Tradewink Regulatory Disclosures

Complete disclosure document — Last updated: September 29, 2026 — Agreement version 4.1

I. Regulatory Status

Tradewink is owned and operated by Tradewink LLC, a California limited liability company. Tradewink LLC is not registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC) or any state, is not a broker-dealer, is not a member of the Financial Industry Regulatory Authority (FINRA) or SIPC, and is not registered with the Commodity Futures Trading Commission (CFTC) or the National Futures Association (NFA) in any capacity.

Tradewink publishes software tools, research, and algorithmic signals that are general and impersonal — not investment advice, and not tailored to any person's financial situation. Use of the Service does not create a fiduciary, advisory, brokerage, or agency relationship between Tradewink and any user.

Users connect their own brokerage accounts via API credentials. Tradewink sends orders to the user's own broker only as the user confirms them or as automation settings the user chose authorize. Tradewink never holds or can withdraw user funds. The user's broker — not Tradewink — executes and clears orders, holds assets, and is responsible for its own regulatory obligations.

You can verify your broker's registration status at FINRA BrokerCheck.

II. Terms of Service

1. Agreement & Parties

These Terms of Service ("Terms") are a binding agreement between you and Tradewink LLC, a California limited liability company ("Tradewink," "we," "us," or "our"). Tradewink LLC owns and operates the Tradewink website, web dashboard, Discord bots, mobile apps, APIs, email and webhook alerts, and related services (together, the "Service"). By creating an account, accepting these Terms, or using the Service, you agree to these Terms and to our Privacy Policy. IMPORTANT: Section 28 contains a binding individual arbitration agreement and class action waiver that affect how disputes are resolved. Please read it carefully.

2. Eligibility

You must be at least 18 years old and able to form a binding contract to use the Service. You may not use the Service if you are barred from doing so under the laws of the United States or your jurisdiction, or if you are located in, or a resident of, a country or region subject to comprehensive U.S. sanctions, or listed on any U.S. government list of prohibited or restricted parties. The Service is operated from the United States. We make no representation that the Service is lawful or appropriate outside the United States, and if you use it elsewhere you are responsible for complying with local law.

3. Nature of Service

Tradewink is software. It publishes AI-generated and algorithmic market analysis, research, alerts, and trade signals, and provides a paper-trading simulator so you can test ideas without real money. Public subscription plans include paper trading only; separately approved private beta accounts may enable live broker order submission (see Section 6). Signals and analysis are produced from market data and model output and are not tailored to your financial situation, investment objectives, tax position, or risk tolerance. They are for informational and educational purposes and are not a guarantee or personalized recommendation. AI-generated output may be inaccurate, incomplete, delayed, or based on flawed data, and algorithmic models can and do malfunction. The analysis is not financial advice.

4. No Guarantee of Accuracy or Performance

We do not guarantee the accuracy, completeness, timeliness, or profitability of any analysis, signal, prediction, backtest, or statistic. Past performance, including live, paper-trading, and backtested or hypothetical results, does not guarantee or predict future results. Hypothetical and backtested results have inherent limitations: they are prepared with the benefit of hindsight, do not involve financial risk, and may not reflect the impact of liquidity, slippage, fees, or other market factors. Markets are unpredictable and you may lose some or all of the money you trade.

5. Regulatory Status: Not an Adviser or Broker

Tradewink LLC is not registered as an investment adviser with the U.S. Securities and Exchange Commission (SEC) or any state, is not a broker-dealer and is not a member of FINRA or SIPC, and is not registered with the Commodity Futures Trading Commission (CFTC) or the National Futures Association (NFA) in any capacity, including as a commodity trading advisor or commodity pool operator. Tradewink does not hold, custody, or have the ability to withdraw your money or assets. For approved live beta users, its software can submit orders to a connected broker; the broker executes and clears them. Regulatory obligations depend on the actual services and arrangements, not solely on this description. You can check your broker's registration at FINRA BrokerCheck (brokercheck.finra.org).

6. Trading Modes & Your Trading Decisions

Public subscription plans provide paper trading, not live trading. Paper orders are simulated or sent to a connected paper or sandbox account and do not use real money. A limited number of separately approved private beta accounts may connect a live broker and enable real-money order submission. Live access is not included in any public plan. For an approved beta account, the Service can submit, modify, and cancel real orders through the connected broker according to the enabled features and account settings; losses can occur. Live trading requires a separate in-product risk acknowledgment and may be disabled. Paper results are hypothetical: simulated fills can differ materially from real fills, and paper performance does not predict real-money results. You are responsible for your broker account, settings, orders, and trading decisions.

