Datalign is a technology-based firm designed to match prospective investors (“Investors”) with unaffiliated investment advisers based on the Investor’s self-reported personal financial information, location, required services and desired relationship with an adviser. Datalign was formed in September 2021 and its principal owner is Impact Ready Holdings, LLC. Impact Ready Holdings, LLC is indirectly owned by David Blundin. Datalign’s principal service is providing advice over the Internet for Investors seeking introductions to third-party investment advisers. Datalign does not manage Investors’ assets, and the advice it provides is limited to matching Investors with suitable third-party investment advisers that have elected to participate in Datalign’s matching platform (“Participating Advisers”). Datalign’s fully interactive Internet-based matching service utilizes questionnaires that Investors are required to complete regarding the Investor’s personal and financial circumstances, including the Investor’s age, state of residence, investable assets, income, desired services, desired relationship with an adviser, and investment risk tolerance. Participating Advisers are screened for current state or federal registration status, disciplinary history, and advisory services offered. Participating Advisers are interviewed to determine their areas of expertise with regard to financial planning. The information that is collected allows Datalign to form an initial basis for a match between an Investor and Participating Adviser that meets the Investor’s specifications, based the information provided by the Investor and Participating Advisers. An Investor is then introduced to a suitable Participating Adviser through the Datalign platform. Once Datalign introduces an Investor to a Participating Adviser, the Investor and Participating Adviser will communicate outside of the Datalign platform and determine whether or not they would like to engage in an investment advisory relationship together. In consideration for making introductions, Datalign is paid a fee by each Participating Adviser. As a result, Datalign’s business model includes an inherent conflict of interest because it has an incentive to introduce an Investor to a Participating Adviser even if a suitable Participating Adviser is not available.

Datalign makes no guarantee that each introduced Participating Adviser will be successful in managing the assets of any particular Investor, nor does it make suitability determinations about any such strategy, product, or offering for a particular Investor. However, Datalign is a fiduciary to Investors and Participating Advisers and as a fiduciary is obligated to place its clients’ interests of its own in every situation. If no Participating Advisers are deemed appropriate by Datalign based on an Investor’s profile, no introduction will be made. Datalign does not provide any advice regarding specific investments or securities, nor does it participate in the management of Investors’ accounts. Although Datalign makes introductions it believes are suitable based on the information provided by the Investor and Participating Adviser, it does not analyze or recommend particular strategies or offerings of a Participating Adviser, or make suitability determinations about any such strategy, product, or offering for a particular Investor. Further, Datalign does not assess the fees charged by Participating Advisers, although Datalign will review Participating Advisers’ fee schedules during the initial screening and interview process. Datalign will only introduce Investors to Participating Advisers, and Investors should be aware that other investment advisers not on Datalign’s platform may be more suitable for the Investors specifications and financial circumstance. Datalign does not maintain an ongoing Datalign Page 5 client relationship with Investors. For a more fulsome discussion of Datalign’s methods of analysis, please refer to Item 8 below. Except for the verification of Investors, Datalign provides all of its services to Investors solely through its fully interactive Internet-based platform. Datalign only introduces Investors to Participating Advisers with which it has referral agreements. Investors are not obligated to engage with any Participating Adviser that is matched through the Datalign platform. Datalign does not provide portfolio management services to wrap fee programs. Since Datalign does not manage Investors’ assets or have the ability to hire or fire managers on behalf of its Investors, Datalign does not have regulatory assets under management.