Your privacy is important to us. It is Thorn.io's policy to respect your privacy regarding any
information we may collect from you across our website, https://thorn.io,
and other sites we own and operate.
1. Information we collect
When you visit our website, our servers may automatically log the standard data provided by your
browser. It may include your computer’s Internet Protocol (IP) address, your browser type and
the pages you visit, the time and date of your visit, the time spent on each page, and other
We may also collect data about the device you’re using to access our website. This data may
device type, operating system, unique device identifiers, device settings, and geo-location
we collect can depend on the individual settings of your device and software. We recommend
policies of your device manufacturer or software provider to learn what information they make
We may ask for personal information, such as your:
- Social media profiles
- Date of birth
- Phone/mobile number
- Home/Mailing address
- Work address
- Payment information
2. Legal bases for processing
We will process your personal information lawfully, fairly and in a transparent manner. We
process information about you only where we have legal bases for doing so.
These legal bases depend on the services you use and how you use them, meaning we collect and use
information only where:
- it’s necessary for the performance of a contract to which you are a party or to take steps
request before entering into such a contract (for example, when we provide a service you
- it satisfies a legitimate interest (which is not overridden by your data protection
as for research and development, to market and promote our services, and to protect our
- you give us consent to do so for a specific purpose (for example, you might consent to us
you our newsletter); or
- we need to process your data to comply with a legal obligation.
Where you consent to our use of information about you for a specific purpose, you have the right
change your mind at any time (but this will not affect any processing that has already taken
We don’t keep personal information for longer than is necessary. While we retain this
will protect it within commercially acceptable means to prevent loss and theft, as well as
access, disclosure, copying, use or modification. That said, we advise that no method of
transmission or storage is 100% secure and cannot guarantee absolute data security. If
retain your personal information for our compliance with a legal obligation or in order to
vital interests or the vital interests of another natural person.
3. Collection and use of information
We may collect, hold, use and disclose information for the following purposes and personal
will not be further processed in a manner that is incompatible with these purposes:
- to enable you to customise or personalise your experience of our website;
- to enable you to access and use our website, associated applications and associated social
- to contact and communicate with you;
- for internal record keeping and administrative purposes;
- for analytics, market research and business development, including to operate and improve
website, associated applications and associated social media platforms;
- for advertising and marketing, including to send you promotional information about our
services and information about third parties that we consider may be of interest to you; and
- to comply with our legal obligations and resolve any disputes that we may have.
4. Disclosure of personal information to third parties
We may disclose personal information to:
- third party service providers for the purpose of enabling them to provide their services,
(without limitation) IT service providers, data storage, hosting and server providers, ad
analytics, error loggers, debt collectors, maintenance or problem-solving providers,
advertising providers, professional advisors and payment systems operators;
- our employees, contractors and/or related entities;
- sponsors or promoters of any competition we run;
- credit reporting agencies, courts, tribunals and regulatory authorities, in the event you
pay for goods or services we have provided to you;
- courts, tribunals, regulatory authorities and law enforcement officers, as required by law,
connection with any actual or prospective legal proceedings, or in order to establish,
defend our legal rights; and
- third parties to collect and process data.
5. International transfers of personal information
The personal information we collect is stored and processed in Poland, or where we or our
affiliates and third-party providers maintain facilities. By providing us with your personal
information, you consent to the disclosure to these overseas third parties.
We will ensure that any transfer of personal information from countries in the European Economic
(EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by
standard data protection clauses approved by the European Commission, or the use of binding
rules or other legally accepted means.
Where we transfer personal information from a non-EEA country to another country, you acknowledge
third parties in other jurisdictions may not be subject to similar data protection laws to the
our jurisdiction. There are risks if any such third party engages in any act or practice that
contravene the data privacy laws in our jurisdiction and this might mean that you will not be
seek redress under our jurisdiction’s privacy laws.
6. Your rights and controlling your personal information
Choice and consent: By providing personal information to us, you consent to us
collecting, holding, using and disclosing your personal information in accordance with this
policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by
us, that you have your parent or legal guardian’s permission to access and use the website and
(your parents or guardian) have consented to you providing us with your personal information.
have to provide personal information to us, however, if you do not, it may affect your use of
website or the products and/or services offered on or through it.
Information from third parties: If we receive personal information about you
personal information about somebody else, you represent and warrant that you have such person’s
to provide the personal information to us.
Restrict: You may choose to restrict the collection or use of your personal
If you have previously agreed to us using your personal information for direct marketing
may change your mind at any time by contacting us using the details below. If you ask us to
limit how we process your personal information, we will let you know how the restriction affects
use of our website or products and services.
Access and data portability: You may request details of the personal information
hold about you. You may request a copy of the personal information we hold about you. Where
will provide this information in CSV format or other easily readable machine format. You may
that we erase the personal information we hold about you at any time. You may also request that
transfer this personal information to another third party.
Correction: If you believe that any information we hold about you is inaccurate,
date, incomplete, irrelevant or misleading, please contact us using the details below. We will
reasonable steps to correct any information found to be inaccurate, incomplete, misleading or
Notification of data breaches: We will comply laws applicable to us in respect
Complaints: If you believe that we have breached a relevant data protection law
to make a complaint, please contact us using the details below and provide us with full details
alleged breach. We will promptly investigate your complaint and respond to you, in writing,
the outcome of our investigation and the steps we will take to deal with your complaint. You
the right to contact a regulatory body or data protection authority in relation to your
Unsubscribe: To unsubscribe from our e-mail database or opt-out of
(including marketing communications), please contact us using the details below or opt-out using
opt-out facilities provided in the communication.
We use “cookies” to collect information about you and your activity across our site. A cookie is
piece of data that our website stores on your computer, and accesses each time you visit, so we
understand how you use our site. This helps us serve you content based on preferences you have
8. Business transfers
If we or our assets are acquired, or in the unlikely event that we go out of business or enter
bankruptcy, we would include data among the assets transferred to any parties who acquire us.
acknowledge that such transfers may occur, and that any parties who acquire us may continue to
personal information according to this policy.
9. Limits of our policy
Our website may link to external sites that are not operated by us. Please be aware that we have
control over the content and policies of those sites, and cannot accept responsibility or
their respective privacy practices.
10. Changes to this policy
reasonable steps to let users know about changes via our website. Your continued use of this
any changes to this policy will be regarded as acceptance of our practices around privacy and
process your personal information, we will ask you to re-consent to the amended privacy
Thorn.io Data Controller
This policy is effective as of 6 April 2020.