Disclosures &
Legal Notices

1. Not Investment Advice

Evolving Alpha is a systematic, automated trading signal publication service that publishes buy and sell signals exclusively through the Collective2 platform. All signals are generated by a mechanical, rules-based algorithmic system and are transmitted identically to all subscribers simultaneously. No signal is tailored, personalised, or adapted to the individual financial situation, investment objectives, risk tolerance, or personal circumstances of any subscriber.

The strategy manager (the strategy manager, Panama) is not a registered investment adviser, broker-dealer, financial planner, or licensed financial professional in any jurisdiction. The publication of trading signals does not constitute the provision of investment advisory services.

You should not construe any information provided through this website or the Evolving Alpha strategy as a substitute for professional financial advice. Before making any investment decision, you should consult with a qualified, licensed financial adviser who is familiar with your personal circumstances.

2. Hypothetical Performance Disclaimer

All backtested performance figures presented on this website, including the stated returns of +15.1% over two years, 50% win rate, 4.78 profit factor, and 1.9% maximum drawdown, are derived from hypothetical backtesting of historical market data. These results:

• Were not achieved in an actual trading account during the period shown
• Do not account for the impact of actual trading, including execution costs, slippage, and market impact
• Were computed with the benefit of hindsight using historical data not available at the time signals would have been generated
• May have been prepared with the benefit of back-testing, which allows adjustments to be made to improve the apparent historical performance
• Do not reflect trading in actual client accounts and therefore do not reflect the impact of material economic and market conditions on the decision-making process

No representation is being made that any account will or is likely to achieve profits or losses similar to those shown. The strategy is currently operating in paper (simulated) trading mode on Alpaca's paper trading platform. Paper trading results may also differ materially from live trading results due to differences in execution, liquidity, and market conditions.

Past performance, whether actual, paper-traded, or hypothetical, is not necessarily indicative of future results.

3. Risk Disclosure

Systematic trend following strategies, including those based on Turtle Trading methodology, are subject to the following specific risks:

Trend Following Risk

Trend following strategies perform poorly in range-bound, choppy, or mean-reverting markets. Extended periods of sideways price action can generate multiple consecutive losing trades. The strategy may experience significant drawdowns before a profitable trend develops.

Low Trade Frequency Risk

The strategy generates approximately 4–8 signals per month. Extended periods of no signals are normal and expected. Subscribers should not interpret an absence of signals as a system malfunction.

Drawdown Risk

The strategy employs a 15% maximum drawdown halt. Before reaching this threshold, subscribers may experience drawdowns of up to 15% from peak equity. Individual trades risk 1% of account equity per unit, with up to 4 units possible in a single position, representing a maximum single-trade risk of approximately 4% of equity.

Execution Risk

Signals published through Collective2 may be executed at prices different from those used in the strategy's model account due to subscriber account size, brokerage execution quality, order routing, and market conditions at the time of execution.

Algorithm Risk

The strategy relies on automated algorithms to generate signals. Software errors, data feed failures, connectivity issues, or unexpected market conditions may cause the algorithm to behave in an unintended manner or fail to generate signals at the appropriate time.

AI Self-Improvement Risk

The strategy incorporates an AI-driven parameter refinement engine. While all parameter changes require simulation validation and human approval before implementation, the use of AI-generated analysis introduces the risk of incorrect pattern identification, overfitting to recent data, or unintended behavioural changes following parameter updates.

Instrument Concentration Risk

The strategy trades a single instrument (SPY, the S&P 500 ETF). All performance is therefore correlated to the performance of the US equity market. Diversification across multiple instruments or asset classes is not provided by this strategy.

4. Regulatory Status

Evolving Alpha is published by the strategy manager, a private individual resident in the Republic of Panama. The strategy is distributed through Collective2, a platform operated by MEXEM LTD, an investment firm regulated by the Cyprus Securities and Exchange Commission (CIF license number 325/17).

The strategy manager is not registered as an investment adviser, commodity trading adviser (CTA), broker-dealer, or in any other regulated capacity with the SEC, CFTC, NFA, Panama's Superintendency of the Securities Market (SMV), or any other regulatory authority. The publication of systematic, non-personalised trading signals through the Collective2 platform is conducted on the basis that such activity does not require registration as an investment adviser under applicable law.

This determination is based on the impersonal nature of the signals (identical signals transmitted simultaneously to all subscribers), the mechanical rules-based nature of the strategy (no discretionary judgement applied), and the absence of personalised investment advice.

5. Panama Securities Law

The primary legal framework governing securities activities in Panama is Decree Law 1 of 1999 on the Securities Market (the "Securities Law"), supervised by the Superintendency of the Securities Market (SMV).

Under Panama's Securities Law, "investment advisers" are defined as individuals or entities that, for compensation, provide advice to others on the pricing of securities or the suitability of investing in, buying, or selling those securities. The SMV has not issued definitive guidance on whether the automated publication of systematic, non-personalised trading signals through international platforms constitutes "investment advisory services" requiring SMV registration.

The strategy manager intends to monitor regulatory developments in Panama and will seek formal SMV guidance or obtain necessary registrations if required by applicable law. This disclosure will be updated accordingly.

6. Notice to United States Subscribers

Evolving Alpha publishes identical, non-personalised trading signals to all subscribers simultaneously. Under the US Investment Advisers Act of 1940, the publisher of bona fide impersonal trading signals of general and regular circulation may qualify for the "publisher exemption" under Section 202(a)(11)(D), thereby not requiring registration as an investment adviser with the SEC.

