Once you choose a system, you need to stick with it ... Warren Buffett, Legendary Investor

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1. Terms and Conditions of Service (TCS). Graycell Advisors (together with its affiliates and employees referred to herein as “GA” or "we" or "us") is a publisher of financial and investment commentary and opinions, including, but not limited to subscription-based newsletters, like the Prudent Biotech and Graycell Small Cap newsletters, along with any related publications (“Newsletter”, "Report", "Publication", "Subscription", "Service"). The Newsletter presents companies that comprise our model portfolio. Please carefully read the Terms and Conditions of Service (“TCS”) set forth below. As a condition of using the website and subscription, you agree to the TCS.

By using the Service, you affirm that you are at least 18 years of age and are not otherwise barred from receiving and using the newsletter under the laws of the United States or other applicable jurisdiction. You also affirm that you are able and competent to enter into this Agreement and to abide by and comply with the TCS. In addition, you will not use the content on the website or our name and server to violate any US or international laws, including copyright and spamming.

2. Responsibility. You alone are responsible for your own investment decisions. The information contained herein does not constitute a personal recommendation or takes into account the particular investment objectives, financial situations, or needs of individual investors. Subscribers and investors should always conduct their own due diligence with any potential investment. You should independently verify all information contained in the Newsletter, and on our website(s), and consider obtaining professional advice before making any investment decision.

3. Risk. All stock investments carry a degree of risk. By investing in any of the stocks of the companies profiled or mentioned in the Newsletter, etc., you can and may lose some or all your investment. Do not invest in any stock if you are not prepared to lose your entire investment. We are not liable, nor do we assume any responsibility for losses incurred because of any information provided or not provided or not made available on time, herein or on our website, or through any other medium. In addition, we do not guarantee the accuracy and completeness of any information furnished by us. Even following all our suggestions will not assure positive results.

4. Volatility. Stocks are volatile. Some segments, like biotech and small cap, are even more volatile due to the nature of the industry and the market segment. Significant monthly volatility should be expected based on market conditions. In the case of an industry-specific newsletter, like biotech, there is a significant additional risk from one-industry exposure, as would be true for any industry-focused portfolio or fund. A concentrated portfolio of 8-or-10 holdings will have greater up-and-down volatility than the same industry fund or an industry index, like the Nasdaq Biotechnology Index or the small cap Russell 2000 index, with many more holdings running into hundreds and even thousands of stocks.

5. Performance. Past performance is no guarantee of future success, and you should not assume that the performance of our model portfolio in the future will meet or exceed the model's historical performance. Historical performance figures and analysis provided are hypothetical, unaudited, and prepared by us. Performance before the launch of the product was backtested. No actual trades have taken place. The performance results obtained are intended for illustrative purposes only, and although we believe the results to be accurate, we cannot guarantee it and they have not been independently verified.

6. Non-Advisor. We are not a registered investment advisor, also known as RIA, and nothing contained in any materials should be construed as a recommendation to buy or sell securities.

7. Member Portfolio Results. Actual performance results achieved by members will differ by some measure from results reported for the portfolio for various reasons, including, without limitation:
• model portfolio performance results do not reflect trading commissions and exchange fees
• model portfolio performance results do not account for the impact, if any, of certain market factors, such as lack of liquidity, to initiate or close positions, that may affect results
• model portfolio positions are opened and closed at the opening prices on the first trading day after the publication of the newsletter. Such prices may not be available, and could be better or worse, at the time trades are placed by members
• model portfolio prices are recorded at the beginning of the month while members may join at any time during the month, at which time prices may be different - higher or lower

8. Existing Positions. We may or may not have existing positions in the stocks mentioned in the newsletter before the dissemination of the newsletter. We do not favor any subscriber of a product, and a bulk alert is sent to all subscribers via email once the newsletter is available in the Members Area.

9. Models. Our models are proprietary and/or licensed. We can change the models at any time without any notification. The historical performance will change anytime a revision occurs. We also have dedicated products that can be used by professional investors and institutions and that can leverage the same models.

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17. No-risk Subscription Offer. The offer to refund your subscription within a specific period cannot be used again within 6 months from the date of the Refund. After your first Sign Up, if you decide to cancel and receive a refund, you may NOT Sign Up again within the 6-month duration and expect the same refund period offer. Instead, you can still Sign Up, but the new subscription will not be covered by the refund offer and you cannot request a refund.

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19. Your Right of Cancellation. You may choose to cancel at any point. If your cancellation request is within the money-back guarantee period, you shall receive a full refund of the paid amount. If the request falls after the money-back guarantee period, you will not be refunded any amount and will lose your membership access. In such a situation, a better alternative for you can be to let the subscription expire at the end of the period and not renew while retaining your access to the remaining subscription period.

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Graycell Advisors, and its affiliates, officers, employees, families, and all other related parties, collectively referred to as ‘Graycell’ and/or ‘we,’ is a publisher of financial information, such as the Smallcap, and Prudent Biotech newsletters. We are not a Registered Investment Advisor (RIA). Historical performance figures provided are hypothetical and unaudited, and based on our proprietary analysis and system performance, back-tested over an extended period of time. Hypothetical or simulated performance results have limitations, and unlike an actual performance record, simulated results do not represent actual trading and consequently do not involve financial risk of actual trading. The performance results obtained are intended for illustrative purposes only. No representation is being made that an account will or is likely to achieve profit or losses similar to those shown. Past performance is not indicative of future results, which may vary. All stock and related investments have a degree of risk, which can result in a significant or total loss. In addition, biotech sector and smallcaps are characterized by much higher risk and volatility than the general stock market. Information contained herein is general and does not constitute a personal recommendation or takes into account the particular investment objectives, financial situations, or needs of individual investors. If you decide to invest in any of the stocks of the companies mentioned in the newsletters, samples, alerts, etc., sent to you or available on our websites, you can and may lose some or all of your investment. You alone are responsible for your investment decisions. Use of the information herein is at one's own risk. We are simply sharing the results of our model. Nothing should be construed as a recommendation or an offer to buy or sell any securities, and we are not liable nor do we assume any liability or responsibility for losses incurred as a result of any information provided or not provided or not made available in a timely manner, herein or on our website or using any other medium. We cannot guarantee the accuracy and completeness of any information furnished by us. We may or may not have existing positions in the stocks mentioned in our reports. Our models are proprietary and/or licensed, and can be changed or revised based on our discretion at any time without any notification. Subscribers and investors should always conduct their own due diligence with any potential investment, and consider obtaining professional advice before making an investment decision.
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