MarTrust Privacy Policy
Last updated: 27 October 2026
1. Introduction
MarTrust Corporation Limited, a company part of The Marcura Group, respects your privacy and is committed to protecting your personal data. This Privacy Policy (or “Policy”) is issued on behalf of MarTrust Corporation Limited, a company incorporated in England and Wales with its registered office address at Office 7.09, 7th Floor, Tintagel House, 92 Albert Embankment, London, SE1 7TY, United Kingdom.
MarTrust Corporation Limited is authorised and regulated by the Financial Conduct Authority as an Electronic Money Institution (Firm Reference Number 1018989). This Policy applies to holders of MarTrust Accounts (including crew members), contacts at our corporate clients, users of the MarTrust App and visitors to our website.
It is important that you read this Policy together with any other policies we may issue regarding the collection and processing of personal data, so that you are fully aware of how and why we are using your data. This Policy supplements The Marcura Group’s (www.marcura.com) other data protection-related policies and is not intended to override them.
If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO and/or Legal team using the details set out in Section 11 below.
2. Purpose of this Policy
The purpose of this Policy is to inform you as to how we handle your personal data when you use our services, visit and use the functionality contained within our website (regardless of where you visit it from), to inform you about your privacy rights and how the law protects you. This website is not intended for children and we do not knowingly collect data relating to children.
3. Collection of your personal data
| Question | Further information |
| What information do we collect about you? | We may collect, use, store and transfer different kinds of personal data about you.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We have grouped together the personal data we may collect as follows: Identity data includes first name, last name, username or similar identifier, marital status, title, date of birth, gender, nationality and place of birth, and details and copies of your passport or other identity documents (including the photograph they contain). Contact data includes physical address, email address and telephone numbers. Employment data if you are a crew member, includes your rank, the name of your employer (and of any ship manager or crewing agency acting for it) and, where your employer provides it, the vessel you serve on (including its IMO number). Financial data includes bank account information and the balance of your MarTrust Account. Tax data includes your country or countries of tax residence, your Tax Identification Number(s) (TIN), your place of birth and the tax self-certification you provide to us. See Section 4 for how we use this information. Transaction data includes details about payments to you and transactions you perform to your selected beneficiaries. This information includes the amount, currency, type of transaction, source of funds, exchange rate, recipient name and bank details. Technical data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website and the MarTrust App. Profile data includes your interests, preferences, feedback and survey responses. Usage data includes information about how you use the website and the MarTrust App. Aggregated data such as statistical or demographic data that is derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. We may aggregate your usage data (e.g., information about how you use our website and related features) to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy. Through the course of our business relationship, we may ask for additional evidence in order for us to comply with our legal obligations. These can include, but are not limited to, documents required to verify any information provided to us, or evidence of source of funds. We do not ask you for details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic data. We do not ask you for information about criminal convictions and offences. However, the checks we must carry out to prevent financial crime, such as sanctions, politically exposed persons (PEP) and adverse media screening, may reveal such information. Where this happens, we process it only as permitted by the Data Protection Act 2018 (Schedule 1, paragraphs 10 and 12), for the prevention of unlawful acts and to meet our regulatory obligations. Biometric data when we verify your identity, our identity verification provider, Onfido Limited, compares a photograph or video of your face (including a check that you are physically present) with the photograph in your identity document. This involves processing biometric data, which is a special category of personal data. We do this with your explicit consent, which we ask for before the check starts. You do not have to consent, and you can withdraw your consent at any time. If you do not consent, our onboarding team will instead verify your identity by reviewing your identity documents manually, which may be provided to us through your employer. |
| How do we collect your personal data? | We use different methods to collect data from and about you including through:
Direct interactions you may give us your personal information by completing our Customer Onboarding Form (COF), User Form, Cardholders Details Form and providing supporting information and documentation for the purposes of helping us adhere to our compliance obligations, filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
We also collect your data when you are using our App to perform crew to crew transfers via the MarTrust e-Wallet. Tax self-certification when you open an account, and again if your circumstances change or when we review your account, we ask you to confirm your country or countries of tax residence and your Tax Identification Number(s) (see Section 4). Automated technologies or interactions where technical data about your equipment, browsing actions and patterns that we may automatically collect as you interact with our website, by using cookies and other similar technologies. Please see our Cookie Policy for further details. Third parties or publicly available sources where we may receive personal data about you or technical data about you from parties such as Google Analytics, Segment, SurveyMonkey (when you participate in our surveys) based outside the UK. We also receive information about you from identity verification, fraud prevention and sanctions screening providers when we carry out checks we are required by law to perform. Your employer if you are a crew member, your employer (or a ship manager or crewing agency acting on its behalf) gives us your name, address, identity document details and rank (and, where available, the IMO number of your vessel) so that we can open your MarTrust Account. Where we need more information to open your account, such as proof of your address, we may ask your employer for it. Your employer also tells us the amount and currency of the wages and other payments to be made to you. |
| Do you have to provide us with your personal data? | We require certain personal data to allow you to use our services and the website (e.g. to submit a contact form, among other actions) and where we need to collect personal data by law. For example, you must provide a tax self-certification under the International Tax Compliance Regulations 2015. If you do not provide the information we need, we may be unable to open your account or continue to provide our services to you. |
| How do we use your personal data? | We will only use your personal data when the law allows us to. The table below sets out the purposes for which we use your personal data and the lawful basis we rely on for each purpose. Where we rely on legitimate interests, we have explained what those interests are. |
| What we use your personal data for | Our lawful basis |
| To register you as a new customer and to open, administer and close your MarTrust Account. | Performance of our contract with you.
