Privacy Policy

This Privacy Policy describes how GamerGains Labs, Inc. and our subsidiaries and affiliates ("Gains.com," "we," "us," or "our") handle personal information that we collect through our digital properties that link to this Privacy Policy, including our website at gains.com and our mobile applications (collectively, the "Service"), as well as through social media, our marketing activities, and other activities described in this Privacy Policy.

This Privacy Policy is incorporated into and forms part of our Terms and Conditions. Any dispute arising out of or relating to this Privacy Policy or our data practices — including claims relating to cookies, pixels, software development kits, analytics, session-replay, or other tracking technologies — is subject to the dispute-resolution provisions of the Terms and Conditions, including the requirement of individual binding arbitration and the waiver of class actions, and to a pre-dispute written notice and 30-day good-faith informal resolution period, unless you have validly opted out of arbitration as described in the Terms and Conditions.

Gains.com is a social casino that offers sweepstakes promotions. Players may purchase Gold Coins for entertainment play, may receive promotional Sweeps Coins at no cost, and may redeem eligible Sweeps Coins prizes for cash or other prizes under our Sweepstakes Rules. The Service is available only to individuals who are 18 years of age or older (or the age of majority in their jurisdiction, if higher) and who are located in eligible U.S. jurisdictions. Our Terms and Conditions and Sweepstakes Rules govern eligibility.

1. Personal Information We Collect

Information you provide to us

• Identity and contact data, such as your first and last name, email address, phone number, date of birth, country and state of residence, postal code, and the username and password you set for your account.
• Eligibility and verification data. Before we process certain prize redemptions, or where we otherwise need to verify your identity, our identity-verification provider collects on our behalf images of your government-issued photo ID, a self-portrait photo used for identity confirmation (see Section 2, Biometric Information), and related details such as your address. Where required for tax reporting or enhanced due diligence, we may collect taxpayer information such as a Social Security number.
• Financial and transaction data, such as payment card details and billing information (collected and processed by our payment processors), your purchase and redemption history, prize information, and any digital asset wallet address you provide to receive a prize redemption.
• Communications, including support requests and chat conversations, survey responses, and promotion or giveaway entries.
• Marketing preferences, such as your choices about receiving marketing email, SMS, and push notifications.
• User-generated content, such as profile pictures, display names, and other content you make available through the Service.

Information from third-party sources

• Social login providers. If you sign in with Google, Facebook, or Apple, we receive information from that provider such as your name, email address, and profile photo, per your settings with that provider.
• Identity-verification and fraud-prevention providers, which return verification outcomes, risk assessments, and related signals about your account and devices.
• Payment processors and financial partners, which provide payment confirmations, fraud and chargeback signals, and related transaction information.
• Advertising, attribution, and analytics partners, which provide information about how you reached the Service, such as campaign and click identifiers.
• Public sources, including public blockchain ledgers, which by design expose wallet addresses and transaction details.
• Referrals. If you join through a friend's referral link, we associate your signup with the referring player's username. We do not collect or import anyone's contact lists.

Information collected automatically

• Device data, such as operating system type and version, device model, browser type, screen characteristics, IP address, language settings, mobile carrier and network information, and device identifiers, including advertising identifiers where you have permitted them.
• Online activity data, such as the pages and screens you view, games you play and session information, navigation paths, access times, purchases and redemptions you complete, and whether you open our emails or click links in them.
• Location data. We derive your approximate location (such as state and city) from your IP address each time you use the Service, because state eligibility is a legal requirement of our sweepstakes. We and our service providers, including the licensed third-party game providers that operate certain games within the Service, may also collect precise geolocation information from your device or browser to verify your physical location and to satisfy legal, licensing, and compliance obligations. Where precise device location is collected, you will be asked for the applicable device or browser permission before collection begins, and you may decline, although some games or features may be unavailable where your location cannot be verified.
• App Tracking Transparency (iOS). On iOS we request your permission through Apple's App Tracking Transparency framework before using your device's advertising identifier for cross-app ad measurement. You can decline without affecting your ability to use the Service.

