We’re so happy to have you here. These Terms of Service (“Terms”) govern your use of Creato and the software,
content, and services (collectively, “Services”) offered by Creato.
For better service delivery, please read these terms carefully before you start using the Services.
The term “device” refers to the device which is used to access the Services including but not limited to
computers, smartphones and tablets.
The term “you” refers to the user of the Services.
When you sign up for any of the Services or otherwise use or access them, you agree to be bound by these Terms
and all applicable laws, rules, and regulations. By using the Services, you indicate that you accept these Terms
and that you agree to abide by them. If you do not agree to these Terms, please refrain from using the services.
We reserve the right to modify or discontinue, temporarily or permanently, the Services (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 any the Services.
We may suspend or terminate your use of the Services due to fraud or breach of any of your obligations under
these Terms. Such termination or suspension may be effected immediately and without notice. For users violating
these Terms, Creato reserves the right to:
Suspend partial account functions or permanently terminate services;
Revoke all or part of the User Balance (if applicable) and restrict withdrawals;
Refer criminal activities to law enforcement agencies.
You acknowledge that we 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 our 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 we reserve the right to terminate accounts that are inactive for an extended period of time. You further acknowledge that we reserve the right to change these general practices and limits at any time, in its sole discretion, with or without notice.
You are solely responsible for all code, video, images, information, data, text, software, music, sound, photographs, graphics, messages or other materials (“content”) that you upload, post, publish or display (hereinafter, “upload”) or email or otherwise use via the Services. The following are examples of the kind of content and/or use that is illegal or prohibited by Creato. We reserve the right to investigate and take appropriate legal action against anyone who, in our sole discretion, violates this provision, including without limitation, removing the offending content from the Services, suspending or terminating the account of such violators and reporting you to the law enforcement authorities. You agree to not use the Services to:
a. Email or otherwise upload any content that
(i) infringes any intellectual property or other proprietary rights of any party;
(ii) you do not have a right to upload under any law or under contractual or fiduciary relationships;
(iii) contains software viruses or any other computer code, files or programs designed to interrupt, destroy or
limit the functionality of any computer software or hardware or telecommunications equipment.
(iv) poses or creates a privacy or security risk to any person;
(v) constitutes unsolicited or unauthorized advertising, promotional materials, commercial activities and/or
sales, “junk mail,” “spam,” “chain letters,” “pyramid schemes,” “contests,” “sweepstakes,” or any other form of
solicitation;
(vi) is unlawful, harmful, threatening, abusive, harassing, tortious, excessively violent, defamatory, vulgar,
obscene, pornographic, libelous, invasive of another’s privacy, hateful racially, ethnically or otherwise
objectionable;
(vii) in the sole judgment of Creato, is objectionable or which restricts or inhibits any other person from
using or enjoying the Services, or which may expose Creato or its users to any harm or liability of any type;
(viii) involves selling, renting, sharing, or transferring your Creato account or content obtained via Creato to
any third party; or downloading content without an explicitly displayed “download” button;
(ix) contains hate speech—defined as content intended to vilify, humiliate, or incite hatred or fear against a
group based on race, ethnicity, national origin, religion, gender identity or expression, sexual orientation,
age, disability, or similar characteristics (excluding self-referential or empowering uses);
(x) features, involves, or promotes:
Exploitation or abuse of individuals under 18, or suggestions of underage participation in sexual activities;
Firearms, weapons, or goods subject to legal prohibitions/restrictions;
Drugs, drug paraphernalia, or encouragement of self-harm/suicide;
“Revenge porn” (sexually explicit content without the subject’s explicit written consent for recording and
sharing);
Public nudity or sexual activities recorded in jurisdictions where such acts are illegal, or in public places
where members of the public could reasonably witness them (excluding private property with no public presence);
(xi) shares others’ personal data without explicit written consent, including but not limited to names, identity
