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INTEGRAL PRIVACY POLICY


Data protection is of a particularly high priority for Integral Development
Corp., and its subsidiaries (collectively “Integral”). In this Privacy Policy,
we would like to disclose the nature, scope, and purpose of the personal data we
collect, use and process. Furthermore, data subjects are informed, by means of
this Privacy Policy of the rights to which they are entitled. This Privacy
Policy embodies our commitment to you on protection of your data.

 1. Definitions

    The data protection declaration of Integral is based on the terms used by
    the European Union for the adoption of the General Data Protection
    Regulation (GDPR). Our data protection declaration is for the general
    public, as well as our customers, employees, agents and business partners.
    In this Privacy Policy, Integral uses, inter alia, the following terms:

     1. Personal data
    
        Personal data means any information relating to an identified or
        identifiable natural person (“data subject”). An identifiable natural
        person is one who can be identified, directly or indirectly, in
        particular by reference to an identifier such as a name, an
        identification number, location data, an online identifier or to one or
        more factors specific to the physical, physiological, genetic, mental,
        economic, cultural or social identity of that natural person.
    
     2. Data subject
    
        Data subject is any identified or identifiable natural person, whose
        personal data is processed by the controller responsible for the
        processing.
    
     3. Processing
    
        Processing is any operation or set of operations which is performed on
        personal data or on sets of personal data, whether or not by automated
        means, such as collection, recording, organisation, structuring,
        storage, adaptation or alteration, retrieval, consultation, use,
        disclosure by transmission, dissemination or otherwise making available,
        alignment or combination, restriction, erasure or destruction.
    
     4. Profiling
    
        Profiling means any form of automated processing of personal data
        consisting of the use of personal data to evaluate certain personal
        aspects relating to a natural person, in particular to analyse or
        predict aspects concerning that natural person's performance at work,
        economic situation, health, personal preferences, interests,
        reliability, behaviour, location or movements.
    
     5. Controller
    
        Controller or controller responsible for the processing is the natural
        or legal person, public authority, agency or other body which, alone or
        jointly with others, determines the purposes and means of the processing
        of personal data; where the purposes and means of such processing are
        determined by applicable law, the controller or the specific criteria
        for its nomination may be provided for by applicable law.
    
     6. Processor
    
        Processor is a natural or legal person, public authority, agency or
        other body which processes personal data on behalf of the controller.
    
     7. Recipient
    
        Recipient is a natural or legal person, public authority, agency or
        another body, to which the personal data are disclosed, whether a third
        party or not. However, public authorities which may receive personal
        data in the framework of a particular inquiry in accordance with Union
        or Member State law shall not be regarded as recipients; the processing
        of those data by those public authorities shall be in compliance with
        the applicable data protection rules according to the purposes of the
        processing.
    
     8. Third party
    
        Third party is a natural or legal person, public authority, agency or
        body other than the data subject, controller, processor and persons who,
        under the direct authority of the controller or processor, are
        authorised to process personal data.
    
     9. Consent
    
        Consent of the data subject is any freely given, specific, informed and
        unambiguous indication of the data subject's wishes by which he or she,
        by a statement or by a clear affirmative action, signifies agreement to
        the processing of personal data relating to him or her.

 2. Name and Address of the Controller/Processor

    The Controller or Processor for the purposes of this Privacy Policy pursuant
    to the European Union General Data Protection Regulation (EUGDPR) and other
    data protection laws applicable to Integral is:

    Integral Development Corp.
    3223 Hanover Street
    Suite 110
    Palo Alto, CA 94304 USA
    privacy@integral.com
    www.integral.com

 3. COLLECTION OF INFORMATION
     1. Why Integral collects information including Personal Data.
    
        In order to better serve your particular needs, Integral (and third
        parties working on behalf of Integral) may collect confidential
        information from and/or about you during the course of your relationship
        with Integral. Some of this information may be Personal Data.
    
        This confidential information is collected through various methods
        including, but not limited to Integral’s platform(s), applications and
        websites. Integral may also obtain information directly from you and
        from third party sources. We may also use the standard "cookie" feature
        of major browser applications and other data capture mechanisms that
        allow us to store data about you including, without limitation, your
        visit to our platforms, applications and websites.
    
