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Privacy Policy & Terms & Conditions

Our Agreement

This is Creato’s Terms and Conditions of Use (“Terms of Use”) which explains the rules on users in order to protect ourselves and also Creato’s users as well. Yours and our rights should be known and understood before you use Creato’s websites (current addresses: & and mobile application (collectively, the “Platform(s)”) which are operated and owned by ESSAA Limited and/or its subsidiary(ies) and/or affiliate(s) (collectively referred to as “Creato”, “we”, “us” or “Company”) (our website and the App, are referred to collectively in this Terms of Use as the “Services”). Terms of Use also come with our privacy policy, we suggest users take a few moments to read these before enjoying our Services.  By using our Services you agree and acknowledge that you have read and understood these Terms of Use and that you are deemed to have accepted and agreed to be bound by them in full.

If you do not agree to these Terms of Use, do not use any portion of our Services.

If you have any questions about the Terms of Use, please contact us at or via +852 6146 8385.

Change of Terms of Use

Creato reserves the right, at its sole discretion, to change, modify, add or remove portions of these Terms of Use, at any time. The amended Terms of Use are effective from the date they are published through the Platforms. It is your responsibility to check these Terms of Use periodically for changes. Your continued use of the Platforms following the posting of changes will mean that you accept and agree to the changes. As long as you comply with these Terms of Use, Creato grants you a personal, non-exclusive, non-transferable, limited privilege to enter and use the Platform(s). Your access to our Platform(s) and Services (as defined below) will be terminated upon your notice to us that any change is unacceptable.

In addition, when using the Services, you shall be subject to any additional terms applicable to such Services that may be posted on the page relating to such Services from time to time and the privacy policy adopted by Creato from time to time (“the Privacy Policy”). All such terms are hereby expressly incorporated by reference in this Terms of Use.

Register with us

You may be required to register with Creato in order to access certain contents and use certain functions, including to access Creato’s mobile application (“App”), including but not limited to the submission of travel experience, reviews, comment, purchasing services, redemption of gifts and so forth (“Creato Member(s)”). In order to create an account (“Account“) you agree represent, warrant and covenant with us that:-

  • Your personal particulars are true, accurate, current, complete and not misleading in all respects, and further undertake to promptly update Creato if there is any subsequent change in such particulars. If you provide any information that is untrue, inaccurate, non-current or incomplete, or else Creato has reasonable grounds to suspect that such information is untrue, inaccurate, non-current or incomplete, Creato has the right to suspend or terminate your account and refuse any and all current or future use of the Platforms.

  • You are at least 18 years old or above and capable of forming a legally binding contract; and

  • if you register an Account on behalf of another person, a company or a business, that you have the authorization to do so;

  • You do not select a username or password that violates any person’s rights or one that in our opinion is offensive, improper or inappropriate. If you do so, we reserve the right to modify or delete the username or password and/or terminate your Account with the Platforms. In any event, we shall not be liable in any way for any improper use of a username or password by any user.


Access and Use of the Service

  • To use the Web / App, you must have a compatible mobile device. Creato does not warrant that the Web / App will be compatible with the mobile device that you use.

  • The Creato mobile application may automatically download and install updates from time to time or require the downloading and installation of updates or new versions for continued use. You acknowledge that in some instances updates and/or new versions may reduce or remove features and functionality in prior versions of the Web / App.

  • We may provide you with emails, push notifications, alerts, and other messages related to the Web / App and/or our Services, such as enhancements, offers, products, events, and other promotions. After downloading the App, you will be asked to accept or deny push notifications/alerts. If you deny, you will not receive any push notifications/alerts. If you accept, push notifications/alerts will be automatically sent to you. If you no longer wish to receive push notifications/alerts from the App, you may opt-out by changing your notification settings on your mobile device. With respect to other types of messaging or communications, such as emails, text messages, etc., you can unsubscribe or opt-out by following the specific instructions included in such communications.

