Cake is a platform that positions itself between private users and commercial companies and ensures that private users can earn money with their data in a safe and anonymous way while commercial companies gain anonymous insights into the real spending patterns of their customers and their competitors' customers.

1. What data do we save?

A. Identity data
Cake initially asks for the name, first name and date of birth of the user. This data is stored in a secure Cake database.

In a next step in the service (when requesting the rewards or when performing payment initiation services), Cake requests a photo of the identity card. The data on this identity card is collected via OCR and stored in a secure Cake database.

B. Transaction data
When linking the user's bank account to the Cake app, we save all information about this bank account (number, currency, transaction data, balance, etc.)

C. Other information
In addition to the identity data and the bank account details, we also keep a number of data to control anti-money laundering and to improve our services. An overview of all data that Cake stores and processes can be found in the privacy policy.

2. Where do we store this data?

We make a distinction between the identity data and all other data (hereinafter "the other data"). The identity data is disconnected from all other data and stored in a separate database with very strong security and strict access rights.

The other data is stored in separate databases on which analyzes are made of the income and expenses of the users.

3. What do we do with this data?

The other data is aggregated and processed into statistics and insights. These statistics and insights are made available to Cake for Business partners.

By only processing the other data in statistics and ensuring that sufficient users are processed in the displayed statistics, Cake guarantees that commercial companies can never find out the identity of the users.

4. What is Cake's revenue model?

Cake has designed a number of products that can be built with the statistics and insights of the other data. These products are:

  • Market Insights

  • Customer Insights

  • Acquisition & Targeting

  • Micro Surveys

Some examples of Market Insights are:

  • What is the average income of users in a certain region?

  • How much do Limburg women spend on shoes on average?

  • How much do men spend on clothing on average?

  • Which competitor wins or loses in a certain region?

  • What is the most interesting region to open a specific store?

Some examples of Customer Insights are:

  • How loyal are my customers?

  • Where do my customers go shopping?

  • How often do my customers go shopping with me and with my competitors?

  • From whom do I lose customers and from whom do I win customers?

  • Where do my customers go shopping before they come to my store?

The targeting of the users means that Cake shows commercial actions in the app to the users who are eligible for this. Companies can in this way give compensation to users who go shopping at the commercial partner. This payment is always made via the Cake platform, whereby the anonymity of the user remains guaranteed.
Micro Surveys are small surveys / satisfaction surveys that commercial partners want to launch in the Cake app.

5. What is the benefit for users?

On the one hand, users enjoy the functionality of the app and, on the other hand, they receive a fee for using the app.

Functionalities:

  • 1 app for an overview of all bank accounts

  • 1 app to make payments with all bank accounts

  • advice on income and expenditure (PFM: Personal Finance Management)

Compensation:

  • Every time a user's data is processed in a statistic or insight that is taken by a commercial partner, the user receives a fee for this. After all, Cake shares the remuneration it receives from its commercial partners with its users.

  • Every time a user goes shopping following a commercial promotion announced in the app, the user receives a fee.

  • All reimbursements are always paid to users via Cake. The commercial partners do not touch the identity of the users in any way.

6. What is the advantage for the commercial companies

Through Cake, commercial companies can gain insights into the real spending patterns of their customers. The statistics and insights that Cake can make available are not based on interests or extrapolated queries, but on real transactions from private individuals. The insights that Cake can give, therefore, go much deeper and further than the insights that companies have been able to obtain so far.

7. What does GDPR say?

Cake owes its business model to GDPR and PSD2. Without these two it is not possible for Cake to be able to offer its services.

When using the app, the user explicitly agrees to store, edit and commercialize his data (identity data and other data).

This agreement is given by accepting the general terms and conditions and the privacy policy. Without acceptance, the user cannot continue in the app.

The user cannot partially agree with the terms and conditions and the privacy policy. Full acceptance is after all necessary to be able to offer both the functionalities and the reimbursements. Without acceptance the user would see an empty app.

The general terms and conditions and privacy policy are written in clear and clear language and have been reviewed by GDPR specialists from a reputed law firm.

In addition, it is important to note that Cake provides a separation between the identity data and the other data and that the user's identity will never be shared with the commercial partners or that the user's identity can never be traced by third parties parties.

All statistics and insights are based on anonymized and aggregated data.

8. What is PSD2?

PSD2 is a European regulation that means that European banking institutions are obliged to share their customers' account information with other companies that have been licensed to do so with the financial regulator. In Belgium that is the National Bank of Belgium (NBB).

Cake was recognized by the NBB on 9 July 2019 as a payment institution with the services payment initiation services and account information services and is registered as such in the register of the NBB.

This means that Cake must provide for appropriate measures in areas such as internal control, compliance, (internal and external) audit, a European anti-money laundering policy, risk management policy, conflict of interest policy, business continuity plan and IT infrastructure.

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