Terms and Conditions

Risk Considerations
As it may relate to certain recommended actions, it is the sole duty of the client and/or controlling
operating or investing entity to perform their own risk assessment and due diligence relating to any
operational recommendations or changes to your financial risk profile. All investing involves some
degree of risk, whether it is associated with market volatility, purchasing power or a specific
security.  Fixed income securities are subject to the risks associated with debt securities generally,
including credit, liquidity and interest rate risk*.  Equity investments* are subject to market risk, which
means that the value of its investments may go up or down in response to the prospects of individual
companies, particular sectors and/or general economic conditions*.  Alternative investing* is not
suitable for all investors and are not riskless investments, so investors can lose money.  An
investment in real estate securities is subject to greater price volatility and the special risks
associated with direct ownership of real estate.

General Disclosures
This information discusses general market activity, industry or sector trends, or other broad-based
economic, market or political conditions and should not be construed as research or investment
advice. This material has been prepared by Zephyr Advisory Group and is not financial research nor a
product of Zephyr Advisory Group or its affiliates. It was not prepared in compliance with applicable
provisions of law designed to promote the independence of financial analysis and is not subject to a
prohibition on trading following the distribution of financial research. The views and opinions
expressed may differ from those of Zephyr Advisory Group or other departments or divisions Zephyr
Advisory Group and its affiliates. Investors are urged to consult with their financial advisors before
buying or selling any securities. This information may not be current and Zephyr Advisory Group has
no obligation to provide any updates or changes.

This material is provided for educational purposes only and should not be construed as investment
advice or an offer or solicitation to buy or sell securities.

There is no guarantee that these objectives will be met.

Views and opinions expressed are for informational purposes only and do not constitute a
recommendation by Zephyr Advisory Group or its affiliates to buy, sell, or hold any security, they
should not be construed as investment advice.

THIS MATERIAL DOES NOT CONSTITUTE AN OFFER OR SOLICITATION IN ANY JURISDICTION WHERE OR
TO ANY PERSON TO WHOM IT WOULD BE UNAUTHORIZED OR UNLAWFUL TO DO SO.

Prospective investors should inform themselves as to any applicable legal requirements and taxation
and exchange control regulations in the countries of their citizenship, residence or domicile which
might be relevant.

This material is provided for informational purposes only and should not be construed as investment
advice or an offer or solicitation to buy or sell securities. This material is not intended to be used as a
general guide to investing, or as a source of any specific investment recommendations, and makes no
implied or express recommendations concerning the manner in which any client’s account should or
would be handled, as appropriate investment strategies depend upon the client’s investment
objectives.

No offer to acquire any interest in a fund or a financial product is being made to you in this document.
If you do not understand the contents of this document and site, you should consult with a financial
advisor.

Zephyr Advisory Group Web site – Terms and Conditions of Use
Access to the Zephyr Advisory Group Web site defined below is provided by ZEPHYR
ADVISORY GROUP. For purposes of this agreement, “ZEPHYR ADVISORY GROUP”, “we,” “us”
or “our” shall mean Zephyr Advisory Group LLC and its affiliates, and their officers, directors,
managing directors, partners, and employees. The “Zephyr Web site” shall mean the Web
site of Zephyr Advisory Group LLC available to the general public and located at
zephyradv.com and select other domains.

Monitoring by ZEPHYR ADVISORY GROUP: Your use of the products and services on this
Web site may be monitored by ZEPHYR ADVISORY GROUP, and that the resultant information
may be used by ZEPHYR ADVISORY GROUP for its internal business purposes or in
accordance with the rules of any applicable regulatory or self-regulatory organization.
Information Made Available Through this Service: You are permitted to store, display,
analyze, modify, reformat, and print the information made available to you via these
services only for your own use. You are not permitted to publish, transmit, or otherwise
reproduce this information, in whole or in part, in any format to any third-party without the
express written consent of ZEPHYR ADVISORY GROUP. In addition, you are not permitted to
alter, obscure, or remove any copyright, trademark or any other notices that are provided to
you in connection with the information. ZEPHYR ADVISORY GROUP reserves the right, at any
time and from time to time, in the interests of its own editorial discretion and business
judgment to add, modify, or remove any of the information. These Terms and Conditions of
Use are not intended to, and will not, transfer or grant any rights in or to the information
other than those which are specifically described herein, and all rights not expressly granted
herein are reserved by ZEPHYR ADVISORY GROUP or the third-party providers from whom
ZEPHYR ADVISORY GROUP has obtained the information. You are required to read and abide
by any additional terms and conditions that may be posted on this service from time to time
concerning information obtained from specific third-party providers. Such third-party
providers shall have no liability to you for monetary damages on account of the information
provided to you via this service.

