Privacy Policy

July XX, 2026

Spontalis Private Limited, a company registered and existing in India under the Companies Act, 2013 (hereinafter referred to as “Pearbae”/“we”/“our”/“us”) operates an online platform under the brand name of ‘Pearbae’ for connecting people through online matching and offline events, available at www.pearbae.com and on the Google Play Store and App Store as Pearbae (collectively referred to as the “Services”). This Privacy Policy (hereinafter referred to as the “Privacy Policy”) provides greater transparency into our privacy practices and principles while processing the Personal Information and/or Sensitive Personal Information (as defined below) when its users (“you”/“your”/“Users”/“Customers”) access and use our Services. We respect your privacy and are committed to safeguarding your information.

This Privacy Policy is a part of and is to be read with the Terms and Conditions (“Terms & Conditions”) available at https://pearbae.com/terms-conditions. By using our Services, you agree to the Terms & Conditions of this Privacy Policy. You also consent to our use and disclosure of your Personal Information and/or Sensitive Personal Information in the manner described in this Privacy Policy. If you do not agree with the Terms & Conditions of this Privacy Policy, please refrain from using our Services.

1. Collection of Information

Personal Information

Personal Information means and includes any information that identifies you by reference to an identifier including, but not limited to name, email, phone, age, biometric data, social media profile details, etc.

App Usage Data

App Usage Data means and includes information related to your use of the Services including, but not limited to interactions with features, session duration, app crash reports, log files, in-app/website preferences, etc.

Location Information

Location Information means and includes your approximate or precise location, subject to permission granted by you.

Device Information

Device Information means and includes information about the device you use to access the Services including, but not limited to device info, browser type, operating system, IP address, etc.

Sensitive Personal Information

Sensitive Personal Information shall have the meaning ascribed to it under the applicable law and is presently defined to mean such Personal Information which consists of information including, but not limited to passwords, financial information (credit/debit card or other payment details), sexual orientation, medical records, mental health condition, etc.

User-generated Content

Posts, comments, reviews, ratings, photos, and other associated metadata. We may combine information that we collect from you through the Services with information that we obtain from others and information derived from other products or services we provide.

Any of the information received by us for processing or storing under lawful contract or otherwise, provided that any information that is freely available or accessible in public domain or furnished under the Right to Information Act, 2000 or any other law for the time being in force, shall not be regarded as Sensitive Personal Information.

We collect the above information because it is necessary for us to be able to provide and administer the Services and its features. We also collect certain information to comply with specified statutory requirements.

Access without Sign-Up

You may initially, access certain portions or features of the Services without creating an account or logging in. In such cases, Pearbae may collect limited technical and usage data to enable basic functionality and analytics.

Depending on your interactions or continued usage, Pearbae may prompt you to sign up or log in to access additional features or continue availing our Services. Pearbae reserves the right to restrict or limit access to certain features or services unless you complete the sign-up process.

The information collected by us is processed based on your consent. In view of this, you are required to give such a consent and you may at any time, wholly or partly, withdraw your consent. Even if you have consented to our using your information for a specific purpose, you will have the right to change your decision at any time, but this will not affect any processing that has already taken place.

We may, in our legitimate interests, deidentify or anonymize your collected information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (“Deidentified Information”) (or we may collect information that has already been deidentified/anonymized), and we may use such Deidentified Information for any purpose. To the extent we possess or process any Deidentified Information, we will maintain and use such information in deidentified/anonymized form and not attempt to reidentify the information, except solely for the purpose of determining whether our deidentification/anonymization process satisfies legal requirements.

2. Usage of your Information

The information we collect and process from Customers, enables us to personalise and continuously improve your experience of our Services, including, but not limited to personalising your social connections; showing relevant events, and experiences near you; facilitating bookings and payments; supporting features like social posting, commenting, and following; improvement of our Services, website, app, analytics, safety, and fraud prevention; sending updates, promotions, and notifications (which you may opt out of); etc.

Automated Processing and Profiling

In certain cases, Pearbae may use automated tools and algorithms to analyse user preferences and behaviour for the purpose of providing personalized recommendations, content suggestions, and enhanced user experiences. Such processing may amount to profiling under applicable data protection laws. No decision with significant legal or similar effects is made solely based on automated processing. Users who wish to know more about our personalization practices may contact us at compliance@pearbae.com.

3. Sharing of Information

We operate globally and may share your information to third parties in locations around the world for the purposes described in this Privacy Policy. Wherever your information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of the same. By accepting this Privacy Policy, you hereby explicitly provide your consent and grant us the right to transfer your information to third parties located within the territory of India or globally.