  • Creato does not guarantee that the Services will always be available or uninterrupted. Creato will not be liable to you if for any reason the Services are unavailable at any time or for any period. You are responsible for making all arrangements necessary for you to have access to the Services. You are also responsible for ensuring that all persons who access the Services through Internet connection are aware of this Terms of Use and other applicable terms and conditions for the Services, and that they comply with them.

  • Creato reserves the right to modify or discontinue, temporarily or permanently, the Service (or any part thereof) with or without notice. You agree that Creato will not be liable to you or to any third party for any modification, suspension or discontinuance of the Service.

  • You acknowledge that Creato may establish general practices and limits concerning use of the Services, including without limitation the maximum period of time that data or other content will be retained by the Services and the maximum storage space that will be allotted on Creato’s servers on your behalf. You agree that Creato has no responsibility or liability for the deletion or failure to store any data or other content maintained or uploaded by the Services. You acknowledge that Creato reserves the right to terminate accounts that are inactive for an extended period of time. You further acknowledge that Creato reserves the right to change these general practices and limits at any time, in its sole discretion, with or without notice.

  • You are solely and entirely responsible for maintaining the confidentiality of your user identification code, password or any other piece of information as part of our security procedures. You must not disclose it to any third party. In no event shall Creato be responsible or liable for any loss or damage in relation to the unauthorized use of your Account by any person; you will immediately notify us of any unauthorized use of your Account or any other breach theof security with respect to the use of the Services; and

  • If you know or suspect that anyone other than you has knowledge of your user identification code or password, you must promptly notify Creato at

  • You may not use anyone else’s account at any time, without the permission of the account holder. You understand that you may voluntarily terminate your use of and delete your account from the Platforms by using the applicable deactivation mechanism provided on the Platforms.

  • Creato reserves the rights, in its sole discretion, to modify the Services, including without limitation by removing, adding, or modifying any portion of the Platforms and to edit, modify, share, erase, delete or remove any post reviews, opinions, advice, ratings, discussions, comments, messages, survey responses, and other communications, as well as files, images, photographs, video, sound recordings, musical works and other content as uploaded, posted or shared by a you on the Platforms (“Your Content(s)“) for any reason from time to time and without notice. Creato shall have no liability to you for any of the foregoing actions except pursuant to terms of any service agreement entered into with Creato, if any. Except as specified in the Terms of Use, Creato is not a party to any actual transaction between you any other user of the Platforms.



When you use our Platform, you agree to our Privacy Policy, and its provisions are part of these Terms of Use.

Our Intellectual Property Rights

We own or are the licensee(s) of “Our Content“, which includes, but is not limited to, all intellectual property rights on the Platform (including all copyright, patents, logos, trademarks, service marks, trade names, domain names, social media identifiers, designs, whether registered or unregistered) and materials, information and Your Content on the Platform or accessed as part of the Services, any database operated by Creato, all the Platforms’ design, text, graphics, software, photos, video, music, sound, data, all software compilations, underlying source code and software (including applets and scripts), and all the selection, coordination, arrangement and enhancement. You understand and agree that Our Content is protected and you will not download, copy, modify, reproduce, print or distribute Our Content in any way unless you have received our prior written permission. Copying or storing of any Content other than personal and non-commercial use is expressly prohibited without prior written permission from Creato or from the copyright holder identified in such Contents copyright notice.

Your Content and the permission you give us

You hereby warrant that you have the right to use Your Content and you acknowledge and agree that Creato may not pre-screen or pre-approve Your Content which you upload, post or share on the Platforms and you agree that Creato has the sole and absolute right, but not the obligation, to review, edit, post, refuse to post, remove and monitor Your Content. Creato has the sole and absolute right, but not the obligation, to disclose Your Content and the circumstances surrounding its transmission to any third-party, at any time, for any reason, including to determine compliance with the Terms of Use as well as to satisfy any applicable law, regulation or authorised government request.

By uploading, posting or sharing Your Content on the Platform, you unconditionally grant Creato a non-exclusive, worldwide, perpetual, irrevocable, royalty-free right to exercise the copyright, publicity and database rights (but no other rights) you have in Your Content in order that Creato can use, publish, host, display, promote, copy, download, forward, distribute, reproduce, transfer, edit, sell and re-use Your Content in any form and anywhere, with or without making any commercial gains or profits, and carry out the purposes set out in the Privacy Policy and herein.