If you are a contact at one of our corporate clients: our legitimate interests in setting up and managing our relationship with that client. |
| To verify your identity, carry out customer due diligence, screen against sanctions, PEP and adverse media lists, and monitor transactions to prevent and detect fraud, money laundering and terrorist financing. | Compliance with our legal obligations, including under anti-money laundering and sanctions laws.
Our legitimate interests in preventing fraud and financial crime and protecting our customers and business, where this goes beyond what the law strictly requires. |
| To verify your identity using facial verification, which compares an image of your face with the photograph in your identity document. | Your explicit consent. If you do not consent, our onboarding team will verify your identity by reviewing your documents manually. |
| To provide our services to you, including receiving wages your employer pays to you, carrying out payments and transfers you instruct, and issuing and operating your MarTrust card. | Performance of our contract with you.
Where your employer has arranged our services for you: our legitimate interests, and those of your employer, in paying you safely and efficiently. |
| To tell your employer whether your MarTrust Account has been opened and is active, and to share aggregated information about how its crew use our services (see “When do we disclose your personal data?” below). | Our legitimate interests, and those of your employer, in making sure your wages can be paid to you through us. |
| To determine your tax residence and report information to HMRC under the Common Reporting Standard (see Section 4). | Compliance with our legal obligations. |
| To send you service communications, such as circulars, reminders, changes to our terms and other important notifications. | Performance of our contract with you and compliance with our legal and regulatory obligations. |
| To send you marketing, including suggestions and recommendations about our services that may interest you. | Email and text marketing to individuals (including crew members, sole traders and partnerships other than limited liability partnerships and Scottish partnerships): your consent.
Marketing to people who work for our corporate clients, at their business contact details: our legitimate interests in promoting our services. You can opt out of marketing at any time (see Section 8). |
| To ask you to take part in surveys or give feedback about our website or services. | Our legitimate interests in understanding our customers’ needs and improving our services. If a survey invitation also contains marketing, we will only send it by email or text message with your consent. |
| To administer, protect and improve our website and the MarTrust App, including through analytics. | Our legitimate interests in running our business, keeping our systems secure and improving our services. Where we use non-essential cookies, we rely on your consent (see our Cookie Policy). |
| To share information within The Marcura Group for account administration, technical support, and business and product development. | Our legitimate interests in operating our business efficiently as part of a group. |
| To respond to requests from regulators, law enforcement and other public authorities, and to establish, exercise or defend legal claims. | Compliance with our legal obligations.
Our legitimate interests in protecting our legal rights. |
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We use automated checks in some of our processes, and we may introduce more over time. For example, if a document you upload does not meet our requirements (such as an unacceptable document type), our systems may automatically reject it and ask you for another one. If you do not provide what we need within the time we give you, your account may be restricted automatically. Where an automated check alone leads to a significant decision about you, such as declining a payment or restricting your account, we will tell you, and you can ask for a member of our team to review the decision, give us your views and contest it.
| Question | Further information |
| Do you have to inform us of any changes to your personal data? | It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. This includes any change to your country of tax residence, which you should tell us about within 30 days so that we can keep your tax self-certification up to date (see Section 4). |
| When do we disclose your personal data? | Your personal data will be shared with the website’s hosting provider, only as necessary to fulfil the website-related services. We partner with and are supported by service providers around the world. Personal information will be made available to these parties only when necessary to fulfil the services they provide to us, such as website, software, system, and platform support; direct marketing services; cloud hosting services; advertising; data analytics; and order fulfilment and delivery.
