Privacy Policy
Last Updated: 01-21-2026
1. Introduction
Xinger Solutions GmbH ("we", "us", "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, and protect your information when you use the Spin The Wheel mobile application ("App").
2. Data Controller
Xinger Solutions GmbH
Wirtschaftspark 8a
3462 Absdorf
AUSTRIA
+43 676 83924444
3. Information We Collect
3.1 Automatically Collected Information
Device Information: Device ID, device type, operating system version
Usage Data: App usage statistics, feature interactions
Technical Data: IP address, crash reports, performance data
3.2 User-Provided Information
Wheel Content: Wheels and items you create (stored locally and optionally shared)
Share Codes and PINs: When you share wheels with others
3.3 Third-Party Services
AppLovin MAX: We use AppLovin MAX for advertising. Please refer to their privacy policy: https://www.applovin.com/privacy/
Analytics: We may use analytics services to understand app usage
4. How We Use Your Information
We use collected information to:
Provide and improve the App's functionality
Process your requests (sharing wheels, downloading wheels)
Display relevant advertisements
Analyze app usage and performance
Ensure app security and prevent fraud
5. Legal Basis for Processing (GDPR)
If you are located in the EEA, we process your personal data based on:
Legitimate Interest: App functionality, security, and improvement
Consent: Where required by law, we obtain your consent
6. Data Sharing
We may share your information with:
Service Providers: Third-party services that help us operate the App (hosting, analytics)
Advertising Partners: AppLovin MAX and their partners for ad delivery
Legal Requirements: When required by law or to protect our rights
We do not sell your personal data.
7. Data Storage and Security
Local Storage: Your wheels and settings are stored locally on your device
Server Storage: Shared wheels are stored on our servers with encryption
Security Measures: We implement appropriate technical and organizational measures to protect your data
8. Data Retention
Local Data: Stored on your device until you delete the App or clear data
Shared Wheels: Stored on servers until deleted by the creator or after inactivity
Analytics Data: Retained for up to 3 years
9. Your Rights (GDPR)
If you are located in the EEA, you have the right to:
Access: Request a copy of your personal data
Rectification: Correct inaccurate data
Erasure: Request deletion of your data
Portability: Receive your data in a portable format
Object: Object to processing of your data
Withdraw Consent: Withdraw consent at any time
To exercise these rights, contact us at office@xinger.org
10. Children's Privacy
The App is not intended for children under 13 (or 16 in the EEA). We do not knowingly collect data from children. If you believe we have collected data from a child, please contact us.
11. International Data Transfers
Your data may be transferred to and processed in countries outside your jurisdiction. We ensure appropriate safeguards are in place.
12. Cookies and Tracking Technologies
The App may use cookies and similar technologies. For more information, see our Cookie Policy.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes through the App or other means.
14. Contact Us
For privacy-related questions or to exercise your rights, contact us at:
Email: office@xinger.org
Address: Wirtschaftspark 8a, 3462 Absdorf, AUSTRIA