Legal

Privacy Policy

Effective date: October 27, 2026 · Version 2026-10-27.2 · Controller: MooChedda Inc.
In short: MTFX is used by individual account holders and by staff of licensed broker and dealer firms. We collect what we need to run accounts, admit firms, keep the platform secure, operate trading and settlement records, and meet legal obligations. We do not sell personal information and do not use advertising or tracking cookies.

1. Who we are and whom this covers

This Privacy Policy explains how MooChedda Inc. ("MooChedda", "we", "us" or "our"), with its registered office at [Registered office address], handles personal information in connection with the MTFX platform, its websites and API (the "Service"). For the information described here, MooChedda is the controller.

It covers: individual account holders; individuals who apply for membership on behalf of a firm; Authorised Users, meaning staff of member firms who use MTFX; contacts at member firms; and visitors to our websites. A member firm is responsible to its own clients for client information it handles, under its own privacy notice. This Policy should be read with our Terms of Service (individuals) or Member Terms (firms).

2. Summary

TopicWhat happens
What we collectApplicant and user identity and contact details, firm and licence details, account and security data, trading and ledger records, screening results, and technical data such as IP addresses.
WhyTo review membership, provide and secure the Service, operate trading, netting and settlement records, prevent fraud and market abuse, comply with law, and communicate with members.
Who we share withService providers acting on our instructions, the user's own firm, professional advisers, regulators and authorities where required, and a successor in a corporate transaction. Never sold.
CookiesStrictly necessary session and security cookies only.
RetentionFor the duration of membership, then as long as legal, regulatory, audit and dispute needs require. Trading records are kept in pseudonymised form after erasure.
Your rightsAccess, export, correction, erasure, restriction, objection and complaint, depending on where you live. Export and erasure requests are available on the account page.

3. Information we collect

3.1 Information provided to us

3.2 Information created when the Service is used

3.3 Information collected automatically

IP address, browser and device information and request times, used for security, rate limiting, abuse prevention and troubleshooting, plus the cookies and browser storage described in Section 7.

3.4 Information from third parties

Members' clients. MTFX is designed to work with client identifiers chosen by the member, not client names. Members are asked not to submit clients' personal data. If a member does so, it is responsible for having a lawful basis and giving the required notices.

4. How we use information and our legal bases

Where the EU or UK General Data Protection Regulation ("GDPR") or similar laws apply, we rely on the legal bases shown below.

PurposeExamplesLegal basis
Membership reviewVerifying firms and their licences, screening applicants, deciding applicationsLegitimate interests (admitting only licensed firms); legal obligation where applicable
Provide the ServiceRunning accounts, accepting and matching Orders, recording Trades, netting, settlement instructions, notificationsPerformance of our contract with you (individuals) or with your member firm; legitimate interests in respect of firm staff
Security and fraud preventionAuthentication, two-factor sign-in, lockouts, rate limiting, detecting suspicious activityLegitimate interests; legal obligation where applicable
Market integrity and complianceSurveillance for market abuse, investigations, trade reversals, sanctions screening, record-keeping, responding to regulatorsLegitimate interests (fair and orderly markets); legal obligation where applicable
BillingCalculating and invoicing feesPerformance of contract
CommunicationsAccount emails, service notices, responses to requestsPerformance of contract; legitimate interests
Improve the ServiceDiagnosing errors, measuring performance, planning capacityLegitimate interests
Legal claimsEstablishing, exercising or defending legal claims; enforcing the Member TermsLegitimate interests; legal obligation

You may ask us for details of the balancing tests we carried out for legitimate interests.

5. Automated decisions

Orders are accepted or rejected automatically against membership status, eligibility, trading hours, price collars, recorded balances and risk limits, and leveraged positions may be closed automatically when margin is insufficient. These decisions concern the member firm's trading. Sanctions screening and surveillance raise matches and alerts automatically, but a person reviews them before any final action against an individual. Where the GDPR applies and a decision based solely on automated processing has legal or similarly significant effects on you, you may ask for human review.

6. How we share information

We do not sell or rent personal information or share it for cross-context behavioural advertising. We share it only as follows:

7. Cookies and browser storage

We use only cookies and browser storage that are strictly necessary to provide the Service and keep it secure.

