GM Gaming, as an operator of ThunderLuck (“the Company”, “we” or “us”) is a company operating online gaming websites as well as online gaming mobile applications. We respect your privacy and are committed to protect the privacy of our users (“user” or “you”).
- What type of information we collect
- How we collect your information
- Cookies and Google Analytics
- How we use the information we collect
- With whom we share the information, and for what purpose
- For how long we retain the information we collect
- How do we safeguard your information
- How to contact us
What type of information we collect
We collect two types of data and information from our users.
The first type of information is un-identified and non-identifiable information pertaining to a user(s), which may be made available or gathered via your use of the Services (“Non-personal Information”). We are not aware of the identity of the user from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time and the domain name of the website from which you linked to the Services; etc.), in order to enhance the functionality of our Services. We may also collect information on your activity on the Services (e.g. pages viewed, online browsing, clicks, actions, etc.).
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”). When you use our Services, you will be asked to provide Personal Information to us.
The Personal information we collect through our Services includes information which is submitted directly by the user, such as: full name; e-mail address; home address; date of birth; phone number; payment means (e.g. credit card number); and other financial information that we may need in order to provide our Services.
We may also collect Personal Information from your device (e.g. IP address) and your device’ unique identifiers (e.g. MAC addresses, UUID, etc.).
If we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information for as long as it remains combined.
How we collect information
There are three main methods we may use to collect information:
- We collect information which you provide us voluntarily. For example, we collect Personal Information which you provide when you respond to communications from us, open an account and use the Services, etc.
- We collect information through your use of the Services. In other words, when you are using our Services, we are aware of it and may gather the information relating to such usage, either independently or through the help of third-party services as detailed below.
- We collect information through our trusted third-party service providers, such as information about your credit history and other financial information which is relevant to our Services, as well as information which is gathered in order to conduct anonymous analytics, verify your identity or prevent fraudulent or illegal activity.
Cookies and Google Analytics
A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
Our website uses the following types of cookies:
- 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
- 'persistent cookies' which are read only by our website, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
- 'third party cookies' which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.
Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Service may not operate properly and your online experience may be limited.
How we use the information we collect
- To set up your account and to provide our Services (e.g. process your payments; etc.)
- To communicate with you and to keep you informed of our latest updates;
- To provide you with a responsible gaming environment;
- To market our websites and products or those of any of our business partners and marketing affiliates (see below under “Marketing”);
- To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services;
- To perform a research or to conduct anonymous analytics in order to improve and customize our Services to your needs and interests;
- To support and troubleshoot our Services and to respond to your queries; and
- To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority (e.g. the Maltese Gaming Authority), or to comply with a subpoena or similar legal process or respond to a government request.
With whom we share the information we collect
We may share Personal Information with the following recipients: (i) our subsidiaries; (ii) companies (and their employees) within the same corporate group as the Company (“Group”) and other affiliated companies; (iii) subcontractors and other third party service providers; (iv) auditors or advisers of any of the Group's business processes; and (v) any potential purchasers or investors in any of the companies within the Group.
We may also disclose Personal Information, or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies (including our Agreement), including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
Third party collection of information
Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via our Services (e.g. by clicking on a link to any other website or location) or via other sites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them.
For how long we retain the information we collect?
We value your privacy and control over your Personal Information, and therefore you may, at any time, request to change and update it by contacting us.
Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
How do we safeguard and transfer your information?
We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of our users’ information, and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse our Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.
Since we operate globally, it may be necessary to transfer your Personal Information to countries outside the European Union. The data protection and other laws of these countries may not be as comprehensive as those in the European Union − in these instances we will take steps to ensure that a similar level of protection is given to your Personal Information. You hereby consent to transfer of your Personal Information to countries outside the European Union.
If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse our Services or acted in an inappropriate manner, please contact us directly.
We may use your Personal Information, such as your name, email address, telephone number, etc. ("Connection Details") ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our Services, as well as products, services, websites and applications which relate to: (i) other companies within the Group; or (ii) our business partners and affiliates (collectively: “Marketing Affiliates”), which we believe may interest you.
We may also share and disclose Connection Details with our Marketing Affiliates (including with other online gaming operators) for the purpose of providing you different marketing offers we or our Marketing Affiliates believe are relevant for you. Our Marketing Affiliates may use this Personal Information for different marketing techniques, such as direct email, SMS and telephone marketing, for the purpose of providing you with promotional materials, concerning their related products, services, websites and applications.
Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us or from our Marketing Affiliates. In addition, at any time, you may request to unsubscribe and discontinue receiving marketing offers by contacting us.
If you unsubscribe we will remove your email address from our marketing distribution lists and from any future lists we may share with our Marketing Affiliates. However, you may need to separately unsubscribe from marketing offers sent by our Marketing Affiliates. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you service-related updates and notifications.
You hereby acknowledge and agree that by downloading, installing or accessing to our Services, we may send you marketing materials which relate to our Marketing Affiliates and also share your Personal Information (e.g. Connection Details) with our Marketing Affiliates for the purpose of direct marketing.
In addition, in the event we sell all or any part of our database to any business partner, online gaming operator or any Marketing Affiliate, we may transfer your Connection Details to them, for the purpose of them offering you’re their products or providing you with promotional materials, concerning their related products, services, websites and applications. Out of respect for your right to privacy, you may opt-out and request, at any time, that we shall not transfer your Connection Details to any business partner, online gaming operator or any Marketing Affiliate, as part of the transaction relating to our database, by contacting us in which case your Connection Details will not be transferred.
The Services are not designated to users under the age of 18. If you are under 18, you should not download or use the Services nor provide any Personal Information to us.
We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that a user under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us.
Information about us
The details of the Company are as follow:
of Villa Seminia 8,
Sir Temi Zammit Avenue,