At THNDR we respect your privacy and are committed to protecting your personal data. This privacy notice will inform you of our practices around handing personal data and outline privacy rights and how the law protects you.
This privacy notice is provided in a layered format with clickable sections set out below. Please refer to the Glossary for additional information on the terms used in this privacy notice.
THNDR LTD is a company responsible for designing and maintaining a next-generation competitive gaming platform called Clinch. This platform includes an API and suite of developer tools for powering mobile games and applications with Clinch**.**
CLINCH is a peer-to-peer wagering system. For this operation THNDR is takes a fee for the oracle function, i.e. the confirmation of results of a clinch.
Payment is instantaneous, borderless, low-fee, peer-to-peer using the Bitcoin Lightning Network.
The Clinch service and all Clinch games, wholly owned and operated by THNDR, were tested to ensure that they are as fair and skill-based as possible. All players operate under the same rules and are dealt the same hand of cards during a Clinch (i.e. game or match). The outcome of all matches on the Clinch platform are skill-based and any element of randomness or luck are minimized.
This privacy notice aims to provide information on how THNDR collects and processes personal data, including any data provided to the Company directly via any company website or otherwise. It is important that you read this privacy notice together with any other privacy notice, fair processing notice or privacy policy THNDR may provide on specific occasions when the Company is collecting or processing personal data about the user so that you are fully aware of how and why your data is being used.
THNDR LTD is the controller and responsible for all personal data (collectively referred to as THNDR, the Company, “we“, “us” or “our” in this privacy notice).
THNDR has appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. Any questions about this privacy notice, including any requests to exercise your legal rights, should be directed towards the data privacy manager using the details set out below.
Full name of legal entity: THNDR LTD
Name or title of data privacy manager: Desiree Dickerson
Email address: hello@thndr.games
Postal address: THNDR LTD, 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the chance to deal with ant concerns before approaching the ICO. Please contact the THNDR data privacy manager in the first instance.
This version was last updated on 3 Jun 2024 and historic versions can be obtained by contacting the company at hello@thndr.games.
It is important that the personal data the Company holds about you is accurate and current. Please keep THNDR informed if your personal data changes during your relationship with us.
The THNDR website or mobile application may include links to third-party websites, plug-ins and applications. Clicking on said links or enabling those connections may allow third parties to collect or share data about you. THNDR does not control third-party websites and is not responsible for privacy statements of any third party. When you leave any THNDR website, we encourage you to read the privacy notice of any website you visit.
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped together follows:
Any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). THNDR does not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor does the Company collect any information about criminal convictions and offences.
Includes first names, last names, usernames or similar identifiers.
Includes delivery address (also for potential physical prizes), email address, and telephone numbers.In the case of physical prizes (e.g T-Shirts, Badges), THNDR we may collect and store additional details of the products and services you have purchased or won from the Company and other personal data.
Bolt11 invoice transaction data between you and other participants of our services. This data includes details about payments settled by THNDR through a Clinch.
Includes internet protocol (IP) address, non-precise location based on your IP address, your login data, browser type and version, time zone setting and GPS location, language preference, browser plug-in types and versions, operating system and platform, mobile device make, model and operating system, mobile identifiers such as Apple IDFA or Google AAID, mobile device properties related to the device screen size and orientation, audio volume and battery, mobile network carrier, network connection type and speed and other technology on the devices you use to access our website or mobile applications.
Including your internet protocol (IP) address, operating system, browser type, browser ID, date/time of visit, and pages visited.
Includes your username, payments, or orders made by you, your interests, preferences, feedback and survey responses.
Includes information about how you use our website, mobile applications, products and services, and your progress in our games.
Messages to us includes chat logs and player support tickets as well as messaging via social media accounts.
includes your preferences in receiving marketing from us and our third parties,your communication preferences, and your engagement with email marketing campaigns.
THNDR also collects, uses, and shares Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, the Company may aggregate your Usage Data to calculate the percentage of users accessing a specific website or mobile application feature. However, if the Company combines or connects Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
THNDR does not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 18 or knowingly allow such persons to use our services. If you are under 18, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 18 may provide any personal data. If the Company becomes aware that personal data has been collected about a child under age 18, the Company will delete that data as quickly as possible. If you believe that THNDR might have any data from or about a child under the age of 18, please contact us immediately at hello@thndr.games
Where THNDR is required to collect personal data by law, or under the terms of a contract the Company has with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, the Company may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
If there is a change in legislation, the Company may need to request updated personal data from you. In such instances, the Company will make efforts to communicate with you to meet the new requirements. There might be situations where the Company is required to prompt you to provide necessary data in accordance with new regulations to ensure continued access to THNDR services.
THNDR can also be responsible for changes and may require you to provide necessary data as part of an update to our Privacy Policy.
When you agree to this Privacy notice within one of our games and services, we create an account for you on our platform. This backs up your history, progress, and enables the Company to authenticate you.
Your Clinch password and the Clinch web platform is not connected to your general THNDR account available on Google Play and the App Store..
