Upturn Disclosures

Investment-advisory, methodology, performance, simulation, and product disclosures

Last Updated: August 26, 2026

By using Upturn, you agree to Upturn's Terms of Use, Privacy Policy & Disclosures. These Disclosures describe important limitations, assumptions, risks, and conflicts relating to Upturn's investment-advisory services, ratings, research tools, artificial-intelligence features, and hypothetical or simulated performance. They should be read before relying on any information presented through the website or mobile application.

Important: Investing in securities involves risk, including the possible loss of principal. Past performance, historical advisories, ratings, backtests, and simulations do not guarantee future results. Upturn does not promise that any security, portfolio, advisory, rating, or strategy will achieve a profit or avoid a loss.

Form ADV Part 3 — Relationship Summary

Upturn Corporation ("Upturn," "we," or "us") is an investment adviser registered (https://adviserinfo.sec.gov/firm/summary/290614) with the U.S. Securities and Exchange Commission ("SEC"). Registration with the SEC does not imply a particular level of skill or training. Brokerage and investment-advisory services and fees differ, and it is important for you to understand those differences. Free tools and educational materials are available at Investor.gov/CRS and adviserinfo.sec.gov.

Upturn's current Form ADV Part 3 (Form CRS) and Form ADV Part 2A brochure are available through the SEC's Investment Adviser Public Disclosure database. Upturn Corporation Form ADV Part 3 can be found here. The filed versions control if this webpage or document differs from a current regulatory filing. Contact info@upturn.io for an up-to-date copy free of charge.

What Investment Services and Advice Can Upturn Provide Me?

Upturn provides automated investment-advisory services to retail investors through its website and mobile application and may make features available through other authorized interfaces (collectively, the "Services"). Upturn covers approximately 9,500 U.S.-listed stocks and exchange-traded funds ("ETFs"), although coverage, availability, and eligibility may change.

The Services use proprietary quantitative, statistical, machine-learning, and rules-based methods to generate daily BUY, SELL, or PASS advisories and related Strong, Regular, or Weak BUY classifications. Upturn also provides historical advisory charts, Upturn Star Ratings, Top Picks, Top Performers, market indicators, watchlists, hypothetical Robo-Portfolios, company fundamentals, analyst perspectives, price-behavior classifications, and AI-assisted research and search tools.

Upturn's advisory output is automated and generally the same for users viewing the same security at the same time. It does not consider a particular user's complete financial circumstances, tax position, investment horizon, holdings, liquidity needs, or risk tolerance. Filters, watchlists, searches, and portfolio selections personalize what a user sees, but do not convert general model output into individualized financial planning.

Upturn does not currently exercise investment discretion, execute trades, select a broker, custody client assets, connect to or monitor a user's brokerage account, rebalance actual holdings, or verify whether a user follows an advisory. Users make their own investment and trading decisions through a broker of their choice. There is no minimum account balance imposed by Upturn for access to the Services.

For more detailed information about our services please see our Form ADV Part 2A brochure, at Items 4 and 7.

What Fees Will I Pay?

Upturn may offer free access, free trials, and paid subscription plans. Current prices, plan features, usage limits, trial terms, and renewal terms are disclosed on Upturn’s pricing and billing pages or at the time of purchase. Payments are processed by Stripe. Upturn does not receive or store complete payment-card numbers or card security codes.

Upturn charges only the applicable subscription fee for access to its Services. Upturn does not charge a percentage of assets, deduct fees from a brokerage account, or charge commissions for securities transactions.

If you independently buy or sell securities through a broker, you may incur costs that are not charged by or paid to Upturn. These may include brokerage fees, bid-ask spreads, taxes, regulatory fees, and expenses charged by an ETF, mutual fund, custodian, or other third party. Unless expressly stated otherwise, these third-party costs are not included in Upturn’s hypothetical or simulated performance results.

For more detailed information about our fees and costs please see our Form ADV Part 2A brochure, at Items 5, 6 and 7.

What Are Upturn’s Legal Obligations and Conflicts of Interest?

When Upturn acts as an investment adviser to a client, it is required to act in the client's best interest and not place its interests ahead of the client's interests. Upturn's business model nevertheless creates actual or potential conflicts that users should understand.

