Privacy Policy

2.1 Information You Provide Directly

• Identity Information: full legal name, date of birth, and government-issued identification, only if we ask you to verify your identity.
• Contact Information: email address and mobile phone number.
• Account Credentials: username and password (stored as a one-way cryptographic hash by our sign-in provider; we cannot read your password).
• Financial Information: deposits are paid through our payment provider's hosted checkout. We do not receive or store full card numbers or bank account credentials. We store the cash-out destination you give us.
• Communications: messages to our support team, contact form submissions, and attachments.
• Referral Information: referral or agent codes provided at registration.
• Identity Documents (Sensitive PI): photos of the front and back of your ID and a selfie submitted for verification, stored in private storage.

2.2 Information Collected Automatically

• Device Information: device type, operating system, and browser type and version.
• Usage Information: pages and features used, game loads and redemptions, ledger transactions, rewards, and navigation.
• Location Information: general location (country and state) derived from your IP address, used to check eligibility. We do not collect precise GPS location.
• Log Data: server logs including access times, referring URLs, and error reports.
• Cookies and Similar Technologies: see Section 7.
• Fraud Prevention Signals: your IP address at signup and at your latest sign-in, a random identifier stored in a cookie on your browser, and salted, irreversible hashes of your IP address and device. We use them to spot multiple accounts and to protect free rewards from abuse.

2.3 Information from Third Parties

• Payment Provider: confirmation of your deposits and payouts, and their status.
• Game Platforms: the usernames and balances of the game accounts we create for you.
• Analytics Providers: aggregated insights about Platform usage.

3.1 Platform Operation

• Create and manage your Customer Account
• Provide access to games, sweepstakes promotions, and Platform features
• Process deposits, game loads, redemptions, and cash-outs
• Run rewards, WinSweeps Coins, Free Play, VIP tiers, and leaderboards
• Respond to your support inquiries and customer service requests

3.2 Identity Verification & Compliance

• Verify your identity, age (21+), and eligibility when required
• Check that you are not using the Platform from a Prohibited Territory
• Detect, investigate, and prevent fraud, abuse, and prohibited conduct
• Enforce our Terms of Service and Sweepstakes Rules

3.3 Platform Improvement & Analytics

• Analyze how users interact with the Platform to improve features and user experience
• Monitor Platform performance, uptime, and security

3.4 Marketing & Communications

• Send transactional email, such as verification, password resets, support replies, and account notices
• Send promotional email about new features, bonuses, and promotions when your notification settings allow it. You may opt out at any time via the unsubscribe link in any email or in your notification settings
• Show in-app notifications about your account and rewards

3.5 Legal Obligations

• Comply with applicable laws, regulations, and legal processes
• Respond to lawful requests from government authorities and law enforcement
• Establish, exercise, or defend legal claims

3.6 Sensitive Personal Information

We collect and process Sensitive PI (government-issued identity documents and selfies) solely for the following limited purposes:

• Age and identity verification
• Fraud detection and prevention

When you verify, our own servers read the barcode and the printed text on your ID and, with your consent given on the verification form, compare the photo on your ID with your selfie. The face measurements are used only for that comparison and are not kept; we keep the result and your photos as described above. No outside service receives your ID for this check.

We do not use Sensitive PI to infer characteristics about you, nor do we share it with third parties for advertising or marketing purposes.

4.1 Service Providers

We share Personal Information with Service Providers who process data on our behalf to operate the Platform. The Service Providers we use include:

• Hosting and Database: Vercel hosts the Platform. Supabase hosts our database, sign-in, and file storage, including identity documents in private storage.
• Payment Processing: Paydora processes deposits and cash-out payments and receives only the transaction data needed to do so.
• Game Platforms: the third-party platforms that run the Games receive your game username and the credits loaded or redeemed.
• Email Delivery: Resend sends transactional and promotional email on our behalf.
• Analytics: PostHog and Google Analytics help us understand how the Platform is used.
• Live Chat assistant: messages you type in Live Chat, with the account details needed to answer them (balances, deposit, load and cash-out status), are sent to Groq, or to Google Gemini as a backup, to draft an answer from our rules and FAQ. Passwords and ID documents are never sent.
• Staff Alerts: Telegram delivers internal alerts to our staff, which can include your username, phone number, and transaction amounts.

4.2 Agents

Some players join through an agent who works with WinSweeps, or are assigned to one by our team. An agent can see their own players' profiles, deposits, game activity, verification documents, support chats, and balances, so that they can support those players. Agents must use this information only to help you.

4.3 Business Transfers

If WinSweeps is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of its assets, your Personal Information may be transferred as part of that transaction. We will notify you of any material change in ownership or use of your Personal Information by email or a prominent notice on the Platform before the change takes effect.

4.4 Legal Requirements & Safety

We may disclose your Personal Information if we believe in good faith that such disclosure is necessary to:

• Comply with a subpoena, court order, or other legal process
• Respond to lawful requests from law enforcement or government agencies
• Protect the legal rights, property, or safety of WinSweeps, our users, or the public
• Investigate or prevent suspected fraud, abuse, violations of our Terms of Service, or illegal activity

4.5 With Your Consent

We may share your information with third parties in circumstances not described above when you have expressly consented to such sharing.

10.1 General Rights (All Users)

• Right to Know / Access: request information about the categories and specific pieces of Personal Information we have collected about you, and how it is used and shared.
• Right to Correction: request correction of inaccurate Personal Information. You can update most account information directly in your profile and settings.
• Right to Deletion: request deletion of your Personal Information, subject to records we are legally required to keep.
• Right to Opt Out of Marketing: opt out of marketing emails at any time via the unsubscribe link or your notification settings. You cannot opt out of transactional messages such as security alerts and cash-out confirmations.
• Right to Withdraw Consent: where we process your data based on consent, you may withdraw that consent at any time by contacting us.

10.2 California Residents (CCPA / CPRA)

California residents have the following additional rights under the CCPA/CPRA:

• Right to know about the categories and specific pieces of Personal Information collected, used, and disclosed
• Right to delete Personal Information (subject to exceptions)
• Right to correct inaccurate Personal Information
• Right to opt out of the sale or sharing of Personal Information for cross-context behavioral advertising
• Right not to be discriminated against for exercising CCPA rights
• Right to limit the use and disclosure of Sensitive Personal Information

Do Not Sell or Share: We do not sell Personal Information for monetary consideration. If any disclosure counts as "sharing" under California law, you can opt out through support@winsweeps.games (or the contact form at winsweeps.games/contact) with the subject line "Do Not Sell or Share."

10.3 Virginia, Colorado, Connecticut & Other State Residents

Residents of these states may have similar rights to access, correct, delete, and port their Personal Information, and to opt out of targeted advertising and profiling. Contact us through support@winsweeps.games (or the contact form at winsweeps.games/contact) to exercise these rights.

10.4 How to Exercise Your Rights

• Email: support@winsweeps.games
• Contact form: winsweeps.games/contact
• Subject Line: include "Privacy Request" and the specific right you wish to exercise
• Response Time: we will verify your identity before processing your request and will respond within 45 days of receipt (with a possible extension of up to 45 additional days where reasonably necessary and upon notice to you)

10.5 Account Deletion Requests

You may request the deletion of your account at any time through support@winsweeps.games (or the contact form at winsweeps.games/contact) with the subject line "Delete Account". We will confirm your request by email and process it within 3 to 5 business days.

Before deletion, any Cash-out Balance you are owed is paid out, subject to verification. Once your account is deleted, your profile, game history, balances, and WinSweeps Coins are no longer available.