Privacy Policy

For the purposes of the DPA, CAYRE acts as a data controller in relation to the personal information we determine how and why to process.

This means CAYRE is responsible for ensuring that personal information under our control is handled in accordance with applicable data protection requirements.

Certain third party service providers, including payment, banking, technology, hosting, communications and Smart Locker providers, may process personal information in connection with the services they provide to CAYRE.

In accordance with the DPA, CAYRE aims to ensure that personal information is:

• Processed fairly and lawfully
• Collected for specified and legitimate purposes
• Limited to information reasonably necessary for those purposes
• Kept accurate and, where appropriate, up to date
• Retained only for as long as reasonably necessary
• Processed with respect for your rights
• Protected through appropriate security measures
• Transferred outside the Cayman Islands only where appropriate protections or other lawful grounds are in place

Depending on how you use CAYRE, we may collect:

• Your name
• Email address
• Telephone number
• Account and profile information
• Delivery, collection and transaction information
• Information relating to items you list, purchase or sell
• Order numbers and transaction history
• Seller payment or withdrawal information where required
• Ratings, reviews and feedback
• Communications between you and CAYRE
• Smart Locker information, including locker location, selected locker size, access information and delivery or collection timestamps
• Device, browser, IP address and website usage information
• Information collected through cookies or similar technologies
• Other information you voluntarily provide to us

We aim to collect only the personal information reasonably necessary to operate CAYRE and provide our services.

We may use your information to:

• Create and manage your CAYRE account
• Enable you to list, buy and sell items
• Process and manage transactions
• Facilitate payments, seller withdrawals and refunds
• Facilitate Smart Locker drop offs and collections
• Send order confirmations, collection information, locker codes and other transaction related notifications
• Communicate with buyers and sellers where necessary
• Provide customer support
• Maintain transaction and business records
• Investigate disputes, complaints or suspected misuse
• Detect and prevent fraud and unauthorised activity
• Protect the safety and security of CAYRE and our community
• Improve the website, Smart Locker system and overall CAYRE experience
• Comply with applicable legal, regulatory, accounting and banking requirements
• Send promotional or marketing communications where permitted

We will not use personal information for an unrelated purpose unless that use is permitted by applicable law or, where required, we have obtained your consent.

CAYRE will only process personal information where there is an appropriate lawful basis for doing so.

Depending on the circumstances, this may include:

Contractual necessity: Where processing is necessary to provide the CAYRE service you have requested, such as creating an account, completing a transaction or facilitating a Smart Locker exchange.

Legal obligations: Where information must be processed or retained to comply with applicable laws or regulatory requirements.

Legitimate interests: Where processing is reasonably necessary for CAYRE's legitimate business interests, such as protecting the platform, preventing fraud, resolving disputes and improving our services, provided those interests do not unjustifiably prejudice your rights.

Consent: Where you have provided consent for a specific purpose, such as certain forms of marketing communication where consent is required.

Online payments made through CAYRE are processed using Cayman National Bank's ecommerce merchant services and its approved payment technology providers.

When a buyer makes a payment, certain information necessary to authorise and process the transaction may be provided to Cayman National Bank and the relevant payment service providers.

CAYRE does not intend to directly collect or store complete debit or credit card details where those details are securely handled through the payment processing service.

CAYRE Wallet

Every CAYRE user will have access to a CAYRE Wallet within their account.

When a seller successfully sells an item through CAYRE, the amount due to the seller will be credited to their CAYRE Wallet in accordance with CAYRE's applicable fees, commission and transaction terms.

Available CAYRE Wallet credits may be used within the platform where this functionality is available or may be withdrawn to the user's nominated bank account.

Seller Withdrawals

Users may request to withdraw available funds from their CAYRE Wallet at any time.

CAYRE allows up to 48 hours from a valid withdrawal request for the transfer to be processed to the user's nominated bank account. Additional processing time may apply depending on the receiving bank or circumstances outside CAYRE's control.

To process a withdrawal, CAYRE will need to collect and process certain banking information. This may include:

• Account holder's full name
• Bank name
• Bank account number
• Any additional banking or payment information reasonably required by Cayman National Bank or the relevant financial institution to complete the transfer

This information will be used for purposes including processing requested withdrawals, verifying payment instructions, maintaining transaction records, preventing fraud, resolving payment issues and complying with applicable legal, banking and regulatory requirements.

Users are responsible for ensuring that the banking information they provide is complete and accurate. Incorrect or incomplete banking information may result in a withdrawal being delayed, rejected or returned.

CAYRE will only retain banking information for as long as reasonably necessary for the purposes for which it was collected and in accordance with applicable legal, regulatory, accounting and recordkeeping requirements.

Banking information will not be sold or used by CAYRE for unrelated marketing purposes.

Transaction Information

CAYRE may receive, generate and retain information relating to payments, Wallet activity and withdrawals, including:

• Payment status
• Transaction amount
• Transaction or payment reference
• Date and time of payment
• Order information
• CAYRE Wallet balance and transaction history
• Credits added to or used from a CAYRE Wallet
• Withdrawal requests
• Withdrawal amounts and status
• Refund or chargeback information
• Relevant banking information required to process seller withdrawals
• Limited payment related information provided by the payment processor

This information may be processed where reasonably necessary for operating the CAYRE Wallet, completing transactions, processing withdrawals, maintaining financial records, resolving disputes, preventing fraud and complying with applicable legal or regulatory requirements.