• Upturn earns subscription revenue and therefore has an incentive to make the Services engaging, encourage continued use, and promote paid features.
• Upturn may receive advertising revenue through Google AdSense. Advertisements, including advertisements for financial products, are supplied by third parties and are not recommendations or endorsements by Upturn.
• Upturn personnel and their families may invest in securities covered by the Services. Upturn's Code of Ethics prohibits trading ahead of clients and trading on material nonpublic information and provides for monitoring and mitigation of identified conflicts.
• Vendors, data providers, AI providers, or business partners may have their own commercial interests. Their information or services may be incorporated into the Services, but Upturn does not treat third-party content as guaranteed or independently verified in every instance.
• Upturn may change features, methodologies, factor weights, coverage, subscription terms, or data providers. Such changes may affect ratings, advisories, displayed histories, and user experience.

Upturn does not receive transaction-based compensation for user trades and does not currently execute trades or manage client assets. Any future brokerage, custody, execution, referral, revenue-sharing, or asset-based arrangement would require additional disclosure and, where applicable, amendments to regulatory filings and client agreements before launch.

How Do Financial Professionals Make Money?

Upturn personnel may receive salary, equity, bonuses, or other compensation from Upturn. Compensation practices can create incentives connected to company growth, subscriptions, product adoption, fundraising, or other business objectives. Upturn maintains policies designed to prevent compensation from overriding its fiduciary obligations.

Legal or Disciplinary History

Users should review Upturn's current Form CRS and public record at adviserinfo.sec.gov for the most current response concerning disciplinary history. Investor.gov/CRS provides free tools to research investment advisers and financial professionals. The current regulatory filing controls over any summary on the website.

Additional Information

For current regulatory documents, information about the Services, or a free copy of Upturn's Relationship Summary, contact info@upturn.io. A user's primary interaction with Upturn is through the website, mobile application, and this email address; Upturn is designed as an automated advisory service and does not promise ongoing access to a dedicated human financial professional.

Considerations Before Using Upturn

Should I Choose an Automated Investment-Advisory Service?

Upturn may be appropriate for investors who want technology-based analysis and remain comfortable making their own brokerage and trading decisions. It may not be appropriate for a person seeking comprehensive financial planning, continuous review of an entire household portfolio, tax or estate advice, individualized human guidance, brokerage execution, custody, or discretionary management.

Before investing, users should consider emergency savings, near-term obligations, debt, insurance, liquidity needs, taxes, time horizon, risk capacity, and the possibility of loss. Users should consult qualified investment, legal, tax, and accounting professionals when appropriate.

How Does Upturn Choose Investments to Recommend?

Upturn applies proprietary quantitative, statistical, machine-learning, and rules-based methods to historical price, volume, market, and other data. The system evaluates multiple indicators and patterns to identify potential upward or downward trends and ordinarily updates advisories after the market close. Algorithms, thresholds, inputs, data sources, and classifications may change over time without preserving the same historical behavior.

A BUY, including Strong, Regular, or Weak BUY, means Upturn's model identifies differing levels of evidence of a possible upward trend. PASS means the model does not currently identify sufficient support for a BUY and is not necessarily a directive to sell or a view that the security will decline. SELL means model conditions supporting the prior BUY have weakened or reversed.

These labels are probabilistic model outputs—not promises, price targets, guarantees, or individualized instructions.

Relevant Experience and Automated Advice

Upturn's financial advice is automated. The website, mobile application, and underlying systems were developed and are overseen by Upturn. Information about the education, experience, qualifications, and roles of Upturn's supervised persons appears in applicable Form ADV filings. Users should rely on the current filed brochure and supplements rather than an older website biography.

General Product and Data Disclosures

Coverage, Availability, and Data Timing

• Upturn generally covers U.S.-listed stocks and ETFs. Coverage is not exhaustive, and a symbol, exchange listing, security classification, or feature may be added, removed, delayed, or unavailable.
• Upturn’s advisory model requires at least three months of historical stock-price data before generating an advisory for a security. Therefore, a recently listed or recently IPO’d company generally will not receive an Upturn Advisory until at least three months of sufficient price data are available. Data gaps or other limitations may delay eligibility beyond three months.
• Prices displayed in advisory charts are generally based on the latest available market close and may be delayed by approximately one trading day. They are not real-time executable quotations.
• Corporate fundamentals, analyst data, target prices, revenue segments, ownership data, employee counts, market capitalization, news, and other third-party information may be delayed, incomplete, restated, mapped incorrectly, or affected by provider methodology.
• Corporate actions, symbol changes, splits, dividends, delistings, mergers, bankruptcies, stale prices, missing data, and survivorship or selection effects may distort comparisons or simulations.
• Service interruptions, model errors, data-provider failures, or notification delays may cause an advisory or other information to be late, unavailable, or inaccurate.