NameTypePurposeDuration
mtf_atCookie (httpOnly, SameSite=Strict)Keeps you signed in (short-lived access token)15 minutes by default
mtf_rtCookie (httpOnly, SameSite=Strict)Renews your session without asking for your password againUp to 30 days, or until sign-out
mtf_csrfCookie (SameSite=Strict)Protects against cross-site request forgeryUp to 30 days
mtf_userBrowser local storageBasic profile details (name, email, role, account status) for the signed-in interface; no password or tokenUntil sign-out
mtf_inst_groupsBrowser local storageWhich instrument groups you left openUntil cleared

Blocking these prevents signing in.

8. International transfers

We and our service providers may process personal information outside the country where it was collected, including in the United States. Where we transfer personal information from the European Economic Area, the United Kingdom or Switzerland to a country without an adequacy decision, we use appropriate safeguards such as the Standard Contractual Clauses and the UK International Data Transfer Addendum. You can request a copy of them.

9. How long we keep information

CategoryRetention
Applications (including rejected ones)For as long as needed to evidence the decision, generally at least five (5) years.
Authorised User account dataWhile the account is active. On approved erasure, it is pseudonymised: name, email, phone, IP addresses, two-factor and API credentials are removed or replaced.
Orders, Trades, ledger, netting and settlement recordsAs long as required by applicable record-keeping law and our contractual obligations to members, generally at least five (5) to seven (7) years after the record is created or membership ends, and longer under a legal hold. After erasure they are linked only to a pseudonymous identifier.
Screening results and audit logsAs long as the related records are kept. IP addresses and user-agents are removed on erasure.
Session, recovery-code and one-time tokensUntil they expire or are used, revoked or replaced.
Real-time market event feedAbout one day; contains market information, not identities.
Rate-limit countersFor the length of the rate-limit window.

10. How we protect information

No system is completely secure. If we become aware of a personal-data breach affecting you, we will notify you, your firm and the relevant authorities where the law requires.

11. Your rights and choices

Depending on where you live, you may have the right to access and export your personal information (use Download my data on the account page), have it corrected, have it erased (use Request erasure; records we must keep are pseudonymised instead), restrict or object to processing, ask for human review of significant automated decisions, and complain to a data-protection authority. For anything not self-service, email privacy@[your-domain] from the email address on your account. We may need to verify your identity, and we respond within the time required by law, usually one month under the GDPR or 45 days under US state laws. Some requests may need your firm's involvement where they affect its records. We will not discriminate against you for exercising your rights.

12. Region-specific information

12.1 European Economic Area, United Kingdom and Switzerland

You have the rights described in Section 11 under the GDPR, the UK GDPR and the Swiss Federal Act on Data Protection, and may complain to your local supervisory authority. Where required, our EU representative is [EU representative, if appointed] and our UK representative is [UK representative, if appointed].

12.2 California and other US states

Where state privacy laws apply to information about you, we collect the categories described in Section 3 (identifiers, professional or employment-related information, commercial information about your firm's trading, internet activity, and inferred location) for the purposes in Section 4, and disclose them to the recipients in Section 6. We do not sell personal information or share it for cross-context behavioural advertising, and have not done so in the last 12 months. You have the rights to know, delete and correct, and not to be discriminated against for exercising them. If we deny a request, you may appeal by replying to our decision.

12.3 Canada

We handle personal information in accordance with PIPEDA and applicable provincial laws. You may access and correct your information and complain to the Office of the Privacy Commissioner of Canada. Our privacy officer can be reached at privacy@[your-domain].

13. Children

The Service is not directed to anyone under 18 (or the age of majority where they live), and they may not open accounts. We do not knowingly collect children's personal information; if you believe a child has given us information, contact us and we will delete it.

14. Changes to this Policy

We may update this Policy. We will notify Authorised Users through the Service or by email before material changes take effect. The version and effective date above identify the current Policy.

15. Contact and complaints

MooChedda Inc.
Attn: Privacy
[Registered office address]
Email: privacy@[your-domain]

Please contact us first so we can try to resolve your concern. You may also complain to the data-protection authority where you live or work, or where you believe an infringement occurred.