Terms & Conditions

Effective Date: 1 June 2026

Last Updated: 14 July 2026

Version: 1.2.1

These Terms & Conditions (the “Terms”) govern your access to and use of the Fraw mobile application, website, software, electronic systems, official functions, extensions, creator tools, and related services collectively referred to as the “Service.”

The Service is operated by Untitled Labs Limited (“Fraw,” “we,” “us,” or “our”), a company incorporated in Hong Kong.

By creating an account, accessing, downloading, installing, or using the Service, you agree to be bound by these Terms and any policies incorporated into them.

If you do not agree with these Terms, you must not access or use the Service.

1. Eligibility

You must be at least the age of majority applicable to you and have the legal capacity to enter into these Terms.

Where applicable law permits a person below the age of majority to use the Service only with parental or legal guardian consent, the Service may be used by that person only where:

  • the required consent has been validly obtained;
  • Fraw provides or accepts an appropriate method for obtaining or verifying that consent; and
  • the use otherwise complies with applicable law and Fraw’s eligibility requirements.

The Service may not be available to children or persons below a specified age in countries or regions where Fraw has not implemented a legally required consent, age-assurance, age-verification, or child-protection method.

By using the Service, you represent and warrant that:

  • you meet the eligibility requirements applicable to you;
  • you have the legal capacity and authority required to use the Service;
  • the information you provide is accurate, complete, and current;
  • you are not prohibited from using the Service under applicable law; and
  • your use of the Service complies with applicable laws and regulations.

We may request information reasonably necessary to assess:

  • eligibility;
  • age;
  • legal capacity;
  • parental or guardian authority;
  • identity;
  • country or region;
  • regulatory eligibility; or
  • compliance with these Terms.

We may refuse registration or restrict, suspend, or terminate access where we reasonably believe that:

  • you are not eligible to use the Service;
  • legally required consent has not been obtained or verified;
  • information provided concerning eligibility is inaccurate or misleading;
  • the Service may not lawfully be provided to you;
  • access is prohibited or restricted in your country or region; or
  • restriction is necessary to comply with applicable law, a regulatory requirement, or a lawful governmental request.

2. Account Registration and Security

To access certain features, you may be required to create an account.

Account registration may be supported through third-party authentication providers, including Apple ID or Google login, or through other methods made available by Fraw.

You agree to:

  • provide accurate, complete, and current registration information;
  • keep your login credentials secure and confidential;
  • maintain the security of devices used to access your account;
  • accept responsibility for activity occurring under your account; and
  • notify us promptly of unauthorized access, suspected compromise, or other security issues.

You must not:

  • sell, rent, transfer, sublicense, or share your account;
  • create an account using false or misleading information;
  • impersonate another person or entity;
  • create accounts through unauthorized automated methods;
  • create an account to evade a regional, regulatory, safety, or enforcement restriction; or
  • allow another person to use your account in violation of these Terms.

We may:

  • refuse account registration;
  • reclaim usernames or account identifiers;
  • request verification;
  • restrict account functionality;
  • suspend or terminate accounts;
  • require a password reset or other security action; or
  • block or limit account access from particular countries, networks, devices, or regions,

where reasonably necessary to protect the Service, prevent fraud or abuse, enforce these Terms, protect users, respond to a regulator, or comply with law.

3. Nature of the Service

Fraw is a subscription-tiered, credit-based AI creative platform and electronic service.

The Service may include:

  • official Fraw-provided functions and tools;
  • official extensions and feature experiences;
  • AI generation and transformation functions;
  • Rebuild and Blend functions;
  • private user-created extensions;
  • published user-created extensions;
  • subscription plans;
  • top-up purchases;
  • referral and promotional programs;
  • creator tools;
  • Diamonds and creator reward systems;
  • content-hosting, display, publication, discovery, and distribution functions; and
  • other features introduced by Fraw from time to time.

The Service operates through two connected systems:

  • a subscription tier system, which determines access rights, feature permissions, and eligibility for certain functions; and
  • a credit usage system, which determines usage quantity.

Subscription tier determines access. Credits determine usage quantity.

We may modify, add, remove, restrict, suspend, replace, or discontinue any part of the Service at any time, subject to applicable law.

Features, subscription plans, credits, extensions, creator functions, reward systems, payment methods, withdrawal functions, content availability, and other parts of the Service may vary by:

  • country or region;
  • device or operating system;
  • platform or app store;
  • subscription tier;
  • account status;
  • service availability;
  • local content requirements;
  • regulatory registration status;
  • licensing or notification status;
  • legal or regulatory requirements; or
  • technical and operational conditions.

Making the Service available for download or access in a country or region does not guarantee that:

  • every feature will be available there;
  • every transaction type will be supported;
  • creator publication will be available;
  • content available elsewhere will be available there;
  • Diamond earning or withdrawal will be available;
  • every payment or payout method will be supported;
  • the Service will remain available indefinitely; or
  • Fraw has established a permanent place of business, local office, local entity, or physical presence there.

We may restrict, modify, delay, suspend, block, or discontinue particular functions or the entire Service in a country or region where reasonably necessary because of:

  • legal or regulatory requirements;
  • registration, licensing, filing, notification, certification, or approval requirements;
  • local representation or contact-person requirements;
  • content-removal or access-blocking obligations;
  • tax or payment-provider requirements;
  • sanctions or trade restrictions;
  • security or safety concerns;
  • app-store or platform requirements;
  • governmental or regulatory action;
  • technical limitations;
  • operational feasibility; or
  • risk to Fraw, users, service providers, or third parties.

4. Regulatory Registrations and Regional Operation

4.1 Regulatory Status May Vary

In some countries or regions, operating or making the Service available may require Fraw to:

  • register as an electronic-system operator;
  • register as a digital-platform provider;
  • obtain a business licence or regulatory approval;
  • submit a notification or filing;
  • appoint a local representative, contact person, or responsible officer;
  • maintain local records;
  • provide regulatory reports;
  • establish procedures for lawful requests;
  • maintain a complaint or content-removal channel;
  • implement local technical, safety, or content controls; or
  • satisfy other legal or administrative requirements.