Historical Advisory Charts and Last-Close Prices

Historical advisory charts display prior model outputs overlaid on historical prices. A displayed BUY or SELL marker does not show an actual trade by Upturn or a user. Unless expressly stated otherwise, simulated entries and exits use the applicable prior or latest closing price. That price may not have been available when the market next opened, in the quantity desired, or at all. Overnight gaps, spreads, volatility, liquidity, trading halts, and market impact can cause materially different execution.

Blue, green, red, profit, or loss markers are visualization conventions for hypothetical advisory cycles. They should not be interpreted as audited account results or evidence that any client achieved the displayed outcome.

Upturn Star Rating for Stocks and ETFs

The Upturn Star Rating is a 1-to-5-star summary of historical advisory performance, simulated investment performance, and selected supporting characteristics. It is distinct from the current BUY, SELL, or PASS advisory and from the recency of that advisory. A highly rated security may have a current PASS or SELL, and a low-rated security may have a current BUY.

The rating is generally calculated in this order: Advisory Performance and simulated Stock or ETF Performance; Trading Volume; Price Path; Price Stability; and, for individual companies, Company Fundamentals. The final rating is bounded between one and five stars. The methodology, weights, lookback periods, thresholds, and data inputs may be changed as Upturn improves its models.

• Advisory Performance considers the simulated success rate and consistency of completed historical advisory cycles.
• Stock or ETF Performance considers realized simulated results from completed cycles and unrealized simulated results associated with an open cycle.
• Trading Volume is a liquidity proxy. Moderate or low volume may reduce a rating because hypothetical results may be difficult to execute in practice.
• Price Path evaluates the direction and persistence of closing prices over approximately three market quarters. Qualifying Hockey-Stick Growth or Strong Uptrend patterns may increase a rating by one star, subject to the five-star cap.
• Price Stability evaluates how smoothly or erratically price moved over the same period. Highly Choppy behavior or Extreme Price Shocks may reduce a rating. A favorable path and unfavorable stability can exist at the same time.
• Company Fundamentals for individual stocks considers financial health, growth momentum, and ownership. Weak fundamentals may reduce a rating. Company Fundamentals are not applied to ETFs.

Star labels such as Outstanding, Above Average, Moderate, Below Average, or Not Recommended are comparative summaries under Upturn's methodology. They are not credit ratings, analyst ratings, guarantees, or predictions of future performance.

Price Path and Price Stability

Price Path classifications may include Hockey-Stick Growth, Strong Uptrend, Steady Uptrend, Flat or Range-Bound, Rolling Over, Downtrend, and Steep Decline. Price Stability classifications may include Very Smooth, Smooth, Moderately Choppy, Choppy, Highly Choppy, and Extreme Price Shocks. These labels are generated from historical closing-price behavior, may change as the lookback window advances, and may not capture intraday volatility or the cause of a price move.

A pattern label is descriptive, not predictive. A strong upward path may reverse abruptly; a declining or choppy security may subsequently rise. Users should not rely on a path or stability label as a stand-alone timing signal.

Company Fundamentals, Unit Economics, and Quantitative Style

Company Fundamentals, Financial Health, Growth Momentum, Ownership, Unit Economics, and Quantitative Style ratings summarize selected financial and market data under Upturn's formulas. Metrics may use percentile ranks, provider-normalized data, financial statements, valuation ratios, cash-flow measures, ownership data, moving averages, volatility, size, short interest, and liquidity. Formula components and weights may evolve.

These ratings simplify complex information and may omit material facts, industry-specific accounting differences, off-balance-sheet obligations, recent filings, or subsequent events. Percentile rankings depend on the comparison universe and date. A high score does not establish that a security is fairly valued or suitable for a particular investor.

