Privacy Notice

MANOR HOUSE CAPITAL PRIVACY NOTICE

Our Commitment to Your Privacy: Manor House Capital has a long-standing policy of protecting the confidentiality and security of information we collect about our clients. We do not share nonpublic information about you ("Information") without your consent except for the specific purposes described below, in accordance with all applicable laws. This Notice describes the Information we may gather and the circumstances under which we may share it.
Why We Collect and How We Use Information: We limit the collection and use of Information to the minimum we require to deliver superior service to you. Such service includes advising you about our products, services and other opportunities, maintaining your accounts with us, processing transactions requested by you or other persons authorized by you and administering our business.

How We Gather Information: We get most Information directly from you, when you apply for, access and use our and our business partners' financial products and services - whether in person, by telephone or electronically. We may verify this information or get additional information from consumer reporting agencies or public sources. This Information may relate to your finances, employment, avocations or other personal characteristics, as well as transactions and interactions with or through us or with others.

How We Protect Information: Our employees, registered representatives and investment adviser representatives acting on our behalf are required to protect the confidentiality of Information and to comply with our established policies. They may access Information only when there is an appropriate reason to do so, such as to administer or offer our products or services. We also maintain physical, electronic and procedural safeguards to protect Information, which comply with all applicable laws. Employees who violate our Privacy Policy will be subject to disciplinary process.

Disclosure of Information: We may disclose any Information when we believe it necessary for the conduct of our business, or where disclosure is required by law. For example, Information may be disclosed for audit or research purposes, to attorneys or other professionals, or to law enforcement and regulatory agencies to help, among other things, prevent fraud or money laundering. In addition, we may disclose Information to other Manor House Capital companies or third party service providers (i) to enable them to provide business services for us, such as performing computer related or data maintenance or processing services for us, (ii) to facilitate the processing of transactions requested by you, (iii) to assist us in offering our or other Manor House Capital companies' products and services to you, or (iv) for credit review or reporting purposes. We may also provide Information to other non-affiliated companies with which we have joint marketing agreements, such as an agreement with another financial institution or an investment adviser, trust company or other company enabling us to offer you certain of its products or services. Except in those specific, limited situations, without your consent, we will not make any disclosures of Information to other companies who may want to sell their products or services to you. For example, we do not sell customer lists and we will not sell your name to a catalogue company or telemarketer. Moreover, it is Manor House Capital's policy to require all third parties that are to receive any Information to sign strict confidentiality agreements.

Our Former Clients: Even if you are no longer a Manor House Capital client, our Privacy Policy will continue to apply to you.

To Whom This Policy Applies: This Privacy Policy applies to Manor House Capital, along with all funds managed or administered by any third parties employed by Manor House Capital, except to the extent that in special circumstances any third party has a special policy and sends notice of that policy to its clients who are affected by the special policy. This Privacy Policy applies to products or services provided by Manor House Capital in the United States and which are used primarily for personal, family, or household purposes (not business purposes).

Access to and Correction of Information: Upon your written request, we will make available for your review any file we may maintain for your personal Information; provided, however, that any Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available. If you notify us that any Information is incorrect, we will review it. If we agree, we will correct our records. If we do not agree, you may submit a short statement of dispute, which we will include in any future disclosure of the disputed Information.

Further Information: We reserve the right to change this Privacy Policy at any time. The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive. This notice complies with a recent Federal law and regulations regarding privacy. You may have additional rights under other foreign or domestic laws that may apply to you.

