Privacy & Data Security Policy

Version 1.3 | Last Updated: December 21, 2025
Entity: Uncharted Investments LLC (A Wyoming Series LLC)

1. Data We Collect (The "Need-to-Know" Basis)

Uncharted Investments only collects data essential for the automated execution of the Ashimoto 3-5-7 strategy and mandatory regulatory compliance:

  • Identity Data: Legal name, verified email address, and verified mobile phone number.
  • Financial Integration (OAuth): We utilize Alpaca OAuth 2.0. We store your Access Tokens and Refresh Tokens; we never request or store your Alpaca password.
  • Trade Telemetry: Execution timestamps, fill prices, and account balance snapshots (used solely for the Club Orchestrator and "Nightly True-Up").
OAUTH 2.0 SECURE AUTHENTICATION

2. The "Vault" Protocol & Withdrawal Protection

INSTITUTIONAL-GRADE SECURITY

We treat your brokerage credentials with institutional-grade security:

  • AES-256 Encryption: All OAuth tokens and API keys are encrypted at rest using the AES-256 standard. Keys are only decrypted in memory during an active, authenticated trading session.
  • "Trade-Only" Scope Enforcement: In alignment with Alpaca's security standards, our platform only requests account:read and trading scopes.
  • Withdrawal Protection: Uncharted Investments is physically incapable of accessing bank details or initiating withdrawals. Our Security Auditor service automatically purges any connection where "Withdrawal" permissions are detected.
Zero Withdrawal Access: We cannot access your bank details or move funds out of your account. Our OAuth scopes are restricted to trading operations only.

3. Third-Party Data Sharing & OAuth Integration

We do not sell or lease member data. Data is shared only with core infrastructure partners to facilitate the service:

  • Alpaca Markets: To transmit trade orders and receive execution data via secure OAuth 2.0 handshake.
  • Twilio/SendGrid: To deliver the 30-Day Compliance Heartbeat alerts and the 2-hour "Critical Phase" SMS notifications.
Minimal Data Sharing: These partners only receive the data required to perform their specific function (e.g., Twilio only receives your phone number).

4. The 30-Day Data Re-Verification (The Heartbeat)

Consistent with our Terms of Service, we perform a "Data Health Check" every thirty (30) days:

  • Verification: You must re-verify your contact information to ensure you can receive critical safety alerts.
  • Auto-Halt: If contact data is unverified or your "Heartbeat" expires, trading is paused and OAuth tokens are moved to a "Restricted" state until the "Communication Pipe" is re-verified.
Why Trading May Be Paused: If your 30-day Heartbeat expires or contact information is unverified, trading will be automatically paused until you re-verify. This protects you from missed critical alerts.

5. Data Retention & The "Right to Forget"

  • Revocation: If a member leaves the club or revokes access via the Alpaca Dashboard, all associated tokens are permanently deleted from our database within 24 hours.
  • Audit Trail: We retain a log of your MSA/ToS Sign-offs and Trade History for legal compliance and tax reporting purposes for a period of seven (7) years.

6. Member Responsibility & Supervision

While we provide the Dead Man's Switch and Security Auditor, members are responsible for:

  • Securing their local machine/device against malware.
  • Maintaining Active Supervision (per FINRA 3110) of their trading account during market hours.
  • Responding promptly to "Critical Phase" SMS alerts.

7. Data Breach & Incident Response

In the unlikely event of a data breach, Uncharted Investments will:

  1. Notify affected members within 72 hours via email and SMS.
  2. Invalidate all potentially compromised OAuth tokens, requiring members to re-authenticate.
  3. Provide a detailed remediation report.

8. Your Rights & Contact

As a member of the Wyoming LLC, you have the right to access, correct, or request the deletion of your data (subject to legal retention requirements).

Data Protection Officer:
privacy@unchartedinvesting.com