PRIVACY POLICY

1. INTRODUCTION

This Privacy Policy explains how AVENTORA LIMITED (“we”, “us”, “our”) collects, uses, processes, and protects your personal data when you access or use the Velvet.zone platform (“Platform”, “Service”). It sets out the basis on which any personal data we collect from you, or that you provide to us, will be handled in connection with your use of 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 activity involving financial risk or reward. All gameplay is conducted within a simulated environment using tokens  (“Diamonds”), which has no monetary value and cannot be exchanged, redeemed, or withdrawn for real money or items of real-world value.

This Privacy Policy applies to all users of the Platform, regardless of location, and should be read together with our Terms and Conditions and any other policies made available within the Service. By accessing or using the Platform, you acknowledge that your personal data will be processed in accordance with this Privacy Policy and applicable data protection laws.

We are committed to protecting your privacy and handling your personal data in a transparent, secure, and lawful manner. We process personal data only where necessary to operate the Platform, provide its features, maintain security, improve user experience, and comply with legal obligations.

The Platform is not intended for use by individuals under the age of 18 (or the applicable age of majority in your jurisdiction). We do not knowingly collect personal data from minors. If we become aware that personal data has been collected from a person who does not meet the age requirements, we will take appropriate steps to delete such data.

From time to time, we may update this Privacy Policy to reflect changes in the Platform, legal requirements, or our data processing practices. Any updates will be published on the Platform with a revised “Last Updated” date, and continued use of the Service constitutes your acceptance of such changes.

If you do not agree with this Privacy Policy, you must not access or use the Platform.

2. DATA WE COLLECT

We collect and process personal data only to the extent necessary to operate the Platform, provide its features, maintain security, comply with legal obligations, and improve the overall user experience in a free-to-play social gaming environment.

We collect information that you provide directly when you create an account or interact with the Platform. This may include your email address, username, and any optional profile information you choose to provide. Where you contact us, we collect the content of your communications, including messages, attachments, and any additional information you choose to share. If you participate in promotions, surveys, or feedback requests, we may collect the information you submit in connection with those activities.

We automatically collect certain technical and usage data when you access or use the Service. This may include your IP address, device identifiers, device type, operating system, browser type and version, language settings, time zone, connection data, and log information such as timestamps, session duration, pages or features accessed, and navigation paths. We may also collect diagnostic data, crash reports, and performance metrics to ensure the stability and functionality of the Platform.

We collect detailed gameplay and interaction data as part of the operation of the Service. This includes information about your activity within the Platform, such as games played, frequency of use, session behavior, progression levels, achievements, leaderboard participation, and interactions with social features. We also collect data relating to tokens (Diamonds) (Diamonds), including balances, earning activity, spending within games, and transfers between users where such functionality is available. This data is used solely to support gameplay, progression systems, and user experience.

All data relating to tokens (Diamonds) and in-platform activity is treated strictly as gameplay data within a simulated environment. It does not represent financial information, is not linked to any real-world monetary value, and is not used for financial profiling, creditworthiness assessment, or gambling-related behavioral analysis.

We may collect communication and support data when you interact with our support channels, including records of inquiries, complaints, and resolutions. Where necessary, we may request additional information to verify your identity or to investigate and resolve account-related issues, including security incidents or suspected misuse of the Platform.

Where required for legal, compliance, or security purposes, we may collect limited verification data, such as confirmation of age, location, or eligibility. This may involve requesting documentation or additional information to ensure that users meet the requirements to access the Platform. Such data will be processed only for the specific purpose for which it is collected.

We may collect data through cookies, SDKs, and similar tracking technologies that allow us to recognize your device, store preferences, analyze usage patterns, and improve the functionality of the Platform. This may include information about your interactions with the Service, session data, and aggregated analytics. Further details on the use of such technologies are provided in our Cookie Policy.

We do not intentionally collect special categories of personal data, such as information relating to health, race, political opinions, religious beliefs, or other sensitive characteristics. Users are advised not to submit such information through the Platform. If such data is provided voluntarily, it will be handled in accordance with applicable data protection laws and only to the extent necessary to address the relevant request.

We do not knowingly collect personal data from individuals who do not meet the applicable age requirements. If we become aware that data has been collected from a minor, we will take appropriate steps to delete such data and restrict access to the Platform.