     2. Specific information Integral collects and how it is collected
         1. General
        
            Integral collects several types of information when a data subject
            or automated system interacts with Integral, its platforms,
            applications, websites and service offerings. This information
            includes, for example:
        
             1. Contact information including name, email, phone, fax and
                address of individual users of Integral’s platforms,
                applications and websites
             2. Organization/Company name and customer type of individual users
                of Integral’s platforms, applications and websites
             3. National ID (e.g. driving license, Passport, CONCAT, tax Id) of
                users of Integral’s platforms where required by applicable law,
                for example by MIFID II.
             4. The browser types and versions used,
             5. System information related to the accessing of Integral’s
                platforms, applications, websites and services including,
                without limitation, the website from which an accessing system
                reaches our website (so-called referrers), the sub-websites, the
                date and time of access to the Internet site, an Internet
                protocol address (IP address), the Internet service provider of
                the accessing system, and any other similar data
             6. Personal data of employees and agents relevant to their
                employment or work on behalf of Integral including, name, email,
                phone, address, passport information, date of birth, photo,
                marital status, spouse and dependent information, NIC#, bank
                account details, emergency contact information, salary
                information, ethnic information (self-identified) and past
                employment history
                
                
        
         2. Cookies
        
            The Internet pages of Integral use cookies. Cookies are text files
            that are stored in a computer system via an Internet browser. Many
            Internet sites and servers use cookies. Many cookies contain a
            so-called cookie ID. A cookie ID is a unique identifier of the
            cookie. It consists of a character string through which Internet
            pages and servers can be assigned to the specific Internet browser
            in which the cookie was stored. This allows visited Internet sites
            and servers to differentiate the individual browser of the dates
            subject from other Internet browsers that contain other cookies. A
            specific Internet browser can be recognized and identified using the
            unique cookie ID. Through the use of cookies, Integral can provide
            the users of this website with more user-friendly services that
            would not be possible without the cookie setting. By means of a
            cookie, the information and offers on our website can be optimized
            with the user in mind. Cookies allow Integral to recognize our
            website users. The purpose of this recognition is to make it easier
            for users to utilize Integral’s website. The website user that uses
            cookies, e.g. does not have to enter access data each time the
            website is accessed, because this is taken over by the website, and
            the cookie is thus stored on the user's computer system. The data
            subject may, at any time, prevent the setting of cookies through the
            Integral website by means of a corresponding setting of the Internet
            browser used, and may thus permanently deny the setting of cookies.
            Furthermore, already set cookies may be deleted at any time via an
            Internet browser or other software programs. This is possible in all
            popular Internet browsers. If the data subject deactivates the
            setting of cookies in the Internet browser used, not all functions
            of our website may be entirely usable.
        
         3. Information about data subjects from third parties
        
            Integral obtains information including personal data from third
            parties. This occurs in two contexts:
        
             1. Personal data about data subjects that are individuals that are
                employees or agents of Integral’s institutional customers.
             2. Service providers to Integral related to employment or retention
                of Integral’s employees or agents.
                
                
        
            In such cases, Integral is a Processor and not a Controller and
            Integral processes the information on behalf of or for the benefit
            of the Controller and relies on the Controller for obtaining consent
            or other lawful purpose for processing the information.

 4. What Integral Does with the Information it collects

    Integral uses confidential information including Personal Data in: (i)
    authenticating and verifying authorized use of our platforms, applications,
    websites, and services, and (ii) improving, offering and administering
    platforms, applications, websites, and services. We may also use and
    disclose confidential information and Personal Data in aggregate or
    statistical form which is not identifiable with the submitter, or as
    permitted/required by law.

    Integral may also give information about the submitter, such as name and
    address, to persons or organizations that may wish to provide you with
    information about their or related products or services. These organizations
    may include affiliates of Integral.

    Integral may also give information about the submitter when compelled by
    legal order (e.g. subpoena) or applicable law.