The applicability, scope, status, timing, and continuation of such requirements may be uncertain, may change, or may depend on governmental interpretation.

4.2 No Guarantee of Registration or Continued Availability

Fraw does not guarantee that:

  • it is required to register in every country where the Service is accessible;
  • a registration or licence has been or will be completed in every country;
  • an authority will accept, renew, or maintain a registration;
  • a local representative will be appointed in every country;
  • a required approval will remain effective;
  • regulatory conditions will remain commercially or technically feasible; or
  • the Service will continue to be available where a registration, licence, filing, representative, or other requirement applies.

Where Fraw determines or reasonably suspects that a registration, licence, filing, notification, local representative, regulatory approval, or related compliance step may be required, Fraw may:

  • delay market availability;
  • restrict new registrations;
  • block particular features;
  • prevent publication or public distribution;
  • disable creator rewards or withdrawals;
  • suspend transactions;
  • limit the Service to existing users;
  • remove the Service from an app store;
  • suspend access from the relevant country or region; or
  • discontinue the Service there.

4.3 Regulatory Information

Where required or reasonably necessary, Fraw may provide authorities, app stores, payment providers, service providers, or professional advisers with information concerning:

  • Fraw’s corporate identity;
  • the Service;
  • electronic systems used to operate the Service;
  • service categories;
  • domain names;
  • applications;
  • contact information;
  • data-processing practices;
  • cloud or infrastructure providers;
  • content-moderation systems;
  • complaint-handling procedures;
  • user-generated-content features;
  • payment or creator functions;
  • cybersecurity contacts;
  • regulatory representatives; or
  • other information required for registration, licensing, reporting, audit, or compliance.

Fraw may update, correct, supplement, withdraw, or replace regulatory submissions where appropriate.

4.4 User Cooperation

You agree to provide accurate information reasonably requested where necessary to:

  • determine your country or region;
  • comply with regional eligibility requirements;
  • respond to a regulatory inquiry;
  • investigate unlawful conduct;
  • administer a complaint;
  • satisfy a tax, payment, or payout obligation;
  • comply with a valid legal request; or
  • maintain the lawful operation of the Service.

You must not use false location information, technical circumvention, virtual private networks, proxy services, false identities, or other methods for the purpose of evading a lawful country restriction, regulatory restriction, content block, or account limitation.

4.5 Regional Service Notices

Fraw may publish country- or region-specific service notices that supplement these Terms and explain local requirements, feature availability, account verification, public-content functions, creator participation, payments, rewards, moderation, regulatory compliance, or other regional conditions.

If you access or use the Service from a country or region for which Fraw has published a regional service notice, that notice forms part of these Terms and applies to your use of the Service in that country or region.

Regional service notices may provide that certain functions are:

  • unavailable;
  • delayed;
  • subject to additional verification;
  • limited to eligible users;
  • restricted by age, account status, or location;
  • subject to local content or moderation rules;
  • unavailable for creator rewards or withdrawal; or
  • otherwise modified to comply with applicable law or operational requirements.

For users located in Vietnam, please review the Vietnam Regional Service and Creator Notice.

If a regional service notice conflicts with these Terms, the regional service notice will apply to users in the relevant country or region to the extent:

  • Fraw expressly states that the regional rule applies;
  • the conflict concerns the availability or operation of a regional feature;
  • the conflict concerns a country-specific legal or regulatory requirement; or
  • applicable law requires a different result.

Nothing in a regional service notice limits any mandatory right or protection that cannot lawfully be excluded, restricted, or waived.

5. Subscription Tiers and Access

Access to features, functions, permissions, and eligibility within the Service is determined by your active subscription tier, account status, country or region, and any other criteria designated by Fraw.

Fraw may offer:

  • Free plans;
  • Basic plans;
  • Premium plans;
  • monthly subscriptions;
  • yearly subscriptions;
  • promotional plans;
  • trial plans; or
  • other plans from time to time.

Available plans, credit allocations, billing periods, access rights, feature permissions, and commercial terms may be displayed:

  • within the Service;
  • in the purchase flow;
  • on pricing pages;
  • in app-store listings;
  • in help-center materials; or
  • in related policies.

Fraw may update plan features, credit allocations, access permissions, eligibility criteria, or commercial terms prospectively, subject to applicable law.

Credits do not independently determine subscription tier and do not automatically grant access to higher-tier features.

Purchasing top-up credits does not upgrade your subscription tier.

If you have an active subscription, your tier remains tied to that subscription during the applicable billing period unless adjusted because of:

  • cancellation;
  • expiration;
  • refund;
  • chargeback;
  • payment failure;
  • fraud review;
  • account suspension;
  • policy enforcement;
  • platform action;
  • regional unavailability; or
  • legal or regulatory requirements.

Where Fraw becomes unable to continue providing some or all subscription functions in a country, available remedies will be determined in accordance with:

  • applicable law;
  • the relevant app-store or payment-provider rules;
  • the nature and timing of the restriction;
  • services already provided; and
  • any non-waivable consumer rights.

6. Credits

Fraw uses a virtual credit system for certain usage within the Service.

Credits may be issued through:

  • subscriptions;
  • top-up purchases;
  • account signup;
  • referrals;
  • promotions;
  • campaigns;
  • customer-support adjustments; or
  • other distributions authorized by Fraw.

Fraw may distinguish between different categories of credits, including:

  • paid credits;
  • subscription-included credits;
  • promotional credits;
  • referral credits; and
  • free credits.

Different categories of credits may be subject to different rules relating to:

  • access;
  • expiry;
  • usage;
  • regional availability;
  • exclusions;
  • reward eligibility;
  • refunds; and
  • restoration.

