SilverGames Privacy Policy

Version 2.0 — Effective as of October 22, 2026

Thank you for choosing to use silvergames (“Sweepstakes Platform,” “Service,” or “Site”). This Privacy Policy explains how Cogwheel Group Ltd (the “Company,” “Operator,” “we,” “us,” or “our”), a Cyprus limited liability company, Company Number ΗΕ 482634, located at 236 Strovolou Avenue, Strovolos, 2048 Nicosia, Cyprus, collects, uses, stores, discloses, and safeguards your personal information when you access and use our Site, mobile applications, and any associated services.

By using our Site or engaging with our platform, you agree to the terms of this Privacy Policy. If you disagree, you must discontinue using our Site and services immediately.

1. Who We Are

silvergames is owned and operated by Cogwheel Group Ltd, a Cyprus limited liability company located at 236 Strovolou Avenue, Strovolos, 2048 Nicosia, Cyprus. Although the Operator is incorporated in Cyprus, all operations and services targeting U.S. customers are conducted in compliance with applicable U.S. federal and state law. Governing law and dispute resolution are addressed in Section 15 of the Terms of Use, which is incorporated herein by reference.

The Services are offered solely to persons located in permitted States of the United States. The Services are not offered, and may not be accessed, from any other country or territory, including the European Economic Area and the United Kingdom. Access from outside the permitted States is blocked, and we do not knowingly collect personal information from individuals located outside the United States.

This Privacy 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, 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 acknowledge and consent to the collection, use, and disclosure of your personal information described in this Privacy Policy.

• Primary Company Address: 236 Strovolou Avenue, Strovolos, 2048 Nicosia, Cyprus

• Website/Platform: https://www.silvergames.us

For privacy-related inquiries or to exercise your data protection rights, please contact our privacy team at support@silvergames.us.

2. Definitions

To avoid ambiguity, the following definitions apply throughout this Policy:

• Personal Information: Information that identifies, relates to, or describes you, or could reasonably be linked to you (e.g., name, email address, physical address, or government-issued identification).

• Sensitive Personal Information: Information such as government-issued identification numbers, Social Security numbers, precise geolocation, financial account details, or other data that may receive special legal protections.

• Anonymous Information or Aggregated Information: Information that cannot reasonably be used to identify you, such as aggregated usage statistics.

• Cookies and Similar Technologies: Small files or code (e.g., cookies, web beacons, and pixels) placed on your device to collect data about how you use our Site or to remember your preferences.

3. Scope of This Privacy Policy

This Privacy Policy applies to all personal information collected about you by Cogwheel Group Ltd when you:

• Visit our website or any affiliated sites.

• Register for an account or participate in any sweepstakes, promotions, or related services.

• Communicate with us via email, phone, live chat, or other methods.

4. Information We Collect

We collect various types of personal information to provide our Services and improve your experience.

4.1. Information You Provide Directly

1. Account Registration Data

• Full legal name

• Date of birth (you must be at least 18 or the age of majority in your jurisdiction)

• Email address

• Phone number

• Physical or mailing address

• Username and password

2. Verification Information (KYC)

• Government-issued identification details (e.g., driver's license or passport)

• Secondary government-issued identification, when required

• Proof of address (e.g., utility bill or bank statement)

• Social Security number, where legally required

• Employment verification documentation, when required

• Source of funds documentation, when required

• Bank account verification, when required

• Payment method ownership confirmation, when required

• Video call verification records, when required

• Other documentation for identity verification, enhanced due diligence, or fraud prevention, as determined at our sole discretion

3. Payment and Transaction Details

• Partial credit or debit card information (e.g., last four digits and expiration date) or other payment method details

• Records of Gold Coin package purchases and Sweeps Coin redemptions

4. Communications

• Emails, chat transcripts, support tickets, complaints, or any messages you send us

4.2. Information Collected Automatically

Device and Usage Data

• IP address and approximate geolocation (city/state or more precise location if you grant permission)

• Browser type, operating system, and device type

• Referring and exit pages/URLs

• Date and time stamps and session lengths

• Page visits, clicks, and navigation paths

Cookies and Similar Technologies

• Cookies, web beacons, pixels, or similar tracking tools to personalize your experience, analyze Site usage, and serve relevant promotions

• Tracking pixels and similar technologies for fraud detection, user behavior analysis, and security monitoring

• Analytics tracking through third-party services (e.g., Google Analytics and Meta/Facebook Analytics)

• Marketing and advertising pixels for campaign tracking and audience measurement

• See Section 9 for more details on cookies and tracking technologies.

