Tradewink Regulatory Disclosures
Complete disclosure document — Last updated: April 2026 — Agreement version 3.4
Tradewink Inc. — Regulatory Disclosure Document — April 2026 — Agreement v3.4
Generated from https://www.tradewink.com/disclosures
I. Regulatory Status
Tradewink and its operators are not registered as investment advisors under the Investment Advisers Act of 1940, broker-dealers under the Securities Exchange Act of 1934, or with the Financial Industry Regulatory Authority (FINRA), the U.S. Securities and Exchange Commission (SEC), or any state securities regulator.
Tradewink does not hold any securities licenses. The platform provides software tools and algorithmic trading signals — not investment advice. Use of this service does not create a fiduciary, advisory, or agency relationship between Tradewink and any user.
Users connect their own brokerage accounts via API credentials. Tradewink acts as a software tool executing instructions on behalf of the user through the user's own brokerage account. The user's broker — not Tradewink — is responsible for order execution, custody of assets, and regulatory compliance.
You can verify your broker's registration status at FINRA BrokerCheck.
II. Terms of Service
1. Nature of Service
Tradewink is an AI-powered stock analysis and trading assistant. All analysis, strategies, alerts, and trade signals generated by Tradewink are produced by artificial intelligence and algorithmic models. They 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. 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.
2. No Guarantee of Accuracy or Performance
AI-generated analysis, predictions, strategies, and trade signals may be inaccurate, incomplete, or outdated. Past performance of any strategy or signal does not guarantee future results. Markets are inherently unpredictable and you may lose some or all of your invested capital.
3. Autonomous Trading Disclaimer
If you enable autonomous or semi-autonomous trading features (including day trading, strategy execution, and exit management), you acknowledge that: 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, or software bugs may result in unintended trades or losses; you should only enable autonomous trading with capital you can afford to lose.
4. Brokerage API Keys
Your brokerage API keys are encrypted at rest and transmitted securely. However, by providing your keys you grant Tradewink permission to place orders, query account data, and manage positions on your behalf. You may revoke access at any time by removing your keys.
5. Not a Registered Investment Advisor
Tradewink and its operators are not registered as investment advisors under the Investment Advisers Act of 1940, broker-dealers under the Securities Exchange Act of 1934, or with FINRA, the SEC, or any state securities regulator. We do not hold any securities licenses. The platform provides software tools and algorithmic signals — not investment advice. Use of this service does not create a fiduciary, advisory, or agency relationship. You can verify your own broker's registration status at FINRA BrokerCheck (brokercheck.finra.org).
6. Risk Acknowledgment
Trading stocks, options, and other securities involves substantial risk of loss. You acknowledge that: you are trading with your own funds and at your own risk; you have read and understand the risks of trading; you will not hold Tradewink, its developers, or operators liable for any trading losses; you are of legal age to trade securities in your jurisdiction.
7. Data & Privacy
Tradewink stores your Discord user ID, watchlist, trading preferences, and encrypted brokerage credentials. We do not sell your data to third parties. AI analysis may be processed by third-party LLM providers (e.g., Anthropic). No personally identifiable financial data is shared with LLM providers.
8. Limitation of Liability
To the maximum extent permitted by law, Tradewink and its operators shall not be liable for any direct, indirect, incidental, special, consequential, or exemplary damages arising from your use of this service, including but not limited to trading losses, lost profits, or data loss.
9. Waiver of Legal Claims
You waive any right to bring legal action, claims, lawsuits, or demands against Tradewink, its operators, contributors, affiliates, or any associated parties for any losses, damages, or harm — whether financial, consequential, incidental, or otherwise — arising from your use of this product or reliance on its outputs. This waiver applies to the fullest extent permitted by applicable law.
10. Indemnification
You agree to indemnify and hold harmless Tradewink, its creator, and all associated parties from any claims, liabilities, damages, costs, or expenses (including legal fees) arising from your use of the service, your trading activities, or any violation of these terms on your part.
11. No Warranty
Tradewink is provided on an "AS IS" and "AS AVAILABLE" basis without warranties of any kind, whether express or implied, including but not limited to warranties of merchantability, fitness for a particular purpose, accuracy, or non-infringement.
