Privacy Statement

The purpose of the Payce Digital Privacy Policy (the “Privacy Policy”) is to provide you, the User, with information on Cave Shepherd Card (Barbados) Inc.’s (“Cave Shepherd Card”) use of your Personal Information in accordance with the Data Protection Act of Barbados (the “Act”).  Your privacy is important to us and this Privacy Policy covers Payce Digital Mobile App’s (the “App”) treatment of personally identifiable information (“Personal Information”) and other data that Cave Shepherd Card (Barbados) Inc. (“Cave Shepherd Card”) gathers when Users access the App and its related services and functionalities (collectively the “Services”).  This Privacy Policy applies to Cave Shepherd Card’s online and mobile digital channels and services owned or operated by Cave Shepherd Card.

We encourage Users to read this Privacy Policy so that they understand how Cave Shepherd Card collects, uses, shares and protects your Personal Information.  We may ask your permission before collecting certain information through the App.

1. Personal Information About You

Personal Information essential for fulfilling most financial requests and applications include:

  • Information establishing your identity – such as your name, address, phone number, title, business phone number, email address, date of birth, passport number, nationality and account numbers. This information can be in any form included paper, electronic, video or voice recording;
  • Information to authenticate your identity – such as knowledge-based information (i.e. username, password and account information), device information (i.e. device model, browser type, IP address, security cookie and approximate physical location of device)
  • Information related to transactions – arising from your relationship with and through Cave Shepherd Card.
  • Information you provide on an application – for the provision of our products and services, such as your annual income, place of employment, investments, account balance, financial liabilities, transaction history.
  • Information about financial behaviour – such as your App usage patterns, payment history and credit worthiness
  • Additional information – this may be requested to help us determine your eligibility for products and services that we offer.

For purposes described in this Privacy Policy.

2. Collection and Usage of Personal Information

2.1 General Information

Cave Shepherd Card may collect, store and use Personal Information that a User enters while accessing the App or using the Services or which a User provides to Cave Shepherd Card upon application for the Cave Shepherd Card Account.

Cave Shepherd Card may use your Personal Information for lawful purposes including, in particular, where necessary:

(i) to establish your identity

(ii) to confirm your eligibility for products and services and to set up, maintain and deliver your Services; and/or.

(iii) for compliance with a legal and regulatory obligation to which Cave Shepherd Card is subject (such as compliance with anti-money laundering requirements).

Cave Shepherd Card may also customize the advertising and content on the App, communicate with the User about specials and new features of the App, operational and logistical notifications and communicating with the User about Cave Shepherd related offers and important updates.  Cave Shepherd Card may also analyse in aggregate Account usage in order to adapt the Services to User needs, to research the effectiveness and benefits of the App and Services and to develop new tools on the App.

For the avoidance of doubt the terms and conditions outlined under the Cave Shepherd Card (Barbados) Inc. Cardholder Agreement also applies.

2.2 Eligible Device Functionality and Access to Non-Personal Information

When a User accesses the App or uses the Services in line with the Cave Shepherd Card Mobile Terms and Conditions, Cave Shepherd Card may collect or access information about your device; such as device model, unique device number, browser type, User location, IP address, cookie information and the page requested by User.  Information about your device helps us to improve User experience, measure the effectiveness of the App, enhance security measures and protect Personal Information and financial information.

Cave Shepherd Card also uses session data, collected through cookies, to better understand how the App is navigated, how many visitors arrive at specific pages, the length and frequency of stays at the App and the internet protocol addresses from which visitors connect to the App.  Cave Shepherd Card treats all data obtained from the foregoing activities in this Clause 2.2 as Non-Personal Information, except where Cave Shepherd Card is required to do so by law.  For the avoidance of doubt, Cave Shepherd Card shall not make specific identity reference to any User in the provision of aggregate information to any of its partners (banks or merchants).

2.3 Limitation of Access to Non-Personal Information on Devices

Access to the App and/or the Services may involve access to information on User device.  User can control access to this information through device settings.  Refer to your device documentation for instructions on allowing or blocking access to information.  If you choose not to provide access to information on your device, some services may not operate effectively.