Any use of any of such Your Content other than those permitted under the Terms of Use, the Privacy Policy and the terms and conditions of any service agreement(s) is strictly prohibited and Creato shall reserves all its rights in this respect. You acknowledge that you will be solely responsible for any adverse consequences arising from their breach of intellectual property laws. For the avoidance of doubt, any consent of any third parties on the use of Your Content and materials mentioned above shall not release you from the restrictions/prohibitions imposed hereunder.

You agree that Creato is free to use, disclose, adopt and modify all and any ideas, concepts, proposals, suggestions, comments and other communications and information provided by you in connection with your use of the Platforms/Systems without any remuneration or compensation to you. You hereby waive all and any rights and claims for any consideration, fees, royalties, charges and/or other payments in relation to Creato’s use, disclosure, adoption and/or modification of such ideas, concepts, proposals, suggestions, comments and/or other communications and information.

Creato takes no responsibility whatsoever for Your Content on the Platforms or any of Your Content sent through the Platforms, or for any of Your Content lost and does not make any representations or warranties regarding the content or accuracy of any material therein. Your Content of any kind made by you or any third-party is made by the respective author(s) or distributor(s) and not by Platforms. Other Creato Members may post content that is inaccurate, misleading or deceptive. Creato does not endorse and is not responsible for any content, and will not be liable to you or any other person for any loss or damage caused by your reliance on such content. Such content reflects the opinions of the person submitting it and may not reflect the opinion of Creato. Creato does not control or endorse any content, and specifically disclaims any liability concerning or relating to Your contribution of, use of, or reliance on any content and any actions resulting from your participation in any part of the Platforms or Services, including any objectionable content.

You may not access or collect data from our Platforms or Services using automated means (without our prior written permission) or attempt to access data that you do not have permission to access.

Purchase Donuts

  1. You clearly understand and agree that you have to firstly purchase some Donuts through the sales channel recognized by Creato in order to use the specific features, such as participating in a DareMe, in the Services. In case of any violation of the foregoing, Creato may deactivate or delete your account, and you will not be able to obtain any data through your account, including the Donuts and royalties under your account.

  2. You clearly understand and agree that the purchase of Donuts is a deliberate conduct, and Creato is not obliged to refund any money for the reasons provided by you unless otherwise required by the law. If you cancel an order at the app store after purchasing the Donuts, we will take back the Donuts that are already used by you, as well as any effect associated with the use of Donuts (including but not limited to sharing royalties, level, experience, or ranking).

  3. You understand and agree that any event Donuts acquired (such as Donuts giveaways) cannot be redeemed for cash unless specified in these Terms of Use (such as the royalty sharing mechanism).

  4. Creato strictly prohibits any user from acquiring cash from another user under any circumstances, and from conducting cash transactions , or selling Donuts or being an agent of sales of Donuts , or selling or lending accounts in private. In case of any violation of the foregoing, Creato may deactivate or delete your account, and you will not be able to obtain any data through your account, including the Donuts and royalties under your account.

  5. You agree that we will only implement necessary modifications and adjustments for any error of the Donut balance in your account due to the maintenance or other technical failure of our Services and the Platforms.

  6. You understand and agree that all free Donuts earned on the Platforms are valid for one year.

Mechanism of Sharing Royalties (Profit-sharing Mechanism)

  1. Based on the contribution of your account (the popularity of your DareMe), you will be entitled to certain royalties. You can receive the royalties only when the accumulated royalties in your account have reached US$100. You have to enter the receiving account information to obtain your royalties. We only pay you when we have receive an instruction from you.

  2. If you materially violate the Community Guidelines of Creato, we will deactivate or delete your account, and you will not be able to obtain any data through your account, including the Donuts and royalties under your account.

  3. Creato may determine the royalty calculation method at its decision. We reserve the right to modify the royalty calculation method at any time without additional notice. If you log in and use Creato’s services, it will be deemed that you have agreed upon and accepted our full right for calculating and paying royalties.

