Privacy Policy

This Privacy Policy explains how we collect, use, disclose, protect, and retain personal information when you visit and use the website villento-play.com, including the review page operated under the project name Villento Casino, and when you use our online casino services as a player. It applies to website visitors, registered players, and other individuals whose personal information we process in connection with our services.

This Privacy Policy is intended to meet the requirements of applicable Canadian privacy laws (including the Personal Information Protection and Electronic Documents Act - PIPEDA - and substantially similar provincial legislation), while also aligning, where relevant, with international best practices such as the EU General Data Protection Regulation (GDPR) and Mexican data protection regulations.

By accessing or using villento-play.com, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, you should not use our website or services.

Effective date: 1 January 2026
Last updated: January 2026

Who We Are

The website villento-play.com, including the review content under the project name Villento Casino, is operated for Canadian players (excluding Ontario) in connection with the online gaming brand Villento Casino.

Data Controller / Operator

Legal entity: Fresh Horizons Ltd
Legal form: Limited company (Ltd)
Registered corporate address: 4 The Office, North Sound Road, Zenes Building, Grand Cayman, Cayman Islands
Corporate registration jurisdiction: Cayman Islands / British Virgin Islands (exact company registration number not specified in this document)
Gaming permit: Interactive gaming permit issued by the Kahnawake Gaming Commission, Canada (permit number not specified here; confirmed active via the Commission's registry as of May 2024)

Role and Responsibility

For the purposes of this Privacy Policy, Fresh Horizons Ltd determines the purposes and means of processing personal information collected through villento-play.com and acts as the "organization" or "data controller" under applicable privacy laws.

Data Protection Contact

We have designated a data protection contact team responsible for privacy and data protection matters.

Postal address (privacy matters):
Data Protection Officer / Privacy Team
Fresh Horizons Ltd
4 The Office, North Sound Road
Zenes Building, Grand Cayman
Cayman Islands
Online contact: You may contact us through the customer support and contact channels indicated on https://villento-play.com (including any "Contact Us", live chat, or support ticket functionality). Please clearly mark your message with "Privacy" or "Data Protection".

We will ensure that privacy-related requests received via these channels are forwarded to the appropriate person or team.

What Personal Data We Collect

Information You Provide to Us

Registration and account data: When you create an account or otherwise interact with villento-play.com, we may collect your full name, date of birth, address, country of residence, email address, telephone number, preferred language, and login credentials.
Verification (KYC/AML) data: To comply with gaming, KYC (Know Your Customer), and anti-money laundering (AML) obligations, we may request identity documents (such as ID card, passport, driver's licence), proof of address, and additional information required by regulatory authorities (e.g., occupation, source of funds declarations).
Customer support communications: When you contact customer support or our privacy team (e.g., via live chat, forms, or other channels on villento-play.com), we collect the information you provide and any related metadata (time, channel, language).
Marketing and preference data: Your preferences regarding newsletters, promotional offers, communication channels, and similar settings.

Technical and Device Data

Technical identifiers: IP address, device identifiers, browser type and version, operating system, language settings, time zone, referring URLs, and information about your connection to our servers.
Usage and log data: Date and time of visits, pages viewed, clicks, navigation paths, login/logout times, session duration, and technical error logs.

Payment and Financial Data

Payment details: Limited payment information such as the type of payment method used (e.g., credit card, e-wallet, bank transfer), masked card numbers or account identifiers, transaction IDs, and payment status. Full payment card details are typically processed directly by our regulated payment service providers and not stored in full by us.
Transaction history: Deposits, withdrawals, bets, wins, losses, bonuses credited or redeemed, and other account balance movements.

Behavioral and Gaming Data

Gameplay data: Betting history, games played, session times, stake sizes, outcomes, bonuses used, voluntary limits set (e.g., deposit or loss limits), and self-exclusion information.
Interaction data: Clicks on promotions, responses to campaigns, engagement with emails and on-site messages, and responses to surveys or feedback forms.

Cookies and Similar Technologies

Cookies: Small text files stored on your device that help us recognize your browser, maintain sessions, remember preferences, and understand how you interact with villento-play.com and the Villento Casino content.
Similar technologies: Web beacons, pixels, tags, and local storage objects used for analytics, fraud prevention, and marketing (where permitted by law and, where required, based on your consent).

