Risk disclosures

TEMPLATE — NOT LEGAL ADVICE. This document is a product-specific draft prepared to help Zap communicate trading risk. It has not been reviewed by counsel and must be reviewed, completed, and approved by qualified securities counsel before it is published or relied upon. Bracketed items (e.g., Zap) are placeholders. See the legal review notes accompanying this draft.

Read This First

Zap is software made available by Zap ("Zap," "we," "us," or "our") that places equities orders inside a dedicated, ring-fenced trading wallet you connect through Robinhood's official Agentic trading interface. Trading securities involves substantial risk, including the risk of losing some or all of the money you put into the connected wallet. Before you connect a wallet, fund it, or enable any trading mode, read this entire document. By using Zap to place or propose trades, you confirm that you have read and understood these disclosures and that you accept the risks described here.

This document has three parts: (1) a Risk Disclosure, (2) a Not Investment Advice statement, and (3) an Automated and Autonomous Trading Disclosure.

Part 1 — Risk Disclosure

You can lose money

The value of equities rises and falls. An AI-driven strategy can be wrong, can be wrong repeatedly, and can lose money in any market condition — including markets that are rising overall. You should only fund the connected wallet with money you can afford to lose. Zap does not protect against, insure, or reimburse trading losses, and is not a bank, a deposit account, or an SIPC- or FDIC-insured product. Any SIPC protection applicable to your brokerage account is provided by your broker, not by Zap, and protects against broker failure — not against investment losses.

No guaranteed returns

Zap makes no promise, guarantee, or representation that you will earn a profit, avoid a loss, or achieve any particular result. Any examples, projections, target ranges, hypothetical figures, or illustrations shown anywhere in the product or our marketing are for illustration only, are not predictions, and should not be relied upon as a basis for any decision.

Past performance is not indicative of future results

Any historical, backtested, simulated, or hypothetical performance figures have inherent limitations and do not reflect actual trading. Backtested and simulated results are constructed with the benefit of hindsight and do not account for all real-world conditions (including liquidity, fees, slippage, and the emotional and operational factors of live trading). Past or hypothetical performance is not a guarantee of, and may bear no relationship to, future results.

Market risk

Equity prices are affected by company-specific events, sector and macroeconomic conditions, interest rates, volatility, liquidity, news, and broad market sentiment. Markets can gap, move sharply, or become illiquid with little or no warning. Trading halts, circuit breakers at the exchange or market level, volatility auctions, and other market mechanics can prevent orders from being filled at expected prices — or at all.

Execution and liquidity risk

Orders Zap submits may be filled at prices different from those expected (slippage), may be partially filled, or may not be filled at all. Quoted or last-traded prices may differ from execution prices. Order routing, queue position, market hours, and your broker's execution practices all affect outcomes. Zap does not control order routing or execution — your broker does.

Technology and operational risk

Zap depends on software, third-party services, network connectivity, and external systems that can fail, be delayed, be interrupted, or behave unexpectedly. This includes, without limitation: the Anthropic AI models used to generate trade ideas; Robinhood's Agentic trading interface and brokerage systems; our hosting, database, and payment providers; and the public internet. Bugs, outages, latency, data errors, model errors, and degraded or missing market data can cause missed trades, unintended trades, delayed trades, or trades at unfavorable prices. Where data appears malformed or unavailable, Zap is designed to stop rather than guess ("fail closed"), but no system can eliminate technology risk.

Third-party dependency risk

Zap relies on Robinhood as the broker and on Robinhood's Agentic program, which is offered on a limited/beta basis and is governed by Robinhood's own terms. Changes to, restrictions on, suspension of, or termination of that program — or of any third-party provider — are outside our control and can interrupt or end Zap's ability to trade your connected wallet. Your relationship with your broker is governed by your agreement with that broker.

Concentration and strategy risk

Depending on the risk level you select, a meaningful portion of the connected wallet may be allocated to a small number of positions or to a single security. Higher risk levels permit larger positions, larger per-name concentration, and a larger daily loss before the circuit breaker engages. More concentrated or more active postures can produce larger and faster losses.