  4. If you cancel the order at the app store after purchasing the Donuts, we will take back the royalties associated with those Donuts given by you. If we find that you have frequently cancelled orders, we will deactivate or delete your account, and you will not be able to obtain any data through your account, including the Donuts and royalties under your account.


Limitation or Termination of the Services

These Terms of Use shall remain in full force and effect while you use the Platforms or the Services. Creato may terminate or suspend your access to the Services or your Account at any time, for any reason, and without notice, which may result in the forfeiture and destruction of all information associated with your Account.

Creato may also terminate or suspend any and all Services and access to the Platforms immediately, without prior notice or liability, if you breach any of the terms or conditions of this Terms of Use. If we determine that you have clearly, seriously or repeatedly breached our Terms of Use or any additional terms and conditions or policies as referred herein, we may suspend or permanently disable access to your Account. We may also suspend or disable your Account if you repeatedly infringe other people’s intellectual property rights or where we are required to do so for legal reasons.

In the event that Creato limits or terminates the use of the Services, you agree that Creato reserves the right, at any time, to take such action as it considers appropriate, desirable or necessary including but not limited to taking legal actions against you. Creato shall have no obligation to deliver any of Your Content to you at any time, both before or after cessation of the Services or upon removal of Your Content from the Platforms.

Force Majeure

Creato shall be excused from performance under these Terms of Use, to the extent it is prevented or delayed from performing, in whole or in part, as a result of an event or series of events caused by or resulting from: (i) weather conditions or other elements of nature or acts of God; (ii) acts of war, acts of terrorism, insurrection, riots, civil disorders, or rebellion; (iii) quarantines or embargoes; (iv) labour strikes; (v) error or disruption to major computer hardware or networks or software failures; or (vi) other causes beyond the reasonable control of Creato.

Disclaimer of warranties

You acknowledge and agree that (i) Creato shall not be responsible in any way for any direct or indirect damage or loss that may arise or result from the use of the Platform, for whatever reason made and that (ii) Creato shall not be liable for any default of obligations or duties directly or indirectly caused by or resulted from any causes beyond the Creato’s reasonable control, including but not limited to Internet failure or any system default.

As permitted by applicable law, you expressly agree that use of the Platform is at your sole risk. Neither Creato or its subsidiaries or affiliates or any of its respective employees, agents, merchants, third-party content providers or licensors or any of their officers, directors, employees or agents, warrant that the use of the Platform will be uninterrupted, secure, virus-free, or error free, nor do they make any warranty as to (a) the results that may be obtained from use of the Platform, or (b) the accuracy, completeness, or reliability of (i) the user contents on the Platform, including, without limitation, offerings, products, or other available programs, (ii) descriptions of offerings, products, or other available programs, or (iii) user contents provided through the platform. The platform and all content, user contents and other information contained on the Platform, offerings, products and other available programs accessible or available through the Platform, are made accessible or available on an “as is” and “as available” basis. To the extent allowed by applicable law, Creato hereby disclaims any and all representations, warranties, and conditions, whether express, implied, or statutory, as to the operation of the Platform or the user contents or other information contained on the Platform or the offerings, products, or other available programs accessible or available through the Platform, including, without limitation, those of title, non-infringement, non-interference, merchantability, suitability, and fitness for a particular purpose, as well as warranties implied from a course of performance or course of dealing.

Limitation of Liability

As permitted by applicable law, in no event shall Creato or its subsidiaries or affiliates or any of its respective employees, officers, directors, agents, merchants, partners, third-party content providers or licensors, or any of their officers, directors, employees, or agents, be liable for any direct or indirect lost profits or lost business damages, indirect, incidental, special, consequential, or punitive damages arising out of, related to, or in connection with any of the following: (a) your use of the Platform, Your Content, including, without limitation, any personal information, and any other information either contained in the platform or submitted by you to the platform; (b) your inability to use the Platform; (c) modification or removal of Your Content or user content posted, uploaded or shared on the Platform; (d) these Terms of Use; or (e) any improper use of information you provide to the platform, including, without limitation, any personal information. The aggregate liability of Creato to you for all claims and expenses arising from your use of the Services and/or the Platform shall be limited to the amount of HK$100.