7. Brokerage Connections & Scope of Account Access

You may connect a supported paper-trading or sandbox account. Separately approved private beta users may also connect a supported live brokerage account. When you enable trading features, you authorize the Service to submit, modify, and cancel orders in the selected account, read its balances, positions, orders, and trade history, and manage protective stop and exit orders according to your settings. In live mode these are real orders and can result in losses. The Service cannot withdraw funds, transfer assets to another account, or change your account credentials. Your API keys are encrypted at rest and used only to operate the features you enable. You may revoke access by removing your keys in the Service and revoking them at your broker. Your relationship with your broker is governed by your agreement with that broker.

8. Risk Acknowledgment

Trading stocks, options, futures, forex, digital assets, event contracts, and other instruments involves substantial risk of loss and is not suitable for everyone. You acknowledge that: you trade with your own money and at your own risk; you have read and understand the risks of the products you trade; losses can exceed your deposit in leveraged products; and you are solely responsible for evaluating whether any trade is appropriate for you. Consider consulting a licensed financial professional before trading.

9. Subscriptions, Free Trials, Auto-Renewal & Cancellation

Some features require a paid subscription. Prices, billing period, and included features are shown before you subscribe. PAID SUBSCRIPTIONS RENEW AUTOMATICALLY at the end of each billing period at the then-current price, and your payment method will be charged until you cancel. If your plan includes a free trial, you must provide a payment method; unless you cancel before the trial ends, your subscription converts to a paid subscription and you are charged the price shown at sign-up on the day the trial ends. You can cancel online at any time from the billing page of your dashboard, and cancellation takes effect at the end of the current billing period; you keep access until then. Except where required by law, fees are non-refundable and we do not provide partial-period refunds, but you may request a refund from the billing page and we review each request. We will give you at least 30 days' notice before a price increase applies to your subscription, and you can cancel before it takes effect. Prices exclude applicable taxes. Payments are processed by our payment processor (Stripe), and we do not store your full card number.

10. Privacy & Data

Our Privacy Policy explains what we collect and how we use it, and is part of these Terms. In short: we store your account details, watchlists, preferences, encrypted brokerage credentials, and trading activity; we do not sell your personal information; and to answer your questions and generate analysis we send relevant context to third-party AI model providers. When you use the in-app assistant, that context can include your positions, balances, profit and loss, and recent trades so the assistant can answer questions about your account. We never send your brokerage credentials, password, or payment card details to AI model providers.

11. Acceptable Use, Prohibited Uses & Insider Trading

You agree not to: use the Service for any unlawful purpose, including trading on material non-public information, market manipulation, spoofing, layering, or wash trading; circumvent trading, margin, or regulatory restrictions; resell, redistribute, publish, or commercially exploit signals or other content without our written permission; share your account or API access; scrape, reverse engineer, or interfere with the Service, or probe its security; or use the Service to build a competing product. You represent that information you provide is accurate and lawfully obtained. Tradewink's analysis is based on publicly available data and does not use material non-public information.

12. Intellectual Property & License

The Service, including its software, models, content, signals, text, graphics, logos, and the Tradewink and Winkie names and marks, is owned by Tradewink LLC or its licensors and is protected by intellectual property laws. Subject to these Terms, we grant you a limited, revocable, non-exclusive, non-transferable license to use the Service for your own personal, non-commercial purposes. If you send us feedback or suggestions, you allow us to use them without obligation to you. All rights not expressly granted are reserved.

13. Third-Party Services, Data & Conflicts of Interest

The Service relies on third parties, including brokers and exchanges, market data vendors, AI model providers, hosting, authentication, payment, messaging, and analytics providers. We do not control and are not responsible for third-party services, their availability, accuracy, or terms, and your use of them may be subject to their own terms and privacy policies. Market data may be delayed, incomplete, or incorrect. Links to third-party sites are provided for convenience and are not endorsements. Unless we say so expressly, Tradewink is not affiliated with, and does not receive compensation from, any broker or exchange it integrates with. Tradewink's owners and personnel may use the Service in their own accounts and may hold or trade positions in instruments that appear in signals or analysis. Signals are generated by the same automated process for everyone and are not changed to benefit those positions.