Except where required by applicable law:

  • credits are licensed, not sold;
  • credits are non-transferable;
  • credits are non-refundable;
  • credits are not redeemable for cash;
  • credits may not be sold, traded, exchanged, or gifted without authorization;
  • credits do not constitute stored value;
  • credits do not constitute electronic money;
  • credits do not constitute a bank deposit;
  • credits do not constitute a security or investment; and
  • credits do not create ownership or personal-property rights.

We may adjust, reverse, remove, suspend, or expire credits where reasonably necessary in connection with:

  • fraud;
  • abuse;
  • chargebacks;
  • payment reversals;
  • technical errors;
  • duplicate credits;
  • policy violations;
  • account suspension or termination;
  • regional service suspension;
  • governmental or regulatory action;
  • legal requirements; or
  • platform-protection measures.

7. Credit Expiry and Top-Ups

Credits may expire or reset according to the plan, promotion, purchase type, or policy under which they were issued.

Subscription-included credits may expire or reset at the end of the relevant billing period.

Promotional, referral, or Free Credits may expire according to the applicable program or campaign rules.

Top-up credits may expire according to the conditions displayed in the Service, purchase flow, help center, or related materials.

Top-up credits increase usage quantity only.

Top-up credits do not:

  • change your subscription tier;
  • upgrade access rights;
  • unlock higher-tier functions;
  • grant creator publishing rights;
  • grant creator reward eligibility;
  • grant withdrawal rights;
  • override a country or regional restriction; or
  • extend an expired subscription.

Feature access while using top-up credits continues to follow your then-current tier, account status, country availability, regulatory availability, and applicable Service rules.

8. Official Functions and User-Created Extensions

The Service may include both official Fraw-provided functions and user-created extensions.

Official functions may include:

  • official extensions;
  • selected or featured official experiences;
  • Rebuild;
  • Blend; and
  • other tools developed or designated by Fraw.

Access to official functions is governed by:

  • subscription tier;
  • account status;
  • country availability;
  • regulatory availability;
  • Service rules; and
  • applicable law.

Certain users may be permitted to create private extensions for personal or internal use.

Certain eligible users may be permitted to publish extensions for wider access within the Service.

Not all users may:

  • create extensions;
  • publish extensions;
  • use public extensions;
  • monetize extensions;
  • earn Diamonds;
  • withdraw creator rewards; or
  • access every category of official function.

These permissions are governed by Fraw’s tier rules, Creator Policy, product rules, moderation requirements, country availability, regulatory status, and applicable law.

Official functions do not generate creator reward eligibility unless Fraw expressly states otherwise.

9. Creator Features and Published Extensions

Fraw may permit certain eligible users to publish extensions and participate in creator-related features.

Creator eligibility, publication rights, visibility, distribution, moderation, monetization, and access to creator tools are determined by Fraw.

Eligibility may depend on factors including:

  • subscription tier;
  • account standing;
  • account age or time on plan;
  • verification status;
  • moderation or quality review;
  • fraud and abuse review;
  • country or region;
  • regulatory registration or approval;
  • electronic-system operator requirements;
  • payout-provider availability;
  • tax or legal requirements; and
  • compliance with these Terms and applicable policies.

Creator participation does not guarantee:

  • publication;
  • approval;
  • visibility;
  • ranking;
  • promotion;
  • distribution;
  • user traffic;
  • monetization;
  • Diamonds;
  • withdrawal;
  • creator earnings; or
  • continued access to creator functions.

We may approve, reject, limit, demote, remove, unpublish, archive, suspend, or terminate creator access or published extensions where reasonably necessary for:

  • safety;
  • quality control;
  • user protection;
  • fraud prevention;
  • abuse prevention;
  • intellectual-property enforcement;
  • privacy protection;
  • child protection;
  • content-law compliance;
  • policy enforcement;
  • legal or regulatory compliance;
  • compliance with a lawful content-removal or access-blocking request;
  • reputational protection; or
  • platform integrity.

Your participation in creator features is also governed by the Fraw Creator Policy, which forms part of these Terms.

10. User-Generated Content and Platform Responsibilities

10.1 User-Generated Content

Published Extensions and other public-facing features may contain content created, submitted, configured, selected, uploaded, or published by users.

User-generated content may include:

  • extension names;
  • descriptions;
  • prompts;
  • instructions;
  • reference images;
  • thumbnails;
  • generated examples;
  • creator names;
  • public metadata;
  • comments or reports where supported; and
  • other materials made available through the Service.

Fraw does not endorse or guarantee the legality, accuracy, safety, quality, originality, or suitability of user-generated content merely because it appears in the Service.

10.2 Content Controls

Fraw may implement measures including:

  • automated filtering;
  • manual review;
  • reporting controls;
  • complaint procedures;
  • access restrictions;
  • age restrictions;
  • regional restrictions;
  • content warnings;
  • visibility limits;
  • takedown procedures;
  • account suspension; and
  • repeat-offender enforcement.

Fraw may modify these systems to comply with local electronic-system, intermediary, user-generated-content, platform, or content laws.

10.3 Country-Specific Content Restrictions

Content or extensions available in one country may be unavailable in another.

Fraw may restrict or remove content based on:

  • local law;
  • a court order;
  • a regulator’s request;
  • a governmental request;
  • public-order requirements;
  • child-safety requirements;
  • intellectual-property claims;
  • privacy complaints;
  • platform rules;
  • local cultural or religious restrictions;
  • national-security requirements;
  • fraud or consumer-protection concerns; or
  • Fraw’s reasonable assessment of legal or operational risk.

You have no right to require Fraw to make particular content available in every country.

11. Diamonds and Creator Rewards

Fraw may operate a creator reward system using an internal reward unit referred to as “Diamonds” or a similar designation.

Diamonds are part of Fraw’s internal creator reward system.

Diamonds are not:

  • a general user currency;
  • stored value;
  • electronic money;
  • a bank deposit;
  • personal property;
  • a security or investment;
  • transferable;
  • freely exchangeable; or
  • a guaranteed right to cash payment.

Only users designated by Fraw may be eligible to earn Diamonds or creator rewards.