Further details about cookies are provided in the "Cookies & Tracking Technologies" section below.

Legal Basis for Processing

Our collection and use of personal information is guided primarily by Canadian privacy laws (including PIPEDA and substantially similar provincial laws). For users located in the European Union (EU), European Economic Area (EEA), or Mexico, we also align our practices with the principles of the GDPR and Mexican data protection law to the extent applicable.

Consent

Express consent: We obtain your consent where required by law, for example when you register an account, accept this Privacy Policy, choose to receive marketing communications, or accept non-essential cookies.
Implied consent: In certain cases permitted by Canadian law, we may rely on your implied consent (for example, when you contact us and reasonably expect us to use your information to respond).
Withdrawal: You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice. See the "Your Rights" section below.

Contractual Necessity

We process personal information where it is necessary to enter into and perform our contract with you, including:
- creating and managing your player account;
- processing deposits, wagers, and withdrawals;
- providing games and related services;
- offering customer support and handling your requests.

Legitimate Interests / Reasonable Purposes

We process personal information for purposes that we consider reasonable in the circumstances and that are compatible with your expectations, such as:
- preventing and detecting fraud, abuse, and unauthorized access;
- ensuring network and information security;
- improving and personalizing our services and website;
- conducting internal analytics and business planning.
Where GDPR applies, these activities are based on our legitimate interests, balanced against your fundamental rights and freedoms.

Legal and Regulatory Obligations

We process and retain certain information because we are legally required to do so, including:
- compliance with KYC/AML regulations and gaming regulatory frameworks under the Kahnawake Gaming Commission;
- record-keeping, audit, and reporting obligations;
- responding to lawful requests from public authorities, courts, or regulators;
- enforcing self-exclusion and responsible gambling measures where required by law or regulator.

Protection of Vital Interests and Others

In rare cases, we may process personal information to protect your vital interests or those of others, for example where we believe there is a serious risk of harm or financial crime.

Purpose of Processing

Provision of Casino and Website Services

Account management: To register and maintain your account, authenticate you, and provide access to games and related services on villento-play.com.
Transactions: To process deposits, bets, wins, withdrawals, and bonuses, including necessary communications regarding payments and account balances.
Customer support: To respond to inquiries, resolve issues, and provide technical assistance.

Regulatory Compliance and Risk Management

KYC/AML and responsible gambling: To verify your identity, detect and prevent fraud and money laundering, manage self-exclusion and voluntary limits, and comply with gaming and financial regulations.
Record-keeping: To retain records required for audits, regulatory inspections, and dispute resolution.

Improvement, Personalization, and Analytics

Service improvement: To analyze usage of villento-play.com and the Villento Casino content, identify technical issues, and improve performance and usability.
Personalization: To tailor content, game recommendations, and certain offers based on your preferences and prior interactions, where permitted by law and supported by an appropriate legal basis.
Statistics and business analytics: To produce aggregated statistics and reports that do not identify you directly, for internal planning and management.

Marketing and Communications

Direct marketing: To send you newsletters, promotional offers, loyalty program updates, and information about new games and features, where allowed by law and based on your consent or another lawful basis.
Service messages: To send important non-marketing communications, such as changes to our Terms & Conditions, Privacy Policy, security alerts, and account notifications.

Fraud Prevention and Security

Security monitoring: To monitor logins and activities for unusual patterns, protect against unauthorized access, and maintain the integrity of our systems.
Incident handling: To investigate and respond to suspected or actual security incidents, fraud, and misuse.

Disclosure & Sharing

Service Providers and Technical Partners

IT and hosting providers: Companies that provide data hosting, cloud infrastructure, and technical support necessary to operate villento-play.com and related gaming services.
Payment service providers: Regulated financial and payment institutions that process deposits, withdrawals, and other financial transactions on our behalf.
Analytics and anti-fraud tools: Vendors that assist with analytics, fraud detection, identity verification, and security monitoring.

These third parties are contractually required to process personal information only on our instructions and to implement appropriate safeguards.

