1.Introduction and Scope
SOOMI LIMITED ("we", "us" or "our"), a company incorporated in Hong Kong, operates the CakeGrowth affiliate marketing platform, connecting SaaS providers ("Advertisers") with promoters who market their products ("Publishers", also referred to as "Affiliates"). This Policy applies to our official website (https://www.cakegrowth.com), the platform and all related services. We process your personal information in accordance with the Personal Information Protection Law, the Data Security Law, the Cybersecurity Law and other applicable laws and regulations of the People's Republic of China ("PRC"), as well as, where applicable, the Personal Data (Privacy) Ordinance of Hong Kong. By accessing or using our services, you acknowledge that you have read and agree to this Policy.
2.Information We Collect
2.1 Information You Provide Directly
When you register an account, apply for onboarding, request a demo or communicate with us, we collect:
Account information: company/individual name, business email, contact person, contact phone number and (where required) mailing address.
Onboarding materials (Advertisers): company name, official website, product introduction and expected promotional goals submitted for qualification review.
Settlement information: for individual Publishers — name, mobile number and payment-related information (collected and verified through a third-party payment platform); for enterprises and individual industrial and commercial households — corporate bank account, account-opening bank, unified social credit code and information required for invoicing; for Advertisers — information required for account funding and invoicing.
Verification materials: documents used for real-name/entity verification and for verifying ownership of traffic sources (such as ID documents and business licenses).
ID numbers, bank account details and similar data constitute sensitive personal information. We collect such information only to the extent necessary for real-name verification, settlement and tax compliance, and we will separately inform you and obtain your consent at the time of collection.
2.2 Information Collected Automatically
Device and usage data: IP address, browser type, operating system, device identifiers and timestamps.
Tracking technologies: we use cookies, web beacons and pixel tags to record your actions within the console and to attribute Publisher referrals. Non-essential cookies are enabled only with your consent; you may manage or refuse them through your browser settings.
2.3 Information from Third Parties
Performance data: we obtain successful conversion data (e.g., subscriptions, registrations) generated by Publishers from Advertisers, for the purpose of calculating commissions.
Payment and settlement services: relevant information from third-party payment and settlement service providers.
3.How We Use Information
Service provision: operating the affiliate platform, tracking referral links and managing account access.
Commission processing: calculating, confirming, invoicing and transferring funds between Advertisers and Publishers, and withholding and remitting applicable taxes as required by law.
Analytics and risk control: analyzing platform performance, optimizing promotions and preventing fraud.
Communications: sending transactional notices (e.g., payment notifications) and policy updates; sending marketing messages with your consent.
Compliance: fulfilling tax, anti-money-laundering and other statutory obligations.
4.Information Sharing and Disclosure
We do not sell your personal information. We share information only in the following circumstances:
4.1 Between Advertisers and Publishers
To facilitate affiliate cooperation, we share necessary performance data (such as clicks, conversion status and traffic-source category) between the relevant Advertiser and Publisher. We do not share either party's sensitive financial or identity information.
4.2 Service Providers
We share data with trusted third parties to the extent necessary for them to perform their services, and require them to protect it in accordance with the law:
third-party payment, settlement and tax withholding service providers, and corporate remittance banks;
cloud hosting and data storage (Alibaba Cloud, Guangzhou);
fraud detection and security monitoring.
4.3 Legal Requirements and Business Transfers
Compliance disclosure: we may disclose relevant information where required by law, regulation or valid legal process, or to protect the legitimate rights and interests of ourselves and others.
Business transfers: in a merger, acquisition or asset transfer, user information may be transferred as part of the business assets. We will require the transferee to remain bound by this Policy and will separately notify you of any material changes.
5.Data Storage and Cross-Border Processing
Your personal information is stored and processed on servers located in mainland China (Alibaba Cloud, Guangzhou region). Our business primarily serves Advertisers and Publishers in mainland China. As we are incorporated in Hong Kong, where remote access to such information from outside mainland China or any cross-border transfer is required for our operations, we will take the necessary measures and complete the required procedures in accordance with the cross-border data transfer requirements of applicable PRC laws.
6.Automated Decision-Making
To perform affiliate referral attribution, commission calculation and anti-fraud detection, we may process and analyze relevant data automatically. We ensure the transparency of such processing and the fairness and reasonableness of its outcomes, and we will not impose unreasonable differential treatment. We will not make decisions that significantly affect your rights and interests solely through automated decision-making. Where such decisions (e.g., anti-fraud blocking, commission invalidation) significantly affect your rights, you have the right to request an explanation from us and to refuse decisions made solely by automated means. You may exercise these rights by contacting [email protected].
7.Your Rights
Under the Personal Information Protection Law and other applicable laws, you have the following rights in relation to your personal information:
Right to know and decide: to understand and decide on our processing of your information, and to restrict or refuse processing by others.
Right to access and copy: to access and copy your personal information collected by us.
Right to correct and supplement: to correct inaccurate or supplement incomplete information.
Right to deletion: to request deletion under statutory circumstances (subject to statutory retention obligations, such as financial and tax requirements).
Right to withdraw consent: to withdraw consent previously given (without affecting processing carried out before the withdrawal).
Right to delete your account and to request explanations.
To exercise these rights, please email [email protected]. We will verify your identity and process your request within the statutory time limit.
8.Data Security and Retention
Security: we adopt encrypted transmission (SSL/TLS), access controls, security audits and other measures to protect your data; however, please understand that no internet transmission can be guaranteed to be absolutely secure.
Retention: we retain your information while your account is active and for the period necessary to fulfill legal and tax obligations. Financial and tax records are retained as required by applicable law. Information beyond these periods will be deleted or anonymized.
9.Protection of Minors
Our services are intended for enterprises and professional users (B2B), not minors. We do not knowingly collect personal information of persons under the age of 18; if we discover any such information, we will delete it promptly.
10.Changes to This Policy
We may update this Policy from time to time. In the event of material changes, we will notify you via an announcement on our official website (https://www.cakegrowth.com) or by email.
11.Contact Us
If you have any questions or complaints about this Policy, please contact:
Entity: SOOMI LIMITED
Email: [email protected]
Address: Room H18, 4/F, Century Industrial Centre, 33-35 Au Pui Wan Street, Fotan, Sha Tin, Hong Kong