14. AI Model Limitations

Tradewink uses third-party large language models (such as models from Anthropic, OpenAI, and Google, routed through OpenRouter) to generate analysis, signals, conviction scores, and explanations. These are general-purpose models, not purpose-built forecasting systems. You acknowledge that: (a) they can produce plausible-sounding but incorrect output ("hallucinations"), including wrong tickers, prices, dates, or news events; (b) confidence and conviction scores describe how well a setup matches the model's criteria and are NOT a probability of profit — a 95% confidence signal is not 95% likely to be profitable; (c) backtest and paper-trading results are simulations subject to hindsight bias, overfitting, survivorship bias, and execution assumptions that may not hold in live markets; (d) "self-improving" means the system updates itself without manual intervention, not that it gets better over time, and retrained models can overfit to conditions that have ended; and (e) AI output is a starting point for your own review, not a recommendation to act. For more detail, visit https://www.tradewink.com/ai-limitations.

15. Pattern Day Trader Disclosure

Effective June 4, 2026 (SEC Release No. 34-105226; FINRA SR-FINRA-2025-017), FINRA Rule 4210 was amended to eliminate the Pattern Day Trader (PDT) designation and the legacy $25,000 minimum equity requirement for day trading. The new standard applies risk-based intraday margin with a minimum account equity of $2,000. Firms have until October 20, 2027 to implement the change; during this transition period your broker may still apply PDT-style tracking or equity requirements — confirm the rules in effect at your own broker. Tradewink does not enforce a PDT round-trip quota and does not block a fourth day trade. Tradewink evaluates entries against broker-reported buying power, trading status, and margin requirements, together with configurable operational risk limits (such as a maximum number of trades per day and a daily-loss circuit breaker) that are throughput and risk controls, not regulatory day-trading gates. You are solely responsible for understanding and complying with the intraday margin and day-trading rules currently in effect at your broker. For current guidance, see FINRA Regulatory Notice 26-10 and your broker's current day-trading policy.

16. Order Routing, Best Execution & Payment for Order Flow

Orders the Service generates go to a simulator, a connected paper or sandbox account, or, for separately approved private beta users who enable live mode, a connected live brokerage account. Tradewink does not route orders between users or execute or clear broker orders. For large orders above configurable thresholds, the Service may split an order over time (TWAP slicing) or, where your broker supports it, use the broker's own algorithms. Tradewink does not receive payment for order flow or other compensation from brokers, market makers, or trading venues. Your broker executes real-money orders and is responsible for its applicable obligations. We track execution metrics such as slippage, fill rate, and latency to improve the Service.

17. Tax Considerations & Wash Sale Notice

Automated and frequent trading can create taxable events and may trigger the wash sale rule under Internal Revenue Code Section 1091, which disallows a loss when you buy the same or a substantially identical security within 30 days before or after selling it at a loss. The Service may warn you about potential wash sales, but warnings are best-effort and will miss cases (for example, trades in other accounts, substantially identical securities, or options). You are solely responsible for your taxes and recordkeeping. Tradewink does not provide tax advice; consult a qualified tax professional.

18. Cryptocurrency & Digital Assets

If you use the Service with cryptocurrencies or other digital assets, you acknowledge that: digital assets are highly volatile and may lose all value; markets operate 24/7, so automation may act at any time; regulatory treatment varies by jurisdiction, is evolving, and some assets may be treated as securities or commodities; Tradewink does not custody any digital assets and all trades occur at your connected exchange or broker; and you are solely responsible for complying with the laws that apply to you.

19. Margin & Leverage Risk

If your account uses margin or leverage: gains and losses are amplified; you can lose more than you deposited; your broker may issue a margin call or liquidate positions without notice; and forced liquidation in volatile markets can produce losses exceeding your account balance. Tradewink does not monitor your margin requirements and is not responsible for margin calls or liquidations. Understand margin trading fully before enabling automation on a margin account.

20. Options Trading Risk

Options involve significant risk and are not appropriate for all investors. Options can expire worthless, resulting in a total loss of the premium paid; some strategies have unlimited loss potential; short options carry assignment risk; and limited liquidity can produce poor fills. Tradewink's options analysis is based on models that may not account for all market conditions. Before trading options, read the Options Clearing Corporation publication "Characteristics and Risks of Standardized Options," available at theocc.com.