Notwithstanding the above, we may share your information in the following manner:

  • With service providers, hosts, and venue partners to confirm bookings;
  • With third-party service providers like maps, analytics, and payment gateways; and
  • As required by law or to protect rights, safety, or property.
  • With our affiliates, meaning an entity that controls, is controlled by, or is under common control with Pearbae. Our affiliates may use such information in a manner consistent with this Privacy Policy.

4. Cookies & Tracking

We use Cookies and similar technologies for personalisation, analytics, and advertising, in order to enable us in providing you with a good experience when you use our Services and further allowing us to improve our Services.

Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you directly to us, to another party on our behalf, or to another party in accordance with its privacy policy. You may turn off and/or limit our access to Cookies, however this may affect your overall user experience of our Services, since it will no longer be personalized to you. It may also stop you from saving customized settings like login information.

Cookies can help us identify and impose additional security measures when someone may be attempting to access an account without authorisation.

We also use Cookies to help provide you with content relevant to your locale.

You may block and/or limit our access to Cookies, however this may affect your overall user experience, since it will no longer be personalized to you. It may also stop you from saving customized settings like login information.

Your web browser may also allow you to manage your cookie preferences, including to delete and disable cookies. Cookie settings are device and browser specific, so you will need to set cookie preferences for each device’s browser.

5. User Rights

You can control your choices regarding our collection, use and sharing of your information. In accordance with local or applicable law, you may exercise any of the following rights by contacting us using the information provided in clause 11:

  • Access, modify, or delete your profile data;
  • Request content removal or account deletion;
  • Opt-out of marketing communications and targeted advertisements; and/or
  • You may request access to the Personal Information we hold about you to amend or delete it.

6. Information Security & Retention

We implement reasonable industry-standard security measures that are designed to protect guest information from unauthorized access, disclosure, use and modification, but cannot guarantee absolute protection.

All interactions with our Services use the Transport Layer Security/Secure Sockets Layer (TLS/SSL) protocol. All data is encrypted via SSL/TLS when transmitted from our servers to your browser. We also implement role-based access, multi-factor authentication, and regular reviews to ensure only authorised staff can view your information. Additionally, we run regular security audits and vulnerability assessments.

We may be required to share your information with government authorities and agencies for the purposes of verification of identity or for prevention, detection, investigation including cyber incidents, prosecution and punishment of offences. You agree and consent for us to disclose your information, if so required under the applicable law.

Your information is retained only as long as it is necessary or as is required by law and for providing the Services. We calculate the appropriate retention period for your information by considering its nature and sensitivity, the purposes for which we are processing the information, and any applicable statutory retention periods. Using these criteria, we regularly review the information which we hold and the purposes for which it is held and processed. Once processing has been completed, we may securely delete or anonymise your collected information.

If you terminate your account, stop using the Services, or our Agreement with you under the Terms & Conditions is terminated, we will delete your information as it is no longer relevant, but we may continue to process your personal data as required under applicable law, in order to establish, exercise or defend legal claims where relevant.

7. Public Content & Social Features

Certain features of the Services may allow you to initiate interactions between the Services and third-party services or social-media platforms, including but not limited to X (formerly Twitter), Instagram, Facebook, and other social networks (“Social Features”). Social Features include features that allow you to access our pages on third-party platforms, and from there ‘like’ or ‘share’ our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service.

Please avoid posting Sensitive Personal Information.

9. Children's Information

Our Services are not intended for users under the age of eighteen (18). We do not permit individuals under the age of 18 on our platform. By using our Services, you represent that you are at least 18 years old.

If we discover that we have collected personal information from a minor, we will promptly delete that information. If you believe we may have collected such data, please contact us at compliance@pearbae.com.

10. Updates

We may update this Privacy Policy from time to time to accommodate new technologies, industry practices, statutory or regulatory requirements, or for other purposes. We shall on a best effort basis provide notice to you through the contact details provided to us by you however, you are encouraged to check our Privacy Policy periodically.

In cases where you access the Services without creating an account or providing identifiable contact details, we may be unable to communicate policy updates or notifications directly to you. All updates to this Privacy Policy shall be made available periodically, and continuous use of our Services following such updates, constitutes a valid and binding acceptance by you.

11. Grievance Officer

If you have any concerns about privacy please contact us with a thorough description and we will aim to resolve the issue within thirty (30) days from the date of receipt, in accordance with applicable laws. In case there is a delay, we will notify you accordingly.

12. Notices

Notices may be sent either by email to you at the last email address you provided us (if any), or by posting notice of such changes in our Services on our website or application, or by other means consistent with applicable law. Your continued use of the Services after any such updates constitutes your acknowledgment and acceptance of the revised terms.