SilverGames Cookie Policy

Version 1.1 — Effective as of October 22, 2026

Operated by Cogwheel Group Ltd, Company number ΗΕ 482634, 236 Strovolou Avenue, Strovolos, 2048 Nicosia, Cyprus.

Platform: www.silvergames.us

DRAFT — FOR INTERNAL REVIEW

Contents

  1. About This Policy

  2. What Are Cookies and Similar Technologies

  3. Why We Use Cookies

  4. Categories of Cookies We Use

  5. Third-Party Cookies and Service Providers

  6. How Long Cookies Last

  7. Managing Your Cookie Preferences

  8. Do Not Track and Opt-Out Preference Signals

  9. Consequences of Disabling Cookies

  10. Changes to This Cookie Policy

  11. Document Integration

  12. Contact Us

  13. Change Log

1. ABOUT THIS POLICY

This Cookie Policy explains how SilverGames uses cookies and similar technologies when you visit or interact with www.silvergames.us. It should be read together with our Privacy Policy, which describes more broadly how we collect, use, and protect your personal information.

This Cookie Policy does not stand alone. It forms part of, and is incorporated by reference into, the SilverGames Terms of Use, and is to be read together with the Terms of Use, the Sweepstakes Rules, the Privacy Policy, and the Responsible Social Gaming Policy (collectively, the "Platform Documents"). When you accept the Terms of Use and the Sweepstakes Rules at registration, you accept all of the Platform Documents, and you acknowledge and consent to the use of cookies and similar technologies described in this Policy, subject to the preferences you set as described in Section 7.

The SilverGames platform is owned and operated by Cogwheel Group Ltd, Company number ΗΕ 482634, a Cyprus limited liability company having its registered office at 236 Strovolou Avenue, Strovolos, 2048 Nicosia, Cyprus. In this Policy, "SilverGames," "the Company," "we," "us," and "our" refer to Cogwheel Group Ltd. Although the Operator is incorporated in Cyprus, the Services are offered solely to persons located in permitted States of the United States, and all operations and services targeting U.S. customers are conducted in compliance with applicable U.S. federal and state law.

2. WHAT ARE COOKIES AND SIMILAR TECHNOLOGIES

A cookie is a small text file placed on your device by a website you visit. Cookies are widely used to make websites work, to make them work more efficiently, and to provide information to the site operator.

We also use technologies that function similarly to cookies, including:

  • Web beacons and pixels — small graphic files embedded in pages or emails that record whether a page has been viewed or an email opened.

  • Local storage — data stored by your browser that persists between sessions, used to remember settings and improve performance.

  • Software development kits and tags — code included in our pages that allows a third-party service, such as an analytics or fraud prevention provider, to function.

  • Device and browser identifiers — technical signals, including device fingerprint data, used to recognise a device across sessions for security and fraud prevention purposes.

In this Policy, all of these are referred to together as "cookies." A cookie may be a "first-party" cookie, set by SilverGames, or a "third-party" cookie, set by a service provider whose technology we use.

3. WHY WE USE COOKIES

We use cookies to:

  • Enable the Site to function and allow you to sign in to and use your User Account.

  • Keep your session secure and prevent unauthorised access to your account.

  • Detect and prevent fraud, bonus abuse, multi-accounting, and automated or bot activity.

  • Confirm your geographic eligibility and enforce the jurisdictional restrictions set out in the Terms of Use and Sweepstakes Rules.

  • Remember your preferences and settings, such as language and display options.

  • Understand how the Site is used so that we can improve it.

  • Measure the performance of our marketing campaigns.

  • Deliver promotional content and offers that are relevant to you, where permitted by law.

4. CATEGORIES OF COOKIES WE USE

We group the cookies we use into the following categories. The specific cookies in use may change from time to time as we update the Site and our service providers.

Category

Purpose

Can you disable it?

Strictly necessary

Required for the Site to operate. These cookies enable account sign-in, session management, load balancing, security, and the correct functioning of purchase and redemption flows.