Cookies and similar technologies

We and our service providers use cookies, local storage, pixels, software development kits, and similar technologies to operate the Service, remember your preferences and login status, measure usage, and support advertising and measurement as described in Section 5. These include both session and persistent technologies, and both first-party and third-party technologies. Tools in use include Google Analytics and Google Tag Manager (including server-side tagging), Mixpanel, AppsFlyer, Meta and Snapchat technologies, Sentry, and Intercom.

Categories of Personal Information (Notice at Collection)

In the preceding 12 months we have collected the following categories of personal information as defined by applicable state privacy laws: Retention periods for each category are described in Section 7 (Data Retention).

• Identifiers (name, email, phone, address, date of birth, government ID, IP address) — Collected: Yes — Sources: you; your devices; identity-verification providers; social login providers; payment processors; referral signups — Purposes: account creation, eligibility, KYC, fraud prevention — Disclosed to: identity-verification, fraud-prevention, payment, and cloud providers; advertising, analytics, and attribution partners (hashed identifiers and device identifiers) — Sold or shared: shared for cross-context behavioral advertising (opt-out available)
• Customer records (payment information, transaction history) — Collected: Yes — Sources: you; payment processors — Purposes: purchases, prize redemptions, accounting — Disclosed to: payment processors, accountants, regulators where required — Sold or shared: not sold or shared
• Characteristics such as age/date of birth — Collected: Yes (18+ eligibility) — Sources: you — Purposes: eligibility and legal compliance — Disclosed to: identity-verification and compliance providers — Sold or shared: not sold or shared
• Commercial information (purchases, redemptions, promotional participation) — Collected: Yes — Sources: you; our systems — Purposes: service operation, promotions, analytics — Disclosed to: service providers — Sold or shared: not sold or shared
• Biometric information (facial geometry extracted from selfie verification) — Collected: Yes — Sources: identity-verification provider during KYC — Purposes: identity verification and fraud prevention — Disclosed to: identity-verification provider — Sold or shared: not sold or shared
• Internet or network activity (gameplay events, device data, interactions with the Service and our ads) — Collected: Yes — Sources: your devices; analytics and attribution partners — Purposes: analytics, fraud prevention, advertising measurement — Disclosed to: analytics, attribution, and advertising partners — Sold or shared: shared for cross-context behavioral advertising (opt-out available)
• Geolocation data (approximate location derived from IP address and device signals; precise geolocation collected by us or our service providers, including game providers, with your device permission) — Collected: Yes — Sources: your devices; game providers — Purposes: eligibility, licensing, and compliance; fraud prevention — Disclosed to: compliance and fraud-prevention providers; game providers — Sold or shared: not sold or shared
• Audio, electronic, visual, or similar information (selfie and government ID images captured during verification; profile pictures) — Collected: Yes — Sources: you; identity-verification provider — Purposes: identity verification and fraud prevention — Disclosed to: identity-verification provider — Sold or shared: not sold or shared
• Inferences (preferences and activity profiles) — Collected: Yes — Sources: our systems — Purposes: personalization, promotions, responsible-play measures — Disclosed to: service providers — Sold or shared: not sold or shared
• Sensitive personal information (government ID number; Social Security/taxpayer identification number where required for tax reporting; biometric identifiers; account log-in credentials; precise geolocation where collected as described in Section 1) — Collected: Yes — Sources: you; your devices; identity-verification provider; game providers — Purposes: identity verification, eligibility, licensing and compliance, fraud prevention, tax reporting, and account security only; not used to infer characteristics — Disclosed to: identity-verification provider; compliance and fraud-prevention providers; game providers — Sold or shared: not sold or shared

2. Biometric Information

When you complete identity verification, our third-party identity-verification provider collects, on our behalf, images of your government-issued ID and a self-portrait photo, and uses facial comparison technology, which may involve a scan of face geometry, to confirm that you are the holder of the identification document. This processing is used solely to verify your identity, to comply with our legal obligations, and to protect the Service against fraud and account misuse. We do not use biometric information for marketing, we do not sell it or otherwise profit from it, and we do not use it to make automated decisions unrelated to identity verification.