All data collected is proportionate and limited to what is necessary for the operation of a free-to-play social casino service. We do not use personal data for purposes that would introduce financial risk profiling, real-money gambling analysis, or any activity inconsistent with the non-monetary nature of the Platform.

3. HOW WE USE YOUR DATA

We use your personal data to operate, maintain, and improve the Platform and to provide you with a secure, stable, and engaging experience within a free-to-play social gaming environment.

Your data is used to create and manage your account, authenticate your access, and enable the core functionality of the Service. This includes supporting gameplay, maintaining your progress, managing tokens (Diamonds) (Diamonds), enabling participation in leaderboards and social features, and ensuring continuity of your experience across sessions and devices where applicable.

We process your data to ensure the proper functioning, performance, and reliability of the Platform. This includes monitoring system activity, diagnosing technical issues, identifying errors, preventing service disruptions, and optimizing performance. We may analyze how users interact with the Platform to improve usability, refine game mechanics, enhance features, and develop new functionality.

Your data is used to maintain the security and integrity of the Platform. This includes detecting, preventing, and investigating unauthorized access, fraudulent behavior, abuse of the Service, manipulation of gameplay systems, or breaches of our Terms and Conditions. We may use automated tools and internal monitoring systems to identify suspicious activity and to protect both the Platform and its users.

We use your data to communicate with you in relation to the Service. This includes sending essential communications such as account-related notifications, security alerts, technical updates, and changes to our Terms or policies. Where permitted, we may also provide in-platform messages or notifications related to gameplay, such as bonuses, rewards, or feature updates, which are considered part of the Service experience.

We process your data to comply with legal and regulatory obligations. This may include verifying eligibility requirements, such as age restrictions, responding to lawful requests from authorities, enforcing our legal rights, and maintaining records where required for compliance or dispute resolution purposes.

We may use aggregated, anonymized, or pseudonymized data for analytical, research, and statistical purposes. This allows us to understand overall user behavior, improve gameplay balance, optimize engagement features, and enhance the Platform without identifying individual users.

We may also use your data to enforce our Terms and Conditions and internal policies. This includes reviewing activity for compliance, investigating reported issues, resolving disputes, and taking action where necessary to maintain a fair and safe environment.

All processing of personal data is carried out in a manner consistent with the nature of the Platform as a non-monetary social casino service. Your data is not used for financial profiling, credit scoring, risk assessment, or any form of gambling-related behavioral analysis. We do not make automated decisions that produce legal or financial effects based on your gameplay activity.

To the extent that optional features or communications may require your consent under applicable law, such processing will be based on your explicit permission, and you will have the ability to withdraw consent at any time where applicable.

By using the Platform, you acknowledge and agree that your personal data is processed only for legitimate operational, security, compliance, and improvement purposes, and solely within the context of providing a free-to-play entertainment service with no real money or financial components.

4. LEGAL BASIS FOR PROCESSING

Where applicable, under the General Data Protection Regulation (GDPR) and equivalent data protection laws, we process your personal data only where we have a valid legal basis to do so. The applicable legal basis depends on the type of data concerned and the specific purposes for which it is processed, as described in this Privacy Policy.

We process personal data where it is necessary for the performance of a contract with you. This includes enabling access to the Platform, creating and managing your account, authenticating your identity, supporting gameplay functionality, maintaining your progress and tokens (Diamonds) (Diamonds), and providing customer support. Without such processing, we would not be able to provide the Service or deliver its core features.

We rely on our legitimate interests to operate, maintain, secure, and improve the Platform. These interests include ensuring system stability and performance, preventing fraud and abuse, detecting unauthorized access, maintaining fair gameplay, analyzing user behavior in order to improve features and user experience, and developing new functionality. Where we rely on legitimate interests, we carefully assess and balance our interests against your rights and freedoms, and we implement appropriate safeguards to ensure that your privacy is not adversely affected.

We process personal data where necessary to comply with legal and regulatory obligations. This may include responding to lawful requests from public authorities, complying with court orders or legal processes, enforcing our legal rights, maintaining records for compliance purposes, and ensuring that users meet applicable eligibility requirements, including age restrictions.

Where required by applicable law, we rely on your consent as a legal basis for processing certain categories of data. This may include the use of non-essential cookies, similar tracking technologies, or certain types of communications. Where processing is based on consent, you have the right to withdraw your consent at any time, and such withdrawal will not affect the lawfulness of processing carried out prior to withdrawal.