THNDR does not connect Clinch IDs with THNDR ID (i.e. the ID available in the Google Play and App Store version of games), without player request and direct action inside our services.
The security of your account relies on your protection of your password and mobile device. You are responsible for maintaining the security of your password and mobile device. You are solely responsible for any and all activities that occur under your accounts. You may not share your password with anyone. We will never ask you to send us your password or other sensitive information via email or chat, although we may ask you to enter this type of information during the log-in and sign-in process.
Any email or other communication requesting your password or asking you to provide sensitive account information via email should be treated as suspicious and should be reported to THNDR immediately. If you do share your password or mobile device with a third party for any reason, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please immediately change it. If you believe that unauthorised access has already occurred please report it as fast as possible to hello@thndr.games.
We authenticate users in Clinch by logging into one of the existing platforms, such as Google or X (Previously Twitter). This authentication is stored on Firebase servers.
THNDR uses different methods to collect data from and about you through:
You may give THNDR your Identity, and Contact data by filling in forms or by corresponding with the Company by post, phone, email, or otherwise. This includes personal data you provide when you: avail of our products or services; create an account on our website or mobile applications; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback.
As you interact with our website or mobile applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources. Technical Data from the following parties: analytics providers; advertising networks; and search information providers. Contact and Transaction Data from providers of technical, payment, and delivery services. Identity and Contact Data from data brokers or aggregators
Cookies listed below are necessary for THNDR’s websites to work properly:
THNDR will only use your personal data when the law allows us to. Most commonly, THNDR will use your personal data in the following circumstances:
Where the Company needs to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for THNDR’s legitimate interests (or those of a third party) and your interests, and fundamental rights do not override those interests.
Where THNDR is required to comply with a legal or regulatory obligation.
Generally THNDR does not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us hello@thndr.games
In the description below you will find a list of how THNDR intended to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (hello@thndr.games) if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.
To register you as a new customer or client, THNDR processes your identity and contact data. The lawful basis for this is the performance of a contract with you.
For processing your orders or requests and delivering products/services, including managing payments and collecting debts, the company uses your identity, contact, transaction, and marketing and communications data. This is based on the performance of a contract with you and the company's legitimate interests in recovering debts.
To manage the Company’s relationship with you, including notifying you about changes and soliciting feedback, THNDR processes your identity, contact, profile, and marketing and communications data. This is necessary for the performance of a contract, compliance with legal obligations, and the Company's legitimate interests in maintaining updated records and understanding customer usage.
For your participation in competitions, surveys, and feedback, the company uses your identity, contact, profile, usage, social media, and marketing and communications data. This is necessary for contract performance and the company's legitimate interests in understanding customer usage, business development, and customer support.
To administer and protect their business and website, THNDR processes your identity, contact, technical, and usage data. This is necessary for the Company's legitimate interests in business operation, IT services, network security, fraud prevention, and legal compliance.
For data analytics to improve their website, apps, products, marketing, and customer relationships, the company uses your technical and usage data. This is done for the Company's legitimate interests in defining customer types, keeping platforms updated, business development, and marketing strategies.
The company processes your identity, contact, profile, usage, marketing and communications, and technical data to deliver relevant content and ads and to understand their effectiveness. This is necessary for the company's legitimate interests in studying customer usage, product development, business growth, and marketing strategy.
To make product/service suggestions and show personalised advertising, THNDR processes your identity, contact, technical, usage, profile, marketing and communications data, and technical and usage data. This is necessary for the company's legitimate interests in product development and business growth, as well as delivering relevant content and advertisements.
At THNDR, we strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
THNDR may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you ( hereafter referred to as marketing).
You will receive marketing communications from THNDR if you have requested information from us or proposed goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
THNDR will obtain your express consent through opt-in before sharing your personal data with any company outside THNDR’s group of companies for marketing purposes.
You may ask us or third parties to stop sending you marketing messages at any time by contacting us at any time – hello@thndr.games
Regardless of opting out of receiving marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience, or other transactions.
We may send you push notifications through our web and mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device or web browser. If you need support in changing these settings, please contact us at help@thndr.games.
If you wish to limit behaviourally targeted advertising, you can do so by limiting ad tracking in your device settings. You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and turning off “Allow Apps to Request to Track” or selecting "Limit Ad Tracking" (Apple iOS) or "Opt-out of Interest Based Ads" (Android).
For mobile advertising in apps, you can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting (iOS).
For display advertising on the Web, you can also adjust your browser settings to limit certain tracking by means of cookies, and by visiting the following sites: http://www.aboutads.info/choices and http://www.youronlinechoices.eu/.
THNDR will only use your personal data for the purposes for which it was collected, unless the Company reasonably considers there is a need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at hello@thndr.games. If the Company needs to use your personal data for an unrelated purpose, you will be notified along with an explanation of the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
THNDR may be required to share your personal data with the parties listed below. Sharing your personal data with said parties will only be done for purposes set out in the section, ‘Purposes for which we will use your personal data’.