documents, contact details, GPS data, banking/medical records, email addresses, home addresses, or privately
scraped data;
(xii) is misleading, artificially inflates engagement metrics, or conceals AI-generated/synthetic origins
(including “deepfakes”)—AI-generated content must be disclosed as “AI-generated” per Creato’s Community
Guidelines;
b. Interfere with or disrupt the Services or servers or networks connected to the Services, or disobey any
requirements, procedures, policies or regulations of networks connected to the Services;
c. Violate any applicable local, state, national or international law, or any regulations having the force of
law;
d. Impersonate any person or entity, or falsely state or otherwise misrepresent your affiliation with a person
or entity;
e. Solicit personal information from anyone under the age of 18;
f. Harvest or collect email addresses or other contact information of other users from the Services by
electronic or other means for the purposes of sending unsolicited emails or other unsolicited communications;
g. Advertise or offer to sell or buy any goods or services for any business purpose that is not specifically
authorized;
h. Further or promote any criminal activity or enterprise or provide instructional information about illegal
activities;
i. Obtain or attempt to access or otherwise obtain any materials or information through any means not
intentionally made available or provided for through the Services;
j. Circumvent security measures, including using proxies/VPNs to disguise location for payment fraud, bypassing
regional restrictions, or evading safety controls; using ad-blocking software; accessing via automated programs
(e.g., crawlers, robots); sending excessive requests beyond human capacity; introducing malware;
reverse-engineering Creato’s source code (except as legally permitted); or exploiting system vulnerabilities.
The Service is for your personal use only. Unless otherwise expressly authorized herein or in the Services, you agree not to display, distribute, license, perform, publish, reproduce, duplicate, copy, create derivative works from, modify, sell, resell, exploit, transfer or upload for any commercial purposes, any portion of the Services, use of the Services, or access to the Services. You shall not engage in third-party commercial activities (including but not limited to advertising, sponsorships, or product placements) via Creato without prior written authorization from Creato, unless expressly permitted under Creato’s separate Creator Advertising & Promotion Policy.
If you are under 13, you are not authorized to use the Services, with or without registering. Users under the age of 18, and individuals required by law to register as sex offenders, are prohibited from using Creato services.
Some of our Services are available via a mobile device, including
(i) the ability to upload content to the Services via a mobile device,
(ii) the ability to browse the Services and the Website from a mobile device
(iii) the ability to access certain features through an application downloaded and installed on a mobile device
(collectively, the “Mobile Services”). To the extent you access the Services through a mobile device, your
wireless service carrier’s standard charges, data rates, and other fees may apply.
In addition, downloading, installing, or using certain Mobile Services may be prohibited or restricted by your
carrier, and not all Mobile Services may work with all carriers or devices. By using the Mobile Services, you
agree that we may communicate with you regarding Creato and other entities by SMS, MMS, text message or other
electronic means to your mobile device and that certain information about your usage of the Mobile Services may
be communicated to us.
In the event you change or deactivate your mobile telephone number, you agree to promptly update your Creato
account information to ensure that your messages are not sent to the person that acquires your old number.
Software (defined below) available in connection with the Services and the transmission of applicable data, if any, is subject to United States export controls. No Software may be downloaded from the Services or otherwise exported or re-exported in violation of U.S. export laws. Downloading or using the Software is at your sole risk. Recognizing the global nature of the Internet, you agree to comply with all local rules and laws regarding your use of the Service, including as it concerns online conduct and acceptable content.
AI-generated content via Creato (including virtual dialogues, images, text, etc.) must comply with the
following:
It shall not be used for illegal, fraudulent, or rights-infringing purposes;
If used for public distribution or commercial scenarios, it must be clearly labeled as “Generated by Creato AI”
in a prominent manner, and shall not mislead others into believing it is human-created;
It shall not be used to falsify others’ images or statements (especially sexually explicit content), or for
defamation or harassment.
