OMeT Institutional Privacy Policy

v1.0.0

April 10, 2026

Governance & Applicability

©2026 OM e-Trading LLC ("OMeT" or the "Company"). OMeT is a registered Swap Execution Facility (SEF) regulated by the Commodity Futures Trading Commission (CFTC). OMeT operates as an institutional digital marketplace facilitating rules-based, anonymous, all-to-all execution for cleared OTC derivatives.

The platform utilizes a proprietary matching engine and the patented eMOD® protocol (comprising Request for Market, Open Market Phase, and Volume Matching) to ensure pre-trade certainty and immediate clearing finality. Access to OMeT’s infrastructure and related data products is restricted solely to eligible institutional participants, including broker-dealers, asset managers, and other qualified counterparties who meet CFTC SEF eligibility requirements. Retail investors are strictly prohibited from accessing OMeT services.

Information provided on this site is sourced from OMeT’s internal system of record and trusted infrastructure partners, including OSTTRA, GMEX, and LimitHub. While OMeT strives for technical stewardship and structural accuracy, all information is provided "as is" without express or implied warranties. Nothing on this website constitutes an offer, solicitation, or recommendation to enter into any specific derivative transaction or investment strategy.

OMeT, the OMeT logo, eMOD®, Request for Market (RFM), Open Market Phase (OMP), and Volmax (VMX) are trademarks or registered trademarks of OM e-Trading LLC.

Participant Identity & Anonymity Mechanics

OMeT is committed to ensuring our digital infrastructure is accessible and user-friendly for all institutional participants. Our design system prioritizes "Authority Without Noise," utilizing high-contrast grids and data-dense layouts for professional clarity. If you encounter difficulty navigating our site or notice features that are not fully accessible, please email our team at compliance@om-etrading.com with “Institutional Access” in the subject line. We treat accessibility as a component of our broader operational governance

The "Waterfall" Data Capture (Audit Trail)

OMeT maintains an immutable record of all platform activity to ensure market integrity.

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System State Logs: The platform captures every keystroke and state transition within the matching engine.
Metadata Categories: We collect structured execution metadata, including timestamps, order priority levels, and limit token validations.
No Interpretive Data: We do not capture or provide internal debate, opinions, or strategic speculation; we persist only deterministic logic.

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Infrastructure Isolation & Data Sovereignty

To meet the rigorous standards of global financial institutions, OMeT utilizes Ownership-First infrastructure.

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Dedicated AWS Instances: Participant data is managed within isolated, OMeT-managed AWS instances with strictly controlled access.
Access Control: Network security is enforced via Mutual TLS (mTLS) for verified connectivity and HashiCorp Vault for secrets management.
"Break-Glass" Protocol: Emergency administrative access is governed by an audited protocol requiring forensic justification and post-session reporting.

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Regulatory Data Retention

Data retention is a fiduciary obligation, not a storage policy.

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CFTC Compliance: Transactional records are retained for a minimum of five (5) years post-maturity of the swap.
Operational Logs: Sandbox and "Digital Twin" audit logs are retained for twelve (12) months to support compliance monitoring.
Immutable Storage: Records are persisted in auditable formats that prioritize regulatory observability.

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Third-Party Market Nodes

Information is disclosed only to integrated market infrastructure required for execution and clearing.

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Clearinghouses (CCPs): CME Group, LCH, and Asigna.
Middleware & Utilities: OSTTRA LimitHub (credit verification) and MarketWire (post-trade affirmations).
No Commercial Data Sale: OMeT does not share participant data with default advertising or retargeting networks.

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Canon Certification & "Never Say" Audit

This draft has undergone a Vision Charter Compliance Review:

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IDENTITY CHECK: Frames OMeT as "Market Structure," not a platform or app.
TONE CHECK: Neutral, analytical, and devoid of "game-changing" or "disruptive" clichés.
CLAIMS CHECK: Describes conditions (mechanics) rather than promising execution outcomes.

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Institutional Cookies & Behavioral Tracking

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Exclusion of Commercial Ad Pixels

To maintain High Signal Density and project Institutional Permanence, OMeT enforces a strict prohibition on commercial behavioral tracking.

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No Ad Pixels: OMeT does not utilize LinkedIn Insights Tags, Google Ad Pixels, or Meta Pixels on its primary marketing or operational domains.
Reasoning: We view third-party tracking as a source of Information Leakage and a "Digital Veneer" that compromises the structural integrity required by Tier 1 banks.
Direct Interaction: We believe true authority does not track; it describes. We rely on direct, peer-to-peer technical reviews rather than retargeting algorithms to engage participants.

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Mandatory Operational Cookies

OMeT utilizes only Essential Cookies required for the deterministic operation of the platform.

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Security & Authentication: Temporary session tokens are utilized to enforce Mutual TLS (mTLS) handshakes and secure access to the Client Login portal.
Platform Performance: Local storage may be used to persist your Customizable Dashboard settings and tenor panel preferences to ensure a high-performance operator experience.
Consent Stamping: A single boolean value is stored to record your GDPR/regulatory consent status, creating a permanent compliance record in our backend CRM.

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Non-Identifiable Metrics

We use anonymized, first-party analytics to monitor Platform Health and Liquidity Formation metrics (e.g., matching engine latency or STP success rates). These metrics are never shared with external marketing agencies and are used solely to improve our Market Structure Architecture.

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