We contractually require our identity-verification provider to retain biometric identifiers and biometric information no longer than the earlier of (a) the date the initial purpose for collection has been satisfied, or (b) three (3) years after your last interaction with us, unless a longer period is required by law, after which they are permanently destroyed.

3. How We Use Your Personal Information

Service delivery

• Provide, operate, and improve the Service, including game play, Gold Coin purchases, and Sweeps Coins prize redemptions.
• Establish and maintain your account and player profile.
• Enable security features, such as sending security codes by email or SMS and remembering trusted devices.
• Communicate with you about the Service, including announcements, updates, security alerts, and support and administrative messages.
• Provide customer support and respond to your requests, questions, and feedback. We use automated tools, including artificial-intelligence assistance, to help answer support requests; you can always ask to reach a human agent.

Eligibility, identity verification, and sweepstakes administration

• Verify that you meet age and location eligibility requirements, including deriving your approximate location from your IP address and, where applicable, collecting precise geolocation as described in Section 1.
• Verify your identity before processing certain prize redemptions and as otherwise required by law.
• Administer sweepstakes promotions, including confirming entries, verifying winners, fulfilling prizes, and, where permitted by our Sweepstakes Rules and applicable law, publishing winner information.
• Administer responsible-gameplay tools, such as self-exclusion and play limits, and honor those choices across the Service.

Payments, compliance, and protection

• Process purchases and prize redemptions through our payment and digital-asset partners, including fraud and chargeback management.
• Comply with applicable laws and legal process, including anti-money-laundering obligations, source-of-funds review, sanctions screening, tax reporting and related documentation, and responses to lawful requests from government authorities.
• Prevent, detect, investigate, and deter fraudulent, harmful, unauthorized, or illegal activity, including misuse of promotions and the operation of multiple accounts. We use automated screening to help identify risk; account decisions that significantly affect you, such as declining a redemption, generally include human review.
• Audit our internal processes, enforce our Terms and Conditions and Sweepstakes Rules, and protect our rights and the rights, privacy, safety, and property of you and others.

Research, analytics, and marketing

• Analyze and improve the Service, including understanding how players use features and games.
• Send you direct marketing communications, which you can opt out of at any time as described in Section 5 and Section 6.
• Measure and improve our advertising, including by sharing hashed identifiers and event information with advertising platforms as described in Section 4 and Section 5.
• Personalize your experience with the Service and our communications.

Other uses

• With your consent, where we specifically ask for it.
• To create aggregated, de-identified, or anonymized data that no longer reasonably identifies you, which we may use and share for any lawful business purpose. Where we rely on de-identified data, we maintain it without attempting to re-identify it.

We may offer loyalty, referral, VIP, and promotional programs that provide benefits, such as bonus coins, and that involve the collection of personal information. Participation is voluntary; the material terms are presented when you enroll or participate, and you may withdraw at any time by contacting support. We calculate the value of these programs in good faith based on the expense to us of providing the benefits, and any difference in prices or benefits offered is reasonably related to the value of the personal information involved.

