Last Updated: September 30, 2019

SUMMARY

 

Cake Browser does not know who you are, so we can’t tie any search terms or website visits to you or any other user. We have thoughtfully designed Cake to protect your privacy and collect the least amount of information necessary to help you have a great experience searching and browsing the web.

 

We also believe in being transparent about what data we collect and how it is used. That’s why we’ve put together this privacy policy so you can easily see what we know about you, how we use that information, and why.

 

This privacy policy, with our “Terms of Service & License Agreement”, is the agreement between you and us that explains what data we collect, how we store and transfer it, and how we use it. We encourage you to read this privacy policy carefully when using our application or services. By using our application or other online services, you are accepting this privacy policy.

 

When we post changes to this privacy policy, we will revise the “last updated” date on the top of this privacy policy, and the most recent version of our policy will govern our use of your data. We encourage you to review this privacy policy periodically.

To obtain the highest level of privacy in Cake, use Private Mode. You may also wish to use a Virtual Private Network (VPN) to ensure that web requests from your device do not include your IP address.

 

What Information Does Cake Collect From You?

Our products may require your personal information to function properly. When we collect your data, we may associate it with a unique ID and a unique device ID that are generated when you install a Cake product or begin using our services. These identifiers are anonymized and are in place so we can understand app usage. We do not know who you are, which means that we can’t tie any search terms or website visits to you or any other user.  Even when we are required to pass along your IP address on web requests for websites you visit or the search engines you select (an IP address is an essential technical element for websites and search engines), we never associate that IP address with any search or browsing history, and we never associate it with your name, e-mail address, or other personally identifying information without your knowledge and consent.

 

You don't have to grant any app permissions in order to use Cake Browser. We may ask for app permissions (for example, we may ask to send you push notifications or for location information) in order to enhance your experience, but you can always choose whether or not to grant those permissions.

 

The section below describes the information we collect from you and how it is used:

Search Terms (e.g. “nba scores”)

How does Cake get it?

You type it in to perform a search

How does Cake use it?
Cake passes the search terms to the selected search provider in order to return search results and type-ahead search suggestions. In normal browsing mode, Cake analyzes anonymized search terms to better optimize the user experience and may share or sell anonymized search terms to 3rd parties seeking to better understand web usage (Cake does not collect or share anonymized search terms in Private Mode). In normal browsing mode, Cake may send search terms to a partner that returns relevant sponsored results (Cake does not make this request in Private Mode).

Is it stored? If so, why?

Search terms are not stored in any way in Private Mode.

In normal browsing mode, search term(s) are stored in your history on your local device (in an encrypted fashion that is inaccessible to our company) so you can easily revisit previous searches. You can permanently delete your search history at any time. Cake also stores search terms in normal browsing mode in an anonymized fashion in no way tied to your identity. For example, Cake knows that 28 people in California searched for “pink flamingo”, but Cake doesn’t know who those people are.

Is it shared? If so, why?

Search terms are shared with the selected search provider in order to return search results and type-ahead search suggestions. Search terms in Private Mode are not shared with any party other than the chosen search providers.

In normal browsing mode, Cake may send search terms to a partner that returns sponsored results (Cake does not make this request in Private Mode). Cake may also collect and share anonymized search terms in normal browsing mode (e.g. 28 people searched for “pink flamingo” in the past month) with 3rd parties seeking to better understand web usage (Cake does not collect or share anonymized search terms in Private Mode). In no case are any search terms connected to individual users.

Web Site Addresses (e.g. Amazon.com)

How does Cake get it?
You type it in to navigate directly to a particular web site or page

How does Cake use it?

Cake makes a web request on your behalf for this web site address to return the page you desire. In normal browsing mode, Cake analyzes anonymized web site addresses to better optimize the user experience (for example, to improve the ad blocker on the most popular sites visited) and may share or sell anonymized website visit information to 3rd parties seeking to better understand web usage (Cake does not collect or share anonymized web site addresses in Private Mode).

Is it stored? If so, why?