You acknowledge and agree that the Services may contain content or features (“Service Content”) that are
protected by copyright, patent, trademark, trade secret or other proprietary rights and laws. Except as
expressly authorized by Creato, you agree not to modify, copy, frame, scrape, rent, lease, loan, sell,
distribute or create derivative works based on the Services or the Service Content, in whole or in part, except
that the foregoing does not apply to your own User Content (as defined below) that you legally upload to the
Services. In connection with your use of the Services, you will not engage in or use any data mining, robots,
scraping or similar data gathering or extraction methods. If you are blocked by Creato from accessing the
Services (including by blocking your IP address), you agree not to implement any measures to circumvent such
blocking (e.g., by masking your IP address or using a proxy IP address). Any use of the Services or the Service
Content other than as specifically authorized herein is strictly prohibited. The technology and software
underlying the Services or distributed in connection therewith are the property of Creato, our affiliates and
our partners (the “Software”). You agree not to copy, modify, create a derivative work of, reverse engineer,
reverse assemble or otherwise attempt to discover any source code, sell, assign, sublicense, or otherwise
transfer any right in the Software. Any rights not expressly granted herein are reserved by Creato.
The Creato name and logos are trademarks and service marks of Creato (collectively the “Creato Trademarks”).
Other company, product, and service names and logos used and displayed via the Services may be trademarks or
service marks of their respective owners who may or may not endorse or be affiliated with or connected to
Creato. Nothing in these Terms of Service or the Services should be construed as granting, by implication,
estoppel, or otherwise, any license or right to use any of Creato Trademarks displayed on the Services, without
our prior written permission in each instance. All goodwill generated from the use of Creato Trademarks will
inure to our exclusive benefit.
Under no circumstances will Creato be liable in any way for any content or materials of any third parties (including users), including, but not limited to, for any errors or omissions in any content, or for any loss or damage of any kind incurred as a result of the use of any such content. You acknowledge that Creato does not pre-screen content, but that Creato and its designees will have the right (but not the obligation) in their sole discretion to refuse or remove any content that is available via the Services. Without limiting the foregoing, Creato and its designees will have the right to remove any content that violates these Terms of Service or is deemed by Creato, in its sole discretion, to be otherwise objectionable. You agree that you must evaluate, and bear all risks associated with, the use of any content, including any reliance on the accuracy, completeness, or usefulness of such content.
With respect to the content or other materials you upload through the Services or share with other users or
recipients (collectively, “User Content”), you represent and warrant that you own all right, title and interest
in and to such User Content, including, without limitation, all copyrights and rights of publicity contained
therein. By uploading any User Content you hereby grant and will grant Creato and its affiliated companies a
nonexclusive, worldwide, royalty-free, fully paid up, transferable, sublicensable, perpetual, irrevocable
license to copy, display, upload, perform, distribute, store, modify and otherwise use your User Content in
connection with the operation of the Services or the promotion, advertising or marketing thereof in any form,
medium or technology now known or later developed.
You acknowledge and agree that any questions, comments, suggestions, ideas, feedback or other information about
the Services (“Submissions”), provided by you to Creato are non-confidential and Creato will be entitled to the
unrestricted use and dissemination of these Submissions for any purpose, commercial or otherwise, without
acknowledgment or compensation to you.
You acknowledge and agree that Creato may preserve content and may also disclose content if required to do so by
law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with
legal process, applicable laws or government requests; (b) enforce these Terms of Service; (c) respond to claims
that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety
of Creato, our users and the public. You understand that the technical processing and transmission of the
Services, including your content, may involve (a) transmissions over various networks; and (b) changes to
conform and adapt to technical requirements of connecting networks or devices.
Creato respects the intellectual property of others, and we ask our users to do the same. If you believe that
your work has been copied in a way that constitutes copyright infringement, or that your intellectual property
rights have been otherwise violated, you should notify Creato of your infringement claim in accordance with the
procedure set forth below.
We will process and investigate notices of alleged infringement and will take appropriate actions under the
Digital Millennium Copyright Act (“DMCA”) and other applicable intellectual property laws with respect to any
alleged or actual infringement. A notification of claimed copyright infringement should be emailed to
rollingkwok@gmail.com.
