Rallies.ai Comprehensive Platform Disclosures

Prepared for Blotter Inc. d/b/a Rallies.ai

Effective Date: [INSERT DATE]

Last Updated: March 10, 2026

IMPORTANT: PLEASE READ THIS ENTIRE DOCUMENT CAREFULLY BEFORE USING THE RALLIES.AI PLATFORM, MOBILE APPLICATION, WEBSITE, NEWSLETTER, DISCORD BOT, OR ANY ASSOCIATED SERVICES. THIS DOCUMENT CONTAINS IMPORTANT DISCLOSURES ABOUT THE NATURE OF OUR SERVICES, YOUR RIGHTS, AND THE RISKS ASSOCIATED WITH USING OUR PLATFORM. BY ACCESSING OR USING ANY RALLIES.AI SERVICE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE DISCLOSURES.

SECTION 1: ENTITY IDENTIFICATION AND REGULATORY STATUS

1.1 Corporate Entity Information

Legal Entity: Blotter Inc., a Delaware corporation

Doing Business As: Rallies.ai

Business Address: 22361 SE 43rd Pl, Issaquah, WA 98029

State of Incorporation: Delaware

Contact Email: legal@rallies.ai

Support Email: support@rallies.ai

Privacy Email: privacy@rallies.ai

1.2 Ownership Structure and Affiliated Entities

IMPORTANT: THE FOLLOWING OWNERSHIP AND AFFILIATION DISCLOSURES ARE PROVIDED FOR FULL TRANSPARENCY REGARDING ALL ENTITIES INVOLVED IN THE OPERATION OF RALLIES.AI AND RELATED SERVICES.

Parent Holding Entity: Wolf Technologies LLC

Wolf Technologies LLC is a separate limited liability company that holds ownership interests in Blotter Inc. (d/b/a Rallies.ai). Wolf Technologies LLC is owned by the founding members of the Rallies.ai platform.

Affiliated Marketing Entity: WOLF Financial, LLC

WOLF Financial, LLC is a separate limited liability company that operates digital marketing, content creation, and social media services in the financial media space. The relationship between WOLF Financial, LLC and Rallies.ai is as follows:

• WOLF Financial, LLC and Blotter Inc. (d/b/a Rallies.ai) share common ownership through Wolf Technologies LLC. The same founding members have ownership interests in both entities.
• WOLF Financial, LLC provides marketing, content creation, and audience development services that may promote or reference Rallies.ai.
• WOLF Financial, LLC does NOT exercise editorial control over Rallies.ai platform features, AI-generated content, data displays, or investment-related information.
• WOLF Financial, LLC may operate as a "publisher" or "pilot" on third-party platforms (including but not limited to AutoPilot) where it may manage or promote investment portfolios, content strategies, or trading-related activities.
• Users should be aware that the common ownership between WOLF Financial, LLC and Rallies.ai creates a material conflict of interest. Activities conducted by WOLF Financial, LLC in the investment or trading space may affect the perceived independence of Rallies.ai content and services.
• WOLF Financial, LLC's activities on third-party investment platforms are separate from and not controlled by Rallies.ai. However, the overlapping ownership and personnel between these entities means that individuals involved in WOLF Financial's trading or investment-related activities may also be involved in Rallies.ai operations.
• Rallies.ai maintains separate corporate governance, financial accounts, operational decision-making processes, and business records from WOLF Financial, LLC, notwithstanding common ownership through Wolf Technologies LLC. Each entity operates as a distinct business with its own management responsibilities, revenue streams, and regulatory obligations.

1.3 Regulatory Status Disclosures

IMPORTANT: RALLIES.AI IS NOT A REGISTERED INVESTMENT ADVISER (RIA), BROKER-DEALER, FINANCIAL PLANNER, FIDUCIARY, OR FINANCIAL INSTITUTION OF ANY KIND. RALLIES.AI HAS NOT FILED FORM ADV, FORM CRS, OR ANY REGISTRATION DOCUMENT WITH THE SEC, FINRA, CFTC, NFA, OR ANY STATE SECURITIES REGULATOR.

Blotter Inc. (d/b/a Rallies.ai) makes the following affirmative regulatory disclosures:

• Rallies.ai is NOT registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC) under the Investment Advisers Act of 1940, nor with any state securities regulator.
• Rallies.ai is NOT registered as a broker-dealer with the SEC or the Financial Industry Regulatory Authority (FINRA).
• Rallies.ai is NOT registered as a commodity trading advisor (CTA), commodity pool operator (CPO), or introducing broker with the Commodity Futures Trading Commission (CFTC) or the National Futures Association (NFA).
• Rallies.ai is NOT registered as a money services business (MSB) with the Financial Crimes Enforcement Network (FinCEN).
• Rallies.ai is NOT a bank, credit union, or any type of depository institution regulated by the OCC, FDIC, NCUA, or any state banking regulator.
• Rallies.ai does NOT act as a fiduciary to any user under any federal or state law.
• Rallies.ai does NOT hold, transmit, custody, or control any user funds, securities, cryptocurrencies, or other financial assets.
• Rallies.ai does NOT execute, facilitate, route, or process any securities transactions, trades, or orders on behalf of any user.
• No employee, contractor, affiliate, or agent of Rallies.ai holds any securities license, Series 65, Series 66, Series 7, or equivalent registration in connection with Rallies.ai services.
• Rallies.ai has NOT applied for or received any exemptive relief, no-action letter, or interpretive guidance from the SEC, FINRA, CFTC, or any regulatory body.

1.4 Publisher's Exclusion

Rallies.ai operates as a publisher of bona fide financial information and research content under the Publisher's Exclusion set forth in Section 202(a)(11)(D) of the Investment Advisers Act of 1940, as interpreted by the U.S. Supreme Court in Lowe v. SEC, 472 U.S. 181 (1985), and as recently affirmed in Lingley et al v. Seeking Alpha, Inc., No. 1:23-cv-05849 (S.D.N.Y. Aug. 15, 2024).

Under this exclusion, Rallies.ai qualifies as a publisher because:

• All content provided is impersonal in nature and not tailored to the specific financial circumstances of any individual user.
• Content is of general circulation, available equally to all platform users with the same subscription tier.
• Rallies.ai provides disinterested analysis without promoting specific securities for the company's own financial gain from trading activity.
• AI-generated content is based on publicly available data and general analytical frameworks applied uniformly, not personalized investment recommendations.
• Platform features such as stock screeners, data filters, alerts, and portfolio analytics do not constitute personalized investment advice, consistent with the Seeking Alpha precedent.

This Publisher's Exclusion has NOT been confirmed by the SEC, any court, or any regulatory body as applied to Rallies.ai specifically. Rallies.ai's reliance on this exclusion is based on its own legal analysis and the existing precedent cited above. The SEC retains the authority to determine, at any time, that Rallies.ai's activities do not qualify for this exclusion, which could require Rallies.ai to register as an investment adviser or cease certain activities.

1.4.1 Persona-Based Content Customization and Publisher's Exclusion Risk

IMPORTANT: RALLIES.AI CUSTOMIZES CERTAIN CONTENT (INCLUDING NEWSLETTERS AND NOTIFICATIONS) BASED ON USER-PROVIDED PERSONA INFORMATION SUCH AS INVESTOR TYPE, TRADING TIME HORIZON, AND CONTENT PREFERENCES. USERS SHOULD UNDERSTAND THE REGULATORY IMPLICATIONS OF THIS CUSTOMIZATION.

