Spinnin! - Privacy Policy
Last updated: 29 October 2026
In short:
- Spinnin! has no registration, no user account and no game server of our own.
- Your progress, scores, settings and any Photo Mode photo are stored only on your device. Photos are never uploaded.
- Ads are shown by Google AdMob only. Personalised ads are used only where you consent (in the EEA, UK and Switzerland through a consent form) and, on iOS, only if you allow tracking in Apple's prompt.
- Purchases are handled by Apple or Google. We never receive your payment details.
- The Game needs an internet connection and checks it by contacting a Google server (see section 3).
- We only receive personal data about you if you email us.
- You can change your choices at any time (see section 9).
1. Who is responsible
1.1 Controller: the operator of the Game, acting under the brand names The Rising Apps and The Rising Heat ("we", "us", "our") · Contact: therisingheat1@gmail.com
1.2 The brand names The Rising Apps and The Rising Heat are not a separate legal entity.
1.3 This policy applies to the Spinnin! mobile game for iOS and Android (the "Game") and to these web pages.
1.4 We have not appointed a representative in the EU or UK (GDPR / UK GDPR Article 27) or a Data Protection Officer. You can contact us directly at the email above for any privacy matter.
1.5 Third parties such as Apple, Google and Google AdMob process some data as independent controllers under their own privacy policies (section 3).
2. Data stored only on your device
The following is created and kept locally on your device. We do not receive it:
- Game progress, levels, high scores, "Remove Ads" status and settings (sound, notifications, etc.).
- A local event log used by the Game on the device (for example, gameplay events for balancing). It is written only to a file in the Game's storage on your device and is never sent to us or anyone else.
- Photo Mode images: a photo you choose (or, on iPhone, take with the camera) is resized and saved inside the Game's storage on your device to skin the blocks. It stays on your device and is never uploaded to us or anyone else by the Game. You can delete a photo at any time with the trash (Remove) button in Photo Mode.
Your device's own backup service (iCloud / Google backup) may include this data according to your device settings; that is handled by Apple or Google.
3. Data processed by third parties
| Provider | What | Why | Their policy |
|---|---|---|---|
| Apple (App Store) / Google (Google Play) | Account, purchase and payment data, download and crash/diagnostic data according to your device settings | Distributing the Game, processing purchases and refunds, platform analytics they provide to developers in aggregated form | Apple · Google |
| Google AdMob (Google Mobile Ads SDK and User Messaging Platform) | IP address, device and app information, advertising identifier (IDFA if you allow tracking on iOS; Android Advertising ID unless you deleted/limited it), ad interaction data, consent status, approximate location derived from IP | Serving, limiting frequency of, measuring and (with consent) personalising ads; fraud prevention | How Google uses data from partner apps |
| Google (connectivity check) | IP address and standard request data, sent every few seconds while you play when the Game contacts www.gstatic.com/generate_204 to check that you are online. Nothing is stored by us. | Checking the internet connection that the Game requires | |
| GameAnalytics | A random identifier created by the GameAnalytics SDK, device model, operating system, app version, country derived from IP, and gameplay and ad events (sessions, stages started/won/lost, ads shown and their revenue). Only after you have answered the consent prompts, and only where ad/measurement consent allows it. | Measuring retention, stage difficulty and ad performance in aggregate so we can improve the Game | GameAnalytics |
Our own statistics service
The Game also sends anonymous usage statistics to our own server (operated by us, no third party). This includes a random install code created by the Game, basic device and app information (such as device model, operating system, app version, language and country), how the Game is played (sessions, stages and their results, screens), ad and purchase events (including ad revenue and store transaction details for Remove Ads), and app performance and crash information. It contains no name, e-mail, contacts, photos, advertising ID or precise location. We use it only to understand and improve the Game and keep it for up to 24 months. You can ask us to delete it or object to it at any time (see Contact).
The Game does not download any remote configuration file. When you visit these web pages, our web host logs standard request data (such as IP address and time) as any website does.
Apart from the providers listed above, we use no other analytics or ad networks.