Tax and regulatory risk

Trading generates taxable events. Frequent trading can have meaningful tax consequences, including short-term capital gains treatment and wash-sale considerations. Zap does not provide tax advice. You are responsible for the tax consequences of trading in your account, including any reporting. The legal and regulatory treatment of AI-driven and autonomous trading is evolving and may change.

Part 2 — Not Investment Advice

Zap is software, not an investment adviser, and nothing Zap provides is investment advice, a recommendation, or a solicitation to buy or sell any security. Zap executes a strategy and risk configuration that you select and authorize; it does not assess whether any security, strategy, allocation, or risk level is suitable for you, your financial situation, your objectives, or your risk tolerance. Trade ideas are generated algorithmically — including by AI language models that can be inaccurate, incomplete, or simply wrong — and are constrained by the limits you set; they are not personalized advice.

Zap and Zap are not your fiduciary and do not owe you fiduciary duties unless and until Zap is registered as an investment adviser and a written advisory relationship is established with you. Zap is not currently registered as an investment adviser or broker-dealer [CONFIRM / UPDATE with counsel]. You are solely responsible for your investment decisions, including your decision to use Zap, the strategy and risk level you choose, whether to fund the connected wallet, and whether to enable autonomous trading. If you need advice, consult a licensed financial professional, tax adviser, or attorney before using Zap.

Part 3 — Automated and Autonomous Trading Disclosure

How Zap trades

Zap operates in one of two modes that you control:

• Semi-automatic (default). The agent proposes trades; you approve each one with a one-tap action. Proposals expire if you do not act, so an unapproved proposal will not execute. Nothing is bought or sold in the connected wallet without your specific approval.
• Fully autonomous (gated). When enabled, the agent decides and executes trades on its own, without asking you to approve each one. You will not see or sign off on individual orders before they are placed. Full-auto is off by default and only becomes available after you complete identity/eligibility verification, the feature is enabled for your account, and you provide a separate, explicit, recorded acknowledgment. Until then, your account runs in semi-automatic mode.

Guardrails reduce risk — they do not remove it

Every candidate order — in both modes — passes through hard limits enforced in Zap's own backend, independently of the AI, before any order reaches your broker. These limits are tied to the risk level you choose and include a maximum percentage of the wallet per trade, a per-symbol concentration cap, a daily trade cap, and a daily-loss circuit breaker that automatically pauses the agent for the day when your loss threshold is crossed. Oversized AI suggestions are clamped down or rejected, and the engine fails closed on bad or missing data.

These guardrails are risk-mitigating, not risk-eliminating. They limit the size and frequency of trades and cap a single day's loss at the configured threshold; they do not prevent losses, do not guarantee the circuit breaker will trigger at an exact price or value, do not protect against gaps, halts, slippage, or overnight and multi-day moves, and do not ensure profitability. You can still lose a substantial portion — or in adverse cases all — of the connected wallet even with guardrails in force.

Scope: only the ring-fenced wallet

Zap only ever trades the dedicated Robinhood Agentic wallet you connect and fund. It cannot access, trade, or withdraw from the rest of your Robinhood holdings or any other account, and it cannot move money out to you or to any third party. The most you can lose through Zap's trading is limited to the value of the assets in that connected wallet (plus applicable fees and taxes). You remain responsible for funding decisions and for the wallet itself.

Your responsibilities and controls

You are responsible for monitoring the connected wallet and for the configuration you select. You can switch back to semi-automatic, pause the agent, or disconnect at any time, subject to orders already submitted to or being processed by your broker, which may not be cancelable. Acknowledging full-auto means you accept that trades will be executed without your per-trade review or approval, within the guardrails then in effect.

AI-specific limitations

The AI models that generate trade ideas can produce outputs that are inaccurate, biased, outdated, or otherwise flawed, and may behave unpredictably. Zap's design constrains and reviews those outputs against your guardrails, but it cannot guarantee that any given trade idea is sound or that the resulting trade will be profitable.

---

These disclosures are part of and incorporated into the Zap Terms of Service. Capitalized terms not defined here have the meanings given in the Terms.