Rallies.ai uses persona data provided during onboarding (e.g., whether a user identifies as a "day trader" or "long-term investor") to customize the selection, prioritization, and presentation of content in newsletters, notifications, and certain platform features. Users should understand:

• The Seeking Alpha precedent (Lingley v. Seeking Alpha, 2024) protected user-applied filters to generally available content. Rallies.ai's persona-based customization goes further by using AI to generate different content selections for different user personas, which is a closer question under the Publisher's Exclusion.
• The differentiation of content by user persona involves editorial judgments about which information is most relevant to different investment approaches. These judgments are not personalized investment recommendations and are based on general assumptions about investor types, not your individual financial circumstances, risk tolerance, or investment objectives.
• The same underlying financial data and news sources are available to all Rallies.ai users regardless of their selected persona. Persona-based customization affects content selection and presentation, not the underlying data itself.
• The news severity matrix (scoring news from 1-10 in importance, differentiated by investor type) involves editorial judgments by Rallies.ai about what constitutes important news for different types of investors. A "10 out of 10" rating for a day trader may differ from a "10 out of 10" for a long-term investor. These ratings are editorial opinions, not investment recommendations.

1.4.2 Implicit Recommendation Risk

Users should be aware that the SEC may consider the manner in which information is organized, prioritized, ranked, filtered, or presented to constitute an implicit recommendation, even in the absence of explicit advisory language. Specifically:

• The selection of which news articles, data points, or analysis to highlight in newsletters or notifications involves editorial judgment that could be construed as an implicit recommendation to pay attention to certain securities or events.
• The ranking or ordering of information (such as by AI-generated severity scores) could be interpreted as suggesting relative importance or urgency for investment decisions.
• The combination of portfolio-specific data display with AI-generated commentary about those holdings, even when framed as educational, could be viewed by regulators as functionally equivalent to personalized advice.
• Rallies.ai does not intend any content organization, ranking, or prioritization to constitute a recommendation. All such features are editorial decisions about information presentation, not investment advice.

1.4.3 SEC Marketing Rule Implications

The SEC's Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act) regulates how investment advisers present performance data and marketing materials. While Rallies.ai is not currently a registered investment adviser, users should understand:

• If the SEC determines that Rallies.ai's activities constitute investment advice, the Marketing Rule would apply to any performance data displayed on the platform, including AI Arena results and any AutoPilot portfolio performance.
• The Marketing Rule prohibits the presentation of gross performance without corresponding net performance, requires specific disclosures about performance calculation methodology, and restricts the use of hypothetical and back-tested performance data.
• Rallies.ai's current display of AI Arena simulated performance would likely not comply with the Marketing Rule if Rallies.ai were classified as an investment adviser. This further underscores that AI Arena is an educational/entertainment feature, not an advisory service.

1.5 Potential Future Regulatory Changes

Users should be aware that:

• The regulatory classification of Rallies.ai may change in the future. If the SEC, FINRA, or any regulatory body determines that Rallies.ai's activities require registration, Rallies.ai will comply with applicable registration requirements, which may result in changes to platform features, services, or availability.
• Rallies.ai may, at its discretion, voluntarily seek registration as a registered investment adviser (RIA) or other regulated entity in the future. Such registration would change the nature of the relationship between Rallies.ai and its users, including the imposition of fiduciary duties and additional regulatory requirements.
• Changes in law, regulation, or regulatory interpretation could affect Rallies.ai's ability to offer certain features or services.

1.6 What Rallies.ai IS

Rallies.ai is an AI-powered financial research, education, and portfolio tracking platform. As of the effective date of these disclosures, the platform provides:

• Aggregated financial data from third-party sources for educational and informational purposes.
• AI-generated research content, market summaries, and analytical commentary.
• Read-only portfolio tracking and net worth aggregation across connected brokerage, banking, and savings accounts.
• Simulated trading competitions (AI Arena) using fictional funds for educational demonstration only (see Section 3.4 for critical disclosures about simulated performance).
• Personalized data displays based on user-connected accounts, which constitute data organization and presentation, NOT investment advice.
• Newsletter content with portfolio-relevant market information for educational purposes.
• Push notifications about market events and news relevant to user holdings for informational purposes only.
• A Discord bot (Ask Rallies) that provides AI-generated responses to financial queries.

Rallies.ai does NOT currently offer trade execution, copy trading, automated trading, portfolio subscription services, or any feature that would allow users to buy, sell, or otherwise transact in securities directly through the Rallies.ai platform.

SECTION 2: INVESTMENT ADVICE AND RECOMMENDATION DISCLAIMERS

IMPORTANT: NOTHING ON THE RALLIES.AI PLATFORM, MOBILE APPLICATION, WEBSITE, NEWSLETTER, DISCORD BOT, PUSH NOTIFICATIONS, OR ANY OTHER COMMUNICATION FROM RALLIES.AI CONSTITUTES INVESTMENT ADVICE, FINANCIAL ADVICE, TRADING ADVICE, A RECOMMENDATION TO BUY OR SELL ANY SECURITY, TAX ADVICE, LEGAL ADVICE, OR ANY OTHER FORM OF PROFESSIONAL ADVICE.

2.1 No Investment Advice

All information provided through any Rallies.ai service, including but not limited to the web application, iOS mobile application, email newsletters, push notifications, Discord bot (Ask Rallies), social media accounts, and any other distribution channel, is provided solely for general informational and educational purposes. No content on any Rallies.ai service should be interpreted as:

• A recommendation to buy, sell, hold, or otherwise transact in any security, cryptocurrency, commodity, or other financial instrument.
• A recommendation regarding the suitability of any investment for any particular individual.
• A recommendation to open, close, or maintain any brokerage, banking, or investment account with any particular provider.
• A suggestion, endorsement, or solicitation of any particular investment strategy, allocation, or portfolio construction methodology.
• An offer or solicitation to buy or sell securities.
• Tax planning, tax preparation, or tax advice of any kind.
• Legal advice or legal analysis.
• Retirement planning, estate planning, or insurance advice.

2.2 No Personalized Recommendations

Even though Rallies.ai displays information related to your specific connected portfolio, brokerage accounts, banking accounts, or savings accounts, this display of information does NOT constitute personalized investment advice. Specifically:

• Portfolio tracking features merely aggregate and display data you have chosen to connect. The organization and presentation of your own financial data does not constitute advice.
• AI-generated insights about securities in your portfolio are based on publicly available information and general analytical frameworks applied uniformly. They are not tailored recommendations based on your personal financial situation, risk tolerance, investment objectives, time horizon, tax status, or any other individual factor.
• Newsletter content that references securities in your connected portfolio is editorial content organized by relevance, not a personalized recommendation to take any action.
• Push notifications about events affecting securities you hold are informational alerts, not calls to action or advice to buy, sell, or hold any position.
• Screeners, filters, rankings, ratings, and sorting tools are data organization features. Any result produced by these tools reflects the application of user-selected or algorithmically determined criteria to publicly available data and does not represent a recommendation.
• The display of gainers, losers, trending securities, or other market data organized by objective criteria (such as price change, volume, or market capitalization) constitutes factual data presentation, not a subjective recommendation.

2.3 SEC Definition of Investment Advice

Under the Investment Advisers Act of 1940, "investment advice" generally requires: (1) advice or analysis concerning securities, (2) provided as a regular business, (3) for compensation. The SEC may broadly interpret what constitutes "advice" and has indicated that even the manner in which information is organized, presented, prioritized, or curated could, under certain circumstances, be construed as advice. Users should understand that while Rallies.ai has structured its services to avoid providing investment advice as defined by law, the SEC retains broad discretion in applying this definition, and no assurance can be given that the SEC would agree with Rallies.ai's characterization of its services.

2.4 No Fiduciary Duty

Rallies.ai does not owe you a fiduciary duty of any kind. We do not act as your investment adviser, financial planner, broker, agent, or in any fiduciary capacity. We have no obligation to act in your best interest with respect to any investment decision you may make. We have no obligation to disclose conflicts of interest beyond those disclosed in this document. You are solely responsible for evaluating the merits and risks of any investment decision.