 5. What is the lawful basis for Integral controlling or processing the
    information:

    Integral will ensure that one of the following lawful bases exist for all
    confidential information collected, including, Personal Data:

     1. Information is required to be collected by contract – where the
        processing is necessary for the performance of a contract. An example of
        this is when Integral collects individual representative information on
        customer contracts.
     2. Compliance with legal/regulatory obligation: where the processing is
        necessary for Integral to comply with a legal obligation under
        applicable law. An example of this is where Integral collects
        identifying information, including National ID numbers, from traders
        using its platform under MIFID II.
     3. Legitimate interest: Examples of legitimate interests include fraud
        prevention and transferring personal data within a group of companies or
        processing of personal data strictly necessary and proportionate for the
        purposes of ensuring network and information security.
     4. Consent: where the individual has given consent for their personal data
        to be processed for a specific purpose. An example of this is where
        customers who are natural persons agree to use our website applications,
        or when and employee of Integral submits their personal information to
        our Human Resources department.
     5. Vital interests of individual. An example of this is if Integral needed
        to process Personal Data because it is necessary to protect the
        individual’s or someone else’s life.
     6. The processing is in the interest of the relevant public.
        
        

 6. What is the Period which Integral will keep the information

    The criteria used to determine the period of storage of confidential
    information including personal data is the relevant lawful purpose for which
    it is held or 10 years, whichever is later. If the storage of the data is no
    longer required as previously stated then the confidential information
    including personal data is blocked or erased.

 7. Rights of the data subject for information it collects
     1. Right of confirmation
    
        Each data subject shall have the right to obtain from the controller the
        confirmation as to whether or not personal data concerning him or her
        are being processed. If a data subject wishes to avail himself of this
        right of confirmation, he or she may, at any time, contact Integral’s
        Data Protection staff at the contact information stated herein.
    
     2. Right of access
    
        Each data subject shall have the right to obtain from the controller
        free information about his or her personal data stored at any time and a
        copy of this information. Furthermore, the data subject may have access
        to the following information:
    
         1. the purposes of the processing;
         2. the categories of personal data concerned;
         3. the recipients or categories of recipients to whom the personal data
            have been or will be disclosed, in particular recipients in third
            countries or international organisations;
         4. where possible, the envisaged period for which the personal data
            will be stored, or, if not possible, the criteria used to determine
            that period;
         5. the existence of the right to request from the controller
            rectification or erasure of personal data, or restriction of
            processing of personal data concerning the data subject, or to
            object to such processing;
         6. the existence of the right to lodge a complaint with a supervisory
            authority;
         7. where the personal data are not collected from the data subject, any
            available information as to their source;
         8. the existence of automated decision-making, including profiling,
            referred to in Article 22(1) and (4) of the GDPR and, at least in
            those cases, meaningful information about the logic involved, as
            well as the significance and envisaged consequences of such
            processing for the data subject.
         9. Furthermore, the data subject shall have a right to obtain
            information as to whether personal data are transferred to a third
            country or to an international organisation. Where this is the case,
            the data subject shall have the right to be informed of the
            appropriate safeguards relating to the transfer.
            
            
    
     3. Right to rectification
    
        Each data subject shall have the right to obtain from the controller
        without undue delay the rectification of inaccurate personal data
        concerning him or her. Taking into account the purposes of the
        processing, the data subject shall have the right to have incomplete
        personal data completed, including by means of providing a supplementary
        statement.
    
     4. Right to erasure (Right to be forgotten)
    
        Each data subject shall have the right to obtain from the controller the
        erasure of personal data concerning him or her without undue delay, and
        the controller shall have the obligation to erase personal data without
        undue delay where one of the following grounds applies, as long as the
        processing is not necessary:
    
         1. The personal data are no longer necessary in relation to the
            purposes for which they were collected or otherwise processed.
         2. The data subject withdraws consent to which the processing is based
            according to point (a) of Article 6(1) of the GDPR, or point (a) of
            Article 9(2) of the GDPR, and where there is no other legal ground
            for the processing.
         3. The data subject objects to the processing pursuant to Article 21(1)
            of the GDPR and there are no overriding legitimate grounds for the
            processing, or the data subject objects to the processing pursuant
            to Article 21(2) of the GDPR.
         4. The personal data have been unlawfully processed.
         5. The personal data must be erased for compliance with applicable law.
         6. The personal data have been collected in relation to the offer of
            information society services referred to in Article 8(1) of the
            GDPR.
            