12. Assumption of Risk
You voluntarily assume all risks associated with using Tradewink, including but not limited to: financial losses from trades executed by the system; losses caused by technical failures, software bugs, API outages, network interruptions, or data feed errors; losses resulting from market volatility, illiquidity, or adverse market conditions; and any unintended trades or missed exits due to system behavior. You acknowledge that autonomous trading systems can and do malfunction, and that no safeguard is foolproof. Tradewink shall not be liable for losses arising from force majeure events including but not limited to: exchange outages, broker API downtime, market circuit breakers or trading halts, internet service disruptions, natural disasters, regulatory actions, or any event beyond Tradewink's reasonable control.
13. Binding Arbitration & Class Action Waiver
Any dispute, claim, or controversy arising from or relating to these terms or your use of Tradewink shall be resolved exclusively through binding arbitration administered by the American Arbitration Association (AAA) under its Commercial Arbitration Rules, and not by a court or jury. You and Tradewink each waive the right to a trial by jury. You also waive the right to participate in any class action, collective action, or representative proceeding against Tradewink — all claims must be brought in your individual capacity only. The arbitrator may award the same relief that a court could, but only to the extent required to satisfy your individual claim. This arbitration agreement shall survive termination of your account or these terms.
14. Governing Law & Jurisdiction
These terms shall be governed by and construed in accordance with the laws of the State of California, United States, without regard to its conflict of law provisions. To the extent that arbitration is not applicable, you consent to the exclusive jurisdiction of the state and federal courts located in Los Angeles County, California.
15. Severability
If any provision of these terms is found to be unlawful, void, or unenforceable by a court or arbitrator, that provision shall be enforced to the maximum extent permissible, and the remaining provisions shall continue in full force and effect. The unenforceability of any single provision shall not affect the validity of the remaining terms.
16. Brokerage Account Recommendation
When connecting a brokerage, we strongly recommend creating a separate account dedicated to Tradewink. Do not use your main trading account — this keeps your primary portfolio safe and makes it easy to track performance.
17. Modification of Terms
We reserve the right to update these terms at any time. Continued use of Tradewink after changes constitutes acceptance of the updated terms. Material changes will be communicated via Discord.
18. Pattern Day Trader Disclosure
If you execute four or more day trades within five business days in a margin account, your broker may designate you as a Pattern Day Trader (PDT) under FINRA Rule 4210. PDT accounts are required to maintain a minimum equity of $25,000. If your account falls below this threshold, your broker may restrict your ability to day trade until the minimum is met. By enabling Tradewink's autonomous day trading features, you acknowledge that the system may execute multiple intraday round-trip trades that could trigger PDT classification on your brokerage account. Tradewink enforces a configurable PDT guard (default: 3 round-trips per 5-day window) but this safeguard is best-effort and does not replace your own monitoring. You are solely responsible for understanding and complying with PDT rules at your broker. For more information, see FINRA's Day-Trading Risk Disclosure Statement (FINRA Rule 2270).
19. Order Routing & Best Execution
Tradewink routes orders directly to the brokerage you have connected — it does not act as an intermediary, market maker, or alternative trading system. 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. Tradewink does not receive payment for order flow and does not route orders between users. Execution quality metrics (slippage, fill rate, latency) are tracked internally for service improvement. Your broker is responsible for final order execution and best-execution obligations under applicable regulations.
20. Payment for Order Flow Disclosure
Tradewink does not receive payment for order flow (PFOF) from any broker, market maker, or third party. Tradewink does not route orders between users and does not operate as an alternative trading system (ATS). All orders are submitted directly to your connected broker via their API.
21. Tax Considerations & Wash Sale Notice
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. 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). You are solely responsible for tracking wash sales and complying with tax obligations. Consult a qualified tax professional for advice on your specific situation.
22. Cryptocurrency & Digital Assets
If you use Tradewink to trade cryptocurrencies or digital assets, you acknowledge that: digital assets are highly volatile and may lose all value; cryptocurrency markets operate 24/7 and autonomous trading may execute at any time; regulatory treatment of digital assets varies by jurisdiction and is evolving; Tradewink does not custody any cryptocurrency — all crypto trades are executed through your connected broker or exchange; certain digital assets may be classified as securities by the SEC or commodities by the CFTC, and trading them may be subject to additional regulations; you are solely responsible for understanding and complying with applicable laws regarding digital asset trading in your jurisdiction.
