Privacy Policy

Last Updated: 06/17/2026

Note: This Privacy Policy goes into effect on 6/17/2026. You can see the previous version here.

WELCOME

This Privacy Policy (“Policy”) explains how we collect, use, store, protect, and share your personal information through our services. Based, Inc. is the data controller of the personal information collected through the services (as defined in our Terms of Service (“Terms”). Based, Inc. is referred to in this Policy as “Based”, “we”, “our” or “us”.

How we handle your information depends on which services you use, and how you use them. This Policy is grouped into these sections:

  • about us and this Policy;

  • information we collect & why we use it;

  • our disclosures of information to others;

  • how to control your privacy; and

  • information about local privacy laws.

We encourage you to read this Policy carefully. If you have questions, please contact us. To exercise your privacy rights online, use our Data Subject Request form.

ABOUT US AND THIS POLICY

This Policy is designed to explain how we process your personal information and how you can exercise control over our processing. Capitalized terms that are used but not defined in this Policy are defined in our Terms. The Terms describe how the Services work in general, and establish a contract between you and us governing your use of the Services.

Contact Us

If you have any questions or feedback about this Policy, contact us at support@basedbodyworks.com or write to us at: Based Bodyworks, Inc. at 11750 Wilshire Boulevard, Los Angeles, CA, 90025. To exercise your privacy rights online, use our Data Subject Request form.

Changes to this Policy

Because the Services change often, this Policy may change over time. Anytime we modify the Policy, we post a revised version on the Services, as noted at Last Update above.

If we intend to materially change our collection or use of your information, we will notify you before the material changes to this Policy take effect, so you have time to review them. If we have your contact information (such as your email), we’ll try to notify you that way. We may also post a temporary notice on the Services, or notify you by other means to the extent required by law.

Check the Last Update periodically to ensure you’re aware of the current Policy. By using or accessing the Services, you signify that you have read, understand and agree to be bound by this Policy and the Terms.

When this Policy applies

This Policy applies to you when you use the Services, effective as of the Last Update. However, some collection and use of information falls outside this Policy:

Outside services: The Services link to, embed, integrate or otherwise connect you with third-party websites, services or other events or activities that are not owned or controlled by Based (“Outside Materials”). Outside Materials are not part of the Services. This Policy doesn’t apply to any information you may exchange with providers of Outside Materials. Those third parties have their own policies and practices about data. We encourage you to familiarize yourself with their privacy notices and applicable contractual terms.

Our personnel: If you are a current or former employee or contractor of ours, this Policy does not apply to you. Reach out to hr@based.com with any inquiries about your personal information.

When we don’t control your information: If we receive your information in our role as a service provider to another business, our agreement with that business governs our use of your information. We will refer any questions or concerns of yours to that business.

Information we collect & why we use it

We and our third-party service providers collect and process information when you interact with the Services. This includes:

  • information you submit or provide directly,

  • data collected automatically by various technologies (which we call “Usage Data”), and

  • information we receive or infer from other sources.

The following tables describe, comprehensively, how the services collect and use your information, and the purpose behind that processing.

Information You Submit

What we collect

How we use it

Why we process it

Legal basis

Retention

What Personal Information We Collect

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

What Personal Information We Collect

The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.

Information We Collect Directly from You

Information that you directly submit to us through our Services may include:

  • Contact details including your name, address, phone number, and email.

  • Order information including your name, billing address, shipping address, payment confirmation, email address, and phone number.

  • Account information including your username, password, security questions and other information used for account security purposes.

  • Shopping information including the items you view, put in your cart, saved into your account like loyalty points, reviews, referrals or gift cards, or purchases.

  • Loyalty points/product reviews/referrals/gift cards saved.

  • Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.

Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.

Information We Collect about Your Usage

We may also automatically collect certain information about your interaction with the Services ("Usage Data"). To do this, we may use cookies, pixels and similar technologies ("Cookies"). Usage Data may include information about how you access and use our Site and your account, including device information, browser information, information about your network connection, your IP address and other information regarding your interaction with the Services.

Information We Obtain from Third Parties

Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:

  • Companies who support our Site and Services, such as Shopify.

  • Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.

  • When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy. Also see the section below, Third Party Websites and Links.

How We Use Your Personal Information

  • Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to your account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and other features and functionalities related to your account. We may also enhance your shopping experience by enabling Shopify to match your account with other Shopify services that you may choose to use. In this case, Shopify will process your information as set forth in its Privacy Policy and Consumer Privacy Policy.

