Clock Out Capital LLC

Effective Date: August 6, 2026

Last Updated: August 6, 2026

1. Introduction

Clock Out Capital LLC ("Clock Out Capital," "we," "us," or "our") respects your privacy. This Privacy Policy explains how we collect, use, share, and protect personal information when you visit clockoutcapital.com, use the Clock Bots automated trading software, the stock screener, or any of our other services (collectively, the "Services").

By using the Services, you agree to the practices described in this Policy. If you do not agree, do not use the Services.

2. Information We Collect

2.1 Information You Provide

Account information: name, email address, password, time zone, and (for paid Subscriptions) billing address.

Payment information: credit or debit card details, processed and stored by our third-party payment processor (e.g., Stripe). We do not store full payment card numbers on our systems.

Brokerage and third-party connections: OAuth tokens, API keys, connected-wallet addresses, and limited account metadata (e.g., account number, available buying power, current positions) from brokerages, exchanges, or services you connect (such as SnapTrade-supported brokerages, Alpaca, cryptocurrency exchanges accessed via our exchange connectors, or self-custody wallets connected through WalletConnect for decentralized venues such as Hyperliquid). We do not store your brokerage username or password, and for self-custody wallet connections we never receive or store your wallet's private key or seed phrase.

Configuration data: the parameters, watchlists, indicator settings, scan criteria, bot configurations, and strategy descriptions you create within the Services.

AI and voice inputs: the text prompts you send to in-product AI assistants; and, if you use voice features, the audio you submit (for example, microphone input to a voice debate or voice command). See Sections 2.5 and 4.6 for how AI inputs are processed and shared.

Communications: messages you send to support, comments you post in any community area, broadcasts you author (if you are a creator), and your responses to surveys.

Notification destinations: if you enable a notification channel, the destination you supply for it — a mobile telephone number for SMS, a browser or device push subscription generated when you grant notification permission, and any third-party messaging identifier you connect (for example a Telegram chat id or a Discord webhook). We use these solely to deliver the notifications you enabled.

2.2 Information We Collect Automatically

Device and usage data: IP address, browser type, operating system, device identifiers, pages visited, features used, time stamps, referring URLs, and click patterns.

Performance and diagnostic data: error logs, latency data, and bot execution logs (orders generated, signals fired, configuration changes).

Cookies and similar technologies: see Section 6 below.

2.3 Information from Third Parties

Brokerage data: account balances, positions, orders, fills, and historical trade data from any brokerage you connect.

Market data providers: real-time and historical price, quote, fundamentals, and news data licensed from third parties.

Analytics and advertising partners: aggregated information about your interactions with our marketing channels.

2.4 Voice Audio and Biometric Identifiers

If you use voice features (for example, the voice debate or any microphone-based interaction), we process the audio you submit solely to transcribe it to text and generate a response. We do not create voiceprints, voice-recognition templates, or other biometric identifiers from your audio, and we do not use your audio to identify you. Audio is transmitted to a third-party speech-to-text provider for transcription (see Section 4.6) and is retained only as described in Section 8.

Except for voice audio processed as described above, we do not knowingly collect Social Security numbers, government-issued IDs, biometric identifiers, retina/iris scans, fingerprints, face or hand geometry, or precise geolocation data. For creators who reach reportable payout thresholds, we collect taxpayer identification information (e.g., a W-9) — see Section 2.6. We are not a broker-dealer or money services business and do not perform Know-Your-Customer (KYC) onboarding; KYC is performed by the brokerages and exchanges you connect.

2.5 AI Features and User-Configured AI Providers

The Services include AI assistants (for example, the educational market-brief, strategy-setup, and analysis assistants). When you use these features, the text of your prompt — which may include configuration data and questions you ask — is processed by a large-language-model provider to generate a response.

By default, AI features are processed through AI providers we engage as our service providers (see Section 4.1). You may also optionally configure your own AI provider by supplying your own API key and, for self-hosted or compatible endpoints, your own provider URL. When you do this:

Your prompts and the associated inputs are transmitted to the provider you selected, under that provider's terms and privacy policy, not ours;
We store your provider API key in encrypted form solely to make calls you initiate;
We are not responsible for how your chosen provider collects, uses, retains, or trains on the data you send it; and
You are responsible for ensuring you have the right to send any data to that provider and that the provider's terms are acceptable to you.

