CAKE

CAKE Privacy Policy

Last Updated: July, 14, 2024

CFB, Inc., d/b/a CAKE (“CAKE,” “we,” “us,” “our”) provides an invitation-only, subscription-based membership community for shoppers. We work with brands (our “brand partners”) to provide members with exclusive member privileges, such as promotional codes that can be redeemed on our brand partners’ websites or stores (“CAKE Cards”).

This Privacy Policy (“Policy”) describes how CAKE collects, uses, and discloses information from and about you when you visit any of our websites that we have linked to this Policy (each a “Site” and together the “Sites”), use any of our products or services, or otherwise interact with us (collectively, together with the Site and any interactions with us, the “Services”).This Policy is incorporated into and made part of our Terms of Service. This Policy does not apply to the practices of entities we do not own or manage, or to websites that we have not linked to this Policy. By using the Services, including by visiting the Sites, you agree to the collection, use, disclosure, and other handling of your information as described in this Policy.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. IF YOU DO NOT WANT US TO HANDLE YOUR INFORMATION AS DESCRIBED IN THIS POLICY, DO NOT USE THE SERVICES.

Table of Contents. This Policy contains the following sections:

Information We Collect
How We Use Your Information
How We Disclose Your Information
Your Choices
Security and Retention
Third-Party Links and Content
Children’s Privacy
Information for Non-United States Residents
Changes to This Policy
Contact Us

1. Information We Collect

The information we collect from and about you may vary depending on how you use the Services. We collect information from you, automatically when you use the Services, and from other sources.

Information You Provide to Us. We collect information that you provide to us, including any information provided when you interact with us in any way via the Services or via email or phone, in person, or otherwise. For example, we collect your information when you create an account, respond to a survey, engage with us at a conference or event, interact with us via phone, email, or online chat functionality (e.g., for customer service purposes), or otherwise interact with us in any form or medium.

The information you provide to us may include, but is not limited to:

Contact information, such as your name, email address, postal address, and phone number.
Login information, such as username and password.
Personal characteristics, such as age and date of birth.
Information about your transactions on the Services, such as the fact that you have purchased a subscription to the Services and the date and cost of the purchase (note that we do not collect your full payment information).
Your responses to surveys.
Information about your preferences, such as the brand partners that are of interest to you.
General location information such as your city/state and zip code, including general location inferred from your IP address.
Audio and visual information, subject to applicable laws, such as photographs (e.g., photos you provide on the Site or photos of you at our events or events in which we are participating), audio recordings (e.g., recordings of customer service calls), and video recordings (e.g., recordings of online calls or live events).
Any other information that you voluntarily choose to provide to us by any means and in any medium.

If you purchase a subscription to the Services, your payment information is collected and processed by a third-party payment processor, not CAKE. Our payment processor may provide us with limited information such as the last four digits of your payment card and the expiration date, but we do not collect or store your full payment information. As noted above, we may collect other information about your transactions on the Services.

Information Collected Automatically. When you interact with the Services or when you interact with our content anywhere online, we and third parties may collect information about your browser, device, and use of the Services, including but not limited to your IP address, device type and model, operating system, unique device identifier, cookie identifiers, other device or online identifiers, browser type, language, frequency of use of the Services, web logs, crash reporting, Site pages visited, and navigation through those pages. We may also collect technical information when you interact with emails or other communications from us (e.g., whether you opened an email). Some of this information is collected using cookies and other similar technologies. For more information, see the “Your Choices” section below.

Information Collected from Other Sources. We may collectinformation about the CAKE Cards you select through the Services, such as the CAKE Cards you select, the brand partner supplying the CAKE Cards, and how quickly you use the CAKE Cards. We may also collect information about your use of CAKE Cards on our brand partners’ websites or stores, such as the CAKE Card you redeemed, the value of the redemption, information about the item(s) you purchased using the CAKE Card (such as the item price, name, and quantity), order information (such as order ID), and your billing and shipping address.

If someone invites you to become a CAKE member, we may collect information that they provide us about you, such as your name, email address, and the message they want us to send you as part of the invitation.

If you choose to connect the Services with other apps on your device (e.g., your photos), these apps may allow us to have access to and store additional information as it relates to your use of the Services (e.g., to upload photos to the Services). If you do not want us to access this information, do not initiate these connections.

We may collect information about your interactions with us on third-party platforms, including our social media accounts. This information includes, but is not limited to, your likes and shares of our content, your comments on our content, and your social media handle.

If you log into the Services using your social media credentials, we may collect information about you from the social media site based on the authorizations and permissions set with the social media site. Logging into the Services through social media credentials is optional, and you will have the opportunity to grant permission when you attempt to connect.

We store some information that we receive from social media sites with other information that we collect about you. The social media site controls the information that it collects from you. For information about how the social media site may use and disclose your information, including any information you make public, please consult its privacy policy. We have no control over how any third-party site uses or discloses the information it collects about you.

We may collect information about you from other sources, in accordance with applicable law.

2. How We Use Your Information

We use the information we collect for various purposes, depending on the type of information and the way you interact with the Services, including:

To provide, manage, and improve the Services.
To administer your account.
To process transactions such as subscription payments (as explained above, full payment information is collected and processed by a third-party payment processor, not by us).
To communicate with you about your use of our Services, including to respond to your inquiries and for customer service purposes, which may include communicating with you via email or SMS/text message.
To engage in analysis and research regarding the use of our Services.
To test and create new products, features, and services.
For marketing and advertising purposes, including to provide contextual advertisements on the Services, to develop a more complete understanding of you, and to send you marketing communications, including via email and SMS/text message (subject to any opt-out preferences you have communicated to us).
To provide surveys.
For security, auditing, and similar business operational purposes.
To address technical issues on the Services.
To comply with legal requirements, relevant industry standards, and our policies.
To protect the safety, rights, property or security of CAKE, our users, employees, third parties, members of the public and/or our Services.
To prevent fraud and enforce our legal terms and policies.
For any other lawful purpose (subject to your consent where legally required).