MANOR HOUSE CAPITAL DISCLOSURES

Information Does Not Constitute a Recommendation, Solicitation or Offer: None of the information contained in this website constitutes a recommendation, solicitation or offer by Manor House Capital to buy or sell any securities, futures, options or other financial instruments or provide any investment advice or service. The information contained in this website has been prepared without reference to any particular user's investment requirements or financial situation. Certain transactions give rise to substantial risk and are not suitable for all investors. Prior to the execution of any transaction by you involving information you received from this website, you should consult your business advisor, attorney and tax and accounting advisors with respect to the price, suitability, value, risk or other aspects of any stock, mutual fund, security or other investment. Pricing and other information generated through the use of data or services made available herein may not reflect actual prices or values that would be available in the market at the time provided or at the time that the user may want to purchase or sell a particular security or other instrument. The information and services provided on this website are not provided to and may not be used by any person or entity in any jurisdiction where the provision or use thereof would be contrary to applicable laws, rules or regulations of any governmental authority or regulatory or self-regulatory organization or clearing organization or where Manor House Capital is not authorized to provide such information or services. Some products and services described in this website may not be available in all jurisdictions or to all clients. The information in this website is only directed to U.S. residents.

Risk of Loss: The past performance is not a guarantee of any investments future performance, and there can be no assurance that the investment will achieve comparable results in the future. Performance for an individual investor may vary from the performance stated herein as a result of the timing of their investment(s), different management and incentive fee structures. Investment returns as such are subject to audit, and may change. Investment strategies may involve a great deal of risk, and loss of principal is a possibility. Investment funds may be illiquid, and redemptions are subject to the terms of the offering.

Insurance and Annuity Products: The information for the private placement life insurance account statement provided by Manor House Capital, LLC ("MHC") has been acquired from the insurance carrier monthly statements provided to Manor House Capital and the client and the investment manager monthly return tear sheets provided by each investment manager. Manor House Capital is relying on the information provided by insurance carrier and investment manager when compiling the account statement. Although the statements of fact and data in this report have been obtained from, and are based upon, sources we believe to be reliable, Manor House Capital can not guarantee their accuracy, and any such information may be incomplete or condensed. As such Manor House Capital does not guarantee or warrant the correctness or accuracy of the information provided to Manor House Capital by the respective parties, nor does it guarantee the accuracy or correctness of the account statement provided. This report is for information purposes only and is not intended as an offer or solicitation with respect to purchase or sale of any security. Each client should consult the monthly, quarterly, and annual life insurance policy statement provided by the insurance carrier to note the appropriate insurance carrier charges and investment returns for their respective insurance policy. There are no guaranteed cash values under this contract. The cash value is subject to investment risk, and past performance of the investment funds is neither a guarantee of future performance nor a guarantee that investment objectives of the fund will be achieved. Fund performance on the tear sheets is estimated by the investment manager, and is subject to change by investment managers and/or auditors. Refer to the original illustrations and/or PPM for a summary of any and all non-guaranteed and guaranteed insurance charges associated with the particular insurance contract. Manor House Capital does not provide legal, tax, or accounting advice. As such please consult your respective advisor for answers to any questions pertaining those subject matters.

MANOR HOUSE CAPITAL ANTI-MONEY LAUNDERING

Anti Money Laundering: Important Information About Procedures for Opening a New Account: To help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens a new account.

What this means to you: When you open an account, we will ask for your name, address, date of birth and other information that will allow us to identify you. We will also ask to see your driver's license or other identifying documents.

MANOR HOUSE CAPITAL WEBSITE TERMS OF USE

Your access to and use of the www.manorhousecapital.com Web site (this "Site"), which is owned and operated by Manor House Capital, LLC ("MHC"), is governed by the following terms and conditions of usage ("Terms of Use"). Do not use this Site if you do not agree to be bound by these Terms of Use. If you do not wish to be bound by these Terms of Use, you must not use this Site.

PLEASE READ THESE TERMS OF USE CAREFULLY BEFORE USING THIS SITE.