21. Futures, Forex & Event Contracts

The Service can be used with futures, retail foreign exchange (forex), and event-contract markets through your connected broker or exchange. These products are regulated primarily by the Commodity Futures Trading Commission (CFTC) and the National Futures Association (NFA) rather than the SEC, and their risks differ from equities. You acknowledge that: futures and forex are leveraged, losses can exceed your deposited funds, and you may have to meet margin calls on short notice; forex trades over-the-counter, not on a regulated exchange, and your counterparty is your broker; event contracts are binary and can expire worthless; the legality and availability of event contracts vary by state and are subject to ongoing litigation and rulemaking; and overnight gaps, limit moves, thin sessions, and contract roll and expiration can cause losses larger than modeled. Tradewink is not registered with the CFTC or NFA in any capacity, including as a futures commission merchant, retail foreign exchange dealer, introducing broker, commodity trading advisor, or commodity pool operator. Its analysis of these products is general and not tailored to any person. Before trading them, read the CFTC and NFA risk disclosures your broker must provide, including the futures risk disclosure statement under CFTC Regulation 1.55 and, for forex, the disclosure required by CFTC Regulation 5.5.

22. Changes, Suspension & Beta Features

We may change, suspend, or discontinue any part of the Service at any time. Features labeled beta, preview, or experimental may be incomplete, change without notice, or be withdrawn, and are provided with no commitment of availability. If we discontinue a paid feature you are currently paying for, we will give you notice and, where appropriate, a prorated refund.

23. Disclaimer of Warranties

THE SERVICE AND ALL CONTENT, SIGNALS, AND OUTPUT ARE PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING ANY WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, NON-INFRINGEMENT, ACCURACY, OR UNINTERRUPTED OR ERROR-FREE OPERATION. WE DO NOT WARRANT THAT ANY ORDER WILL BE SUBMITTED, FILLED, MODIFIED, OR CANCELLED AS INTENDED. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES, SO SOME OF THESE EXCLUSIONS MAY NOT APPLY TO YOU.

24. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW: (A) TRADEWINK LLC AND ITS MEMBERS, MANAGERS, EMPLOYEES, CONTRACTORS, AND AGENTS WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY TRADING LOSSES, LOST PROFITS, LOST OPPORTUNITIES, OR LOSS OF DATA, ARISING OUT OF OR RELATING TO THE SERVICE OR THESE TERMS, EVEN IF ADVISED OF THEIR POSSIBILITY; AND (B) OUR TOTAL LIABILITY FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THE SERVICE OR THESE TERMS WILL NOT EXCEED THE GREATER OF THE AMOUNT YOU PAID US IN THE 12 MONTHS BEFORE THE EVENT GIVING RISE TO THE CLAIM OR ONE HUNDRED U.S. DOLLARS (US$100). THESE LIMITATIONS DO NOT APPLY TO LIABILITY THAT CANNOT BE LIMITED UNDER APPLICABLE LAW, SUCH AS LIABILITY FOR OUR FRAUD, GROSS NEGLIGENCE, OR WILLFUL MISCONDUCT.

25. Assumption of Risk & Release

You voluntarily assume all risks of using the Service, including losses from: orders placed by automation you enabled; technical failures, software bugs, API outages, network interruptions, or data errors; market volatility, illiquidity, gaps, halts, or circuit breakers; and actions or failures of your broker, exchange, or other third parties. To the fullest extent permitted by law, you release Tradewink from claims for such losses, except claims arising from our fraud, gross negligence, or willful misconduct or that cannot be released under applicable law. We are not liable for delays or failures caused by events beyond our reasonable control, including exchange or broker outages, internet or hosting failures, natural disasters, or government action.

26. Indemnification

To the extent permitted by law, you agree to indemnify and hold harmless Tradewink LLC and its members, managers, employees, contractors, and agents from third-party claims, liabilities, damages, and costs (including reasonable attorneys' fees) arising from your violation of these Terms or of law, your misuse of the Service, or trades placed in your account.

27. Termination

You may stop using the Service and delete your account at any time. We may suspend or terminate your access if you violate these Terms, if required by law, or to protect the Service, other users, or third parties. When your access ends, your license ends, automation stops sending orders, and you should revoke your API keys at your broker; orders already sent to your broker may still execute. Sections that by their nature should survive termination (including 4, 5, 12, and 23 through 31) survive.

