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.
Our Group Legal & Compliance Department (GLCD) is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the GLCD using the details set out in Section 10 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
|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 and gender.
Contact data includes physical address, email address and telephone numbers.
Financial data includes bank account 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.
Profile data includes your interests, preferences, feedback and survey responses.
Usage data includes information about how you use the website.
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 collect any 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 and biometric data. Nor do we collect any information about criminal convictions and offences.
|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:
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 EU
|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.|
|How do we use your personal data?||We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
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 third party 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.
|Do you have to inform of 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.|
|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 of the EEA, 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
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.
MarTrust is affiliated to businesses within The Marcura Group (www.marcura.com), some of which are based outside the EEA, 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.
We may partner with other organisations (including but not limited to MailChimp) and as part of these arrangements, you may be a customer of our business partners in addition to MarTrust. You should review the privacy statements of our partners if you would like to know more about the information they collect.
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 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. 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. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have 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 which give personal data the same protection it has in the UK.
5. 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. If you provide paper-based documentation for the purpose of identity verification these will be stored and kept in the fireproof and secure filing cabinet located in our registered office.
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.
5. 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 GLCD, the details of which are shown below.
7. 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.
|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 can not 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.|
|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.
|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 GLCD.
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 clearly unfounded, repetitive 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 try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
8. 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.
If you have a complaint about this Policy or any element of how we use your personal data, then please contact us first. 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
Alternatively, you can use an online form via the Information Commissioner’s website (https://ico.org.uk/concerns).
If you are based in, or the issue you would to complain about took place in the EEA, please visit this website (https://edpb.europa.eu/aboutedpb/board/members_en) for a list of local data protection authorities in other EEA countries.
10. Contact details
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO, our EU Representative (as required pursuant to Article 27 of the General Data Protection Regulation 2016/679 of the European Parliament) and/or the GLCD by using the details set out below.
|DPO||Nikhil Kamboj c/o Ten Intelligence Ltd
+44 (0) 7738 219 101
|EU Representative||Miguel Verissimo|
+971 (0) 4 3636 275