The liability limitations in this clause are not intended to limit any express representations or warranties by Creato that are included in other applicable terms, nor are they intended to limit remedies you might have for product-related injury.


You agree to indemnify, and hold harmless Creato, its subsidiaries, its affiliates, its officers, directors, employees, agents, partners, representatives, shareholders, servants, attorneys, predecessors, successors and assigns from and against any claims, actions, demands, liabilities, losses, damages, costs and expenses (including legal fees and litigation expenses on a full indemnity basis) made against Creato by any third party due to or arising out of or in connection with your use of the Platform and its Services.


When you use the Platform or send emails to Creato, you are communicating with Creato electronically and consent to receive electronic communications related to your use of the Platform. We will communicate with you by email or by posting notices on the Platform. You agree that all agreements, notices, disclosures, and other communications that are provided to you electronically satisfy any legal requirement that such communications be in writing. Notices from Creato will be considered delivered to you and effective when sent to the email address you provide on the Platform or from which you otherwise email Creato.

The provisions of the Terms of Use shall be enforceable independently of each other and the validity of each provision shall not be affected if any of the others is invalid. In the event any provision of the Terms of Use is determined to be illegal, invalid or unenforceable, the validity and enforceability of the remaining provisions of the Terms of Use shall not be affected and, in lieu of such illegal, invalid, or unenforceable provision, there shall be added as part of the Terms of Use one or more provisions as similar in terms as may be legal, valid and enforceable under the applicable law.

If there is any conflict among (i) these Terms of Use, (ii) specific policies, terms and conditions appearing on the Platforms, (iii) Privacy Policy, (vi) user guidelines and/or (v) any specific terms and conditions of use in respect of any special events hosted by Creato, the latest shall prevail over other documents and then the following descending order of procedure shall apply:- (i) Privacy Policy; (ii) the specific policies, terms and conditions appearing on the Platform and (iii) the Terms of Use, subject always to the express contrary provisions (if any) contained in the aforesaid documents.

The Terms of Use and any dispute or matter arising from or incidental to the use of the Platform shall be governed by and construed in accordance with the laws of Hong Kong, unless otherwise specified.

Any dispute, controversy, difference or claim arising out of or relating to this Terms of Use, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The law of this arbitration clause shall be Hong Kong law. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be one. The arbitration proceedings shall be conducted in English.

In the event of any breach of the Terms of Use by any one party, the other party shall be entitled to remedies in law and equity as determined by arbitration.

Except as expressly set forth herein, no person other than the parties to these Terms of Use shall have any right to enforce any term hereof.

Should there be any inconsistency between the English version and any version in other language, the English version shall always prevail.

Creato is a digital application for consumers (“Web / App”) and it belongs to ESSAA Limited and/or its subsidiary (ies) and/or affiliate(s), registered and based in Hong Kong (“Creato”, “we”, “us” or “our”). (Our website located at and the Web and App, are referred to collectively in this Privacy Policy (“Policy”) as the “Services”).

This Policy explains how we collect, process, use, store, protect and disclose your information when you use our Services and the services offered by third party operators (“Operators”), and with whom we share it. This Policy applies to all the Services that display or link to this document. This Policy also comes with our Terms of Use.

Before using the Services or submitting any Personal Data (as defined below) to Creato, please review this Policy carefully and contact us at if you have any questions.  By using the Services, you agree to the practices described in the Policy. If you do not agree to the Policy, please do not access or use the Services.


Scope of Terms

  • Creato reserves the right to update, amend or modify the terms of this Policy or any part of it without prior notice, and your continued access of the Services signifies your acceptance of the updated, amended or modified Policy, unless the changes reduce your rights in which case we will ask for your consent. If you do not agree to all the terms and conditions in this Policy and/or any subsequent updates, amendments or modifications thereto, you must stop accessing or otherwise using the Services.

  • Accordingly, please visit this page if you wish to access and view the current version of the Policy.


