Privacy & Cookie Policy
Last updated: April 6, 2026
1. Data Controller
This website wheelgiveaway.com (hereinafter "the Site") is operated by a private individual, without a VAT number, residing in Italy. The Site is not a commercial activity and is not subject to the tax obligations applicable to businesses.
For any privacy-related inquiries, you may write to: privacy@wheelgiveaway.com
2. Data Collected by the Site
2.1 No direct collection of personal data
The Site does not collect, store, or transmit any personal data from its users. There are no registration forms, user accounts, newsletters, or proprietary tracking systems.
2.2 Data processed locally (localStorage)
The tool on the Site (the random picker wheel) uses the browser's localStorage technology to save user-entered data (participant names, draw history, preferences). This data:
- Remains exclusively on the user's device
- Is never transmitted to external servers
- Is not accessible to the Site operator or any third parties
- Can be deleted at any time by the user by clearing their browser data
2.3 Service Worker (PWA)
The Site uses a Service Worker to function as a Progressive Web App (PWA). The Service Worker caches site resources to enable offline functionality. It does not collect or transmit personal data.
3. Cookies
3.1 Cloudflare technical cookies
The Site is hosted on Cloudflare Pages. Cloudflare may set strictly necessary technical cookies for the operation and security of the site:
| Cookie | Purpose | Duration | Type |
|---|---|---|---|
__cf_bm | Bot management and anti-abuse protection | 30 minutes | Technical / Necessary |
__cflb | Load balancing | Session | Technical / Necessary |
cf_clearance | Security challenge verification | Up to 24h | Technical / Necessary |
These cookies are strictly necessary and do not require user consent under the GDPR and the ePrivacy Directive.
3.2 No profiling or advertising cookies
The Site does not use any profiling, advertising, or third-party tracking cookies. No advertising networks (such as Google AdSense) or analytics tools that use cookies are present on the Site.
4. Cloudflare Web Analytics
The Site may use the basic analytics features provided by Cloudflare. Cloudflare Web Analytics:
- Does not use additional cookies
- Does not track individual users
- Only collects aggregate data (visit count, country of origin)
- Is GDPR-compliant without requiring consent
5. Legal Basis for Processing
The legal basis for data processing is:
- Legitimate interest (Art. 6(1)(f) GDPR): for strictly necessary technical cookies for site operation and abuse protection.
6. User Rights (GDPR)
Under Articles 15-22 of the GDPR, users have the right to access, rectify, or erase their data.
Since no personal data is stored on our servers, you can exercise the "right to be forgotten" simply by clearing your browser cache and localStorage. For other inquiries: privacy@wheelgiveaway.com
7. Applicable Legislation
- Regulation (EU) 2016/679 (GDPR)
- Italian Legislative Decree 196/2003 (Privacy Code)
- ePrivacy Directive 2002/58/EC