Eligibility remains subject to:

  • creator-program rules;
  • subscription tier;
  • account standing;
  • qualifying activity;
  • fraud and abuse checks;
  • country availability;
  • regulatory status;
  • payment-provider support;
  • tax and legal requirements; and
  • compliance with these Terms and the Creator Policy.

Fraw may determine and revise from time to time, to the extent permitted by law:

  • how creator rewards are calculated;
  • which actions are eligible or ineligible;
  • exclusions for official functions;
  • exclusions for promotional or Free Credit activity;
  • exclusions for self-usage;
  • exclusions for connected or related accounts;
  • conversion methodology;
  • minimum withdrawal thresholds;
  • settlement timing;
  • holding periods;
  • verification requirements;
  • fraud-review procedures;
  • withholding rules;
  • reversal rules;
  • forfeiture rules;
  • expiration rules; and
  • suspension rules.

Creator rewards, Diamond accrual, conversion, withdrawal functionality, and payout methods may not be available in every country or region.

Availability may depend on:

  • applicable law;
  • electronic-system or platform registration;
  • tax requirements;
  • identity verification;
  • payment verification;
  • payout-provider support;
  • account eligibility;
  • Fraw’s operational readiness; and
  • compliance review.

The display or accumulation of Diamonds does not guarantee that withdrawal is available in your country or region and does not create an immediate, unconditional, or vested right to receive cash or other payment.

Where withdrawal is unavailable, restricted, suspended, or subject to further verification, Fraw may retain the relevant Diamond record in accordance with the Creator Policy and applicable law without being required to make an immediate payment.

Any creator reward rights remain subject to:

  • these Terms;
  • the Creator Policy;
  • continued eligibility;
  • account compliance;
  • fraud review;
  • applicable law;
  • regulatory availability; and
  • availability of a supported payout method.

12. Referral and Promotional Programs

Fraw may offer:

  • referral programs;
  • member-get-member programs;
  • invite programs;
  • promotional campaigns;
  • signup rewards;
  • limited-time offers; or
  • other benefit programs.

The structure, eligibility conditions, rewards, exclusions, limits, expiration rules, and anti-abuse controls may be displayed in the Service or in related materials.

Referral or promotional rewards may be issued as:

  • Free Credits;
  • promotional credits;
  • discounts;
  • temporary access;
  • account benefits; or
  • other rewards designated by Fraw.

Unless Fraw expressly states otherwise:

  • promotional rewards do not create creator payout rights;
  • Free Credits do not generate Diamonds;
  • referral rewards are non-transferable;
  • promotional benefits may expire; and
  • promotional benefits have no cash value.

You must not manipulate referral or promotional programs through:

  • self-referrals;
  • fake accounts;
  • duplicate accounts;
  • automated activity;
  • collusion;
  • device manipulation;
  • payment manipulation;
  • identity manipulation;
  • location manipulation;
  • misleading promotion; or
  • other abusive conduct.

We may:

  • refuse rewards;
  • reverse rewards;
  • remove credits;
  • disqualify participants;
  • suspend accounts;
  • terminate participation; or
  • take other appropriate action,

where we reasonably suspect abuse, manipulation, fraud, or violation of program rules.

13. Billing, Renewals, Cancellations, and Refunds

Paid plans and purchases may be billed through:

  • Apple App Store;
  • Google Play;
  • web checkout;
  • payment processors; or
  • other authorized billing channels.

Before completing a purchase, you are responsible for reviewing:

  • the price;
  • currency;
  • applicable taxes;
  • billing period;
  • renewal terms;
  • included credits;
  • included features;
  • subscription duration;
  • cancellation method;
  • expiry terms; and
  • any other material conditions displayed in the purchase flow.

Subscriptions may renew automatically unless canceled before the applicable renewal date through the relevant billing platform.

Deleting the Fraw app or deleting your Fraw account may not automatically cancel an app-store or third-party subscription.

You are responsible for canceling through the applicable billing platform where required.

Where billing is processed by Apple App Store, Google Play, or another third party:

  • that provider’s billing, cancellation, renewal, and refund terms may apply;
  • cancellation may need to be completed through that provider;
  • the provider may control refund eligibility and processing;
  • Fraw may not be able to directly issue or approve a refund controlled by that provider; and
  • you should follow the provider’s applicable procedures for billing and refund requests.

Except where required by applicable law or applicable payment-platform rules, payments for subscriptions, top-ups, credits, or related purchases are non-refundable.

Nothing in these Terms excludes, restricts, or modifies any:

  • consumer guarantee;
  • cancellation right;
  • refund right;
  • remedy;
  • warranty; or
  • other statutory protection

that cannot lawfully be excluded, restricted, or modified under the law applicable to you.

We may change plan prices, included features, access rights, credit allocations, and other commercial terms prospectively, subject to applicable law and any notice required by the applicable billing provider.

14. User Content and Inputs

You may submit prompts, text, images, photographs, files, instructions, extension assets, and other materials to the Service collectively referred to as “User Content.”

You retain ownership of User Content that you lawfully own.

You grant Fraw a worldwide, non-exclusive, royalty-free, transferable, and sublicensable licence to:

  • host;
  • store;
  • reproduce;
  • copy;
  • adapt;
  • format;
  • process;
  • transmit;
  • display;
  • make available;
  • moderate;
  • analyze;
  • secure; and
  • otherwise use

your User Content as reasonably necessary to:

  • provide the Service;
  • perform requested AI generation or transformation;
  • store content at your request;
  • operate extensions;
  • publish content you choose to publish;
  • secure and maintain the Service;
  • prevent abuse;
  • enforce policies;
  • respond to reports and complaints;
  • provide support;
  • comply with law;
  • comply with lawful regulatory or governmental requests; and
  • protect Fraw, users, and third parties.

This licence continues for as long as reasonably necessary to provide the relevant feature or fulfil the purposes described in these Terms and the Privacy Policy.