23. Margin & Leverage Risk
If your brokerage account uses margin, you acknowledge that: trading on margin amplifies both gains and losses; you may lose more than your initial deposit; your broker may issue a margin call requiring you to deposit additional funds or liquidate positions without notice; forced liquidation during volatile markets may result in losses exceeding your account balance; Tradewink does not monitor your margin requirements and is not responsible for margin calls or forced liquidations. You should fully understand margin trading and its risks before enabling autonomous trading on a margin account.
24. Options Trading Risk
Options trading involves significant risk and is not appropriate for all investors. If you enable options trading through Tradewink, you acknowledge that: options can expire worthless, resulting in a total loss of the premium paid; certain options strategies involve unlimited loss potential; assignment risk exists for short options positions; options liquidity may be limited, resulting in unfavorable fills; Tradewink's AI analysis of options is based on models that may not account for all market conditions. Before trading options, you should read the Options Clearing Corporation (OCC) publication "Characteristics and Risks of Standardized Options" available at theocc.com.
25. Scope of Account Access
By connecting your brokerage API keys, you grant Tradewink limited authorization to: submit buy and sell orders, query account balances and positions, manage open orders and stop losses, and retrieve trade history. Tradewink cannot: withdraw funds from your account, transfer securities to another account, change your account settings or credentials, or access any account other than the one connected. You may revoke this authorization at any time by removing your API keys.
26. Prohibited Uses & Insider Trading
You agree not to use Tradewink in connection with any illegal activity, including but not limited to: trading on material non-public information (insider trading); market manipulation, spoofing, or layering; circumventing trading restrictions or regulatory requirements. You represent that all information you use in connection with Tradewink is obtained from lawful sources. Tradewink's AI analysis is based solely on publicly available data and does not incorporate or rely on material non-public information.
27. AI Model Limitations
Tradewink uses third-party large language models (including Claude, GPT, and Gemini, routed via OpenRouter) to generate market analysis, trade signals, conviction scores, and explanations. These are general-purpose AI models, not purpose-built forecasting systems. You acknowledge that: (a) LLMs can and do produce plausible-sounding but factually incorrect output ("hallucinations"), including incorrect ticker references, wrong dollar amounts, fabricated news events, or misremembered dates; (b) AI confidence scores reflect the model's self-assessment of how well a setup matches its 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 shown on the platform are historical simulations subject to hindsight bias, overfitting, survivorship bias, and execution assumptions that do not hold in live markets; (d) the term "self-improving" describes a system that updates itself without manual intervention — it does NOT mean the system gets monotonically better over time, and retrained models can overfit to regimes that have already ended; (e) AI-generated outputs should be treated as a starting point for your own review, not as recommendations to act. For a detailed explanation of known failure modes, visit https://www.tradewink.com/ai-limitations.
28. Acceptance & Electronic Signature
By typing your full legal name and clicking "Accept & Continue" below, you are providing your electronic signature and confirm that you have read, understood, and agree to all of the above terms. This 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 will not be able to enable trading or autonomous features.
III. Privacy Policy
1. Information We Collect
We collect the following information when you use Tradewink: your Discord user ID and username; watchlist tickers and trading preferences you configure; encrypted brokerage API credentials (if you choose to connect a broker); trade history and portfolio data retrieved from your connected broker; usage data such as commands used and features accessed.
2. How We Use Your Information
Your information is used to: provide AI-powered market analysis and trade signals; execute trades on your behalf when autonomous trading is enabled; personalize your experience (watchlists, strategies, preferences); improve our AI models and service quality; send alerts and notifications via Discord. We do not use your individual trading data or portfolio information to train AI models. Aggregate, anonymized performance metrics may be used to improve system-wide strategy calibration.
3. Data Storage & Security
Brokerage API keys are encrypted at rest using Fernet symmetric encryption with PBKDF2-derived keys. Keys are never stored in plaintext and are decrypted only at the moment of broker API communication. Your data is stored in our database infrastructure with encrypted connections (TLS 1.2+). We maintain administrative, technical, and physical safeguards for customer records consistent with FINRA customer information protection standards (FINRA Notice 00-66). These include structured logging with API key sanitization, role-based access controls, and automated security monitoring.
