These disclosures apply to the alphaAI Capital website at alphaai.capital, the application at app.alphaai.capital, and any related services provided under the alphaAI brand (collectively, the “Platform”). The Platform is operated by alphaAI Capital Management LLC (“alphaAI Capital” or “alphaAI”). These disclosures do not apply to Portfolio Lab, which is governed by separate disclosures available at portfoliolab.ai. These disclosures are subject to change without notice; the effective date above reflects the most recent update.

1. Not Investment Advice

The information provided on the Platform is for general informational and educational purposes only and should not be construed as investment, tax, legal, or accounting advice. Nothing on the Platform constitutes a recommendation, offer, or solicitation to buy or sell any security, investment strategy, or advisory service. Any investment decision should be made based on your specific financial situation, objectives, and risk tolerance, and in consultation with qualified professionals. Communications you receive from alphaAI Capital, including communications about the Platform or particular strategies, do not become individualized investment advice unless and until you are an advisory client of alphaAI Capital with an executed Investment Advisory Agreement in place.

2. Regulatory Status

Advisory services are provided by alphaAI Capital Management LLC, an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”). SEC registration does not imply a particular level of skill or training and does not constitute an endorsement of the firm by the Commission.

You may verify alphaAI Capital’s registration and review its Form ADV filings on the SEC’s Investment Adviser Public Disclosure (IAPD) website at adviserinfo.sec.gov. alphaAI Capital’s advisory services are available only to residents of the United States and only in jurisdictions where alphaAI Capital is registered or otherwise authorized to provide advisory services.

3. AI and Algorithmic Investment Process

alphaAI Capital uses artificial intelligence and machine-learning models as part of a systematic, rules-based investment process. The AI analyzes a range of inputs, including fundamental, technical, macroeconomic, and alternative data, to generate signals that inform portfolio decisions. Those decisions are implemented through predefined rules for allocation, trading, and risk management, within limits aligned to each client’s stated investment profile and risk tolerance.

The terms “AI” and “machine learning” describe a class of statistical models trained on historical data. References on the Platform to specific numbers of models, datasets, or years of training history reflect the configuration of our system at the time of publication and may change as our systems evolve. We may add, retrain, retire, or replace models from time to time without notice.

The use of AI does not eliminate investment risk and does not guarantee any particular outcome. In particular:

• Models are trained on historical data and may not perform as expected in market conditions outside of the data on which they were trained
• Models can produce inaccurate signals, fail to recognize material changes in market regimes, or be affected by errors or limitations in input data, code, or underlying assumptions
• Adaptive portfolio management responds to changing conditions but may not avoid losses, may execute trades at unfavorable prices, and may produce losses from whipsaw if conditions reverse quickly after an adjustment
• Phrases such as “automated downside protection” describe a risk management approach. They are not guarantees of loss avoidance, and downside protection mechanisms may fail to engage, may engage at the wrong time, or may detract from returns in conditions where they were not needed

The system does not operate without oversight. alphaAI Capital, as an SEC-registered investment adviser, is responsible for the design, calibration, monitoring, and ongoing review of its AI-driven processes, and remains accountable for portfolio decisions made on behalf of clients under its fiduciary duties. AI is a tool used by alphaAI Capital; it is not a substitute for the firm’s professional judgment, fiduciary obligations, or compliance with applicable law.

Clients bear all investment risk associated with their accounts, including risks arising from AI-generated signals or the implementation of those signals.

4. No Duty to Update

Content on the Platform reflects alphaAI Capital’s views, methodologies, and current intentions as of the date of publication and is subject to change at any time without notice. alphaAI Capital has no obligation to update, revise, or correct any information on the Platform. Discussions of investment objectives, strategies, portfolio construction, risk management, asset allocation, constraints, or other characteristics are general in nature, represent internal guidelines only, and may be modified, suspended, or abandoned at any time based on market conditions, model updates, regulatory considerations, or other factors.

5. Forward-Looking Statements

The Platform may contain forward-looking statements, including statements regarding expected strategies, methodologies, risk management techniques, model behavior, or future market conditions. Such statements are based on current assumptions and expectations and are subject to significant risks and uncertainties. Forward-looking statements are not guarantees of future performance or outcomes, and actual results may differ materially from those expressed or implied. We undertake no obligation to update any forward-looking statement.

6. Performance Information

Any references to performance, returns, outcomes, or strategy characteristics on the Platform, whether explicit or implied, are provided for illustrative and informational purposes only. Past performance does not guarantee future results. No assurance can be given that any investment strategy will achieve its objectives or avoid losses.

