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repo/luckythorne/content/privacy-policy.md
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---
title: Privacy Policy
linkTitle: Privacy Policy
description: "How LuckyThorne collects, uses and protects your personal data, plus your rights and how to contact us. 18+, T&Cs apply."
description: "How LuckyThorne handles personal data, cookies and your GDPR rights. A template to be reviewed by counsel. 18+, T&Cs apply."
h1: Privacy Policy
slug: privacy-policy
weight: 810
weight: 920
showInNav: false
showInFooter: true
footerGroup: legal
relatedPages:
- cookie-policy
- terms
- affiliate-disclosure
- responsible-gambling
- faq
- about-review
schemaType: none
date: 2026-07-15
lastmod: 2026-07-15
date: 2026-07-16
lastmod: 2026-07-16
hideCta: true
---
> **Notice:** This Privacy Policy is a working draft and must be reviewed and approved by qualified legal counsel before publication. Data-protection obligations vary by jurisdiction and by how the site actually operates, so the bracketed items below must be completed and verified before this page goes live.
This page is a template containing placeholder wording that must be reviewed and completed by qualified legal counsel before publication.
_Effective date: [PLACEHOLDER: effective date to be confirmed by legal counsel]._
LuckyThorne is an affiliate information website operated by Thorne Media Ltd. We are not a gambling operator and do not accept deposits, hold funds, or run games. This notice explains, in general terms, how personal data may be processed when you visit this site. Specific legal facts below are marked as placeholders and should be confirmed by counsel and against the site's actual data-processing arrangements.
_Last updated: 15 July 2026._
## 1. Who we are (data controller)
This Privacy Policy explains how Thorne Media Ltd ("we", "us", "our"), the operator of LuckyThorne, handles personal data collected through our website at https://luckythorne.example/. LuckyThorne publishes information and reviews about online casino products and directs visitors to third-party operators; this policy covers the data we process as the publisher of this site.
The data controller responsible for this website is [PLACEHOLDER: legal entity name, e.g. Thorne Media Ltd], registered at [PLACEHOLDER: registered address]. You can contact us regarding privacy matters at [PLACEHOLDER: data protection contact email] or, for general queries, hello@luckythorne.example. Where required, our data protection representative or officer is [PLACEHOLDER: DPO / EU representative details, if appointed].
If anything here is unclear, or you wish to exercise your rights, contact us at hello@luckythorne.example.
## 2. What data we collect
## Who we are
We may collect a limited amount of personal data, which typically includes: information you provide directly (for example, when you contact us by email); technical data collected automatically (such as IP address, browser type, device information and pages viewed); and analytics and usage data gathered through cookies and similar technologies, subject to your consent. The precise categories in use should be confirmed at [PLACEHOLDER: list of data categories actually processed].
The data controller responsible for the personal data described in this policy is Thorne Media Ltd. Our registered contact address and company registration details are set out at [PLACEHOLDER: registered company address and registration number to be confirmed]. The identity of any data protection officer or EU/UK representative, where one is required, is set out at [PLACEHOLDER: DPO / representative details to be confirmed by legal counsel].
## 3. Lawful bases for processing
Our default audience is the United Kingdom (en-GB), and we also serve visitors in Germany (de-DE) and Finland (fi-FI). The specific data-protection laws that apply to you may depend on your location; the legal framework and lawful bases referenced below are [PLACEHOLDER: applicable data-protection legislation and jurisdiction to be confirmed by legal counsel].
We process personal data only where a lawful basis applies under applicable data protection law. Depending on the activity, the relevant basis may be your consent (for example, for non-essential cookies and marketing), our legitimate interests (for example, to keep the site secure and understand how it is used), or compliance with a legal obligation. The specific basis for each processing activity should be documented at [PLACEHOLDER: mapping of processing activities to lawful bases].
## What data we collect
## 4. Cookies and analytics
Depending on how you use the site, we may process the following categories of personal data:
This site uses cookies and similar technologies. Non-essential cookies, including analytics and any marketing cookies, are set only where you have given consent, which you can change at any time via the "Cookie settings" link in the footer. Full details of the cookies used, their purposes and durations are set out in our [Cookie Policy]({{< relref "cookie-policy.md" >}}). Analytics providers and their configuration should be confirmed at [PLACEHOLDER: analytics providers and settings].
- **Contact data** you provide directly, such as your email address and message content when you write to hello@luckythorne.example.
- **Technical and usage data** generated automatically when you visit, such as IP address, device and browser information, pages viewed, and referring links. The exact fields, retention periods and tools used are set out at [PLACEHOLDER: analytics and logging tools to be confirmed].
- **Cookie and tracking data**, including identifiers used for analytics and for measuring outbound clicks to partner operators. Details are described in our cookie information at [PLACEHOLDER: link to cookie policy to be confirmed once published].
