Privacy Policy

Last updated: January 5, 2026

Effective Date: January 5, 2026
Last Updated: January 5, 2026

StarWins LLC ("StarWins," "we," "our," or "us") operates the StarWins platform, including the StarWins mobile app, website, and related pages (collectively, the "Platform").

This Privacy Policy explains what information we collect, how we use it, how we disclose it, and your rights and choices. By using or accessing the Platform, you acknowledge that you have read and understand this Policy.

1. Information We Collect

We collect information in the following categories:

A. Identifiers and Contact Information

  • Name, email address, phone number (if provided)
  • Username and account identifiers

B. Commercial Information

Records of StarCoins purchases, receipts/transaction IDs, subscription status (if any), and redemption-related records. (Apple/Google and payment processors may handle payment method details; we typically receive confirmation and transaction metadata.)

C. Precise Geolocation (Mandatory)

Precise geolocation (GPS-level) and/or other reliable location signals. We use location to determine feature availability (including StarCash eligibility by state) and to prevent prohibited access and fraud.

If you do not allow location access, the Platform (or key features) may not function.

D. Internet/Network Activity and Device Information

  • IP address, device identifiers (including mobile advertising IDs where permitted), device type, OS version, browser type
  • Language, time zone, carrier/ISP, app version, device settings

E. Usage and Gameplay Information

  • Screens visited, taps/clicks, session duration, feature usage
  • Gameplay events and outcomes, wager activity, balances, and related logs
  • Crash reports, diagnostic logs, performance metrics

F. Verification and Compliance Information (StarCash)

If you request StarCash redemption or use features that require verification, we and our service providers may collect:

  • Government-issued ID, selfie/liveness check data, proof of address, date of birth
  • Risk and fraud signals tied to device/account behavior

We may use a verification vendor such as Persona to help verify identity and eligibility.

2. How We Use Information

We use information to:

  • Create and manage accounts and provide Platform functionality
  • Enable gameplay, maintain balances, and prevent abuse/cheating
  • Process purchases and maintain transaction records
  • Determine eligibility and enforce location-based availability (including state-by-state access to StarCash)
  • Detect, prevent, and investigate fraud, payment abuse, and security incidents
  • Provide customer support and communicate with you
  • Operate mandatory analytics for reliability, debugging, performance monitoring, and product improvement
  • Comply with legal obligations and enforce our Terms and Sweepstakes Rules

3. How We Disclose Information

We may disclose information to:

A. Service Providers / Contractors

We use service providers to help operate the Platform, such as:

  • Cloud hosting and infrastructure
  • Analytics and performance monitoring
  • Fraud prevention and security vendors
  • Customer support tooling
  • Identity verification/KYC vendors (e.g., Persona) for StarCash redemption flows

These providers are authorized to use information only to perform services for us and are restricted from using it for their own purposes, except as permitted by law.

B. Legal, Safety, and Rights Protection

We may disclose information if we believe it is necessary to:

  • comply with law or legal process,
  • respond to lawful requests,
  • investigate fraud or security incidents,
  • protect the rights, property, or safety of StarWins, our users, or others.

C. Business Transactions

We may disclose information in connection with a merger, acquisition, financing, reorganization, or sale of assets.

We do not sell personal information for money.
We do not share personal information for cross-context behavioral advertising as defined by California law.

4. Retention

We retain information for as long as reasonably necessary to provide the Platform and for legitimate business and legal purposes, including security and fraud prevention.

Typical retention examples:

  • Account data: while your account is active, and for a reasonable period after closure
  • Purchase/transaction records: as required for accounting, audits, dispute handling, and legal compliance
  • Verification (StarCash) data: as necessary to complete verification, comply with legal obligations, and prevent fraud
  • Logs/analytics: retained for a limited period to maintain security and reliability, and to improve the Platform

5. Location and Analytics (Mandatory)

Mandatory Location

We use precise location and/or other location signals to:

  • enable or restrict StarCash features depending on where you are physically located,
  • detect VPN/proxy/location spoofing,
  • prevent prohibited access and fraud.

Mandatory Analytics

We collect and analyze usage, diagnostics, and performance data to:

  • keep the Platform stable and secure,
  • detect abuse and fraud,
  • troubleshoot issues,
  • improve gameplay and product performance.

6. Cookies, SDKs, and Similar Technologies

We may use cookies, pixels, SDKs, and similar technologies to support:

  • core functionality,
  • analytics and performance monitoring,
  • fraud prevention and security.

Device/platform settings may allow you to limit certain identifiers (for example, advertising ID settings). However, because location and analytics are mandatory for the Platform's operation and compliance, limiting certain settings may reduce or prevent access to the Platform or certain features.

7. Security

We use reasonable administrative, technical, and physical safeguards designed to protect information. No system can be guaranteed 100% secure.

8. Minors

The Platform is intended for adults. We do not knowingly collect personal information from anyone under 18.

9. California Privacy Notice (CCPA/CPRA)

This section applies to California residents.

A. Categories of Personal Information Collected

In the last 12 months, we may have collected the following categories:

  • Identifiers (name, email, account identifiers)
  • Commercial information (purchase/redemption records)
  • Internet/network activity (usage and device data)
  • Precise geolocation
  • Verification/compliance information for StarCash (where applicable)

B. Sources

We collect information from:

  • you directly (account info, support messages, verification submissions),
  • your device and your use of the Platform (usage, diagnostics, location),
  • service providers (verification results, fraud signals),
  • app stores/payment processors (transaction confirmations).

C. Purposes

We use information for the purposes listed in Section 2, including operating the Platform, security/fraud prevention, eligibility enforcement, analytics/performance, and legal compliance.

D. Disclosures

We disclose information to service providers/contractors described in Section 3, and for legal/safety/business transaction purposes as described there.

E. Selling / Sharing

We do not sell personal information for money.

We do not share personal information for cross-context behavioral advertising.

F. Your Rights

Subject to legal exceptions, you may have the right to:

  • request access to specific pieces of personal information we have about you,
  • request deletion of personal information,
  • request correction of inaccurate personal information.

G. How to Submit a Request

Email support@starwins.gg with the subject line:

  • Privacy Request – Access
  • Privacy Request – Delete
  • Privacy Request – Correct

We may need to verify your identity before fulfilling your request. We will not discriminate against you for exercising your rights.

10. Changes to This Policy

We may update this Policy from time to time. We will post updates in-app and/or on our website with an updated "Last Updated" date.

11. Contact

For questions or privacy requests, contact: support@starwins.gg