To be effective, the notification must be in writing and contain the following information:
a. an electronic or physical signature of the person authorized to act on behalf of the owner of the copyright
or other intellectual property interest;
b. a description of the copyrighted work or other intellectual property that you claim has been infringed;
c. a description of where the material that you claim is infringing is located on the Services, with enough
detail that we may find it on the Services;
d. your address, telephone number, and email address;
e. a statement by you that you have a good faith belief that the disputed use is not authorized by the copyright
or intellectual property owner, its agent, or the law;
f. a statement by you, made under penalty of perjury, that the above information in your Notice is accurate and
that you are the copyright or intellectual property owner or authorized to act on the copyright or intellectual
property owner’s behalf.
If you believe that your User Content that was removed (or to which access was disabled) is not infringing, or
that you have the authorization from the copyright owner, the copyright owner’s agent, or pursuant to the law,
to upload and use the content in your User Content, you may send a written counter-notice containing the
following information to the Copyright Agent:
a. your physical or electronic signature;
b. identification of the content that has been removed or to which access has been disabled and the location at
which the content appeared before it was removed or disabled;
c. a statement that you have a good faith belief that the content was removed or disabled as a result of mistake
or a misidentification of the content; and
d. your name, address, telephone number, and email address, a statement that you consent to the jurisdiction of
the federal court located within Northern District of California and a statement that you will accept service of
process from the person who provided notification of the alleged infringement.
If a counter-notice is received by the Copyright Agent, Creato will send a copy of the counter-notice to the
original complaining party informing that person that it may replace the removed content or cease disabling it
in 10 business days. Unless the copyright owner files an action seeking a court order against the content
provider, member or user, the removed content may be replaced, or access to it restored, in 10 to 14 business
days or more after receipt of the counter-notice, at our sole discretion.
Repeat Infringer Policy: In accordance with the DMCA and other applicable law, Creato has adopted a policy of
terminating, in appropriate circumstances and at Creato’s sole discretion, users who are deemed to be repeat
infringers. Creato may also at its sole discretion limit access to the Services and/or terminate the memberships
of any users who infringe any intellectual property rights of others, whether or not there is any repeat
infringement.
The Services may provide, or third parties may provide, links or other access to other sites and resources on the Internet. We have no control over such sites and resources and we are not responsible for and do not endorse such sites and resources. You further acknowledge and agree that Creato will not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any content, events, goods or services available on or through any such site or resource. Any dealings you have with third parties found while using the Services are between you and the third party, and you agree that Creato is not liable for any loss or claim that you may have against any such third party.
YOUR USE OF THE SERVICE IS AT YOUR SOLE RISK. THE SERVICE IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS.
COMPANY EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED OR STATUTORY, INCLUDING, BUT
NOT LIMITED TO THE IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE AND
NON-INFRINGEMENT.
Creato MAKES NO WARRANTY THAT (I) THE SERVICE WILL MEET YOUR REQUIREMENTS, (II) THE SERVICE WILL BE
UNINTERRUPTED, TIMELY, SECURE, OR ERROR-FREE, (III) THE RESULTS THAT MAY BE OBTAINED FROM THE USE OF THE SERVICE
WILL BE ACCURATE OR RELIABLE, OR (IV) THE QUALITY OF ANY PRODUCTS, SERVICES, INFORMATION, OR OTHER MATERIAL
PURCHASED OR OBTAINED BY YOU THROUGH THE SERVICE WILL MEET YOUR EXPECTATIONS.
DUE TO THE OBJECTIVITY OF TECHNOLOGY, Creato'S SOFTWARE AND SERVICES MAY CONTAIN WORDS OR RELATED FEEDBACK THAT
WILL INEVITABLY OFFEND YOU. Creato HAS NO INTENTION OF SUBJECTIVE INFRINGEMENT.