When you submit User Content and initiate an AI-generation, transformation, Rebuild, Blend, or extension-based request, you instruct Fraw to process, host, reproduce, adapt, transmit, and disclose that User Content to:

  • Fraw’s systems; and
  • third-party service providers reasonably necessary to provide, secure, support, moderate, or troubleshoot the requested function.

You represent and warrant that:

  • you own or control the necessary rights in your User Content;
  • you have all permissions, consents, licences, and lawful authority necessary to submit it;
  • your User Content does not violate law;
  • your User Content does not violate another person’s privacy, publicity, intellectual-property, confidentiality, contractual, or other rights;
  • your User Content is not misleading, fraudulent, harmful, or unlawful; and
  • your User Content does not breach these Terms or other applicable policies.

If User Content includes personal information, an image, likeness, voice, or other information relating to another person, you represent and warrant that you have all rights, permissions, consents, and lawful authority necessary to submit that content and request the relevant processing.

You must not submit another person’s personal information or image in violation of:

  • privacy rights;
  • data-protection law;
  • publicity rights;
  • intellectual-property rights;
  • confidentiality duties;
  • child-protection law;
  • contractual restrictions; or
  • other applicable rights.

You are solely responsible for your User Content and the consequences of submitting, publishing, sharing, or using it.

15. AI Output

The Service may generate images, text, transformations, recommendations, or other output based on your inputs collectively referred to as “Output.”

You acknowledge that:

  • Output is generated by automated systems;
  • Output may be inaccurate;
  • Output may be incomplete;
  • Output may contain errors;
  • Output may be offensive or inappropriate;
  • Output may be unavailable;
  • Output may be non-unique;
  • similar or identical Output may be generated for other users;
  • Output may resemble existing material;
  • Output may not be suitable for commercial use;
  • Output may not be legally protectable;
  • Output may be restricted in a particular country; and
  • Output may require human review.

Fraw does not guarantee:

  • accuracy;
  • legality;
  • originality;
  • uniqueness;
  • non-infringement;
  • suitability;
  • quality;
  • commercial value;
  • availability; or
  • fitness for any particular purpose.

You are solely responsible for reviewing, evaluating, and verifying Output before:

  • using it;
  • relying on it;
  • sharing it;
  • publishing it;
  • distributing it;
  • licensing it;
  • selling it;
  • commercializing it; or
  • using it in connection with any decision.

You must not rely on Output as professional legal, medical, financial, safety, or other regulated advice.

16. Acceptable Use

You agree not to use the Service to:

  • violate any law or regulation;
  • infringe intellectual-property rights;
  • violate privacy or publicity rights;
  • breach confidentiality obligations;
  • submit unlawful, harmful, deceptive, abusive, or infringing content;
  • create or distribute non-consensual intimate imagery;
  • exploit or endanger children;
  • impersonate another person or entity;
  • create deceptive identity materials;
  • commit fraud, scams, or financial manipulation;
  • generate spam or unauthorized promotional content;
  • harass, threaten, intimidate, or abuse others;
  • distribute malware or malicious code;
  • interfere with or disrupt the Service;
  • bypass security controls;
  • reverse engineer the Service except where legally permitted;
  • scrape, extract, or harvest information without authorization;
  • manipulate credits, Diamonds, rewards, or referrals;
  • engage in self-dealing or collusive reward activity;
  • evade tier restrictions;
  • evade country or regional restrictions;
  • evade a lawful content or access restriction;
  • evade a regulatory suspension or account block;
  • falsify your country, region, identity, or eligibility;
  • avoid moderation or enforcement systems;
  • create unauthorized automated accounts;
  • overload infrastructure;
  • misuse APIs or technical interfaces;
  • test vulnerabilities without authorization; or
  • assist another person in prohibited conduct.

We may investigate suspected violations and take action including:

  • content removal;
  • generation blocking;
  • feature restriction;
  • extension removal;
  • credit reversal;
  • Diamond reversal;
  • reward forfeiture;
  • account suspension;
  • account termination;
  • preservation of evidence;
  • reporting to authorities; or
  • legal action.

17. Moderation, Review, and Enforcement

We may, but are not obligated to, review:

  • User Content;
  • prompts;
  • uploaded images;
  • generated Output;
  • extensions;
  • published extensions;
  • creator activity;
  • referral activity;
  • credits;
  • Diamonds;
  • transaction activity;
  • support reports;
  • complaints;
  • account relationships;
  • device signals;
  • payment signals;
  • IP addresses;
  • location signals; and
  • usage patterns.

We may use:

  • automated systems;
  • manual review;
  • third-party moderation;
  • safety filters;
  • fraud-detection tools; or
  • hybrid review processes.

We may remove, restrict, deny, suspend, reverse, demote, archive, unpublish, or terminate:

  • content;
  • extensions;
  • accounts;
  • credits;
  • Diamonds;
  • rewards;
  • creator privileges;
  • public visibility;
  • transactions; or
  • access to the Service,

where reasonably necessary for:

  • fraud prevention;
  • abuse prevention;
  • safety;
  • user protection;
  • quality control;
  • policy enforcement;
  • intellectual-property compliance;
  • privacy protection;
  • child protection;
  • legal compliance;
  • regulatory requests;
  • court orders;
  • content-removal requirements;
  • access-blocking requirements;
  • security; or
  • platform integrity.

We do not guarantee that all content will be reviewed before being made available.

18. Reports, Complaints, and Content Removal

Users and third parties may submit reports or complaints regarding:

  • unlawful content;
  • intellectual-property infringement;
  • unauthorized use of an image;
  • privacy violations;
  • impersonation;
  • deceptive content;
  • child-safety concerns;
  • harassment;
  • fraud;
  • non-consensual intimate content;
  • harmful Output; or
  • violations of these Terms.

Fraw may request information reasonably necessary to identify and evaluate the reported content.

Fraw may:

  • temporarily restrict content while reviewing a report;
  • disable generation;
  • unpublish an extension;
  • restrict content in a particular country;
  • remove content;
  • preserve records;
  • contact the account holder;
  • refer the matter to a service provider;
  • cooperate with an app store;
  • cooperate with a regulator or authority;
  • reverse related rewards;
  • suspend an account; or
  • take other action permitted by law.

