The rails we operate on

What we are not

We are not a registered investment adviser, broker-dealer, commodity trading advisor, money transmitter, or custodian. You remain trader of record on your exchange.

Customer elects

You elect the venue, the pair, and either North Star (a packaged card you attach) or a card you build. We record it and execute. We do not pick a market. A silent push that changes your card would break this rail.

No custody — FinCEN / state money transmission

Funds never sit here. The website never accepts an API secret. Live, if later armed on a local executor, is trade-only. Withdraw and transfer stay off. If we cannot move value, we are not transmitting money. Taking a withdraw key would collapse this rail.

Not advice — Advisers Act / CFTC

We do not tell you which asset to hold or which way to trade. North Star is still an election of a published card plus a pair you choose. We do not publish win rates, backtests, or returns as marketing. Counsel still answers when a packaged card becomes advice.

Sanctions — OFAC

Signup records that you are 18 or older, not sanctioned, and not in a denied region. That is an attestation. It is not a live OFAC feed. A live screen is later work. We do not infer.

Advertising — FTC

No guaranteed results. No fake testimonials. No AI that 'decides' for you. Data-calibrated rules execute what you elected.

Data — GDPR as the ceiling, US state privacy as the floor

GDPR-level data rights (access, erase, portability, no sale) are built on this desk. That is the privacy bar. It does not replace securities, commodities, or money-transmitter law. CCPA/CPRA and other state privacy acts are covered by the same minimization: we do not sell or share for ads.

Email and SMS — CAN-SPAM / TCPA

This paper desk does not email or text. Magic link and verify are local tokens. We do not send unsolicited financial advice.

One person, one desk

No customer subusers. Only the master grants a person. Staff cannot add people or change grants. Impersonate is a snapshot.

Your data

We keep only what the desk needs. We do not sell or share personal data for ads. Exchange secrets never enter this website. Export and erase are yours. Counsel reviews before live. We never recommend a pair.

What this desk holds

• Account. Email, password hash, region attestation, 18+ attestation, optional TOTP secret on this machine.
• Session. Session id, last seen, optional IP. Customer and staff idle 8 hours. Master 12 hours.
• Venue link. Exchange name, API name, whitelist label. Never the secret. Trade-only. Withdraw false.
• Elections. The pair, card, and parameters you elected. North Star is a card you attach — not a pick we made.
• Paper execution. Fills, audit, journal, tickets, templates. Kept 400 days, then pruned.

What this desk never holds

• Exchange API secrets
• Withdraw or transfer permission
• Seed phrases or exchange passwords
• Card numbers or bank accounts
• A live OFAC list (signup is an attestation we record)
• Advertising identifiers or sale of personal data

Your rights

• Access / portability. Download your desk as JSON from Your data.
• Erase. Remove this desk from the local store. Operator cannot self-erase.
• Restrict. Revoke other sessions. Sign out anytime.
• Do not sell or share. We do not sell personal data and do not share it for cross-context behavioral advertising.
• Object / complain. Email kent@lumenbotfi.com. This paper desk has no paid ads and no processors beyond this machine.

Essential cookies only: session, pending 2FA, and CSRF. No advertising pixels. No sale of personal information. No share for cross-context ads. We do not need a tracking-consent wall because we do not track.

Data request: kent@lumenbotfi.com · Your data on the desk · Do not sell or share

Risk

Trading cryptocurrency involves substantial risk of loss and is not suitable for every investor. Past performance is not indicative of future results. Paper is paper. Live is live. We do not publish win rates as marketing.

What attaching North Star means

Desk signup is not North Star. North Star is a separate enrollment. After you elect the service, the engine connects and runs the published card on your trade-only venue. You do not elect each fill. Withdraw stays off. Secrets never enter this website. Counsel memos are held off this vault on purpose. This website still does not arm live Coinbase.

Live writes

Paper runs now. This website still refuses live writes and does not arm the local vault. That is a machine gate, not a comment on off-vault counsel.