Regulators, Authorities, and Dispute Bodies

Gaming regulators: The Kahnawake Gaming Commission and, where applicable, other competent gaming authorities, in connection with licensing, audits, reporting, or complaints.
Law enforcement and public authorities: Where required by applicable law, court order, or lawful request, or where we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

Affiliates and Group Entities

Group relationships: Villento Casino is part of the broader Casino Rewards Group network. We may share necessary information within such related entities for:
- group-level risk management and fraud prevention;
- customer support and account administration where services are centralized;
- marketing and loyalty program management, where permitted by law and in line with your preferences.

Marketing and Advertising Partners

Advertising networks and analytics partners: Where allowed and subject to your consent (where required), we may share limited pseudonymized information (e.g., cookie identifiers, general location data) with advertising and analytics partners to measure the effectiveness of campaigns and to deliver relevant online ads.

Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of our business, personal information may be transferred as part of the transaction, subject to appropriate confidentiality and data protection safeguards.

We do not sell your personal information in the ordinary sense of the word. Any sharing of information with third parties is limited to the purposes and categories described in this Privacy Policy and subject to applicable law.

International Transfers

Personal information collected through villento-play.com may be stored and processed in Canada and in other jurisdictions where we or our service providers operate. These may include the Cayman Islands, British Virgin Islands, the European Union, and other countries.

Cross-Border Transfers

Corporate locations: Because Fresh Horizons Ltd has its registered corporate address outside Canada (in the Cayman Islands) and corporate ties to the British Virgin Islands, some information may be accessed or processed from these jurisdictions.
Service providers: Our third-party service providers may be located in Canada, the EU/EEA, the United Kingdom, the United States, or other regions. Their processing locations will depend on their infrastructure and services.

Safeguards for International Transfers

Contractual protections: Where required (for example, for transfers of personal data from the EU/EEA), we use appropriate contractual safeguards such as the European Commission's Standard Contractual Clauses or other equivalent mechanisms approved by regulators.
Regulatory alignment: For Canadian residents, we follow PIPEDA guidance on cross-border data flows, informing you that your information may be transferred to and processed in foreign jurisdictions where it may be accessible to law enforcement and regulatory authorities under the laws of those jurisdictions.
Vendor due diligence: We select service providers that implement appropriate security measures and that commit to processing personal information in line with applicable privacy requirements.

Data Retention

We retain personal information only for as long as necessary to fulfil the purposes described in this Privacy Policy, to comply with legal and regulatory obligations, to resolve disputes, and to enforce our agreements. Retention periods may vary depending on the type of information and applicable law.

General Retention Principles

Account and identification data: Typically retained for the duration of your account and for a period of up to 5 years after account closure, unless a longer period is required by law (e.g., AML regulations may require up to 7 years of retention).
Transaction and gaming data: Retained for at least 5 - 7 years from the date of the relevant transaction or event, to meet accounting, tax, regulatory, and dispute resolution requirements.
Customer support records: Retained for up to 3 - 5 years after the issue is resolved, depending on the nature of the inquiry and related legal requirements.
Marketing data: Retained until you opt out or withdraw your consent, or for a shorter period if required by law. We may retain limited records (e.g., your email and opt-out status) to ensure we respect your choice.
Technical logs: Server logs and security logs are generally retained for a shorter period (typically from a few months up to 2 years), unless needed longer for security investigations or legal purposes.

Deletion and Anonymization

When personal information is no longer required for the purposes described above, we will securely delete it or irreversibly anonymize it so that it no longer identifies you.
We may retain anonymized or aggregated information (which cannot be linked back to you) for statistical, analytical, or business purposes.

Criteria Used to Determine Retention Periods

the nature and sensitivity of the personal information;
the potential risk of harm from unauthorized use or disclosure;
the purposes for which we process it and whether those purposes can be achieved by other means;
legal, regulatory, tax, accounting, and reporting obligations;
limitation periods for potential claims or regulatory investigations.

Your Rights

Your rights depend on your place of residence and the laws that apply. We strive to provide a high level of transparency and control, and we will honor applicable rights under Canadian law, as well as rights inspired by the GDPR and Mexican privacy law where relevant.

Rights under Canadian Privacy Law

Right of access: You may request confirmation as to whether we hold personal information about you and obtain access to that information, subject to lawful restrictions.
Right to correction (rectification): You may request correction of inaccurate, incomplete, or outdated personal information.
Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time, subject to legal or contractual restrictions and reasonable notice. This may affect our ability to provide certain services.
Right to complain: You may submit a complaint to us and, if unresolved, escalate it to the competent privacy regulator (see "Complaints & Contacts").