Fraw is not required to resolve private disputes between users, but may act where reasonably necessary to protect the Service or comply with law.

19. Regulatory, Governmental, and Law-Enforcement Requests

19.1 Lawful Requests

Fraw may receive requests, demands, orders, notices, or inquiries from:

  • courts;
  • regulators;
  • law-enforcement agencies;
  • ministries;
  • cybersecurity authorities;
  • tax authorities;
  • consumer-protection bodies;
  • data-protection authorities;
  • electronic-system regulators;
  • app stores;
  • payment providers; or
  • other competent bodies.

Subject to applicable law, Fraw may:

  • verify the request;
  • seek clarification;
  • preserve relevant records;
  • restrict or remove content;
  • restrict an account;
  • disclose information;
  • provide technical or administrative information;
  • suspend a feature;
  • block access in a country;
  • cooperate with an investigation;
  • challenge an invalid or excessive request; or
  • take other legally permitted action.

19.2 Access to Electronic Information

Where required by valid applicable law, Fraw may provide access to or disclose electronic information, electronic records, account information, transaction records, content records, system information, or other data within Fraw’s possession or control.

Any such access or disclosure will be subject to:

  • the legal authority relied upon;
  • the scope of the request;
  • applicable privacy and confidentiality obligations;
  • technical feasibility;
  • the rights and safety of users and third parties; and
  • any lawful basis for objection, limitation, or challenge.

Nothing in these Terms gives a government authority greater access than it is lawfully entitled to receive.

19.3 Confidentiality of Requests

Fraw may be prohibited from notifying you about:

  • an investigation;
  • a preservation request;
  • a disclosure request;
  • a content-removal order;
  • an access restriction;
  • a regulatory inquiry; or
  • another governmental action.

Fraw may delay or omit notice where notice is prohibited, would compromise an investigation, create a safety risk, or otherwise be inappropriate under applicable law.

20. Intellectual Property

The Service, including its:

  • software;
  • source code;
  • systems;
  • interfaces;
  • workflows;
  • design;
  • branding;
  • graphics;
  • logos;
  • names;
  • documentation;
  • databases;
  • technical architecture; and
  • underlying technology,

is owned by Fraw or its licensors and is protected by applicable intellectual-property laws.

Except for the limited right to use the Service in accordance with these Terms, no right, title, or interest in the Service is transferred to you.

You may not:

  • copy;
  • reproduce;
  • modify;
  • distribute;
  • sell;
  • lease;
  • sublicense;
  • reverse engineer;
  • decompile;
  • disassemble;
  • create derivative works from; or
  • commercially exploit

the Service or any part of it, except where expressly permitted by law or authorized by Fraw in writing.

Fraw’s names, logos, product names, and branding may not be used without prior written permission.

21. Third-Party Services

The Service may rely on or integrate with third-party services, including:

  • app stores;
  • payment processors;
  • login providers;
  • cloud-hosting providers;
  • analytics providers;
  • communication providers;
  • security providers;
  • fraud-prevention providers;
  • moderation providers;
  • payout providers;
  • regulatory-registration providers;
  • professional advisers; and
  • AI model providers.

Third-party services are governed by their own terms, privacy policies, and operating rules.

Fraw does not control and is not responsible for third-party:

  • availability;
  • performance;
  • pricing;
  • billing practices;
  • refund decisions;
  • security;
  • content;
  • data practices;
  • outages;
  • restrictions;
  • account actions;
  • regulatory actions; or
  • compliance decisions.

Your use of third-party services is at your own risk and subject to the applicable third-party terms.

22. Privacy

Your use of the Service is subject to the Fraw Privacy Policy, which explains how we collect, use, disclose, store, retain, and otherwise process personal information.

Supplemental regional privacy notices or addenda may apply depending on where you live.

By using the Service, you acknowledge that your information may be processed as described in:

  • the Privacy Policy;
  • any applicable regional addendum;
  • any notice presented in the Service; and
  • applicable law.

Where processing requires consent under applicable law, Fraw may request that consent separately.

Where required by applicable law, Fraw may process, preserve, or disclose information to:

  • maintain a regulatory registration;
  • respond to a lawful authority;
  • investigate a complaint;
  • remove prohibited content;
  • address a cybersecurity incident;
  • comply with a preservation requirement;
  • protect users; or
  • maintain the lawful operation of the Service.

23. Cybersecurity and Electronic-System Integrity

Fraw uses reasonable technical, administrative, and organizational measures designed to protect the Service and information processed through it.

Fraw may:

  • monitor systems;
  • log activity;
  • investigate suspicious behaviour;
  • restrict access;
  • preserve security records;
  • cooperate with cybersecurity authorities;
  • notify affected persons or regulators where required;
  • perform testing;
  • apply patches;
  • change infrastructure;
  • suspend affected features; or
  • take other reasonable security measures.

You agree not to interfere with:

  • system integrity;
  • availability;
  • confidentiality;
  • authentication;
  • access controls;
  • logging;
  • monitoring;
  • incident response;
  • moderation systems; or
  • regulatory compliance systems.

No system is completely secure. Fraw does not guarantee that unauthorized access, security incidents, outages, or data loss will never occur.

24. Service Availability

The Service is provided over internet, electronic-system, cloud, and third-party infrastructure and may be affected by:

  • maintenance;
  • updates;
  • third-party outages;
  • provider restrictions;
  • technical failures;
  • capacity limits;
  • network issues;
  • cybersecurity incidents;
  • registration delays;
  • regulatory review;
  • governmental blocking;
  • legal restrictions;
  • force majeure events; or
  • other circumstances outside Fraw’s control.

We do not guarantee uninterrupted, continuous, or error-free availability.