Analyst Perspective and Price Targets

Analyst Perspective summarizes third-party analyst coverage, rating distribution, and price-target upside. Analyst opinions are not Upturn's proprietary advisory, may be stale, may change without notice, and may be affected by analyst conflicts, coverage limitations, methodology, or access to management. A consensus rating is not a guarantee of accuracy.

Price targets are forecasts, commonly for an approximately one-year horizon. They are not fair-value determinations by Upturn, executable prices, or assurances that a security will reach any level. Comparisons with current price or a 52-week range can become outdated as prices and estimates change.

AI-Assisted Search, Company Information, SWOT, Similar Companies, Investor Fit, and Risk Profiles

Upturn uses AI to assist with natural-language stock and ETF search and to generate or summarize company descriptions, company details, SWOT-style analysis, competitive context, similar companies, investor-fit observations, risk profiles, financial narratives, growth projections, and other research content. AI-supported search queries may be sent to Google Gemini or another search, grounding, cloud, or AI provider.

AI-generated or AI-summarized content may contain factual errors, omissions, stale information, unsupported inferences, biased framing, incorrect entity or ticker mappings, hallucinations, or inconsistent conclusions. Grounding and source retrieval reduce but do not eliminate these risks. AI content is informational context and should not be treated as audited research, a company filing, a guarantee, or the sole basis for an investment decision.

Investor-fit and risk-profile labels describe general characteristics associated with a security or strategy. They do not assess a user's complete circumstances and are not a personal suitability, best-interest, or risk-tolerance determination. Similar-company results are based on available descriptions, industry, themes, business characteristics, or model inference and may omit closer competitors or include imperfect comparisons.

Top Picks, Top Performers, Search Results, and Filters

Today's Top Picks is a rules-based list that may include securities meeting criteria such as a four-star or higher Upturn rating, a recent Strong BUY, specified market-capitalization or employee thresholds, positive recent profitability, and minimum trading volume. Top Performers is a rules-based list of securities with stronger simulated performance over a stated historical period. Criteria, eligibility, ranking, and list membership may change.

Inclusion in Top Picks or Top Performers is not a guarantee, individualized recommendation, or representation that the security will outperform. These lists may be affected by data availability, screening thresholds, lookback choices, survivorship, market regime, and the timing of model updates.

Search and filters narrow a universe using user-entered terms and selected criteria. Natural-language results may be model-inferred rather than exhaustive. Risk annotations attached to filters are generalized heuristics based on factors such as size, liquidity, volatility, or historical performance; they do not measure a user's personal risk tolerance.

Upturn Gauge and Market Overview

The Upturn Gauge and related market-overview tools summarize the distribution of Upturn advisories among an eligible subset of covered securities, such as higher-rated large- and mid-cap stocks. Labels such as bullish, bearish, correction, growth, or recession reflect Upturn's proprietary classification and are not official economic determinations, forecasts, or market-timing guarantees. The eligible universe, thresholds, and overlay data may change.

Watchlists and Notifications

Watchlists organize securities selected by a user but do not represent monitored brokerage holdings. Notifications may alert users to advisory changes or other events, but delivery may be delayed, duplicated, interrupted, blocked by device settings, or unavailable. Users remain responsible for monitoring investments and should not rely on a notification as the exclusive method of receiving time-sensitive information.

Robo-Portfolios and Simulations

Upturn Robo-Portfolios are user-directed, hypothetical research and simulation tools—not custodial accounts, pooled vehicles, actual managed portfolios, or discretionary robo-advisers. Instant portfolios may be generated from a pool satisfying selected filters; Custom portfolios permit user-selected filters or holdings. Upturn does not purchase, sell, rebalance, or custody the securities shown.

Unless expressly stated otherwise, portfolio simulations assume an equal-weighted portfolio and apply Upturn's historical BUY and SELL advisories using closing-price assumptions. Equal weighting may be approximated using daily percentage returns. Actual whole-share constraints, fractional-share availability, cash balances, deposits, withdrawals, taxes, dividends, fees, spreads, slippage, market impact, corporate actions, and rebalancing are generally not reflected.

SPY may be used as a benchmark. SPY is not necessarily an appropriate benchmark for every portfolio, strategy, security type, risk level, or time period. Benchmark comparisons may omit fees and differences in reinvestment, risk, composition, timing, and investability.