You understand and agree that when you use Creato and related services, all virtual content displayed to you by
Creato, including but not limited to virtual agent dialogue and its elements, are mainly presented to you based
on Creato's algorithm and its own content library. The content of feedback and display belongs to Creato. If you
cannot understand the above behavior and agree to Creato, with your consent, you can pay, delete, publicize and
display the virtual characters you created, and pay and modify relevant service rules at any time. , you can
choose not to register and use related services provided by Creato.
YOU EXPRESSLY UNDERSTAND AND AGREE THAT Creato WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL,
CONSEQUENTIAL, EXEMPLARY DAMAGES, OR DAMAGES FOR LOSS OF PROFITS INCLUDING BUT NOT LIMITED TO, DAMAGES FOR LOSS
OF GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES (EVEN IF COMPANY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH
DAMAGES), WHETHER BASED ON CONTRACT, TORT, NEGLIGENCE, STRICT LIABILITY OR OTHERWISE, RESULTING FROM: (I) THE
USE OR THE INABILITY TO USE THE SERVICE; (II) THE COST OF PROCUREMENT OF SUBSTITUTE GOODS AND SERVICES RESULTING
FROM ANY GOODS, DATA, INFORMATION OR SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR TRANSACTIONS ENTERED
INTO THROUGH OR FROM THE SERVICE; (III) UNAUTHORIZED ACCESS TO OR ALTERATION OF YOUR TRANSMISSIONS OR DATA; (IV)
STATEMENTS OR CONDUCT OF ANY THIRD PARTY ON THE SERVICE; OR (V) ANY OTHER MATTER RELATING TO THE SERVICE. IN NO
EVENT WILL Creato’S TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES OR CAUSES OF ACTION EXCEED THE AMOUNT YOU
HAVE PAID COMPANY IN THE LAST SIX (6) MONTHS, OR, IF GREATER, ONE HUNDRED DOLLARS ($100).
Creato shall not be liable for disputes arising from users’ failure to disclose AI-generated content as
required. Creato shall not be liable for system damage or data leakage caused by users’ violation of technical
security clauses (e.g., using automated tools or circumventing safety measures).
SOME JURISDICTIONS DO NOT ALLOW THE DISCLAIMER OR EXCLUSION OF CERTAIN WARRANTIES OR THE LIMITATION OR EXCLUSION
OF LIABILITY FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, SOME OF THE ABOVE LIMITATIONS SET FORTH ABOVE
MAY NOT APPLY TO YOU OR BE ENFORCEABLE WITH RESPECT TO YOU. IF YOU ARE DISSATISFIED WITH ANY PORTION OF THE
SERVICES OR WITH THESE TERMS OF SERVICE, YOUR SOLE AND EXCLUSIVE REMEDY IS TO DISCONTINUE USE OF THE SERVICES.
IF YOU ARE A USER FROM NEW JERSEY, THE FOREGOING SECTIONS TITLED “DISCLAIMER OF WARRANTIES” AND “LIMITATION OF
LIABILITY” ARE INTENDED TO BE ONLY AS BROAD AS IS PERMITTED UNDER THE LAWS OF THE STATE OF NEW JERSEY. IF ANY
PORTION OF THESE SECTIONS IS HELD TO BE INVALID UNDER THE LAWS OF THE STATE OF NEW JERSEY, THE INVALIDITY OF
SUCH PORTION SHALL NOT AFFECT THE VALIDITY OF THE REMAINING PORTIONS OF THE APPLICABLE SECTIONS.
You agree that you are solely responsible for your interactions with any other user in connection with the Service and Creato will have no liability or responsibility with respect thereto. Creato reserves the right but has no obligation, to become involved in any way with disputes between you and any other user of the Service.
We may update our Terms of Service from time to time. Therefore, you are advised to check this page regularly for any changes. We will notify you of any changes by posting the new terms and conditions on this page. For material changes involving AI content standards or users’ core rights, notifications will be sent via in-app push, email, or similar methods. Continued use of the Services after such notifications constitutes acceptance of the revised Terms.