No warranties made as to content; no responsibilities to update: ZEPHYR ADVISORY
GROUP makes no warranty, express or implied, concerning this service. The services
provided by us and our third-party providers are on an “AS IS” basis at your sole
risk. ZEPHYR ADVISORY GROUP expressly disclaims any implied warranty of
merchantability or fitness for a particular purpose, including any warranty for the
use or the results of the use of the services with respect to their correctness,
quality, accuracy, completeness, reliability, performance, timeliness, or continued
availability.

Neither ZEPHYR ADVISORY GROUP nor any of its third-party providers shall have any
responsibility to maintain the data and services made available on this Web site or to supply
any corrections, updates, or releases in connection therewith. Availability of data and
services are subject to change without notice.
 

For web content – legal and terms of use disclosures to be added
No liability for content; no liability arising from use: ZEPHYR ADVISORY GROUP shall
have no liability, contingent or otherwise, to you or to third parties, or any responsibility
whatsoever, for the failure of any connection or communication service to provide or
maintain your access to this service, or for any interruption or disruption of such access or
any erroneous communication between ZEPHYR ADVISORY GROUP and you, regardless of
whether the connection or communication service is provided by ZEPHYR ADVISORY GROUP
or a third-party service provider. ZEPHYR ADVISORY GROUP shall have no liability, contingent
or otherwise, to you or to third parties, for the correctness, quality, accuracy, timeliness,
reliability, performance, continued availability, completeness or delays, omissions, or
interruptions in the delivery of the data and services available on this Web site or for any
other aspect of the performance of this service or for any failure or delay in the execution of
any transactions through this service. In no event will ZEPHYR ADVISORY GROUP be liable for
any special, indirect, incidental, or consequential damages which may be incurred or
experienced on account of you using the data or services made available on this Web site,
even if ZEPHYR ADVISORY GROUP has been advised of the possibility of such damages.
ZEPHYR ADVISORY GROUP will have no responsibility to inform you of any difficulties
experienced by ZEPHYR ADVISORY GROUP or third parties with respect to the use of the
services or to take any action in connection therewith.

Content not to be construed as a solicitation or recommendation: This
material has been prepared for informational purposes only without regard to any
particular user’s investment objectives, financial situation, or means, and Zephyr
Advisory Group is not soliciting any action based upon it. This material is not to be
construed as a recommendation; or an offer to buy or sell; or the solicitation of an
offer to buy or sell any security, financial product, or instrument; or to participate in
any particular trading strategy in any jurisdiction in which such an offer or
solicitation, or trading strategy would be illegal. Certain transactions, including
those involving futures, options, and high-yield securities, give rise to substantial
risk and are not suitable for all investors. Although this material is based upon
information that Zephyr Advisory Group considers reliable and endeavors to keep
current, Zephyr Advisory Group has not verified this information and does not
represent that this material is accurate, current, or complete and it should not be
relied upon as such.

No determination of suitability has been made; not all risks are disclosed;
private advisors should be consulted: The fact that Zephyr Advisory Group has
made the data and services provided on this Web site available to you constitutes
neither a recommendation that you enter into a particular transaction nor a
representation that any product described on this Web site is suitable or appropriate
for you. Many of the products described on this Web site involve significant risks,
and you should not enter into any transactions unless you have fully understood all
such risks and has independently determined that such transactions are appropriate
for you. Any discussion of the risks contained herein with respect to any product
should not be considered to be a disclosure of all risks or complete discussion of the

 

For web content – legal and terms of use disclosures to be added
risks which are mentioned. You should neither construe any of the material
contained herein as business, financial, investment, hedging, trading, legal,
regulatory, tax, or accounting advice nor make this service the primary basis for any
investment decisions made by or on behalf of you, your accountants, or your
managed or fiduciary accounts, and you may want to consult your business advisor,
attorney, and tax and accounting advisors concerning any contemplated
transactions.

