This Privacy Notice sets forth the policy of Horizon Asset Management LLC, Kinetics Asset Management LLC and Kinetics Advisers, LLC (collectively referred to as, “Horizon Kinetics”), affiliated companies that are wholly owned by Horizon Kinetics LLC with respect to non-public personal information of current, prospective and former clients (“Clients”). This policy may be changed with or without notice.

From time to time, Horizon Kinetics collects non-public information from you including:

i. information we receive from you on applications or other forms, correspondence or conversations, including, but not limited to, your name, address, phone number, social security number, assets, income and date of birth; and

ii. information about your transactions with us, our affiliates, or others, including, but not limited to, your account number and balance, payments history, parties to transactions, cost basis information, and other financial information.

Horizon Kinetics does not disclose any of non-public personal information about our Clients to non-affiliated third parties, except as permitted by law or as is necessary to service your account. For example, Horizon Kinetics is permitted by law to disclose all of the information we collect, as described above, to our attorneys, auditors, brokers/banks (custodians) and regulators and certain service providers, in such case, only as is appropriate or necessary to provide Client support or facilitate the management of Client investments. Thus, it may be necessary, under anti-money laundering and similar laws, to disclose information about Clients in order to accept assets from them. Horizon Kinetics will also release Client information if directed to do so by a Client, if compelled to do so by law or in connection with any government or self-regulatory organization request or investigation.

Horizon Kinetics seeks to carefully safeguard Client information and, to that end, restricts access to non-public personal information about our Clients to those employees and other persons who need to know the information to enable Horizon Kinetics to provide services to its Clients. Horizon Kinetics and our service agents maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your non-public personal information. In the event that you maintain an account through a financial intermediary, including, but not limited to, a broker-dealer, bank, or trust company, the privacy policy of your financial intermediary would govern how your non-public personal information would be shared with nonaffiliated third parties.

If you have any questions about this Privacy Policy, you may contact Horizon Kinetics at or (646) 291-2300.