cake_wallet/PRIVACY.md

Privacy Policy

Last modified: January 24, 2024

Introduction

Cake Labs LLC ("Cake Labs", "Company", or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you use the App (our "App") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:
	- On this App.
	- In email, text, and other electronic messages between you and this App.
It does not apply to information collected by:
	- Us offline or through any other means, including on any other App operated by Company or any third party (including our affiliates and subsidiaries); or 
	- Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the App.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, you have the choice to not use the App. By accessing or using this App, you agree to this privacy policy. This policy may change from time to time. Your continued use of this App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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 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 but is not limited to ChangeNOW, Onramper, and MoonPay.
- "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 Never Receive Nor Collect

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.

Data relating to your funds, and their security and privacy, remains on your device at ALL times. Your private keys (including your Monero private view 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.

Information We May Receive But Do Not Retain

We may receive but do NOT store information from and about users of our App, including:
	- The device IP address, the block height to which your wallet is synchronized, and any transactions or channels which you use our Node to submit to supported cryptocurrency networks.
We receive this information:
	- Automatically as you use the App, unless you turn certain features off in your App privacy settings.

This data is provided by connecting to the Nodes and price API maintained by Cake Labs. You have the right to choose not to provide synchronization data to Cake Labs by choosing a different Node. We provide a list of Nodes in the app that include our own and third party Nodes, or you can use your own Node (which we recommend). You have the right to choose not to connect to our Fiat API service by disabling this Fiat API in App privacy settings.

Personal Data that may be 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 or channels 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 incapable of sharing this data and will not use 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 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. We recommend connecting to your own Node to limit third party sharing of your Personal Information.

If you use our Fiat API service, you will share your IP address and the cryptocurrency and fiat currency exchange pair for which your wallet requests a spot price quote. You can disable this Fiat API in App privacy settings.

Information We May Collect About You and How We Collect It

We 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”);
	- Device data and error log data;
We collect this information:
	- Directly from you ONLY when you provide it to us.

Personal information is received by Cake Labs ONLY in the event that you choose to provide it to us by voluntarily contacting Cake Labs regarding support, questions or suggestions. You may optionally send us Error reports to help us improve the App. These Error reports contain error logs and basic device data. You can review and make modifications to these Error reports before sending them to us, or you may choose not to send them to us at all.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:
	- To present our App and its contents to you.
	- To allow you to sync using the closest geographical Node: In the event that you choose to synchronize your wallet using the Node maintained by Cake Labs, we determine your location using your IP address to redirect your Wallet to the fastest possible Node.
	- To contact you: In the event that you contact Cake Labs first, we will use the Personal Data with which you provide us, to contact you by email, Telegram, Reddit, or any other means.
	- To manage your requests: To attend and manage your requests to us. 
	- For any other purpose with your consent.

Transfer of Your Personal Data

Personal Data received by the Cake Labs Nodes, or voluntarily submitted to Cake Labs through e-mail, Telegram, Reddit, or any other method, may be transferred to computers located outside of your governmental jurisdiction, where the data protection laws may differ from yours. Your consent to this Privacy Policy, and your submission of such information, represents your agreement to this transfer.

Cake Labs will take all necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organization or a country, unless there are adequate controls in place to protect the security of your data.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. For example, we may, from time to time, disclose the number of users who have downloaded our Application.

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 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.

We may also disclose your personal information:
	- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
	- To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
	- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cake Labs, our customers, or others.

Cake Labs is incapable of providing any authority or government agency with data received by the Cake Labs Nodes, because we do not store this data.

Under certain circumstances, Cake Labs may be required by authorities to disclose Personal Data which you voluntarily provide us, including your e-mail address, Telegram username, or Reddit username. WE STRONGLY RECOMMEND THAT YOU DO NOT TRANSMIT ANY PERSONALLY IDENTIFIABLE INFORMATION TO US VIA THESE OR ANY OTHER METHODS.

Data Security

You are responsible for your personal data, including all data related to the safety of your funds. You should take all appropriate action to protect this data. Cake Labs cannot recover any data related to your funds in the event that you lose or give away this data. Cake Labs strongly recommends that you take action to secure your funds, by writing down your seeds or keys, storing encrypted backups, and never sharing this information.

Cake Labs undertakes any and all reasonable steps possible to secure any data that you voluntarily transmit to us. However, we cannot guarantee that any outside system used to transmit this data is entirely secure and, as such, we recommend that you exercise caution when voluntarily transmitting data to us.

In any situation, Cake Labs takes no responsibility for interception of personal 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.

Other Websites and Third-Party Services

The App may contain links to other websites that are not operated by us. If you click on a Third-Party Service link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

The App includes several optional Third-Party Services, which may not be available to all users. If you use Third-Party Services, you must agree to their respective Privacy Policies. When using certain optional features in the app such as buying and selling, you may be asked to provide information to a Third-Party Service. You will need to read and accept the privacy policy for that third party. This Third-Party Service may ask for your name, your photo ID, your social security number or other similar number, mailing address, cryptocurrency address, or other information. They may ask you to take a selfie image. Information shared with a Third-Party Service is subject to their respective Privacy Policies.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we will notify you through a notice on the App. The date the privacy policy was last revised is identified at the top of this document. You are responsible for periodically visiting our App and this privacy policy to check for any changes to our Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, you are encouraged to contact us by email at info@cakewallet.com.