Firm Description Alinea Invest, Inc. (hereinafter referred to as “Alinea”, the “Firm”, “we”, “us”, “our”) is a Delaware corporation with its principal office located in New York City, NY and is registered with the Securities and Exchange Commission (the “SEC”) as an investment advisor. The Firm was formed in November 2020 and is owned by Anam Lakhani, and Eve Halimi. Each owns 36% of the company and are control persons. Services Alinea provides web-based discretionary investment advisory services to separately managed accounts of individuals (each a “Client,” and collectively, “Clients”) in a program that bundles or “wraps” services together and charges a single fee based on the value of assets under management (the “Program”). The services included in the wrap are advisory, trade execution, clearance, settlement, and custody and reporting. Alinea offers these services to individual taxable accounts. The Program seeks to provide personalized, long-term oriented investment portfolios that are primarily invested in what Alinea considers high-quality stocks while seeking to provide personalized protection against market downturns, enabled via a mobile application. The Program does not provide comprehensive financial or tax planning or legal advice, and Clients are advised and afforded the opportunity to seek the advice and counsel of the Client’s own tax, financial, and legal advisers. Neither Alinea nor any of its affiliates is responsible for establishing or maintaining any Client’s compliance with the requirements of the Internal Revenue Code for a Traditional IRA or Roth IRA, or any other type of account that may be offered through the Program or determining any Client’s individual tax treatment regarding such account. Furthermore, neither Alinea nor any of its affiliates is responsible for withholding any tax penalties that may apply to Clients’ Alinea accounts or for any state or federal income tax withholding, except as may otherwise be required by applicable law. The Program seeks to provide personalized, long-term oriented investment portfolios Each equity strategy is comprised primarily of a concentrated basket of stocks (long) Advisory Business – Program Description Alinea’s Program interacts with its Clients predominantly through a software application that is available through mobile platforms (the “Alinea App”). The advisory services are delivered solely through the Alinea App. Alinea does not provide investment advice in person or over the phone or in any manner other than through the Alinea App. Alinea’s Program maintains an online presence through the Firm’s website, www.alinea-invest.com, primarily for informational purposes. Alinea utilizes the information from the questionnaire to create an investment portfolio that is customized to Clients’ risk tolerance, financial parameters, and investment objectives. For each Client’s portfolio plan, Alinea considers the Client’s employment status, income, investment goals and reasons to invest, time horizon and net assets. Alinea evaluates each Client’s responses and proposes a portfolio plan from among conservative, moderate, and aggressive growth portfolios. A Client is required to enter into an investment advisory agreement with Alinea (“Advisory Account Management Agreement”), which discusses

the services the Client will receive, the fees charged to the Client, and the conditions of the Client’s relationship with Alinea. Our advisory relationship begins upon the effective date of the Advisory Account Management Agreement with a Client. Any preliminary information provided to a Client before we accept the Advisory Account Management Agreement does not constitute investment advice under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and should not be relied on as such. Alinea offers discretionary and non-discretionary investment recommendations and advisory services to individual investors. Alinea interacts with investment advisory clients, as well as prospective clients, solely through the App Platform. Alinea does not offer financial planning services, tax, accounting, or legal advice. Alinea utilizes the App Platform to collect information with respect to each client and prospective clients and to deliver account notifications and content, and to provide Alinea’s investment recommendations. Upon account opening (“Client Onboarding”), the client will be prompted to complete a series of questions that will be used, in combination with other available client information collected through the App Platform prior to and/or after account opening including banking information. These questions are important to the development of any investment recommendations. Client Onboarding is only complete once a client (i) has linked the client’s bank account (“Funding Account”) to the Firm’s custodian via the App Platform. No staff at the Firm will have access to a client’s bank account information nor will staff at the Firm have access to a client’s login credentials; and (ii) has accepted and countersigned Alinea’s investment advisory agreement electronically. Only when Client Onboarding is complete will a client have the availability to purchase stocks via the App Platform. Clients should consider that Alinea primarily uses electronic (not telephonic) means to provide customer support. To receive customer support, clients may contact us using email or through the App Platform. Clients and prospective clients should be comfortable communicating through those channels. Further, clients should understand that clients will not interact directly with investment advisory personnel. Alinea reserves the right to deny any prospective clients access to the Alinea App Platform and to terminate client accounts for reasons related, but not limited, to unsuitability and/or if clients fail to timely maintain financial and other information previously provided by the client on the App Platform or update this information on at least an annual basis. A client’s failure to timely update their information in the App Platform could materially impact the quality and applicability of Alinea’s investment recommendations. During the Client Onboarding process, the client will also be prompted to simultaneously open a brokerage account held by the designated custodian in order to execute any trades. The independent custodian will hold client funds and securities. At any time, clients may terminate an account, or withdraw all or part of an account. See below (Fees and Compensation) for more information regarding fees, including withdrawal/administrative charges.