No. The Site cannot function without them.

Security and fraud prevention

Used to detect and prevent fraudulent activity, multi-accounting, bonus abuse, bot and automated traffic, and unauthorised account access, and to confirm geographic eligibility.

No. These are essential to protecting the integrity of the Platform and to meeting our compliance obligations.

Functional

Remember choices you make, such as display preferences, saved settings, and previously used options, so that you do not need to re-enter them.

Yes, though some features may not work as intended.

Analytics and performance

Help us understand how visitors use the Site, which pages are visited, how long sessions last, and where errors occur, so that we can improve the Services.

Yes.

Advertising and marketing

Measure the performance of our marketing campaigns and, where permitted by law, deliver advertising about our Services that is relevant to your interests, including through audience segments.

Yes.

5. THIRD-PARTY COOKIES AND SERVICE PROVIDERS

Some cookies used on the Site are set by third parties that provide services to us. These providers may collect information about your use of the Site in accordance with their own privacy policies. Our current providers include:

  • SEON — fraud detection and prevention, device fingerprinting, and the identification of multi-accounting and bonus abuse. SEON technologies fall within the security and fraud prevention category.

  • Cloudflare, Inc. — security, bot mitigation, network performance, and IP-based geolocation used to confirm location eligibility. Cloudflare cookies fall within the strictly necessary and security categories.

  • Google — analytics and campaign measurement, including Google Analytics. These cookies fall within the analytics and advertising categories.

  • Meta Platforms, Inc. — advertising measurement and audience tools, including the Meta pixel. These cookies fall within the advertising category.

  • Our customer relationship management and messaging provider — measurement of email and message delivery and engagement, including whether a message has been opened or a link followed. These technologies fall within the analytics and advertising categories.

  • PaywithSoap and Rapyd — payment orchestration and payment processing respectively, including fraud screening and transaction security in connection with Gold Coin package purchases.

We do not control third-party cookies. You should review the privacy and cookie policies of these providers for information about their practices and about the choices they make available to you.

6. HOW LONG COOKIES LAST

  • Session cookies are temporary and are deleted when you close your browser. We use them for sign-in, session security, and navigation.

  • Persistent cookies remain on your device for a defined period, or until you delete them. We use them to remember your preferences, to recognise returning devices for security and fraud prevention, and for analytics and campaign measurement.

The retention period of a persistent cookie varies according to its purpose. Security and fraud-prevention identifiers, including IP address data, may be retained for longer periods, consistent with the retention schedule set out in the Privacy Policy.

7. MANAGING YOUR COOKIE PREFERENCES

7.1 On-Site Preferences

Where a cookie preference control is made available on the Site, you may use it to accept or decline non-essential cookies and to change your choices at any time. Strictly necessary and security cookies cannot be disabled through this control, because the Site cannot operate securely without them.

7.2 Browser Settings

Most browsers allow you to view, manage, block, and delete cookies through their settings. The relevant controls are usually found in the privacy or security section of your browser's settings menu. Because the process differs between browsers, please consult your browser's help documentation.

7.3 Advertising Opt-Outs

You may opt out of certain interest-based advertising through industry tools, including:

  • The Network Advertising Initiative opt-out page.

  • The Digital Advertising Alliance opt-out page.

  • The advertising settings offered directly by Google and Meta.

You may also contact us at support@silvergames.us to opt out of targeted advertising, and, if you reside in a State with a comprehensive consumer privacy law, to exercise any applicable right to opt out of the sale or sharing of personal information. See the Privacy Policy.

7.4 Mobile Devices

Mobile operating systems provide device-level controls that allow you to limit ad tracking or reset your advertising identifier. These controls are found in the privacy settings of your device.

8. DO NOT TRACK AND OPT-OUT PREFERENCE SIGNALS

Some browsers transmit a "Do Not Track" signal. There is no common industry standard for how such signals should be interpreted, and we do not currently respond to Do Not Track signals.

