COOKIE POLICY

1. INTRODUCTION

This Cookie Policy explains how AVENTORA LIMITED (“we”, “us”, “our”) uses cookies and similar technologies on the Velvet.zone platform (“Platform”, “Service”). It describes what these technologies are, why we use them, and how you can control their use when accessing or interacting with the Service.

Velvet.zone is a free-to-play social casino platform designed solely for entertainment and social interaction. The Platform does not offer real money gambling, wagering, or any financial activity, and all gameplay takes place within a simulated environment using tokens (Diamonds) that has no real-world value. The use of cookies on the Platform is strictly aligned with this non-monetary, entertainment-based context.

This Policy explains how cookies are used to support the operation, functionality, performance, and security of the Platform. Cookies help us maintain session continuity, enable account access, protect against unauthorized use, and ensure that the Platform operates efficiently. They also allow us to understand how users interact with the Service so that we can improve usability, optimize performance, and enhance the overall user experience.

This Cookie Policy should be read together with our Privacy Policy, which provides further information on how personal data is collected, used, and protected. Where cookies involve the processing of personal data, such processing will be carried out in accordance with the principles and safeguards described in the Privacy Policy and applicable data protection laws.

By accessing or using the Platform, you acknowledge that cookies and similar technologies may be used in accordance with this Policy, subject to your preferences and applicable legal requirements. Where required by law, we will request your consent before placing non-essential cookies on your device.

You have control over how cookies are used. You may accept or reject certain categories of cookies through the consent management tools provided on the Platform, and you may also configure your browser settings to block or delete cookies. Please note that restricting certain cookies may affect the functionality and performance of the Service.

We may update this Cookie Policy from time to time to reflect changes in technology, legal requirements, or the way the Platform operates. Any such updates will be published on the Platform and will take effect as described in the relevant section of this Policy.

If you do not agree with the use of cookies as described in this Policy, you should adjust your preferences accordingly or discontinue use of the Platform.

2. WHAT ARE COOKIES

Cookies are small text files that are placed and stored on your device when you access or use the Platform. They allow the Platform to recognize your device, maintain session continuity, and store certain information about your interaction with the Service in order to support functionality, security, and performance.

Cookies may be set directly by the Platform (first-party cookies) or by third-party service providers acting on our behalf (third-party cookies). In addition to traditional browser cookies, we may use similar technologies such as local storage, session storage, software development kits (SDKs), tracking pixels, and device identifiers, which perform comparable functions. For the purposes of this Policy, all such technologies are collectively referred to as “cookies”.

Cookies perform a range of technical roles depending on how they are implemented. Certain cookies are essential for the operation of the Platform and are required to enable core features such as account login, authentication, session management, and protection against unauthorized access. Without these cookies, the Platform would not be able to function properly.

Other cookies are used to collect information about how users interact with the Platform. This may include data relating to navigation, feature usage, gameplay activity, session duration, and system performance. This information helps us monitor and improve the stability, efficiency, and usability of the Service. Where possible, such data is aggregated, anonymized, or pseudonymized to reduce its sensitivity.

Cookies may also be used to remember your preferences and settings, such as language selection, user interface configuration, and other personalization choices. This enables the Platform to provide a more consistent and tailored experience across multiple sessions and visits.

Cookies can be categorized based on their duration. Session cookies are temporary and are automatically deleted when you close your browser or end your session. Persistent cookies remain on your device for a defined period or until manually deleted, allowing the Platform to recognize your device and retain certain settings across visits.

Some cookies may involve the processing of personal data, such as IP addresses, device identifiers, or online activity information. Where this occurs, such processing is carried out in accordance with our Privacy Policy and applicable data protection laws. We ensure that any personal data processed through cookies is limited to what is necessary for the relevant purpose and is protected by appropriate safeguards.

Cookies may also be categorized based on their function, such as strictly necessary cookies required for core operation, and performance or analytics cookies used to understand usage and improve the Platform. Where required by applicable law, non-essential cookies are only used with your consent.

All cookies used on the Platform are implemented in a manner consistent with the nature of the Service as a free-to-play social casino environment. Cookies are used exclusively to support functionality, performance, security, and user experience, and are not used for financial tracking, credit assessment, or any form of gambling-related profiling.

The use of cookies does not create any financial relationship, tracking of monetary activity, or assessment of user spending behavior, as the Platform does not involve real money or items of real-world value. All cookie-based processing remains strictly within the context of a simulated, non-monetary environment.

By understanding how cookies and similar technologies operate, you can make informed decisions about how they are used when accessing the Platform and manage your preferences accordingly.