IP Address Logging

Each time you access the Service, we automatically capture and retain your public Internet Protocol (IP) address. We use this identifier to verify your geographic eligibility, detect the use of VPNs or proxies, prevent multi-accounting, and investigate suspected fraud or abuse.

IP addresses are retained for a minimum of five (5) years after your last activity or for as long as necessary to satisfy our legal and regulatory obligations. By creating an account or continuing to use the Service, you expressly acknowledge and consent to this collection, storage, and processing of your IP address.

4.3. Information from Third Parties

Verification Services

• Identity and age verification through third-party providers (e.g., Sumsub)

Analytics and Marketing Partners

• Usage data and insights from analytics platforms (e.g., Google Analytics and Meta/Facebook Ads)

Social Media

• Limited profile data, such as public usernames and friend lists, if you connect via social networks, subject to your social media privacy settings

5. How We Use Your Information

We process your personal data for the following business purposes:

1. Account Management and Sweepstakes Participation

• Creating, maintaining, and securing your user account

• Enabling your participation in sweepstakes and promotional events

2. Identity Verification and Fraud Prevention

• Confirming age, residency, and identity requirements, including analyzing stored IP address data to detect VPN/proxy use, bonus abuse, or other fraudulent activity

• Monitoring and preventing fraudulent or unauthorized activities

3. Transaction Processing

• Handling Gold Coin package purchases

• Processing redemptions and prize payouts

4. Customer Support and Communications

• Responding to inquiries, complaints, and support requests

• Sending important account or service updates

5. Legal and Regulatory Compliance

• Complying with laws, court orders, or governmental requests

• Maintaining records required by regulatory or compliance frameworks

6. Marketing and Promotions (Where Permitted)

• Sending promotional emails about new features, updates, or special offers

• Respecting your opt-out preferences, as required by law

7. Analytics and Service Improvements

• Analyzing usage patterns to optimize our Site and user experience

• Improving functionality, content, and features based on aggregate data

8. Behavioral and Interest-Based Advertising

• Where permitted by law, we may use cookies or similar technologies to deliver advertisements about our Services tailored to your interests or browsing activities.

• This may involve creating “audience segments” based on your interactions with the Site.

• You can typically opt out of such targeted advertising by adjusting your device or browser settings and/or using industry opt-out tools (see Section 9).

6. Our Basis for Processing Your Information

We process personal information only where we have a proper basis for doing so. In general, we process your information for one or more of the following reasons:

• Consent: You have agreed to the processing, for example, by opting in to receive marketing communications.

• Contractual Necessity: Processing is necessary to provide the Services you have requested and to perform our agreement with you.

• Legal Obligations: We are required to process your information by applicable law, including age verification, anti-fraud, and record-keeping requirements.

• Legitimate Business Interests: Processing is reasonably necessary to secure the Platform, prevent fraud and abuse, and improve the Services.

7. Data Sharing and Disclosure

We do not sell or rent your personal data. However, we may share your information in the following situations:

1. Within Our Corporate Structure

• Affiliates of Cogwheel Group Ltd for internal administrative purposes

2. Third-Party Service Providers

• Payment Processors: PaywithSoap, as a payment orchestration platform, and Rapyd, as a payment processor, for handling Gold Coin package purchases and prize payouts

• Marketing Services: Our customer relationship management and messaging provider for delivering transactional and promotional communications

• Verification Services: Providers such as Sumsub for identity and age checks

• Analytics Providers: Providers such as Google Analytics and Meta to help us understand platform usage

• Hosting, Security, and Email Distribution Vendors: Providers such as Cloudflare and, where applicable, AWS/SendGrid

• Geolocation and Fraud Detection: Providers such as Cloudflare and SEON, which collect and store IP addresses and related device data on our behalf to confirm location eligibility and combat fraud

3. Service Provider Obligations

These providers are contractually obligated to maintain confidentiality and may only use your data to perform tasks on our behalf.

