Privacy Policy of LotoSpin Last Updated Date of This Privacy Policy: June 3, 2026 Welcome to LotoSpin (hereinafter referred to as "this App"). This App is a lightweight random decision & lucky draw tool developed and operated by us (hereinafter referred to as "we"). We attach great importance to the protection of your personal information and strictly comply with the relevant laws and regulations such as Clause 5.1.1 of the App Store Review Guidelines, regulatory requirements and Apple's privacy norms, and are committed to providing you with safe, reliable and convenient services. This Privacy Policy will clearly and explicitly inform you how we collect, use, store and protect your personal information, as well as the rights you enjoy. Please carefully read and fully understand all the contents of this Policy before using this App, especially the bolded clauses. Your continued use of this App indicates that you have fully understood and agreed to all the provisions of this Policy. If you do not agree to this Policy, please do not use this App. I. Personal Information We Collect To realize the core functions of this App and improve service quality, we only collect necessary information actively provided by you or generated during use, and do not collect personal information irrelevant to the services, strictly following the principle of "legality, propriety and necessity". The details are as follows: (I) Information Actively Provided by You List & Option Information: To realize core functions such as Spin Wheel, Lucky Draw, List Picker, Group Split and Challenge Mode, you need to actively input custom option text, name lists and candidate content. Such information is only used to meet your current random selection needs and is a necessary prerequisite for realizing the corresponding functions. Function Selection Information: The function types you select when using this App (such as wheel custom entries, random number range, Yes/No setting, grouping quantity, challenge round parameters, finger roulette participant rules etc.) are used to accurately match your needs, generate random results that meet your expectations and optimize the tool experience. Saved Content Information: When you save custom wheel templates, saved name lists or historical draw results, such content will be stored locally on your device. Such information is only used for your local access and management, and will not be uploaded to any server without your consent. (II) Special Instructions on Participant Name Content (Related to List Picker & Group Split Function) The list picker and group split function of this App may involve real names, member information input by users. Such name content is only processed locally for random drawing and grouping calculation. Our processing strictly complies with relevant laws and regulations on personal information and privacy protection. The specific instructions are as follows: Collection Scope: We only collect name and list content that you actively type in when you use list-related functions, and do not actively collect any personal information in other scenarios. Purpose of Use: It is only used for real-time local random calculation of draw, selection and grouping effects, with no other purposes. It is not used for identity recognition, user profiling or any operations irrelevant to random decision functions. Storage Agreement: We do not store your input name information in any form on our servers. After finishing one-time random operation, temporary name cache will be automatically cleared; only your manually saved lists are kept locally on your own device. Sharing Agreement: We will not share your input name and list content with any third party. All random calculation processing is completed entirely locally on your device, without the participation of any third party in data processing. (III) Automatically Collected Information Device-Related Information: To ensure the normal operation of the App, optimize performance and troubleshoot faults, we will automatically collect your device model, operating system version, App version number and device identifiers (such as IDFA/IDFV, which are only collected with your authorization). Such information is only used for technical optimization and not for identifying your personal identity. Usage Behavior Information: We will collect relevant behavior data of your use of this App, including function usage records (such as the number of wheel creations, times of lucky draw, grouping counts, challenge usage frequency and operation preferences). Such data is collected anonymously, cannot be linked to your personal identity, and is only used for analyzing user habits, improving product functions and optimizing service quality. Log Information: When you use the App, we may automatically generate operation logs including access time, operation steps, function response status and crash information. Such logs are used for fault diagnosis, security maintenance and service optimization, and will not be used for other purposes. II. How We Use Your Personal Information We strictly abide by the principle of "minimum necessary use" and only use your personal information for the following purposes: To provide, maintain and optimize the core functions of this App, including Finger Roulette, Spin Wheel, Lucky Draw, Random Number, Yes/No, List Picker, Group Split and Challenge Mode; To verify your identity when you use paid membership services, complete payment confirmation and activate premium permissions; To optimize the