Privacy Policy (ChatGPT App)

Effective date: March 27, 2026
Provider: Spheric Admin Ltd ("we," "us," "our")
Contact: privacy.widgets@olutely.com
Product: "Lottery" (the "App"), a ChatGPT app

1) Scope

This policy explains how we process data through the Lottery App when it is used inside ChatGPT. The App displays read-only widgets for supported lottery draws and returns the latest completed draw results in a structured format. This policy covers Spheric Admin Ltd's processing through the App, its MCP server, and related hosting, logging, and analytics services. It does not replace OpenAI's policies for ChatGPT platform processing.

Important: Our current MCP server configuration logs full MCP request bodies to the server console and sends HTTP and MCP request telemetry to Mixpanel. For current lottery tool calls, the tool input schema is an empty object, but the logged or tracked request data can still include the tool name, JSON-RPC request ID, request path, IP address, user agent, response status, response time, and an OpenAI subject identifier if the platform supplies one.

2) Current tool contracts and app behavior covered by this policy

  • All current lottery tools use the same input contract: an empty object {}. The App does not ask you to enter name, email address, phone number, account credentials, location, files, or free-text tool arguments through the current tool schemas.
  • All current lottery tools use the same top-level output fields: jackpot (integer), drawDate (YYYY-MM-DD), and numbers (lottery-specific number groups). Current response metadata for these tools is an empty object {}.
  • us-powerball-lottery: output numbers.main[5] and numbers.powerball[1].
  • us-mega-millions-lottery: output numbers.main[5] and numbers.megaBall[1].
  • eu-euromillions-lottery: output numbers.main[5] and numbers.luckyStars[2].
  • eu-eurojackpot-lottery: output numbers.main[5] and numbers.euroNumbers[2].
  • it-superenalotto-lottery: output numbers.main[6], numbers.jolly[1], and numbers.superstar[1].
  • ca-lotto-649-lottery: output numbers.main[6] and numbers.bonusBall[1].
  • ca-lotto-max-lottery: output numbers.main[7] and numbers.bonusBall[1].
  • au-oz-lotto-lottery: output numbers.main[7] and numbers.supplementary[2].
  • es-la-primitiva-lottery: output numbers.main[6], numbers.complementario[1], and numbers.reintegro[1].
  • uk-lotto-lottery: output numbers.main[6] and numbers.bonusBall[1].
  • uk-thunderball-lottery: output numbers.main[5] and numbers.thunderball[1].
  • Current widget behavior is read-only. The widget renders the result data returned by the tool and does not currently include account creation, sign-in, form submission, file upload, clipboard write actions, or follow-up message actions implemented by the widget code.

3) Data categories, purposes, recipients, retention, and controls

3.1 Tool invocation data and tool results

What: The selected lottery tool name, the current empty tool input object {}, and the structured tool result fields jackpot, drawDate, and the relevant numbers groups listed above.
Why: To return the requested lottery result, render the matching widget, and show the latest completed draw in ChatGPT.
Recipients: Our MCP server, OpenAI/ChatGPT as part of the tool invocation flow, and the widget runtime inside ChatGPT.
Retention by us: We do not use a separate app database to maintain user profiles or a per-user lottery history for this App. The resulting structured lottery output is cached in server memory for up to 24 hours by lottery name to reduce duplicate fetches. That cache is keyed by lottery name, not by user identity. Tool request and response details may also appear in logs and analytics telemetry as described in section 3.3.
Your controls: You can choose whether to use the App. Because current tool schemas do not ask for personal fields, you do not need to provide personal information to use the App's tool interface.

3.2 Server-side lottery result retrieval using OpenAI web search

What: When one of the lottery tools is called, our server sends OpenAI an API request that includes the selected lottery name, the current date, and the required JSON schema for the result, with web search enabled so OpenAI can identify reliable public lottery-result sources. Under the current server code, this outbound request is based on the selected tool and not on user-entered tool fields, because the current tool input schema is empty.
Why: To identify the latest completed draw and return structured results in the output format required by the App.
Recipients: OpenAI as our API provider. As part of OpenAI's web search functionality, OpenAI may consult public web sources to obtain lottery results.
Retention by us: We do not intentionally store the outbound OpenAI request in a separate app database. The structured result returned to us may be kept in the 24-hour in-memory cache described above and may also appear in operational logs if an error occurs.
Your controls: You can choose not to use the App. If you do use it, the App's current tool contract does not require you to submit personal information to retrieve results.