4. Legal Compliance and Protection

• Government authorities or law enforcement when legally mandated, including through court orders or subpoenas

• To protect our rights, property, and the safety of our users or the public

5. Corporate Transactions

In connection with mergers, acquisitions, or asset sales, your data may be transferred to the acquiring entity.

6. With Your Consent

We may share your data with additional third parties if you explicitly opt in.

If we engage in cross-context behavioral advertising with third-party ad networks or social media platforms (e.g., for “custom audiences”), we will share only the minimum information, such as hashed email addresses or device identifiers, necessary to deliver relevant advertisements, in compliance with applicable laws.

8. Data Retention

We keep your personal data only as long as necessary to:

• Fulfill the purposes outlined in this Privacy Policy

• Comply with legal, regulatory, or contractual obligations

• Address disputes or enforce agreements

Retention Categories

Account and Compliance Data: We may keep your account data for a minimum of five (5) years after account closure, or as required by law or our contractual obligations. This includes identity verification records, transaction history, and communications.

Operational Data: Certain operational data has different retention periods, as detailed in our Terms of Use and Sweepstakes Rules. For example, Sweeps Coins have specific expiry periods as outlined in the Sweepstakes Rules.

IP Address Data: IP addresses are retained for a minimum of five (5) years after your last activity for security, fraud prevention, and regulatory compliance purposes.

Once personal information is no longer needed, we securely delete or anonymize it in accordance with our internal data retention policies and applicable laws.

9. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar technologies to:

• Recognize and remember your login preferences

• Analyze how you use and navigate our Site

• Provide relevant promotional content and personalized offers

Managing Cookies

• Most browsers allow you to block or delete cookies through your settings. However, blocking cookies may affect Site functionality.

• You can opt out of certain targeted advertisements by visiting industry websites such as the Network Advertising Initiative or the Digital Advertising Alliance.

• If applicable, you may see a “Your Privacy Choices” or “Do Not Sell/Share My Personal Information” link on our Site to manage cookie preferences in states where it is required.

10. Data Security

We implement industry-standard safeguards to protect the personal information we collect. These measures include:

• Encryption: SSL/TLS for sensitive data in transit

• Access Controls: Restricting personal information to authorized personnel

• Monitoring and Auditing: Monitoring our systems and auditing them to address potential vulnerabilities

Despite our efforts, no security practice is entirely foolproof. We cannot guarantee absolute data security, and you share information at your own risk.

Incident Response

If we become aware of a breach that compromises your personal information, we will notify you and any applicable regulators as required by law.

11. Where Your Information Is Processed

The Services are offered only to persons located in permitted States of the United States, and the personal information we collect relates to users located in the United States.

Your information is processed and stored in the United States and, to the extent necessary for the administration of the Platform, may be accessed by the Operator and by our service providers in the other jurisdictions in which they operate.

We take reasonable steps to ensure that your personal information remains protected, consistent with this Privacy Policy and applicable law, wherever it is processed.

12. Your Rights and Choices

Depending on the laws in your jurisdiction, you may have the right to:

• Access the personal information we hold about you

• Correct or update inaccurate or incomplete data

• Request deletion of your personal information, where allowable by law

• Object to or restrict certain data processing activities

• Withdraw consent where we have relied on your consent, for example, for marketing

• Opt out of certain forms of direct marketing

To exercise any of these rights, please email us at support@silvergames.us. We may ask you to verify your identity before responding to your request.

Authorized Agents and Appeals: If your local law (e.g., some U.S. state laws) allows you to use an authorized agent to submit a request or gives you the right to appeal a decision we have made, please provide us with the relevant documentation or contact us at support@silvergames.us.

