1. Overview

This Privacy Policy explains what information WinSpree ("WinSpree," "we," "us") collects through the WinSpree mobile application (the "App"), how we use and share it, and the choices you have. It applies to everyone who uses the App, including participants in the WinSpree Weekly Sweepstakes. By using the App, you agree to the collection and use of information as described here. This Policy should be read together with our Terms & Conditions, which govern the Sweepstakes itself.

2. Information We Collect

Account information: your mobile phone number (used to sign in via SMS verification), email address, date of birth, your country of residence (and, if you reside in the United States or Canada, your state or province), your chosen username, and an optional profile photo. Your phone number, date of birth, and place of residence are used specifically to verify you meet the minimum age requirement in our Terms and to operate your account; your email is used to deliver Sweepstakes prizes and account notices.

Gameplay information: scores, personal bests, global leaderboard rankings, in-App game session data, and the tickets you earn toward the Sweepstakes and how you earned them (check-ins, game performance, referrals).

Social information: your friends list, incoming and outgoing friend requests, multiplayer match invitations and results, referral relationships (who referred you and who you have referred), and the direct messages you send to and receive from friends. Messages are stored on our servers so they can be delivered and shown in the App, and are automatically screened for prohibited content as described in our Terms. We do not use the content of your messages for advertising, and we do not sell it.

Presence information: while the App is open, your device records that you are using it and, if you have a game open, which game. It is stored on our servers as a single record that is overwritten roughly every ninety seconds while the App is in the foreground, rather than as a history of the sessions you have played, and it is marked offline as soon as you leave the App. You choose who can see it, and switching it off deletes the record outright; see Sections 4 and 7.

Proof-of-Payment Share information: if you choose to take part in the optional Proof-of-Payment Share described in Section 4(d) of our Terms, the social media handle you enter, the link to the public post you submit, and the outcome of our review of it. We use these only to check that the post meets the requirements in Section 4(d) and to award the Tickets for it, and we do not use them for advertising and do not sell them. Anything you choose to put in the post itself is published by you, on a platform operated by Instagram or TikTok under its own privacy policy, and is outside our control; we ask you not to include your email address, your full legal name, or any account number or balance.

Safety and moderation information: reports you file about another player (including any message you choose to quote into the report), blocks you place, and records of any message or username that our content filter rejected. These are retained so that we can review reports and act on abusive behaviour.

Device and technical information: push-notification tokens (so we can notify you about friend requests, match invites, Sweepstakes wins, your daily check-in, the Last-Minute Sprint, and when another player passes your score on a leaderboard); your device’s current offset from UTC, stored so that the daily check-in reminder arrives at midday where you actually are rather than in the middle of your night; device-integrity signals collected by Google Firebase App Check to help confirm requests to our servers come from a genuine copy of the App; and, only while actively playing the Tilt Balance game, real-time motion/orientation sensor readings used solely to control gameplay in the moment — these readings are not transmitted to our servers or stored.

Advertising information: if you choose to watch a rewarded video ad in exchange for an in-game item, such as a hint or an extra life, Google AdMob independently collects information needed to serve and verify that ad, under its own privacy policy — see Section 5.

3. How We Use Information

We use the information above to: create and secure your account; verify your eligibility to use the App and participate in the Sweepstakes; operate gameplay, leaderboards, friends, and multiplayer features; award, track, and display your Sweepstakes tickets; conduct the weekly drawing and notify and verify winners; deliver prizes; send push notifications you would reasonably expect (friend requests, match invites, prize claims, a daily reminder to collect your check-in tickets, a weekly notice when the Last-Minute Sprint opens, and a message when another player takes a top-three leaderboard place from you or a friend beats one of your high scores — each of which you can switch off in Settings); prevent fraud, cheating, and abuse; and comply with legal and tax obligations related to prize awards.

4. Information Shared With Other Users

Some information you provide is visible to other players by design: your username and optional profile photo appear on leaderboards, in Winner History (once you have confirmed a prize per the Terms), and to your friends and multiplayer opponents. Direct messages you send are visible to the friend you send them to. If you have left presence switched on, your friends can also see when you are using the App, whether you are in a game and which one, and, when you are not in the App, roughly how long ago you were last seen. Presence is limited to your friends by default; the "Everyone" setting is reserved for features that do not exist yet and today shows your presence to no one beyond your friends. Your phone number, email address, date of birth, and state/province are never shown to other users.

5. How We Share Information With Others

Service providers: we use Google Firebase and Google Cloud Platform (Authentication, Cloud Firestore, Cloud Functions, Cloud Messaging, App Check, and Cloud Storage) to run the App's backend. These providers process data on our behalf and are contractually restricted from using it for their own purposes.

Google AdMob: when you watch a rewarded ad, Google AdMob acts as an independent controller of the advertising data it collects, governed by Google's own privacy policy (policies.google.com/privacy), not this one.

Prize payouts: if you win a prize, we share the minimum information necessary (your email address and prize amount) with the independent payout provider that delivers prizes on our behalf, so it can send your payout and let you choose how to receive it. If you choose a wallet, bank, or card transfer, you give those details to that provider directly and WinSpree never receives them; that provider may also collect tax information from you where the amount requires it. Its use of your information is governed by its own privacy policy.

Legal and safety: we may disclose information if required by law, subpoena, or legal process, or when we believe in good faith it is necessary to protect the rights, property, or safety of WinSpree, our users, or the public.

We do not sell your personal information, and we do not share it with third parties for their own independent marketing purposes.