Rights Aligned with GDPR (for EU/EEA Users)

Where the GDPR applies (for example, if you are located in the EU/EEA and we are subject to its scope for specific processing activities), you may have the following additional rights:

Right to restriction: To request that we restrict processing of your personal data in certain circumstances.
Right to object: To object to processing based on our legitimate interests, including profiling, and to object at any time to processing for direct marketing.
Right to data portability: To receive the personal data you provided to us in a structured, commonly used, and machine-readable format and to request that we transmit it to another controller where technically feasible.
Right to erasure: To request deletion of your personal data in specific circumstances, for example where it is no longer necessary for the purposes for which it was collected and no legal obligation requires its retention.

Rights under Mexican Privacy Law (ARCO Rights)

For individuals located in Mexico, we align our practices with the Federal Law on Protection of Personal Data Held by Private Parties and related regulations. This includes the following ARCO rights:

Access: To know what personal data we hold about you and the conditions of its processing.
Rectification: To request correction of your personal data if it is inaccurate or incomplete.
Cancellation: To request that we stop processing and, where appropriate, delete your personal data when it is no longer necessary for the purposes described, subject to legal retention obligations.
Opposition: To object to the processing of your personal data for specific purposes, including marketing, in justified cases.

We will consider and respond to such requests in line with applicable Mexican regulations where they apply to our processing activities.

How to Exercise Your Rights

Submit a request: You may submit a privacy request by contacting us through the support or contact channels provided on villento-play.com, clearly indicating that your request is related to privacy or data protection. You may also write to our postal address to the attention of the Data Protection Officer / Privacy Team.
Provide necessary information: For security reasons, we may ask you to provide information to verify your identity (e.g., login information or account details) before fulfilling your request.
Response timeframe: We aim to respond to all valid requests within 30 days of receipt or within a shorter or longer period if required or permitted by applicable law. If we need more time due to complexity or volume, we will inform you of the extension and reasons.
Fees: Requests are generally handled free of charge. However, where permitted by law, we may charge a reasonable fee or refuse to act on requests that are manifestly unfounded, repetitive, or excessive.

Please note that some rights may be limited by legal obligations, regulatory requirements, or the rights of other individuals. If we cannot fully comply with your request, we will explain the reasons, subject to legal restrictions.

Cookies & Tracking Technologies

Types of Cookies We Use

Strictly necessary cookies: Session cookies required for the functioning of villento-play.com, such as authentication, security, and maintaining your session while you navigate pages, including Villento Casino content.
Functional cookies: Cookies that remember your preferences (e.g., language, region, saved settings) to provide a more personalized experience.
Analytics cookies: First- or third-party cookies used to collect information about how visitors use our website, such as pages visited, time spent, and errors encountered, helping us improve performance and design.
Advertising and targeting cookies: Cookies set by us or third-party partners to deliver relevant advertisements and measure the effectiveness of campaigns, where permitted by law and, where required, based on your consent.

Session vs. Persistent Cookies

Session cookies: Temporary cookies that are deleted when you close your browser.
Persistent cookies: Cookies stored on your device for a longer period, until they expire or are deleted, used for functions such as remembering your preferences or login status.

Managing Cookies

Browser settings: Most browsers allow you to manage cookies by blocking or deleting them. Please refer to your browser's help section for instructions. If you block essential cookies, certain features of villento-play.com may not function properly.
On-site controls: Where required by law, we provide cookie banners or preference tools allowing you to accept or reject non-essential cookies (such as analytics or advertising cookies).
Third-party opt-outs: Some third-party analytics or advertising providers may offer their own opt-out mechanisms. Details may be provided in our cookie notices or within the third parties' privacy documentation.

Data Security

We implement a range of technical and organizational measures designed to protect personal information from unauthorized access, use, alteration, or destruction, in line with industry standards and applicable legal requirements.

