WhoPays~Privacy Policy

Introduction

Welcome to WhoPays (“we,” “our,” or “us”). We are committed to protecting your privacy and being transparent about our data practices. This Privacy Policy explains how WhoPays handles information when you use our mobile application.

Information We Do NOT Collect

WhoPays does not collect, store, or transmit any of the following:

• Personal Information: We do not collect names, email addresses, phone numbers, or any other personally identifiable information
• User-Entered Names: The names you enter into the roulette wheel are stored locally on your device only and are never transmitted to our servers
• Location Data: We do not access or collect your location information
• Contact Information: We do not access your contacts or address book
• Photos or Camera: We do not access your photos, camera, or media library
• Financial Information: We do not collect credit card or banking information (in-app purchases are handled securely by Apple)

How WhoPays Works

WhoPays is a simple decision-making tool:

• You enter participant names or select colors
• You spin the wheel
• The app randomly selects a participant
• All data stays on your device and is cleared when you start a new spin

The app functions completely offline and does not require an internet connection except for displaying advertisements in the free version.

Third-Party Services

Google AdMob (Advertising)

The free version of WhoPays displays advertisements provided by Google AdMob. AdMob may collect certain information to provide personalized ads:

• Device Information: Device type, operating system, unique device identifiers
• Advertising ID: Apple’s Advertising Identifier (IDFA) for ad personalization
• Usage Data: How you interact with ads
• IP Address: For general location-based advertising

You can control ad tracking: Go to your iPhone Settings → Privacy & Security → Tracking → and toggle off “Allow Apps to Request to Track”

For more information about Google’s privacy practices, visit: https://policies.google.com/privacy

Apple In-App Purchases

If you purchase the Premium unlock, the transaction is processed securely by Apple. We do not have access to your payment information. Apple’s Privacy Policy applies: https://www.apple.com/legal/privacy/

Premium Version

When you upgrade to Premium for $0.99, all advertisements are removed, and no advertising-related data collection occurs. Your premium purchase is tied to your Apple ID and managed by Apple’s App Store.

Data Security

Since WhoPays does not collect or transmit your personal information, there is no data stored on our servers that could be compromised. All participant names you enter are stored locally on your device using standard iOS security measures.

Children’s Privacy

WhoPays is rated 4+ and is suitable for all ages. We do not knowingly collect any information from children under 13 (or the applicable age in your jurisdiction). Since we don’t collect personal information at all, WhoPays is fully compliant with children’s privacy regulations including COPPA.

Your Rights and Choices

Opting Out of Personalized Ads

You can limit ad tracking on your iOS device:

• Go to Settings → Privacy & Security → Tracking
• Toggle off “Allow Apps to Request to Track”
• Additionally: Settings → Privacy & Security → Apple Advertising → Toggle off “Personalized Ads”

Remove All Ads

Purchase the Premium version for $0.99 to completely remove advertisements and any associated data collection.

Delete Your Data

Since all data is stored locally on your device, you can delete it by:

• Clearing participant names in the app (they’re not saved between sessions anyway)
• Deleting the WhoPays app from your device

International Users

WhoPays is available worldwide. If you use WhoPays outside of Canada, please be aware that any information processed by third-party services (like AdMob) may be transferred to and processed in other countries, including the United States.

California Privacy Rights (CCPA)

If you are a California resident, you have specific rights regarding your personal information. However, since WhoPays does not collect personal information, there is no data to access, delete, or opt-out from. The only data collected is through AdMob for advertising purposes, which you can control through your device settings.

European Users (GDPR)

If you are in the European Economic Area (EEA), you have rights under GDPR. Since WhoPays does not collect or store personal data, there is minimal data processing. AdMob’s data collection for advertising purposes is based on consent, which you can withdraw through your device settings or by upgrading to Premium.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will notify you of any material changes by:

• Updating the “Last Updated” date at the top of this policy
• Posting a notice in the app (for significant changes)
• Sending a notification through the App Store (if required)

We encourage you to review this Privacy Policy periodically.

Analytics and Crash Reporting

WhoPays may collect anonymous crash reports and basic analytics to help us improve the app’s performance and fix bugs. This information is anonymized and cannot be used to identify you. No personal information is included in crash reports.

No Selling of Data

We do not sell, rent, or trade any user information to third parties. We have no user data to sell.

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Summary