28. Dispute Resolution: Arbitration & Class Action Waiver

Informal resolution first: before starting arbitration, you and we agree to try to resolve any dispute informally for at least 60 days after one of us sends the other a written notice describing the dispute and the relief requested. Send notices to us at support@tradewink.com with the subject "Legal Notice." Binding arbitration: if the dispute is not resolved, any claim arising out of or relating to these Terms or the Service will be resolved by binding individual arbitration administered by the American Arbitration Association (AAA) under its Consumer Arbitration Rules (or, if you use the Service for a business, its Commercial Arbitration Rules), rather than in court. The Federal Arbitration Act governs this section. The arbitrator decides all issues about the scope and enforceability of this section, except that a court decides the class action waiver and mass-filing provisions below. Arbitration may be held by video or in the county where you live. Payment of filing and arbitrator fees follows the AAA rules. Exceptions: either party may bring an individual claim in small claims court, and either party may seek relief in court to stop infringement or misuse of intellectual property. CLASS ACTION WAIVER: YOU AND TRADEWINK MAY BRING CLAIMS ONLY IN AN INDIVIDUAL CAPACITY, NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY CLASS, COLLECTIVE, OR REPRESENTATIVE PROCEEDING, AND EACH OF US WAIVES THE RIGHT TO A JURY TRIAL. If 25 or more similar claims are filed by or with the help of the same counsel, they will be administered in batches of up to 25 claims, and the AAA's mass-arbitration procedures will apply. If the class action waiver is found unenforceable for a particular claim or request for relief (such as public injunctive relief), that claim or request will be severed and decided by a court after the individual arbitration ends, and the rest of this section still applies. Opt out: you may opt out of this arbitration agreement by emailing support@tradewink.com within 30 days after you first accept these Terms, with the subject "Arbitration Opt-Out" and your name and account email. Opting out does not affect the rest of these Terms. If we change this section, the change will not apply to a dispute we were notified of before the change.

29. Governing Law & Venue

These Terms are governed by the laws of the State of California and applicable U.S. federal law, without regard to conflict-of-law rules. Any claim not subject to arbitration will be brought exclusively in the state and federal courts located in Los Angeles County, California, and you and we consent to their personal jurisdiction, except that you may bring a small claims action in your county of residence.

30. Changes to These Terms

We may update these Terms. For material changes we will notify you in the Service, by email, or through Discord at least 14 days before the changes take effect, except for changes required by law or to address security, which may take effect immediately. Where we require it, you must accept the updated Terms to keep using trading and automation features. If you do not agree, stop using the Service and you may cancel your subscription. Changes do not apply retroactively.

31. General Terms & Contact

These Terms and the Privacy Policy are the entire agreement between you and us about the Service. If any provision is found unenforceable, it will be enforced to the maximum extent permitted and the rest will remain in effect. Our failure to enforce a provision is not a waiver. You may not assign these Terms without our consent; we may assign them in connection with a merger, acquisition, or sale of assets. You agree to receive notices and disclosures electronically. Questions and legal notices: Tradewink LLC, support@tradewink.com.

32. Acceptance & Electronic Signature

By typing your full legal name and selecting "Accept & Continue," you are signing these Terms electronically, agreeing to be bound by them, and confirming that you are at least 18 and have read and understood them, including the arbitration agreement and class action waiver in Section 28. Your electronic signature has the same legal effect as a handwritten signature. If you do not agree, you may decline and still use basic read-only features (analysis, charts, news), but you will not be able to enable trading or automation features. Effective September 29, 2026.

III. Privacy Policy

1. Who We Are

This Privacy Policy explains how Tradewink LLC ("Tradewink," "we," "us") collects, uses, and shares personal information when you use the Tradewink website, web dashboard, Discord bots, mobile apps, APIs, and email and webhook alerts (the "Service"). Tradewink LLC is responsible for your personal information. Contact us at support@tradewink.com.

2. Information We Collect

Information you give us: your name, email address, username, and an optional phone number when you create or authenticate an account; your Discord user ID and username if you link Discord; watchlists, alerts, trading preferences, and risk settings; brokerage or exchange API credentials if you connect an account (stored encrypted); messages you send to the in-app assistant, support requests, survey answers, and feedback; strategy publications, public ratings/reviews, report reasons and optional notes, and member block choices; and records of your acceptance of our terms, including the version, the time, and the name you typed as your electronic signature. Information from your connected broker: account balances, buying power, positions, orders, fills, and trade history. Billing information: our payment processor, Stripe, collects your card details; we receive only your plan, subscription status, payment amounts, and similar billing records, never your full card number. Information collected automatically: IP address, browser and device type, pages viewed, links and buttons clicked, referring pages, performance and error diagnostics, and session recordings (see Section 6); and, in our mobile app, push notification tokens and a device public key used to verify trade approvals.

3. How We Use Your Information

We use personal information to: provide and operate the Service; send orders to your broker that you confirm or that your automation settings authorize; generate analysis and answer your questions; process payments and manage subscriptions; send alerts, service notices, and, if you have not opted out, product updates and marketing email; secure the Service and prevent fraud and abuse, including screening submitted research text and reviewing content reports; debug problems and improve the Service; keep records of our agreements with you; and comply with law. We may use trade outcomes, including from your account, in de-identified or aggregated form to evaluate and improve our own strategies and models. We do not give your personal information to AI model providers to train their models.

