The Company Gainy Inc. is a digital investment adviser registered with the SEC since July 26th, 2021. Gainy, through its mobile platform, provides clients with automated investment advisory and portfolio management services by utilizing proprietary algorithms that match securities to clients’ interests and risk profiles. The investments are executed through brokerage accounts that all clients open with DriveWealth LLC (“DriveWealth”), a brokerage company and a member of Financial Industry Regulatory Authority (“FINRA”). DriveWealth is not affiliated with Gainy. When opening an account on the Gainy mobile platform, all clients simultaneously enter into an advisory agreement with Gainy and a brokerage and custody agreement with DriveWealth. Additional information about Gainy services, structure and directors is provided in Part 1 and Part 2B of Gainy Form ADV which is available online at www.adviserinfo.sec.gov or at www.gainy.app. We encourage visiting our website www.gainy.app for additional information. Types of Advisory Services Offered and How We Tailor Our Services Gainy focuses on the simplification of investment decisions for retail investors by creating thematic-based model portfolios of stocks and cryptocurrencies (“Thematic Trading Fractionals” or “TTFs”) that can be replicated in clients’ portfolios by purchasing fractional shares of the stocks comprising the model portfolio via DriveWealth autopilot platform. Once the portfolio is created in a client’s account, Gainy maintains the weights of the underlying securities in accordance with the model portfolios by utilizing DriveWealth auto-pilot functionality. With the current capabilities of the platform, all securities purchases/sales are executed at 10:30 am of the closest business day, provided that the client’s account is fully funded for such transactions and that the markets are open on this date. For example, if a client using Gainy’s platform sends an order to buy a specific TTF at 3 p.m., and there are enough funds to make this acquisition, the buy orders for the corresponding fractional shares will be placed at 10:30 a.m. the next trading day. When creating TTFs, Gainy’s investment objective

is to seek maximum long-term, risk-adjusted returns while maintaining the thematic focus of each TTF. Thematic investments and the Match Score As a part of the investment advisory process, Gainy collects data on clients’ interests with regard to industries, sectors, and investment topics. The stocks and cryptocurrencies are divided into groups linked to certain investment topics. These groups become an integral part of creating TTFs. Furthermore, based on the onboarding questionnaire, Gainy establishes the risk tolerance of individual investors and assigns them to groups based on the risk profile: Conservative, Moderate, and Aggressive. ADV Part 2A – Firm Brochure Page: 5 Gainy Inc. Each stock and cryptocurrency on the Gainy platform receives a Match Score for each user based on how well the stock fits the thematic requirements and the risk profile of a user. The client may choose to direct Gainy to buy a single security of the client’s choosing or instruct Gainy to invest in a group of stocks resembling a model portfolio referred to as Thematic Trading Fractionals (TTFs), and give Gainy a discretion to further buy and sell stocks to follow the chosen TTFs Thematic Trading Fractionals (TTFs) Following the grouping of securities by investment themes, Gainy creates model portfolios (referred to as “Thematic Trading Fractionals” or “TTFs”). The portfolios are optimized using the proprietary optimization algorithm based on the Risk Budgeting approach, further enhanced by optimizing the diversification within the portfolio and bringing the portfolio’s relative volatility (beta) closer to the market. The Gainy platform allows clients to search through the available TTFs and highlights those that have the highest Match Score for each client, and therefore better match the client’s investment interests and risk profile. The Match Score of a TTF is calculated as a weighted Match Score for securities comprising the TTF. Financial Planning Service Through Software In addition to investment advisory and portfolio management services, Gainy also provides certain software-based financial planning, informational, and portfolio analysis tools and services to its clients. These products and services are provided as part of Gainy’s software platform.