4. How We Share Your Personal Information

• Service providers. Third parties that provide services on our behalf, such as cloud hosting and infrastructure, analytics, email, SMS, and push-notification delivery, customer support tooling, and security and fraud prevention.
• Identity-verification and fraud-prevention providers, which process your information, including verification data and device signals, to verify identity and protect the Service.
• Payment processors and financial partners, including card processing and digital-asset custody and payout providers, which process the financial information needed to complete your purchases and prize redemptions.
• Game content providers. Licensed game studios and aggregation platforms receive pseudonymous account identifiers and game-session information needed to operate their games and features within the Service.
• Advertising, analytics, and attribution partners. We share information such as hashed email addresses, hashed phone numbers, event information (for example, signups and purchases), device identifiers, and click identifiers with advertising platforms, including Meta, Snapchat, and Google, and with our mobile-attribution provider, to measure campaigns and to reach audiences likely to be interested in the Service. You can opt out of this sharing as described in Section 5 and Section 6.
• Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.
• Public blockchains. If you choose a digital-asset prize redemption, the transaction, including your wallet address and amount, is recorded on a public blockchain that anyone can view. Blockchain records are public by design and cannot be altered or deleted by us.
• Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us.
• Authorities and others, including regulators, law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
• Business transferees, in connection with a corporate transaction or its negotiation or diligence, such as a merger, acquisition, financing, reorganization, or sale of assets, including in bankruptcy or similar proceedings.
• Other users and the public, to the extent you choose to make profile information or other content visible through the Service.
• Third parties you designate, where you instruct us or consent to the sharing.

5. Tracking Technologies and Your Advertising Choices

We use the technologies described in Section 1 for four purposes: technical operation of the Service, functionality and remembering your preferences, analytics, and advertising and measurement.

We do not sell personal information in exchange for money. Like many businesses, we disclose certain identifiers and activity data (such as hashed identifiers, device identifiers, and event data) to advertising partners for cross-context behavioral advertising, as described in Section 4, which may be considered a 'sale' or 'sharing' under some state privacy laws; you may opt out as described below. We have disclosed personal information in this way in the preceding 12 months. We do not knowingly sell or share the personal information of anyone under 18.

Your choices:

• Global Privacy Control. We treat a Global Privacy Control (GPC) signal from your browser as a valid request to opt out of the sale or sharing of your personal information, including for targeted advertising, as required by applicable law. Because there is no industry consensus on legacy Do Not Track signals, GPC is the signal we honor.
• Your Privacy Choices. Use the Your Privacy Choices link in the Service footer to opt out of targeted-advertising sharing and to submit privacy requests.
• Cookie controls. Your browser settings allow you to block or delete cookies; some Service features may not function without them.
• Platform ad settings. You can adjust ad preferences in your accounts with Meta, Snapchat, and Google, and use industry tools from the Digital Advertising Alliance (optout.aboutads.info) and the Network Advertising Initiative.
• Mobile settings. On iOS, you can decline or revoke tracking permission in Settings; on Android, you can reset or delete your advertising ID.
• Marketing opt-outs. Unsubscribe links in our marketing emails, replying STOP to marketing texts, and notification settings in the app each stop the corresponding channel. You will continue to receive non-marketing service communications, such as receipts and security messages. Email opt-outs may take up to ten (10) business days to take effect; SMS STOP requests are honored promptly. You may receive communications already in progress during these periods.

6. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights with respect to your personal information:

• Know and access: confirm whether we process your personal information and obtain a copy of it, including in a portable format.
• Correct: fix inaccuracies in your personal information.
• Delete: request deletion of your personal information. You can also delete your account directly in the app or website settings, and account deletion triggers deletion requests to our verification and fraud-prevention providers and suppression of marketing, except that we and they retain information as needed for fraud prevention, security, identity verification, and legal compliance, as described in Section 7. Because we must be able to verify identity and eligibility to lawfully operate the sweepstakes, requesting deletion of information required for those purposes will result in closure of your account, and pending entries and unredeemed prizes may be affected, as described in the Sweepstakes Rules, including forfeiture of Sweeps Coins upon account closure.
• Opt out: of targeted advertising, of any sale or sharing of personal information, and of certain profiling in furtherance of decisions that produce legal or similarly significant effects.
• Limit or consent to sensitive data processing, where applicable law provides that right. We process sensitive data, such as verification documents and biometric data, only as strictly necessary to provide the Service you request and to meet our legal obligations.
• Appeal: if we decline a request, you may appeal by replying to our decision, and we will respond as applicable law requires. If your appeal is denied, you may contact your state Attorney General.
• Non-discrimination: we will not deny you the Service, charge different prices, or provide a different level of quality because you exercised a privacy right, except as permitted by applicable law — for example, differences reasonably related to a voluntary loyalty, referral, or promotional program, or situations where the personal information is necessary to provide the Service, so that granting a deletion request means we can no longer provide you the Service.