We do not use your AI prompts or AI-generated outputs to make trading decisions on your behalf. AI outputs are educational and informational only and are subject to the Risk Disclosure and the Voice & AI Content Addendum.

2.6 Creator Taxpayer Information

If you participate in the Creator Program and your cumulative payouts (cash and platform credit combined) reach the IRS reporting threshold in a calendar year (currently $600), we collect taxpayer identification information from you (for example, a completed IRS Form W-9) before further payouts are released. This information is used solely for tax reporting and payout compliance, is shared with our payments and tax-form processors (see Section 4.1), and is retained per Section 8.

2.7 Connected Agents

If you issue an access token to a third-party software agent (a "Connected Agent"), we record the token's scope, its expiry, changes you make to its capabilities, and a log of the actions taken with it. A Connected Agent is not our service provider and does not act on our behalf — it is software you chose and control. Data the agent retrieves from your account passes into that agent's own environment, under whatever terms exist between you and its provider, and we have no visibility into or control over what it does with that data afterwards. Revoking the token stops further access but does not reach anything the agent has already retrieved.

3. How We Use Your Information

We use personal information to:

Provide, maintain, and improve the Services, including executing your bot configurations against your connected brokerage account;

Process Subscriptions, payments, and refunds;

Authenticate users and prevent fraud, abuse, and security incidents;

Transcribe and respond to voice inputs, and generate educational AI assistant responses to your prompts;

Calculate and process creator referral commissions, marketplace earnings, and payouts, and meet associated tax-reporting obligations;

Communicate with you about your account, Subscription, security alerts, product changes, and support requests, over the notification channels you have enabled (including SMS text message and browser push, where you have opted in — see Terms of Service Section 6A);

Send marketing communications, from which you can opt out at any time;

Conduct analytics, research, and product development;

Comply with legal obligations and enforce our Terms of Service;

Aggregate or de-identify data for any lawful purpose, including market research and product analytics.

4. How We Share Information

We do not sell personal information for monetary consideration. We share personal information only as described below.

4.1 Service Providers

We share information with vendors who perform services on our behalf. Our current subprocessors are: Supabase (database, authentication), Stripe and Stripe Connect (payment processing and creator payouts), Cloudflare (network, tunnel, and backup storage), SnapTrade (brokerage connectivity and order transmission), Alpaca (brokerage execution), Resend (transactional email), Twilio (SMS text-message delivery, where you have enabled SMS), Dropbox Sign (creator-agreement e-signature), and the AI providers listed in Section 4.6. These vendors are bound by contract to use the information only to provide services to us.

Two clarifications about things that are not on that list:

Third-party messaging destinations you nominate (for example Telegram or Discord) receive the notification content we send there at your direction, but they are your chosen destinations rather than our subprocessors, and their own terms govern what they do with it.
Cryptocurrency exchanges and decentralized venues you connect are your counterparties, not our subprocessors. Orders you configure are transmitted to the venue you selected, under that venue's terms.

4.2 Brokerages and Trading Counterparties

When Clock Bots transmits an order to your connected brokerage, the brokerage receives the order details. Your relationship with the brokerage is governed by that brokerage's own privacy policy.

4.3 Legal and Safety

We may disclose information when we reasonably believe disclosure is required to: (a) comply with applicable law, regulation, or legal process (e.g., subpoena or court order); (b) enforce our Terms of Service; (c) protect the rights, property, or safety of Clock Out Capital, our users, or the public; or (d) detect, prevent, or address fraud, security, or technical issues.

4.4 Business Transfers

If Clock Out Capital is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you and post a notice on our website if your information becomes subject to a different privacy policy.

4.5 With Your Consent

We will share information for any other purpose disclosed to you with your consent.

4.6 AI and Voice Providers

To power AI assistants and voice features, we transmit your prompt text and (for voice) your audio to AI and speech providers:

Default AI providers (engaged by us as service providers): Anthropic (Claude), and where applicable OpenAI and Google (Gemini). These providers process inputs to generate responses under contracts that restrict use to providing the service to us.
Voice transcription and synthesis: voice features are currently disabled, and no voice audio is transmitted to any speech provider. If and when voice is re-enabled, the provider then in use will be named here and in Section 4.1 before the feature is switched on, and the representations in Section 2.4 will be re-confirmed against that provider's actual processing.
User-configured providers: if you supply your own AI provider key (Section 2.5), your inputs go to the provider you chose, under that provider's terms — not as our subprocessor.

