Privacy Policy

The Based Apps Privacy Policy was updated on July 31, 2023.

In the following policy, Based Apps refers to the service offered by Based Apps Ltd. (the “Company” or “We”) through the website and mobile applications (the “Service”). This Privacy Policy explains what information we collect through your access and use of our Service the use we make of such information; and the security level we provide for protecting such information.
By visiting our websites and using the Services provided here, you consent to the terms outlined in this privacy policy.

Legal Framework

The Company is domiciled in Scotland and thus governed by the laws and regulations of the Scotland and United Kingdom.

Data Collection

In most cases, we don’t need your personal information to provide our services.

Visiting our website: We use specific analytics software (Google Analytics, Matomo & etc.) provided by third-parties only on Based Apps main website to collect some information (device type, language and etc.) in order to improve our services. Other our websites have no analytics software at all to ensure users’ privacy.

BasedVPN: Our VPN nodes do not collect any traffic sent by your devices by default. We do not collect IP addresses, device information & etc.

Native Applications: When you use our native applications, we (or the mobile app platform providers) may collect certain information in addition to the information mentioned elsewhere in this Policy. We may use mobile error analytics software to send crash information to our developers so that we can fix bugs rapidly. Some operating systems may also collect and aggregate anonymous statistics if you opt-in. Therefore, such data may be governed by the privacy policy and terms and conditions of such software vendors. None of the software on our apps will ever access or track any location-based information from your device at any time.

Data Use

We do not have any advertising on our websites & applications. Any data that we do have will never be shared except under the circumstances described below in the Data Disclosure Section. We do NOT do any analysis on the limited data we do possess.

Data Storage

All servers used in connection with the provisioning of the Service are located in the United Kingdom, European Union or United States of America. Only Based Apps employees have access to the servers. Data is ALWAYS transferred in encrypted format to our servers. All application specific data (e.g. BasedVPN traffic) is ALWAYS encrypted and we do not possess the ability to access any user encrypted data on the production servers.

Right to Access, Rectification, Erasure and Portability

Through the Service, you can directly access, edit, delete or export personal data (according to the EU General Data Protection Regulation) processed by the Company in your use of the Service.

Data Retention

When a BasedApps account is closed, data is immediately deleted from production servers. Active accounts will have data retained indefinitely.

Data Disclosure

Usually, we do not disclose your account information (except e-mail address) to third-party companies & government authorities. We do not provide any information unless we have received an original copy of the court order by registered post or in person.
If a request is made for user’s application-specific encrypted data, that Based Apps does not possess the ability to decrypt, the fully encrypted data may be turned over. However, Based Apps uses military-grade encryption algorithms & encrypted data cannot be decrypted be government authorities.
If permitted by law, Based Apps will always contact a user first before any data disclosure. Based Apps may contest court orders. In such situations, the Company will not comply with the court order until all legal or other remedies have been exhausted. Therefore, not all court orders will lead to data disclosure.

Modifications to Privacy Policy

Based Apps reserves the right to periodically review and change this policy from time to time and we will notify users who have enabled the notification preference about changes to our Privacy Policy. Continued use of the Service will be deemed as acceptance of such changes.

Applicable Law

This Agreement shall be governed in all respects by the substantive laws of the United Kingdom. Any controversy, claim, or dispute arising out of or relating to the Agreement shall be subject to the jurisdiction of the competent court being expressly reserved.

Warrant Canary

Based Apps has not produced any information in response to a secret subpoena and has not built “backdoors” for any government into our products. All government requests for user data need to come through the front door (i.e., by serving valid legal process upon Based Apps).

Contact information

Based Apps Ltd. (reg no. SC775767)

5 South Charlotte Street

EH2 4AN Edinburgh, Scotland

United Kingdom