Purpose: This Site is provided solely for the purpose of providing information about Manor House Capital and its activities. The information provided on this Site is 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 law or regulation or which would subject Manor House Capital to any registration requirement within such jurisdiction or country. Manor House Capital IS NOT UTILIZING THIS SITE TO PROVIDE INVESTMENT OR OTHER ADVICE TO YOU OR ANY OTHER PARTY, AND NO INFORMATION OR MATERIAL AT THIS SITE IS TO BE RELIED UPON FOR THE PURPOSE OF MAKING OR COMMUNICATING INVESTMENT OR OTHER DECISIONS. NEITHER THE INFORMATION NOR ANY OPINION CONTAINED ON THIS SITE CONSTITUTES INVESTMENT ADVICE OR A SOLICITATION BY Manor House Capital FOR THE PURCHASE OR SALE OF ANY SECURITIES, FUTURES, OPTIONS OR OTHER FINANCIAL INSTRUMENTS OR TO PROVIDE ANY INVESTMENT ADVICE OR SERVICE.

IF YOU ARE IN ANY DOUBT AS TO WHETHER THIS SITE CAN BE LAWFULLY USED BY YOU DO NOT USE THIS SITE.

The information on this Site has been compiled from both internal and external sources. Manor House Capital uses reasonable efforts to make sure that the information appearing on this Site is accurate and up-to-date. However, Manor House Capital does not represent or warrant that the information contained herein is accurate or complete.

Posted Guidelines: In addition to these Terms of Use, when using this Site, you will be subject to and agree to follow any posted guidelines or rules, which may be posted on this Site from time to time.

Passwords: The password protected areas of this Site, and the information contained on or through this Site, may be accessed only by persons who have been authorized by Manor House Capital to use such areas pursuant to these Terms of Use and solely based on written representations and warranties or other information such persons have given to Manor House Capital. The password assigned to you is for your use only and you are solely responsible for the safekeeping of your password. You are responsible if your password is lost, stolen or misused and you must notify Manor House Capital immediately if any of these events happen. You will be responsible for all activity attributable to your password including for any adverse regulatory or other consequences for Manor House Capital or any of its other customers arising as a result of any unauthorized use of your password. YOUR FAILURE TO COMPLY WITH THESE REQUIREMENTS MAY HAVE SERIOUS REGULATORY CONSEQUENCES FOR Manor House Capital AND THEREFORE FOR YOU.

Right to Terminate User Access: Manor House Capital reserves the right to limit, restrict and terminate your access to, and use of, this Site at any time, in whole or in part, in its sole discretion and without notice.

DISCLAIMER OF WARRANTY AND LIMTATION OF LIABILITY

Information "As Is" and "As Available": THE INFORMATION PROVIDED ON OR THROUGH THIS SITE IS PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTY OF ANY KIND. YOUR USE OF THIS SITE IS AT YOUR OWN RISK. ALTHOUGH THE INFORMATION ON THIS SITE IS OBTAINED OR COMPILED FROM SOURCES Manor House Capital BELIEVES TO BE RELIABLE, Manor House Capital CANNOT AND DOES NOT GUARANTEE OR MAKE ANY REPRESENTATION OR WARRANTY, EITHER EXPRESS OR IMPLIED, AS TO THE ACCURACY, VALIDITY, SEQUENCE, TIMELINESS, COMPLETENESS OR CONTINUED AVAILABILITY OF ANY INFORMATION OR DATA MADE AVAILABLE ON THIS SITE. IN NO EVENT WILL Manor House Capital BE LIABLE FOR ANY DECISION MADE OR ACTION OR INACTION TAKEN BY YOU IN RELIANCE ON ANY INFORMATION OR DATA ON THIS SITE. Manor House Capital FURTHER EXPLICITLY DISCLAIMS, TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, ANY WARRANTY OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. Manor House Capital, SUPPLIERS OF THIRD-PARTY CONTENT AND ANY OTHER THIRD PARTY WORKING WITH Manor House Capital, WILL NOT BE RESPONSIBLE OR LIABLE, DIRECTLY OR INDIRECTLY, FOR ANY DAMAGES OR LOSS (INCLUDING DIRECT, INDIRECT, INCIDENTAL, CONSEQUENTIAL AND ANY AND ALL OTHER FORMS OF DAMAGES OR LOSSES REGARDLESS OF THE FORM OF THE ACTION OR THE BASIS OF THE CLAIM) CAUSED OR ALLEGED TO BE CAUSED IN CONNECTION WITH YOUR USE OF THIS SITE WHETHER OR NOT FORESEEABLE, EVEN IF Manor House Capital, SUPPLIERS OF THIRD-PARTY content OR OTHER THIRD PARTIES WORKING WITH Manor House Capital IN CONNECTION WITH THIS SITE, HAVE BEEN ADVISED OF THE POSSIBILITY OR LIKELIHOOD OF SUCH DAMAGES.