3. HOW WE USE COOKIES

We use cookies and similar technologies to ensure that the Platform operates correctly, securely, and efficiently, and to provide a consistent, responsive, and optimized user experience within a free-to-play social gaming environment.

Cookies are used to support the essential functionality of the Platform. This includes maintaining your login session, authenticating your access, enabling secure navigation between pages, and ensuring that core features such as gameplay, account management, and tokens (Diamonds) (Diamonds) tracking function as intended. These cookies are necessary for the technical operation of the Service and cannot be disabled without affecting its functionality.

We use cookies to maintain the security and integrity of the Platform. This includes detecting and preventing unauthorized access, identifying suspicious or abusive activity, supporting fraud prevention mechanisms, and ensuring that interactions with the Service are legitimate. Cookies may be used to enforce security controls, manage session validity, and protect user accounts against misuse.

Cookies are also used to monitor performance and maintain the stability of the Platform. This includes collecting information about system behavior, load times, error rates, crash events, and overall performance metrics. This allows us to identify technical issues, diagnose problems, implement fixes, and improve the reliability and efficiency of the Service.

We use cookies to understand how users interact with the Platform. This includes analyzing gameplay activity, session duration, feature usage, navigation patterns, and engagement with different parts of the Service. Such analysis helps us improve usability, refine game mechanics, optimize user flows, and enhance the overall user experience. Where possible, this data is aggregated, anonymized, or pseudonymized to reduce the identification of individual users.

Cookies may be used to remember your preferences and settings, including language selection, interface configurations, and other user-specific choices. This ensures that your experience remains consistent across sessions and reduces the need to reconfigure settings each time you access the Platform.

We may use cookies to support internal analytics and measurement activities. These activities are strictly focused on improving the Platform, understanding usage trends, and enhancing performance. Cookies are not used to evaluate financial behavior, spending capacity, or any form of economic activity, as the Platform does not involve real money or items of real-world value.

Cookies may also be used in connection with third-party service providers that assist us in analytics, infrastructure, performance monitoring, or technical operations. Any such use is limited to what is necessary to support the Platform and is subject to contractual obligations, confidentiality requirements, and applicable data protection laws. Third parties are not permitted to use cookie data for their own independent purposes beyond those specified by us.

Where required by applicable law, we will obtain your consent before placing or using non-essential cookies. You will be provided with a consent management tool that allows you to accept, reject, or customize your preferences. You may withdraw or modify your consent at any time through the available settings or through your browser configuration.

Cookies may operate in combination with other technologies, such as device identifiers or local storage, to ensure continuity of service across sessions and devices. Any such use is limited to operational and technical purposes and is implemented in accordance with applicable legal requirements.

All use of cookies is strictly aligned with the nature of the Platform as a free-to-play social casino service. Cookies are used exclusively to support functionality, performance, security, and user experience. They are not used for financial tracking, credit assessment, behavioral scoring related to gambling, or any activity that would introduce monetary or economic implications.

The use of cookies does not create any financial relationship, entitlement, or expectation of value. All data collected through cookies relates solely to the operation of a simulated, non-monetary environment and is processed accordingly.

By using the Platform and managing your preferences through the available tools, you acknowledge and agree that cookies may be used for the purposes described in this section, subject to your choices and applicable legal requirements.

4. TYPES OF COOKIES

We use different types of cookies depending on their function, origin, and duration in order to ensure that the Platform operates effectively, securely, and efficiently within a free-to-play social gaming environment.

Strictly necessary cookies are essential for the operation of the Platform and enable core functionality without which the Service cannot be provided. These cookies support account authentication, session management, secure navigation, system integrity, and protection against unauthorized access or misuse. They are automatically activated when you use the Platform and do not require your consent where permitted by applicable law.

Performance and analytics cookies are used to understand how the Platform is used and to improve its functionality. These cookies collect information about gameplay activity, feature usage, session duration, navigation paths, and system performance. This allows us to monitor technical performance, identify errors, optimize features, and enhance the overall user experience. Where required by applicable law, such cookies are only used with your prior consent.

Functionality cookies are used to remember your preferences and settings. This may include language selection, interface configuration, display preferences, and other user-specific choices. These cookies help ensure that your experience remains consistent and personalized across sessions and reduce the need to re-enter preferences each time you access the Platform.

Security cookies are used to protect the Platform and its users. These cookies support mechanisms designed to detect suspicious behavior, prevent unauthorized access, enforce security measures, and maintain the integrity of user sessions. They may also assist in limiting abuse, identifying anomalies, and ensuring that interactions with the Platform are legitimate.

We may also use cookies in connection with load balancing and infrastructure management. These cookies help distribute traffic efficiently across servers, maintain system stability, and ensure that the Platform remains responsive and available during periods of high usage.