In limited and exceptional circumstances, we may process personal data where necessary to protect vital interests or to prevent serious harm, including situations involving security incidents or misuse of the Platform. Such processing will only occur where strictly necessary and proportionate.

Where we process personal data based on legitimate interests, you have the right to object to such processing in certain circumstances. Where you exercise this right, we will assess your request and cease processing unless we have compelling legitimate grounds to continue or where processing is required for the establishment, exercise, or defense of legal claims.

Where data is processed for multiple purposes, more than one legal basis may apply depending on the context. We ensure that each processing activity is supported by at least one valid legal basis and is carried out in accordance with the principles of lawfulness, fairness, transparency, data minimization, and purpose limitation.

All processing of personal data is conducted in a manner consistent with the nature of the Platform as a free-to-play social casino service. Personal data is not used for financial profiling, credit scoring, risk assessment, or any form of gambling-related behavioral analysis. We do not carry out automated decision-making that produces legal or similarly significant financial effects based on your personal data.

By using the Platform, you acknowledge that your personal data is processed only where a valid legal basis exists and solely for the purposes necessary to operate, secure, and improve a non-monetary entertainment service.

5. SOCIAL CASINO CONTEXT

Masutis operates as a free-to-play social casino platform designed solely for entertainment and social interaction. The Service simulates certain elements commonly associated with casino-style games, including chance-based mechanics, randomized outcomes, and progression systems, but does not involve real money gambling, betting, wagering, or any activity that carries financial risk or reward.

All gameplay takes place within a closed, simulated environment using virtual in-platform currency referred to as “tokens (Diamonds)”. tokens (Diamonds) are a digital feature used only to enable gameplay, track user progress, and support engagement within the Platform. They have no monetary value, are not convertible into real money or items of value, and cannot be withdrawn, redeemed, or exchanged under any circumstances. They do not represent assets, deposits, stored value, or any form of financial instrument, and their use is strictly limited to the internal functionality of the Service.

Personal data collected in connection with your use of the Platform is processed only for the purpose of supporting this social gaming environment. This includes maintaining your account, recording gameplay activity, managing virtual balances, enabling participation in leaderboards, facilitating social interactions, and ensuring that the Platform operates as intended. Data relating to tokens (Diamonds), balances, and gameplay behavior is treated as in-platform usage data only and is not linked to any real-world financial value.

We do not use personal data for financial profiling, creditworthiness assessment, income analysis, or any form of economic evaluation. The Platform does not assess or infer your financial situation, spending capacity, or risk tolerance. Because no real money activity takes place, there is no basis or need for financial or gambling-related analysis.

The Platform does not carry out gambling-related behavioral profiling. We do not monitor or analyze users for indicators such as betting behavior, loss patterns, or addiction risk, as such considerations are not applicable in a non-monetary environment. Any analysis of user behavior is limited to improving gameplay, enhancing user experience, optimizing performance, and maintaining fair and secure operation of the Service.

Any terminology used within the Platform that may resemble financial or gambling-related language, including terms such as “win”, “winnings”, “reward”, “balance”, “transaction”, or similar expressions, is used strictly within a fictional, simulated context. Such terminology is part of the user interface and gameplay design and does not reflect real financial activity, legal rights, or entitlement to value.

The Platform does not offer or facilitate the exchange of value between users in any real-world sense. While certain features may allow the transfer or sharing of tokens (Diamonds) within the Platform, such transfers are limited to virtual interactions and do not create any legal, financial, or contractual relationship between users.

We do not process personal data for the purpose of enabling or supporting any external monetization of gameplay. Any attempt by users to assign monetary value to tokens (Diamonds), accounts, or gameplay activity outside the Platform is strictly prohibited under our Terms and is not supported or recognized by the Service.

All data processing activities are designed and implemented in a manner consistent with the nature of the Platform as a non-monetary, entertainment-based service. We ensure that personal data is handled proportionately and only to the extent necessary to operate and improve the Platform, without introducing financial, gambling, or economic risk considerations.

By using the Platform, you acknowledge and agree that all gameplay occurs within a simulated environment, that no real money or items of value are involved at any stage, and that your personal data is processed solely in connection with providing, maintaining, and improving a free-to-play social gaming experience.

