Spin the Wheel Privacy Policy

1.1 This Privacy Policy describes how Orionity ("Orionity", "we", "us", or "our") collects, uses, stores, discloses, and otherwise processes information in connection with the Spin the Wheel mobile application ("App").

1.2 This Privacy Policy applies to the current version of the App made available by Orionity and to the related legal page hosted on orionity.com.

1.3 The current version of the App is designed as a local-only application and does not require account registration in order to use its core functionality.

1.4 For the purposes of applicable data protection law, Orionity acts as the controller of personal data only to the extent Orionity actually processes personal data in connection with the App.

2.1 The App allows you to create and store list names, item names, weights, and related raffle configuration chosen by you ("User Content").

2.2 In the current version of the App, User Content is stored locally on your device.

2.3 Orionity does not intentionally collect, receive, host, or synchronize User Content on Orionity-controlled servers in the current version of the App.

2.4 The App does not require you to create an Orionity account or profile in order to use the main raffle functionality.

2.5 If you contact Orionity directly, Orionity may process the information you choose to provide in your message, such as your email address and the contents of your request.

3.1 Information stored locally in the App is used to provide the requested functionality of the App, including saving lists, editing entries, storing weights, and performing wheel or raffle draws.

3.2 If you contact Orionity, Orionity may use your message and contact details to respond to your inquiry, provide support, or address legal or operational matters.

3.3 Orionity does not use User Content for targeted advertising and does not sell personal information.

4.1 Where Orionity processes personal data in connection with the App, Orionity generally relies on one or more of the following legal bases, where applicable: (a) performance of a contract or steps taken at your request, (b) Orionity’s legitimate interests in operating, securing, and improving the App and related services, (c) compliance with legal obligations, and (d) your consent where consent is required by law.

5.1 In the current version of the App, core User Content remains on your device unless you export it, share it, back it up through device-level services, or otherwise cause it to leave the device.

5.2 Device manufacturers, operating system providers, app store operators, backup providers, and similar third parties may independently process certain technical or account-related data outside Orionity’s control.

5.3 Any such third-party processing is governed by the terms, settings, and privacy policies of those third parties.

6.1 Orionity does not intentionally disclose User Content through Orionity-controlled servers in the ordinary operation of the current version of the App.

6.2 Orionity may disclose personal data where necessary: (a) to comply with applicable law, regulation, legal process, or enforceable governmental request, (b) to protect rights, safety, property, users, or the public, (c) in connection with a corporate transaction such as a merger, acquisition, financing, reorganization, or sale of assets, or (d) to service providers acting on Orionity’s behalf, where such processing exists and is appropriate.

6.3 If Orionity adds analytics, subscriptions, cloud synchronization, crash reporting, advertising, or similar integrations in a future version of the App, this Privacy Policy will be updated before or at the time those changes become effective.

7.1 If subscriptions, paid features, or in-app purchases are offered through Apple, Google, RevenueCat, or another provider, those providers may process transaction, entitlement, account, and device-related information under their own terms and privacy policies.

7.2 Orionity is not responsible for the privacy practices of independent third-party platforms, stores, or payment intermediaries.

8.1 In the current version of the App, User Content generally remains stored on your device until you modify it, delete it, clear app data, or uninstall the App.

8.2 If you wish to remove User Content stored locally, you may do so from within the App or by removing the App from your device, subject to any separate device backup or retention systems outside Orionity’s control.

8.3 Orionity retains communications or records received directly from you only for as long as reasonably necessary for the purposes for which they were collected, including support, compliance, dispute resolution, and enforcement purposes.

9.1 To the extent Orionity processes personal data through service providers, partners, or infrastructure in the future, such processing may involve transfers to countries outside your country, state, or region of residence.

9.2 Where required by applicable law, Orionity will implement appropriate safeguards for such transfers.

10.1 The App is not directed to children under the age of 13 and is not intended to knowingly collect personal information from children through Orionity-controlled systems.

10.2 If you believe that a child has provided personal information to Orionity in connection with the App, please contact Orionity so appropriate measures can be considered.

11.1 Depending on your jurisdiction and the nature of the processing, you may have rights relating to personal data processed by Orionity, including rights of access, correction, deletion, restriction, objection, portability, and complaint to a competent supervisory authority.

11.2 Because the current version of the App stores core User Content locally on your device rather than on Orionity-controlled systems, Orionity may not be able to access, retrieve, correct, or delete that locally stored User Content on your behalf.

11.3 To exercise rights regarding personal data actually processed by Orionity, you may contact Orionity using the contact details below.

12.1 Orionity uses reasonable organizational and technical measures appropriate to the nature of the data Orionity processes. However, no method of storage, transmission, or electronic processing can be guaranteed to be completely secure.

13.1 Orionity may update this Privacy Policy from time to time to reflect legal, operational, or product changes.

13.2 When Orionity updates this Privacy Policy, the updated version will be published at this URL and the effective date above will be revised.

14.1 If you have questions about this Privacy Policy or want to submit a privacy-related request, you may contact Orionity at admin@orionity.com or through the contact page available on orionity.com.