Privacy Policy

Last Updated: [DATE]

[COMPANY_NAME] ("Creedo," "we," "us," or "our") operates the Creedo platform available at creedo.club (the "Service"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

By using Creedo, you agree to the collection and use of information in accordance with this policy.

1. Information We Collect

1.1 Information You Provide

  • Account Information: Email address, username, password, and profile details you provide during registration.
  • Identity Verification (KYC): When you request your first withdrawal, we collect identity documents (government-issued ID) and a selfie for liveness verification through our third-party KYC provider ([Sumsub/Onfido/Veriff]).
  • Payment Information: Your selected payout method details (PayPal email, mailing address for Visa prepaid cards, etc.). We do not store full payment credentials; payouts are processed through Tremendous, our payment partner.
  • Communications: Any messages, feedback, or support requests you send to us.

1.2 Information Collected Automatically

  • Device Information: Device type, operating system, browser type, device identifiers, and device fingerprint data used for fraud prevention.
  • Usage Data: Pages visited, offers viewed, offers completed, time spent on the platform, click patterns, and feature interactions.
  • IP Address and Location: Your IP address, approximate geographic location, and information about whether you are using a VPN or proxy service.
  • Cookies and Tracking Technologies: We use cookies, pixels, and similar technologies to maintain your session, remember preferences, and analyze platform usage. See our Cookie Policy section below.

1.3 Information from Third Parties

  • Offer Completion Data: When you complete an offer (e.g., install a game, reach a milestone), our advertising partners send us confirmation ("postback") that you completed the required action. This data includes offer identifiers, completion status, and reward amounts.
  • Fraud Prevention Data: We may receive risk scores and fraud signals from third-party fraud prevention services.

2. How We Use Your Information

We use the information we collect to:

  • Provide the Service: Create and manage your account, process offer completions, calculate and credit rewards, process withdrawals.
  • Personalize Your Experience: Our AI matching engine analyzes your activity patterns, preferences, and completion history to rank and recommend offers personalized to you.
  • Prevent Fraud: Detect and prevent fraudulent activity, multi-accounting, and abuse of our platform using device fingerprinting, behavioral analysis, IP intelligence, and identity verification.
  • Improve the Platform: Analyze usage trends, conduct A/B testing, optimize offer matching algorithms, and improve features.
  • Communicate with You: Send transactional notifications (offer credits, withdrawal updates), product updates, and promotional messages. You can opt out of promotional messages at any time.
  • Comply with Legal Obligations: Respond to legal requests, enforce our Terms of Service, and comply with applicable laws.

3. How We Share Your Information

We do not sell your personal information. We share information only in these circumstances:

  • Payment Processors: We share necessary information with Tremendous to process your withdrawals (PayPal, Visa prepaid, Amazon gift cards).
  • KYC Providers: Identity documents and selfie data are shared with our verification provider solely for identity verification purposes.
  • Advertising Partners: We share anonymized or aggregated offer completion data with advertising partners. We do not share your personal identity with advertisers.
  • Fraud Prevention Services: We share device and behavioral data with fraud prevention partners to protect the platform.
  • Analytics Providers: We use PostHog for product analytics. Data shared with analytics providers is used solely to improve the Service.
  • Legal Requirements: We may disclose information if required by law, regulation, legal process, or governmental request.
  • Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

4. Data Retention

  • Account Data: Retained for as long as your account is active, plus [90 days / 1 year] after account deletion for fraud prevention and legal compliance.
  • KYC Documents: Retained for [5 years] after verification, as required by applicable anti-money-laundering regulations.
  • Usage and Analytics Data: Retained in anonymized/aggregated form indefinitely for platform improvement.
  • Support Communications: Retained for [2 years] after resolution.

5. Your Rights and Choices

Depending on your jurisdiction, you may have the following rights:

  • Access: Request a copy of the personal information we hold about you.
  • Correction: Request correction of inaccurate personal information.
  • Deletion: Request deletion of your account and personal information, subject to legal retention requirements.
  • Opt-Out of Marketing: Unsubscribe from promotional emails at any time via the link in any email or through your account settings.
  • Data Portability: Request your data in a machine-readable format.
  • Do Not Track: We honor Do Not Track browser signals where technically feasible.

For California Residents (CCPA): You have the right to know what personal information we collect, request deletion, and opt out of the sale of personal information (we do not sell personal information). To exercise these rights, contact us at [DPO_EMAIL].

For EU/EEA Residents (GDPR): Our legal basis for processing your data includes: performance of our contract with you (providing the Service), legitimate interests (fraud prevention, platform improvement), and your consent (marketing communications). You have the right to lodge a complaint with your local data protection authority.

To exercise any of these rights, email us at [DPO_EMAIL].

6. Security

We implement industry-standard security measures including:

  • Encryption of data in transit (TLS/SSL) and at rest.
  • Secure authentication and session management.
  • Regular security assessments.
  • Access controls limiting employee access to personal data.

No system is 100% secure. If you believe your account has been compromised, contact us immediately at [SUPPORT_EMAIL].

7. Children's Privacy

Creedo is not intended for users under the age of 18. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from a user under 18, we will delete that account and associated data promptly.

8. Third-Party Links

Our Service may contain links to third-party websites or apps (e.g., game offers). We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any personal information.

9. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the "Last Updated" date. Continued use of the Service after changes constitutes acceptance of the updated policy.

10. Contact Us

If you have questions about this Privacy Policy or want to exercise your data rights:

  • Email: [DPO_EMAIL]
  • Address: [COMPANY_ADDRESS]
  • Company: [COMPANY_NAME], registered in [JURISDICTION]