ClawBack.capital · Privacy Policy

Effective date: 26 June 2026 Last updated: 26 June 2026

Notice. This Privacy Policy applies to all ClawBack.capital surfaces — the web portal at clawback.capital (and subdomains), the CBC KATANA macOS desktop application, the CBC iOS application, and any official API operated under the ClawBack.capital name. ClawBack.capital is developed and operated by Samurai Networks (https://samurainw.com) ("Samurai Networks", "we", "us", "the Operator") in the United Kingdom. ClawBack.capital is a private platform; public sign-up is not currently available.

This Privacy Policy is a draft and has not yet been reviewed by counsel.

This document explains what data the Service collects, why it collects it, how it stores and shares it, and the rights you have over it.


1. Who we are

Data controller Samurai Networks
Product ClawBack.capital (operated by Samurai Networks)
Website https://samurainw.com
Jurisdiction United Kingdom
Contact privacy@clawback.capital
DPO Samurai Networks acts as data controller and informal DPO until a formal appointment is made

For the purposes of UK GDPR and the Data Protection Act 2018, Samurai Networks is the data controller of personal data processed by the Service.

2. What we collect

2.1 Information you provide directly

When you connect a brokerage account or configure the Service, we collect:

We do not ask for or store your broker login passwords. OAuth flows go directly to your broker; we receive only the access token the broker grants us.

2.2 Information collected automatically while you use the Service

2.3 Information received from third parties

When you connect a brokerage account, your broker sends us:

We may also receive market data (quotes, bars, news) from data providers such as Alpaca Market Data, Polygon.io, TradingView, yfinance, GlobeNewswire/PRNewswire RSS, and similar. Market data is not personal data — but if the data provider attaches an identifier to your request (e.g. an API key the Operator holds), the provider may log that request.

3. How we use your information

We use the information described above only to operate the Service for you. Specifically:

Purpose Legal basis (UK GDPR)
Authenticate you and route requests to the correct connected account Contract performance
Read your broker account state to display it in the UI Contract performance
Submit orders that you (or strategies you have configured) authorise Contract performance
Maintain an audit log of every signal, decision, order, and fill — the platform's core safety feature Legitimate interest (operator must be able to reconstruct any trading day for diagnostic and dispute purposes)
Detect, prevent, and respond to security incidents Legitimate interest
Comply with legal obligations including tax-record retention and any regulatory request Legal obligation
Improve the Service (debugging, performance tuning) Legitimate interest

We do not use your data for advertising, marketing, profiling, or to train any third-party machine-learning model. We do not sell your data.

4. Where we store data

Data is stored in the following systems:

We currently do not store any data outside the United States, the United Kingdom, or the European Economic Area.

5. Sharing with third parties

We share your data only with the following categories of third parties, only to the extent necessary to operate the Service:

Third party What we send Why
Your connected brokers (Alpaca, Paradex, Binance, etc.) Order instructions you authorise; credentials/tokens you provided so we can read account state To execute trades and read state on your behalf
Market-data providers (Alpaca Market Data, Polygon.io, TradingView, yfinance, GlobeNewswire/PRNewswire RSS) Symbols you watch or trade To retrieve quotes, news, and historical data
AWS (sub-processor) All data described in § 4 Hosting infrastructure
Cloudflare (sub-processor) HTTP request metadata (IP, headers, body) for routing DNS, TLS, CDN, OAuth dispatch
Anthropic (optional, AI Risk Advisor feature) Recent audit-log summaries, strategy parameters If you enable the AI advisor; processed under Anthropic's API terms and not used for model training per Anthropic's commercial-API policy
GitHub (developer-only) The Operator's own commits and CI logs — never your trading data Source control and CI
Sentry / observability stack Application error reports (may include account identifier; never credentials) Diagnose and fix bugs

We do not share your data with advertisers, data brokers, marketing platforms, or analytics platforms that profile users (no Google Analytics, no Facebook Pixel, no Hotjar, etc.).

If we are ever required by law (subpoena, court order, valid regulatory request) to disclose data, we will — but we will, where lawful, notify you first and limit the disclosure to what is required.

6. Data retention

Data category Retention period
Audit log (signals → decisions → orders → fills → closes) Indefinitely while your account is active; minimum 7 years after closure for tax and broker-record purposes
Broker credentials Until you remove the account, revoke the OAuth grant, or close your account with us
Server access logs 90 days, then deleted
Application error logs 30 days, then deleted
Email / authentication records 12 months after last successful login, then deleted
Backups Encrypted nightly snapshots retained 30 days, then expunged

When you close your account, we delete or anonymise personal data within 30 days, except where longer retention is required by law (e.g. UK tax record retention).

7. Your rights (UK GDPR / EU GDPR)

If you are in the UK or EEA, you have the right to:

  1. Access the personal data we hold about you (subject access request).
  2. Rectify inaccurate or incomplete data.
  3. Erase your data ("right to be forgotten"), subject to legal retention obligations.
  4. Restrict processing in certain circumstances.
  5. Object to processing based on legitimate interest.
  6. Data portability: receive your data in a structured, commonly-used machine-readable format.
  7. Withdraw consent at any time where processing is based on consent.
  8. Complain to the UK Information Commissioner's Office (ICO) at if you believe we have mishandled your data.

To exercise any of these rights, email privacy@clawback.capital. We will respond within one month (or notify you if a complex request requires up to two further months).

8. Security

We use industry-standard measures appropriate to the sensitivity of the data:

No security measure is perfect. If we become aware of a data breach affecting you, we will notify you and the ICO as required by UK GDPR — within 72 hours of becoming aware where the breach is likely to result in a risk to your rights and freedoms.

9. Cookies and similar technologies

The web portal uses:

We do not use third-party analytics cookies, advertising cookies, or social-media trackers. You can clear cookies through your browser at any time; doing so will sign you out of the portal.

The macOS and iOS apps store equivalent preferences in UserDefaults (not cookies). No telemetry is sent to third parties.

10. Children's privacy

The Service is not directed to children under 18 and we do not knowingly collect data from children. If you believe we have collected data from a child, please contact privacy@clawback.capital and we will delete it.

11. International data transfers

If you access the Service from outside the United Kingdom, you understand that your data is transferred to and processed in the United States (AWS us-east-1). The transfer is protected by the appropriate UK International Data Transfer Agreement (IDTA) or Standard Contractual Clauses with AWS and Cloudflare as data processors.

12. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be communicated through the Service or by email at least 30 days before they take effect. The "Last updated" date at the top of this document reflects the most recent revision.

13. Contact

For questions about this Privacy Policy, to exercise any of the rights described in § 7, or to give notice of any matter requiring the Operator's attention:

Samurai Networks — developer + operator of ClawBack.capital Website: https://samurainw.com Email: privacy@clawback.capital Postal: [forthcoming]