Confidentiality
Confidentiality & data handling
Your strategy and your returns are your business. Here is exactly what we ask for, who sees it, where it is kept, how long we keep it, and what we never do with it. We sign an NDA before you send any data.
Last updated 2026-09-26. Questions: [email protected].
The short version
- NDA first. We sign your NDA (on reasonable terms) or use our mutual NDA, before you send any data.
- Minimum data. Most audits need only a returns series and the number of variants you tried. You can send it anonymised: no fund name, no positions.
- Positions and trades, if you choose to send them (a Tier 2 audit), are handled to the same standard. They never leave the encrypted analysis machine except as the delivered report, apart from the AI-assisted analysis tooling listed below.
- One person. Only the founder, Raghuram Vadapally, sees your materials.
- Used only to perform your audit. Never published, sold or shared, and never traded on.
- Confidential results. Your audit is published only if you opt in, in writing.
- Deleted on a schedule. Your files are deleted within 30 days of report delivery, unless you ask otherwise.
Before anything is sent
An NDA before you send data
We sign your NDA on reasonable terms, or you can use our short mutual NDA. Either way it is signed before you send any returns file, strategy material or code. Tick the NDA box on the intake form, or email [email protected] and we will send ours or review yours.
The intake form itself asks only for a high-level description. Please do not put exact rules, code, data, credentials or trade files into it.
Data minimisation
What we need, and what we don’t
Most audits need only two things:
- a returns series: daily or monthly returns of the strategy, plus the benchmark you judge it against; and
- the number of variants you tried before settling on this one. An honest estimate is fine.
A Deep Audit is sharper if you also send the returns of the other variants you tested (the grid), but that is optional. We do not need your code, your exact rules, your positions, your counterparties, or any account details. Never send passwords or logins.
If you choose a deeper Tier 2 audit, you also send positions and trades in our data-contract format. That data is handled to the same standard as returns: same NDA, same folder, same deletion schedule, and it never leaves the encrypted analysis machine except as the delivered report (apart from the AI-assisted analysis tooling listed below).
Anonymised is fine
You can send it anonymised
Label the file “Strategy A”. Leave out the fund name, manager names, instruments and positions. Dates and returns are enough for the statistics. If you prefer, rescale the returns to a stated volatility; tell us what you did and we will note it in the report.
Anonymised data limits what anyone could learn from it, including us. It is the option we suggest for funds and allocators.
People
Who sees it
Only Raghuram Vadapally, the founder. Holdout Labs has no employees or contractors. If that changes, nobody else will see your materials unless they are bound by confidentiality obligations at least as strict as these, and we will tell you first.
Place
Where it is kept and how it moves
- Engagement files (returns, variant grids, any code) are kept in a dedicated client folder on the founder’s work computer. Client files are stored on a drive encrypted at rest (BitLocker).
- Client data is never stored in code repositories. Our own code lives on GitHub; your data does not.
- In transit, the website and intake form use TLS (HTTPS). For files, we agree a method with you after the NDA: an encrypted archive with the password sent by a separate channel, or your own secure file-share. Step by step: how to send data.
- Never in public material. Client data does not appear in our published audits, examples, posts or newsletter.
Sub-processors
Service providers that can touch your data
This is the complete list. Each provider processes data only to provide its service to us.
| Provider | What for | What it can see |
|---|---|---|
| Cloudflare | Website hosting; the intake-form database (Cloudflare D1, US); sending the intake notification email | What you type into the intake form |
| Zoho Mail | Our email mailbox | Emails you send us, and intake notifications |
| Anthropic | AI-assisted analysis tooling | Engagement data we analyse with it. AI-assisted analysis uses Anthropic’s Claude with model training on our data turned off; we plan to move client work to a commercial Claude plan (which does not train on customer data by default). AI-assisted analysis is part of how we deliver every audit, and our prices assume it; we tell you this before any data is sent, so you can decide whether to proceed. |
| Stripe | Card payments, once enabled | Billing details only, never your strategy or returns |
GitHub hosts our own code. Client data is never stored in code repositories, so it does not go to GitHub.
Separate from client work: the public request-an-audit form (a public indicator you want us to test, with an optional email for the publication notice, removed after 365 days) and the Out of Sample newsletter (subscriptions held by Beehiiv). Please don’t put confidential strategy details into either; neither is covered by an NDA. We never sell data from them. Details: privacy notice.
Retention
How long we keep it
| What | How long |
|---|---|
| Intake-form submissions | Deleted automatically from the intake database after 365 days by a daily job. The notification email is kept with our correspondence (below), and deleted sooner on request. |
| Your engagement files (returns, variant grids, positions and trades, any code) | Deleted within 30 days of report delivery, unless you ask us to keep them for a follow-up. For a Sealed Forward Trial, kept for the life of the trial, because the seal depends on them. |
| Monitoring subscriptions (returns and backtest series) | For monitoring subscriptions, data is kept for the life of the subscription and deleted within 30 days of cancellation (a written confirmation on request). |
| Your report and our correspondence | A copy is kept for the record, for up to three years, so we can answer follow-up questions. Ask and we delete it sooner. |
| Billing records | As long as tax law requires. |
Ask for deletion at any time at [email protected]. On request, we confirm deletion to you in writing.
Publication
Your results stay confidential
You may have read that we publish every result. That commitment covers only our own research: audits we run on public strategies, such as the published audit batches, where the failures are published too.
Client engagements are confidential by default. We never publish your grade, your numbers, your name, or the fact that you are a client. A client’s results are published only with that client’s written opt-in, and only in the form the client approves.
Firewall
What we never do
- Sell, rent or share your data or your report.
- Trade your strategy, or trade on anything learned in your engagement. The founder’s personal trading is walled off from client work: we do not trade client strategies.
- Use your strategy or data in our own research, products or published audits.
- Put your data into public material, code repositories, or AI tools that are allowed to train models on it.
- Disclose anything about your engagement, except where the law requires it. If that happens, we will tell you where the law allows.
Questions, or ready to start?
Ask for our mutual NDA, send yours for review, or ask anything about how we handle data: [email protected]. This page sits alongside our terms, privacy notice and disclaimer. Where you and we have signed an NDA, the NDA governs.