6. SHARING OF DATA

We do not sell, rent, or trade your personal data to third parties. We only share personal data where it is necessary to operate the Platform, provide the Service, comply with legal obligations, or protect our legitimate interests.

We may share your personal data with trusted third-party service providers who assist us in delivering and maintaining the Platform. These may include providers of cloud hosting, infrastructure, data storage, analytics, security monitoring, customer support systems, communication tools, and technical maintenance services. Such providers act as data processors on our behalf and are contractually bound to process personal data only in accordance with our instructions, to maintain confidentiality, and to implement appropriate technical and organizational measures to protect your data.

Where applicable, we may share personal data with affiliated entities or group companies for internal administrative, operational, and support purposes. This may include centralized management, system maintenance, analytics, or customer support functions. Any such sharing is limited to what is necessary and is subject to appropriate safeguards to ensure compliance with applicable data protection laws.

We may disclose personal data where required to comply with legal or regulatory obligations. This includes responding to lawful requests, subpoenas, court orders, or requests from law enforcement authorities, regulators, or other competent public bodies. We may also disclose data where necessary to enforce our legal rights, comply with applicable laws, or protect the integrity of the Platform.

We may share personal data where necessary to establish, exercise, or defend legal claims, or to investigate and prevent fraud, abuse, unauthorized access, or violations of our Terms and Conditions. This may involve sharing data with legal advisors, auditors, insurers, or other relevant parties involved in such processes.

In the event of a corporate transaction, such as a merger, acquisition, restructuring, or sale of assets, personal data may be transferred or disclosed to prospective or actual buyers, investors, or other relevant parties, subject to appropriate confidentiality obligations and safeguards. In such cases, we will take reasonable steps to ensure that your personal data continues to be protected in accordance with this Privacy Policy.

We may also share data with analytics and measurement providers to help us understand how users interact with the Platform, improve performance, and optimize user experience. Where possible, such data is aggregated, anonymized, or pseudonymized before being shared.

We may disclose limited information where necessary to protect the rights, property, or safety of the Platform, our users, or third parties. This may include situations involving suspected security incidents, technical vulnerabilities, or misuse of the Service.

Where personal data is shared with third parties, we ensure that such sharing is proportionate and limited to what is necessary for the relevant purpose. We require all recipients to comply with applicable data protection laws and to implement appropriate safeguards, including confidentiality obligations, data security measures, and restrictions on further use or disclosure.

We do not authorize any third party to use your personal data for their own independent marketing, financial profiling, credit assessment, or gambling-related analysis. Any processing carried out by third parties must be strictly aligned with the nature of the Platform as a free-to-play, non-monetary social gaming service.

We may share aggregated or anonymized data that does not identify you personally for analytical, research, or business purposes. Such data cannot be used to identify you and falls outside the scope of personal data protection laws.

All data sharing activities are carried out in a manner consistent with the nature of the Platform. Personal data is not shared for purposes involving financial transactions, monetary evaluation, or real-money gambling, and no third party is permitted to derive or assign economic value based on your activity within the Platform.

By using the Platform, you acknowledge and agree that your personal data may be shared in accordance with this section, strictly for operational, legal, security, and improvement purposes related to the provision of a free-to-play social casino service.

7. INTERNATIONAL TRANSFERS

Your personal data may be transferred to, stored in, and processed in countries outside your country of residence, including jurisdictions that may not provide the same level of data protection as your local laws. This may occur where we use international infrastructure, cloud-based services, analytics tools, or support providers that operate across multiple jurisdictions.

Where personal data originating from the European Economic Area, the United Kingdom, or other jurisdictions with data transfer restrictions is transferred internationally, we ensure that appropriate safeguards are implemented in accordance with applicable data protection laws. These safeguards may include the use of Standard Contractual Clauses approved by the European Commission or the United Kingdom, adequacy decisions where available, or other legally recognized transfer mechanisms designed to ensure that your personal data is afforded an equivalent level of protection.

In addition to contractual safeguards, we implement technical and organizational measures to protect your data during international transfers. These measures may include encryption in transit and at rest, access controls, data minimization, role-based access restrictions, monitoring of data access, and contractual limitations on further transfer or disclosure by recipients.

Where personal data is transferred to third-party service providers, such providers act as data processors and are required to process personal data strictly in accordance with our instructions. They are contractually bound to maintain confidentiality, implement appropriate security measures, and comply with applicable data protection laws. We conduct appropriate due diligence to ensure that such providers can meet these obligations.