We will honor your request as required by applicable laws.

13. Children’s Privacy

Our Services are not intended for individuals under the age of 18 or the age of majority in your jurisdiction, whichever is higher. We do not knowingly collect personal information from minors.

If you believe we might have collected data from or about a minor, please contact us immediately, and we will take appropriate steps to delete such information.

We also conduct KYC and age verification checks. Any account found to be under the lawful age will be terminated, and any associated data will be promptly deleted or anonymized.

14. Third-Party Links

Our Site may include links to third-party websites or services that we do not operate. We are not responsible for the privacy practices or content of those external sites. We encourage you to review their privacy policies before sharing any personal information.

15. Dispute Resolution

All disputes, claims, or controversies arising out of or relating to this Privacy Policy, our data practices, or your use of our Services are subject to the binding arbitration provisions set forth in Section 15 of our Terms of Use.

By using our Services, you agree to resolve all disputes through individual arbitration and waive rights to a jury trial and class action participation, as detailed in the Terms of Use.

For complete details regarding dispute resolution procedures, arbitration requirements, and your rights, please refer to Section 15 of our Terms of Use. Those provisions are incorporated herein by reference.

16. U.S. State Privacy Rights

The Services are not offered in California, and California residents are not eligible to register or participate.

If you reside in a state in which the Services are offered and that state has enacted a comprehensive consumer privacy law, you may have additional rights, including:

• The right to know what categories of personal data we collect and the specific pieces of information

• The right to request deletion of personal data, subject to legal exemptions

• The right not to be discriminated against for exercising these rights

16.1. Identifiers

• Internet Protocol (IP) Address: Collected for security, anti-fraud, and geolocation compliance; retained for up to five (5) years; not sold; shared only with service providers such as SEON.

Do Not Sell or Share

We do not sell personal information for monetary compensation. If any of our data practices would be considered a sale or sharing of personal information under the law of your state, including cross-context behavioral advertising, you may opt out at any time by contacting us at support@silvergames.us.

16.2. Other U.S. State Privacy Laws

• If you reside in Colorado, Virginia, Utah, Texas, Oregon, Iowa, Nebraska, New Hampshire, Rhode Island, or another state with a comprehensive privacy law, you may have rights similar to or additional to those described above (e.g., appeal rights, authorized agents, and the right to opt out of targeted advertising).

• We will comply with all applicable data privacy regulations and honor valid consumer requests in these states.

17. Changes to This Privacy Policy

We reserve the right to modify or update this Privacy Policy at any time. If we make material changes to how we handle personal information, we will:

• Post a revised version on our Site and update the “Effective Date.”

• Provide additional notice (e.g., email notification) if required by law.

We encourage you to review this Privacy Policy periodically. Your continued use of our Site after changes are posted will signify your acceptance of the updated terms.

18. Document Integration

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 Privacy Policy is incorporated by reference into, and forms part of, the Terms of Use. The Platform Documents comprise the following, each available on the Site:

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

• Sweepstakes Rules: Contains specific procedures for sweepstakes participation and prize redemption.

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

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

Acceptance of the Terms of Use and the Sweepstakes Rules at registration constitutes acceptance of all the Platform Documents. They are not accepted individually or selectively, and your continued use of the Services following any amendment to any Platform Document constitutes acceptance of the amended set.

In the event of any conflict between the Platform Documents, the more specific provision shall govern:

• The Sweepstakes Rules take precedence on eligibility, entry, and prize redemption.

• The Terms of Use take precedence on platform usage, account management, and the legal framework.

• This Privacy Policy takes precedence on the collection, use, and disclosure of personal information.

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

19. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us using one of the following methods:

• Email: support@silvergames.us

• Mailing Address: Cogwheel Group Ltd, 236 Strovolou Avenue, Strovolos, 2048 Nicosia, Cyprus

• Website: https://www.silvergames.us

We will make every reasonable effort to address and resolve your inquiries promptly.

20. Change Log