--- title: Privacy Policy linkTitle: Privacy Policy 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: 920 showInNav: false showInFooter: true footerGroup: legal relatedPages: - cookie-policy - terms - affiliate-disclosure - responsible-gambling schemaType: none date: 2026-07-16 lastmod: 2026-07-16 hideCta: true --- This page is a template containing placeholder wording that must be reviewed and completed by qualified legal counsel before publication. 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. ## 1. Who we are (data controller) 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]. ## 2. What data we collect 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]. ## 3. Lawful bases for processing 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]. ## 4. Cookies and analytics 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]. ## 5. Sharing your data 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]. ## 6. International transfers 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]. ## 7. Data retention 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]. ## 8. Your rights 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]. ## 9. How to exercise your rights 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. ## 10. Changes to this policy 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. --- 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.