4. Data we receive
4.1 Emails: if you contact us, we receive your email address and whatever you write (and any attachments). We use it only to answer you and handle your request.
4.2 Feedback from the rating prompt: if you give fewer than 5 stars, you can choose to send a short message. It is sent over an encrypted connection (HTTPS) to our own server together with the star rating, the Game version, your platform and device model, and a random install code (used only so each install can send feedback once and to block spam; it does not identify you). Do not include personal information in the message. We keep feedback for up to 24 months to improve the Game, then delete it.
4.3 Usage statistics: the anonymous statistics described in section 3 ("Our own statistics service").
4.4 We do not receive your photos, payment card details, name, or contacts.
4.5 We do not sell your personal data for money. See section 13.2 for the meaning of "sale/sharing" under California law in connection with ads.
5. Purposes and legal bases (GDPR / UK GDPR Art. 6)
| Purpose | Legal basis |
|---|---|
| Providing the Game and its features, including Photo Mode and restore purchases | Performance of a contract (Art. 6(1)(b)); on-device processing |
| Personalised ads and storing/accessing information on your device for ads | Consent (Art. 6(1)(a) and ePrivacy Directive Art. 5(3)), collected via Google's consent form (UMP) |
| Non-personalised / limited ads, ad measurement and fraud prevention | Legitimate interests (Art. 6(1)(f)) in funding a free game, and consent where required for device access |
| Anonymous usage statistics, performance and crash information (our own statistics service and GameAnalytics) to understand and improve the Game | Legitimate interests (Art. 6(1)(f)) in keeping the Game working well; consent where required for GameAnalytics |
| Answering your emails and requests | Legitimate interests (Art. 6(1)(f)); contract where it concerns the Game |
| Security of our web pages, legal compliance, defending claims | Legitimate interests (Art. 6(1)(f)); legal obligation (Art. 6(1)(c)) |
| Local notifications | Your permission on the device (consent) |
6. Device permissions
| Permission | When asked | Use | If refused |
|---|---|---|---|
| Photo picker (no permission) | When you choose to pick a photo in Photo Mode | The system photo picker gives the Game only the single photo you select; no access to your library | - |
| Camera (iOS only) | When you tap Camera in Photo Mode | Capture one photo to skin blocks; stored only on device | Use the picker or default skins |
| Photos - add only (iOS); no permission on Android (saved to Pictures/Spinnin, Android 10+) | When you tap Save on a finished picture | Save an image to your library; the Game cannot read your library | Image is not saved |
| Notifications | At first launch, after the consent and tracking prompts | Local reminders scheduled on the device, maximum 3 per week; no push server | No reminders; you can also turn them off later with the Reminders toggle in the Game's settings |
| App Tracking Transparency (iOS) | Before ads are personalised | Allows AdMob to use the IDFA | Ads still shown, without IDFA-based tracking |
You can change permissions anytime in your device settings.
7. Tracking, advertising IDs and consent
7.1 EEA, UK and Switzerland: before ads load, the Game shows Google's User Messaging Platform (UMP) consent form, certified under the IAB TCF where applicable. You can accept, reject or customise.
7.2 iOS: the Game asks for permission to track via Apple's App Tracking Transparency prompt. If you decline, the IDFA is not available to us or AdMob.
7.3 Android: you can delete or reset your Advertising ID in Settings › Privacy › Ads (wording varies by device).
7.4 US states: where required, we offer a way to opt out of "sale/sharing" or targeted advertising (section 13.2), and we honour Global Privacy Control-type signals where technically applicable.
7.5 If you bought "Remove Ads", interstitial ads stop permanently. Optional rewarded videos remain available, so the Google Mobile Ads SDK is still initialised and processes data as described above when it loads or shows those videos.
8. Retention
- On-device data: until you delete it (for example a Photo Mode photo) or uninstall the Game.
- Emails: as long as needed to handle your request and then up to 24 months for record-keeping, unless a longer period is required by law or for legal claims.
- Usage statistics on our server: up to 24 months, then deleted.