3.3 Technical delivery data, server console logs, and analytics telemetry

What: Technical data generated when the App is accessed or its MCP tools are called, including HTTP method, request path, URL, IP address, user agent, response status, and response time. Our current MCP server utility also logs full MCP request bodies to the server console. For MCP calls, Mixpanel telemetry sent through the EU Mixpanel endpoint can include the JSON-RPC method, request ID, URL, timestamp, duration, status code, request params, IP address, user agent, and, for tool calls, an OpenAI subject identifier if supplied in request metadata. Because the current tool input schema is empty, tool-call params generally identify the tool call and its metadata rather than user-entered tool fields.
Why: Security, abuse prevention, reliability, debugging, incident response, and understanding how the App is being used.
Recipients: Our hosting and infrastructure providers, personnel who need access for operations or security, and Mixpanel for server-side analytics telemetry.
Retention: We aim to minimize server-side operational logs and generally retain them for no longer than 30 days unless a longer period is reasonably necessary for security investigations, abuse prevention, or legal obligations. Mixpanel telemetry is retained in our analytics workspace until deleted by us or until an applicable Mixpanel or account retention setting removes it.
Your controls: You can choose not to use the App and can contact us with access, deletion, or other rights requests regarding personal data we hold.

3.4 Contact data if you email us

What: Your email address and the contents of your message.
Why: To respond to privacy, support, or legal requests and maintain a record of the request.
Recipients: Spheric Admin Ltd and our email/service providers acting on our behalf.
Retention: Up to 24 months after final resolution unless a longer period is required by law or reasonably needed to establish, exercise, or defend legal claims.

4) What we do not do

  • No account creation or sign-in through the current App flow.
  • No sale of personal information.
  • No current tool fields that ask for name, email address, telephone number, postal address, payment information, files, or free-text content.
  • No client-side advertising SDKs or client-side analytics trackers embedded in the current lottery widgets.
  • No direct third-party API calls from the current widget code to fetch lottery results; the widget is read-only and the server performs the result retrieval.

5) Cookies and similar technologies

We do not intentionally set advertising cookies or place client-side analytics trackers through the current Lottery widget. ChatGPT/OpenAI, your browser, and our hosting providers may use their own cookies or similar technologies for platform operation, security, or delivery under their own policies.

6) Sharing and disclosure

We do not sell personal information. We share data only when needed to:

  • Operate, host, monitor, secure, and troubleshoot the App through service providers such as hosting, infrastructure, analytics, and email providers.
  • Retrieve and structure lottery results through OpenAI's API and web search capabilities.
  • Comply with law, regulation, legal process, or enforceable government request.
  • Protect the rights, safety, and security of users, us, and the service.

7) User rights and controls

Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, or object to processing of personal data we hold.

To exercise rights or ask questions, contact privacy.widgets@olutely.com. We may need to verify your identity before fulfilling a request.

Because the App runs inside ChatGPT, you can also manage conversation and account data through OpenAI controls. OpenAI's privacy policy: https://openai.com/policies/privacy-policy.

8) International transfers

The App may be accessed globally and processed in countries where we or our service providers operate. Where required, we use appropriate safeguards for international data transfers.

9) Security

We implement reasonable technical and organizational safeguards designed to protect data processed through the App. No system is guaranteed to be completely secure.

10) Children's privacy

The App is not directed to children under 13 (or the minimum age required in your jurisdiction). We do not knowingly collect personal information from children through this App.

11) ChatGPT / OpenAI platform notice

ChatGPT/OpenAI independently processes chat content, account information, platform telemetry, and in-session widget data under OpenAI's own terms and privacy practices. This policy does not replace OpenAI's policies; it describes Spheric Admin Ltd's processing through this App.

12) Changes to this policy

We may update this policy from time to time. If we make material changes, we will update the effective date above and ensure the policy continues to reflect the App's current tool inputs, outputs, logging, analytics, and data uses.

13) Contact

Questions about this policy or App privacy practices: privacy.widgets@olutely.com (Spheric Admin Ltd).