2.5 Consult Qualified Professionals

Before making any investment decision, you should consult with a registered investment adviser (RIA) or other qualified financial professional who can evaluate your specific circumstances, a certified public accountant (CPA) or qualified tax professional for tax-related questions, a licensed attorney for legal questions, and other qualified professionals appropriate to your specific situation. Rallies.ai is not a substitute for professional advice.

SECTION 3: ARTIFICIAL INTELLIGENCE, TECHNOLOGY, AND PERFORMANCE DISPLAY DISCLOSURES

3.1 AI-Generated Content

IMPORTANT: RALLIES.AI USES ARTIFICIAL INTELLIGENCE AND LARGE LANGUAGE MODELS (LLMs) TO GENERATE CONTENT. AI-GENERATED CONTENT MAY CONTAIN ERRORS, INACCURACIES, HALLUCINATIONS, OUTDATED INFORMATION, OR MISLEADING STATEMENTS. AI HAS NO UNDERSTANDING OF FINANCIAL MARKETS OR INVESTMENT PRINCIPLES. YOU SHOULD NEVER RELY SOLELY ON AI-GENERATED CONTENT FOR ANY FINANCIAL DECISION.

Rallies.ai utilizes the following AI and machine learning technologies:

• Large Language Models (LLMs) including models from OpenAI (including GPT-4, GPT-5, and successor models), Google (Gemini), Anthropic (Claude), and other providers for generating text-based research summaries, market commentary, chat responses, and newsletter content.
• Natural language processing for analyzing news articles, earnings transcripts, and other financial documents.
• Machine learning algorithms for data classification, sentiment analysis, news severity scoring, and content relevance ranking.
• Automated content generation systems for newsletters, push notifications, and in-app informational displays.

3.2 AI Prompting and Subjective Inputs Disclosure

IMPORTANT: THE SEC HAS INDICATED THAT THE MANNER IN WHICH AI MODELS ARE PROMPTED, CONFIGURED, AND DIRECTED CONSTITUTES SUBJECTIVE INPUT BY THE PLATFORM OPERATOR. USERS SHOULD UNDERSTAND THAT ALL AI-GENERATED CONTENT ON RALLIES.AI REFLECTS CHOICES MADE BY RALLIES.AI REGARDING HOW AI MODELS ARE INSTRUCTED, WHAT DATA THEY ARE GIVEN, AND HOW THEIR OUTPUTS ARE FILTERED, RANKED, AND PRESENTED.

Rallies.ai makes the following disclosures regarding AI prompting and configuration:

• All AI models used by Rallies.ai are configured with prompts, instructions, system messages, and parameters chosen by Rallies.ai personnel. These prompting decisions are subjective and reflect editorial choices made by Rallies.ai.
• AI prompts include compliance-oriented language frameworks designed to minimize the generation of content that could be construed as investment advice. These frameworks instruct AI models to use hedging language (e.g., 'the data suggests,' 'some investors might consider,' 'historically speaking') rather than directive language. However, no prompting system is perfect, and AI models may generate outputs that appear to constitute advice despite these safeguards.
• The selection of which data to provide to AI models, which questions to allow users to ask, which topics to prioritize, and how AI outputs are filtered, ranked, or displayed are all editorial and business decisions made by Rallies.ai that involve subjective judgment.
• Rallies.ai's AI prompting methodology has NOT been reviewed, approved, or endorsed by the SEC, FINRA, or any regulatory body.
• Changes to AI prompts, model versions, or configuration parameters may occur without notice and may affect the nature, quality, and content of AI-generated outputs.

3.3 Known Limitations of AI Technology

Users must understand and accept the following limitations:

• AI Hallucinations: AI models can and do produce factually incorrect information. This includes fabricating statistics, earnings data, analyst ratings, price targets, executive statements, SEC filings, and other financial data points that appear authoritative but are entirely fictitious. There is no reliable way to distinguish AI-generated facts from AI-generated fabrications without independent verification.
• Data Currency: AI models may not have access to the most recent data. Information may be outdated by hours, days, or weeks depending on the data source, model training cutoff, and API refresh frequency.
• Inconsistency: AI models may produce different and potentially contradictory results when presented with the same query at different times or in different contexts.
• No Understanding: AI models have no genuine understanding of market conditions, economic principles, financial theory, or company fundamentals. They generate text based on statistical patterns in training data, not from comprehension or expertise.
• No Predictive Ability: AI models cannot predict future market movements, stock prices, earnings results, or economic conditions with any reliability. Any forward-looking statements generated by AI are speculative and should not be relied upon.
• Bias: AI models may reflect biases present in their training data, including survivorship bias, recency bias, popularity bias, and other systematic errors that could skew the information presented.
• Severity Scoring Limitations: AI-generated news severity ratings, importance scores, and relevance rankings are algorithmic approximations. These scores reflect the AI model's statistical assessment, not objective measures of significance. The scoring methodology involves subjective inputs from Rallies.ai (see Section 3.2).
• Algorithmic Bias: AI models trained on historical financial data inherently reflect historical biases, including survivorship bias (over-representing companies and strategies that survived), sector bias, geographic bias, large-cap bias, and recency bias. These biases can systematically skew the information, analysis, and rankings presented to users. Rallies.ai does not audit or correct for all possible biases in AI outputs.
• Model Changes Without Notice: AI models used by Rallies.ai (including those provided by OpenAI, Google, and others) may be updated, replaced, deprecated, or modified by their providers without prior notice to Rallies.ai. Such changes can affect the quality, consistency, and character of AI-generated content in ways that Rallies.ai cannot predict or control.
• AI Content Labeling: Rallies.ai labels AI-generated content as AI-generated where feasible and appropriate. However, due to the pervasive use of AI throughout the platform, not every individual data point, sentence, or analysis may carry a separate AI-generated label. Users should assume that all analytical commentary, research summaries, chat responses, newsletter content, and notification text on the platform is AI-generated unless explicitly stated otherwise.

3.4 AI Arena and Performance Display Disclosures

IMPORTANT: THIS SECTION CONTAINS CRITICAL DISCLOSURES ABOUT SIMULATED TRADING PERFORMANCE. THE U.S. SECURITIES AND EXCHANGE COMMISSION (SEC) STRICTLY REGULATES THE DISPLAY OF INVESTMENT PERFORMANCE. USERS MUST READ AND UNDERSTAND THESE DISCLOSURES.

3.4.1 AI Arena Overview

The AI Arena feature allows AI models to compete in simulated trading environments using fictional funds. NO REAL MONEY IS INVESTED. NO REAL TRADES ARE EXECUTED. AI Arena is an educational and entertainment feature only.

3.4.2 Simulated and Hypothetical Performance Disclosures

IMPORTANT: ALL PERFORMANCE DATA DISPLAYED IN AI ARENA IS HYPOTHETICAL AND SIMULATED. IT DOES NOT REPRESENT ACTUAL TRADING, ACTUAL ACCOUNTS, OR ACTUAL INVESTMENT RESULTS. HYPOTHETICAL PERFORMANCE HAS INHERENT LIMITATIONS AND SHOULD NOT BE RELIED UPON FOR INVESTMENT DECISIONS.