Collection of Your Personal Data

We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:

  • Information you provide: We collect the content, communications and other information you provide when you use our Services, including when you download the App and create an account (“Account“), we may collect information that alone or in combination with other information in our possession to identify you (“Personal Information“), including but not limited to: name, email address, gender, date of birth, username, photographs, location, language and any other login Information. We use your contact information to authenticate your account and keep it secure and to communicate with you about the Services.

  • Automatic information: We automatically collect certain information about your computer or mobile device hardware and software. This information can include your IP address, mobile device type and model, browser type, device ID, device hardware settings, information about your internet browser and operating system, details of web pages and pages within the Services, domain names, access times, and other information about your physical location, and information derived from web page histories, add-ons, cookies, and other technological sources.

  • Usage: we may choose to collect information about how you use our Services, such as the types of content you view or engage with, content you share, features you use, actions you take, people or accounts you interact with, the time, frequency, and duration of your use, pages of the Web / App you have viewed and hyperlinks you have clicked.

  • Geolocation data: When you use the Web / App on a mobile phone or other portable device, we may collect information concerning your location, provided the privacy settings on your portable device allow sharing of such location information with the Web / App, this includes shared information uploaded by you or others showing your current or previous location. We use your location information to show you interesting locations near you and to present you with relevant offerings from third-party suppliers, based on your location. You can change the privacy settings on your device or disable the location services in the Web / App at any time.

  • You can also use the Services to connect to ‘Google Maps’ to receive navigation services between your destinations. Your use of the ‘Google Maps’ service is subject to ‘Google Maps’ terms and conditions and privacy policies and is not covered by this Policy.

  • Demographic information: We may also collect demographic information, such as preferences, language, region and currency.

  • Information that is searched for or browsed when you use our Services, such as web pages used or terms searched and pages visited through the Web / App, as well as other information browsed or provided when using our Services.

  • Communication Data: We may choose to collect information when you contact us with questions or concerns and when you voluntarily respond to requests for your opinion and feedback.

  • Social Media Data: We have pages on social media sites including but not limited to, Instagram, Facebook, Medium, Twitter, MeWe, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.


Internet Activity Data: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g.,, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation patterns. In particular, the following information is created and automatically logged in our systems:

  • Log Data: Information that your browser automatically sends whenever you visit the Site. Log Data includes your Internet Protocol address, browser type and settings, operating system, the date and time of your request, how you interacted with the Site, and how you interacted with mobile or email notifications.

  • Cookies Data: Please see the “Cookies” section below to learn more about how we use cookies.

  • Device Data: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.

  • Usage Data: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.

  • Location Data: We derive a rough estimate of your location from your IP address.

  • Email Open/Click Data: We may use pixels in email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.

Personal Data Collected from Third Parties/Publicly Available Sources:

  • When you create your account, and/or authenticate with a third-party service like Facebook or Google, we may collect and store information associated with that third-party account, such as your username and email address. We will never publish something through one of your third-party accounts without your express permission.

  • Derived Data: We may infer your preferences for content and features of the Service, or future products and services, based on the Personal Data we collect about you.

  • Cookies: We may use cookies to operate and administer our website, gather usage data on our website, and improve your experience on it. “Cookies” are small text files containing a string of characters that can be placed on your computer or mobile device that uniquely identifies your browser or device. Cookies can be stored on your computer or mobile device for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer or mobile device when you open your browser and browse the Internet again (persistent cookies).

  • Cookies and other technologies allow a site or services to know if your computer or device has visited it before. These technologies can then be used to deliver products, services, and ads, help us understand how the site or service is being used, help you navigate between pages efficiently, help remember your preferences, and generally improve your experience in using our services. If you limit the ability of websites to set cookies, you may be unable to access certain parts of the website and you may not be able to benefit from the full functionality of the website.

  • If you access the website on your mobile device, you may not be able to control tracking technologies through the settings.

  • Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the website and enhance your experience when you use the website. For more information on how Google uses this data, go to

  • Online Tracking and Do Not Track Signals: We and our third party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the website and use that information to send targeted advertisements. We make reasonable commercial efforts to recognize and support “Do Not Track” signals.