performance, compatibility and user experience of the App, diagnose and fix technical faults; To send you important notices such as version updates, function adjustments and service announcements; To comply with legal obligations, respond to legal procedures and protect our legitimate rights and interests; For other purposes explicitly authorized by you. We will not use your personal information for any purpose that is not disclosed in this Policy or not authorized by you. III. Local Processing and Storage of Your Content LotoSpin is a local-first random decision tool. All random calculation operations are performed directly on your device. Local Processing: All your input name lists, custom wheel content and parameter setting data are processed locally on your iOS device. We do not upload your original list data or random result records to our servers without your explicit consent. Local Storage: Manually saved wheel templates, name lists and historical draw records are saved locally in your device storage. We do not store your custom content on our servers. Temporary Cache: Temporary cache files generated during random calculation are stored locally and automatically deleted when you exit the App or complete the current task. We do not retain temporary cache data. IV. Sharing, Disclosure and Transfer of Personal Information No Sharing: We will not share your personal information, including your input name lists, custom wheel content and saved data, with any third parties without your explicit consent. No Sale or Lease: We will not sell, rent or otherwise transfer your personal information to any third parties for commercial purposes. Legal Disclosure: We may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). Business Transfer: In the event of a merger, acquisition or asset sale, your personal information may be transferred as part of the transaction. We will notify you via a prominent notice on our App before such transfer and ensure the transferee complies with this Privacy Policy. V. Your Rights You have the following rights regarding your personal information: Right to Access: You have the right to view the personal information we hold about you in the "Settings - Privacy" page of this App. Right to Delete: You can delete your saved name lists, custom wheel files and historical records in this App at any time; if you wish to delete all your personal information, you can contact customer service to apply. After verifying your identity, we will delete the relevant information in a timely manner (except as required by laws and regulations); since temporary cache data is automatically deleted after processing, no additional deletion operation is required. Withdrawal of Consent: You can withdraw the relevant permission authorization for this App through "Settings - Privacy & Security" on your Apple device; you can also withdraw your consent to the collection and use of personal information through the relevant settings in this App. After withdrawing consent, we will no longer collect or use your relevant personal information, but it will not affect the legality of the personal information processing activities carried out based on your consent before the withdrawal. Account Cancellation: You can contact our customer service to apply for canceling your LotoSpin account. After the account is canceled, we will delete all your personal information (except as required by laws and regulations), and you will no longer be able to use the paid membership services of this App. If you encounter difficulties in exercising the above rights, you can contact us through the contact information at the end of this Policy, and we will respond to your needs and provide you with assistance in accordance with the law within 15 working days. VI. Protection of Minors' Personal Information This App is mainly intended for adults. We do not actively collect personal information of minors (under 18 years old). If you are a minor, you need to use this App under the supervision of a guardian, and you can only input name lists and save custom content with the guardian's consent. If a guardian finds that a minor has used this App and input personal name information without consent, he/she can contact our customer service. After verifying the identity, we will delete the relevant personal information of the minor and take measures to restrict his/her use of this App. VII. Updates to This Privacy Policy With the update of laws and regulations, the optimization of the functions of this App (including the iteration of Spin Wheel, Group Split, Challenge Mode and List Picker functions) and the change of user needs, we may revise this Privacy Policy. The revised Privacy Policy will be informed to you in a prominent way such as pop-up window or announcement in this App, and the updated Policy will take effect on the date of release. If you continue to use this App after the update of the Privacy Policy, it indicates that you have fully understood and agreed to all the contents of the revised Policy; if you do not agree to the revised Policy, please do not continue to use this App and can apply for account cancellation. VIII. Contact Us If you have any questions, opinions or suggestions about this Privacy Policy, or need to exercise your rights related to personal information or report issues such as privacy leakage, you can contact us through the following methods: Customer Service Email: nguyenthikieudie6989@icloud.com We will respond to your inquiries and demands and handle them within 15 working days.