Where required by applicable State law, we honour opt-out preference signals such as Global Privacy Control transmitted by your browser or device, treating them as a request to opt out of targeted advertising and of the sale or sharing of personal information.

9. CONSEQUENCES OF DISABLING COOKIES

Blocking or deleting cookies may affect how the Site functions. In particular, you may not be able to sign in to your User Account, your session may not be maintained correctly, purchase and redemption flows may not complete, and your saved preferences may not be retained.

Blocking strictly necessary or security cookies will prevent us from confirming your geographic eligibility and from protecting your account against unauthorised access, and may prevent you from accessing the Services altogether.

10. CHANGES TO THIS COOKIE POLICY

We may update this Cookie Policy from time to time to reflect changes to the technologies we use, to our service providers, or to applicable law. Any revised version will be posted on the Site with an updated effective date and change log entry. Where required by law, we will provide additional notice. Your continued use of the Site after a revised Policy is posted constitutes your acceptance of it.

11. DOCUMENT INTEGRATION

11.1 One Integrated Agreement

The Platform Documents are not independent documents. They are published, accepted, and enforced as a single integrated set governing your access to and use of the Services. This Cookie Policy is incorporated by reference into the Terms of Use and forms part of them. Each of the other Platform Documents is likewise incorporated into the Terms of Use and is to be read together with this Cookie Policy.

11.2 Acceptance of the Platform Documents

As a condition of registration, you are required to affirmatively accept the Terms of Use and the Sweepstakes Rules. By doing so, you agree to be bound by all of the Platform Documents, and you acknowledge and consent to the data practices described in the Privacy Policy and this Cookie Policy. You do not accept the Platform Documents individually or selectively; acceptance of the Terms of Use and the Sweepstakes Rules constitutes acceptance of the set as a whole.

Your continued access to or use of the Services following the posting of any amendment to any Platform Document constitutes your acceptance of the amended set, subject to any advance-notice or rejection rights expressly provided in the Terms of Use, including those applicable to the arbitration provisions.

11.3 Document Hierarchy

In the event of any conflict or inconsistency between the Platform Documents, the more specific provision shall govern. For matters of eligibility, entry, methods of obtaining Sweeps Coins, the mail-in Alternative Method of Entry, playthrough, and prize redemption, the Sweepstakes Rules take precedence. For matters of platform usage, account management, purchases, and the legal framework, including dispute resolution, the Terms of Use take precedence. For matters concerning cookies and similar technologies, this Cookie Policy takes precedence, and for all other matters concerning the collection, use, and disclosure of personal information, the Privacy Policy takes precedence.

11.4 Dispute Resolution Is Governed Solely by the Terms of Use

The Platform Documents contain a single operative dispute resolution provision, which appears in Section 15 of the Terms of Use. Where this Cookie Policy or any other Platform Document refers to arbitration, governing law, forum, class action waiver, or the right to opt out, that reference is to the provisions of the Terms of Use and does not create a separate or additional agreement.

11.5 The Platform Documents

The Platform Documents comprise the following, each available on the Site:

  • Terms of Use: Governs general platform usage, account management, purchases, and the legal framework, including dispute resolution.

  • Sweepstakes Rules: Contains the specific procedures for sweepstakes participation, methods of obtaining Sweeps Coins, the mail-in Alternative Method of Entry, and prize redemption.

  • Privacy Policy: Explains how we collect, use, and protect your personal information.

  • Cookie Policy: Describes the cookies and similar technologies we use and how to manage them.

  • Responsible Social Gaming Policy: Describes the player protection tools available to you, including breaks from play and self-exclusion.

12. CONTACT US

If you have questions about this Cookie Policy or about how we use cookies, please contact us:

13. CHANGE LOG

Version

Effective Date

Description

1.0

September 6, 2026

Creation of Cookie Policy

1.1

October 22, 2026

Updates