Privacy Policy
How we collect, use, share and protect your information — including the brokerage account data you choose to connect.
Last updated 24 August 2026 · Effective 24 August 2026
This policy describes actual system behaviour. It is not legal advice, and it should be reviewed by counsel licensed in your jurisdiction before you rely on it commercially.
1. Who we are
Warren Davis Data Systems (“Warren”, “we”, “us”) provides an institutional market-intelligence terminal. This policy applies to the Warren web application, desktop applications, mobile applications and the APIs that serve them (together, the “Service”).
For privacy questions, data-subject requests or security disclosures, contact privacy@warrendavisdata.com.
2. Information we collect
2.1 Information you provide
- Account information — name, work email address, and a password stored only as a salted hash. We never store your password in a recoverable form.
- Mandate profile — optional jurisdiction, mandate objective, risk budget and sector coverage, used solely to order what the terminal shows you first.
- Content you create — watchlists, alerts, saved briefings, trading-agent definitions and assistant conversations.
2.2 Brokerage information (only if you connect an account)
Brokerage connections are optional and are established through SnapTrade, a third-party aggregator. When you connect an account:
- You authenticate directly with your brokerage through SnapTrade’s interface. Warren never receives, transmits or stores your brokerage username, password, MFA codes or security answers.
- Warren receives only the tokens and identifiers SnapTrade issues, plus the account data you authorise: account names and numbers in masked form, balances, positions, and order and transaction history.
- You may disconnect a brokerage at any time from within the terminal or from your brokerage. Disconnection revokes our access immediately.
2.3 Information collected automatically
- Operational logs — request paths, timestamps, response codes, latency and error traces, retained for security and reliability.
- Device and session data — IP address, browser or application version, and session identifiers.
- Usage of the assistant — the text of what you ask, which desk answered and which data tools were called, so an answer can be audited back to its sources.
2.4 Voice
Voice is off unless you turn it on. When enabled, audio is carried over LiveKit and transcribed so the assistant can act on it. We do not retain raw audio recordings. Transcripts are handled the same way as typed messages under this policy.
3. How we use information
- To operate the Service and show you the data and analysis you request.
- To display positions and performance from brokerages you have connected.
- To evaluate the alerts you configure and notify you when they fire.
- To authenticate you, secure accounts and prevent abuse.
- To diagnose faults and improve reliability and performance.
- To meet legal, regulatory and audit obligations.
We do not sell personal information. We do not use your brokerage data, positions or holdings for advertising, and we do not share them with data brokers.
4. Automated processing and AI
Warren’s assistant sends the text of your question, and the market data retrieved to answer it, to a third-party model provider (OpenRouter, which routes to the model provider serving your request). The assistant is constrained to answer only from data it has fetched through Warren’s own tools.
- Do not paste material non-public information, personal data about third parties, or credentials into the assistant.
- We do not permit your content to be used to train third-party models where the provider offers that control, and we configure providers accordingly.
- Assistant output is informational. It is not investment advice and must not be treated as a recommendation.
5. When we share information
We share personal information only as follows.
| Recipient | Purpose | What is shared |
|---|---|---|
| SnapTrade | Brokerage connection, positions, order routing | User identifier, connection tokens, order instructions you confirm |
| OpenRouter and its model providers | Assistant responses | Your question text and the market data retrieved for it |
| LiveKit | Voice transport | Audio stream and session metadata, while a voice session is active |
| Hosting and infrastructure providers | Running the Service | Data at rest and in transit, under contract |
| Email provider | Account and alert notifications | Email address and message content |
We may also disclose information where required by law, to enforce our agreements, to protect rights and safety, or in connection with a merger or acquisition — in which case we will give notice before your information becomes subject to a different policy.
6. Retention
- Account and content — kept while your account is active, and deleted within 30 days of account closure unless we must retain it by law.
- Brokerage data — deleted within 30 days of disconnecting the brokerage or closing your account.
- Operational logs — retained up to 90 days.
- Records we are legally required to keep — retained for the period the applicable law requires.
7. Security
- Encryption in transit using TLS, and encryption at rest for stored data.
- Passwords stored only as salted hashes.
- Secrets held in a managed secret store, never in source control.
- Access to production data limited to personnel who need it, and logged.
- Orders cannot be submitted without a preview you saw and confirmed; the confirmation is cryptographically bound to the exact order you approved.
No system is perfectly secure. If you believe your account has been compromised, contact security@warrendavisdata.com immediately.
8. Your rights
Depending on where you live, you may have the right to access, correct, delete, port or restrict processing of your personal information, to object to processing, and to withdraw consent. Residents of the EEA and UK have these rights under the GDPR; residents of California have rights under the CCPA/CPRA, including the right not to be discriminated against for exercising them.
To exercise any right, contact privacy@warrendavisdata.com. We respond within 30 days, or tell you why we need longer. You may also lodge a complaint with your local supervisory authority.
9. International transfers
We and our providers may process information in countries other than your own, including the United States. Where required, transfers rely on Standard Contractual Clauses or another lawful transfer mechanism.
10. Children
The Service is intended for professional and institutional users and is not directed to anyone under 18. We do not knowingly collect information from children.
11. Changes to this policy
We will post any change on this page and update the date above. For material changes we will give notice in the Service or by email before the change takes effect.
12. Contact
Warren Davis Data Systems · privacy@warrendavisdata.com
See also our Terms of Service.