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put addresses, phone numbers, credit card details, national identity numbers, and other sensitive information on your profile which is open to abuse and misuse. Please keep in mind that if you directly disclose personal data or sensitive personal data through the system or the messaging function, this information may be collected and used by others, please use it at your own risk.

How We Use Personal Data

We may use Personal Data for the following purposes:

  • To provide the Service;

  • To verify your identity;

  • To create your account, facilitate network connections, recommend content, operate, protect, improve, optimize and further personalize the Service for users;

  • To respond to your inquiries, comments, feedback, or questions;

  • To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;

  • To compile aggregate statistics about you and to analyse the Services usage;

  • To send you direct marketing if you have consented to it;

  • To analyze how you interact with our Service;

  • To maintain and improve the Service and marketing;

  • To develop new products and services;

  • To authenticate your account and keep it secure;

  • To enforce our Terms of Use;

  • To prevent spam, fraud, abuse, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and

  • To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behaviour and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Policy.

Disclosure of Information

We may from time to time share and disclose your Personal Data and other data to third parties, some of whom may be located outside your home country. The circumstances under which such sharing and disclosure will take place may include without limitation, the following:

  • If you are a visitor, to the relevant Operator in connection with a Services which you have made reservations, rentals, and/or bookings for or intend to make reservations, rentals, and/or bookings for.

  • If you are an Operator, to any visitor in connection with the Services you are offering.

  • To our third party service providers (including Google Analytics), which we engage amongst others for the performance of certain services on our behalf, such as web hosting services, data analysis, marketing, market research, and to otherwise provide you with customer service.

  • If and to the extent required by any applicable law, order of court or requests by any governmental authority to make such disclosure.

  • Within the Creato group of companies (if any). In case of a corporate transaction, in connection with the sale, merger, acquisition, or other corporate reorganization or restructuring of our corporation, your Personal Information may be disclosed, shared or transferred to the new controlling entity or its authorised third party for carrying on our business.

  • To our advisors, agencies or other parties concerned in order to protect the rights and property of Creato.

  • In any other case, to any third parties with your prior written consent (and in which case we will make it possible for you to withdraw your consent as easily as it was to provide consent).

We do not sell, rent, or lease our customer lists to third parties. In order to help provide our services, we occasionally provide information to other companies that work on our behalf. We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

We may share aggregate or anonymous information with relevant third parties, including our advertisers, some of whom maybe located outside your home country. Such information does not contain any Personal Information and will not identify you personally. However, in some occasions, these third parties may possess information about you or obtain your information from other sources. When they combine such information with our aggregate information, they may be able to identify you personally.

There may be links present on Creato which could result in you leaving Creato and/or being taken to other third party websites. You should note that any Personal Information that you provide to these third party websites are not subject to this Policy, and Creato is not liable for any losses, damages, costs or expenses which you may suffer or incur in connection with you providing or making available Personal Information or other data to such third party websites.

Additional Information

If you contact our customer service team via our website or mobile application, we will receive your email address and may track your IP address, as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you) for 7 years after the deletion of your account.

We will retain your personal data for the period necessary to fulfil the purposes outlined in this Policy and other legitimate business purposes unless we are otherwise required by law to dispose of your personal data. If you close your account, we will retain certain data for analytical purposes and recordkeeping purposes, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our System or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties as described in this Policy, retention of that information will be subject to those third parties’ policies.

To prevent abuse of the mobile application and/or website, Creato may block accounts as part of its moderation procedures. In order to do this, we check accounts and messages for content that indicates breaches of our Terms of Use. If an account or message meets certain criteria that demonstrate that the Terms of Use are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact Creato to contest the decision.

Data Storage

By using our Services, you acknowledge that Creato is operating through servers located in a number of countries around the world, including the United States. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.

We keep Personal Data for as long as reasonably necessary for the purposes described in this Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.

Direct Marketing

This is when we use your data to send you details about our updates or related products, services and offers provided by us or our co-branding, rewards or loyalty programme partners or any services provided by our business partners.