Cayman National Bank and relevant payment service providers may also process personal information in accordance with their own privacy notices, legal obligations and security requirements.

CAYRE uses Smart Lockers to facilitate exchanges between buyers and sellers.

When you use a CAYRE Smart Locker, information associated with your transaction may be processed, including:

• Order number
• Locker location
• Locker size
• Delivery and collection status
• Access code or other access credentials
• Drop off and collection timestamps
• Information necessary to notify the buyer or seller

This information is used to facilitate the transaction, maintain the security of the locker network, provide customer support and investigate potential issues or disputes.

Users are responsible for keeping Smart Locker access codes and other access credentials confidential.

CAYRE does not sell your personal information.

We may share personal information where reasonably necessary with trusted organisations that help us operate CAYRE, including:

• Cayman National Bank and payment processing providers
• Smart Locker technology and service providers
• Website hosting and technology providers
• Email, SMS and communications providers
• IT and security service providers
• Accountants, lawyers and professional advisers
• Regulatory, law enforcement or government authorities where legally required

Where a third party processes personal information on CAYRE's behalf, we will take reasonable steps to ensure that appropriate data protection and confidentiality arrangements are in place.

We aim to disclose only the information reasonably necessary for the relevant purpose.

CAYRE is a community marketplace and certain information may need to be shared between buyers and sellers to facilitate transactions.

Users must respect the privacy of other CAYRE members.

Personal information obtained through a CAYRE transaction must not be used for unrelated purposes, including unsolicited marketing, harassment or inappropriate contact.

Misuse of another member's personal information may result in action being taken against the relevant CAYRE account.

Where permitted, CAYRE may use your contact information to send you news, platform updates, offers, competitions or other marketing communications.

You have the right to ask us to stop using your personal information for direct marketing at any time.

Marketing preferences do not affect essential service communications. For example, even if you opt out of marketing, we may still contact you about an active transaction, your account, Smart Locker collection or an important security issue.

CAYRE may use cookies and similar technologies to operate the website, remember preferences, understand website usage, improve performance and provide a better user experience.

Where required, users will be provided with appropriate choices regarding nonessential cookies.

Further information may be provided through a separate Cookie Policy or cookie management tool on the CAYRE website.

CAYRE will not retain personal information for longer than reasonably necessary for the purpose for which it was collected.

Retention periods may vary depending on the type of information and may take into account:

• The duration of your CAYRE account
• Transaction and payment requirements
• Accounting and financial recordkeeping requirements
• Fraud prevention
• Dispute and complaint resolution
• Legal and regulatory obligations
• The establishment, exercise or defence of legal claims

When personal information is no longer required, we will take reasonable steps to securely delete, destroy or anonymise it where appropriate.

CAYRE takes reasonable technical and organisational measures to protect personal information against unauthorised or unlawful access, disclosure, alteration, loss or destruction.

Where appropriate, this may include access controls, secure systems, encryption, restricted administrative access and the use of reputable third party service providers.

Users also have a responsibility to protect their accounts. Passwords, Smart Locker codes and other access credentials should be kept confidential and should not be shared with unauthorised persons.

While we take reasonable precautions, no internet based service or electronic storage system can guarantee absolute security.

Some of CAYRE's technology or service providers may process or store information outside the Cayman Islands.

Where personal information is transferred internationally, CAYRE will take reasonable steps to ensure the transfer complies with the DPA, including ensuring that an appropriate level of protection or other lawful safeguard or basis for the transfer applies.

Subject to applicable limitations and exemptions under the DPA, you may have the right to:

• Be informed about how your personal information is being used
• Request access to personal information held about you
• Request the correction of inaccurate personal information
• Request that certain processing of your personal information stop or be restricted
• Require CAYRE to stop using your personal information for direct marketing
• Exercise applicable rights relating to decisions made solely through automated processing
• Make a complaint regarding the handling of your personal information
• Seek compensation in circumstances provided for under applicable law

Requests relating to your personal information can be submitted using CAYRE's contact details.

We will respond to valid requests in accordance with the timeframes and requirements of applicable Cayman Islands data protection law.

You also have the right to raise a data protection complaint with the Office of the Ombudsman of the Cayman Islands.

CAYRE is not intended to be used by individuals who do not meet the minimum age requirement specified in our Terms & Conditions.

We do not knowingly seek to collect personal information from individuals who are not permitted to use CAYRE.

If we become aware that personal information has been collected in circumstances where it should not have been, we will take appropriate steps in accordance with applicable law.

CAYRE may contain links to or integrate with third party services.

These organisations may process information under their own privacy policies and legal obligations. We encourage users to review the privacy information provided by third parties where appropriate.

We may update this Privacy Policy from time to time to reflect changes to CAYRE, our service providers, technology, legal requirements or the way we process personal information.

When we make changes, the updated Privacy Policy will be published on the CAYRE website and the “Last Updated” date will be revised.

Where a significant change materially affects how we use your personal information, we may provide additional notice where appropriate.

If you have questions about this Privacy Policy, would like to exercise your data protection rights or have concerns about how your personal information has been handled, please contact us using the contact information provided on the CAYRE website.

CAYRE | Cayman Resellers Grand Cayman, Cayman Islands