We may impose:

  • usage limits;
  • request limits;
  • storage limits;
  • rate limits;
  • generation limits;
  • country restrictions;
  • device restrictions;
  • content restrictions;
  • registration restrictions; or
  • temporary service restrictions.

We may perform maintenance or updates without prior notice where reasonably necessary.

25. Suspension or Withdrawal from a Country

Fraw may restrict, suspend, remove, or discontinue the Service in a country or region where:

  • registration is required but incomplete;
  • a registration is rejected, suspended, revoked, or expires;
  • a licence or approval is unavailable;
  • a local representative cannot be appointed or maintained;
  • compliance obligations become unreasonable or infeasible;
  • a regulator or authority requires restriction;
  • an app store removes the Service;
  • an infrastructure provider restricts service;
  • legal exposure becomes unacceptable;
  • required data, content, security, tax, or reporting controls cannot be supported;
  • access is blocked or materially disrupted; or
  • continued availability creates unacceptable risk.

Such action may include:

  • closing new registration;
  • disabling purchases;
  • preventing publication;
  • disabling public extensions;
  • restricting creator rewards;
  • suspending payouts;
  • removing the app from local stores;
  • restricting network access;
  • terminating local service; or
  • taking other proportionate action.

Where required by applicable law, Fraw will provide notice or available remedies.

26. Disclaimer of Warranties

To the fullest extent permitted by law, the Service is provided “as is” and “as available.”

Fraw disclaims all warranties, whether:

  • express;
  • implied;
  • statutory; or
  • otherwise.

This includes implied warranties of:

  • merchantability;
  • satisfactory quality;
  • fitness for a particular purpose;
  • title;
  • non-infringement;
  • accuracy;
  • availability; and
  • quiet enjoyment.

We do not warrant that:

  • the Service will be uninterrupted;
  • the Service will be error-free;
  • the Service will be secure;
  • defects will be corrected;
  • data will never be lost;
  • any feature will remain available;
  • any plan will remain unchanged;
  • any credit or reward system will continue;
  • any extension will remain available;
  • any creator program will remain available;
  • any payout method will remain supported;
  • any regulatory registration will be obtained or maintained;
  • the Service will remain available in a particular country; or
  • any Output will be accurate, lawful, original, unique, or suitable.

Nothing in this section excludes warranties or consumer protections that cannot lawfully be excluded.

27. Limitation of Liability

To the fullest extent permitted by law, Fraw and its affiliates, officers, directors, employees, contractors, licensors, and partners will not be liable for:

  • indirect damages;
  • incidental damages;
  • consequential damages;
  • special damages;
  • exemplary damages;
  • punitive damages;
  • lost profits;
  • lost revenue;
  • loss of business;
  • loss of goodwill;
  • loss of opportunity;
  • loss of data;
  • loss of content;
  • loss of credits;
  • loss of Diamonds;
  • loss of creator rewards;
  • loss arising from third-party services;
  • loss arising from Output;
  • loss arising from interruption of the Service;
  • loss arising from a governmental or regulatory action;
  • loss arising from a regional content restriction;
  • loss arising from a registration, licence, approval, or filing issue; or
  • loss arising from suspension or removal of the Service in a country.

To the fullest extent permitted by law, Fraw’s total aggregate liability for all claims arising out of or relating to the Service or these Terms will not exceed the greater of:

  • the amount you paid directly to Fraw during the twelve months before the event giving rise to the claim; or
  • the minimum amount required by applicable law.

The limitations in this section apply regardless of the legal theory of liability and even if Fraw was advised of the possibility of the loss.

Some jurisdictions do not allow certain liability limitations or exclusions. In such jurisdictions, the limitations apply only to the maximum extent permitted by law.

Nothing in these Terms excludes or limits liability where exclusion or limitation is prohibited by applicable law.

28. Indemnification

To the fullest extent permitted by law, you agree to defend, indemnify, and hold harmless Fraw and its affiliates, officers, directors, employees, contractors, licensors, and partners from and against claims, liabilities, damages, losses, penalties, costs, and expenses, including reasonable legal fees, arising out of or relating to:

  • your use of the Service;
  • your User Content;
  • your extensions;
  • your publication or sharing of content;
  • your use or commercialization of Output;
  • your violation of these Terms;
  • your violation of applicable law;
  • your infringement of third-party rights;
  • your fraud or abuse;
  • your submission of another person’s personal data without lawful authority;
  • your evasion of a regional or regulatory restriction;
  • your violation of a content-removal or access restriction; or
  • your manipulation of credits, Diamonds, rewards, or referrals.

This obligation does not apply to the extent a claim results directly from Fraw’s own unlawful conduct.

29. Suspension and Termination

We may suspend, restrict, or terminate your access to the Service, with or without notice, where reasonably necessary if:

  • you violate these Terms or another policy;
  • we suspect fraud, abuse, manipulation, or unlawful conduct;
  • your account creates security, legal, regulatory, operational, or reputational risk;
  • payment is reversed or disputed;
  • required by law, court order, regulator, app store, or service provider;
  • your use creates risk to users, creators, Fraw, or partners;
  • you are no longer eligible;
  • required consent is unavailable;
  • a required registration, licence, filing, notification, approval, or representative is unavailable;
  • the Service is discontinued in your country or region;
  • access is restricted by a governmental authority;
  • continued access would expose Fraw to unreasonable compliance risk; or
  • continued access is not commercially or technically feasible.

Upon suspension or termination:

  • your right to use the Service may end immediately;
  • access to features may be restricted;
  • public content may be removed or unpublished;
  • credits may be limited, reversed, or forfeited to the extent permitted by law;
  • Diamonds may be withheld, reversed, suspended, or forfeited;
  • creator privileges may be removed;
  • extensions may be archived or removed;
  • payout requests may be delayed or canceled where permitted by law and policy; and
  • records may be retained where required or permitted.

Termination does not affect accrued rights, payment obligations, or provisions that by their nature should survive.

30. Changes to the Service

We may change the Service from time to time.