Upturn may recommend a minimum number of holdings, such as 12, as a general diversification prompt. A holding count alone does not ensure diversification. Securities can share sector, factor, issuer, geographic, correlation, concentration, or liquidity risks. Upturn does not guarantee diversification across industries, asset classes, or markets.

Robo-Portfolio Star Ratings

Upturn assigns each Robo-Portfolio a Star Rating based on two simulated historical-performance measures: the ending value of a hypothetical $1 investment and the portfolio’s Sharpe ratio. Both applicable thresholds must be satisfied:

• Five Stars: Ending value of at least $2.00, equivalent to a cumulative return of at least 100%, and a Sharpe ratio of at least 1.75.
• Four Stars: Ending value of at least $1.50, equivalent to a cumulative return of at least 50%, and a Sharpe ratio of at least 1.50.
• Three Stars: Ending value of at least $1.00, equivalent to a cumulative return of at least 0%, and a Sharpe ratio of at least 1.00.
• Two Stars: Ending value of at least $0.75, equivalent to a cumulative return of at least −25%, and a Sharpe ratio of at least 0.75.
• One Star: The portfolio does not satisfy the minimum requirements for a Two-Star rating.

These ratings are based entirely on hypothetical or simulated historical results and do not represent the performance of an actual client account. The Sharpe ratio measures simulated return relative to historical volatility under Upturn’s stated calculation assumptions. A higher rating or Sharpe ratio does not guarantee future returns, indicate low future risk, or mean that the portfolio is suitable for a particular investor.

Upturn may revise the applicable historical period, thresholds, calculation assumptions, or rating methodology.

Newly Listed Securities and Minimum Price History

Upturn’s advisory model requires at least three months of sufficient historical price data before it can generate an advisory for a stock or ETF. Therefore, a recently listed security, including a recently completed initial public offering, generally will not receive an Upturn Advisory during its first three months of public trading.

Availability after three months is not guaranteed. Missing or unreliable data, limited liquidity, corporate actions, listing changes, or other data-quality limitations may delay or prevent a security from becoming eligible for Upturn Advisories.

Advisory Strength and PASS

BUY Strength and BUY Classifications

BUY Strength reflects the proportion of Upturn’s technical and quantitative indicators that support a BUY advisory. Upturn uses BUY Strength to classify a BUY advisory as STRONG BUY, REGULAR BUY, or WEAK BUY.

• STRONG BUY means a higher proportion of the evaluated indicators support the BUY advisory.
• REGULAR BUY means a moderate proportion of the evaluated indicators support the BUY advisory.
• WEAK BUY means a lower proportion of the evaluated indicators support the BUY advisory.

These classifications indicate different levels of agreement among Upturn’s model indicators. They do not represent the probability that a security will increase in value, predict the amount of any return, or guarantee a profit. A STRONG BUY can result in a loss, and a WEAK BUY can subsequently perform well.

PASS Advisory

A PASS advisory means Upturn’s model does not currently identify sufficient support for a BUY advisory. PASS is not necessarily a prediction that the security will decline and should not automatically be interpreted as a SELL advisory.

A PASS advisory may subsequently change to BUY or SELL as prices, trading volume, market conditions, or the model’s indicators change.

Historical Periods and Lookback Windows

Performance calculations may use a fixed starting date, rolling historical period, or feature-specific lookback period. The applicable period may vary among advisory charts, stock and ETF ratings, Top Performers, Price Path and Price Stability classifications, and Robo-Portfolio simulations.

Changing the starting date, ending date, or lookback period can materially change cumulative returns, annualized returns, volatility, Sharpe ratios, advisory success rates, ratings, and benchmark comparisons. Results calculated for different periods should not be treated as directly comparable unless the periods and methodologies are the same.

Changes to Models and Historical Results

Upturn may update its advisory algorithms, model parameters, indicators, thresholds, eligible security universe, data sources, rating methodology, or calculation procedures.

Historical advisories may reflect the model that was operating when each advisory was originally generated. Other metrics or classifications may be recalculated using newer methodologies. Consequently, historical advisories, current ratings, and recalculated performance metrics may have been produced using different model versions and may not be directly comparable.

Upturn will not necessarily revise every historical advisory after changing a model or methodology.

