Integral MTF Privacy Policy

Effective Date: 29 September 2026

Integral Development Corporation (Europe) Limited operates the Integral Multilateral Trading Facility. This Privacy Policy explains how we use personal data relating to MTF participants, their authorised persons, prospective participants, business contacts and visitors to the MTF website. It should be read alongside the Integral MTF Rulebook and any participant documentation.

WHO WE ARE AND HOW TO CONTACT US

Integral Development Corporation (Europe) Limited, registered in England and Wales with company number 03206664, is the operator of the Integral MTF and is authorised and regulated by the Financial Conduct Authority under FRN 460420. For the purposes described in this Privacy Policy, Integral is the controller of your personal data.
- Address: 1 Great St Helen's, London, EC3A 6HX, United Kingdom.
- Privacy enquiries: [email protected].
- Data Protection Officer: [email protected].
PERSONAL DATA WE COLLECT

The personal data we process depends on your relationship with the MTF and the services you use. It may include the following.
- Identity and professional information, including name, job title, employer, business contact details, role and authority to act for a participant or client.
- Account and access information, including user IDs, platform access records, account preferences and security information.
- Onboarding and due diligence information, including information needed to assess an application, verify identity, undertake anti-money laundering, sanctions, fraud-prevention or credit-reference checks, and meet regulatory requirements.
- Platform and transaction-related information, including personal data contained in orders, transaction records, confirmations, audit trails, platform activity and regulatory reports.
- Communications and recordings, including correspondence and relevant telephone, email and instant-message communications connected with the MTF.
- Website and technical information, including IP address, device and browser information, pages viewed, cookies and similar technologies.
- Information received from participants, clients, public sources, regulatory authorities and other legitimate sources where necessary for the purposes below.

HOW WE USE PERSONAL DATA

We use personal data only where the law permits us to do so. The principal purposes and legal bases are set out below.

Purpose	Legal Basis	Examples of Data Used
Assessing prospective participants and maintaining participant and authorised-person records.	Legitimate interests in operating a properly controlled MTF and protecting its participants and markets; legal obligation where due diligence is required.	Identity, professional, onboarding and due-diligence information.
Providing MTF access and administering the participant relationship.	Performance of the Participant Agreement where applicable; otherwise legitimate interests in operating the MTF.	Account, access, communications and platform information.
Meeting legal and regulatory obligations, including recordkeeping, transaction reporting, transparency, market surveillance and responding to regulatory authorities.	Legal obligation.	Onboarding, transaction, platform, communications and regulatory information.
Protecting the MTF, investigating suspected fraud, misuse, market abuse, security incidents and other breaches.	Legitimate interests in security, integrity and prevention of unlawful or improper activity; legal obligation where applicable.	Technical, platform, communications, due diligence and transaction information.
Managing enquiries, complaints, legal claims and internal governance.	Legitimate interests in administering the MTF and defending legal rights; legal obligation where applicable.	Contact, communications, complaint and relevant regulatory information.
Website analytics and business-to-business marketing.	Consent for non-essential cookies; legitimate interests for proportionate business-to-business marketing, subject to the right to object.	Business contact, preference, website and cookie information.

OUR LEGITIMATE INTERESTS

Where we rely on legitimate interests, these include operating an orderly and resilient MTF, maintaining security, preventing fraud and market abuse, protecting our legal rights, responding to enquiries and developing appropriate services for institutional users. We balance these interests against the rights and freedoms of the individuals concerned.
WHO WE SHARE PERSONAL DATA WITH

We do not sell personal data. We limit access to people who need it for the purposes in this Privacy Policy. We may share personal data with the following recipients where necessary.
- Authorised employees and, where relevant, UK-based Integral group personnel who support the operation, governance or compliance of the MTF.
- The Financial Conduct Authority, other competent authorities, law-enforcement bodies, courts and government agencies where required or permitted by law.
- Professional advisers, auditors and insurers where necessary for advice, assurance, legal claims or regulatory matters.
- Other parties where disclosure is necessary to establish, exercise or defend legal claims, prevent crime or protect the integrity of the MTF.
At the effective date of this Privacy Policy, Integral does not use non-cookie third-party processors to process MTF-related personal data.
INTERNATIONAL TRANSFERS

Integral does not transfer personal data processed as part of the Integral MTF trading service outside the United Kingdom. Website cookie providers may process limited technical information outside the United Kingdom. Where this applies, we will use the transfer safeguards required by UK data-protection law and provide relevant information through the website cookie controls.
HOW LONG WE KEEP PERSONAL DATA

We retain MTF-related personal data for seven years from the end of the relevant participant relationship or the last relevant activity, as applicable. This includes participant and authorised-person records, due-diligence material, communications, platform records, transaction information, surveillance records and regulatory records.

We may keep information longer where necessary to meet a legal or regulatory obligation, respond to a regulator, establish, exercise or defend legal claims, or preserve evidence in connection with an investigation. We retain marketing suppression information only for as long as needed to respect an objection or unsubscribe request. We delete or anonymise personal data when it is no longer required.
COOKIES AND SIMILAR TECHNOLOGIES

The MTF website uses cookies and similar technologies. These may include strictly necessary cookies, Google Analytics cookies, Google Tag Manager technologies and HubSpot technologies used for cookie preferences, analytics and, where enabled, marketing.

We use non-essential cookies only where you have given your consent through the website cookie controls. You can withdraw or change your preferences at any time through those controls. You can also configure your browser to block or delete cookies, although this may affect certain website functions.
YOUR RIGHTS

Subject to applicable law, you have the right to request access to your personal data, correction of inaccurate data, deletion, restriction of processing, data portability and to object to processing based on legitimate interests. You have an absolute right to object to direct marketing. Where we rely on consent, you may withdraw it at any time without affecting processing carried out before withdrawal.

We do not make decisions about you based solely on automated processing where the decision produces legal or similarly significant effects. We may use automated tools to identify potential security, fraud or compliance issues, but material decisions are subject to appropriate human review.

To exercise your rights, contact [email protected] or [email protected]. We may need to verify your identity before responding. We normally respond within one month and will explain if an extension is permitted and necessary.
DATA PROTECTION COMPLAINTS

If you are unhappy with how we have handled your personal data, please contact us first at [email protected] or [email protected] and clearly state that your message is a data-protection complaint. We will acknowledge your complaint within 30 days, investigate it without undue delay and communicate the outcome to you.

You also have the right to complain to the Information Commissioner's Office. Details of how to make a complaint are available at https://ico.org.uk/make-a-complaint/.
SECURITY

We use appropriate technical and organisational measures, including access controls, monitoring, incident management and regular review, to protect personal data against unlawful or accidental loss, disclosure, alteration or access.
CHILDREN AND SPECIAL-CATEGORY DATA

The Integral MTF is for institutional and professional users and is not directed at children. We process special-category data only where necessary and a valid condition under data-protection law applies.
CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy where our processing activities, systems or legal obligations change. We will publish the current version on the MTF website with its effective date.
CONTACT DETAILS

For questions about this Privacy Policy or our handling of personal data, contact the Privacy Team at [email protected] or the Data Protection Officer at [email protected]. You may also write to Integral Development Corporation (Europe) Limited, 1 Great St Helen's, London, EC3A 6HX, United Kingdom.