Disclosure and Terms Of Use

Harpswell Capital Advisors, LLC is an SEC registered investment adviser located in New Gloucester, Maine. Harpswell Capital Advisors may only transact business in those states in which it is registered, or qualifies for an exemption or exclusion from registration requirements. Harpswell Capital Advisors’ web site is limited to the dissemination of general information pertaining to its advisory services. Accordingly, the publication of Harpswell Capital Advisors’ web site on the Internet should not be construed by any consumer and/or prospective client as Harpswell Capital Advisors solicitation for the rendering of personalized investment advice or to effect, or attempt to effect, transactions in securities.

Harpswell Capital Advisors may include links to third-party websites on this website. Harpswell Capital Advisors does not endorse or adopt the content contained on any third-party website link. Harpswell Capital Advisors does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any unaffiliated third party, whether linked to this website or incorporated herein.

Certain portions of Harpswell Capital Advisor’s web site (i.e., newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, Harpswell Capital Advisor (and those of other investment and non-investment professionals) positions and/or recommendations as of a specific prior date. Due to various factors, including changing market conditions, such discussion may no longer be reflective of current position(s) and/or recommendation(s). Views regarding the economy, securities markets or other specialized areas, like all predictors of future events, cannot be guaranteed to be accurate and may result in economic loss to the investor. Moreover, no client or prospective client should assume that any such discussion serves as the receipt of, or a substitute for, personalized advice from Harpswell Capital Advisors or from any other investment professional. Harpswell Capital Advisors is neither an attorney nor an accountant, and no portion of the web site content should be interpreted as legal, accounting or tax advice. Any information regarding historical market performance is for illustrative and education purposes only. Clients or prospective clients should not assume that their performance will equal or exceed historical market results and/or averages. Information in this website is for informational purposes only and does not attempt to address the financial objectives, situation or specific needs of any investor, nor is it intended to serve as investment advice since the availability and effectiveness of any strategy is dependent upon your individual facts and circumstances. Results will vary and no suggestion is made about how any specific solution or strategy performed in reality. Past performance is not indicative of any specific investment or future results.

This website may include forward-looking statements. All statements other than statements of historical fact are forward-looking statements and we can give no assurance that such expectations will prove to be correct. Various factors could cause actual results or performance to differ materially from those discussed in such forward-looking statements.

This website is owned by Harpswell Capital Advisors and any and all accompanying screens, information, materials, user documentation, user interfaces, images, arrangement of information, related software and other proprietary property of Harpswell Capital Advisors or its licensors accessible via the website is and shall remain the exclusive property of Harpswell Capital Advisors and its licensors. This site is for your personal and non-commercial use. You many not modify, copy, distribute, transmit, display, perform, reproduce, publish, license, create derivative works from, transfer or sell any information, products or services obtained from this site.

Registration with the SEC does not imply a certain level of skill or training. Additional information about Harpswell Capital Advisors is available at the SEC’s website.

HARPSWELL CAPITAL ADVISORS, LLC NOTIFICATION OF PRIVACY POLICIES AND PRACTICES

Source: Harpswell Capital Advisors Compliance Manual, Exhibit D (Revised February 2020)

HARPSWELL’S COMMITMENT TO YOU

Maintaining the confidentiality of the personal information of our clients, and our visitors; it is one of our highest priorities. As fiduciaries, we have a duty to exercise the utmost care with our client’s information and all employees are bound by the policies and procedures regarding confidential information in our Compliance Manual. We are committed to safeguarding the use of the personal information you have entrusted to us and have established procedures to protect its security and confidentiality. Harpswell does not sell your personal information to anyone. Nor do we provide such information to others except for proper business purposes in connection with the management or servicing of our relationship with you, as discussed below.

Federal law requires us to tell you how we collect, share and protect your personal information. Federal law also gives consumers the right to limit some but not all sharing of personal information. This notice sets forth the type of personal information we collect, how that information is used by us, and how we protect your personal information.

COLLECTION OF PERSONAL INFORMATION

Personal information may be collected from you in order to provide you with products or services, process transactions on your behalf, and comply with legal and regulatory requirements. Information may be collected from any of the following sources:

From you: We collect information from you when you request information or services or enter into an investment management agreement with us. We may also collect information from investor questionnaires, W-9’s and other applications or forms that you complete when requesting information or services from us. This information may include items such as your name, address, e-mail address, social security number, birth date, annual income, net worth, marital status, investment goals and investment risk tolerance. If you indicate you have a spouse or partner, his/her personal and financial account information may also be requested.
From transactions: If you obtain advice or services from us, we keep records of the advice or service provided. We also keep records relating to items such as your account balance, payment history, securities positions and securities purchases and sales. This enables us to provide you with a history of your transactions with us and service your account.
From our website: If you visit our website, we may use a so-called “cookie” to track the amount of time you spend on our site, the parts of our site you visited and other technical information. We use this information to improve the functionality of our website.

HOW DO WE SHARE YOUR INFORMATION AND WHY?

As an investment advisor, we share client information only in order to implement our services. We do not (nor do we intend to) sell or distribute personal information about current or former clients to third parties except as set forth below. Federal law gives consumers the right to limit some but not all sharing. In the table below, we list some reasons we may share your personal information.

Servicing our clients/everyday business purposes

Harpswell may share non-public personal information with unaffiliated third parties (such as custodians, brokers, regulators, attorneys, accountants, and other financial institutions) in order to provide agreed upon services to you, consistent with applicable law, including, but not limited to, processing transactions and general account maintenance. We will also reveal or share your personal information where the law requires it, such as for tax reporting purposes or to comply with legal and regulatory requirements.

Marketing purposes

Harpswell does not disclose and does not intend to disclose your personal information to third parties to offer you services or sell you products. We will only share your information for purposes of servicing your accounts, not for marketing purposes.

Authorized users

Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s).

Information about former clients

Harpswell does not disclose and does not intend to disclose non-public personal information to third parties for former clients.

PROTECTION OF YOUR PERSONAL INFORMATION

Our employees may, from time to time, have access to your personal information in order to provide services to you. We restrict access to personal financial information to those employees who need to know that information in order to provide you with investment services. All employees are subject to the terms of our company’s policies requiring employees to treat confidentially all information obtained from or about you or your account. Employees are also trained on their responsibilities to protect client information. We also maintain physical, electronic and procedural safeguards designed to protect nonpublic personal financial information. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors and any third parties that assist in

providing our services to you are required to protect the personal information they receive from us or directly from you.

CHANGES TO OUR PRIVACY POLICY

We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. If we revise our Policy, we will provide you with a revised copy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to opt out.

ANY QUESTIONS?