Cookies can also be categorized based on their origin. First-party cookies are set directly by the Platform and are primarily used to support core functionality, security, and internal operations. Third-party cookies may be set by service providers that assist us with analytics, infrastructure, or technical services. Any use of third-party cookies is strictly limited to the purposes necessary to operate and improve the Platform and is subject to contractual safeguards and applicable data protection laws.

Cookies may further be classified based on their duration. Session cookies are temporary and are deleted automatically when you close your browser or end your session. Persistent cookies remain on your device for a defined period or until manually deleted, allowing the Platform to recognize your device and retain certain settings across multiple visits.

Some cookies may involve the processing of personal data, such as IP addresses, device identifiers, or online activity. Where this occurs, such processing is carried out in accordance with our Privacy Policy and applicable data protection laws. We ensure that such data is limited to what is necessary and is protected by appropriate technical and organizational measures.

All types of cookies used on the Platform are implemented in a manner consistent with the nature of the Service as a free-to-play social casino environment. Cookies are used exclusively to support functionality, performance, security, and user experience. They are not used for financial tracking, credit assessment, or any form of gambling-related profiling.

The use of cookies does not create any financial relationship, entitlement, or expectation of value. No cookie is used to assign monetary value, track financial behavior, or establish any form of economic profile. All cookie-related processing remains strictly within the context of a simulated, non-monetary environment.

By using the Platform and managing your preferences through the available consent tools, you acknowledge and agree that different types of cookies may be used for the purposes described in this section, subject to your choices and applicable legal requirements.

5. THIRD-PARTY COOKIES

We may engage selected third-party service providers to support the operation, security, performance, and improvement of the Platform. In connection with these services, such providers may place cookies or use similar technologies on your device to deliver analytics, infrastructure, monitoring, or technical functionality.

These third-party cookies are used strictly for purposes necessary to operate and enhance the Platform. This may include measuring usage of the Service, understanding how users interact with features, monitoring performance and system stability, detecting errors, preventing abuse, and supporting the overall reliability of the Platform. Any such processing is carried out on our behalf and in accordance with our instructions.

Third-party cookies may collect certain technical and usage information, such as device identifiers, IP address, browser type, operating system, session activity, and interactions with the Platform. Where possible, this data is aggregated, anonymized, or pseudonymized. Where personal data is involved, such processing is conducted in accordance with our Privacy Policy and applicable data protection laws.

We require all third-party providers to comply with strict contractual obligations. These obligations include processing personal data only for specified purposes, maintaining confidentiality, implementing appropriate technical and organizational security measures, and not retaining data for longer than necessary. Third parties are not permitted to use cookie data for their own independent purposes beyond the services they provide to us.

We do not permit third-party providers to use cookies for financial profiling, credit assessment, behavioral scoring related to gambling, or any activity that would introduce monetary or economic evaluation. The use of third-party cookies is strictly limited to supporting the Platform as a free-to-play, non-monetary social gaming service.

Where required by applicable law, we will obtain your consent before allowing the use of non-essential third-party cookies. When you first access the Platform, you will be presented with a consent management tool that allows you to accept, reject, or customize your cookie preferences. You may withdraw or modify your consent at any time through the available settings.

You may also manage third-party cookies through your browser settings. Most browsers allow you to block or delete cookies, restrict specific types of cookies, or receive notifications when cookies are used. Please note that disabling third-party cookies may affect certain aspects of the Platform, particularly where such cookies are used to support analytics, performance monitoring, or technical services.

Third-party cookies may involve the transfer of data to jurisdictions outside your country of residence. Where this occurs, we ensure that appropriate safeguards are in place, including contractual protection and compliance with applicable data protection laws, to ensure that your personal data remains adequately protected.

We may update or change the third-party providers we use from time to time. Any such changes will be made in accordance with this Policy and applicable legal requirements, and where necessary, reflected in updates to this Cookie Policy or the consent management tool.

All use of third-party cookies is aligned with the nature of the Platform as a free-to-play social casino environment. No third-party cookies are used to track real money activity, assign monetary value, or create any form of financial or economic profile. All data collected through such technologies is used exclusively to support functionality, performance, security, and user experience within a simulated, non-monetary environment.

By using the Platform and managing your preferences, you acknowledge and agree that third-party cookies may be used in accordance with this section, subject to your choices and applicable legal requirements.

6. MANAGING COOKIES

You have control over how cookies are used when you access and interact with the Platform. Where required by applicable law, we provide a cookie consent mechanism that allows you to manage your preferences in relation to non-essential cookies.

