Last updated: 2026-03-19
In short
These Terms govern your use of Creto, an application by Del Portal Technologies S.A.C. (Lima, Peru) for organizing Secret Santa gift exchanges. By using the app you accept these Terms; if you do not agree, do not use it.
You must be at least 14 years old to use Creto; children under 14 require parental or guardian consent, in accordance with Peruvian law. By creating an account you confirm that the information you provide is accurate.
You are responsible for keeping your credentials confidential and for activity under your account. The content you enter (display name, group name, and wishlist) is your responsibility and must not be unlawful, offensive, or infringe third-party rights. You can report abusive content to support@delportaltechnologies.com.
Creto is a free service: it includes no in-app purchases, subscriptions, or advertising. We grant you a personal, limited, non-exclusive, and non-transferable license to use the app. The trademark, software, and content of Del Portal Technologies S.A.C. are protected; you retain ownership of the content you enter.
The app is provided "as is" and "as available". To the maximum extent permitted by law, we do not warrant that it will be uninterrupted or error-free, and we are not liable for indirect or consequential damages arising from its use. None of this limits the non-waivable rights that Peruvian law grants to consumers.
We may modify the app or these Terms; material changes will be communicated in the app. You may stop using Creto and delete your account at any time. These Terms are governed by the laws of the Republic of Peru and submitted to the courts of the Lima Judicial District.
Del Portal Technologies S.A.C. processes your personal data in accordance with Peru's Law No. 29733 (Personal Data Protection) and its regulations. This section explains what data Creto collects, why, and what rights you have.
We use your data to operate the app (create and manage groups, run the draw, and store your wishlist), authenticate your account, provide support, prevent fraud and abuse, and keep the app stable through diagnostics. The draw assignment (who gives to whom) is stored on our server with access controls that prevent others from seeing it: each participant only sees their own assignment, and not even the organizer can see the full map. We do not sell your data or use it for advertising.
Under Law No. 29733, you have the right to access, rectify, cancel, and object to the processing of your data, as well as to data portability and to withdraw your consent. You can exercise these rights by writing to privacy@delportaltechnologies.com.
We share data only with providers that process it on our behalf, under confidentiality obligations: Supabase (database and authentication) and Sentry (crash reporting), both located in the United States; and the Apple App Store and Google Play for app distribution and, when enabled, push notifications. These international transfers are carried out with the safeguards required by Law No. 29733, such as model contractual clauses. We do not sell data to third parties.
We keep your data while your account is active. When you delete your account, we delete the associated data; we retain only the minimum required by law for security or compliance.
| Data type | Retention period |
|---|---|
| Account and profile (email, display name) | While the account is active; deleted when you delete the account |
| Groups and wishlists you create | While the account is active; deleted when you delete the account |
| Draw assignments | While the group exists; deleted when you delete the account or the group |
| Diagnostics and crash reports | Up to 90 days |
| Push notification token | Until you disable notifications or delete your account |
You can delete your account from the app (Account -> Delete account) or by writing to privacy@delportaltechnologies.com; we process it within a maximum of 30 days.
Legal inquiries: legal@delportaltechnologies.com