The SEC has established strict rules regarding the display of investment performance. Users must understand the following:

• Back-Tested Performance Prohibition: The SEC considers back-tested performance data (applying an investment strategy retroactively to historical data) to be inherently misleading because it benefits from hindsight bias and the ability to cherry-pick favorable time periods, strategies, or securities after knowing what happened. AI Arena performance that is derived from or influenced by back-tested data should be treated as unreliable.
• Hypothetical Performance Limitations: Even performance generated in real-time within a paper trading (simulated) environment, where no actual money is at risk and no real trade executions occur, is considered "hypothetical performance" by the SEC. The SEC restricts the display of hypothetical performance because it does not reflect the constraints, costs, and risks of actual trading. AI Arena performance is hypothetical performance.
• No Real Execution: AI Arena trades are not executed on any exchange, through any broker-dealer, or in any real brokerage account. Because there is no real trade execution, AI Arena performance does not account for: market impact (the effect of actual orders on market prices), slippage (the difference between expected and actual execution prices), liquidity constraints (the inability to buy or sell at desired prices in real markets), transaction costs (commissions, fees, and spreads), settlement timing, regulatory restrictions, or any other factor that affects real-world trading.
• Performance Calculation Method: AI Arena performance is calculated based on simulated portfolio changes using market data prices at the time of simulated transactions. These calculations use hypothetical, simulated transactions only. No real trades are executed, no real money is at risk, and no real brokerage accounts are involved. The performance shown represents the theoretical result if the simulated trades had been executed at the displayed prices, which does not account for real-world execution factors. These calculations have not been audited, verified, or reviewed by any independent third party, registered public accounting firm, or regulatory body.
• The SEC Ties Performance to Advice: The SEC has indicated that the display of investment performance, combined with the promotion or prioritization of specific portfolios or strategies, may be considered investment advice or marketing material subject to advisory regulations. Users should understand that the display of AI Arena performance, leaderboards, rankings, or comparisons could be construed as an implicit recommendation of higher-performing strategies, even though Rallies.ai does not intend any such recommendation.

3.4.3 AI Arena Leaderboard and Ranking Disclosures

If Rallies.ai displays leaderboards, rankings, or comparisons of AI Arena performance:

• Rankings are based on the simulated, hypothetical performance of AI models within the Arena environment. These rankings do NOT represent rankings of real investment performance.
• The criteria used to rank AI models (e.g., total return, risk-adjusted return, win rate) are selected by Rallies.ai and represent editorial/business decisions. Different ranking criteria would produce different rankings.
• The AI models competing in the Arena are configured with prompts and parameters chosen by Rallies.ai (see Section 3.2). The performance of these models reflects these subjective configuration choices.
• A higher-ranked AI model in the Arena does NOT indicate a better, safer, or more suitable investment strategy for any user. Past simulated performance, even if outstanding, provides ZERO guarantee or indication of future real-world results.
• Users should NEVER attempt to replicate AI Arena strategies, allocations, or trades with real money based solely on simulated performance shown in the Arena.

3.5 AI Chat Feature (Ask Rallies)

The Ask Rallies chat feature, available on the web application, mobile application, and Discord bot, uses AI to respond to user queries. Users must understand:

• The AI chat is NOT a financial advisor, investment consultant, human expert, or registered professional of any kind.
• Responses are generated by AI models based on prompts and configurations designed by Rallies.ai (see Section 3.2). The chat does not connect you with any human professional.
• Chat responses may include language that appears directive or advisory. This language is a function of AI text generation patterns and compliance-oriented prompting. It does NOT constitute a recommendation to take any specific action.
• The AI chat may reference securities in your connected portfolio when answering questions. This contextual use of your data is for information display purposes and does not constitute personalized investment advice.
• The AI chat cannot evaluate your personal financial situation, risk tolerance, investment suitability, tax circumstances, or any other individual factor relevant to investment decisions.
• Chat conversations may be logged, analyzed, and used by Rallies.ai for product improvement, compliance monitoring, and AI training purposes, subject to our Privacy Policy.

3.6 Automated Newsletter Content

Rallies.ai may send automated, AI-generated newsletters. Users must understand:

• Newsletter content is generated algorithmically based on publicly available data matched to user-connected portfolio holdings and user-provided persona information (e.g., investor type, preferred reading style, trading time horizon).
• The use of persona data to customize newsletter content is an editorial and content presentation decision, not a personalized investment recommendation. Users who indicated they are "day traders" will receive differently organized content than users who indicated they are "long-term investors," but the underlying data is publicly available to all.
• News severity ratings and importance classifications are generated by AI models using scoring methodologies that involve subjective inputs from Rallies.ai (see Section 3.2). These ratings are approximations and may not accurately reflect the actual significance of events to your portfolio or investment thesis.
• Newsletters may contain errors including incorrect attribution of news, inaccurate price data, fabricated analyst estimates, or other AI-generated inaccuracies.
• The inclusion or exclusion of any news item in a newsletter does not constitute an endorsement, recommendation, or opinion on any security.
• Users should independently verify all information contained in newsletters before making any financial decision.

3.7 Push Notifications

Rallies.ai may send push notifications to mobile devices. Users must understand:

• Push notifications are informational alerts, not recommendations to buy, sell, or take any action.
• The timing, frequency, and content of notifications is determined algorithmically using AI-generated severity scoring (see Section 3.2 regarding subjective prompting inputs).
• Notifications may be delayed due to network conditions, device settings, or system issues. Users should NOT rely on notifications for time-sensitive trading decisions.
• Receipt of a notification about a security does not imply that any action is required or advisable.
• Notification severity levels (if displayed) are AI-generated estimates and may not accurately reflect the actual importance of the underlying event.

SECTION 4: DATA SOURCES, ACCURACY, AND LIMITATIONS

4.1 Third-Party Data Providers

Rallies.ai aggregates data from multiple third-party providers. We do not independently verify or guarantee the accuracy, completeness, or timeliness of any data from any source.

4.1.1 Snaptrade (Brokerage Portfolio Connections)

• Snaptrade Inc. provides read-only API connections to user brokerage accounts.
• Snaptrade is an independent third-party service. Rallies.ai is not responsible for Snaptrade's availability, accuracy, security, or any failure of service.
• Portfolio data provided through Snaptrade may be delayed, incomplete, or inaccurate. Holdings, balances, and transaction data may not reflect real-time positions.
• Rallies.ai does NOT execute trades through Snaptrade. Connections are strictly read-only for data aggregation.
• Users connect brokerage accounts through Snaptrade at their own risk and should review Snaptrade's terms of service and privacy policy.
• Snaptrade's data collection, storage, and security practices are governed by Snaptrade's own policies, not Rallies.ai's.

4.1.2 Plaid (Banking and Savings Connections)

• Plaid Inc. provides API connections to user checking accounts, savings accounts, and other banking products.
• Plaid is an independent third-party service. Rallies.ai is not responsible for Plaid's availability, accuracy, security, or any failure of service.
• Banking data provided through Plaid may be delayed. Balance data is refreshed periodically and may not reflect real-time account balances or pending transactions.
• Rallies.ai does NOT initiate any banking transactions through Plaid. Plaid connections are strictly read-only.
• Your banking credentials are processed by Plaid, not Rallies.ai. Rallies.ai does not store or have access to your banking login credentials.
• Users connect banking accounts through Plaid at their own risk and should review Plaid's end user privacy policy.
• Certain banks may have restrictions on third-party data access that could affect the availability or accuracy of data provided through Plaid.

4.1.3 Massive / Polygon (Market Data and News)

• Massive Inc. and Polygon.io provide financial data including stock prices, market data, and news content.
• Market data may be delayed by 15 minutes or more depending on the data source and exchange.
• News content is the intellectual property of respective authors and publishers. Rallies.ai does not control, verify, or endorse third-party editorial content.
• Data errors from upstream providers will propagate through the Rallies.ai platform.

4.1.4 TipRanks (Analyst Data)

• TipRanks Ltd. may provide analyst ratings, price targets, and related data.
• Analyst ratings and price targets are opinions of individual analysts and firms. They are NOT endorsed by Rallies.ai and do not constitute recommendations.
• Past analyst accuracy does not guarantee future accuracy.

4.1.5 LSEG (London Stock Exchange Group)

• LSEG may provide financial data, earnings transcripts, and related content.
• LSEG data is subject to LSEG's own terms, conditions, and licensing requirements.
• Earnings transcript data may contain errors from automated transcription processes.