Evolving Alpha operates consistent with this exemption by:

• Transmitting identical signals simultaneously to all subscribers with no individualisation
• Operating on a fixed, regular publication schedule (daily signal checks at 4:05 PM ET)
• Providing no individualised investment advice or personal consultations
• Charging a fixed subscription fee with no performance-based compensation

Evolving Alpha does not accept subscribers who are US persons and who reside in states or jurisdictions that impose additional registration requirements beyond the federal publisher exemption. It is the responsibility of each subscriber to determine whether their participation is lawful under applicable federal and state law.

7. Notice to International Subscribers

Evolving Alpha is made available to subscribers worldwide through the Collective2 platform. The strategy manager makes no representation that the strategy, this website, or the subscription service is appropriate or available for use in any particular jurisdiction outside Panama.

The distribution of trading signals may be restricted by law in certain countries. Subscribers are solely responsible for determining whether their participation in the Evolving Alpha strategy is lawful in their country of residence and for complying with all applicable laws, regulations, and requirements.

In particular, subscribers in the following regions should obtain local legal advice before subscribing:

• European Union / EEA: MiFID II regulations may apply to the reception and transmission of investment signals. Consult a local financial adviser.
• United Kingdom: The Financial Services and Markets Act 2000 may impose requirements. Consult an FCA-authorised adviser.
• Australia: The Corporations Act 2001 regulates financial services. Consult an ASIC-licensed adviser.
• Canada: Provincial securities regulations vary. Consult a securities lawyer in your province.
• Other jurisdictions: Consult local legal counsel regarding the applicability of local securities and financial services laws.

8. AI and Algorithmic System Disclaimer

Evolving Alpha incorporates artificial intelligence (AI) technology, specifically a proprietary AI model, to perform post-trade analysis, identify patterns in historical trade data, and generate parameter refinement proposals. The following additional disclosures apply to the AI components of the strategy:

AI Analysis Limitations

AI-generated post-mortem analyses and parameter proposals are based on pattern recognition in historical trade data. These analyses may identify spurious patterns, overfit to recent market conditions, or fail to account for structural market changes. The AI does not have predictive ability regarding future market behaviour.

Human Oversight

All parameter changes proposed by the AI must pass a paper trading simulation and receive explicit human approval before being implemented. No parameter is changed automatically without human review. A complete audit trail of all proposals, approvals, and rejections is maintained and is publicly visible on the strategy website.

Model Risk

The AI models used may produce incorrect, biased, or nonsensical analyses. The strategy manager does not warrant the accuracy, completeness, or reliability of any AI-generated analysis. AI-generated post-mortems are provided for informational and transparency purposes only and do not constitute investment research or analysis.

Third-Party AI Provider

our proprietary AI engine is a third-party service. The strategy manager has no control over changes to the AI provider's models, pricing, availability, or terms of service. Changes to the AI provider may affect the post-mortem and proposal functions of the strategy. The core mechanical trading signals are not dependent on the AI component and will continue to function in the event of AI service disruption.

9. No Guarantee of Results

No guarantee, representation, or warranty, express or implied, is made regarding:

• The profitability of the strategy in the future
• The accuracy, completeness, or timeliness of any signal or analysis
• The suitability of the strategy for any particular subscriber's financial situation
• The strategy's ability to achieve any specific return target or avoid any specific level of drawdown
• The continuity of the strategy's publication or the Collective2 platform's availability
• The accuracy of the AI-generated post-mortem analyses or parameter proposals

The strategy manager may suspend, modify, or discontinue the strategy at any time without notice. The strategy manager may change the subscription fee, instrument traded, or fundamental approach of the strategy at any time.

10. Conflicts of Interest

The following actual or potential conflicts of interest are disclosed:

Financial Interest in Strategy Performance

The strategy manager receives subscription fees from subscribers through the Collective2 platform. This creates a financial incentive to attract and retain subscribers, which may create incentives to present performance information in a favourable manner. All performance data presented on this website is sourced directly from the strategy's track record on Collective2, which is independently recorded and cannot be altered retroactively.

Personal Trading

The strategy manager may trade personal accounts using strategies, instruments, or approaches that are different from or in addition to the Evolving Alpha strategy. The strategy manager is not required to disclose personal trading activity beyond what is required by applicable law.

Collective2 Revenue Sharing

The strategy manager receives a percentage of subscription fees collected by Collective2. This creates a financial relationship between the strategy manager and Collective2 which may create incentives regarding the use of that platform.

11. Privacy and Data

The Evolving Alpha website collects minimal personal information. Contact form submissions (name, email address, and message content) are transmitted via EmailJS to the strategy manager's email address and are not stored on this website's server.

Subscriber management, billing, and personal data related to strategy subscriptions are handled entirely by Collective2 (MEXEM LTD) in accordance with their privacy policy and the applicable data protection laws of Cyprus and the European Union, including GDPR.

No personal data collected through this website is sold, rented, or shared with third parties for marketing purposes.

12. Contact Information

For questions regarding these disclosures, regulatory concerns, or any matter related to the Evolving Alpha strategy:

These disclosures were last reviewed in April 2026. They will be updated as required by changes in applicable law, regulatory guidance, or the nature of the strategy. Subscribers are encouraged to review these disclosures periodically.