3. Use of Cookies

3.1. A cookie is a small piece of information sent by a web site that is saved on a User’s hard disk by the User’s computer’s browser. It holds information a site may need to personalize a user’s experience and gathers web site statistical data, such as which pages are visited, what is downloaded, the Internet provider’s domain name and country that visitors come from and the addresses of sites visited immediately before and after coming to the App website. However, none of this is associated with a User as an individual and is measured only in aggregate.

3.2. Cave Shepherd may use cookies as part of the functionality and security of the App.   These cookies may include an encrypted persistent cookie installed on the User’s device that contains information to assist Cave Shepherd in verifying that the User is a Cave Shepherd Cardholder and to help block unauthorized attempts to access User information through the mobile service. Cookie technology does not capture individual email addresses or any Personal Information and is used to improve User experience on the App and gather data for web site statistical reporting.

3.3. To browse without cookies, a User can configure his browser to reject cookies or to notify User when a cookie is set. Blocking cookies or opting out of ad customization will not eliminate all advertising on digital channels.  Cave Shepherd does not manage and is not responsible for the digital marketing and cookie practices of third parties.  User experience of the App may be different if User set his browser to block cookies.

4. Sharing of Personal Information

In certain circumstances, Cave Shepherd Card may be legally required to share Personal Information and other information with its employees, agents and/or service providers who are specifically contracted to process your Personal Information for the performance of the App and/or Services and to assist with the App’s management, operation, administration, governance and regulatory compliance.  Cave Shepherd Card’s agents and services providers are required to provide a comparable level of protection and confidentiality of User Personal Information as Cave Shepherd Card.

5. Security of Personal Information

Cave Shepherd Card takes the protection of your Personal Information seriously.  Any transfer of Personal Information by Cave Shepherd Card shall be in accordance with the requirements of the Act.  Each User’s Personal Information is protected by a password for privacy and security and Cave Shepherd Card shall apply appropriate technical and organisational information security measures designed to protect against unauthorised or unlawful processing of Personal Information and against accidental loss or destruction of or damage to Personal Information.

It is the User’s responsibility to prevent unauthorized access to User’s account and Personal Information by selecting and protecting his/her User password appropriately, and limiting access to User’s computer and browser by signing off after User has finished accessing his/her account, as detailed in the Payce Digital Mobile Application Terms and Conditions.

While Cave Shepherd Card endeavours to safeguard each User’s Personal Information to ensure that each User’s account information is kept private, Cave Shepherd Card cannot guarantee the security of User’s account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of User information at any time and User understands, acknowledges and assumes this risk.

Users are encouraged not to respond to text messages, pop-ups or other internet requests that ask you to reveal Personal Information or about your Cave Shepherd Card Account.  Cave Shepherd Card will not send unsolicited text messages or emails asking for your password, personal identification number or your Cave Shepherd Card Account number(s) or any other information related thereto.  You are encouraged to review your statements and report any errors in a timely manner.

For the avoidance of doubt, Users agree to assist Cave Shepherd Card in any investigation into any fraudulent activity linked to Cave Shepherd Card Account accessed via the App and the Services.

6. Changes to Privacy Policy

The Privacy Policy is to be read together with the Payce Digital Mobile Application Terms and Conditions and Cave Shepherd Card (Barbados) Inc. Cardholder Agreement both available at   Cave Shepherd Card may amend this Privacy Policy from time to time in its sole and absolute discretion.  The terms governing collection, storage, transfer and use of Personal Information will be in accordance with the Act.  Users are encouraged to periodically read periodically the Privacy Policy.  Cave Shepherd Card however remains committed to providing notifications within the App and/or website of any material change made to the Privacy Policy.  Users are bound by any changes to the Privacy Policy when they continue to access or use the App and/or the Services after such amendments.

7. Other Information

It is our goal to continuously improve our service offerings to Users.  Therefore, Cave Shepherd Card may routinely collect non-personal aggregate information from surveys, public archives and web sites to help us understand the interests of our Cardholders.

8. Privacy Concerns

Should you have any queries or wish to discuss your data protection rights or the Privacy Policy, please feel free to contact us.  If you choose to send us an e-mail or complete the contact form on the website, please do not include any sensitive information (e.g., card or account numbers).