FRELIVINIA SERVICES LTD, a company duly incorporated in Cyprus, under Registration Number HE352102, operating under the Business Name DRAGONNET, hereinafter referred to as Dragonnet, is a duly authorised and licensed telecommunications services provider in the Republic of Cyprus, hereinafter referred to as the Services.

This Privacy Policy outlines how Dragonnet, manages and protects personal data and/or information which is collected and/or provided by Subscribers to our Services and/or Users of our Websites, hereinafter referred to as the Customers.

The data and/or information of the Customers collected by Dragonnet varies depending on the services provided by Dragonnet to the Customers, the Subscriptions of the Customers and/or the use of the Websites of Dragonnet by the Customers, as follows:

a) Through and throughout the Customer’s use of the Dragonnet’s Websites. Every time a Customer accesses, views and browses and/or uses the Websites, the Customer signifies acceptance of the effective Privacy Policy and provides consent to the management and processing of any data displayed, transferred through or uploaded to the Websites, which does not include personal data of the Customer. If the Customer does not accept the Privacy Policy, then the Customer is not authorized to use the Websites and must immediately cease use of the Websites.

b) Through applications, questionnaires and/or any other documents submitted and/or provided by the Customers to Dragonnet regarding or in connection to the provision of Services by Dragonnet.

c) Throughout any form of communication held between Dragonnet and the Customer, including telephone, email and post.

d) Through the use of the Services by the Customers, provided by Dragonnet.

e) Through the subscription by the Customers to any Services and/or notifications provided by Dragonnet.

Throughout Dragonnet’s relationship with the Customers, Dragonnet may collect the following personal data/information of the Customer:

a) Name, Surname, Residential Address, E-mail, Telephone Number and Date of Birth

b) Banking information, including account number, card information and payment details

c) Data and/or information regarding the Customer’s services provided by Dragonnet

d) Data and/or information regarding and throughout the Customer’s use of Dragonnet’s Websites, including browsing and location data

Dragonnet may collect information about the Customer’s activity on the websites via use of tracking technologies such as cookies. This data may be used without limitation for delivery of relevant content which is based on the Customer’s preferences, use patterns or location, monitoring and evaluating the operation or use of Dragonnet’s websites and analysing internet traffic on the Dragonnet’s websites.

Dragonnet may also collect other non-personal information such as the Customer’s IP address, operating system of the Customer’s computer or the browser used by the Customer, the Customer’s activities, content accessed by the Customer throughout use of Dragonnet’s websites and the Customer’s location information.

Dragonnet may use the data/information collected by Dragonnet as follows:

a) For the purposes of provision of the Services by Dragonnet

b) For the purposes of receiving payments from Customers and providing them with invoices, statements and/or reminders.

c) For the purposes of communication with the Customers and respond to any of their inquiries and/or requests.

d) For marketing and/or promotional purposes and in order to inform and keep informed and/or updated the Customers of Dragonnet with regards to Dragonnet’s Services via email, post and/or text messages, provided that the Customers have requested the same provided relevant consent to Dragonnet for these purposes. Subject to the Customer’s consent provided through the Websites by way of opt-in or through relevant application forms and/or documentation and/or otherwise, Dragonnet may send the Customer information with regards to Dragonnet’s Services or the Customer’s use of the Services. The Customer may at any time opt out of email, text or other communication from Dragonnet, by providing Dragonnet with written notice to opt out of receipt of such communication.

e) For the purposes of improving, altering and updating the Services provided by Dragonnet by managing and comprehending the way in which the Services are used by the Customers.

f) For the purposes of identifying, preventing and detecting fraud, impersonation or any other unlawful acts.

g) For the purposes of collecting and/or receiving any dues by and/from Dragonnet’s Customers.

h) For the purposes of administrating, controlling and monitoring the use of Dragonnet’s Websites.

i) For the purposes of enforcing the Terms and Conditions of Dragonnet.

Dragonnet may collect, process or manage personal information of the Customer, by obtaining the consent of the Customer to the same. Every time the Customer requests Dragonnet to provide its Services to the Customer, and/or downloads any information and/or data made available by Dragonnet on the Websites, the Customer must provide such consent to Dragonnet, by actively agreeing to be bound by the Privacy Policy and the Terms and Conditions, (positive opt-in) the moment the Customer completes an application and/or other documentation with regards to the provision of the Services by Dragonnet and/or at the moment that the Customer proceeds to download any information and/or data from the Websites, as well as at the moment that the Customer proceeds to convey and/or upload any information and/or data, including personal data, through the Websites to Dragonnet.

