, processes, or other information, by trade name, trademark, manufacturer, or supplier or otherwise does not constitute or imply endorsement, sponsorship or recommendation thereof by TwinFocus.

ACCESS TO THIS WEB SITE IS PROVIDED FOR INFORMATIONAL PURPOSES ONLY AND WITHOUT ANY WARRANTIES, EXPRESSED OR IMPLIED, REGARDING THE ACCURACY, COMPLETENESS, TIMELINESS, OR RESULTS OBTAINED FROM ANY INFORMATION POSTED ON THIS WEB SITE OR ANY THIRD PARTY WEB SITE LINKED TO THIS WEB SITE.

You acknowledge and agree that neither TwinFocus, nor its affiliates, subsidiaries or their licensors, service providers, employees, agents, officers or directors will be liable, whether in contract, tort, strict liability or otherwise, for any direct, indirect, incidental, special, consequential, punitive, or exemplary damages, including, but not limited to, damages for loss of profits, revenue, income, goodwill, use, data, or other intangible losses, or damages caused by theft, unauthorized access, systems failure, or communications line failure, or the cost of procuring substitute goods or services, caused by the use of or inability to use the website, materials or any products or services provided herein, or any other matter relating to this website, even if TwinFocus has been advised of the possibility of such damages. Any materials downloaded or otherwise obtained through this website are done at your own risk. You are solely responsible for any damage to your computer system of other equipment, or loss of data that results from such download. Some jurisdictions do not allow the exclusion or limitation of incidental or consequential damages, therefore TwinFocus, and its affiliates, subsidiaries, directors, officers, employees, agents, licensors, and any third-party information providers and vendors shall have limited liability to the extent permitted by law in such jurisdictions. Federal and state securities laws impose liabilities under certain circumstances on persons who act in good faith and the foregoing does not affect any liability that cannot be excluded under applicable law.

You acknowledge and agree to defend, indemnify and hold harmless TwinFocus, its affiliates, and all of its and their officers, directors, agents, suppliers, and licensors from and against any and all claims, damages, costs and expenses, including attorneys’ fees, arising from or related to your improper access to or use of any of the website or any content on or linked to from the website, including, but not limited to, any claim by a third party. TwinFocus reserves the right to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you will assist and cooperate with TwinFocus in asserting any available defenses.

 

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.