diff --git a/PRIVACY.md b/PRIVACY.md index dc3014967..fda8863aa 100644 --- a/PRIVACY.md +++ b/PRIVACY.md @@ -1,6 +1,6 @@ Privacy Policy -Last modified: January 11, 2022 +Last modified: April 27, 2022 Introduction ============ @@ -22,32 +22,32 @@ Definitions - "App" means any software program provided by the Company, downloaded by You on any electronic device, including but not limited to Cake Wallet and Monero.com. - "Device" means any device that can access the App, such as a cell phone or tablet device. - - "Node" means a full Monero or Bitcoin or Litecoin Node (or any other node on a supported cryptocurrency network), which transmits data to your App for processing and synchronization, and to which your Device transmits transactions which you would like to submit to the Monero or Bitcoin or Litecoin networks (or any other supported cryptocurrency network). + - "Node" means a server on a supported cryptocurrency network which transmits data to your App for processing and synchronization, and to which your Device transmits transactions which you would like to submit to the supported cryptocurrency networks. This includes full nodes, Electrum servers, and lightning network nodes. - "Cake Labs Nodes" refers to the set of cryptocurrency nodes operated and maintained by Cake Labs LLC. - "Service" refers to the App. - - "Third-party Service" refers to any service integrated into the App. This includes ChangeNOW, Wyre, MoonPay, and BlockBuy. + - "Third-party Service" refers to any service integrated into the App. This includes but is not limited to ChangeNOW, Wyre, MoonPay, and BlockBuy. - "Usage Data" refers to data collected automatically about your usage of an App. - "You" means the individual, group, corporation, or any other entity accessing or using the Service. Information We Collect About You and How We Collect It ------------------------------------------------------ - We collect several types of information from and about users of our App, including information: + We may collect several types of information from and about users of our App, including information: - By which you may be personally identified, such as name, e-mail address, or and a/any other identifier by which you may be contacted online or offline ("personal information" or "Personal Data”), ONLY when you provide it to us; - - Device IP address, the block height to which your wallet is synchronized, and any transactions which you use our Node to submit to the Monero or Bitcoin or Litecoin networks. + - Device IP address, the block height to which your wallet is synchronized, and any transactions which you use our Node to submit to supported cryptocurrency networks. We collect this information: - Directly from you when you provide it to us. - Automatically as you use the App, if you use one of the Cake Labs Nodes. Information collected automatically may include IP address and block height. Usage Data (including the date and time at which you use an application, the duration of using it, and other ‘metadata’) is NOT collected by Cake Labs through the usage of the App. Cake Labs has no reason to care about any aspect of your continued usage of our App. We believe that this data is your own property and that we have no right to collect it. - Personal information is received by Cake Labs ONLY in the event that you choose to provide it to us. This is provided either by synchronizing your wallet using the Nodes maintained by Cake Labs, or by voluntarily contacting Cake Labs regarding support, questions or suggestions. You also have the right to choose not to provide data to Cake Labs, by choosing a different Node. The option to do so is provided by default with a list of Nodes, but Cake Wallet and Monero.com also provide the ability to add another Node not listed, or use your own Node. + Personal information is received by Cake Labs ONLY in the event that you choose to provide it to us. This is provided either by synchronizing your wallet using the Nodes maintained by Cake Labs, or by voluntarily contacting Cake Labs regarding support, questions or suggestions. You also have the right to choose not to provide data to Cake Labs, by choosing a different Node. The option to do so is provided by default with a list of Nodes, but our Apps also provide the ability to add another Node not listed, or use your own Node. Data relating to your funds, and their security and privacy, remains on your device at ALL times. Your private keys, seeds, backup files, and wallet passcode are your own responsibility. This data is not received, collected, or stored by Cake Labs at any time, for any reason. - Personal Data collected through the Cake Labs Nodes is limited to your device's IP address, the block height to which your wallet is synchronized, and any transactions which you use our Node to submit to the Monero or Bitcoin or Litecoin networks (or any other supported cryptocurrency network). Personal Data received by Cake Labs in this manner is not stored for any length of time, and thus Cake Labs is both unwilling to and incapable of sharing this data, or using it for any purpose beyond ensuring your appropriate connection to our Nodes. + Personal Data sent through the Cake Labs Nodes is limited to your device's IP address, the block height to which your wallet is synchronized, and any transactions which you use our Node to submit to the supported cryptocurrency networks. Personal Data received by Cake Labs in this manner is not stored for any length of time, and thus Cake Labs is both unwilling to and incapable of sharing this data, or using it for any purpose beyond ensuring your appropriate connection to our Nodes. - If you decide to use a Node offered by any third party, some of which we offer by default in our Apps, said third party will receive this Personal Data instead of Cake Labs. We take no responsibility for the actions of any third-party Node offered within the Application. If you decide to synchronize your Wallet using your own Node, neither Cake Labs nor any third party will have access to this Personal Data. + If you decide to use a Node offered by any third party, some of which we include in our Apps, said third party will receive this Personal Data instead of Cake Labs. We take no responsibility for the actions of any third-party Node offered within the Application. If you decide to synchronize your Wallet using your own Node, neither Cake Labs nor any third party will have access to this Personal Data. In any of these situations, Cake Labs takes no responsibility for interception of this data by any outside individual, group, corporation, or institution. You should understand this and take any and all appropriate actions to secure your own data. @@ -76,7 +76,7 @@ Disclosure of Your Information We may disclose personal information that we collect or you provide as described in this Privacy Policy: - To our subsidiaries and affiliates. - To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. - - To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cake Technology's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cake Technology about our App users is among the assets transferred. However, we will provide notice before this Personal Data is transferred and becomes subject to a different Privacy Policy. + - To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Cake Labs's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Cake Labs about our App users is among the assets transferred. However, we will provide notice before this Personal Data is transferred and becomes subject to a different Privacy Policy. - To fulfill the purpose for which you provide it. - For any other purpose disclosed by us when you provide the information. - With your consent.