Technical Measures

Encryption in transit and at rest: Data transmitted between your browser and villento-play.com is protected using modern encryption protocols (such as TLS 1.2 or higher). Where feasible, sensitive data is also encrypted at rest.
Access controls: Access to personal information is restricted to authorized personnel and service providers who require it for legitimate business purposes and are subject to confidentiality obligations.
Network and application security: Firewalls, intrusion detection and prevention systems, anti-malware tools, and secure development practices are used to reduce vulnerabilities and protect systems from attacks.
Authentication and session controls: Strong authentication mechanisms are employed, and sessions may be monitored for suspicious activity. Multi-factor authentication may be used for certain administrative or high-risk access.

Organizational Measures

Policies and training: Staff with access to personal information receive training on privacy and security obligations and are bound by internal policies and confidentiality requirements.
Vendor management: We conduct due diligence on key service providers and require them to implement appropriate security and privacy protections by contract.
Incident response: We maintain procedures for identifying, responding to, and mitigating suspected or actual data breaches. Where required by law, we will notify affected individuals and relevant authorities of qualifying security incidents.

While we take appropriate steps to protect your information, no system can be fully secure. You are responsible for keeping your account credentials confidential and for using up-to-date security measures on your own devices.

Complaints & Contacts

Contacting Us

Postal address (privacy matters):
Data Protection Officer / Privacy Team
Fresh Horizons Ltd
4 The Office, North Sound Road
Zenes Building, Grand Cayman
Cayman Islands
Online contact: Please use the contact channels provided on https://villento-play.com (such as live chat or contact forms) and clearly state that your inquiry relates to privacy or data protection.

Internal Complaint Procedure

Step 1 - Submit your complaint: Describe your concern in detail, including relevant dates, account identifiers, and any supporting documentation. Send it via the online channels or postal address listed above.
Step 2 - Acknowledgment: We will acknowledge receipt of your complaint as soon as reasonably possible, generally within 5 - 10 business days.
Step 3 - Investigation: We will investigate your complaint, which may include reviewing internal records and contacting you for additional information if necessary.
Step 4 - Response: We aim to provide a substantive response within 30 days of receiving a complete complaint, or within any timeframe required by applicable law. If we cannot meet this timeframe, we will inform you of the reason and any extension.

Escalation to Privacy Regulators

If you are not satisfied with our response, you may have the right to lodge a complaint with a supervisory authority:

Canada (federal): Office of the Privacy Commissioner of Canada (OPC) - see https://www.priv.gc.ca for contact details and complaint procedures.
Provincial commissioners (where applicable): In some provinces (e.g., Alberta, British Columbia, Quebec), you may contact the relevant provincial privacy commissioner. Contact information is available on their official websites.
Mexico: For individuals in Mexico, complaints may be submitted to the National Institute for Transparency, Access to Information and Personal Data Protection (INAI). See https://home.inai.org.mx for details.
EU/EEA: If the GDPR applies to you, you may lodge a complaint with your local data protection authority in the EU/EEA. A list of supervisory authorities and contact details is available on the website of the European Data Protection Board.

Please note that the Kahnawake Gaming Commission provides a dispute resolution mechanism primarily for gaming-related issues. Privacy-specific complaints should generally be addressed to us and to the relevant privacy regulators listed above.

Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technical developments. Any updated version will be posted on villento-play.com and will indicate the date of the latest revision.

Notification of Changes

Minor changes: For non-material changes (for example, clarifications or updates that do not significantly affect your rights), we may update the Privacy Policy without specific individual notice, other than updating the "Last updated" date.
Material changes: For significant changes that materially affect how we collect, use, or share your personal information, or that significantly affect your rights, we will provide additional notice, which may include:
- email notifications to the address associated with your account;
- prominent notices or banners on villento-play.com (including on the Villento Casino page);
- notifications in your account dashboard, where applicable.

Advance Notice and Your Options

Notice period: Where feasible and required by law, we will provide at least 30 days' advance notice before material changes take effect.
Your choices: If you do not agree with the updated Privacy Policy, you may:
- adjust your privacy and cookie preferences as offered in the updated notice;
- stop using villento-play.com and request account closure, subject to any legal or regulatory obligations we must fulfil (for example, retention of certain records).

The continued use of villento-play.com after the effective date of an updated Privacy Policy will constitute your acknowledgment of the changes, to the extent permitted by applicable law. This Privacy Policy does not create contractual rights or obligations beyond those already contained in the Terms & Conditions governing your use of our services.