Privacy Policy

Last updated: Jan 9, 2023

This Privacy Policy describes the policies and procedures PDB Pte Ltd ("PDB", the "Company", "we", "us", or "our") collects, uses, and discloses any personal data when you use Based mobile application, our websites and microsites (such as or our digital products and services (such as our competitions or surveys) (collectively, the "Services") or when you otherwise interact with us. We suggest you read this in conjunction with our Terms of Service.

We value the privacy of users, publishers, and others who visit and use the Services (collectively or individually, “you” or “users”) and want you to be familiar with how we handle your personal data, your privacy rights, and how the law protects you.

What We Collect

User-provided information

Your account information

We collect information you provide us directly when you create an account on Based mobile application. This includes:

After registering, you can review and update your account information at any time by logging in to Based or by contacting us at admin @ Please note that your date of birth and country (which is based on the region of your device) cannot be changed. It's important to keep your account details up to date. If you need to make any changes, you can do so by logging in to the app. Information such as your sexual preference, name and username may be visible to other Users who view your profile page.

Profile Information

We recommend and encourage you to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ licence details and other sensitive information which is open to abuse and misuse on your profile. When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk.

Such information may include the following personal data, depending on your activity: 

Information about your purchases on Based

If you purchase paid items available on Based, we will keep your purchase and subscription history; however, we do not process your payment details. This information is collected and processed by your app store (App Store, Google Play Store).

Geolocation Information

If you have given Based access to your location in your device settings, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalise the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

If you have given Based access to your location, but wish to turn this off, you can do so by the following methods:

  1. iPhone app — settings, privacy, location services, Based
  2. Android — settings, location, Based, permissions, location

Other information

You may choose to provide other information directly to us. For example, information you provide when participating in surveys and activities on Based. Your opt-in choices and correspondence with us, such as information used to verify with your account or to resolve your feedback or complaints.

If you would like to find out more about cookies, including how we use them and what choices are available to you, please refer to our Cookie Policy.

Automatically collected information

We may also automatically collect information about you when you access or use our Services. This includes:

Usage data: Usage data may include information such as your device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data. We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device.

Information collected from cookies and similar technologies: Cookies and similar tracking technologies are used by us or our business partners to track the activity on our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Policy.

Information from third parties

Connected social media services: Based allows you to create an account and log in to use the Services through the third-party social media services such as Google or Apple ID. If You decide to register through or otherwise grant us access to a third-party social media service, we may collect personal data from the third-party social media services for which you have approved our access. You may also have the option of sharing additional information with us through your third-party social media service's account. If You choose to provide such information and personal data, during registration or otherwise, you are giving the Company permission to collect, store, and use such additional information and content in a manner consistent with this Privacy Policy.

Information collected from integrations: We also may receive information about you, including log and usage data and cookie information from a third party that conduct business with us. For example, if an advertiser launches a marketing campaign on our Services, we may receive from them limited information about your activity on the advertiser’s site or app, such as whether you bought something from the advertiser. You can control how we use this information to personalize the Services for you as described below.

How We Use Your Information

We may use personal data for the following purposes:

How We Share Your Information

We may share your personal information in the following situations:

How We Store Your Information?

The personal data we collect from you may be stored on a server located in the United States. We may store information on major servers around the world, depending on a variety of factors, including the locations of users and service providers, to bring you our services globally and continuously.

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use you personal information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. 

We will also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods. For example, if we deactivate a user's account because of unsafe behavior or security incidents, we may retain certain information about that account to prevent that user from opening a new Based account in the future.

International Data Transfer

Your personal information may be processed by us, our trusted third party suppliers outside of your state, province, country, or other governmental jurisdiction where data protection and privacy laws or regulations may be equivalent to, or as protective as, the data protection laws and regulations in your country. In accordance with applicable data protection and privacy laws and regulations, we will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this Privacy Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

We may also transfer your personal information outside of your country as permitted by applicable data protection and privacy laws and regulations. Examples include where we need to transfer your personal information: (a) to perform a contract with you (or to take steps before the contract at your request); (b) perform a contract in your interests; or (c) in relation to legal claims.

Your Choices

Control the use of cookies: You may set your browser to refuse all or some browser cookies. Please note that your choice to disable cookies will be specific to the particular browser or device that you are using when you disable cookies, so you may need to separately disable cookies for each type of browser or device. If you disable or refuse cookies, please note that some parts of the website may then be inaccessible or not function properly.

Control mobile notifications: You can at any time request to opt out from allowing us to send you push notifications by adjusting the permissions in your mobile device.

Control advertising and analytics: Some analytics providers we partner with may provide specific opt-out mechanisms and we may provide, as needed and as available, additional tools and third-party services that allow you to better understand cookies and how you can opt out. For example, you may manage the use and collection of certain information by Google Analytics via the Google Analytics Opt-out Browser Add-on.

Change or delete your information: You may make changes to your information, including accessing your information, correcting or updating your information or deleting your information from your user profile page. When you delete your account, your profile is no longer visible to other users and disassociated from content you posted under that account. Please note, however, that the posts, comments, and messages you submitted prior to deleting your account will still be visible to others unless you first delete the specific content. We may also retain certain information about you as required by law or for legitimate business purposes after you delete your account.