At Creato, we respect the privacy of our users. For details please see our Privacy Policy. By using the Service, you consent to our collection and use of personal data as outlined therein.
For Apple users, please read
https://www.apple.com/legal/internet-services/itunes/dev/stdeula/
If you have any questions or comments about these Terms and Conditions, please contact us at
rollingkwok@gmail.com.
This Privacy Notice for CREATO. ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We
are responsible for making decisions about how your personal information is processed. If you do not agree with
our policies and practices, please do not use our Services.
CREATO. is the data controller of your personal data for the purposes of the Platform. Our data protection
contact is: rollingkwok@gmail.com
(This summary provides key points from our Privacy Notice, but you can find out more details about any of these
topics by clicking the link following each key point or by using our table of contents below to find the section
you are looking for.)
What personal information do we process? When you visit, use, or navigate our Services, we may process personal
information depending on how you interact with us and the Services, the choices you make, and the products and
features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? Some of the information may be considered 'special' or
'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and
religious beliefs. We may process sensitive personal information when necessary with your consent or as
otherwise permitted by applicable law. Learn more about sensitive information we process.
Do we collect any information from third parties? We may collect information from third parties such as referral
information, identity verification and fraud prevention services, and advertising or analytics platforms.
How do we process your information? We process your information to provide, improve, and administer our
Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process
your information for other purposes with your consent. We process your information only when we have a valid
legal reason to do so. Learn more about how we process your information.
In what situations and with which types of parties do we share personal information? We may share information in
specific situations and with specific categories of third parties. Learn more about when and with whom we share
your personal information.
How do we keep your information safe? We have adequate organizational and technical processes and procedures in
place to protect your personal information. However, no electronic transmission over the internet or information
storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers,
cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly
collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you
have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access
request, or by contacting us at rollingkwok@gmail.com. We will
consider and act upon any request in accordance
with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
We collect and process the following categories of personal data depending on how you use the Platform:
We may combine this data to improve our services, protect users, and detect misuse.
Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we may
also process sensitive personal information such as biometric data for verification purposes.
Payment Data. We may collect data necessary to process your payment if you choose to make purchases. All payment
data is handled and stored by secure payment processors like Stripe. You may find their privacy notice link(s)
here: https://stripe.com/privacy.
Our Services are not intended for use by children under the age of 18 ("Children"). We do not knowingly collect personal data from Children. If you are under 18, you must not use our Services or provide any personal data to us. If you become aware that a Child has provided us with personal data without parental consent, please contact us immediately at rollingkwok@gmail.com. If we learn that we have collected personal data from a Child without verification of parental consent, we will take steps to delete that information from our servers.
We process your personal data for the following purposes:
| Purpose | Legal Basis |
|---|---|
| To create and manage your Account | Contractual necessity |
| To verify Creators and ensure age compliance | Legal obligation and legitimate interest |
| To process transactions and deliver Paid Services | Contractual necessity |
| To enforce Platform rules and prevent abuse | Legitimate interest and legal obligation |
| To improve and personalise your experience | Legitimate interest and/or consent |
| To respond to support or complaints | Contractual necessity or legal obligation |
| To deliver marketing (where permitted) | Consent or legitimate interest |
| To comply with laws and respond to authorities | Legal obligation |
| To generate images in response to your requests; improving AI image-generation functions using anonymized data. | To generate images in response to your requests; improving AI image-generation functions using anonymized data. |
| To securely process transactions (e.g., Stripe, PayPal) | Contractual necessity |
| Identity verification and fraud detection (e.g., Onfido, Socure) | Legal obligation and legitimate interest |
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
In Short: We may share information in specific situations described in this section and/or with the following
categories of third parties.