Web site addresses are not stored in any way in Private Mode.

In normal browsing mode, web site addresses are stored in your history on your local device (in an encrypted fashion that is inaccessible to our company) so you can easily revisit previously visited sites or pages. You can clear your history at any time. Cake also stores website visits in normal browsing mode in an anonymized fashion in no way tied to your identity. For example, Cake knows that 15 people in California visited “amazon.com”, but Cake doesn’t know who those people are.

Is it shared? If so, why?

Web site visits in Private Mode are not shared in any way.

Cake may collect and share anonymized web site visits in normal browsing mode (e.g. 15 people visited “amazon.com” in the past month) with 3rd parties seeking to better understand web usage. In no case are any website visits connected to individual users.

IP Address

How does Cake get it?

Your IP address is automatically sent from your device with each web request (e.g. as you perform a search or type in a URL)

How does Cake use it?

Your IP address accompanies any web request (like a return address on a letter) made from Cake so that requested results, suggestions and web page(s) can be successfully sent back to your device. Cake also uses your IP Address to determine your high-level location (your country and your state, province or its equivalent).

Is it stored? If so, why?

No, Cake does not store your IP address

Is it shared? If so, why?

Your IP address accompanies any web request (like a return address on a letter) made from Cake so that requested results, suggestions and web page(s) can be successfully sent back to your device. Please note, any SDK installed in the Cake app also has access to IP Address (see below for a full list of SDKs in use by Cake).

Note: You may choose to use a Virtual Private Network (VPN) to ensure that web requests from your device do not reflect your IP address.

Anonymous Ad ID

How does Cake get it?

Cake requests the Anonymous Ad ID from your phone's operating system. If you do not want Cake (or other apps) to have access to this Anonymous Ad ID, you can restrict access in your device settings.

How does Cake use it?

Cake uses the Anonymous Ad ID to optimize its advertising and advertise to other potential users who are similar to you

Is it stored? If so, why?

Yes, Cake stores the Anonymous Ad ID to optimize its advertising (for example, to understand if someone Cake advertised to is still a Cake user)

Is it shared? If so, why?

Cake shares Anonymous Ad IDs with AppsFlyer (a marketing partner) to help optimize our advertising efforts. Please note, any SDK installed in the Cake app also has access to Anonymous Ad ID (see below for a full list of SDKs in use by Cake)

Anonymized Session Info (e.g. session length, number of searches performed, number of pages viewed, etc.)

How does Cake get it?

Cake measures usage of its product features in an anonymous fashion that is not tied to your identity.

How does Cake use it?

Cake uses Anonymized Session Info to understand user behavior, feature usage rates, and other statistics to improve the product experience. For example, if a feature is rarely used, Cake may use this information to remove the feature.

Is it stored? If so, why?

Yes, Cake stores Anonymized Session Info to better understand user behavior, feature usage rates, and other statistics in order to better understand its users and improve the product experience.

Is it shared? If so, why?

Cake may choose to share Anonymized Session Info from time-to-time with potential partners or investors to help them better understand Cake's usage patterns. Bear in mind that all Anonymized Session Info is measured in an anonymous fashion that can't be tied to anyone's identity.

Device Info (e.g. make and model of phone, operating system version, etc.)

How does Cake get it?

Cake requests Device Info from your phone's operating system.

How does Cake use it?

Cake passes your Device Info to the search engine or requested web page with each web request so that your requested results and web page(s) can be optimized for your device. Cake also uses Device Info to better understand its users and improve the product experience for specific devices. For example, if a bug affects only users of a specific make and model of phone, Cake can troubleshoot the issue more effectively by understanding which device is having the problem.

Is it stored? If so, why?

Yes, Cake stores Device Info to better understand its users and improve the product experience for specific devices.

Is it shared? If so, why?

Cake passes your Device Info to the search engine or requested web page with each web request so that your requested results and web page(s) can be optimized for your device. Please note, any SDK installed in the Cake app also has access to Device Info (see below for a full list of SDKs in use by Cake).