In cases where data is transferred to jurisdictions that do not benefit from an adequacy decision, we assess the legal framework of the destination country and, where necessary, implement supplementary measures to ensure that your data remains protected. This may include technical safeguards, contractual commitments, or limitations on the type of data transferred.

International transfers may also occur where necessary for the performance of a contract with you, including the provision of access to the Platform, delivery of core functionality, or provision of customer support. In certain cases, transfers may be required to comply with legal obligations, respond to lawful requests, or establish, exercise, or defend legal claims.

You acknowledge that, due to the nature of a global online service, your personal data may be processed in multiple jurisdictions, including those where our service providers are located. We take reasonable steps to ensure that your personal data remains protected in accordance with this Privacy Policy and applicable legal requirements, regardless of where it is processed.

Where required by applicable law, you may request additional information about the safeguards in place for international transfers, including copies of relevant contractual mechanisms, subject to confidentiality and commercial considerations.

All international data transfers are carried out in a manner consistent with the nature of the Platform as a free-to-play social casino service. Personal data is not transferred for purposes involving financial processing, monetary evaluation, or real-money gambling activity, and no recipient is permitted to use your data in a manner inconsistent with the non-monetary nature of the Service.

By using the Platform, you acknowledge and agree that your personal data may be transferred internationally in accordance with this section, and that such transfers are necessary for the operation, security, and continuous improvement of the Service.

8. DATA RETENTION

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including the operation of the Platform, provision of services, maintenance of security, compliance with legal and regulatory obligations, and enforcement of our Terms and Conditions.

Personal data associated with your account is generally retained for the duration of your active use of the Platform. This includes account information, gameplay activity, tokens (Diamonds) (Diamonds) balances, interaction history, and participation in features such as leaderboards and social functionality. This data is necessary to ensure continuity of your experience and the proper functioning of the Service. Where accounts remain inactive for a prolonged period, we may, at our discretion, restrict, anonymize, or delete associated data in accordance with our internal retention policies.

If you request account deletion or otherwise cease using the Platform, we will take reasonable steps to delete or anonymize your personal data within a reasonable timeframe. However, certain data may be retained where necessary to comply with legal obligations, resolve disputes, enforce agreements, prevent fraud, or protect the integrity and security of the Platform. Such retention will be limited to what is necessary and proportionate for those purposes.

Certain categories of data may be retained for longer periods depending on their nature and purpose. For example, records relating to security incidents, suspected misuse, or violations of our Terms and Conditions may be retained for the duration required to investigate and address such matters and to prevent recurrence. Similarly, data required for legal, regulatory, or audit purposes may be retained for the period mandated by applicable law.

Technical data, system logs, and performance-related information may be retained for shorter durations, except where needed for security monitoring, incident investigation, or long-term system improvement. Where feasible, such data is aggregated, anonymized, or pseudonymized to minimize the identification of individual users.

Data relating to gameplay, tokens (Diamonds) (Diamonds), and in-platform interactions is retained only for as long as necessary to support gameplay functionality, maintain account status, ensure fairness, and preserve system integrity. Such data is not treated as financial or transactional data and is not retained for accounting, financial reporting, or monetary tracking purposes.

We may retain limited backup copies of data for operational continuity, disaster recovery, and security purposes. Such backups are stored securely and are subject to retention limits and access controls. Data in backups may not be deleted immediately; it will be overwritten or securely removed in accordance with backup lifecycle policies.

In some cases, personal data may be retained in a restricted or archived form, where active use is no longer necessary, but retention is required for legal or evidentiary purposes. Access to such data is limited and subject to appropriate safeguards.

When personal data is no longer required for the purposes for which it was collected, we will securely delete, anonymize, or otherwise dispose of it in accordance with applicable data protection laws and industry best practices. Deletion processes are designed to ensure that data cannot be reconstructed or recovered.

Retention periods may vary depending on the category of data, the nature of the processing, and applicable legal requirements. We periodically review our retention practices to ensure that personal data is not kept longer than necessary.

All data retention practices are implemented in a manner consistent with the nature of the Platform as a free-to-play social casino service. Personal data is not retained for financial analysis, credit assessment, or real-money gambling, and no long-term retention is based on economic or monetary considerations.