Combined Information. We may combine information that we collect from and about you (including automatically generated information) with information that we obtain about you from other sources and use such combined information in accordance with this Policy.

Aggregated and De-Identified Information. We may aggregate and/or de-identify information collected through the Services. We may use and disclose appropriately aggregated or de-identified information for any purpose. For example, we may disclose aggregated information about our members to our brand partners.

3. How We Disclose Your Information

We may disclose your information as follows:

Vendors and Advisors. We may disclose your information to companies that provide services to us, such as providers of data storage, web hosting, billing and payment processing, content provision, analytics, sales, marketing and advertising, security, fraud prevention, legal, and consulting services.
Legal Compliance and Rights. We may disclose your information if we believe in good faith that this is required or appropriate to comply with applicable law, regulations, or legal process; establish or exercise our legal rights; defend against legal claims; seek legal representation or advice; and enforce our legal terms, agreements, and policies.
Protection of CAKE and Others. We may disclose your information if we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing, and to protect and defend the rights, property or safety of CAKE, our users, our employees, or others.
Corporate Transactions. We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business or a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
Your Consent. If you have consented to additional disclosure of your information, we will disclose your information consistent with your consent.
Other Disclosures. We may disclose your information as otherwise permitted or required by law.

4. Your Choices

a. Marketing Communications

You may use the unsubscribe link found at the bottom of marketing emails we send to you to opt out of receiving future marketing emails. Note that it may take up to 10 days for your preferences to take effect. If you are currently receiving marketing SMS/text messages from us and wish to opt out of receiving such messages, you may do so by replying STOP.

If you opt out of marketing communications, you may continue to receive certain non-promotional communications about us and our Services, such as communications regarding the status of your account, your purchases, security-related matters, or updates to our legal terms, including this Policy. Opting out of marketing communications will not halt these and any other non-promotional communications.

b. Cookies

We and our vendors and third parties may use cookies and other similar technologies (such as pixels) to collect information about your use of the Services. Cookies are small data files that can be stored on your browser and device. Cookies and similar technologies perform a variety of functions, including enabling the Services to function, securing the Services, personalizing the Services, helping us analyze and understand use of the Services, and assisting with marketing.

You may set your web browser to notify you when you receive a cookie and to accept or refuse certain cookies. However, if you elect not to accept cookies, some functionality and areas of the Services may be restricted. To learn how to manage your cookies, please follow the instructions from your specific browser, or if accessing the Services via a mobile device, refer to the manufacturer’s instructions. If you disable cookies using a browser or device setting, that setting will apply only to the browser or device you are using, so you will need to reset the setting if you use the Services on a different browser or device. If you disable some or all cookies, the Services may not function as intended and some features may be unavailable.

c. Online Analytics

We and our vendors may use third-party analytics services on the Services to help us understand how users engage with the Services, including Google Analytics. These parties may use cookies and other technologies to help collect, analyze, and provide us with reports and/or data. For more information about Google Analytics and how it collects and processes data, please visit: https://policies.google.com/technologies/partner-sites. To opt out of Google Analytics using your information for analytics purposes, see: https://tools.google.com/dlpage/gaoptout.

d. “Do Not Track”

Do Not Track (“DNT”) is a setting that users can enable in certain web browsers. DNT signals do not have a commonly agreed-upon meaning and we do not currently recognize or respond to DNT signals.

5. Security and Retention

Although we take certain measures to protect your information, no method of security is perfect. By using our Services, you acknowledge and accept that we cannot guarantee the security of your information, and that you provide information to us at your own risk. You are responsible for keeping your username and password confidential.

We may retain your information until we determine that retention no longer is necessary to fulfill the purpose for which it was collected and retained, and as required by applicable law. Retention periods may vary depending on the type of information and the context and purpose of its collection and use.

6. Third-Party Links and Content

The Services may have links and embedded content to third-party websites, apps, or other digital properties (“third-party services”) that may have privacy policies that differ from ours. We are not responsible or liable for the practices of such third parties or third-party services. You should check their privacy policies to understand how they may handle your information.

Likewise, the Services may have third-party content. We do not make any representations concerning the accuracy of such information and are not responsible or liable in any way for third-party content on our Services.

The presence on the Services of third-party content or links to third-party services does not indicate our endorsement of any third party or its content or services. You interact with third-party services and third-party content at your own risk.

7. Children’s Privacy

Our Services are not aimed at or intended for use by children under the age of 13. We do not knowingly solicit or collect “personal information” (as defined in the Children’s Online Privacy Protection Act) from children under the age of 13. If we become aware that a child has provided personal information to us, we will delete such information in accordance with applicable law.

8. Information for Non-United States Residents

Please note that CAKE is located in the United States. If you are located outside of the United States, you should be aware that any information you provide to us about yourself is transmitted to us and processed in the United States and other locations where we or our vendors or partners are located. Your information will be protected subject to this Policy and United States laws, which may not be as protective as the laws in your country. By using the Services, you acknowledge and consent to such transfers of your information to the United States and other locations where we or our vendors or partners are located.

9. Changes to This Policy

We may update this Policy from time to time. If we make any changes, we will update the Last Updated date above, and we will provide other notice if required by applicable law. We encourage you to read this Policy regularly to check for changes. Changes to this Policy are effective when they are posted on this page. Your continued use of the Services after we publish changes to this Policy constitutes your acceptance of the updated Policy.

10. Contact Us

If you have questions about this Policy or our privacy practices, please contact us at concierge@cakemembers.com.