## 5. Sharing your data
We do not knowingly collect data from anyone under the age of 18. LuckyThorne is intended for adults only, and access to gambling products is restricted to those aged 18 and over.
We do not sell personal data. Personal data may be shared with service providers who act on our behalf (for example, hosting and analytics suppliers) under appropriate contractual safeguards, and with third parties where required by law. Because we operate an affiliate model, outbound links to gambling operators are handled as described in our [Affiliate Disclosure]({{< relref "affiliate-disclosure.md" >}}); when you follow such a link, any data you subsequently provide is governed by that operator's own privacy policy. Recipients and processors should be listed at [PLACEHOLDER: categories of recipients / processors].
## How and why we use your data
## 6. International transfers
We use personal data to operate and secure the site, to respond to enquiries you send us, to understand how the site is used so we can improve our content, and to measure referrals to third-party operators. The lawful basis we rely on for each purpose is [PLACEHOLDER: lawful bases per processing purpose to be confirmed by legal counsel].
Where personal data is transferred outside your jurisdiction, such transfers are made only where a lawful transfer mechanism is in place, such as an adequacy decision or standard contractual clauses. The transfer mechanisms and destinations relied upon should be confirmed at [PLACEHOLDER: transfer mechanisms and destination countries].
Where the law requires your consent — for example, for non-essential cookies or analytics — we will ask for it and you may withdraw it at any time. We do not sell your personal data.
## 7. Data retention
## Affiliate links and third parties
We retain personal data only for as long as necessary for the purposes for which it was collected, or as required to meet legal, accounting or reporting obligations. Specific retention periods for each category of data should be set out at [PLACEHOLDER: retention periods by data category].
LuckyThorne contains affiliate links. When you click through to a partner operator, that operator becomes responsible for the data it collects from you under its own privacy policy, which we do not control. We may record that an outbound click occurred, together with a tracking identifier, so that referrals can be attributed. The categories of third parties we share data with, and any international transfers involved, are set out at [PLACEHOLDER: list of processors, third parties and transfer mechanisms to be confirmed].
## 8. Your rights
Once you leave our site, we encourage you to read the privacy policy of the operator you visit before creating an account or providing personal or payment information.
Subject to applicable law, you may have the right to access your personal data; to request rectification of inaccurate data; to request erasure; to restrict or object to certain processing; to data portability; and, where processing is based on consent, to withdraw that consent at any time without affecting prior lawful processing. You also have the right to lodge a complaint with a supervisory authority [PLACEHOLDER: name and contact details of the relevant supervisory authority].
## How long we keep your data
## 9. How to exercise your rights
We keep personal data only for as long as needed for the purposes described in this policy, or as required by law. Specific retention periods for each data category are [PLACEHOLDER: retention schedule to be confirmed].
To exercise any of these rights, please contact us at [PLACEHOLDER: data protection contact email]. We may need to verify your identity before responding and will reply within the period required by applicable law. There is normally no fee, although we may charge a reasonable fee or decline a request where permitted, for example if it is manifestly unfounded or excessive.
## Your rights
## 10. Changes to this policy
Subject to the applicable law, you may have the right to access the personal data we hold about you, to have it corrected or deleted, to restrict or object to certain processing, to data portability, and to withdraw consent where processing relies on it. You may also have the right to lodge a complaint with a supervisory authority. The relevant supervisory authority and the exact scope of these rights depend on your location and are [PLACEHOLDER: applicable supervisory authority and rights detail to be confirmed by legal counsel].
We may update this policy from time to time. The effective date of the current version is [PLACEHOLDER: effective date], and any material changes will be reflected on this page. Please review it periodically to stay informed about how personal data is handled.
To make a request, email us at hello@luckythorne.example. We may need to verify your identity before responding.
---
## Security
We take reasonable technical and organisational measures to protect personal data against loss, misuse and unauthorised access. No online service can be guaranteed to be completely secure, and the specific safeguards in place are [PLACEHOLDER: security measures to be confirmed].
## Changes to this policy
We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above and, where appropriate, provide further notice. The effective date of the current version will be confirmed on approval by legal counsel.
## Contact us
If you have any questions about this policy or how we handle your personal data, contact us at hello@luckythorne.example.
Gambling can be addictive. Please play responsibly. You must be 18 or over to gamble. Support is available if gambling stops being fun — details for accessing help are set out on our [responsible gambling page]({{< relref responsible-gambling.md >}}). 18+ | T&Cs apply.
This website is intended for adults aged 18 and over. If gambling is affecting you or someone you know, support is available; please seek help from an appropriate responsible-gambling service. 18+, T&Cs apply, verify on operator site.