By using the Platform, you acknowledge and agree that your personal data will be retained only for legitimate operational, legal, security, and improvement purposes, and strictly within the context of providing a non-monetary entertainment service.

9. DATA SECURITY

We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful access, loss, misuse, alteration, or disclosure. These measures are designed to ensure a level of security appropriate to the nature of the data processed, the scope of processing activities, and the risks associated with the operation of an online platform.

Our security framework includes, where appropriate, encryption of data in transit and at rest, role-based access controls, authentication mechanisms, secure system architecture, network protection measures, and continuous monitoring of systems and infrastructure. Access to personal data is restricted to authorized personnel and service providers who require such access for legitimate operational purposes and who are subject to confidentiality obligations.

We maintain internal policies, procedures, and governance measures designed to safeguard personal data. This includes staff training on data protection and security practices, strict access management protocols, secure development practices, and defined processes for identifying, reporting, and responding to security incidents. We regularly review and update our security measures to address evolving risks, technological developments, and industry best practices.

We take reasonable steps to ensure that any third-party service providers with access to personal data implement appropriate security measures and comply with applicable data protection laws. This includes contractual obligations relating to data protection, confidentiality, and incident management. We may also conduct due diligence and periodic reviews of such providers where appropriate.

We operate monitoring and detection systems to identify unusual or suspicious activity, including unauthorized access attempts, misuse of accounts, or potential vulnerabilities within the Platform. Where a potential security incident is identified, we take appropriate steps to investigate, contain, and remediate the issue in a timely manner.

We have procedures in place to respond to personal data breaches. Where required by applicable law, we will notify relevant supervisory authorities and, where appropriate, affected users within the timeframes prescribed by law. We maintain incident response protocols to ensure that any breach is managed effectively and that appropriate corrective measures are implemented.

While we take reasonable and proportionate steps to protect personal data, no system, network, or method of transmission over the internet can be guaranteed to be completely secure. You acknowledge that there are inherent risks associated with the use of online services and that the transmission of data over the internet may be subject to interception or unauthorized access.

You are responsible for maintaining the confidentiality and security of your account credentials. This includes choosing a strong password, keeping it confidential, and not sharing your login details with any third party. You agree to notify us immediately if you suspect any unauthorized access to your account or any security breach. We are not responsible for any loss or damage resulting from your failure to safeguard your account credentials.

We may implement additional security measures where necessary, including temporary restrictions, additional verification steps, or account monitoring, in order to protect the Platform and its users from threats or misuse.

All security measures are implemented in a manner consistent with the nature of the Platform as a free-to-play social casino service. As the Platform does not involve real money transactions or financial data, the primary focus of our security measures is on protecting account integrity, personal data, and the stability of the Service, rather than financial systems.

By using the Platform, you acknowledge and agree that we take reasonable and appropriate steps to protect your personal data, but that absolute security cannot be guaranteed, and that your use of the Service involves inherent risks associated with digital and online environments.

10. YOUR RIGHTS

Depending on your location and the data protection laws applicable to you, including the General Data Protection Regulation (GDPR) and equivalent legislation, you may have a range of rights in relation to your personal data. These rights are subject to certain conditions, limitations, and exceptions under applicable law and must be exercised in accordance with the procedures described in this section.

You have the right to request access to the personal data we hold about you, together with information about how and why it is processed. This includes the purposes of processing, the categories of personal data involved, the recipients or categories of recipients with whom the data has been shared, the envisaged retention period, and the safeguards in place for international transfers. Where applicable, you may request a copy of your personal data in a structured, commonly used, and machine-readable format.

You have the right to request the correction or rectification of inaccurate, incomplete, or outdated personal data. Where appropriate, you may also request that we supplement the data we hold about you to ensure its accuracy and completeness. We may verify the accuracy of the new data before making any changes.

You have the right to request the deletion of your personal data in certain circumstances. This right may apply where the data is no longer necessary for the purposes for which it was collected, where you withdraw consent, and no other legal basis applies, or where the data has been processed unlawfully. However, this right is not absolute and may be limited to where we are required to retain data for legal, regulatory, security, or legitimate business purposes, including the establishment, exercise, or defense of legal claims or the prevention of fraud and abuse.

