Last updated: 2026-07-15
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.
Creto is intended exclusively for people aged fourteen (14) or older. When you sign up we ask for your date of birth to verify this; we do not keep it. Users over 14 and under 18 may consent to the processing of their personal data under Peruvian law, and we provide information about that processing in plain language. Accounts may not be created by anyone under 14. If we reasonably detect an account belonging to someone below that age, we will restrict its processing and delete it, unless a legal obligation applies. 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 legal@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. Personal data processed through Creto is included in Del Portal Technologies S.A.C.'s personal-data filing system identified by its official Spanish name, “CLIENTES Y USUARIOS DE APLICACION - CRETO”, registered before Peru's National Personal Data Protection Registry under code No. PJ-2026-4427, together with its cross-border data flows, in accordance with Law No. 29733 and its Regulations.
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 legal@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; Brevo (sending account emails: sign-up confirmation and password recovery), located in France, European Union; and the Apple App Store and Google Play for app distribution. 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. If you choose to sign in with Google or Apple, your sign-in is verified by Google LLC or Apple Inc., both in the United States, acting as identity providers; they are involved only at that moment and never receive your group content or wishlists.
Account data and associated content are kept while the account remains active. If no activity initiated by you is recorded for twenty-four (24) consecutive months, the account and its personal data will be deleted or anonymised, unless a legal obligation requires keeping certain data for longer; we will email you before that happens. Activity means signing in, creating or editing a group, or any equivalent action you take: automated processes and account emails do not reset the clock. If you delete your account, we delete the associated data immediately; we retain only the minimum required by law.
| Data type | Retention period |
|---|---|
| Account and profile (email, display name) | While the account is active; deleted when you delete it, or after 24 months of inactivity |
| Groups and wishlists you create | While the account is active; deleted when you delete it, or after 24 months of inactivity |
| Draw assignments | While the group exists; deleted when you delete the account or the group |
| Diagnostics and crash reports | Up to 30 days |
| Reminders scheduled on your device | On your device only; cleared when you sign out or uninstall the app |
You can delete your account from the app (Account -> Delete account) or by writing to legal@delportaltechnologies.com; we process it within a maximum of 30 days.
You can also request deletion from the site's account and data deletion page, which covers all our applications. Delete account and data
Legal inquiries: legal@delportaltechnologies.com