NINE30 is an SEC registered investment adviser offering web-based, discretionary investment advisory services to clients (each a “Client, and collectively, “Clients”) through the NINE30 mobile app (“the Mobile App”). The Firm was formed in March 2023 and is principally owned by Amichay Oren and Andreas Clenow through their ownership of the Firm’s parent company, NINE30 Inc. NINE30 provides investment advice to Clients through a software application that is available in the Mobile App. The Firm does not provide investment advice in person, over the phone, in live chat, or in any manner other than through the Mobile App. The Firm maintains an online presence through www.nine30.com, primarily for informational purposes. NINE30 uses an algorithm to determine investment recommendations that are tailored to meet with each Client’s individual investment needs and objectives based upon information each Client submits via a one or more questionnaires (together, the “Client Profile”). The Client Profile collects, among other information, the Client’s employment status, income, investment goals and reasons to invest, time horizon and net assets (together, “Investment Needs”). NINE30 does not verify the information it receives from Clients or their agent(s) for accuracy, and it will rely on the information Clients provide. It is each Client’s responsibility to promptly update his or her Client Profile, Interests, and Restrictions in the event of a change. The Firm’s recommendations consist of an actively managed portfolio of securities, which consist of equities, American depositary receipts (“ADRs”), exchange traded notes (“ETNs”) and exchange traded funds (“ETFs”). The Firm actively manages the Client’s portfolio on a discretionary basis, whereby it

has the authority to buy, sell, and otherwise effect investment transactions for a Client’s funds and securities without the Client’s prior consent or approval. NINE30 monitors Client Accounts on an ongoing basis, and implements changes, as appropriate. The Firm actively manages the Client’s portfolio in a securities brokerage account (“Client Account”) established by the Client at Alpaca Securities LLC (“Alpaca”), an unaffiliated SEC- registered broker-dealer and Financial Industry Regulatory Authority (“FINRA”) member, which provides brokerage related services to NINE30 and its Clients. Alpaca provides custody, clearing, and settlement services for transactions effected by NINE30 in Client Accounts. The investments of each Client are held in a separate Client Account in the name of the Client at Alpaca, and not with NINE30. Clients open Client Accounts at Alpaca application program interface (“API”) in the Mobile App. NINE30’s services do not include 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 NINE30 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 managed by NINE30 or determining any Client’s individual tax treatment regarding such account. Furthermore, neither NINE30 nor any of its affiliates is responsible for withholding any tax penalties that may apply to Client Accounts or for any state or federal income tax withholding, except as may otherwise be required by applicable law. The Firm does not participate in wrap fee programs. As of the date of this Brochure, the Firm does not have assets under management.