When using our services, your personal data will be shared with our payment providers and banking partners for the purposes of performing the relevant transaction. When you transact with MarTrust, we may need to share your information with payment providers or banking providers outside the UK, such as intermediary or beneficiary banks. For transparency, verification, and legal requirements, we are required to include certain information on the payment which could include: – Your name – Your date of birth – Your address – Beneficiary details – Your identity document If you hold a MarTrust card, the card is issued by Monavate Ltd under a licence from Mastercard, and MarTrust manages the card programme on Monavate’s behalf. We share your identity, contact and card transaction data with Monavate and the card scheme so that your card can be issued and card payments processed. Monavate acts as a separate controller of this information for its card-issuing activities. Monavate’s privacy notice is available at https://www.monavate.com/legal/privacy-policy. If you are a crew member, we tell your employer (or the ship manager or crewing agency acting on its behalf) when your MarTrust Account has been created and whether it is active, so that it knows it can pay your wages to you through us. We may also share information with your employer about how its crew use the MarTrust Services and the App, but only in aggregated form that does not identify you. We do not share details of your account balance, your card or how you spend or transfer your funds with your employer. If a wage payment cannot be credited to your MarTrust Account, it will be returned to your employer, which will then know that the payment was not credited. In the course of using our services, we may need to pass necessary information on to Governmental departments, regulatory bodies, the police/law enforcement agencies or other third parties where we are legally compelled to do so. This includes HM Revenue & Customs (HMRC), to which we report information about reportable accounts under the Common Reporting Standard (see Section 4), and the Financial Conduct Authority. We also share information with identity verification, fraud prevention and sanctions screening providers who help us meet our legal obligations. MarTrust is affiliated to businesses within The Marcura Group (www.marcura.com), some of which are based outside the UK, and personal information may be made available to them if necessary, for the provision of services, account administration, sales and marketing and technical support, and business and product development. Our employees and contractors are required to follow our data privacy and security policies when handling personal information. Our third-party service providers are not permitted to share or use personal information we make available to them for any other purpose than to provide services to us. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers that process personal data on our behalf to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We will share personal information when we believe it is required, such as to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities. |
4. Tax reporting under the Common Reporting Standard (CRS)
Why we collect tax information. MarTrust is a UK Reporting Financial Institution under the International Tax Compliance Regulations 2015, as amended. These rules implement the OECD Common Reporting Standard. They require us to identify the tax residence of our account holders and report certain account information to HM Revenue & Customs (HMRC) each year. We process this information because we have a legal obligation to do so (UK GDPR Article 6(1)(c)).
What we collect. When you open an account, and again if your circumstances change, we ask you to complete a tax self-certification. It confirms your country or countries of tax residence and your Tax Identification Number(s) (TIN) for each one. For UK tax residents, your TIN is normally your National Insurance number or Unique Taxpayer Reference (UTR). We also use your full name, residential address, date of birth and place of birth from your account records. If you are a controlling person of one of our corporate clients (for example, a director or beneficial owner), we may also collect and report this information about you.
What we report. If your account is reportable, we send HMRC your full name, residential address, country or countries of tax residence, TIN(s), date and place of birth, account number and the account balance or value at the end of the calendar year (or at closure, if the account was closed during the year). We may also report whether a valid self-certification was obtained. Your information will be reported to HMRC and may be transferred to the government of another territory in which you are tax resident, under international agreements for the automatic exchange of tax information.
If you do not provide this information. Providing a self-certification is a legal requirement. If you do not provide it, or it is incomplete, we may be unable to open your account or we will suspend it. While your account is suspended, you will not be able to receive payments, make payouts or use your card. If your country does not issue TINs, or you have not yet been issued one, please tell us and we will record the reason instead.
Keeping it up to date. Please tell us within 30 days if your tax residence, address or other information changes, for example when you change your home country. We may ask you to confirm your details during periodic account reviews.
How long we keep it. We keep self-certifications and the records used to complete our CRS reports for 5 years from the end of the last year in which your account is included in our report to HMRC (or, if your account is not reportable, the last year in which we relied on our due diligence procedures to treat it as not reportable), as required by the Regulations, even if your account has closed.
Your rights. You can ask for a copy of the tax information we hold and ask us to correct it. Because we must process and keep this information by law, we cannot delete it or stop reporting it at your request while the legal retention period applies. Once the information has been reported, HMRC is a separate controller of it; see HMRC’s privacy notice at https://www.gov.uk/government/publications/data-protection-act-dpa-information-hm-revenue-and-customs-hold-about-you/data-protection-act-dpa-information-hm-revenue-and-customs-hold-about-you.
5. International transfers
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. We transfer your personal data outside the UK in the circumstances set out below:
- Where the country has been deemed to provide an adequate level of protection for personal data.