            
        
            Where the controller has made personal data public and is obliged
            pursuant to Article 17(1) to erase the personal data, the
            controller, taking account of available technology and the cost of
            implementation, shall take reasonable steps, including technical
            measures, to inform other controllers processing the personal data
            that the data subject has requested erasure by such controllers of
            any links to, or copy or replication of, those personal data, as far
            as processing is not required.
    
     5. Right of restriction of processing
    
        Each data subject shall have the right to obtain from the controller
        restriction of processing where one of the following applies:
    
         1. The accuracy of the personal data is contested by the data subject,
            for a period enabling the controller to verify the accuracy of the
            personal data.
         2. The processing is unlawful and the data subject opposes the erasure
            of the personal data and requests instead the restriction of their
            use instead.
         3. The controller no longer needs the personal data for the purposes of
            the processing, but they are required by the data subject for the
            establishment, exercise or defence of legal claims.
         4. The data subject has objected to processing pursuant to Article
            21(1) of the GDPR pending the verification whether the legitimate
            grounds of the controller override those of the data subject.
            
            
    
     6. Right to data portability
    
        Each data subject shall have the right to receive the personal data
        concerning him or her, which was provided to Integral, in a structured,
        commonly used and machine-readable format. He or she shall have the
        right to transmit that data to another controller without hindrance from
        Integral, as long as the processing is based on consent pursuant to
        point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of
        the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the
        GDPR, and the processing is carried out by automated means, as long as
        the processing is not necessary for the performance of a task carried
        out in the public interest or in the exercise of official authority
        vested in Integral.
    
        Furthermore, in exercising his or her right to data portability pursuant
        to Article 20(1) of the GDPR, the data subject shall have the right to
        have personal data transmitted directly from Integral to another
        controller, where technically feasible and when doing so does not
        adversely affect the rights and freedoms of others.
    
     7. Right to object
    
        Each data subject shall have the right to object, on grounds relating to
        his or her particular situation, at any time, to processing of personal
        data concerning him or her, which is based on point (e) or (f) of
        Article 6(1) of the GDPR. This also applies to profiling based on these
        provisions.
    
        Integral shall no longer process the personal data in the event of the
        objection, unless it can demonstrate compelling legitimate grounds for
        the processing which override the interests, rights and freedoms of the
        data subject, or for the establishment, exercise or defence of legal
        claims. If Integral processes personal data for direct marketing
        purposes, the data subject shall have the right to object at any time to
        processing of personal data concerning him or her for such marketing.
        This applies to profiling to the extent that it is related to such
        direct marketing. If the data subject objects to Integral to the
        processing for direct marketing purposes, Integral will no longer
        process the personal data for these purposes.
    
        In addition, the data subject has the right, on grounds relating to his
        or her particular situation, to object to processing of personal data
        concerning him or her by Integral for scientific or historical research
        purposes, or for statistical purposes pursuant to Article 89(1) of the
        GDPR, unless the processing is necessary for the performance of a task
        carried out for reasons of public interest.
    
     8. Automated individual decision-making, including profiling
    
        Each data subject shall have the right not to be subject to a decision
        based solely on automated processing, including profiling, which
        produces legal effects concerning him or her, or similarly significantly
        affects him or her, as long as the decision (1) is not is necessary for
        entering into, or the performance of, a contract between the data
        subject and a data controller, or (2) is not authorised by applicable
        law and which also lays down suitable measures to safeguard the data
        subject's rights and freedoms and legitimate interests, or (3) is not
        based on the data subject's explicit consent.
    
        If the decision (1) is necessary for entering into, or the performance
        of, a contract between the data subject and a data controller, or (2) it
        is based on the data subject's explicit consent, Integral shall
        implement suitable measures to safeguard the data subject's rights and
        freedoms and legitimate interests, at least the right to obtain human
        intervention on the part of the controller, to express his or her point
        of view and contest the decision.
    
     9. Right to withdraw data protection consent
    
        Each data subject shall have the right to withdraw his or her consent to
        processing of his or her personal data at any time.
    
        If a data subject wishes to exercise the rights stated herein, he or she
        may, at any time, contact Integral’s privacy staff in writing at the
        contact information provided above.