Acceptable Use: You accept sole responsibility for all of your activities using the Web site.
You may not use the Web site in a manner that:
i. Uses technology or other means not authorized by us to access the Web site or our
systems;
ii. Uses or launches any manual or automated device or system, including “robots,”
“spiders,” or “offline readers,” to (a) retrieve, index, “scrape,” “data mine,” access or
otherwise gather any Web site information or our systems; (b) reproduce or circumvent the
navigational structure or presentation of the Web site; or (c) otherwise harvest or collect
information about users of the Web site;
iii. Reverse engineers, decompiles or disassembles any portion of the Web site, except
where such restriction is expressly prohibited by applicable law;
iv. Attempts to introduce viruses or any other computer code, files, or programs that
interrupts, destroys, or limits the functionality of any computer software, hardware, or
telecommunications equipment;
v. Attempts to gain unauthorized access to our computer network or user accounts;
vi. Encourages conduct that would constitute a criminal offense or that gives rise to civil
liability;
vii. Harasses, abuses, stalks, threatens, defames, or otherwise infringes or violates the rights
of us or any other party (including rights of publicity or other proprietary rights);
viii. Is unlawful, fraudulent, or deceptive;
ix. Attempts to damage, disable, overburden, or impair our servers or networks;
x. Reproduces, modifies, adapts, translates, creates derivative works of, sells, rents, leases,
loans, timeshare, distributes or otherwise exploits any portion of (or any use of) the Service
except as expressly authorized herein, without our express prior written consent;
xi. Fails to comply with applicable third-party terms; or
xii. Otherwise violates these Terms and Conditions of Use.

DMCA Notice - How to Provide Notice of Alleged Copyright Infringement:

a. You may not use the Web site for any purpose or in any manner that infringes the rights
of any third-party. In accordance with the Digital Millennium Copyright Act of 1998 (the
“DMCA“), we have a designated agent for receiving notices of alleged copyright
infringement and we follow the notice and take down procedures of the DMCA. We may
terminate your access to the Web site in the event of repeated violations.

b. If you believe one of our users is, through the use of the Web site, unlawfully infringing
the copyright(s) in your work, and wish to have the allegedly infringing material removed,
the following information in the form of a written notification (pursuant to the DMCA) must
be provided to our designated copyright agent: (i) a physical or electronic signature of a
person authorized to act on behalf of the owner of an exclusive right that is allegedly
infringed; (ii) identification of the copyrighted work claimed to have been infringed, or, if
multiple copyrighted works on the Web site are covered by a single notification, a
representative list of such works on the Web site; (iii) identification of the material that is
claimed to be infringing or to be the subject of infringing activity and that is to be removed
or access to which is to be disabled; (iv) information reasonably sufficient to permit us to
locate such material; (v) information reasonably sufficient to permit us to contact you, such
as your address, phone number, and email address; (vi) a statement that you have a good
faith belief that use of the material in the manner complained of is not authorized by the
copyright owner, its agent, or the law; and (vii) a statement that the information in the
notification is accurate, and under penalty of perjury, that you are authorized to act on
behalf of the copyright owner.

c. It is often difficult to determine if your intellectual property rights have been violated.
ZEPHYR ADVISORY GROUP may request additional information before we remove any
allegedly infringing material. Please note that, pursuant to 17 U.S.C. § 512(f), any
misrepresentation of material fact (falsities) in a written notification automatically subjects
the complaining party to liability for any damages, costs and attorney’s fees incurred by us
in connection with the written notification and allegation of copyright infringement. ZEPHYR
ADVISORY GROUP may request additional information before we remove any allegedly
infringing material. Please direct copyright infringement notifications to our law firm(s).
No representations made as to other sites or links: This service may provide links to
certain Internet sites (the “Sites”) sponsored and maintained by third parties. ZEPHYR
ADVISORY GROUP is providing such links solely as a convenience to you. Accordingly,
ZEPHYR ADVISORY GROUP makes no representations concerning the content of the Sites.
The fact that ZEPHYR ADVISORY GROUP has provided a link to the Site does not constitute
an endorsement, authorization, sponsorship, or affiliation by ZEPHYR ADVISORY GROUP with
respect to the Site, its owners, or its providers. ZEPHYR ADVISORY GROUP has not tested
any information, software, or products found on any of the Sites and therefore does not
make any representations with respect thereto, including any representations regarding the
content or sponsors of the Site, or the suitability or appropriateness of the products or
transactions described therein.

New York City Residents: Zephyr Advisory Group conducts its management consulting
and advisory professional services businesses in English and does not provide translation or
language assistance services in any other language. The New York City Department of

Consumer Affairs provides a translation and description of commonly-used debt collection
terms in multiple languages on its website www.nyc.gov/dca.

Colorado Residents: Zephyr Advisory Group conducts its management consulting and
advisory professional services businesses in English and does not provide translation or
language assistance services in any other language. The State of Colorado Department of
Regulatory Agencies within the Consumer Protection Division provides information regarding
consumer rights and protections on its website https://dora.colorado.gov/consumer-
protection.