6. Data Retention

We retain your account information for as long as your account is active. If you delete your account through the App (Settings → Delete Account), we delete your profile, username reservation, friends and friend-request records, your conversations and the messages in them, your presence record, game scores, and leaderboard entries. Conversations are also deleted for both sides when either player blocks the other or removes the friendship. Reports and content-filter records are kept for as long as needed to investigate and act on abuse, and to show a pattern of repeat behaviour. Records in the Sweepstakes ticket ledger, past weekly drawing results, and prize-claim records are retained in their existing de-identified form (tied only to an internal account identifier that, once your account is deleted, can no longer be traced back to you) as required to preserve the integrity and auditability of past and ongoing Sweepstakes drawings, and to meet tax and recordkeeping obligations related to prizes already awarded.

7. Your Rights and Choices

You can review and update your username and profile photo at any time in Settings. You can delete your account and associated data at any time via Settings → Delete Account, as described in Section 6. You can control push notification permissions through your device's operating system settings, and can turn the daily check-in reminder, the Last-Minute Sprint notice and the leaderboard alert off individually via Settings → Notifications. You can choose who sees when you are in the App — nobody, your friends, or everyone — at any time in Settings; choosing Nobody deletes your presence record and stops a new one being written. Depending on where you live, you may also have additional rights described in Sections 9 through 13 below. To exercise any of these rights, you can also contact us as described in Section 16.

8. Children's Privacy

The App is not directed to children and is not intended for use by anyone under the minimum age of majority described in our Terms & Conditions. We do not knowingly collect personal information from children under 13 (or the applicable minimum age in your jurisdiction). If you believe a child has provided us with personal information, contact us and we will take steps to delete it.

9. International Users and Data Transfers

WinSpree's infrastructure runs on Google Firebase and Google Cloud Platform, which may process and store information in the United States and other countries where Google operates data centers. If you access the App from outside the United States, your information will be transferred to and processed in the United States, which may not have the same data protection laws as your home jurisdiction. Where information is transferred out of the United Kingdom, the European Economic Area or Switzerland, that transfer is made under the European Commission's Standard Contractual Clauses (with the UK International Data Transfer Addendum and the Swiss addendum where applicable), which our infrastructure provider incorporates into its terms, together with the supplementary measures described in Section 14.

10. Additional Rights for California Residents

If you are a California resident, the California Consumer Privacy Act (as amended by the CPRA) gives you the right to know what personal information we have collected about you, to request deletion of that information, to correct inaccurate information, and to opt out of the "sale" or "sharing" of personal information. WinSpree does not sell personal information and does not share it for cross-context behavioral advertising outside of the App's own rewarded-ad feature described in Section 2. You can exercise these rights by contacting us as described in Section 16 or by using the in-App deletion tool described in Section 7.

11. Additional Rights for Canadian Residents

If you are a Canadian resident, Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial privacy laws give you the right to access the personal information we hold about you, to request correction of inaccurate information, and to withdraw consent to our collection and use of your information (which may limit or end your ability to use the App). You can exercise these rights by contacting us as described in Section 16.

12. Additional Rights for Users in the United Kingdom, the European Economic Area, and Switzerland

WinSpree does not offer accounts in the European Economic Area or the United Kingdom. If you are nonetheless in either and we hold personal data about you, the EU General Data Protection Regulation or the UK GDPR applies to our processing of it, and WinSpree is the controller of that data. If you are in Switzerland, the Swiss Federal Act on Data Protection gives you materially the same rights, and the rest of this section applies to you as written.

We rely on the following legal bases: performance of a contract with you, to create and operate your account and to administer the Sweepstakes you choose to enter; our legitimate interests, to keep the Service secure, prevent fraud and abuse of the Sweepstakes, moderate user-generated content, and understand how the App is used; your consent, for personalised advertising (which you give or refuse through the consent form shown when you first open the App, and can change at any time in Settings) and for push notifications; and compliance with legal obligations, including record-keeping for prize administration.

You have the right to request access to your personal data, to have inaccurate data corrected, to have your data erased, to restrict or object to our processing of it, to receive it in a portable form, and to withdraw any consent you have given at any time without affecting processing carried out before you withdrew it. Deleting your account through Settings exercises the right to erasure directly and immediately; the other rights can be exercised by contacting us as described in Section 16. We will not charge you for exercising these rights and will respond within one month.

You also have the right to lodge a complaint with your local supervisory authority — the Federal Data Protection and Information Commissioner in Switzerland, the Information Commissioner's Office in the United Kingdom, or the supervisory authority for your country in the EEA — and we would ask that you contact us first so we have the chance to resolve the matter.

13. Additional Rights for Users in Australia and New Zealand

If you are in Australia, the Privacy Act 1988 and the Australian Privacy Principles give you the right to access the personal information we hold about you and to request that we correct it if it is inaccurate, out of date, incomplete, irrelevant, or misleading, and to complain to us and then to the Office of the Australian Information Commissioner. If you are in New Zealand, the Privacy Act 2020 and the Information Privacy Principles give you equivalent rights of access and correction, and the right to complain to the Office of the Privacy Commissioner. You can exercise these rights by contacting us as described in Section 16, or delete your account and its data outright through Settings as described in Section 6.

14. Security

We use commercially reasonable administrative, technical, and physical safeguards designed to protect your information, including relying on Google Firebase's security infrastructure and access-control rules that restrict who and what can read or write your data. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be reflected by updating the version date at the top of this Policy in the App, and, where required by law, we will provide additional notice or seek your renewed consent. Continued use of the App after a change constitutes acceptance of the revised Policy.

16. Contact

Questions about this Privacy Policy, or requests to access, correct, or delete your information, can be directed to WinSpree at winspree.support@gmail.com, or through the contact option provided in the App's Settings screen.