4. AI Model Providers

To generate analysis and answer questions, we send prompts and context to third-party large language model providers, routed through OpenRouter to model providers such as Google, OpenAI, Anthropic, DeepSeek, and Qwen depending on your plan. If you bring your own key, requests go to the provider you choose under your own agreement with that provider. Most requests contain market data and general context only. When you use the in-app assistant, the context can include your positions, account balances, buying power, profit and loss, recent trades, risk settings, and the messages you write, so the assistant can answer questions about your account. We do not add stored brokerage credentials, passwords, or payment card details to AI prompts. Do not put these details or personal identifiers in chat messages or search queries, because the text you submit may be sent to external providers. Model providers may process this data in the United States or other countries under their own terms.

5. Service Providers We Use

We share personal information with service providers that operate parts of the Service for us, only as needed for that purpose: Clerk (sign-in and account management); Stripe (payments); OpenRouter and the AI model providers described above; brokers, exchanges, and SnapTrade (when you connect an account and send orders); Discord (bot messages); Resend (email delivery); Apple Push Notification service (mobile notifications); Fly.io, Neon, and Cloudflare (hosting, database, and network delivery); Sentry (error tracking); Axiom (application log storage); and PostHog (product analytics and session recording, see Section 6). PostHog receives page views, feature usage, performance and error diagnostics, subscription tier, checkout status, and purchase amount. PostHog does not receive broker credentials, order instructions, positions, portfolio balances, or trade history. Market data vendors (such as Polygon.io, Finnhub, FRED, and SEC EDGAR) receive ticker and data requests. Research search providers, including Tavily and DuckDuckGo, receive search queries; strategy search results may also be processed by AI providers. The iOS app asks for consent before AI chat or online strategy search. Do not include personal identifiers or credentials in a search query.

6. Analytics, Session Recording & Cookies

We use cookies and similar browser storage to keep you signed in, remember your settings, and measure how the Service is used. We use PostHog session recording, which captures how pages are used (for example page content, clicks, scrolling, and mouse movement) so we can find and fix problems. Text you type into form fields is masked, and sensitive areas are excluded, before a recording is sent. We do not use advertising cookies or third-party advertising trackers, and we do not use analytics data to target ads. You can block or delete cookies and browser storage in your browser settings; some features, such as staying signed in, will not work without them.

7. How We Share Information

We do not sell your personal information, and we do not share it for cross-context behavioral advertising. We share personal information only: with the service providers described above; with your broker or exchange, to carry out actions you authorize; if required by law, subpoena, or court order, or to protect the rights, safety, and security of our users, the public, or Tradewink; in connection with a merger, acquisition, financing, or sale of assets, subject to this Policy; and with your consent. When you publish a strategy or submit a public review, its content and display attribution can be seen by other users. Marketplace review responses use a member alias instead of a raw account ID. Content reports and block choices are not public: we keep account identifiers server-side to apply them and allow authorized staff to review report reasons and notes. We do not share personal information with unaffiliated third parties for their own marketing.

8. Data Security

Brokerage API credentials are encrypted at rest with authenticated encryption (Fernet) using keys derived with PBKDF2-HMAC-SHA256 (600,000 iterations) and a per-record salt, are never stored in plaintext, and are decrypted only when needed to talk to your broker. Data is sent over encrypted connections (TLS 1.2 or higher). We use access controls, log sanitization that strips API keys, and security monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. We do not currently hold a SOC 2 or similar third-party certification, and no independent security assessment has been completed as of the date of this Policy.

9. Data Retention

We keep personal information while your account is active and afterwards only as long as reasonably needed to provide the Service, keep an accurate record of the instructions sent to your broker and of your agreements with us, resolve disputes, prevent fraud and abuse, and meet legal, tax, and accounting obligations. When you delete your account, we delete or de-identify your personal information except for records we must or reasonably need to keep for those purposes. Account data cleanup removes your authored marketplace listings and reviews, marketplace subscriptions, your reports, reports/moderation state for deleted content, and member block records involving the verified account identities. Moderation audit events retain a pseudonymous member alias, content ID, action and timestamp, without raw account IDs or report notes; pseudonymous records are not necessarily anonymous. No automatic expiry is currently configured for that audit. An incomplete cleanup is reported for retry or support. Authentication identity removal is a separate step, and signing out alone does not delete an identity. Session recordings and analytics are retained according to our analytics provider's retention settings.