4.2 Data Accuracy Disclaimer

IMPORTANT: RALLIES.AI DOES NOT WARRANT THE ACCURACY, COMPLETENESS, TIMELINESS, RELIABILITY, OR AVAILABILITY OF ANY DATA, CONTENT, OR INFORMATION. ALL DATA IS PROVIDED 'AS IS' AND 'AS AVAILABLE' WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED.

• Stock prices may be delayed by 15 minutes or more and may not reflect current market conditions.
• Portfolio balances, positions, and valuations may not reflect real-time conditions or recent transactions.
• Net worth calculations are estimates based on available data and may not include all assets or liabilities.
• Congressional and political trading data is sourced from public filings and may be delayed by the legally permitted reporting window (up to 45 days).
• Cryptocurrency prices may be more volatile and less reliable than traditional securities data.
• Data from different providers may conflict. Rallies.ai does not reconcile conflicting data from different sources.

SECTION 5: BROKERAGE PARTNERSHIPS, TRADING, AND COPY TRADING DISCLOSURES

5.1 Current Platform Status: No Trade Execution

IMPORTANT: AS OF THE EFFECTIVE DATE OF THESE DISCLOSURES, RALLIES.AI DOES NOT OFFER TRADE EXECUTION, COPY TRADING, AUTOMATED TRADING, PORTFOLIO SUBSCRIPTION SERVICES, OR ANY FEATURE THAT ALLOWS USERS TO BUY, SELL, OR OTHERWISE TRANSACT IN SECURITIES DIRECTLY THROUGH THE RALLIES.AI PLATFORM. THE PLATFORM IS CURRENTLY A READ-ONLY NET WORTH TRACKER AND FINANCIAL RESEARCH TOOL.

Rallies.ai itself does NOT:

• Accept, hold, or transmit any order to buy or sell securities.
• Route orders to any exchange, market maker, or alternative trading system.
• Act as a broker, dealer, or market maker in any capacity.
• Execute, facilitate, or process any securities transaction.
• Hold any securities or funds in custody.
• Provide best execution obligations of any kind.
• Engage in money transmission as defined by FinCEN, the Bank Secrecy Act, or any state money transmitter statute. Rallies.ai does not accept, hold, transfer, or transmit money or monetary value on behalf of any user.

5.2 Public.com Partnership

Rallies.ai has a business relationship with Public Holdings, Inc. ("Public.com"), a registered broker-dealer and member of FINRA/SIPC.

• Public.com is an independent, separately regulated broker-dealer. Rallies.ai does not own, operate, or control Public.com.
• Any brokerage account opened through a Rallies.ai referral is an account with Public.com, subject entirely to Public.com's terms of service, customer agreement, and regulatory requirements.
• Rallies.ai may receive compensation from Public.com for user referrals, account openings, or deposits. This compensation may be structured as a per-account fee, per-deposit fee, revenue share, or other arrangement. This creates a financial incentive for Rallies.ai to encourage users to open Public.com accounts. Users should evaluate whether a Public.com account is appropriate for their needs independent of any Rallies.ai facilitation.
• Rallies.ai does NOT guarantee, endorse, or recommend Public.com's services over any other brokerage.
• Any communications by Rallies.ai regarding Public.com or its services are subject to FINRA Rule 2210 requirements for fairness, balance, and accuracy in communications with the public. Rallies.ai is not a FINRA member, but discloses that any promotional content about Public.com is created in connection with a compensated referral relationship.
• Public.com accounts are protected by SIPC up to $500,000 (including $250,000 for cash claims). Rallies.ai accounts and data are NOT covered by SIPC, FDIC, or any investor or depositor protection program.
• Any trading losses incurred in a Public.com account are entirely the responsibility of the user.

5.3 AutoPilot Partnership

IMPORTANT: COPY TRADING AND AUTOMATED TRADING INVOLVE SIGNIFICANT RISKS INCLUDING THE RISK OF TOTAL LOSS OF INVESTED CAPITAL. PAST PERFORMANCE OF ANY STRATEGY, PORTFOLIO, OR TRADER DOES NOT GUARANTEE FUTURE RESULTS. AUTOPILOT IS A REGISTERED INVESTMENT ADVISER (RIA) REGULATED BY THE SEC. RALLIES.AI IS NOT AN RIA.

Rallies.ai and/or WOLF Financial, LLC may maintain a partnership with AutoPilot, a third-party platform that operates as a registered investment adviser (RIA) facilitating copy trading and automated portfolio subscription services.

5.3.1 AutoPilot Relationship Structure

• AutoPilot operates as a registered investment adviser (RIA) with the SEC. Rallies.ai is NOT an RIA and does NOT provide investment advisory services.
• WOLF Financial, LLC may operate as a "publisher" or "pilot" on the AutoPilot platform, managing or promoting investment portfolios that users can subscribe to for copy trading purposes.
• The relationship between WOLF Financial, LLC and AutoPilot is governed by a separate agreement between those entities. Rallies.ai users who interact with AutoPilot portfolios managed by WOLF Financial, LLC are engaging with AutoPilot's platform and WOLF Financial's investment content, not with Rallies.ai's advisory services (as Rallies.ai provides no advisory services).
• The common ownership between WOLF Financial, LLC and Rallies.ai (through Wolf Technologies LLC) creates a material conflict of interest that users must consider when evaluating any AutoPilot portfolio associated with WOLF Financial.

5.3.2 Copy Trading Risk Disclosures

If you engage in copy trading through AutoPilot or any other platform referenced by Rallies.ai:

• Copy trading involves subscribing to an investment strategy or portfolio managed by a third party. When you subscribe, actual trades may be automatically executed in your real brokerage account with real money. These are real financial transactions with real financial consequences.
• You can lose all of the money you invest through copy trading. There is no guarantee of any return.
• Copy trading involves risks beyond traditional self-directed trading, including: strategy creator error or poor judgment; execution delays between the copied trade and your trade; different entry/exit prices due to market movement and slippage; potential for excessive trading frequency and associated costs; concentration risk; tax consequences from trades you did not individually select; and the risk that the strategy creator may change their approach without notice.
• Rallies.ai does NOT manage, supervise, review, or approve any trades executed through AutoPilot or any copy trading platform.
• Rallies.ai does NOT guarantee the performance, suitability, risk level, or compliance of any portfolio or strategy available through AutoPilot.

5.3.3 Performance Display and SEC Compliance

If performance data for AutoPilot portfolios is displayed on the Rallies.ai platform:

• Performance Calculation Method: Any performance data displayed on Rallies.ai for AutoPilot portfolios is derived from AutoPilot's reporting or calculated by Rallies.ai using publicly available market data. Users should understand that performance calculated by Rallies.ai may differ from performance reported by AutoPilot. The most compliant performance methodology, as recognized by the SEC, is client aggregate performance using time-weighted returns. If performance displayed on Rallies.ai is NOT calculated using client aggregate methodology, users should treat such data with additional skepticism.
• Client Aggregate Performance: The SEC considers client aggregate performance (combining the actual results of all clients following a strategy, calculated using time-weighted returns) to be the most compliant method for displaying investment performance. If Rallies.ai displays performance that is NOT calculated using client aggregate methodology, users should treat such performance data with additional skepticism.
• Real vs. Hypothetical: Only performance based on actual trade executions with real money in real brokerage accounts meets the SEC's standard for real performance. Any performance based on paper trading, back-testing, model portfolios, or simulated environments is considered hypothetical and subject to the limitations described in Section 3.4.2.
• Rallies.ai's Liability for Performance Display: If Rallies.ai displays performance for a portfolio that also exists on AutoPilot, users should understand that the performance calculations shown on Rallies.ai may differ from those shown on AutoPilot, and Rallies.ai's calculation methodology has not been audited, verified, or approved by AutoPilot, the SEC, or any independent third party.
• No Endorsement: The display of any AutoPilot portfolio or its performance on Rallies.ai does not constitute an endorsement or recommendation by Rallies.ai.