- Where we use certain service providers, we may use specific contracts approved for use in the UK (such as the International Data Transfer Agreement or the International Data Transfer Addendum to the EU Standard Contractual Clauses) which give personal data the same protection it has in the UK.
- Where a payment is to be made to a recipient or bank in a country that does not have UK adequacy regulations and no other safeguard is available, we may transfer the payment details needed to carry out the payment, as this is necessary for the performance of our contract with you or of a contract made in your interest (for example, where you receive a payment that another customer or your employer has asked us to make to you).
Information reported to HMRC under the Common Reporting Standard (see Section 4) is exchanged by HMRC with the tax authorities of other countries under international agreements for the automatic exchange of tax information. MarTrust does not send this information to foreign tax authorities directly.
You can ask for a copy of the safeguards we rely on for a particular transfer by contacting our DPO or Legal team using the details in Section 11.
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such information. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We store all data electronically in a secure manner to protect its confidentiality, integrity and availability. Data is stored on servers which are protected by actively maintained firewalls. We make use of up-to-date anti-virus software and our servers have restricted access.
We cannot guarantee the security of information collected or transmitted electronically however; we take reasonable care to safeguard your personal information. However, we have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our Data Retention Policy which you can request from us by contacting our Legal team using the details in Section 11.
In particular, we keep customer due diligence and transaction records for 5 years after our business relationship with you ends, as required by the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, and tax self-certifications and CRS records for 5 years from the end of the last year in which the account is reported to HMRC or treated as not reportable (see Section 4). We keep these records even if your account has been closed.
8. Your legal rights
| Legal right | Further information |
| Request access to your personal data (commonly known as a “data subject access request”) | This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. |
| Request correction of the personal data we hold about you | This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. |
| Request erasure of your personal data. | This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, subject to our legal and contractual obligations.
You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. For example, we cannot delete information we are required to keep under anti-money laundering or tax reporting (CRS) laws while the legal retention period applies. |
| Object to processing of your personal data | You can object to processing where we are relying on a legitimate interest (or that of a third party), but you feel such processing impacts your fundamental rights and freedoms. However, you cannot object to the processing which is a legal obligation or where we must process your information to satisfy a contract to which you are a party.
You also have the absolute right to object at any time to our use of your personal data for direct marketing, including any profiling related to direct marketing. If you object, we will stop using your personal data for that purpose. |
| Request restriction of processing of your personal data | This enables you to ask us to suspend the processing of your personal data in the following scenarios:
|
| Request the transfer of your personal data to you or to a third party | We will provide your personal data to you, or a third party you have chosen, in a structured, commonly used, machine-readable format. This right applies to personal data you have provided to us that we process by automated means on the basis of your consent or to perform a contract with you. |
| Withdraw consent at any time where we are relying on consent to process your personal data | This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. |
If you wish to exercise any of the rights set out above, please contact the DPO or the Legal team using the details in Section 11.
What will you need from me if you wish to make a subject access request?
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Do I need to pay to access my personal data?
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is manifestly unfounded or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
How long will it take to respond to my subject access request?
We will respond to your request without undue delay and in any event within one month of receiving it. We may extend this by up to two further months where necessary, taking into account the complexity and number of your requests. If we do, we will tell you within one month of receiving your request and explain why. If we reasonably need further information to confirm your identity, the one-month period will start when we receive it. If we reasonably need you to clarify the information you are asking for, the time limit will be paused until we receive your reply and will start again on the following day.
9. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
10. Complaints
If you have a complaint about this Policy or any element of how we use your personal data, you have the right to complain to us. Please contact our DPO or the Legal team using the details in Section 11. We will acknowledge your complaint within 30 days of receiving it, investigate it without undue delay, keep you informed of progress and tell you the outcome. If you are not satisfied and are located in a European Union country, then please contact your local data protection authority. If you are based in, or the issue relates to, the UK, you can contact the Information Commissioner’s Office at the following address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Alternatively, you can use an online form via the Information Commissioner’s website (https://ico.org.uk/make-a-complaint/).
If you are based in, or the issue you would like to complain about took place in the EEA, please visit this website (https://edpb.europa.eu/about-edpb/about-edpb/members_en) for a list of local data protection authorities in other EEA countries.
11. Contact details
We have appointed a Data Protection Officer (DPO). If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO and/or the Legal team by using the details set out below.
| Contact | Contact Information |
| DPO | Lynsey Hanson c/o Ten Intelligence Limited
+44 1732 525810 50 Churchill Square, Kings Hill, West Malling, Kent, ME19 4YU, United Kingdom |
| Legal | [email protected]
+971 (0) 4 3636 275 |