Choose not to provide us with personal information: You can choose not to provide us with personal information, but that may result in you being unable to use certain features of our Services because such information may be required for you to register as a user, participate in a promotion, survey, or make complaints.

Your Rights

Some jurisdictions' laws grant specific rights to Based users, which are set out in this section. You may have all or some of the following rights set forth below according to applicable laws:

The right to access – You may request Based for copies of your personal information by sending your request to us via email.

The right to rectification – You may request that we correct any information you believe is inaccurate, or complete the information you believe is incomplete by sending your request to us via email.

The right to erasure – You may request that we erase your personal data under certain conditions by sending your request to us via email. Though we cannot guarantee a complete erasure of your data that has been stored in our backup servers, we promise that we will not use the data within the backup servers for any other purpose.

The right to restrict processing – You may request that we restrict the processing of your personal data if you believe such information is collected unlawfully or you have other reason by sending your request to us via email. We will examine your request and respond accordingly.

The right to object to processing – You may object to the processing of any personal information we collect about you, if such information is collected on the basis of legitimate interests, at any time by sending your request to us via email. Please note that we may reject your request if we demonstrate compelling legitimate grounds for the processing, which override your interests and freedom or the processing is for the establishment, exercise, or defense of legal claims.

The right to withdraw consent – You may withdraw your consent and ask us not to continue to collect or process your personal information at any time if that information is collected on the basis of your consent by sending your request to us via email. Your exercise of this right will not affect the processing activities that occurred before your withdrawal.

The right to data portability – You may request that we transfer some of your personal information, if it is collected on the basis of your consent, in structured, commonly used and machine-readable formats to you or other environments designated by you, if technically feasible by sending your request to us via email.

If you make a request, we will respond to your request consistent with the applicable laws as soon as practicable, normally within one month, after proper verification procedures. If you would like to exercise any of these rights, please contact us at our email: admin @

Additional Information for EEA Users

Users in the European Economic Area ("EEA") have the right under to request access to, rectification of, or erasure of their personal information; to restrict processing; to object to processing; to withdraw consent for processing where they have previously provided consent; or to data portability in certain circumstances. These rights can be exercised using the information provided under Your Choices or Your Rights section above.

You may exercise your rights by contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your personal information. For more information, if you are in the EEA, please contact your local data protection authority in the EEA.

As required by applicable law, we collect and process information about individuals in the EEA only where we have a legal basis for doing so. Our legal bases depend on the Services you use and how you use them. We process your information on the following legal bases:

Additional Information for California Users

This Additional Information for California Users section supplements the information contained in our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

The personal information that Based collects, or has collected from you in the twelve months prior to the effective date of this disclosure page, fall into the following categories.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if you provided such personal information directly to us.

Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver's license number, passport number, or other similar identifiers.

Collected: Yes.

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: Yes.

Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

Category G: Geolocation data.

Examples: Approximate physical location.

Collected: Yes.

Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: Yes.

Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: Yes.

Under CCPA, personal information does not include:

Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may disclose and may have disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

When we disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

You can find more information about (a) what we collect and sources of that information, (b) the business and commercial purposes for collecting that information, and (c) the categories of third parties with whom we share that information in the What We Collect, How We Use Your Information, and How We Share Your Information sections above.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their personal information. If you are a resident of California, you have the following rights:

Exercising Your CCPA Data Protection Rights

In order to exercise any of your rights under the CCPA, and if you are a California resident, you can contact us by email.

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information.

Your request to us must:

We cannot respond to your request or provide you with the required information if we cannot:

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonable necessary and with prior notice.

Any disclosures we provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out, please contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to opt out on every browser that You use.


You can opt out of receiving ads that are personalized as served by our Service Providers by following our instructions presented on the Service:

The opt out will place a cookie on your computer that is unique to the browser you use to opt out. If you change browsers or delete the cookies saved by your browser, You will need to opt out again.

Mobile Devices

Your mobile device may give you the ability to opt out of the use of information about the apps you use in order to serve you ads that are targeted to your interests:

You can also stop the collection of location information from your mobile device by changing the preferences on Your mobile device.

"Do Not Track" Policy as Required by California Online Privacy Protection Act (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.


Our Service does not address anyone under the age of 13 ("Young Users"). We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from Young Users without verification of parental consent, We take steps to remove that information from our Servers.

If we need to rely on consent as a legal basis for processing your information and your country requires consent from a parent, We may require your parent's consent before we collect and use that information.

If you believe that we have inappropriately collected Personal Information from a Young User, please contact us at admin @

Other Rights

Sharing for Direct Marketing Purposes (California's Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law), California residents with an established business relationship with us can request information once a year about sharing their personal information with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light law, and if you are a California resident, you can contact us by email.

Content Removal for Users Under 18 (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services or applications to request and obtain removal of content or information they have publicly posted.

To request removal of such data, and if you are a California resident, you can contact us by email with the email address associated with your account.

Be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third party 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.

Changes to this Privacy Policy

As Based evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within Based.

Contact Us

If you have any questions about this Privacy Policy, You can contact us via email: admin @