Computer Viruses: Manor House Capital is not responsible for any computer virus or related problems that may be attributable to this Site.

Internet Security: You understand and agree that Manor House Capital utilizes a variety of electronic networks, including the Internet, to transport data and communications. Complete confidentiality and security is not yet possible over the Internet and the transmission of any data on any electronic network may be subject to delay, interruption, interception, blackout or inaccuracy. Manor House Capital advises you that the Internet is not a secure medium and privacy cannot be ensured. You agree that neither Manor House Capital nor any third party working with Manor House Capital in connection with this Site will be responsible for any kind of loss or damage caused by any such event or by communications line failure, interception by third parties, unauthorized access, theft, systems failure, service interruption, or other occurrence beyond their control, or from any other cause relating to your access to, inability to access or use of this Site, whether or not the circumstances giving rise to such cause may have been within the control of Manor House Capital or any third party working with Manor House Capital in connection with this Site.

Encryption: Manor House Capital may use encryption technology to protect certain transmissions of data to/from this Site, but e-mail and other communications, unless otherwise noted on this Site, are not encrypted to/from this Site. Therefore, you should not send any personal or identifying information, such as account numbers, credit card numbers, Social Security numbers, passwords, etc., to Manor House Capital via e-mail. Your use of e-mail or other electronic communication means you acknowledge that you have no expectation of privacy with respect to the information delivered thereby and that Manor House Capital will not be responsible for any loss or damage that could result from interception by third parties of any information so sent.

RESERVATION OF RIGHTS

Site Content: All content and information contained within this Site or delivered to you in connection with your use of this Site (including all text, graphics, audio, video, icons, software code and trade secrets, as well as the overall organization, design, look, feel and appearance of this Site) (collectively, the "Site Content") is protected under applicable patent, copyright, trademark and other intellectual property laws (collectively, "Proprietary Rights"), both as individual works and as a compilation. Manor House Capital does not waive any of its Proprietary Rights in this Site or in any Site Content, and the availability of any Site Content will not, under any circumstance, constitute a transfer of any Proprietary Rights of Manor House Capital or any of its licensors to any user or any other third party.

Printing and Downloading: If you download any information from this Site for your personal non-commercial use, you agree that you will not remove or obscure any copyright or other notices contained in any such information. You may not copy, republish, redistribute, transmit, participate in the transmission of, create derivatives of, alter, edit or exploit in any manner any material from this Site, including by storage on retrieval systems, without the express written permission of Manor House Capital.

MISCELLANEOUS

Entire Agreement: These Terms of Use constitute the entire agreement of the parties hereto with respect to the subject matter hereof and supersede all prior agreements and undertakings, both written and oral, between the parties with respect to the subject matter hereof.

Severability: If any term or other provision of these Terms of Use is invalid, illegal or incapable of being enforced by any law or public policy, all other terms and provisions of these Terms of Use will nevertheless remain in full force and effect so long as the economic or legal substance of the transactions contemplated hereby is not affected in any manner materially adverse to any party. Governing Law; Forum: These Terms of Use will be governed in all respects by the laws of Pennsylvania.

Waiver of Jury Trial: YOU WAIVE TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW ANY RIGHT YOU MAY HAVE TO A TRIAL BY JURY WITH RESPECT TO ANY ACTIONS OR PROCEEDINGS DIRECTLY OR INDIRECTLY ARISING OUT OF, UNDER, OR IN CONNECTION WITH, THESE TERMS OF USE.