  • Marketing and Advertising. We may use your personal information for marketing and promotional purposes, such as to send marketing, advertising and promotional communications by email, text message or postal mail, and to show you advertisements for products or services. This may include using your personal information to better tailor the Services and advertising on our Site and other websites. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in selling our products, according to Art. 6 (1) (f) GDPR.

  • Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately. If you are an EEA resident, the legal basis for these data processing activities is our legitimate interest in keeping our website secure for you and other customers, according to Art. 6 (1) (f) GDPR.

  • Communicating with You and Service Improvement. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you according to Art. 6 (1) (f) GDPR.

COOKIES

Like many websites, we use Cookies on our Site. For specific information about the Cookies that we use related to powering our store with Shopify, see https://www.shopify.com/legal/cookies. We use Cookies to power and improve our Site and our Services (including to remember your actions and preferences), to run analytics and better understand user interaction with the Services (in our legitimate interests to administer, improve and optimize the Services). We may also permit third parties and services providers to use Cookies on our Site to better tailor the services, products and advertising on our Site and other websites.

Most browsers automatically accept Cookies by default, but you can choose to set your browser to remove or reject Cookies through your browser controls. Please keep in mind that removing or blocking Cookies can negatively impact your user experience and may cause some of the Services, including certain features and general functionality, to work incorrectly or no longer be available. Additionally, blocking Cookies may not completely prevent how we share information with third parties such as our advertising partners.

Please note that while your browser may allow you to transmit a “do not track” signal, like many websites, our Site is not designed to respond to such signals. To learn more about “do not track” signals, you can visit http://www.allaboutdnt.com/.

How We Disclose Personal Information

In certain circumstances, we may disclose your personal information to third parties for contract fulfillment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:

  • With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfillment and shipping).

  • With business and marketing partners, including Shopify, to provide services and advertise to you. For example, we use Shopify to support personalized advertising with third-party services. Our business and marketing partners will use your information in accordance with their own privacy notices.

  • When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship you products or through your use of social media widgets or login integrations, with your consent.

  • With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.

  • In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.

We have in the past 12 months disclosed the following categories of personal information and sensitive personal information about users for the purposes set out above in "How we Collect and Use your Personal Information" and "How we Disclose Personal Information":

Category

  • Identifiers such as basic contact details and certain order and account information

  • Personal information categories listed in the California Customer Records statute such as basic contact details and certain order and account information

  • Commercial information such as order information, shopping information and customer support information

  • Internet or other similar network activity, such as Usage Data

  • Geolocation data such as locations determined by an IP address or other technical measures

Categories of Recipients

  • Vendors and third parties who perform services on our behalf (such as Internet service providers, payment processors, fulfillment partners, customer support partners and data analytics providers)

  • Business and marketing partners

  • Affiliates

We do not use or disclose sensitive personal information without your consent or for the purposes of inferring characteristics about you.

Third Party Websites and Links

Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.

Children's Data

The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.

As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.

Security and Retention of Your Information

Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use insecure channels to communicate sensitive or confidential information to us.

How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.

Your Rights

Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.

  • Right to Access / Know: You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.

  • Right to Delete: You may have a right to request that we delete personal information we maintain about you.

  • Right to Correct: You may have a right to request that we correct inaccurate personal information we maintain about you.

  • Right of Portability: You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.

  • Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.

  • Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.

  • Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.

  • Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.

You may exercise any of these rights where indicated on our Site or by contacting us using the contact details provided below.

We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

We use Shopify's ad services such as Shopify Audiences to help personalize the advertising you see on third party websites. To opt out of personalized advertising with third-party services supported by Shopify, visit https://privacy.shopify.com/en.

Complaints

If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority. For the EEA, you can find a list of the responsible data protection supervisory authorities

here.

International Users

Please note that we may transfer, store and process your personal information outside the country you live in. Your personal information is also processed by staff and third party service providers and partners in these countries.

If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.

Contact

Should you have any questions about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you, please call or email us at support@basedbodyworks.com or contact us at 11750 Wilshire Boulevard, Los Angeles, CA, 90025, US.

For the purpose of applicable data protection laws and if not explicitly stated otherwise, we are the data controller of your personal information.

We and our third-party service providers collect and process information when you interact with the Services. This includes:

  • information you submit or provide directly,

  • data collected automatically by various technologies (which we call “Usage Data”), and

  • information we receive or infer from other sources.

The following tables describe, comprehensively, how the services collect and use your information, and the purpose behind that processing.

Information You Submit