5.4 Future Trading Feature Disclosures

Rallies.ai may, in the future, add features that allow users to execute trades, follow portfolios, or otherwise transact in securities through the platform. If and when such features are added:

• Rallies.ai will update these disclosures to reflect the new features and their associated risks.
• Any trade execution features will be provided through partnerships with registered broker-dealers, not directly by Rallies.ai.
• The addition of trading features may change Rallies.ai's regulatory obligations, potentially requiring registration as a broker-dealer, investment adviser, or other regulated entity.
• Users will be required to acknowledge updated disclosures before using any trading features.
• If trading features allow users to manually execute individual trades (e.g., buy or sell a single security by clicking a button), this is distinct from copy trading or automated trading and involves different regulatory considerations. However, users should understand that even manual trade execution through a platform that also displays research, AI analysis, or performance data may be viewed by regulators as part of an integrated advisory service.
• Integration Doctrine: The SEC may apply an "integration doctrine" in which multiple related entities providing different components of an investment service (e.g., one entity providing research and another providing trade execution) are treated as a single integrated advisory service for regulatory purposes. The common ownership between Rallies.ai, WOLF Financial, and any brokerage or trading partners could be relevant to this analysis.
• If broker-dealer functionality is added, Regulation Best Interest (Reg BI) may apply, requiring that recommendations be in the best interest of the customer and that conflicts of interest be disclosed and mitigated.
• Material changes to platform features, including the addition of any trading, copy trading, or automated investment functionality, will require users to re-accept updated disclosures before using the new features.

SECTION 6: PORTFOLIO TRACKING AND FINANCIAL DATA AGGREGATION

6.1 Portfolio Connection Disclosures

• Account connections are read-only. Rallies.ai cannot and does not initiate transactions, transfers, or changes to any connected account.
• You are sharing account data (including holdings, balances, transactions, and account information) with Rallies.ai and its technology partners.
• Connected account data is used to power portfolio analytics, personalized content, newsletters, notifications, and other platform features.
• Rallies.ai stores connected account data on its servers subject to our Privacy Policy.
• Account data refreshes occur periodically (frequency varies by provider). Your displayed data may not reflect real-time conditions.
• You may disconnect any account at any time through your account settings.

6.2 Net Worth and Valuation Disclosures

• Net worth calculations are estimates based on available data from connected accounts. They may not include all assets, liabilities, or financial obligations.
• Portfolio valuations use pricing data that may be delayed and do not account for bid-ask spreads, market impact, or liquidity constraints that would affect actual liquidation values.
• Performance calculations may vary from those shown by your brokerage due to differences in calculation methodology, timing, dividend treatment, corporate action processing, and data availability.
• Rallies.ai is not responsible for any discrepancy between data shown on our platform and data shown by your brokerage, bank, or other financial institution.

6.3 Checking and Savings Account Data

• Balance data is refreshed periodically and may not reflect pending transactions, holds, or real-time balance changes.
• Banking data is used solely for aggregation and display purposes.
• Your banking credentials are processed by Plaid, not Rallies.ai. We do not store your banking login credentials.
• Connecting banking accounts involves sharing sensitive financial data. Users should understand and accept the privacy implications.

SECTION 7: GENERAL INVESTMENT RISK DISCLOSURES

IMPORTANT: ALL INVESTING INVOLVES RISK, INCLUDING THE POSSIBLE LOSS OF ALL MONEY INVESTED. PAST PERFORMANCE IS NOT A GUARANTEE OR INDICATOR OF FUTURE RESULTS. YOU SHOULD NOT INVEST MONEY THAT YOU CANNOT AFFORD TO LOSE.

7.1 General Market Risks

• Market risk: The value of any investment can decline due to general market conditions, economic events, geopolitical events, natural disasters, pandemics, or other factors beyond anyone's control.
• Liquidity risk: Some securities may be difficult to sell at desired prices, particularly during periods of market stress or for thinly traded securities.
• Concentration risk: Portfolios concentrated in a single sector, geography, asset class, or security face heightened risk of loss.
• Interest rate risk: Changes in interest rates can significantly affect the value of fixed-income securities, REITs, and other interest-rate-sensitive investments.
• Inflation risk: Inflation can erode the real value of investment returns and purchasing power over time.
• Currency risk: International investments are subject to exchange rate fluctuations that can increase or decrease returns.
• Credit risk: Issuers of debt securities may default on interest or principal payments.
• Regulatory risk: Changes in laws, regulations, tax policy, or regulatory enforcement could adversely affect investment values or the ability to transact.
• Systemic risk: Failures in financial markets, institutions, or infrastructure could cause widespread losses.
• Technology risk: Platform outages, data errors, cybersecurity breaches, or AI failures could prevent access to information or result in incorrect data display.

7.2 Cryptocurrency-Specific Risks

• Cryptocurrency assets are highly volatile and can lose the majority or entirety of their value in short periods.
• Cryptocurrency markets are largely unregulated and may be subject to manipulation, fraud, and other illicit activity.
• Cryptocurrency assets are NOT protected by SIPC, FDIC, or any government insurance or guarantee program.
• Cryptocurrency exchanges and custodians may fail, be hacked, become insolvent, or freeze withdrawals.
• The regulatory environment for cryptocurrencies is rapidly evolving and uncertain across jurisdictions.
• Tax treatment of cryptocurrency transactions is complex, may vary by jurisdiction, and may change.
• Technological risks unique to crypto include smart contract vulnerabilities, consensus mechanism failures, quantum computing threats, and network attacks.

7.3 No Performance Guarantees

Rallies.ai makes no guarantee regarding future investment performance of any security, portfolio, or strategy; the accuracy of any forecast, prediction, or estimate; the profitability of any investment decision; or the consistency of AI-generated research or analysis.

SECTION 8: COMPENSATION, CONFLICTS OF INTEREST, AND MATERIAL RELATIONSHIPS

8.1 Revenue Sources

Rallies.ai generates revenue from the following sources, each of which may create conflicts of interest:

• User subscription fees (monthly and annual premium subscriptions).
• Brokerage referral compensation from Public.com and/or other brokerage partners.
• Copy trading revenue share from AutoPilot and/or other copy trading platforms.
• Content and marketing partnerships with data providers (including TipRanks, which involves a reciprocal content arrangement).
• Potential future revenue from newsletter monetization (free-to-paid conversion model).
• Potential future revenue from Discord bot distribution and app marketplace presence.

8.2 Specific Conflicts of Interest

• Rallies.ai has a financial incentive to encourage users to subscribe to premium, connect accounts, and use features that generate revenue.
• Rallies.ai has a financial incentive to promote partner brokerages over non-partner alternatives.
• Rallies.ai has a financial incentive to promote copy trading through AutoPilot because revenue may be earned from subscriptions.
• The common ownership between Rallies.ai and WOLF Financial through Wolf Technologies LLC means that individuals who benefit from WOLF Financial's activities on AutoPilot also benefit from Rallies.ai's growth, creating an incentive to cross-promote.
• Content partnerships (e.g., TipRanks arrangement involving reciprocal social media posts) may influence the prominence of certain data providers' content.
• Newsletter monetization (converting free newsletter readers to paid subscribers) creates an incentive to make free newsletters compelling enough to drive conversions, which could influence editorial choices about what content to include.
• AI Arena results may be presented in ways that emphasize positive outcomes, potentially creating an overly optimistic impression.
• The display of portfolio-specific content in newsletters and notifications may create an impression that Rallies.ai endorses the user's current holdings, when in fact it is merely organizing information by relevance.