Corrections and Data Revisions

Upturn may correct information when it identifies missing data, erroneous ticker or company mappings, incorrect corporate-action treatment, calculation errors, stale information, or other material data-quality issues.

A correction may change a historical chart, performance metric, Star Rating, Price Path, Price Stability classification, company rating, Robo-Portfolio result, or other displayed information. Upturn does not guarantee that every historical display will remain unchanged after a correction or data-provider revision.

ETF-Specific Disclosures

ETFs are portfolios of securities and may have risks that differ from the risks of individual stocks. These risks may include management fees, tracking error, premium or discount to net asset value, concentration, leverage, derivatives exposure, liquidity limitations, closure, and differences between the ETF’s market price and the value of its underlying holdings.

Upturn generally does not apply individual-company fundamentals to ETFs. An ETF’s Upturn Star Rating, advisory, Price Path, and Price Stability are based on the ETF’s available market and advisory data and do not represent a complete evaluation of every underlying holding.

Benchmark Limitations

Upturn may compare a security or Robo-Portfolio simulation with SPY or another benchmark. A benchmark is provided for general comparison and may have a different composition, investment objective, risk level, sector exposure, volatility, fee structure, dividend treatment, and rebalancing methodology.

A comparison with SPY does not mean SPY is the most appropriate benchmark for every stock, ETF, or Robo-Portfolio. Benchmark performance does not reflect the circumstances or performance of an individual user.

No Tax, Legal, or Accounting Advice

Upturn does not provide tax, legal, estate-planning, or accounting advice. Tax consequences vary based on a user’s circumstances, holding period, account type, jurisdiction, gains, losses, and other transactions.

Users should consult qualified tax, legal, accounting, and investment professionals before acting on information provided through the Services.

Material Changes to Methodology

When reasonably appropriate, Upturn may update these Disclosures or its Tutorials to describe material changes to advisory classifications, Star Ratings, simulation methodologies, or other significant features.

Not every model adjustment, threshold change, data correction, or technical modification will result in advance notice. Continued use of the Services after a change is subject to the then-current methodology and disclosures.

Performance Metrics and Simulation Assumptions

All stock, ETF, advisory-cycle, and Robo-Portfolio performance shown by Upturn is hypothetical or simulated unless expressly identified as actual client performance. It is not the performance of a live account managed by Upturn. The simulation is designed to illustrate how historical model advisories would have performed under stated assumptions and benefits from hindsight inherent in historical data and model evaluation.

Broad Assumptions Applicable to Performance Metrics

1. Historical pricing and other data are obtained from third-party providers. Data sources may change, and source data may be inaccurate, incomplete, adjusted, or unavailable.
2. A simulated BUY or SELL ordinarily uses the applicable prior or latest market close. The assumed price may not be available at the next open or for the quantity desired.
3. The simulation assumes signals can be acted upon without delay, slippage, bid-ask spread, liquidity constraint, market impact, trading halt, order rejection, or operational error unless expressly stated otherwise.
4. Returns may be positive or negative. A BUY does not guarantee appreciation, and a SELL does not guarantee profit or prevent subsequent appreciation.
5. Taxes, brokerage commissions, exchange or regulatory fees, fund expenses, advisory subscription costs, financing costs, and other expenses are generally excluded. Dividends, distributions, interest, and reinvestment are generally excluded unless expressly stated.
6. Displayed histories may use a fixed start date, rolling lookback, or feature-specific period. Changing the start date, end date, or lookback can materially change results.
7. Open advisory cycles may include unrealized simulated gain or loss. Those amounts can change and are not realized returns.
8. Backtests and simulations may be affected by selection bias, survivorship bias, look-ahead bias, data-mining risk, overfitting, corporate-action handling, and changes in the model or eligible universe.
9. A model currently in production may differ from the model or parameters that generated earlier advisories. Upturn may preserve historical signals as generated, recalculate some metrics, or update classifications as methodology evolves.
10. Actual investors may enter or exit at different times, ignore advisories, hold different quantities, maintain cash, rebalance, or face constraints not represented in the simulation. Actual results will differ.
11. Simulated results are directionally informative only and are not audited, guaranteed, or a forecast of future performance.