We only share your personal data where necessary and for legitimate purposes. This includes sharing with:
Payment processors
KYC and fraud tools
Analytics providers
Marketing platforms (only with your consent)
Customer support tools
Legal authorities, where required by law or court order
Wherever possible, we enter into data processing agreements with these providers to ensure your data is handled
securely.
The categories of third parties we may share personal information with are as follows:
Payment Processors
Data Analytics Services
Cloud Computing Services
Data Storage Service Providers
User Account Registration & Authentication Services
Government Entities (where required by law)
We also may need to share your personal information in the following situations:
Our Services may contain links to external websites or services not operated by us. We are not responsible for the content, privacy practices, or data use policies of those third parties. We recommend reviewing their privacy notices before submitting any data.
In Short: We currently do not use cookies or similar tracking technologies to collect or store your information.
While we reserve the right to use such technologies in the future to enhance user experience, improve platform
performance, or provide additional functionality, we are not currently utilizing any cookies, web beacons, or
other automated data collection methods. Should this change in the future, we will update this Privacy Notice
accordingly and provide clear information about the types of technologies used and how you can manage your
preferences.
In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar
technologies.
As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine
learning, or similar technologies (collectively, 'AI Products'). These tools are designed to enhance your
experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI
Products within our Services.
All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third parties.
In addition to the AI Products described above, some creator profiles or posts on our platform may include
content that is fully or partially generated or enhanced using artificial intelligence technologies. To ensure
transparency, we may display a notice in relevant areas of the page stating “May contain AI-generated content.”
This notice is provided solely to help you understand that certain content may include AI elements. It does not
affect your rights, your account, or how your personal data is processed. The notice is a transparency measure
and is separate from the AI Products available within our Services.
In Short: If you choose to register or log in to our Services using a social media account, we may have access
to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details.
Where you choose to do this, we will receive certain profile information about you from your social media
provider.
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Singapore. Regardless of your location, please be aware that your information may be
transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with
whom we may share your personal information, including facilities in the United States, Japan, and other
countries.
Where personal data is transferred internationally, we ensure appropriate safeguards are in place, such as:
Adequacy decisions by the relevant authorities
Standard Contractual Clauses (SCCs)
UK Addendum to SCCs (if required)
In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy
Notice unless otherwise required by law.
We retain your personal data only for as long as necessary for the purposes outlined in this Policy, including:
While you maintain an active Account
For legal, regulatory, tax, or audit purposes
For a limited period after account closure, as required by law
After this period, your data is securely deleted or anonymised.
In Short: We aim to protect your personal information through a system of organizational and technical security
measures.
We take the protection of your personal data seriously. We implement appropriate technical and organizational
measures to prevent accidental loss, unauthorized access, or misuse of personal data. These include:
Secure servers and encryption of sensitive data;
Access restrictions and confidentiality agreements for staff;
Breach detection and notification procedures, in line with legal obligations.
You are responsible for keeping your account credentials confidential and must not share them with others.
In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area
(EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and
control over your personal information.
You have the following rights under applicable data protection law:
Right to access -- Request a copy of your personal data
Right to rectification -- Correct inaccurate or incomplete data
Right to erasure -- Ask us to delete your data under certain conditions
Right to restrict processing -- Limit how we use your data
Right to data portability -- Receive your data in a structured format
Right to object -- Stop certain types of processing
Right to withdraw consent -- Where processing is based on consent
Right to lodge a complaint -- With your local data protection authority
To exercise your rights, contact rollingkwok@gmail.com.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you
also have the right to complain to your Member State data protection authority or UK data protection authority.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ('DNT') feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.
In Short: If you are a resident of California, you may have the right to request access to and receive details
about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a
copy of, or delete your personal information.
California residents may have additional rights under the CCPA/CPRA. Please see our separate section for
California residents for more details. To exercise these rights, please contact us at rollingkwok@gmail.com.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Last
updated' date at the top of this Privacy Notice.
If you have questions or comments about this notice, you may contact us by post at:
Japan StarFans Co., Ltd.