How to exercise these rights. Submit a request through the Your Privacy Choices link in the Service, by emailing privacy@gains.com, or through your account settings. We will verify your request using your logged-in account or by matching the information you provide against our records, and we may need additional information for sensitive requests. An authorized agent may submit a request on your behalf with proof of authorization. We respond within the time required by applicable law. Where applicable law permits, access and portability requests may be made up to twice in any 12-month period, and disclosures will cover at least the 12-month period preceding the request, or a longer period where applicable law requires. We may decline, or charge a reasonable fee for, requests that are manifestly unfounded, excessive, or repetitive.

Retention after deletion. When you delete your account, we delete or de-identify personal information unless retention is required for the purposes in Section 7, such as transaction records we must keep under financial, tax, and sweepstakes laws, and records needed for fraud prevention and dispute defense.

California residents may request, once per year and free of charge, information about our disclosure of personal information to third parties for their direct marketing purposes (Cal. Civ. Code § 1798.83) by emailing privacy@gains.com. California users may also contact the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or (800) 952-5210.

7. Data Retention

We retain personal information for as long as your account is active and as needed afterward for the purposes described in this Privacy Policy. The retention period depends on the type of information and the purpose: account and profile data are kept for the life of the account; purchase, redemption, and prize records are kept as required by tax, accounting, anti-money-laundering, and sweepstakes laws; verification records are kept as required for compliance; biometric information follows the schedule in Section 2; and fraud-prevention records are kept as needed to protect the Service. When retention is no longer required, we delete or de-identify the information. Criteria we use include legal obligations, the period needed to resolve disputes and enforce agreements, and whether the information is needed to prevent fraud or abuse.

8. Security

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect, including encryption in transit, access controls, and monitoring. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

If a data breach affecting your personal information requires notice under applicable law, we will notify you and the relevant authorities as and when the law requires.

9. Processing in the United States

We are headquartered in the United States and the Service is offered only in the United States. Your personal information is processed in the United States and may be processed by service providers operating in other countries, where privacy laws may differ from those of your state. We take steps designed to ensure your information is subject to appropriate safeguards wherever it is processed.

10. Children and Age Requirements

The Service is intended only for individuals who are 18 years of age or older (or the age of majority in their jurisdiction, if higher). We do not knowingly collect personal information from anyone under 18, and no part of the Service is directed to children. If you believe we have collected personal information from someone under 18, contact us at privacy@gains.com and we will delete it as required by law.

11. Changes to this Privacy Policy

We may modify this Privacy Policy at any time. If we make material changes, we will notify you in advance by email or by prominent notice in the Service, and where required by law we will obtain your consent. Other changes are effective when we post the modified version with an updated effective date. Your use of the Service after the effective date of a modified Privacy Policy indicates your acceptance of it, to the extent permitted by law. This Privacy Policy operates for the benefit of, and may be assigned to, our successors and assigns, including in connection with the transactions described in Section 4.

12. How to Contact Us

• Privacy requests: privacy@gains.com
• General support: support@gains.com
• Mail: GamerGains Labs, Inc., 25 SE 2nd Ave, Ste 550, #802, Miami, FL 33131
• Social: x.com/playongains

Disputes relating to this Privacy Policy are resolved as described in the section of the Terms and Conditions titled 'Binding Arbitration and Class Action Waiver.'

Policy Version History

• May 1, 2025 — Initial Gains.com policy.
• August 1, 2026 — Comprehensive update: state privacy rights, biometric and advertising disclosures, opt-out mechanisms, retention schedule.
• August 4, 2026 — Location data: disclosed collection of precise geolocation by us and our service providers, including game providers, with device permission; updated Notice at Collection accordingly.