Changes may include:

  • adding or removing features;
  • changing model providers;
  • changing credit requirements;
  • changing subscription benefits;
  • changing eligibility rules;
  • changing supported countries;
  • changing payout providers;
  • changing Diamond calculations;
  • changing storage limits;
  • changing technical requirements;
  • changing content controls;
  • changing regulatory arrangements; or
  • discontinuing features.

Where required by applicable law, we will provide reasonable notice of material changes.

We are not required to maintain any specific feature, provider, model, extension, reward program, registration, country availability, or commercial arrangement indefinitely.

31. Changes to These Terms

We may update these Terms from time to time to reflect:

  • changes to the Service;
  • changes to business practices;
  • changes to legal requirements;
  • changes to regulatory registrations;
  • changes to third-party platforms;
  • changes to content or electronic-system requirements;
  • changes to safety or security requirements; or
  • improvements to clarity.

If we make material changes, we may provide notice:

  • through the Service;
  • by email;
  • on our website;
  • through an app-store update; or
  • by another reasonable method.

The revised Terms will become effective on the date stated at the top of the document.

Your continued use of the Service after the effective date constitutes acceptance of the revised Terms.

Where applicable law requires affirmative acceptance, we may request that acceptance separately.

32. Governing Law

These Terms are governed by the laws of the Hong Kong Special Administrative Region, without regard to conflict-of-law principles.

This choice of law does not deprive you of any mandatory:

  • consumer protection;
  • privacy right;
  • statutory remedy;
  • cancellation right;
  • refund right;
  • regulatory right; or
  • other legal protection

available under the laws of your country or region of residence that cannot lawfully be waived or excluded.

33. Dispute Resolution and Jurisdiction

Subject to any mandatory rights available to you under applicable law, disputes, claims, or controversies arising out of or relating to these Terms or the Service shall be submitted to the competent courts of Hong Kong.

Nothing in these Terms prevents you from bringing a claim, complaint, report, or request before a:

  • court;
  • consumer commission;
  • tribunal;
  • regulator;
  • data-protection authority;
  • electronic-system authority;
  • cybersecurity authority;
  • app store;
  • payment provider; or
  • other competent body

where applicable law gives you a non-waivable right to do so.

Before commencing formal proceedings, you and Fraw are encouraged to attempt to resolve the dispute by contacting the other party and providing:

  • a reasonable description of the issue;
  • relevant account or transaction information; and
  • the requested resolution.

This section does not prevent either party from seeking urgent interim, protective, or injunctive relief where legally available.

34. Notices and Communications

We may send notices relating to the Service through:

  • in-app messages;
  • push notifications;
  • email;
  • website notices;
  • account notifications;
  • app-store communications; or
  • other reasonable methods.

Notices may concern:

  • account activity;
  • purchases;
  • subscriptions;
  • policy changes;
  • regulatory restrictions;
  • country availability;
  • content removal;
  • security incidents;
  • service suspension; or
  • legal matters.

You are responsible for keeping your account contact information current.

Electronic notices have the same effect as written notices where permitted by law.

35. Language and Local Translations

Fraw may provide translations of these Terms for convenience, transparency, or compliance.

Unless a translated version expressly states otherwise, the English version is the primary version used to interpret these Terms.

If there is an inconsistency between the English version and a translated version:

  • the English version will control to the extent permitted by applicable law; and
  • the translated version or mandatory local interpretation will apply to the extent required by applicable law.

The absence of a translation does not waive a mandatory language requirement.

Fraw may delay or restrict availability in a country until legally required translations, disclosures, or notices are available.

36. Assignment

You may not assign or transfer these Terms, your account, or your rights under these Terms without Fraw’s prior written consent.

Fraw may assign or transfer these Terms in connection with:

  • a merger;
  • acquisition;
  • reorganization;
  • financing;
  • sale of assets;
  • corporate restructuring; or
  • transfer of the Service,

subject to applicable law.

37. Force Majeure

Fraw will not be liable for delay or failure to perform caused by events beyond its reasonable control, including:

  • natural disasters;
  • severe weather;
  • fire;
  • flood;
  • earthquake;
  • epidemic or pandemic;
  • war;
  • terrorism;
  • civil disorder;
  • labour disputes;
  • governmental action;
  • regulatory restrictions;
  • licence or registration delays;
  • access blocking;
  • content-blocking orders;
  • power failure;
  • internet failure;
  • cloud-provider failure;
  • payment-provider failure;
  • app-store failure;
  • AI-provider outage;
  • cybersecurity incidents; or
  • other force majeure events.

38. Severability

If any provision of these Terms is held invalid, unlawful, or unenforceable, that provision will be enforced to the maximum extent permitted by law.

The remaining provisions will remain in full force and effect.

39. No Waiver

Fraw’s failure to enforce any provision of these Terms does not waive its right to enforce that provision later.

A waiver is effective only if made in writing by an authorized representative of Fraw.

40. Entire Agreement

These Terms, together with the following documents where applicable, constitute the entire agreement between you and Fraw regarding the Service:

  • the Privacy Policy;
  • regional privacy addenda;
  • the Creator Policy;
  • referral rules;
  • reward rules;
  • payout rules;
  • purchase terms;
  • community or content rules;
  • notices presented in the Service;
  • country-specific service notices; and
  • other policies expressly incorporated by reference.

If there is a conflict between these Terms and another policy, these Terms control unless the other policy expressly states that it overrides a particular provision.

41. Contact Information

If you have questions, concerns, complaints, reports, or requests relating to these Terms or the Service, contact:

  • Untitled Labs Limited
  • 20/F, Harbourside HQ
  • 8 Lam Chak Street
  • Kowloon Bay, Kowloon
  • Hong Kong
  • Support Email: hi@fraw.ai
  • Company Registration: 71095371

Where Fraw appoints a country-specific regulatory representative, electronic-system contact, privacy contact, grievance officer, or other local contact, the relevant details may be published:

  • in the Service;
  • in an applicable regional notice;
  • on Fraw’s website;
  • in an app-store listing; or
  • through another reasonable method.