We may use data such as your demographics, the products and services that you’re interested in, transaction behaviour, portfolio information, location data, social media data, analytics and information from third parties when we market to you.

We don’t give your personal data to others for them to market their products and services to you. If we ever wanted to do this, we’d get your separate consent.

Your Rights and Choices

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data. You may also delete your account. Please note that we will need to verify that you have the authority to delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Policy.

You can stop the delivery of promotional emails from Creato by following the instructions in the email you receive.

We cannot be responsible for the privacy practices of any websites or pages not under our control and we do not endorse any third-party websites or pages, the services or Services described or offered on such sites or pages, or any of the content contained on those sites or pages.

Display of your data and information

Creato is designed to let our users meet and interact with each other. You also understand that your profile on Creato and other information you make available via the Web / App may be viewed and shared by other Creato’s users with individuals who may or may not be Users. For example, you might share information like the photos and messages you send or upload and any metadata provided with those messages, along with any comments or information you provide in connection with your photos.

When using Creato, you should assume that anything you post or submit on the Web / App may be publicly-viewable and accessible, both by users of our Services and non-users of our Services. We want our users to be careful about posting information that will eventually be made public.

When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the Web / App. For up to 30 days it is still possible to restore your Account if it was accidentally or wrongfully deactivated. After 30 days, we begin the process of deleting your Account from our systems. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.

To prevent abuse and/or misuse of Creato by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that the User does not open a new Account and profile in breach of our Terms of Use and to ensure compliance with all laws and regulations.

Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third-party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.

Third Party Accounts If you have registered with Creato using a third-party social media platform, such as Instagram, YouTube or Facebook (“Social Media Account”), your Creato’s profile will be available to all users of Creato whether via our Web / App or our partners’ websites. Remember that when you register with a third party, you are also giving them personal information, so we recommend that you read their privacy policies as Creato does not control how they use their information.

If you have created a Creato’s profile through a third party website and you do not want to link your Creato’s profile to your profile on the third party website, We cannot amend these settings. Please visit the application settings on your third party website profile and follow the instructions to remove the access permissions.

We only use the APIs, OAuth Tokens, Widgets, or other means provided by the applicable Social Media Account to integrate your Social Media Account with our Web / App. As such, we only receive the limited information that each Social Media Account permits to be transferred.

Security of your Personal data

Creato secures your personal data, from loss, unauthorized access, misuse or disclosure. Creato secures such personal data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, misuse or disclosure. Nevertheless, no security system is impenetrable. We cannot guarantee that information that users of the System may happen to transmit or otherwise supply will be totally secure.


Promotions, Advertisements & Researches

We may send you emails or other communications and third-party advertisements with promotional offers if you are opt-in to receiving such communications or advertisements. If you would no longer like to receive special promotion information, advertisements, or other messages from us or third party advertisers, please email at, follow the “Unsubscribe” instructions on such messages, or update your settings and preferences on the System. Please allow us a reasonable period of time in order to satisfy your request, as some advertising campaigns or promotions may already be in process at the time you request to no longer be sent such advertisements or promotions. Please note that after opting out, you may still receive non-marketing and non-promotional messages, including but not limited to product updates and service notices as permitted under applicable local laws and regulations.

From time to time we may run surveys for research purposes and we may contact you to find out if you would like to take part. We may also contact you to find out if you would like to take part in marketing campaigns. Such surveys and marketing campaigns are optional and more information will be provided at the point of contact. We may also contact you for feedback purposes. If you do not wish to be contacted to take part in a survey or marketing campaign, please contact our Customer Support Team via mobile application or website.

We use your personal data to resolve disputes, troubleshoot problems, and enforce our Terms of Use.

Changes to this Policy

We may change this Policy at any time and from time to time. The most recent version of the Policy is reflected by the version date located at the bottom of this Policy. If we make any material changes to our Policy, those changes will apply to the personal data collected after the effective date listed on the Policy, and we will notify you by placing a notice on the System prior to the change becoming effective. We encourage all users to periodically review this Policy for the latest information on our privacy practices.

Effective date

This Policy was last updated on 1 Feb 2022.

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