When you first access the Platform, you will be presented with a cookie banner or consent management tool. This tool allows you to accept, reject, or customize your preferences for different categories of cookies, such as performance or analytics cookies. Strictly necessary cookies, which are essential for the operation of the Platform, cannot be disabled, as the Service would not function properly without them.

You may change or withdraw your consent at any time through the consent management settings available on the Platform. Changes to your preferences will apply to future use of cookies and will not affect the lawfulness of any processing carried out prior to your preference update.

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n addition to the Platform’s consent tools, you can manage cookies through your browser settings. Most web browsers allow you to view, control, block, or delete cookies. You can typically configure your browser to refuse all cookies, accept only certain types, or notify you when cookies are being placed. Please note that the exact functionality may vary depending on the browser and device you use.

Disabling or restricting cookies may impact the functionality, performance, and availability of certain features of the Platform. For example, you may not be able to log in, maintain a session, or access certain parts of the Service if essential cookies are blocked.

You may also delete cookies that have already been stored on your device at any time through your browser settings. Deleting cookies may remove stored preferences and require you to reconfigure certain settings upon your next visit.

Where third-party cookies are used, you may also manage your preferences through the consent tool or through your browser settings. In some cases, third-party providers may offer their own tools for managing data collection, subject to their respective policies.

We may periodically update the cookie consent mechanism to reflect changes in legal requirements, technology, or the types of cookies used. You may be asked to review and update your preferences if significant changes occur.

All cookie management options are provided in a manner consistent with the nature of the Platform as a free-to-play social casino service. Cookie preferences relate solely to functionality, performance, and user experience and do not involve any financial or gambling-related processing.

By using the Platform and managing your preferences, you acknowledge that you have been provided with tools to control the use of cookies and that it is your responsibility to configure these settings in accordance with your preferences.

7. RETENTION OF COOKIES

Cookies are retained on your device for different periods depending on their function, technical characteristics, and the purpose for which they are used. The duration of storage is determined by whether a cookie is classified as a session cookie or a persistent cookie, as well as by the operational necessity of the specific function it supports.

Session cookies are temporary and are automatically deleted when you close your browser or end your session. These cookies are essential for maintaining continuity during your visit, including keeping you logged in, enabling secure navigation between pages, and ensuring that interactions with the Platform function correctly in real time. Session cookies do not remain on your device after your browsing session ends.

Persistent cookies remain on your device for a defined period after your session has ended or until they are manually deleted. These cookies allow the Platform to recognize your device across multiple visits, remember your preferences, and support ongoing functionality, performance optimization, and user experience improvements. The duration of persistent cookies varies depending on their purpose and is limited to what is necessary to achieve that purpose.

Retention periods are determined based on operational requirements, technical functionality, security considerations, and applicable legal obligations. We ensure that cookies are not retained for longer than necessary and that retention periods are periodically reviewed, assessed, and updated to reflect current practices, technological developments, and regulatory expectations.

Where cookies are used for performance monitoring or analytics, retention periods are designed to allow meaningful analysis while minimizing the storage of identifiable data. In many cases, information collected through such cookies is aggregated, anonymized, or pseudonymized as soon as reasonably practicable, reducing the ability to associate data with individual users.

Third-party cookies may have their own retention periods, which are determined by the respective service providers. We require that such retention periods are proportionate and compliant with applicable data protection laws. Where possible, we limit the duration and scope of third-party cookies through contractual, technical, and configuration-based controls. We also require that third-party providers not retain data longer than necessary for the purposes for which it was collected.

Some cookies may be refreshed or renewed when you revisit the Platform or interact with certain features. This may extend their duration where necessary to maintain functionality or preferences. However, such renewal is limited to what is necessary for the relevant purpose and remains subject to applicable legal requirements, including consent where required.

You have control over the retention of cookies on your device. You may delete cookies at any time through your browser settings, which will remove stored information and may reset your preferences or require you to reauthenticate when you next access the Platform. You may also manage or restrict cookies through the consent management tools provided on the Platform.

In addition to active cookies stored on your device, certain data derived from cookies may be retained in server-side systems for limited periods for purposes such as security monitoring, system integrity, and performance analysis. Such data is handled in accordance with our Privacy Policy and applicable data protection laws.

All cookie retention practices are implemented in a manner consistent with the nature of the Platform as a free-to-play social casino service. Cookies are retained solely to support functionality, performance, security, and user experience. They are not retained for financial tracking, credit assessment, or any form of gambling-related profiling, and no retention period is linked to monetary or economic considerations.

The use and retention of cookies do not create any financial relationship, entitlement, or expectation of value. All cookie-related data remains within a simulated, non-monetary environment and is processed accordingly.