You have the right to request the restriction of processing in specific circumstances. This may apply where you contest the accuracy of the data, where processing is unlawful, but you oppose deletion, or where we no longer require the data, but you need it for the establishment, exercise, or defense of legal claims. During the period of restriction, we may continue to store our data, but will limit its use to what is permitted under applicable law.

You have the right to object to the processing of your personal data where such processing is based on our legitimate interests. Where you exercise this right, we will assess your request and cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or where processing is necessary for legal purposes.

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before withdrawal and will apply only to future processing. Where applicable, you may also manage your preferences through settings within the Platform or through cookie management tools.

You may have the right to data portability, allowing you to receive certain personal data in a structured, commonly used, and machine-readable format and, where technically feasible, to have that data transmitted directly to another data controller. This right applies only where processing is based on consent or contract and is carried out by automated means.

You have the right not to be subject to a decision based solely on automated processing, including profiling, that produces legal or similarly significant effects. However, the Platform does not carry out automated decision-making that produces such effects, and no decisions are made based on gameplay or behavioral data that would impact you in a legal or financial sense.

You have the right to lodge a complaint with a competent supervisory authority if you believe that your personal data has been processed in violation of applicable data protection laws. The relevant authority will typically be in the country where you reside, work, or where the alleged infringement occurred. Where possible, we encourage you to contact us first so that we can attempt to resolve your concern directly and efficiently.

To exercise any of your rights, you may contact us using the details provided in this Privacy Policy. We may require you to verify your identity before processing your request to protect your personal data and prevent unauthorized access. We may also request additional information where necessary to clarify the scope of your request or to locate the relevant data.

We will respond to your request within the timeframes required by applicable law, typically within one month, although this period may be extended where permitted by law in the case of complex or multiple requests. Where permitted, we may refuse or limit requests that are manifestly unfounded, excessive, repetitive, or that would adversely affect the rights and freedoms of others or compromise the security or integrity of the Platform.

All rights are exercised in a manner consistent with the nature of the Platform as a free-to-play social casino service. Personal data processed within the Platform relates exclusively to a non-monetary environment and does not involve financial profiling, credit scoring, risk assessment, or gambling-related behavioral analysis. No rights under this section extend to any expectation of financial value, economic benefit, or real-world entitlement arising from gameplay or in-platform activity.

By using the Platform, you acknowledge that your rights are subject to the limitations set out under applicable law and that we will handle all requests in accordance with our obligations as a data controller, taking into account the nature of the Service and the need to maintain a secure, fair, and functional environment for all users.

11. COOKIES

We use cookies and similar technologies to operate the Platform, ensure its proper functionality, enhance performance, and improve your overall user experience. Cookies are small text files that are placed on your device when you access or use the Service. They enable us to recognize your device, maintain session continuity, remember your preferences, and collect information about how the Platform is used.

Cookies may be set by us (first-party cookies) or by third-party service providers acting on our behalf (third-party cookies). Similar technologies, such as local storage, SDKs, tracking pixels, or device identifiers, may also be used for comparable purposes. For this Policy, all such technologies are referred to collectively as “cookies”.

Some cookies are strictly necessary for the operation of the Platform. These cookies support essential functions such as user authentication, session management, security controls, fraud prevention, and access to core features of the Service. Without these cookies, the Platform cannot function properly, and they cannot be disabled.

We may also use cookies to collect information about how users interact with the Platform. These cookies help us understand usage patterns, including pages visited, features used, session duration, navigation paths, and general engagement with gameplay and functionality. This information is used to monitor performance, identify technical issues, optimize system stability, and improve the design and usability of the Platform. Where possible, such data is aggregated, anonymized, or pseudonymized.

In addition, cookies may be used to remember your preferences and settings, such as language selection, interface customization, and other user-specific configurations. This allows us to provide a more consistent and personalized experience across sessions.

We may use cookies to support analytics and measurement activities carried out by third-party providers. These providers help us understand how the Platform is used, measure performance, and improve features. Any data collected through such cookies is processed in accordance with applicable data protection laws and subject to contractual safeguards. We do not permit third parties to use such data for their own independent purposes, including marketing, financial profiling, or gambling-related analysis.

Where required by applicable law, we will request your consent before placing non-essential cookies on your device. When you first access the Platform, you will be presented with a cookie banner or 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 or through your browser configuration.