5. Your Rights and Choices

5.1 Account and Marketing

You may access and update your account information at any time through your account settings. You may opt out of marketing emails by clicking the unsubscribe link in any marketing message; you cannot opt out of transactional messages relating to your Subscription, security, or the operation of Clock Bots.

5.2 State Privacy Rights

Depending on where you live, you may have the right to:

Know what personal information we have collected about you;

Access a copy of your personal information in a portable format;

Correct inaccurate personal information;

Delete your personal information, subject to legal retention requirements;

Opt out of "sale" or "sharing" of personal information for cross-context behavioral advertising (we do not sell personal information for monetary consideration; we may use limited cookies for our own marketing analytics, see Section 6);

Limit the use of sensitive personal information;

Not be discriminated against for exercising any of these rights.

To exercise these rights, email [email protected] or use the data request form available in your account settings. We will respond within forty-five (45) days, subject to extension as permitted by law. We may need to verify your identity before fulfilling a request.

5.3 Authorized Agents

California and certain other state residents may designate an authorized agent to make a request on their behalf. We may require written authorization and identity verification.

5.4 Appeals

If we deny a privacy request, you may appeal by emailing [email protected] with the subject line "Privacy Request Appeal." We will respond within sixty (60) days.

6. Cookies and Tracking Technologies

We use cookies, local storage, and similar technologies to operate the Services, remember your preferences, authenticate sessions, and measure usage. You can disable cookies through your browser settings, but parts of the Services may not function correctly without them.

We do not currently respond to browser "Do Not Track" signals, but we honor opt-out preference signals such as the Global Privacy Control (GPC) where required by applicable law.

7. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. These safeguards include encryption of data in transit (TLS 1.2 or higher) and at rest, access controls, regular vulnerability scanning, and incident response procedures.

No method of transmission over the internet or method of electronic storage is fully secure, however, and we cannot guarantee absolute security. You are responsible for safeguarding your account credentials and any API keys.

If we become aware of a security incident affecting your personal information, we will notify you and applicable regulators as required by law.

8. Data Retention

We retain personal information for as long as necessary to provide the Services, comply with our legal obligations (including tax and recordkeeping obligations), resolve disputes, and enforce our agreements. Specifically:

Account information: for the life of your account plus seven (7) years after closure;

Payment and billing records: at least seven (7) years to satisfy tax and accounting obligations;

Bot execution logs and order history: at least five (5) years to satisfy potential audit and regulatory requirements;

Voice audio: transcribed promptly and retained only transiently for processing; we aim to discard the source audio after transcription and do not retain it for training. AI prompt/response text is retained with your account activity and may be retained in aggregated/de-identified form;

Creator taxpayer information (W-9): retained at least seven (7) years to satisfy IRS recordkeeping obligations;

Notification destinations (mobile number, push subscription, messaging identifiers): for as long as the channel is enabled, plus, for SMS, a record of your consent and of any STOP request, retained as long as needed to honor the opt-out and to evidence compliance;

Connected Agent tokens and their action logs: for the life of the token plus a period sufficient for security review and dispute resolution;

Marketing data: until you opt out plus a reasonable suppression period to honor your opt-out;

Aggregated or de-identified data: indefinitely.

9. Children's Privacy

The Services are not directed to children under 18, and we do not knowingly collect personal information from anyone under 18. If we learn we have collected personal information from a child under 18, we will delete it. If you believe we may have collected information from a child, contact [email protected].

10. International Users

The Services are operated in and intended for use within the United States. If you access the Services from outside the United States, you do so at your own risk and consent to the transfer of your information to the United States, which may have data protection laws different from those in your country.

11. Third-Party Links

The Services may contain links to third-party websites or services. We are not responsible for the privacy practices of third parties. We encourage you to read the privacy policies of any third party you interact with.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this Policy reflects the most recent revision. Material changes will be communicated to you by email or in-product notice at least thirty (30) days before the effective date. Your continued use of the Services after the effective date constitutes acceptance of the revised Policy.

13. Contact Us

Clock Out Capital LLC

Attn: Privacy

Duluth, MN 55807

Email: [email protected]