Park West Building 1001,
6-12-1 Nishi-Shinjuku, Shinjuku-ku,
Tokyo 160-0023, Japan
Or by email at: rollingkwok@gmail.com
Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please submit a request to rollingkwok@gmail.com.
Last Updated: December 2025
This policy is designed to ensure that Creato provides a secure, compliant, and creativity-friendly environment for creators. As a private-domain tool that enables creators to interact with their fans, Creato encourages the creation of original personas, media, and communication content while respecting the intellectual property rights and privacy rights of others.
Creators must ensure that any AI personas, profile information, images, videos, or other materials generated or uploaded through Creato are original or lawfully created. Content should not plagiarize, imitate, or replicate copyrighted characters, public figures, or third-party intellectual property without permission.
If a creator incorporates or references elements from copyrighted works, well-known media, or identifiable third-party assets, the creator must hold the necessary rights, licenses, or permissions required for such use.
Creators assume full responsibility for the personas, media, and communication content they generate or upload on Creato. While Creato supports creativity and expression, any form of intellectual property infringement, misappropriation, or unauthorized use of others' likeness or creative assets is strictly prohibited.
To protect creators, fans, and rights holders, the following types of content are not allowed on Creato:
Since Creato is a private-domain platform without public content discovery, complaints may be submitted by:
Upon receiving a complaint, Creato will conduct an internal review, which may include requesting additional information, evidence, or verification from the reporting party or the creator.
If infringement is confirmed, Creato may take any of the following actions:
Creato will notify the creator of the outcome unless legally prohibited.
Creato maintains the sole discretion to review, restrict, or remove any persona or content that:
Creato may act even without a formal complaint if potential violations are detected.
Creato empowers creators to express themselves by building unique AI personas, personal branding, and
private-domain content for their fan communities. We encourage originality while emphasizing respect for
existing creative works, legal obligations, and the rights of others.
By following this policy, creators contribute to a safe, respectful, and innovative ecosystem.
At Creato, we strictly prohibit all forms of Child Sexual Abuse and Exploitation (CSAE). We maintain a zero-tolerance policy and employ immediate enforcement procedures against Child Sexual Abuse Material (CSAM) on our platform.Uploading this material is considered as a serious violation of our Terms of Service.
We strictly prohibit users from engaging in the following conduct or disseminating the following content on Creato:
Upon discovery of the aforementioned conduct, Creato will take immediate action, including:
We combine automated tools and human review processes to monitor user-generated content. Suspicious or harmful content is immediately flagged, reviewed, and removed in accordance with our policy.
We encourage users to report any behavior, content, or profiles that they believe may violate our Child Safety Standards. You can submit reports via our in-app reporting system or by sending an email to rollingkwok@gmail.com. All reports are reviewed with high priority. Any detected or reported Child Sexual Abuse Material (CSAM) is immediately removed. We comply with our legal obligation to report confirmed Child Sexual Abuse Material to relevant agencies, such as the National Center for Missing & Exploited Children (NCMEC) or equivalent regional organizations.
We fully cooperate with law enforcement and child protection organizations in investigations related to child abuse incidents. We respond promptly to legal requests and share relevant information to assist investigations.
To minimize the risk of abuse, Creato employs verification checks and may impose age-based or feature-based
restrictions on accounts to help protect minors from harmful interactions. We require users, when registering as
creators, to provide a valid, government-issued identification document along with a self-portrait verification
photo to confirm identity and age information. The verification process combines an automated detection system
with human review to prevent forgery, tampering, or the use of another person's identity.
Any attempt to misrepresent age, impersonate others, or use the platform as a minor is considered a serious
violation. Upon detection, Creato will immediately take the following actions:
If you have any inquiries, reports, or concerns related to child safety, please contact us through our
designated contact. You can send an email to rollingkwok@gmail.com.
We will reply and initiate the processing procedure within 24 hours of receiving your correspondence to ensure
all matters concerning child safety receive timely and appropriate attention and response.
Last Updated: December 2025