10. Security Incidents

If we learn of a security incident that affects your personal information or brokerage credentials, we will investigate and contain it promptly, notify affected users without unreasonable delay and within the time required by applicable law, rotate any affected encryption keys, advise affected users to revoke and replace their broker API keys, and notify regulators where the law requires.

11. Your Rights & Choices

You can: access and export the personal information we hold about you; correct inaccurate information; delete your account and personal information (subject to Section 9); revoke broker access at any time by removing your keys in the Service and at your broker; and unsubscribe from marketing email using the link in any marketing message (we will still send service and billing notices). To make a request, email support@tradewink.com. We will verify your identity by confirming control of the email address or Discord account on your Tradewink account, and may ask for more information for sensitive requests.

12. California Privacy Rights

If you are a California resident, you have the right to: know what personal information we collect, use, and disclose; delete it; correct it; opt out of its sale or sharing (we do not sell or share personal information); limit the use of sensitive personal information (we use account credentials and similar sensitive information only to provide the Service); and not be discriminated against for exercising these rights. You may use an authorized agent, who must provide proof of authorization. We respond to verified requests within 45 days, as the law requires. Under California Civil Code Section 1798.83, you may also ask whether we disclosed personal information to third parties for their direct marketing; we do not.

13. European & UK Privacy Rights

If you are in the European Economic Area or the United Kingdom, we process personal information to perform our contract with you, for our legitimate interests in operating, securing, and improving the Service, to comply with legal obligations, and, where required, with your consent, which you may withdraw at any time. You have the right to access, correct, erase, restrict, or object to processing of your personal information, to data portability, and to complain to your local data protection authority.

14. International Data Transfers

The Service is operated from the United States, and your information is processed in the United States and in other countries where our service providers operate. Where the law requires, transfers of personal information from the EEA or UK rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses included in our service providers' data processing terms.

15. Children

The Service is only for people aged 18 or older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has given us personal information, contact us and we will delete it.

16. Law Enforcement & Legal Process

We disclose personal information to government authorities only in response to valid legal process such as a subpoena, court order, or warrant, or when we believe in good faith that disclosure is needed to prevent imminent harm. Where the law allows, we will make reasonable efforts to notify you before disclosing your information.

17. Changes to This Policy

We may update this Policy. If we make material changes, we will notify you in the Service, by email, or through Discord before they take effect, and update the date below.

18. Contact

Questions or requests about this Policy or your data: Tradewink LLC, support@tradewink.com. By mail: Tradewink LLC, 411 E Huntington Dr, Ste 107 #1334, Arcadia, CA 91006.

IV. Risk Disclosures

Trading Risk. Trading stocks, options, futures, cryptocurrency, and other securities involves substantial risk of loss, including the possible loss of your entire invested capital. Past performance of any strategy, signal, or algorithm does not guarantee future results. Markets are inherently unpredictable.

Autonomous Trading Risk. If you enable autonomous or semi-autonomous trading features, trades will be placed in your brokerage account automatically based on AI decisions. You are solely responsible for all trades executed in your account. Technical failures, API outages, market conditions, data feed errors, or software bugs may result in unintended trades, missed exits, or losses. You should only enable autonomous trading with capital you can afford to lose.

AI Limitations. All analysis, strategies, alerts, and trade signals generated by Tradewink are produced by artificial intelligence and algorithmic models. AI-generated recommendations may be inaccurate, incomplete, delayed, or based on flawed data. Algorithmic models can and do malfunction. There is no guarantee of returns, profitability, or any particular outcome from using this service.

No Investment Advice. Tradewink's outputs are provided for informational and educational purposes only and do not constitute financial advice, investment advice, trading advice, or any other form of professional advice. You should consult a qualified financial professional before making investment decisions.

Force Majeure. Tradewink shall not be liable for losses arising from events beyond its reasonable control, including but not limited to: exchange outages, broker API downtime, market circuit breakers or trading halts, internet service disruptions, natural disasters, regulatory actions, or cyberattacks.

V. Day Trading Risk Disclosure

This disclosure is modeled on the day-trading risk disclosure statement that FINRA Rule 2270 requires broker-dealers to give their customers. Tradewink is not a FINRA member; your broker provides its own required disclosures.