Dragonnet processes the personal data/information of the Customers in line with the relevant domestic data protection laws, as well as the EU General Data Protection Regulation.

This data/information is processed for the purposes of effectively providing the Dragonnet’s Services to Customers, to implement Dragonnet’s contractual obligations, to protect and secure Dragonnet’s Customers, to effectively promote the Dragonnet’s operations, to protect Dragonnet’s interests and to monitor and investigate unlawful actions.

Dragonnet may use and/or process personal data/information based on any of the following reasons:

a) The effective provision of the Services by Dragonnet to the Customers, pursuant to relevant agreements concluded between them or otherwise.

b) Dragonnet’s compliance with any law and/or regulation.

c) The provided Customer’s consent. The Customer may cancel and/or revoke such consent.

d) The protection of the legitimate interests of Dragonnet, such as updating and improving Dragonnet’s Services and prevent possibilities of fraud or other unlawful acts.

e) There is a lawful basis for Dragonnet to do so.

f) Dragonnet has the right to use or share such information with any partners and/or counterparties of Dragonnet and with any third parties if this is necessary or required in order for Dragonnet to effectively provide its Services to the Customer.

Dragonnet pursues to allow its Customers to have better control over their data and aims to be at all times in line with the General Data Protection Regulation (GDPR). The Customer always has the right, with regards to its data kept by Dragonnet, to be informed with regards to the processing of such data, to amend or update any data that may be inaccurate, incomplete or incorrect, to erase or delete any such data, to restrict the processing of the data and to access the data upon such request. Following the submission, transmission, upload or otherwise provision of personal information to Dragonnet by the Customer, if such information changes at any time, the Customer may delete, update, review or alter personal information by providing Dragonnet with an email requesting the same. Dragonnet shall use its best endeavours to undertake such requests as soon as possible.


Dragonnet has the right to use or share data/information with any partners and/or counterparties of Dragonnet and with any third parties if this is necessary or required in order for Dragonnet to effectively provide its Services to the Customer.

Dragonnet may further disclose the Customer’s personal information and/or data to third parties, if Dragonnet believes that such third parties need to contact the Customer, without limitation, for the following purposes:

a) Dragonnet is required to do so by law or Court proceedings

b) Dragonnet is required to do so by governmental departments or law enforcement authorities

c) Dragonnet deems in good faith that it is advisable or necessary to provide its Services

Any information/data, whether personal or not, which is posted, transferred through or displayed on Dragonnet’s websites by the Customer or Dragonnet, may not be used or copied in any manner or form without the written consent of Dragonnet. However, the above information/data may be used and/or collected by third parties over which Dragonnet has no control. Dragonnet is not responsible for collection or use of information by third parties, which is posted or made public by the Customer on Dragonnet’s website.

The Websites of Dragonnet may provide or display links to other websites of third party physical or legal entities. While displaying or providing such links, Dragonnet does not endorse, control or operate them, disclaims any liability or responsibility for the content of such websites and use of such websites are at the sole discretion and responsibility of the Customer, including without limitation, such websites’ privacy policies.

Dragonnet does not make any representations or warranties that Dragonnet’s websites or any third party websites for which the links are provided or displayed on Dragonnet’s websites shall function properly, without any interruptions or errors or that they are free of viruses or other issues which may harm the Customer’s computer.

Dragonnet has in place certain procedures in pursuit of safeguarding and securing the information which is transmitted, collected online and/or is otherwise collected by Dragonnet. Dragonnet protects such information, including personal information by undertaking reasonable precautions and following the industries best practices to make sure that such data is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

Dragonnet has in place a Data Protection Officer, systematically guiding and consulting Dragonnet’s employees on the processing of personal data and keeps records of the Customers of Dragonnet. Any Customer may contact Dragonnet at any time, for any clarifications with regards to the type of data kept by Dragonnet, and with regards to accessing, rectifying, erasing and/or restricting that Customer’s personal data.

Dragonnet may revise the Privacy Policy from time to time and provide or display an effective date of the revised Privacy Policy on the Websites. Any revisions and alterations of the Privacy Policy shall be effective as of the date on which the revised or altered Privacy Policy is posted or otherwise made available on the Websites. The Customer should monitor the Privacy Policy and the Terms and Conditions on a regular basis in order to be aware of the most recent applicable Privacy Policy and Terms and Conditions. The Privacy Policy is effective as of the 25th day of May 2018.