Terms, Privacy & Key Disclosures

MGI Machine Guided Investments LLC – Terms & Conditions
Effective Date: April 2026

1. Acceptance of Terms

By accessing or using PortFrame (the "Service"), you agree to be bound by these Terms & Conditions ("Terms"). If you do not agree, do not use the Service.

2. Nature of Service

PortFrame is an educational and informational tool only. The outputs generated by PortFrame are:

• Not investment advice;
• Not recommendations to buy, sell, or hold any security;
• Not a solicitation to engage in any securities transaction;
• Not tailored to the individual needs of any user.

3. No Investment Adviser Relationship

MGI is not registered as an investment adviser with the SEC or any state securities regulator. Your use of PortFrame does not create an investment adviser-client relationship.

4. User Responsibility

You are solely responsible for:

• Your own investment decisions;
• Verifying the accuracy of any output before acting on it;
• Complying with all applicable laws, including if acting on behalf of clients.

5. Performance & Backtesting

1. Backtested results are hypothetical and do not reflect actual trading.
2. Past performance, actual or simulated, is not indicative of future results.
3. Results may vary due to market conditions, data limitations, and modeling assumptions.

6. Model Limitations

1. Outputs are generated solely from user inputs and available data.
2. Changing inputs may produce materially different results.
3. PortFrame does not monitor or update outputs after delivery.

7. AI & Data Limitations

1. Outputs are generated using artificial intelligence and may contain errors, omissions, or biases.
2. MGI does not guarantee the accuracy, completeness, or timeliness of outputs or third-party data, which may be obtained from Tiingo, Polygon and other sources.

8. Subscription & Payment

You agree to pay applicable subscription fees. Payments are non-refundable except as required by law.

9. Intellectual Property

All content, code, and outputs generated by PortFrame are the intellectual property of MGI and may not be copied, modified, or distributed without prior written consent. More explicitly, MGI, PortFrame are pending registration with the U.S. Patent and Trademark Office.

10. Limitation of Liability

To the fullest extent permitted by applicable law, MGI shall not be liable for any direct, indirect, incidental, or consequential damages arising from your use of PortFrame.

11. Governing Law

These Terms are governed by the laws of the State of California, without regard to conflict of law principles.

12. Modifications

MGI may modify these Terms at any time. Continued use of the Service after changes constitutes acceptance.

13. Additional Policies and Disclosures

Your use of PortFrame is also subject to our Privacy Policy and Key Disclosures, which are made available through the Service. In the event of a conflict, these Terms & Conditions control with respect to use of the Service and the parties' legal rights and obligations, the Privacy Policy controls with respect to collection, use, and disclosure of personal information, and the Key Disclosures are provided as a summary for convenience and do not replace or override these Terms & Conditions or the Privacy Policy.

Effective Date: April 2026

1. Introduction

MGI Machine Guided Investments LLC ("MGI," "we," "our," or "us") respects your privacy. This Privacy Policy explains how we collect, use, and safeguard your personal information when you access or use the PortFrame website, mobile application, or related services (collectively, the "Service").

2. Information We Collect

We may collect the following categories of information when you use the Service:

• Account and Contact Information: such as your name, email address, billing address, login credentials, and other information you provide when creating or managing an account.
• Payment and Subscription Information: such as subscription status, billing records, and payment-related information. Payment card and similar payment details may be collected and processed by our third-party payment processors in accordance with their own terms and privacy practices.
• Usage and Device Information: such as IP address, browser type, device type, operating system, pages viewed, features used, access times, referring URLs, and similar technical usage information.
• Cookies and Similar Technologies: we and our service providers may use cookies, pixels, local storage, SDKs, and similar technologies to help operate, secure, analyze, and improve the Service.
• User Inputs and Portfolio-Related Information: such as information, preferences, instructions, portfolio specifications, or other content you submit into PortFrame in connection with use of the Service.

3. How We Use Your Information

We may use your information to:

• provide, operate, maintain, and improve the Service;
• create and administer accounts and subscriptions;
• process payments and billing through our payment service providers;
• authenticate users, protect account security, detect fraud or misuse, and enforce our terms;
• provide customer support and respond to inquiries;
• analyze usage, performance, and reliability of the Service;
• communicate with you about your account, product updates, legal notices, security alerts, and support matters; and
• comply with legal, regulatory, tax, accounting, or recordkeeping obligations.

4. Sharing Your Information

We do not sell or rent your personal information. We may disclose information as follows:

• Affiliates: to our affiliated entities for internal administrative, operational, support, development, or compliance purposes;
• Service Providers: to vendors and contractors that help us operate the Service, such as hosting providers, cloud infrastructure providers, authentication providers, analytics providers, payment processors, customer support tools, email or communications providers, and similar operational service providers, subject to appropriate contractual or confidentiality protections;
• Legal and Compliance Purposes: where required by law, regulation, legal process, or governmental request, or where we believe disclosure is necessary to protect our rights, users, or the Service; and
• Business Transfers: in connection with a merger, acquisition, financing, reorganization, sale of assets, or similar corporate transaction, subject to applicable legal requirements.

5. Cookies, Analytics, and Similar Technologies

We and our service providers may use cookies and similar technologies to maintain sessions, remember preferences, support security, analyze usage, and improve the Service. At this time, the Service does not respond to browser "Do Not Track" signals or similar browser-based privacy preference mechanisms in a standardized way.

6. Data Retention

We retain personal information for as long as reasonably necessary to provide the Service, maintain accounts and subscriptions, comply with legal or recordkeeping obligations, resolve disputes, and enforce agreements.

7. Data Security

We use commercially reasonable safeguards to protect your personal information from unauthorized access, use, or disclosure.

8. Your Rights

You may request access to, correction of, or deletion of your personal information by contacting us at admin@mgi-strategies.com.

9. Changes to This Policy

We may update this Privacy Policy from time to time. Updates will be posted on our website with the "Effective Date" revised accordingly.

• Past performance is not indicative of future results.
• PortFrame is provided by MGI Machine Guided Investments LLC for educational and informational purposes only.
• Outputs are impersonal and are not tailored to the needs of any specific individual.
• MGI is not registered as an investment adviser and does not provide personalized investment advice.
• The inclusion of any security in an output is not a recommendation to buy, sell, or hold that security.
• Backtested performance is hypothetical and does not reflect actual trading.
• PortFrame does not provide tax advice. Any tax-loss harvesting analyses, simulations, monitoring outputs, or related tax-aware portfolio outputs are educational and informational only, may be based on assumptions and available data, may not reflect all tax consequences or wash-sale considerations, and should be reviewed with a qualified tax adviser before acting.
• Results may differ materially from real-world outcomes.
• Data and outputs may contain errors, omissions, or inaccuracies and should be independently verified.
• Users are solely responsible for all investment decisions and should consult a licensed financial professional before acting.