Disclosures

1. Performance Disclosure

Past performance is not indicative of future results.

All performance data presented on our website, in our marketing materials, and through our services reflects historical results from a verified live trading account. These results are provided for informational purposes only and do not constitute a guarantee, projection, or promise of future performance.

Individual results will vary based on factors including but not limited to account size, timing of enrollment, market conditions at the time of trading, and the duration of software use. Results shown may reflect some of our top-performing accounts and should not be considered representative of typical investor outcomes.

2. Nature of Services

We are a software and technology company. We provide access to an automated algorithmic trading system — the Orion Equities Algorithm — that executes trades within your own U.S. regulated brokerage account.

We do not:

• Guarantee specific trading results, returns, or capital preservation
• Manage, pool, or custody client funds at any time
• Provide personalized investment advice tailored to your individual circumstances
• Act as a broker-dealer or asset manager
• Act as a registered investment advisor

We do not represent that any account will or is likely to achieve results similar to those presented in our performance materials. All performance examples, account reports, and figures shown are for illustrative purposes only.

3. Not Investment Advice

Nothing on our website, in our communications, or through our services constitutes investment advice, financial planning advice, tax advice, or legal counsel. No content we produce should be construed as an offer to sell securities, a solicitation to buy securities, or a recommendation of any specific investment, security, or strategy.

You are solely responsible for evaluating whether our services are appropriate for your financial situation, investment objectives, level of experience, and risk tolerance. We strongly encourage you to consult a qualified registered investment advisor, attorney, or tax professional before allocating any capital.

The purchase, sale, or advice regarding securities can only be performed by persons registered with the SEC, FINRA, or applicable state regulators. We and our affiliates are not registered intermediaries of any kind.

4. Investment Risk Warning

Trading equities involves substantial risk and may not be suitable for all investors. You should carefully consider the following before using our services:

• No trading system operates profitably on every trade or in every market environment
• Algorithmic systems can experience technical failures, connectivity issues, or periods of underperformance
• Market conditions can change rapidly and without warning
• Past performance of any trading system or algorithm does not guarantee future results
• You may lose some or all of your invested capital

Do not allocate capital you cannot afford to lose.

5. U.S. Equities — Long-Only Strategy

The Orion algorithm trades U.S.-listed equities only, on a long-only basis. The strategy does not use leverage, does not engage in short selling, and does not trade options, futures, forex, or any other derivative instruments.

Unlike forex or futures trading — which involves significant leverage, margin requirements, and can result in losses exceeding initial investment — Orion's risk architecture is designed to limit maximum loss per trade to 2% of account equity. This does not eliminate risk. It is a risk management framework, not a guarantee against loss.

6. Hypothetical & Simulated Performance

Certain performance figures, backtests, configurations, or illustrations we present may include hypothetical or simulated results. In accordance with CFTC Rule 4.41(b)(1) and NFA Rule 2-29, the following applies to any hypothetical or simulated performance:

HYPOTHETICAL PERFORMANCE RESULTS HAVE INHERENT LIMITATIONS AND DO NOT REPRESENT ACTUAL TRADING.

Specifically:

• There are frequently sharp differences between hypothetical results and actual results subsequently achieved
• They cannot fully account for a trader's ability to withstand losses or adhere to a strategy during adverse conditions
• They may not account for spreads, commissions, slippage, or liquidity constraints
• They do not reflect the impact of actual financial risk
• Hypothetical results are prepared with the benefit of hindsight

No representation is made that any account will or is likely to achieve profits or losses similar to those shown in any hypothetical performance example.

7. Live Account Performance

Where performance data is presented as live account results — including data sourced from independent third-party verification and Interactive Brokers — the following applies:

• Live results from one account are not necessarily representative of results achievable in all accounts
• Returns may vary depending on the timing of account enrollment, starting capital, and individual account configuration
• Results do not account for all fees, commissions, or tax obligations that may apply to individual investors
• All trades, timestamps, and fills are real and verifiable via independent third-party verification
• Results reflect actual trades executed in a live brokerage account

8. Third-Party Verification

We use an independent third-party platform to track and display live account performance. This platform is not affiliated with us. The performance data is pulled directly from the connected Interactive Brokers account and is presented without modification.

Visitors are encouraged to verify all performance data independently.

9. Capacity & Access Limitations

We limit total capital under the Orion algorithm to a maximum of $50,000,000. This limitation exists to preserve the integrity of the strategy's institutional signal detection edge. When this capacity is reached, access to new investors will be closed. We make no representation regarding current capacity availability.

10. No Endorsement

Reference to Interactive Brokers or any other third-party platform does not constitute an endorsement of us by those entities. We are independently operated and have no formal affiliation with Interactive Brokers Group beyond standard API and platform integrations.

11. Regulatory Notice

We are a software company. We are not registered with the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), the Financial Industry Regulatory Authority (FINRA), the National Futures Association (NFA), or any state securities regulator as an investment advisor, broker-dealer, commodity trading advisor, or commodity pool operator.

Users of our services are encouraged to consult with a registered financial professional for personalized investment advice.

12. Testimonials & Client Results

Testimonials and client statements presented on our website reflect the individual experiences of specific investors and may not be representative of the experience of all clients. Individual results will vary. Testimonials are not a guarantee of future performance or success.

13. Intellectual Property

All content on our website — including performance data, strategy documentation, algorithm methodology descriptions, marketing materials, and branding — is our proprietary intellectual property and is protected by applicable copyright and trademark law. Reproduction, distribution, or use of any of our content without prior written consent is strictly prohibited.

14. Contact

For questions regarding these disclosures or our services:

Email: support@gemalgo.com
Website: gemalgo.com