Actual client results will vary based on the timing and amount of contributions, market conditions, strategy selection, advisory fees, brokerage costs, taxes, individual financial circumstances, and other factors. Advisory fees and other costs reduce returns. Net performance reflects the deduction of advisory fees and applicable expenses; gross performance does not. Where performance is presented, alphaAI Capital intends to present results in compliance with SEC Rule 206(4)-1 (the “Marketing Rule”), including the rule’s requirements regarding net performance, applicable time periods, and required disclosures.

Detailed performance information is made available within the logged-in environment of our application to account holders. This approach reflects alphaAI Capital’s policies designed to comply with the Marketing Rule’s requirements concerning the audience and disclosures applicable to performance information.

7. Hypothetical, Simulated, and Backtested Performance

Under the Marketing Rule, “hypothetical performance” includes performance results that were not actually achieved by any portfolio of alphaAI Capital. Hypothetical performance includes, without limitation, model performance, backtested performance (performance generated by applying a strategy to data from time periods when the strategy was not actually used), targeted returns, and projected returns.

Any hypothetical, simulated, backtested, projected, or example results referenced on the Platform are not representative of actual client performance and should not be relied upon as indicators of future results. Such examples are inherently limited and:

• Are prepared with the benefit of hindsight
• May rely on assumptions that may not hold in real-world market conditions
• Do not reflect the impact of all market factors, including liquidity constraints, transaction costs, slippage, taxes, and behavioral considerations
• May reflect strategy parameters, model versions, or asset universes that differ from those in current use

Actual results may differ materially and adversely from any hypothetical, simulated, backtested, projected, or example results. Where hypothetical performance is presented, alphaAI Capital provides additional information, including the criteria used and the assumptions made in calculating the hypothetical performance, in accordance with the Marketing Rule.

8. Testimonials and Endorsements

The Platform may include testimonials or endorsements from current or former clients. Where they appear, the following applies:

• Each testimonial reflects the individual experience and opinion of the person providing it at the time given and is not intended to represent any other client’s experience
• Testimonials are not representative of all clients, and past client experiences do not guarantee future results
• Clients providing testimonials were solicited by alphaAI Capital but were not compensated, directly or indirectly, for providing them, except as may be separately disclosed adjacent to the testimonial
• Where any material conflict of interest exists in connection with a testimonial or endorsement, including any compensation arrangement, it is disclosed adjacent to the testimonial as required by SEC Rule 206(4)-1

alphaAI Capital does not present testimonials in a manner intended to suggest performance results that any individual client should expect to achieve.

9. Third-Party Ratings and Logos

The Platform may display ratings, rankings, or awards issued by third parties (for example, ratings provided by users of third-party review platforms). Where any such rating is displayed, alphaAI Capital has not paid the third party for the rating itself unless otherwise disclosed adjacent to the rating. Ratings reflect the views of the third party or its users at the time the rating was given and may not be representative of any client’s experience with alphaAI Capital. Ratings on third-party platforms may be based on self-selected user samples and may not be statistically representative.

The Platform may also display logos of companies or organizations where individual alphaAI Capital clients work or have worked (for example, on a “Chosen by employees at” section). Such logos identify employers of individual clients only. Their display does not imply that the named company endorses, sponsors, recommends, or is otherwise affiliated with alphaAI Capital, and does not imply any commercial relationship between alphaAI Capital and the company.

10. Investment Risk

All investing involves risk, including the possible loss of principal. No investment strategy, asset allocation, risk management technique, or technology, including any AI or algorithmic process, can guarantee profits or protect against losses in all market conditions. You should carefully consider whether the Platform and any strategy available through it are suitable for you in light of your financial circumstances, investment objectives, risk tolerance, and time horizon.

11. Risks by Asset Type

Depending on the strategy you select or configure, your portfolio may hold standard exchange-traded funds (ETFs), leveraged or inverse ETFs, exchange-traded cryptocurrency products, individual equity securities, or cash. The specific composition of your portfolio depends on the strategy in effect on your account at any given time. Each type of instrument carries distinct risks:

• Standard ETFs: market risk corresponding to the index or basket they track, tracking error, and fund-level expenses that reduce return
• Leveraged and inverse ETFs: these products use derivatives and daily rebalancing to deliver a multiple or inverse of an index’s daily performance. Due to compounding effects, returns over periods longer than one day may diverge significantly, and in some cases dramatically, from the multiple or inverse of the underlying index’s return over the same period. These products are designed for short-term trading and are generally not suitable for buy-and-hold investors. Losses can be magnified, including in volatile or sideways markets
• Exchange-traded cryptocurrency products: cryptocurrency markets are highly volatile and subject to rapid and substantial price swings. Cryptocurrency products are also subject to evolving regulatory treatment, custody risk, and risks specific to the underlying cryptocurrency and the structure of the product
• Individual equity securities: single-issuer risk (the value of the security depends on the performance and circumstances of a single company), liquidity risk, and concentration risk
• Cash and cash equivalents: holdings may earn limited or no interest and are subject to inflation risk

