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This Privacy Policy (hereinafter - Privacy Policy)

This Privacy Policy (hereinafter - Privacy Policy) has been developed under the General Data Protection Policy (hereinafter - GDPR) and is designed to define the processing of personal data and measures to ensure the security of personal data about individuals.

1.Terms and Definitions

1.1. Personal data is any information relating directly or indirectly to a specific or identifiable User of the Website.

1.2. Website means a set of graphic and information materials, as well as computer programs and databases, ensuring their availability on the website at on all sub-domains created on its basis.

1.3. Processing of personal data shall mean any action (operation) or a set of actions (operations) performed with personal data using automation means or without using such means, including: - collection; - recording; - systematization; - accumulation; - storage; - clarification (update, change); - extraction; - use; - transfer (distribution, provision, access); - depersonalization; - blocking; - removal; - destruction of personal data.

1.4. Automated processing of personal data shall mean processing of personal data by hardware means.

1.5. Dissemination of personal data shall mean actions aimed at disclosure of personal data to an indefinite number of persons

1.6. Provision of personal data shall mean actions aimed at disclosure of personal data to a certain person or a certain circle of persons.

1.7. Blocking of personal data shall mean temporary termination of personal data processing (except for cases when processing is necessary to clarify personal data).

1.8. Destruction of personal data shall mean actions resulting in the impossibility to restore the content of personal data in the information system of personal data and (or) as a result of which tangible media of personal data are destroyed.

1.9. De-identification of personal data shall mean actions, as a result of which it becomes impossible, without the use of additional information, to determine the attribution of personal data to a specific data subject.

1.10. Information system of personal data shall mean a set of information technologies and technical means contained in personal data bases and ensuring processing of personal data.

1.11. Cross-border transfer of personal data shall mean a transfer of personal data to the territory of a foreign state to a foreign authority, foreign individual, or foreign legal entity.

1.12. Personal Data Operator shall mean Brazy Portugal Ltd, independently or together with other persons organizing and (or) performing processing of personal data, as well as determining the purpose of personal data processing, the composition of personal data to be processed, actions (operations) performed with personal data.

1.13. Data Subject shall mean an individual to whom the relevant personal data relates.

1.14. User shall mean a natural person to whom the relevant personal data relates who is browsing the content of the website and/or using the functionality of the site for his/her own benefit or for the benefit of the legal entity he/she represents.

1.15. Subdomain shall mean the pages or the set of pages located on tertiary domains belonging to, as well as other temporary pages with contact information of the Operator at the bottom.

1.16. Cookies shall mean a small piece of data sent by a web service and stored on the computer of the data subject, which the browser sends each time the web server in HTTP-request when trying to open the page of the relevant website.

1.17. IP-address shall mean a unique network address of a node in a computer network, through which the data subject accesses the Website.

2.General provisions

2.1. Information about the Operator:

2.1.1. The Operator is FiveLive Owned. The operator Brazy Portugal.

2.2. The current version of this Privacy Policy is available on the Operator’s website at: All categories of data subjects covered by this Privacy Policy are required to familiarize themselves with the text of this Privacy Policy.

2.3. Transfer of personal information by the data subject shall mean the unconditional consent of the User to the terms of this Privacy Policy and the terms of processing of his personal data specified herein. In case of disagreement with the terms of the Privacy Policy, the data subject must refrain from transferring personal information to the Operator.

2.4. The Privacy Policy (including any part thereof) may be changed by the Operator without any special notice and any compensation being paid in connection therewith. The new version of the Privacy Policy shall come into force as soon as it is posted on the Operator's website.

2.5. By accepting the terms of the Privacy Policy, the data subject expresses his/her consent to the processing of data about him/her by the Operator for the purposes provided by the Privacy Policy, as well as to the transfer of data about the data subject to third parties in the cases listed in the Privacy Policy.

2.6. The use of the Website, its services through a web browser that accepts cookies shall mean the consent of the data subject to the fact that the Operator may collect and process data from cookies in order to improve the Website, its content, and functionality. Disabling and/or blocking by the data subject the option of the web browser to receive data from cookies means that the data subject’s use of the Website may be restricted, in particular some of its functions.

2.7. The Operator does not verify the accuracy of personal information provided by the data subject.

3.Composition of information about the Users of the website, which is received and processed by the Operator

3.1. This Privacy Policy applies to the following types of personal information:

3.1.1. Personal information posted by Users, including personal information about themselves when filling out the form on the website. Personal information obtained in this way may include, but is not limited to ∙ identification data (name, surname of the User); ∙ contact data (e-mail address); ∙ other personal information to which the User grants access to the Operator at the Operator's discretion. It is forbidden for the User to provide personal data of third parties without the permission thereof for such distribution or if such personal data of third parties were not received by the User from publicly available information sources.

3.1.2. Data automatically transmitted to the Website in the course of the use thereof through the software installed on the User’s device, including IP-address, individual network number of the device (MAC-address, device ID), electronic serial number (IMEI, MEID), cookies, information about the browser, operating system, access time, and User search queries.

3.1.3. The data additionally provided by the Users upon the Operator's request in order to fulfil the Operator's obligations to the Users in relation to the use of the Website.