High-level Location Info (e.g. your country and your state, province or its equivalent)

How does Cake get it?

Cake uses IP Addresses to determine your high-level location info (your country and your state, province or its equivalent)

How does Cake use it?

Cake uses High-Level Location (your country and your state, province or its equivalent) to better understand its users and where they reside generally.

Is it stored? If so, why?

Yes, Cake stores High-Level Location (your country and your state, province or its equivalent) to better understand its users and where they reside generally.  However, this information is not associated with any search history or other personal information.

Is it shared? If so, why?

Cake may choose to share High-Level Location from time-to-time with potential partners or investors to help them better understand Cake's users. Cake may also share anonymized High-Level Location with 3rd-parties interested in better understanding web usage (e.g., 63 people in California searched for “pink flamingo”).

GPS Location 

How does Cake get it?

If you choose to grant location permissions to Cake, Cake requests GPS Location from your phone's operating system. Remember, you can revoke location permission in your device settings at any time.

How does Cake use it?

Cake passes your GPS Location to your preferred search engine when running a search to return the most locally relevant results. For example, a search for "restaurants near me" will yield much better results with GPS Location than it might with just IP Address. When you grant permission to share location with a web site, Cake will pass your GPS Location to that site. For example, if you are on Walmart.com, the page may request your location to identify the nearest location to improve your shopping experience.

Is it stored? If so, why?

No, Cake does not store your GPS Location

Is it shared? If so, why?

Cake passes your GPS Location to your preferred search engine when running a search to return the most locally relevant results. For example, a search for "restaurants near me" will yield much better results with GPS Location than it might with just IP Address. When you grant permission to share location with a web site, Cake will pass your GPS Location to that site. For example, if you are on Walmart.com, the page may request your location to identify the nearest location to improve your shopping experience. Please note, any SDK installed in the Cake app also has access to GPS Location (see below for a full list of SDKs in use by Cake).

RSS Subscriptions (e.g. you choose to follow news from ESPN.com)

How does Cake get it?

You tell Cake you want to follow a particular site, thus subscribing to its RSS Feed

How does Cake use it?

Cake periodically checks for new items in the RSS Feeds to which you subscribe and posts that content on your home page and/or alerts you that there is new content to explore

Is it stored? If so, why?

Yes, Cake stores the RSS Subscriptions you have so we can look for new items and post them to your home page or alert you that there is new content to explore

Is it shared? If so, why?

No, Cake does not share your RSS Subscriptions

Login Credentials (e.g. usernames and passwords for various web sites)

How does Cake get it?

You may choose to have Cake remember your login credentials for a particular site to make it easier and faster to log in next time you visit

How does Cake use it?

Upon your request, Cake saves your login credentials on your device (in an encrypted fashion that is inaccessible to our company) to save you time by auto-filling them next time you visit a particular site.

Is it stored? If so, why?

Login Credentials are stored on your device (in an encrypted fashion that is inaccessible to our company) to save you time by auto-filling them next time you visit a particular site.

Is it shared? If so, why?

Cake passes your Login Credentials (in an encrypted fashion that is inaccessible to our company) to the web site you're visiting when you attempt to log in.

Push Notification Interactions (e.g. whether or not you opened a push notification)

How does Cake get it?

If you choose to grant notification permissions to Cake, Cake can send you push notifications and knows whether or not you've interacted with those notifications. Remember, you can revoke notification permissions in your device settings at any time.

How does Cake use it?

Cake uses Push Notification Interactions to better understand its users and optimize its push notification effectiveness.

Is it stored? If so, why?

Yes, Cake stores Push Notification Interactions to better understand its users and optimize its push notification effectiveness.

Is it shared? If so, why?

Cake shares Push Notification Interactions with OneSignal (a push notification partner) to help manage the sending of push notifications from Cake and improve their effectiveness.

What Software Development Kits (SDKs) Does Cake Browser Use?

The table below describes the SDKs that are incorporated into Cake Browser.