Performance Metric Definitions

• Cumulative Return: the compounded or aggregated simulated change over the stated period under the applicable advisory or portfolio methodology. The exact display scale should be read with the in-product definition.
• Annualized Return: a simulated return converted to an annual rate. Annualization can magnify short-period results and does not mean the result was earned in any calendar year.
• Annual Volatility: an annualized measure of variability in historical simulated returns. It does not capture every form of risk or predict maximum loss.
• Sharpe Ratio: simulated excess return relative to volatility under Upturn's stated assumptions. It can be unstable over short periods and does not capture tail risk, liquidity risk, or loss severity.
• Advisory Success Rate or Hit Rate: the percentage of completed simulated advisory cycles meeting Upturn's profit or success definition. It does not describe the magnitude of gains or losses and may exclude open cycles.
• Average Profit or Loss and Invested Days: averages across the relevant simulated cycles. Averages can conceal dispersion, outliers, and changing market conditions.
• Realized and Unrealized Simulated Performance: completed-cycle results and open-cycle mark-to-close results, respectively. Neither represents a client account unless expressly stated.

Hypothetical Performance Disclosure

Upturn’s historical advisory results, model portfolios, backtests, Star Ratings derived from simulated results, and related performance charts constitute hypothetical or simulated performance. They do not represent the results of an actual client account or actual trading by Upturn.

Hypothetical performance has inherent limitations. It is calculated using historical data and stated assumptions and does not fully reflect the effect of market conditions, execution delays, liquidity constraints, trading costs, taxes, investor behavior, or other factors that affect actual investment results. No representation is made that any user will achieve results similar to those shown.

Upturn maintains supporting information concerning the criteria, assumptions, risks, and limitations used to calculate displayed hypothetical performance. Additional information is available by contacting info@upturn.io.

Advisory and Research Limitations

• Upturn advisories, ratings, screens, charts, research summaries, and AI-generated content are inputs to a user's decision—not substitutes for independent due diligence.
• No feature accounts for every material company event, macroeconomic condition, valuation concern, portfolio interaction, tax consequence, or personal circumstance.
• No assurance is provided that an advisory will be timely, correct, profitable, suitable, or available before a market move.
• Information can become outdated quickly. Users should verify material facts using current company filings, fund documents, broker information, and other authoritative sources.
• Users should not provide material nonpublic information, brokerage credentials, Social Security numbers, payment-card details, or other highly sensitive information through AI search or other free-text fields.

Advertising, Third-Party Content, and Intellectual Property

Upturn may display advertising supplied through Google AdSense and may receive compensation. Upturn does not independently operate its own targeted-advertising program. An advertisement, sponsored destination, or third-party link is not an Upturn recommendation or endorsement, including when it concerns a financial product. Third parties control their own content, availability, privacy practices, and claims.

Company names, trademarks, logos, and brands belong to their respective owners and are used for identification and informational purposes. Their appearance does not imply sponsorship, affiliation, endorsement, or approval of Upturn.

No Custody, Brokerage, Execution, or Guarantee

Upturn does not currently custody user assets, accept trade orders, execute transactions, choose a broker, or guarantee that a user can purchase or sell at a displayed or simulated price. Investments are not deposits of Upturn, are not FDIC insured, are not guaranteed by Upturn or any government agency, and may lose value.

Changes to Features and Methodologies

Upturn may add, remove, rename, suspend, or modify features, advisory classifications, eligible universes, formulas, factor weights, thresholds, lookback periods, benchmarks, data providers, AI providers, subscription limits, and presentation. A rating or metric calculated after a methodology change may not be directly comparable with an earlier value. Where appropriate, Upturn may update these Disclosures and the Tutorials to describe material changes.

Contact Us

For questions about these Disclosures, the Services, regulatory documents, or account-related matters, contact Upturn Corporation at info@upturn.io.

Regulatory and Source Links

• Upturn Disclosures: https://www.upturn.io/disclosure
• Upturn Tutorials: https://www.upturn.io/Tutorials
• SEC Investment Adviser Public Disclosure: https://adviserinfo.sec.gov
• Investor.gov Relationship Summary resources: https://www.investor.gov/CRS
• SEC Investment Adviser Marketing compliance guide: https://www.sec.gov/resources-small-businesses/small-business-compliance-guides/investment-adviser-marketing