Privacy Policy

Creato is a digital platform for consumers 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 & (Collectively, "Platform(s)"), the services Creato offers 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 Platform you have viewed and hyperlinks you have clicked.
  • Geolocation data: When you use the Platform 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 Platform, 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 Platform 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 Platform, 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 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 Platform 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 Platform 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 Platform. 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 Platform 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 Platform. 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 the 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 September 2023.