4. Third-Party Services
We use the following third-party services to operate Tradewink: Anthropic (Claude AI) for market analysis — no personally identifiable financial data is shared with LLM providers; market data providers (Polygon.io, Finnhub, FRED, SEC EDGAR) for real-time and historical data; brokerage APIs to execute trades on your behalf; Discord for bot communication; Sentry for error tracking; PostHog for product analytics (page views, feature usage, performance metrics — no trading data or financial information is shared with PostHog); Clerk for authentication and user management.
5. Data Sharing
We do not sell, rent, or share your personal data with third parties for marketing purposes. Data is only shared with third-party services as described above, strictly for the purpose of operating the service. We do not share your data with non-affiliated third parties for their own purposes. If this ever changes, we will provide you with advance notice and the ability to opt out before any such sharing occurs, consistent with SEC Regulation S-P.
6. Trading Data Logging
When autonomous trading is enabled, Tradewink logs the following data for each trade: order submissions (ticker, side, quantity, price, order type); execution results (fill price, fill quantity, latency, slippage); position lifecycle events (entry, exit, stop adjustments); daily P&L, win/loss records, and strategy performance metrics; audit trail entries with timestamps. This data is used for performance tracking, risk monitoring, regulatory recordkeeping, and service improvement.
7. Data Retention
Your data is retained for as long as your account is active. Trade history and analytics data are retained to provide performance tracking and learning features. Certain regulatory records (trade execution logs, trade journal entries) are retained even after account deletion to comply with SEC Rule 17a-4 and FINRA Rule 4370 recordkeeping requirements. You may request deletion of non-regulatory data at any time by contacting us.
8. Data Breach Notification
In the event of a security incident that compromises your personal data or brokerage credentials, we will: (1) investigate and contain the breach within 24 hours of discovery; (2) notify affected users via email and Discord within 72 hours with details of what data was affected; (3) immediately invalidate and rotate any compromised encryption keys; (4) advise affected users to rotate their broker API keys as a precaution; (5) report the incident to relevant authorities as required by applicable law, including state breach notification statutes and SEC Regulation S-P incident response requirements. We maintain security monitoring and logging to detect unauthorized access to encrypted credential stores.
9. Your Rights
You have the right to: access the data we hold about you; request correction of inaccurate data; request deletion of your data; revoke broker API access at any time by removing your keys; export your trade history and settings.
10. California Privacy Rights (CCPA)
If you are a California resident, you have the right under the California Consumer Privacy Act (CCPA) to: know what personal information we collect about you; request deletion of your personal information; opt out of the sale of your personal information (we do not sell personal data); not be discriminated against for exercising your privacy rights. To exercise these rights, contact us at [email protected].
11. European Privacy Rights (GDPR)
If you are located in the European Economic Area (EEA) or United Kingdom, you have additional rights under the General Data Protection Regulation (GDPR) including: the right to access, rectify, or erase your personal data; the right to restrict or object to processing; the right to data portability; the right to withdraw consent at any time. Our legal basis for processing your data is your consent (provided during onboarding) and legitimate interest in operating the service. To exercise these rights, contact [email protected].
12. Cookies & Tracking
The Tradewink web dashboard uses essential cookies for authentication and session management. We do not use third-party advertising trackers. Analytics are used solely for service improvement.
13. Children
Tradewink is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from minors.
14. Changes to This Policy
We may update this privacy policy from time to time. Material changes will be communicated via Discord. Continued use of Tradewink after changes constitutes acceptance of the updated policy.
15. Contact
If you have questions about this privacy policy or your data, reach out via our Discord server or email [email protected].
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 provided in accordance with FINRA Rule 2270 (Day-Trading Risk Disclosure Statement).
Pattern Day Trader (PDT) Classification. If you execute four or more day trades within five business days in a margin account, your broker may designate you as a Pattern Day Trader under FINRA Rule 4210. PDT accounts are required to maintain a minimum equity of $25,000 at all times. If your account falls below this threshold, your broker may restrict your ability to day trade until the minimum is restored.
Autonomous Trading and PDT. By enabling Tradewink's autonomous day trading features, you acknowledge that the system may execute multiple intraday round-trip trades that could trigger PDT classification on your brokerage account. Tradewink enforces a configurable PDT guard (default: 3 round-trips per 5-day rolling window) but this safeguard is best-effort and does not replace your own monitoring.
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 [email protected] 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 as of April 2026.
Agreement version 3.4 — Document generated from tradewink.com/disclosures