Pattern Day Trader (PDT) Classification. Historically, executing four or more day trades within five business days in a margin account could cause your broker to designate you as a Pattern Day Trader under FINRA Rule 4210, which required a minimum equity of $25,000 to continue day trading. On April 14, 2026 the SEC granted accelerated approval to FINRA's amendment removing the $25,000 minimum-equity requirement and the Pattern Day Trader designation, effective June 4, 2026, replacing them with a modern intraday-margin standard under the amended FINRA Rule 4210. During a transition period your broker may continue to apply legacy PDT treatment or may apply updated equity, margin, or day-trading buying-power requirements that differ from the legacy $25,000 threshold. You are solely responsible for understanding and complying with the day-trading rules currently in effect at your broker.

Autonomous Trading and Intraday Margin. By enabling Tradewink's autonomous day trading features, you acknowledge that the system may execute multiple intraday transactions subject to your broker's live buying-power, margin, and account-restriction controls. Tradewink does not impose a federal PDT round-trip quota; it uses broker-reported capacity and trading blocks together with configurable operational risk limits. Firms may phase in the amended FINRA framework through October 20, 2027, so you remain responsible for understanding your broker's current implementation.

Day Trading Risks. Day trading can be extremely risky. You should be prepared to lose all of the funds that you use for day trading. You should not fund day trading activities with retirement savings, student loans, second mortgages, emergency funds, or funds set aside for other purposes. Day trading on margin involves additional risks, as borrowing increases both potential gains and potential losses.

Margin Requirements. If you trade on margin, your broker may force the sale of securities in your account without prior notice to meet a margin call. You are not entitled to an extension of time on a margin call. You may lose more than your initial investment when trading on margin.

VI. Order Routing & Execution Disclosure

Order Routing. Tradewink routes orders directly to the brokerage you have connected. It does not act as an intermediary, market maker, or alternative trading system (ATS). All orders are submitted directly to your broker via their API.

Best Execution. Your broker — not Tradewink — is responsible for final order execution and best-execution obligations under applicable regulations (SEC Rule 606, Regulation NMS). Tradewink tracks execution quality metrics (slippage, fill rate, latency) internally for service improvement purposes.

Order Slicing. For large orders exceeding configurable thresholds, Tradewink may use software-based TWAP (Time-Weighted Average Price) slicing to reduce market impact. Where supported by your broker (e.g., IBKR VWAP), native broker algorithms may be used.

Payment for Order Flow (PFOF). Tradewink does not receive payment for order flow from any broker, market maker, or third party. Tradewink does not route orders between users and does not operate as an alternative trading system.

VII. Tax Considerations & Wash Sale Notice

Wash Sale Rules. Autonomous and semi-autonomous trading may trigger wash sale rules under IRS Section 1091. A wash sale occurs when you sell a security at a loss and repurchase the same or a substantially identical security within 30 calendar days before or after the sale. In a wash sale, the loss is disallowed for tax purposes and added to the cost basis of the replacement shares.

Cross-Account Wash Sales. Tradewink does not track wash sales across your other brokerage accounts. If you hold the same or substantially identical securities in multiple accounts, you are responsible for tracking wash sale implications across all of them.

Best-Effort Warnings. Tradewink provides optional wash sale warnings when it detects potential wash sale situations, but these warnings are best-effort and may not catch all scenarios (e.g., trades in other accounts, substantially identical securities, or options).

Tax Professional. You are solely responsible for tracking wash sales and complying with all tax obligations. Consult a qualified tax professional for advice on your specific situation. Tradewink does not provide tax advice.

VIII. Complaints & Regulatory Contacts

Tradewink Support. For questions, issues, or complaints about Tradewink's software, contact us at support@tradewink.com or via the contact form at tradewink.com/contact. We aim to respond to all inquiries within 2 business days.

Execution-Related Issues. For problems related to order execution, fills, account access, margin, or custody of funds, contact your broker directly. Tradewink does not custody funds or execute orders — your broker does.

FINRA Investor Complaint Center. If you have a complaint about your broker or a securities-related dispute, you may file a complaint with FINRA at finra.org/investors/need-help/file-a-complaint or call (240) 386-4357.

SEC Complaint Portal. To report potential securities law violations or file a complaint with the SEC, visit sec.gov/tcr.

FINRA BrokerCheck. Verify your broker's registration, licensing, and disciplinary history at brokercheck.finra.org.

This document constitutes the complete regulatory disclosure for Tradewink, published by Tradewink LLC, as of September 29, 2026.

Tradewink LLC · 411 E Huntington Dr, Ste 107 #1334, Arcadia, CA 91006

Agreement version 4.1 — Document generated from tradewink.com/disclosures