3.1.4. Other information about Users, collection and/or processing of which is stipulated in the agreement.

4.Purposes of collecting and processing information about Website Users

4.1. The operator collects and processes only the information about the Users, including their personal data, which is relevant for achieving the following objectives:

4.1.1. In connection with the use of the Operator’s website.

4.1.2. Sending requests regarding using the Website, informing Users about new services on the Website, informing via electronic mailing lists, including about new promotions, offers, and recommendations about services, contests, and news of the Operator (including offers to leave a review or take a poll). By providing their data User agrees to receive advertising and information messages, and service messages (mailing list).

4.1.3. Performance of marketing tasks, statistical and other research based on impersonal data, to improve the Website, marketing, relationships with Users, as well as further improvement, development of new services.

4.1.4. Communication with the User to fulfil contractual obligations, informing Users about the appearance of new services on the Website, informing by means of electronic mailing lists, including new offers and recommendations about services, contests, and news of the Operator. By submitting their data, the User agrees to be notified by telephone.

4.1.5. To administer and protect the Website, including troubleshooting, data analysis, testing, system maintenance, support, reporting, and data hosting.

4.2. If it is necessary to use personal information about the User for the purposes not stipulated by the Privacy Policy, the Operator requests the User’s consent for such actions.

5.Legal basis for personal data processing

5.1. The Privacy Policy has been developed in accordance with the EU Regulation 2016/679 and local relevant legislations.

5.2. We may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary:

  • To comply with our legal obligations;
  • To comply with legal process and to respond to claims asserted against us;
  • To respond to requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability;
  • To enforce and administer our Terms of Service, or
  • To protect our and our employees’ rights, property or personal safety.

5.3. Legal basis for processing personal data: - consent to the processing of personal data;

5.4. The operator processes personal information, including personal data, only in the following cases:

5.4.1. processing is necessary for fulfilling the Operator’s obligations to the data subjects.

5.4.2. processing is necessary to comply with statutory obligations.

5.4.3. when it is required by applicable law, processing is necessary to ensure the Operator's legitimate interests if such processing does not have a significant impact on the interests, fundamental rights, and freedoms of the data subjects. When processing personal information on this basis, the Operator will always seek to maintain a balance between its legitimate interests and protecting the confidentiality of the data subject.

6.Processing of personal data of the data subjects

6.1. In most cases, personal data is processed automatically without access to it by the Operator. If such access is required, it can be provided only to the persons who need it to complete their tasks. To protect and ensure the confidentiality of data, all persons must comply with internal policies and procedures regarding the processing of Personal Data. They must also follow all technical and organizational security measures in place to protect personal data.

6.2. The operator has implemented sufficient technical and organizational measures to protect personal data from an unauthorized, accidental or unlawful destruction, loss, modification, unfair use, disclosure or access, as well as other unlawful forms of processing. These security measures have been implemented taking into account the state of the art, the cost of their implementation, the risks associated with the processing and the nature of personal data, including the following measures: ∙ anti-virus protection with updated databases; ∙ information backup; ∙ limitation of persons having access to the equipment; ∙ designation of a person responsible for personal data processing.

6.3. Personal data shall be stored by the Operator for as long as it is necessary to achieve the purpose for which it was collected, or to comply with the requirements of laws and regulations.

6.4. Personal information about the data subjects shall not be transferred to third parties, except in the following cases:

6.4.1. The data subject has consented to such actions.

6.4.2. If the Operator participates in a merger, acquisition or any other form of sale of some or all of its assets. In this case, all obligations to comply with the terms of the Privacy Policy shall be transferred to the acquirer of the Operator's assets.

6.5. The Data Subject is hereby notified and agrees that the Operator may receive personal data of third parties, which are provided by the Data Subject when using the Website, and use them to implement certain functions of the Website, provided that the Data Subject guarantees the consent of third parties, whose data are provided by the Data Subject when using the Website, for the data to be processed by the Operator, for the purposes provided by the Privacy Policy, as well as to transfer such data in the cases listed in the Privacy Policy.

6.6. The data subject of personal data has the right to receive, upon request, information from the Operator concerning the processing of their personal data

7.Procedure for withdrawal of consent to personal data processing, updating and correction of personal data, responses to requests for access to personal data

7.1. The data subject shall have the right to withdraw at any time the consent and authorization provided for processing of personal data by sending an email to

7.2. The data subject shall have the right to request deletion, correction, updating of personal data, to request the restriction of personal data processing or to object to the processing of personal data when required by law. The Operator shall respond to these requests in accordance with the law.

7.3. The User shall send inquiries and complaints to the Operator at the contacts specified in this Privacy Policy.

7.4. If it is confirmed that the personal data is inaccurate or unlawful, the personal data shall be updated by the Operator and the processing shall be terminated.

7.5. The Operator shall be obliged to inform the user or his representative about the processing of his/her personal data upon their request.

7.6. When the purposes of personal data processing have been achieved, as well as in case of withdrawal of the User’s consent to processing thereof, the personal data shall be destroyed: - unless otherwise provided for in an agreement to which the data subject on the grounds stipulated by GDPR and other local legislations - unless otherwise provided by other agreement between the Operator and the data subject.

8.Final provisions

8.1. Privacy Policy, relations between the data subject and the Operator, arising in connection with the application of the Privacy Policy, as well as issues not regulated by the Privacy Policy shall be governed by the applicable laws of EU and GDPR.

8.2. Data subjects may send requests, suggestions or questions regarding this Privacy Policy to the Operator at

Revision dated 31.05.2022