Disclosures

Past performance is not indicative of future results.

All performance data presented on gemalgo.com, 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.

GemAlgo LLC is 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.

GemAlgo does not:

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

GemAlgo does 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.

Nothing on our website, in our communications, or through our services constitutes investment advice, financial planning advice, tax advice, or legal counsel. No content produced by GemAlgo 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 GemAlgo's 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. GemAlgo and its affiliates are not registered intermediaries of any kind.

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

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

Do not allocate capital you cannot afford to lose.

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.

Certain performance figures, backtests, configurations, or illustrations presented by GemAlgo 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:

Specifically:

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

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.

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

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

GemAlgo uses an independent third-party platform to track and display live account performance. This platform is not affiliated with GemAlgo. 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.

GemAlgo limits 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. GemAlgo makes no representation regarding current capacity availability.

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

GemAlgo LLC is 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 GemAlgo's services are encouraged to consult with a registered financial professional for personalized investment advice.

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.

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

For questions regarding these disclosures or our services: