FRELIVINIA SERVICES LTD, a company duly incorporated in Cyprus, under Registration Number HE352102, operating under the Business Name DRAGONFREE, hereinafter referred to as Dragonfree, 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 Dragonfree, 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 Dragonfree varies depending on the services provided by Dragonfree to the Customers, the Subscriptions of the Customers and/or the use of the Websites of Dragonfree by the Customers, as follows:

a) Through and throughout the Customer’s use of the Dragonfree’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 Dragonfree regarding or in connection to the provision of Services by Dragonfree.

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

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

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


Throughout Dragonfree’s relationship with the Customers, Dragonfree 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 Dragonfree

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


Dragonfree 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 Dragonfree’s websites and analysing internet traffic on the Dragonfree’s websites.


Dragonfree 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 Dragonfree’s websites and the Customer’s location information.


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

a) For the purposes of provision of the Services by Dragonfree.

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 Dragonfree with regards to Dragonfree’s Services via email, post and/or text messages, provided that the Customers have requested the same provided relevant consent to Dragonfree 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, Dragonfree may send the Customer information with regards to Dragonfree’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 Dragonfree, by providing Dragonfree with written notice to opt out of receipt of such communication.

e) For the purposes of improving, altering and updating the Services provided by Dragonfree 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 Dragonfree’s Customers.

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

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



Dragonfree 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 Dragonfree to provide its Services to the Customer, and/or downloads any information and/or data made available by Dragonfree on the Websites, the Customer must provide such consent to Dragonfree, 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 Dragonfree 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 Dragonfree.

Dragonfree 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 Dragonfree’s Services to Customers, to implement Dragonfree t’s contractual obligations, to protect and secure Dragonfree’s Customers, to effectively promote the Dragonfree’s operations, to protect Dragonfree’s interests and to monitor and investigate unlawful actions.



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

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

b) Dragonfree’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 Dragonfree, such as updating and improving Dragonfree’s Services and prevent possibilities of fraud or other unlawful acts.

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

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

Dragonfree 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 Dragonfree 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 Dragonfree by the Customer, if such information changes at any time, the Customer may delete, update, review or alter personal information by providing Dragonfree with an email requesting the same. Dragonfree shall use its best endeavours to undertake such requests as soon as possible.


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

Dragonfree may further disclose the Customer’s personal information and/or data to third parties, if Dragonfree t believes that such third parties need to contact the Customer, without limitation, for the following purposes:

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

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

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



The Websites of Dragonfree may provide or display links to other websites of third party physical or legal entities. While displaying or providing such links, Dragonfree 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.


Dragonfree does not make any representations or warranties that Dragonfree’s websites or any third party websites for which the links are provided or displayed on Dragonfree 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.



Dragonfree has in place certain procedures in pursuit of safeguarding and securing the information which is transmitted, collected online and/or is otherwise collected by Dragonfree. Dragonfree 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.


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

Dragonfree 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.