You can also manage or disable cookies through your browser settings. Most browsers allow you to block or delete cookies, restrict certain types of cookies, or receive notifications when cookies are placed. However, please note that disabling cookies, particularly essential cookies, may affect the functionality, performance, and availability of certain features of the Platform.

Cookies may be stored on your device for different periods depending on their purpose. Session cookies are temporary and are deleted when you close your browser, while persistent cookies remain on your device for a defined period or until manually deleted. Retention periods for cookies are determined based on their function and necessity.

We may update our use of cookies from time to time to reflect changes in technology, legal requirements, or the functionality of the Platform. Any significant changes will be communicated through the Platform or reflected in this Privacy Policy and our Cookie Policy.

All use of cookies is aligned with the nature of the Platform as a free-to-play social casino service. Cookies are used strictly to support functionality, performance, security, and user experience, and are not used for financial tracking, credit assessment, or any form of gambling-related profiling.

For more detailed information about the types of cookies, we use, their specific purposes, and how long they are retained, please refer to our Cookie Policy.

By using the Platform and managing your preferences through the available consent tools, you acknowledge and agree to the use of cookies as described in this section, subject to your choices and applicable legal requirements.

12. CHANGES TO THIS POLICY

We reserve the right, at our sole discretion, to modify, update, amend, or replace this Privacy Policy at any time to reflect changes in the Platform, our data processing practices, applicable laws, regulatory requirements, or industry standards. Such changes may affect how and why we collect, use, store, or share your personal data.

Any updated version of this Privacy Policy will be made available 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 your personal data is processed, we may provide advance notice or specify a future effective date before such changes come into force.

It is your responsibility to review this Privacy Policy periodically to ensure that you remain informed about how your personal data is processed. Your continued access to or use of the Platform after any changes have taken effect constitutes your acceptance of the updated Privacy Policy and your agreement to be bound by it.

Where changes are material and significantly impact your rights, we may, where reasonably practicable, provide additional notice. This may include in-platform notifications, email communications, or other prominent messaging. However, we are not obligated to provide individual or direct notice of every modification, and failure to receive or review such notice does not affect the validity or applicability of the updated Policy.

If you do not agree with any changes to this Privacy Policy, you must immediately discontinue use of the Platform. Where applicable, you may also exercise your rights, including requesting deletion of your personal data, subject to the conditions and limitations described in this Policy and applicable law.

We may also update this Privacy Policy to reflect the introduction of new features, services, or functionalities, or changes to existing ones. Where such updates involve new categories of personal data or new purposes of processing, we will update this Policy accordingly to ensure transparency and compliance with legal requirements.

Non-material changes may be made at any time without prior notice. These may include corrections of typographical errors, clarifications of existing provisions, 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, consistency, and accuracy of the Policy.

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.

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

All changes to this Privacy 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 processing, financial profiling, or gambling-related data use, and any changes will remain aligned with the non-monetary nature of the Service.

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

13. CONTACT

If you have any questions, concerns, or requests regarding this Privacy Policy or the way your personal data is processed, you may contact us using the details provided below. We aim to handle all inquiries in a timely, transparent, and professional manner, in accordance with applicable data protection laws.

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 exercise your data protection rights, including requests for access, correction, deletion, restriction of processing, objection, or data portability. To protect your personal data, we may require you to verify your identity before processing your request. This may include requesting additional information necessary to confirm that you are the rightful account holder.

We will respond to requests relating to your personal data within the timeframes required by applicable law. In most cases, this will be within one month of receiving a valid request, although this period may be extended where permitted by law in cases of complex or multiple requests. Where we are unable to fulfill a request, we will explain the extent required by law.

If you contact us with a complaint regarding the processing of your personal data, we will review your concerns in good faith and take appropriate steps to address the issue. While we do not guarantee any specific outcome, we are committed to resolving issues fairly and in accordance with our legal obligations.

Where required under applicable law, we may designate a Data Protection Officer (DPO) or a responsible contact for data protection matters. If such a role is in place, the relevant contact details will be made available through the Platform or upon request.

If you are located in the European Economic Area, the United Kingdom, or another jurisdiction with applicable data protection laws, you also have the right to lodge a complaint with a competent supervisory authority if you believe that your personal data has been processed in violation of applicable law. We encourage you to contact us first so that we can attempt to resolve your concern directly.

All communications with us may be recorded and retained for the purposes 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 and official means of communication between you and us in relation to data protection matters and this Privacy Policy.