By using the Platform and managing your preferences, you acknowledge and agree that cookies may be stored on your device for the durations described in this section, subject to your control, browser settings, and applicable legal requirements.

8. CHANGES TO THIS POLICY

We reserve the right, at our sole discretion, to modify, update, amend, or replace this Cookie Policy at any time in order to reflect changes in technology, applicable laws, regulatory requirements, industry standards, or the way the Platform operates and uses cookies.

Any updated version of this Cookie Policy will be published on the Platform and will include a revised “Last Updated” date. Unless otherwise specified, changes will take effect upon publication. Where required by applicable law, or where changes materially affect your rights or the way cookies are used, we may provide advance notice or specify a future effective date before such changes become applicable.

It is your responsibility to review this Cookie Policy periodically to remain informed about how cookies and similar technologies are used. Your continued access to or use of the Platform after any updates take effect constitutes your acceptance of the revised Policy and your agreement to be bound by it.

Where changes are material, including changes to the categories of cookies used, the purposes of processing, or the involvement of third-party providers, we may provide additional notice through appropriate means. This may include in-platform notifications, updates to the cookie banner or consent management tool, or other prominent messaging. However, we are not obligated to provide individual notice of every modification, and failure to review updates does not affect their applicability.

If you do not agree with any changes to this Cookie Policy, you should adjust your cookie preferences using the available consent management tools or discontinue use of the Platform. Where consent is required for certain types of cookies, we will ensure that you are given the opportunity to provide or withdraw such consent in accordance with applicable law.

We may also update this Policy to reflect the introduction of new features, services, or technologies that involve the use of cookies or similar tracking mechanisms. Where such changes introduce new categories of cookies or new purposes of processing, we will update this Policy accordingly and, where required, obtain your consent before implementing such changes.

Non-material updates may be made at any time without prior notice. These may include corrections, clarifications, formatting adjustments, or updates required for technical or operational reasons. Such changes do not affect your rights in a substantive way but are made to ensure clarity, accuracy, and consistency.

From time to time, updates may also be required in order to comply with legal or regulatory obligations imposed by competent authorities. In such cases, changes may take effect immediately where necessary to ensure compliance. You acknowledge and agree that continued use of the Platform following such updates constitutes acceptance of the revised Policy.

Where changes affect your previously given consent, you may be prompted to review and update your preferences through the consent management tool upon your next visit to the Platform. This ensures that your choices remain current and aligned with the updated use of cookies.

We may retain previous versions of this Cookie Policy for record-keeping and compliance purposes, although we are not obligated to provide access to historical versions unless required by applicable law. The version made available on the Platform at any given time shall be the current and applicable version.

All changes to this Cookie Policy are made in a manner consistent with the nature of the Platform as a free-to-play social casino service. Updates do not introduce real money tracking, financial profiling, credit assessment, or gambling-related cookie usage, and any modifications remain aligned with the non-monetary nature of the Service.

By continuing to use the Platform and managing your preferences, you acknowledge and agree that it is your responsibility to remain informed of any updates to this Cookie Policy and that such updates are binding from the moment they take effect.

9. CONTACT

If you have any questions, concerns, or requests regarding this Cookie Policy or the way cookies and similar technologies are used on the Platform, you may contact us using the details provided below. We aim to respond to all legitimate inquiries in a timely and transparent manner.

Email: [email protected]

Company: AVENTORA LIMITED

Registered Address: Dept 6758, 196 High Road, Wood Green, London, United Kingdom, N22 8HH

You may contact us to request additional information about the cookies we use, the purposes for which they are used, or the third-party providers involved. You may also contact us in relation to your cookie preferences, including requests to withdraw consent or clarify how to manage cookies through the Platform or your browser.

Where your request relates to personal data processed through cookies, such requests will be handled in accordance with our Privacy Policy and applicable data protection laws. We may require you to verify your identity before responding to certain requests, particularly where this is necessary to protect your data or prevent unauthorized access.

We will respond to requests within the timeframes required by applicable law and may request additional information where necessary to properly understand and process your inquiry.

If you believe that cookies are being used in a manner inconsistent with this Policy or applicable law, you may raise a complaint with us using the contact details above. We will review such concerns in good faith and take appropriate action where required.

Where applicable, you may also have the right to lodge a complaint with a competent supervisory authority if you consider that your rights have been violated. We encourage you to contact us first so that we can attempt to resolve your concern directly.

All communications may be recorded and retained for the purpose of handling your request, maintaining records, ensuring compliance, and improving our services.

By using the Platform, you acknowledge that the contact details provided in this section constitute the primary means of communication for matters relating to this Cookie Policy.