THNDR requires all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with Company instructions.
All postings in THNDR or Clinch public forums will generally be available to, and freely accessible by, other users including the internet’s general public. Therefore, our users should not expect that any information they post will be kept private or confidential and are encouraged to exercise discretion when using the public forums including provided Chats on our web and room Chats.
Additionally, your username, which you can change, will always be included in conjunction with your postings in the public forums.
THNDR is not responsible for any events arising from the sharing of any information you choose to publicly post or share through these forums. All information or materials uploaded by you while utilising this service are your responsibility.
Some of THNDR’s external third parties may be based outside the U.K. so the processing of your personal data may involve a transfer of data outside the U.K..
Whenever the Company transfers your personal data out of the U.K. we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please be advised that THNDR’s service providers have implemented their own policies and rules concerning the protection of personal data. For more information, please visit the websites of our service providers.
Please contact us at hello@thndr.games if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
THNDR put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, THNDR limits access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instruction and are subject to a duty of confidentiality.
THNDR put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where legally required to do so.
THNDR will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, THNDR considers the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which the Company processed your personal data and whether those purposes can be achieved through other means, and the applicable legal requirements.
By law and for tax purposes, THNDR maintains basic information about our customers (including Contact, Identity, and Transaction Data) for at least six years after users cease being customers.
Details of other retention periods for different aspects of your personal data are contained in our retention policy which you can request from us by contacting us at hello@thndr.games
You may request the deletion of your data and in some circumstances the Company may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case your information may be used indefinitely without further notice to you.
All payment histories for individual accounts are retained for 7 years.
THNDR stores all Lightning Addresses and maintains a record of all payments in the Company database (Firebase Storage) with the account ID and payment details, including metadata about the source and destination of funds.
THNDR utilises Firebase services for user authentication.
Players can request their payment history by contacting us at hello@thndr.games. Upon ID confirmation, the Company will provide the requested data as document via email.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data THNDR holds about you and to check that the Company is lawfully processing it.
Request correction of the personal data that THNDR holds about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask the Company to delete or remove personal data where there is no good reason for continued processing. You also have the right to ask the Company to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where the Company may have processed your information unlawfully or where required to erase your personal data to comply with local law. Note, however, that THNDR may not always be able to comply with your request of erasure for specific legal and tax reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where THNDR relies on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where THNDR processes your personal data for direct marketing purposes. In some cases, THNDR may demonstrate that the Company has compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask THNDR to suspend the processing of your personal data in the following scenarios: (a) if you want the Company to establish the data’s accuracy; (b) where THNDR’s use of the data is unlawful but you do not want the Company to erase it; (c) where you need THNDR to hold the data even if the Company no longer requires it as you need it to establish, exercise or defend legal claims; or (d) you have objected to THNDR’s use of your data but the Company needs to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. THNDR will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for THNDR to use or where the Company used the information to perform a contract with you.
Withdraw consent at any time where THNDR is relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, THNDR may not be able to provide certain products or services to you. THNDR will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us hello@thndr.games.
You will not be required to pay a fee to access your personal data (or to exercise any of the other rights). However, THNDR may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, the Company may refuse to comply with your request in these circumstances.
THNDR may request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. THNDR may also contact you to ask you for further information in relation to your request to speed up the response.
We try to respond to all legitimate requests within one month. Occasionally it may take longer than a month if your request is particularly complex or a number of requests have been made. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of the THNDR business in conducting and managing the Company’s business to enable us to give you the best service/product and the best and most secure experience. THDNR makes sure to consider and balance any potential impact on you (both positive and negative) and your rights before processing your personal data for the Company’s legitimate interests. THNDR does not use your personal data for activities where the Company’s interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us hello@thndr.games
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that the Company is subject to.
Internal Third Parties Other companies in THNDR’s corporate group who may act as joint controllers or processors and who may be based inside or outside the EU.
Service providers who may act as processors based inside or outside the EU and who provide IT, system administration and other services, including, but not limited to, third party analytics and advertising serving companies.
Professional advisers who may act as processors including lawyers, bankers, auditors, and insurers based inside or outside the EU who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators, and other authorities who may act as processors based inside or outside the EU who require reporting of processing activities in certain circumstances.
THNDR has practices in place to prevent money laundering and terrorism financing. THNDR acts according to the Anti-Money Laundering (AML) Policy and, therefore, are obligated to notify authorities in case of any suspicion of illegal activities.
By signing up with THNDR services, you are obliged to:
In order to effectively combat the aforementioned illegal activities,THNDR does the following:
In the event of a breach, THNDR will operate in accordance with AML procedures and retains the right to request from you the following information at any moment: your identification card(s), such as your passport or any document that contains your name, date of birth, and your photo and other potential documents to confirm your personal data and your identity.
To contact us with your questions or comments regarding this Privacy Policy or the information collection and dissemination practices of THNDR, please email us at hello@thndr.games