- Third-party data: according to the third party's own policy (for example, Google's ad data retention).
9. Your choices and how to delete data
- Delete all game data: uninstall the Game (also delete it from any device backups if you wish). There is no in-game reset option.
- Delete a photo: tap the trash (Remove) button in Photo Mode.
- Change ad consent: use the "Privacy Choices" row in Settings > More Settings to reopen the consent form (shown only where Google requires it, such as the EEA and UK).
- Tracking (iOS): Settings › Privacy & Security › Tracking.
- Notifications, camera, photos: device settings; reminders can also be turned off with the Reminders toggle in the Game.
- Emails: ask us to delete your correspondence.
- Usage statistics: email us and we will delete the statistics linked to your install.
10. International transfers
We are based in Israel, which benefits from an EU adequacy decision. Third parties such as Google may process data in the United States and other countries. Google relies on the EU-U.S. Data Privacy Framework (and its UK and Swiss extensions) and/or Standard Contractual Clauses for such transfers. Emails we receive are stored with our email provider (Google Gmail), which may process them worldwide.
11. Security
We keep the amount of data we receive to a minimum, use HTTPS for network requests and use reputable providers. No method of storage or transmission is completely secure, so we cannot guarantee absolute security. Your on-device data is protected by your device's security; keep your device locked and updated.
12. Children
12.1 The Game is suitable for a general audience but is not directed at children. It is rated about 9+ on the App Store, and its Google Play target audience is 13 and older.
12.2 We do not knowingly collect personal information from children under 13 (US COPPA) or under the age of digital consent in their country (GDPR Art. 8, 13-16 depending on the Member State). Because the Game is not directed at children, ad requests are not tagged as child-directed. All ad requests use a maximum ad content rating of PG.
12.3 If you are a parent and believe your child emailed us personal information, contact us and we will delete it.
13. Your rights by region
13.1 EEA, UK, Switzerland (GDPR / UK GDPR / FADP)
You have the right to access, rectification, erasure, restriction, portability, objection (including to processing based on legitimate interests), and to withdraw consent at any time without affecting prior processing. Since most data stays on your device, you can exercise many of these rights yourself (section 9). For data held by Google or Apple, contact them directly.
13.2 California (CCPA/CPRA) and other US states
Categories of personal information processed in connection with the Game in the last 12 months: identifiers (IP address, advertising ID), internet/network activity (ad interactions and in-game usage), approximate geolocation (from IP), and correspondence if you email us. Sources: your device and you. Disclosure for a business purpose: ad and platform providers. The use of advertising SDKs for cross-context behavioural advertising may be considered "sharing" or "selling" under California law. You may opt out by declining tracking on iOS, deleting/limiting your Android Advertising ID, or emailing us with subject "Do Not Sell or Share". We do not knowingly sell or share personal information of consumers under 16. You also have the rights to know, delete, correct, limit use of sensitive data (we do not use sensitive data), and non-discrimination. Residents of other US states with comprehensive privacy laws (for example Virginia, Colorado, Connecticut, Utah, Texas, Oregon) have similar rights, including to appeal a refusal by replying to our decision.
13.3 Israel
Under the Protection of Privacy Law, 5741-1981 (including Amendment 13, in force since August 2025), you may request access to and correction or deletion of information about you held by us. Complaints can be made to the Privacy Protection Authority.
13.4 Brazil (LGPD), Canada (PIPEDA) and other countries
Depending on where you live, you may have rights to confirmation of processing, access, correction, deletion, portability, information about sharing, and to withdraw consent. Contact us and we will respond as required by your local law.
To exercise a right, email us. We may need to ask for information to verify the request. We do not hold accounts, so we generally cannot link on-device data to you.
14. Changes
We may update this policy, for example when we add or change ad providers. We will update the "Last updated" date and give notice in the Game for material changes and, where required, ask for your consent again.
15. Contact and complaints
Email: therisingheat1@gmail.com. You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence (for example your EU national data protection authority, the UK ICO, or the Israeli Privacy Protection Authority).
See also: Terms of Use · Support