8.3 Social Media and Content Creator Disclosures

• Content creators associated with Rallies.ai or WOLF Financial may hold personal positions in securities they discuss. They are not obligated to disclose every position or trade to their audiences.
• Social media content is designed to attract engagement and grow audiences and may emphasize dramatic aspects of market events.
• Content creators are not registered investment advisers and are not licensed to provide investment advice.
• UTM tracking links are used in social media posts to track user acquisition and attribute conversions to specific content and creators.
• Specific compensation disclosures for ETF sponsors and security-specific partnerships are available at wolf.financial/terms-of-service.

SECTION 9: DISCORD BOT (ASK RALLIES) DISCLOSURES

• The Ask Rallies bot uses AI to respond to queries. All AI limitations described in Section 3 apply.
• Bot responses are NOT investment advice, financial advice, or recommendations of any kind.
• The bot may be present in third-party Discord servers that Rallies.ai does not own or control.
• Bot usage data may be collected for product improvement and compliance monitoring.
• API costs associated with bot usage in third-party Discord servers are borne by Rallies.ai. This creates a financial incentive to convert Discord users into Rallies.ai app users, which may influence the bot's promotional messaging.
• Promotional offers, referral links, or calls-to-action presented by the bot are marketing materials.
• The bot's availability, functionality, and the servers in which it operates may change without notice.

SECTION 10: DATA PRIVACY AND SECURITY DISCLOSURES

10.1 Data Collection Summary

• Account information: email, name, onboarding responses (investor type, trading time horizon, newsletter preferences, reading level preference).
• Portfolio data: brokerage holdings, positions, balances, and transactions (via Snaptrade).
• Banking data: checking and savings account balances and account information (via Plaid).
• Usage data: app interactions, feature usage, page views, click events, session data, and funnel analytics (via PostHog).
• Device data: device type, operating system, browser, screen size, and approximate location.
• AI interaction data: chat queries, chat responses, newsletter open rates, notification click-through rates.
• Payment data: subscription information processed through third-party payment processors.
• Persona data: user-provided information about investment style, time horizon, and content preferences used to customize newsletter and notification content.

10.2 Third-Party Data Sharing

• Data aggregation providers (Snaptrade, Plaid) to facilitate account connections.
• AI/LLM providers (OpenAI, Google Gemini, and others) to generate content and chat responses. Your portfolio data and chat queries may be transmitted to these providers' APIs. Rallies.ai uses API-tier access to AI providers, which generally provides enhanced data handling protections compared to consumer-tier access. However, users should review each AI provider's API terms of service and data processing agreements for specific details about data retention, training use, and security practices. Rallies.ai applies data minimization principles where feasible, limiting the personal and financial data sent to AI providers to what is necessary for the requested function.
• Analytics providers (PostHog) for product analytics, event tracking, and funnel analysis.
• Payment processors for subscription billing.
• Brokerage and trading platform partners (Public.com, AutoPilot) for referral attribution, account setup, and partnership functionality.
• Content delivery, hosting, and infrastructure providers.
• Email service providers for newsletter delivery and transactional communications.

10.3 Cross-Border Data Transfers

Some of Rallies.ai's third-party service providers may process data outside of the United States. By using Rallies.ai, you consent to the transfer of your data to servers and facilities located in other countries, which may have different data protection laws than your jurisdiction of residence.

10.4 Data Retention

Rallies.ai retains user data for as long as your account is active and for a reasonable period thereafter as necessary to comply with legal obligations, resolve disputes, and enforce agreements. Upon account deletion, connected account data is scheduled for deletion within thirty (30) days, subject to any legal retention requirements. AI interaction data (chat logs, query histories) may be retained in anonymized form for product improvement purposes.

10.5 Data Security

• No system is completely secure. Rallies.ai cannot guarantee that data will not be accessed, disclosed, or destroyed by unauthorized parties.
• Users are responsible for maintaining the security of their own devices, passwords, and account credentials.
• In the event of a data breach, Rallies.ai will comply with all applicable notification requirements.

10.6 Data Selling

• Rallies.ai does not sell personally identifiable user data to third parties for their independent marketing purposes.
• Aggregated, de-identified data may be used for analytics, research, or business intelligence.
• Users should review the privacy policies of all third-party providers for their respective data handling practices.

SECTION 11: SUBSCRIPTION, BILLING, AND REFUND DISCLOSURES

• Premium subscriptions are billed on a recurring basis (monthly or annually) until canceled.
• Annual subscription pricing reflects a discount compared to the monthly rate. The total annual cost is charged upfront at the time of purchase.
• Free trial periods, if offered, will automatically convert to paid subscriptions at the end of the trial period unless canceled before the trial expires.
• Newsletter access may be offered as a free trial with subsequent conversion to paid access. Users will be notified before any transition from free to paid newsletter access.
• FTC Negative Option Compliance: In accordance with the FTC's Negative Option Rule and related guidance, Rallies.ai clearly discloses: (a) when any free trial period begins and its duration, (b) what charges will occur if the trial is not canceled, (c) how to cancel before charges apply, and (d) the exact amount that will be charged. Users can cancel any subscription or trial through their account settings, the applicable app store (Apple App Store, Google Play Store), or by contacting support@rallies.ai.
• Subscription features, pricing, and availability may change with reasonable notice to existing subscribers.
• Rallies.ai reserves the right to modify, suspend, or discontinue any feature at any time.
• Refund policies are governed by the applicable terms of service and app store policies (Apple App Store, Google Play Store).

SECTION 12: LIMITATION OF LIABILITY AND DISCLAIMERS OF WARRANTIES

12.1 No Warranties

THE RALLIES.AI PLATFORM AND ALL CONTENT, DATA, AND SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE" WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING BUT NOT LIMITED TO WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, COMPLETENESS, TIMELINESS, OR RELIABILITY.

12.2 Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL BLOTTER INC., WOLF TECHNOLOGIES LLC, WOLF FINANCIAL LLC, OR THEIR RESPECTIVE OFFICERS, DIRECTORS, EMPLOYEES, CONTRACTORS, AGENTS, OR AFFILIATES, OR ANY THIRD-PARTY DATA PROVIDER, BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, PUNITIVE, OR EXEMPLARY DAMAGES, INCLUDING BUT NOT LIMITED TO DAMAGES FOR LOSS OF PROFITS, GOODWILL, USE, DATA, INVESTMENT LOSSES, OR OTHER INTANGIBLE LOSSES, ARISING OUT OF OR RELATING TO YOUR USE OF OR INABILITY TO USE THE PLATFORM, REGARDLESS OF THE THEORY OF LIABILITY AND REGARDLESS OF WHETHER RALLIES.AI HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

WITHOUT LIMITATION, RALLIES.AI SHALL NOT BE LIABLE FOR:

• Any investment loss, trading loss, or financial harm resulting from reliance on any content, data, AI-generated information, performance data, or any other information on the platform.
• Any inaccuracy, error, omission, or hallucination in AI-generated content or any other platform content.
• Any unauthorized access to or alteration of your data or connected accounts.
• Any interruption, suspension, or discontinuation of any platform feature or service.
• Any action taken or not taken based on newsletters, push notifications, Discord bot responses, or any Rallies.ai communication.
• Any loss resulting from copy trading, automated trading, or portfolio subscription services provided by third parties including AutoPilot.
• Any failure of third-party services including Snaptrade, Plaid, Public.com, AutoPilot, OpenAI, Gemini, or any data provider.
• Any discrepancy between data shown on Rallies.ai and data shown by your brokerage, bank, or other financial institution.
• Any regulatory action, inquiry, fine, or penalty imposed on you as a result of your use of the platform or reliance on platform content.

12.3 Maximum Aggregate Liability

RALLIES.AI'S TOTAL AGGREGATE LIABILITY FOR ALL CLAIMS SHALL NOT EXCEED THE GREATER OF (A) AMOUNTS PAID BY YOU TO RALLIES.AI IN THE TWELVE (12) MONTHS PRECEDING THE CLAIM, OR (B) ONE HUNDRED U.S. DOLLARS ($100.00).