 8. Security — Data protection for applications and the application procedures

    To help ensure the security of your confidential information that you submit
    to us via our platforms or Sites that use HTTPS , we use security software
    to encrypt the information before and during its transmission through the
    Internet. We allow information to be submitted for transmission only if your
    browser is compatible with our security software. If your browser is not
    compatible, you will receive a message indicating your transaction cannot be
    completed because of the security risk.

    E-mail messages are not secure. Our security software does not encrypt
    e-mail messages. Please keep in mind that transmitting information via the
    Internet is never completely secure and that, therefore, any information
    submitted may be intercepted, viewed, collected, used, altered, copied or
    disclosed by others. We are not responsible for the security or
    confidentiality of communications you send to us (or that we send to you)
    through the Internet.

 9. Links to Other Web Sites

    Integral’s applications and websites may contain links to other websites and
    applications of third parties. Please note that when you click on one of
    these links, you will be accessing a website or application that Integral
    does not control and which may be governed by privacy policies and practices
    that differ from Integral’s. Integral is not, and will not be, responsible
    for the privacy policies or practices of third parties or the content or
    security of any third-party websites and applications.



© 2016–2023 Integral Development Corp. Integral reserves the right to modify
this Privacy Policy at anytime in its absolute discretion.



INTEGRAL COOKIE POLICY


Like almost every other online service, our Services (as defined in the Integral
User Agreement), including our website and apps, use cookies and similar
technologies to provide you with an enhanced user experience as well as allowing
us to analyse and improve our Services. We would not be able to provide you with
all of our Services, including certain personalised features, without the use of
cookies and related technology and as such, your computer, mobile phone, tablet
or other enabled mobile device (which we refer to collectively in this policy as
a “device”) will need to be set up to enable such technologies.

By visiting and continuing to browse our website, downloading and using our app
and using your Integral account, including, where appropriate, with your browser
settings adjusted to accept cookies, you are consenting to our use of cookies,
web beacons and related technologies to provide our Services. If you do not
consent to our use of cookies your only recourse is to stop using the Services
and stop visiting our website. You are also free to disable cookies in your
browser, but doing so may interfere with your use of our website or the
Services. See Section 2 below for information on how to disable cookies.

1. WHAT DO WE MEAN WHEN WE USE THE TERM ‘COOKIE’, ‘WEB BEACON’ OR ‘SIMILAR
TECHNOLOGY’?

Cookies is a term used to describe is a small text file (typically made of
letters and numbers) that is downloaded and stored on your browser or your
device by websites that you visit. They are sometimes considered as forming part
of the “memory” of your use of websites and related services as they allow
service providers to remember you and respond appropriately.

Cookies are typically split into 3 main types, namely:

 * Session cookies.
   Session cookies are stored in your device’s memory only for the length of
   time of your browsing session. They are not accessible after your browser
   session may have been inactive for a period of time and are deleted from your
   device when your browser is closed down.
 * Persistent cookies.
   Persistent cookies are stored in your devices’ memory and are not deleted
   when your browser is closed. Persistent cookies can helpfully remember you
   and your preferences each time you access our Services.
 * Third party cookies.
   Third party cookies are installed by third parties with the aim of collecting
   certain information to carry out various research into behaviour,
   demographics etc.

Integral uses a combination of these types of cookies.

Cookies can also be further categorized as follows:

 * Strictly necessary cookies.
   These are cookies that are required for the necessary operation of our
   services. They include, for example, cookies that enable you to securely log
   into our app.
 * Performance cookies.
   They allow us to recognize and count the number of visitors and to see how
   visitors move around our website when they are using it. This helps us to
   improve the way our website works, for example, by ensuring that users are
   finding what they are looking for easily.
 * Functionality cookies.
   These are used to recognize you when you return to our website. This enables
   us to personalize our content for you and remember your preferences (for
   example, your choice of language or region).
 * Targeting cookies.
   These cookies record your visit to our website, the pages you have visited
   and the links you have followed. We will use this information to make our
   website and the advertising displayed on it more relevant to your interests.
   We may also share this information with third parties for this purpose.
   
   

Web beacons

The term ‘web beacon’ is used to describe an object embedded in a webpage or
email. This object is typically invisible to you, but it permits us to confirm
whether you have viewed the web page and/or email (as the case may be). There
are other names for ‘web beacons’ which you may come across – these include web
bug, tracking bug, clear gif and pixel tag.