12. Adaptive and Hedged Strategy Risks

alphaAI Capital’s strategies are designed to adjust portfolio exposure in response to changing market conditions. Strategies that incorporate hedging or other risk management techniques carry additional risks:

• Hedges may not offset losses fully or at all (basis risk), may incur ongoing costs that reduce returns, and may produce whipsaw losses if markets reverse quickly after a hedge is applied or removed
• Adaptive strategies may execute trades during periods of elevated volatility, when prices may be less favorable, and may underperform static strategies in certain market environments
• Strategies based on publicly disclosed third-party information are subject to latency between the underlying event and the disclosure, between the disclosure and our ingestion of the information, and between our ingestion and execution. Executions based on these signals may occur at less favorable prices than those available at the time of the original underlying event

13. Tax Information

alphaAI Capital is not a certified public accountant or tax adviser, and nothing on the Platform constitutes tax advice. Tax treatment of investments and strategies depends on individual circumstances, including your jurisdiction, filing status, and other personal factors, and is subject to change.

Strategies that incorporate tax considerations, including any strategy that uses tax-loss harvesting, do not guarantee any specific tax outcome. Tax-loss harvesting is subject to the wash sale rules under Section 1091 of the Internal Revenue Code and related guidance, which may disallow losses in certain circumstances. The actual tax benefits of any such strategy depend on your individual circumstances, including your other investment activity inside and outside of alphaAI Capital, your marginal tax rates, the holding period of relevant positions, and changes in tax law. You should consult your own tax professional before making any investment decision.

14. Brokerage, Custody, and SIPC

Brokerage services for alphaAI Capital clients are provided by Alpaca Securities LLC (“Alpaca”), a registered broker-dealer and member of the Financial Industry Regulatory Authority (FINRA) and the Securities Investor Protection Corporation (SIPC). Alpaca, not alphaAI Capital, custodies client assets and is responsible for the execution, clearing, and custody of securities transactions on behalf of clients. alphaAI Capital does not take physical custody of client cash or securities.

SIPC protects securities customers of its members up to applicable limits in the event of broker-dealer failure. SIPC does NOT protect against market losses, declines in the value of investments, or losses arising from poor investment decisions or strategy performance. Cryptocurrency products and certain other holdings may not be eligible for SIPC protection. Information about SIPC, including coverage limits and exclusions, is available at sipc.org.

Brokerage accounts are NOT bank accounts and are NOT insured by the Federal Deposit Insurance Corporation (FDIC). Cash held in a brokerage account is not equivalent to a bank deposit.

You may review the background of Alpaca on FINRA’s BrokerCheck at brokercheck.finra.org.

15. Third-Party Sources and Links

Certain information on the Platform may be derived from third-party sources believed to be reliable. alphaAI Capital does not guarantee the accuracy, completeness, or timeliness of any such information. Any links to third-party websites are provided for convenience only and do not constitute an endorsement of the content, products, or services offered by those third parties. alphaAI Capital is not responsible for the content of third-party websites or for any losses arising from your use of them.

16. Suitability

Not all strategies available through the Platform are suitable for all investors. Strategies that use leveraged or inverse instruments, cryptocurrency products, or active hedging carry elevated risks and may not be appropriate for investors with limited investment experience, short time horizons, low risk tolerance, or limited financial resources. You should consider your investment objectives, risk tolerance, time horizon, liquidity needs, and overall financial circumstances before selecting a strategy and before investing through the Platform.

17. Business Continuity

alphaAI Capital maintains a business continuity program designed to address operational disruptions. Because client assets are held at Alpaca and not at alphaAI Capital, in the event of a disruption affecting alphaAI Capital, client assets generally remain at Alpaca and clients retain access to their accounts through Alpaca, subject to Alpaca’s own policies and procedures. Advisory services provided by alphaAI Capital may be interrupted, modified, or suspended in connection with such events. Additional information about our business continuity program is available on request.

18. Form ADV, Verification, and Contact

alphaAI Capital’s Form ADV Part 2A brochure and Form CRS contain important additional information about the firm, including its services, fees, conflicts of interest, disciplinary information, and other matters. Clients and prospective clients should review these documents carefully. They are available at alphaai.capital/legal and at adviserinfo.sec.gov.

To verify alphaAI Capital’s registration or review its filings, visit adviserinfo.sec.gov. To verify the registration of Alpaca Securities LLC, visit brokercheck.finra.org.

If you have questions about these disclosures, contact us at:

alphaAI Capital Management LLC

Email: support@alphaai.capital

Web: https://www.alphaai.capital

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