SECTION 13: DISPUTE RESOLUTION AND ARBITRATION

IMPORTANT: THIS SECTION AFFECTS YOUR LEGAL RIGHTS, INCLUDING YOUR RIGHT TO FILE A LAWSUIT IN COURT AND YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION.

13.1 Binding Arbitration

You and Blotter Inc. agree that any dispute arising out of or relating to these disclosures or your use of any Rallies.ai service will be resolved exclusively through binding individual arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules. The arbitration shall take place in Wilmington, Delaware, unless the parties mutually agree to a different location or the AAA determines that a different location is more appropriate.

13.2 Class Action Waiver

YOU AND RALLIES.AI AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR ITS INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING. The arbitrator may not consolidate more than one person's claims.

13.3 Governing Law

These disclosures shall be governed by the laws of the State of Delaware, without regard to conflict of laws principles, except that the Federal Arbitration Act governs the arbitration provisions.

13.4 Opt-Out Right

You may opt out of the arbitration and class action waiver by sending written notice to legal@rallies.ai within thirty (30) days of first accepting these disclosures. Your notice must include your name, address, and a clear statement that you wish to opt out.

SECTION 14: REGULATORY COMPLIANCE AND ENFORCEMENT RISK DISCLOSURES

14.1 SEC Compliance

Rallies.ai has implemented the following compliance measures:

• Prohibition on providing personalized investment advice that would require registration under the Investment Advisers Act.
• Clear and prominent disclosures of non-advisory, non-fiduciary status throughout the platform.
• Compliance-oriented language frameworks in AI prompts designed to minimize advisory language.
• Disclosure of material compensation arrangements and conflicts of interest.
• Separation between informational content display and any trade execution functionality (which is provided by third parties).

14.2 Regulatory Enforcement Risk Disclosure

IMPORTANT: THE SEC AND OTHER REGULATORY BODIES RETAIN BROAD DISCRETION TO INVESTIGATE, INQUIRE, AND TAKE ENFORCEMENT ACTION AGAINST ANY COMPANY OPERATING IN THE FINANCIAL INFORMATION SPACE. THE EXISTENCE OF THESE DISCLOSURES DOES NOT GUARANTEE THAT RALLIES.AI WILL NOT BE SUBJECT TO REGULATORY INQUIRY, INVESTIGATION, OR ENFORCEMENT ACTION.

Users should be aware of the following regulatory risks:

• The SEC may, at any time, determine that some or all of Rallies.ai's activities constitute investment advice requiring registration, regardless of these disclosures or Rallies.ai's characterization of its services.
• An SEC inquiry or enforcement action could result in changes to platform features, temporary or permanent suspension of services, fines, or other consequences that could affect users.
• The regulatory landscape for AI-powered financial platforms is evolving rapidly. New regulations, guidance, or enforcement priorities could materially impact Rallies.ai's operations.
• Rallies.ai's reliance on the Publisher's Exclusion, while supported by existing precedent, has not been specifically affirmed by any regulatory body as applied to Rallies.ai.
• The use of AI to generate financial content is a relatively new area with limited regulatory guidance. The SEC's position on AI-generated financial content may change.

14.3 FTC Compliance

• AI-generated content is disclosed as AI-generated where required.
• Material connections between Rallies.ai, WOLF Financial, and promoted products are disclosed.
• Endorsement and testimonial guidelines are followed for any user testimonials or performance claims.

14.4 State Privacy Law Compliance

Rallies.ai complies with applicable state privacy laws including CCPA/CPRA (California), VCDPA (Virginia), CPA (Colorado), CTDPA (Connecticut), and other applicable state laws. See our separate Privacy Policy for complete details.

14.5 State Securities Registration

While Rallies.ai relies on the Publisher's Exclusion for its federal regulatory position, certain states maintain independent authority to regulate investment advice and financial information services within their borders. Rallies.ai monitors applicable state requirements and will comply with any state registration or notice filing requirements that apply to its activities.

14.6 CFPB Jurisdiction

The Consumer Financial Protection Bureau (CFPB) may exercise jurisdiction over certain financial data aggregation activities. Rallies.ai's use of Plaid and Snaptrade for account connection and data aggregation may fall within the CFPB's regulatory scope, particularly under rules related to open banking and consumer financial data rights. Rallies.ai complies with applicable CFPB regulations.

14.7 Internal Compliance Monitoring

Rallies.ai periodically reviews its operations, disclosures, AI prompting methodologies, content generation processes, and compliance with applicable laws and regulations. This includes monitoring of AI-generated content for compliance with disclosure frameworks, review of data handling practices, and assessment of regulatory developments that may affect platform operations.

14.8 Document Retention and Compliance Records

Rallies.ai maintains records of platform operations for compliance and regulatory purposes, including: AI prompt configurations and version histories, content generation logs, user interaction data, partnership agreements and compensation records, compliance review documentation, and material business communications. These records are maintained for a period of not less than five (5) years or as otherwise required by applicable law.

14.9 Regulatory Cooperation

In the event of an SEC inquiry, FINRA inquiry, state regulatory inquiry, CFPB inquiry, FTC investigation, or any other regulatory proceeding, Rallies.ai will cooperate fully with regulatory authorities and will implement any required changes to its operations, which may include suspension, modification, or discontinuation of platform features, with or without notice to users.

14.10 Electronic Communications Consent

By using Rallies.ai, you consent to receive electronic communications including emails, push notifications, in-app messages, and newsletters pursuant to the E-SIGN Act. You may withdraw consent at any time through account settings.

SECTION 15: ADDITIONAL DISCLOSURES

15.1 No Guarantee of Availability

Rallies.ai does not guarantee uninterrupted, continuous, or error-free operation of any service. Services may be temporarily unavailable due to maintenance, updates, or factors beyond our control.

15.2 Modifications

Rallies.ai reserves the right to modify these disclosures at any time. Material changes will be communicated through the platform, email, or other reasonable means. Continued use after changes are posted constitutes acceptance.

15.3 Severability

If any provision is held unenforceable, it will be enforced to the maximum extent permitted by law, and remaining provisions continue in full force.

15.4 Entire Agreement

These Comprehensive Platform Disclosures, together with the Terms of Service, Privacy Policy, Cookie Policy, Electronic Delivery Agreement, and any other documents incorporated by reference, constitute the complete agreement between you and Rallies.ai regarding the subject matter herein.

15.5 Survival

The following provisions shall survive termination of your use of Rallies.ai services or deletion of your account: Section 2 (Investment Advice Disclaimers), Section 7 (Investment Risk Disclosures), Section 8 (Compensation and Conflicts), Section 12 (Limitation of Liability), Section 13 (Dispute Resolution and Arbitration), and any other provision that by its nature should survive.

15.6 Disclosure Accessibility

These disclosures are available at rallies.ai/disclosures (or such other URL as Rallies.ai may designate), are presented to users during account creation, and are accessible at all times through the platform's settings or legal section. Users may request a copy of these disclosures at any time by contacting legal@rallies.ai.

15.7 Contact Information

General Legal: legal@rallies.ai

Privacy: privacy@rallies.ai

Support: support@rallies.ai

Mailing Address: 22361 SE 43rd Pl, Issaquah, WA 98029

15.8 Acknowledgment

By using any Rallies.ai service, you acknowledge that you have read, understood, and agree to be bound by these Comprehensive Platform Disclosures in their entirety. If you do not agree, do not use Rallies.ai services.

END OF COMPREHENSIVE PLATFORM DISCLOSURES

Last Updated: March 10, 2026

Blotter Inc. d/b/a Rallies.ai | All Rights Reserved