SDK

Why Does Cake Use It?

Fabric / Firebase

Cake uses Firebase and Fabric to better identify and troubleshoot app crashes and to capture anonymized session info.

AppsFlyer

Cake uses AppsFlyer to help optimize our advertising efforts by providing conversion attribution to particular marketing campaigns and channels.

OneSignal

Cake uses OneSignal to help manage the sending of push notifications from Cake and improve their effectiveness by understanding open rates and other notification analytics.

AWSCore / AWSKinesis

Cake uses AWS to help manage the transfer of analytics data to the cloud.

 

 

Additional Details

This privacy policy does not cover third-party apps and services you access and use through our products and services, nor does it cover links to other websites. We do not control the privacy and security practices and policies of these third parties and their sites. We encourage you to read the privacy statements of the third-party apps and websites you use. We are not responsible for security practices and policies of third party apps and sites and you agree to release and waive any claim against us as a result of your use of third party apps and sites.

 

By opting-in to push notifications, you agree to receive communications and notices through SMS or push notification technologies. Cake’s communications may be account-related as well as periodic promotional notifications that highlight new features or present new offers from Cake. Your consent to receive electronic communications includes any notices or other information that we may be required by law to provide you in writing or otherwise. You may opt out of receiving certain communications by changing your push notification settings or by following the instructions in any other marketing communications you receive.

 

We will not provide non-masked or non-obscured Personal Information to third parties, except:

 

      To government bodies and law enforcement agencies to comply with the law, for example in judicial proceedings, by court order or other legal process

      To third parties (including professional advisors) to enforce or defend our legal rights, including our terms and conditions, and investigate violations thereof

      To a third-party purchaser or seller (including professional advisors) in connection with a corporate event such as a merger, business acquisition or insolvency situation

      To a third-party partner when you provide your explicit consent

      To any person as required by law

      As described elsewhere in this statement

 

What else should I know?

We keep your information only as long as we need it for legitimate business purposes and as permitted by applicable legal requirements. If you cease usage of the Cake browser, we will retain certain data for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our “Terms of Service & License Agreement”, take actions we deem necessary to protect the integrity of our service, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Privacy Policy, retention of that information will be subject to those third parties’ policies.

 

Onward transfer and consent to international processing

We are a growing corporation with users and operations in multiple countries, including the European Union. We have developed both technical and organizational data practices designed to assure that your information is appropriately protected, but we cannot always know where information may be accessed or processed. While our primary data centers are in the United States, we may transfer personal information or other information to locations outside of the United States. In addition, we may employ other companies and individuals to perform functions on our behalf outside of the United States, and we will seek commercially reasonable assurances that any information we may provide to them is safeguarded adequately and in accordance with this Privacy Policy and the requirements of applicable privacy laws.

 

Terms applicable to our European users

 

If you are visiting from the European Union or other regions with laws governing data collection and use, our processing of your personal data may be subject to additional privacy laws such as the General Data Protection Regulation (“GDPR”), which requires us to have a lawful basis to process your data.  In most cases, the GDPR doesn’t apply, because we simply don’t collect or keep much data about you.  But where the GDPR does apply, we do comply with its requirements.  For example, our “lawful basis” for processing information about you comes from (1) the consent you give by using the Cake Browser, (2) the contract you have with us by virtue of your acceptance of our Terms of Service & License Agreement, and (3) the legitimate interest we have in keeping the information that is necessary to provide you the services.  Please note that aggregated and anonymized data that is not identifiable to you and is not connected with your IP address (for example, the raw number of searches done for “pink flamingos” in a given time frame and the number of people who click on which results) is not personal information, and we may use or sell that information.

 

European individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States should direct their query to us at the e-mail address listed below.  If you request us to remove data, we will respond within a reasonable timeframe.

 

 

CONTACT INFORMATION

If you have any questions about this statement or any privacy issues regarding Cake and our products or services, we can be reached at:

 

Cake Technologies, Inc.

1 E. Center St., Suite 210

Provo, UT 84606