2. MANAGING COOKIES

You can manage your cookies (including the enabling or disabling of cookies) by
using your browser. For example, you block cookies by activating the setting on
your browser that allows you to refuse the setting of all or some cookies.
However, if you use your browser settings to block all cookies (including
cookies that are strictly necessary) you may not be able to access all or parts
of our Services.

Each browser is different and as such we suggest that you check the ‘Help’ menu
on your particular browser (or your mobile phone’s handset manual) to learn how
to change your cookie preference. You may also find more information on how to
manage your cookies from third party websites (such as
www.allaboutcookies.org/manage-cookies/).

Here are some links to popular browser cookie information pages which you might
find helpful to assist in your cookie management:

 * Google Chrome
 * Mozilla Firefox
 * Safari
 * Internet Explorer

3. GENERAL

We hope the above has clearly explained how we use cookies and similar
technologies as well as how you many manage such matters. While we have provided
details of third party websites and services which we thought you may find
useful, please note that we are not responsible for the content, functionality
or services provided by such sites. If you have any further questions or
comments about our use of cookies, please contact us via: privacy@integral.com.
.



E-MAIL DISCLAIMER NOTICE


Emails and any attachments are to be viewed solely by the intended recipient of
Integral Development Corp. (“Integral”). If the reader of the email is not the
intended recipient, you are hereby notified that any use, dissemination,
distribution or copying of this communication is strictly prohibited. Any
confidential information contained in the email must remain confidential. If you
have received the email in error, please immediately notify the sender and
delete the message and all attachments. Although Integral takes reasonable
precautions, e-mail transmission cannot be guaranteed to be secure or error-free
as information could be intercepted, corrupted, lost, destroyed, arrive late or
incomplete, or contain viruses. Integral therefore does not accept
responsibility for the content of emails including, without limitation, any
errors or omissions. If verification is required please contact Integral
Development Corp., 850 Hansen Way, Palo Alto, California 94304 USA,
www.integral.com, or in the UK contact Integral Development Corporation (Europe)
Limited registered in England (#03206664) office address: Tower 42, Level 39, 25
Old Broad Street, London EC2N 1HQ registered address: Gladstone House, 77-79
High Street, Egham, Surrey, TW20 9HY and regulated by the Financial Conduct
Authority. All trademarks displayed, whether denoted as such or not, are the
trademarks of Integral. Nothing contained herein should be construed as
granting, by implication, estoppel, or otherwise, any license or right to use
any Integral trademark or intellectual property without the express written
permission of Integral.

FX GLOBAL CODE DISCLAIMER


Integral supports, though does not mandate, users of its platform to publish a
Statement of Commitment to the FX Global Code or adhere to its principals. Users
should therefore be aware that in transacting on the platform that they may be
completing transactions both with users who have adopted the FX Global Code and
those who have not.

MOBILE APPS


We take the privacy of our users seriously and our mobile apps are designed to
not collect any personal information. Our apps are created to provide a seamless
and enjoyable experience without compromising the security of our users' data.
Our apps do not ask for personal information such as names, addresses, emails,
or payment information, and we do not store any information that could be used
to personally identify our users.

We believe in protecting the privacy of our users and ensuring that their data
is safe. Our mobile apps only collect the minimum amount of data necessary to
provide the service and this data is not shared with any third parties. Our
commitment to protecting user privacy is an integral part of our business and we
take all necessary steps to maintain the security of our users' data.

If you have any questions or concerns about our privacy policy, please feel free
to contact us.

TO YOUR CURRENCY TECHNOLOGY NEEDS

TO YOUR CURRENCY
TECHNOLOGY NEEDS

Speak to us today

HELLO@INTEGRAL.COM

Drop us a line to discuss how we can support the most integral FX functions for
your organization.

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Integral Development Corp

 * Privacy Policy
 * Cookie Policy
 * Email Disclaimer
 * FX Global Code Disclaimer
 * Mobile Apps

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©2023 Integral Development Corp. All rights reserved. Integral technology is
protected under U.S. patents and patent pending applications and related
intellectual property rights.

Awards & Recognition



©2023 Integral Development Corp. All rights reserved. Integral technology is
protected under U.S. patents and patent pending applications and related
intellectual property rights.