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
| Topic | What happens |
|---|---|
| What we collect | Applicant 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. |
| Why | To 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 with | Service 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. |
| Cookies | Strictly necessary session and security cookies only. |
| Retention | For 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 rights | Access, 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
- Membership applications: the firm's legal name, firm type, licence or registration number, regulator, jurisdiction, LEI and website, and the applicant's name, work email, optional phone number and confirmation of authority.
- Individual accounts: name, email, optional phone number and country of residence, and password (stored only as a salted bcrypt hash).
- Identity verification: for individual accounts, information and documents needed to verify identity and eligibility where we request them, and the outcome.
- Authorised User accounts: name, work email, optional phone number, firm and role, and password (stored only as a salted bcrypt hash).
- Communications: messages and support requests, and information members provide to us in connection with membership, funding confirmations, surveillance inquiries or disputes.
- Trading instructions: Orders, cancellations, modifications, requests for quote and watchlists entered by Authorised Users or through their API keys.
3.2 Information created when the Service is used
- Trading and settlement records: Orders and their lifecycle events, rejections and reasons, Trades, positions, recorded balances, ledger journals and entries, settlement obligations and instructions, corporate-action entitlements, fees, margin and funding records. Each is linked to the firm and to the Authorised User who acted.
- Account and security data: account and membership status, screening status, sign-in times, the IP address of the last sign-in, failed sign-in attempts and lockouts, session and refresh tokens, two-factor settings (the secret is encrypted at rest), recovery codes and one-time tokens (stored only as hashes), and API key identifiers and scopes (keys stored only as hashes).
- Acceptance records: the version of the Member Terms and this Policy accepted, when, and from which IP address.
- Audit and compliance records: an audit log of significant actions with IP addresses and, in some cases, browser user-agent; surveillance alerts; and two-person approval records.
- Notifications sent in the Service and by email, including delivery status.
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
- Regulators and public registers: licence and registration details used to verify applicant firms.
- Sanctions and watch lists: results of screening applicants and Authorised Users.
- Member firms: details of the Authorised Users a firm asks us to set up.
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.
| Purpose | Examples | Legal basis |
|---|---|---|
| Membership review | Verifying firms and their licences, screening applicants, deciding applications | Legitimate interests (admitting only licensed firms); legal obligation where applicable |
| Provide the Service | Running accounts, accepting and matching Orders, recording Trades, netting, settlement instructions, notifications | Performance of our contract with you (individuals) or with your member firm; legitimate interests in respect of firm staff |
| Security and fraud prevention | Authentication, two-factor sign-in, lockouts, rate limiting, detecting suspicious activity | Legitimate interests; legal obligation where applicable |
| Market integrity and compliance | Surveillance for market abuse, investigations, trade reversals, sanctions screening, record-keeping, responding to regulators | Legitimate interests (fair and orderly markets); legal obligation where applicable |
| Billing | Calculating and invoicing fees | Performance of contract |
| Communications | Account emails, service notices, responses to requests | Performance of contract; legitimate interests |
| Improve the Service | Diagnosing errors, measuring performance, planning capacity | Legitimate interests |
| Legal claims | Establishing, exercising or defending legal claims; enforcing the Member Terms | Legitimate 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:
- Your member broker (if you opened your account with one): your name, email, identity-check status, balances, deposits and release requests, so it can hold your assets and process your funding.
- The custody partner (house accounts): your account identifier, and for each deposit or release the currency, amount and payout details you give, so it can hold your assets and process movements.
- Your firm (firm staff only): an Authorised User's firm may receive records of that user's activity on MTFX, for example for its own supervision and record-keeping.
- Service providers processing data for us under confidentiality and security obligations, including hosting, database and backup, email delivery, market-data and screening providers.
- Font delivery: our pages load the Inter typeface from Google Fonts, so your browser sends your IP address and browser information to Google.
- Breached-password check: if enabled, we send the first five characters of a password's SHA-1 hash, never the password itself, to the Have I Been Pwned "Pwned Passwords" service.
- Counterparties: where needed to resolve a settlement failure or error, information about the relevant Trade, which may identify the firms involved but not their staff unless necessary.
- Other members: anonymous market information (order-book prices and quantities, trade prices) that identifies neither firms nor individuals.
- Professional advisers such as lawyers, auditors and insurers, under confidentiality duties.
- Regulators, law enforcement and other authorities, including a member's own regulator, where we believe disclosure is required by law or legal process, or is necessary to detect or prevent market abuse, fraud or security issues, or to protect rights and safety.
- Corporate transactions: a buyer or successor in a merger, acquisition, financing, reorganisation or sale of assets, subject to equivalent protections.
7. Cookies and browser storage
We use only cookies and browser storage that are strictly necessary to provide the Service and keep it secure.
| Name | Type | Purpose | Duration |
|---|---|---|---|
mtf_at | Cookie (httpOnly, SameSite=Strict) | Keeps you signed in (short-lived access token) | 15 minutes by default |
mtf_rt | Cookie (httpOnly, SameSite=Strict) | Renews your session without asking for your password again | Up to 30 days, or until sign-out |
mtf_csrf | Cookie (SameSite=Strict) | Protects against cross-site request forgery | Up to 30 days |
mtf_user | Browser local storage | Basic profile details (name, email, role, account status) for the signed-in interface; no password or token | Until sign-out |
mtf_inst_groups | Browser local storage | Which instrument groups you left open | Until 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
| Category | Retention |
|---|---|
| Applications (including rejected ones) | For as long as needed to evidence the decision, generally at least five (5) years. |
| Authorised User account data | While 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 records | As 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 logs | As long as the related records are kept. IP addresses and user-agents are removed on erasure. |
| Session, recovery-code and one-time tokens | Until they expire or are used, revoked or replaced. |
| Real-time market event feed | About one day; contains market information, not identities. |
| Rate-limit counters | For the length of the rate-limit window. |
10. How we protect information
- passwords stored only as salted bcrypt hashes, with strength rules and account lockout;
- authenticator-app two-factor authentication with replay protection, the secret encrypted at rest with AES-256-GCM, and hashed single-use recovery codes;
- httpOnly, SameSite session cookies with CSRF protection, short-lived access tokens and rotating refresh tokens;
- API keys shown once, stored only as hashes and limited to chosen scopes;
- a Content Security Policy and an allow-list for cross-origin requests;
- role-based administrative access, two-person approval for sensitive operations, and an audit log; and
- encryption in transit (TLS) in production.
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.