This Privacy Policy explains how Based Ltd, a UK limited company referred to here as Bramble, we, us, or our, collects, uses, shares, and protects information when you use the Bramble mobile app and onbramble.com, which together we call the Service. Bramble is a read only personal finance tracker and education app offered in the United States. We do not move your money, sell financial products, or give personal financial advice.
1. Who we are and what this covers
Based Ltd is a UK limited company. The company is completing incorporation, and full registration details will be listed here once confirmed. We operate Bramble, a personal finance app for net worth tracking, savings goals we call pots, spending and money leak insights, debt payoff, and financial education we call Money School. The Service is offered to customers in the United States. This Policy applies to personal information we process as a controller, meaning the party that decides why and how data is used, through the Service. It takes effect on July 24, 2026.
Because we are a UK company, the UK General Data Protection Regulation, known as the UK GDPR, and the Data Protection Act 2018 apply to how we handle your personal data, wherever you live. Since we serve customers in the United States, US state privacy laws may apply to you as well. You get the protection of both.
It does not cover how third parties handle your data. Your bank and Apple, for example, have their own privacy policies.
2. Data we collect
Information you give us
- Account and identity. Your name, email address, date of birth so we can confirm you are at least 18, and postal address where we need it for account setup or compliance.
- Authentication data. Credentials used to secure your account, plus settings like a PIN or biometric unlock. Biometric data stays on your device and is handled by iOS, so we never receive it.
- Support and communications. Messages you send us and anything you choose to share when contacting support.
Bank account data via Plaid
When you link a bank account, the connection is handled by Plaid on a read only basis. Through Plaid we request only two things.
- Balances. Account names, types, and current and available balances.
- Transactions. Transaction amounts, dates, descriptions, and categories.
Information collected automatically
- Device and app data. Device model, operating system version, app version, language, and similar technical details.
- Usage and analytics. Events in the app, such as screens viewed or features used, and diagnostic and crash data, used to keep the app working and improve it. See our Cookie Policy for what the website sets.
3. How we use your data
We use personal information to do the following.
- Provide the net worth, spending, pots, and debt payoff features.
- Categorize transactions and spot recurring payments and money leaks.
- Deliver Money School educational content.
- Sign you in, help you recover your account, and keep the Service secure.
- Provide customer support and respond to your requests.
- Maintain, debug, and improve the Service and build new features.
- Process subscriptions and manage what your account has access to.
- Meet our legal obligations and enforce our terms.
We do not use your bank transaction data for third party advertising, and we do not sell it. We also do not make decisions with legal or similarly serious effects about you based only on automated processing.
4. Our legal bases for processing
The UK GDPR requires us to have a legal basis for everything we do with your personal data. We rely on the following.
- Contract. To provide the Service you sign up for, including accounts, account aggregation, and subscriptions.
- Legitimate interests. To secure, debug, and improve the Service, prevent fraud, and communicate with you about it, always balanced against your rights.
- Consent. For linking bank accounts and any optional analytics that need it. You can withdraw consent at any time.
- Legal obligation. To meet recordkeeping, tax, and compliance requirements.
6. We do not sell your data
7. Data retention
We keep personal information for as long as your account is active and as needed to provide the Service. When you delete your account, we delete or anonymize your personal and bank derived data within a commercially reasonable period. The exception is limited records we must keep to meet legal, tax, accounting, or security obligations, or to resolve disputes. You can revoke a bank connection at any time in the app, which stops any further data retrieval for that account.
8. Security
We take security seriously and use industry standard safeguards, including the following.
- Encryption of data in transit over TLS and at rest.
- Row level security and least privilege access, so data is scoped to the account it belongs to.
- Read only bank access, so credentials never touch our systems.
- Access controls, logging, and regular review of our providers.
No method of transmission or storage is 100% secure, so we cannot promise absolute security. If we learn of a breach affecting your personal data, we will notify you and regulators as the law requires.
9. Your rights and choices
Under the UK GDPR, and depending on the state you live in, you have the right to do the following.
- Access and receive a copy of your personal information.
- Correct inaccurate information.
- Delete your information.
- Export your data in a portable format.
- Opt out of certain processing and withdraw consent.
- Object to or restrict processing where that applies.
You also have the right to complain to the UK Information Commissioner's Office, the regulator that oversees us as a UK company, at ico.org.uk. We would appreciate the chance to sort out your concern first, so please contact us before you do.
10. US state privacy rights
If you are a California resident, or live in another US state with a comprehensive privacy law, you have the following rights.
- Know what personal information we collect, use, and disclose.
- Delete personal information we hold about you, subject to exceptions.
- Correct inaccurate personal information.
- Opt out of the sale or sharing of personal information and of certain targeted advertising. As noted above, we do not sell or share your personal information.
- No discrimination for exercising your rights.
The categories of personal information we collect are described in Section 2. We collect them to provide the Service as described in Section 3. To exercise your rights, use the controls in the app or email support@onbramble.com. You may use an authorized agent, and we may need to verify your identity before acting on a request.
11. Children
Bramble is not for children. The Service is meant only for adults aged 18 and over, and we do not knowingly collect personal information from anyone under 18, and never from children under 13. If we learn that we have collected such information, we will delete it. If you believe a minor has given us information, contact support@onbramble.com.
12. Where your data goes
We are a UK company serving customers in the United States, so your data crosses borders by design. Our database and hosting run in the European Economic Area, and providers such as Plaid, Apple, RevenueCat, and Resend process data in the United States. Wherever your data travels, this Policy travels with it.
For transfers of personal data out of the UK, we use safeguards recognized under the UK GDPR, such as the UK International Data Transfer Agreement or Addendum and, where relevant, the European Commission's Standard Contractual Clauses.
13. Changes to this Policy
We may update this Policy from time to time. When we make material changes, we will update the last updated date above and, where it makes sense, notify you in the app or by email. If you keep using the Service after an update, that means you accept the revised Policy.
14. Contact us
Questions, requests, or complaints about privacy? Contact Based Ltd at support@onbramble.com and we will get back to you promptly.
Based Ltd is a UK limited company. Registration details will be listed here once incorporation completes.
Bramble is not a financial advisor. Everything in the app is general education, not financial advice. Questions about this document? Email support@onbramble.com.