Privacy Notice

Last updated: 15 March 2026

This Privacy Notice explains how Five by Five Kft. ("Five by Five", "we", "us", "our") processes personal data when you:

visit our website;
join our waitlist or raffle;
subscribe to our newsletter or create a member account;
purchase our products;
request warranty, repair, or support services; or
otherwise contact us.

We process personal data that you provide directly to us, data generated by your use of our website, and certain information we receive from service providers involved in website, newsletter, payment, or delivery services.

We do not use personal data for profiling. We do not make automated decisions about you that produce legal or similarly significant effects. Any raffle selection is random and is not based on personal characteristics.

1. Data controller

Five by Five Kft.

Registered office: 2040 Budaörs, Esze Tamás u. 13., Hungary

EU VAT: HU26186799

Email: shmoergh@gmail.com

Five by Five Kft. acts as the data controller for the processing described in this Privacy Notice.

2. Data Protection Officer

We are not required to appoint a Data Protection Officer (DPO) under the GDPR.

If you have questions about this Privacy Notice or would like to exercise your rights, please contact us using the details in Section 1.

3. What personal data we process

We may process the following categories of personal data, depending on how you interact with us.

3.1 Waitlist / raffle subscriptions

email address;
name, if you provide it;
record of your subscription and consent, including the date and time of sign-up; and
IP address and basic device or browser information collected through standard website or service logs.

email address;
name, if provided;
date and time of registration;
IP address and technical metadata used for security and verification; and
newsletter engagement data, such as whether an email was opened and which links were clicked, where such functionality is enabled by our newsletter platform.

3.3 Purchases, invoicing, and delivery

name;
billing address;
shipping address;
email address;
phone number (for courier delivery);
order details, including products purchased, dates, and amounts;
invoice information, such as company name and VAT number, if you purchase as a business customer; and
payment status and transaction references.

We do not store full payment card details.

3.4 Warranty, repairs, and support

name and contact details;
order details and proof of purchase;
product identifier (for example, a serial number); and
support messages and other information you provide to us, including attachments where relevant.

3.5 Website operation, security, and analytics

server logs, such as IP address, time of request, requested URL, referrer, browser or user-agent, and error logs;
strictly necessary cookies or similar technologies used to operate the website; and
analytics data, which may include aggregated usage statistics (for example, page views and browser or device type) and/or analytics cookies or similar technologies, if enabled.

4. Purposes, legal bases, and whether data is required

We process personal data only where we have a lawful basis for doing so.

Context	Main purposes	Legal basis
Waitlist / raffle	To manage sign-ups, maintain a record of consent, operate the waitlist or raffle, and send related notifications	Consent under Art. 6(1)(a) GDPR; related service security and logging may also rely on legitimate interests under Art. 6(1)(f) GDPR
Newsletter / member account	To manage subscriptions or member registrations, send newsletters, provide member-only content, and understand newsletter engagement	Consent under Art. 6(1)(a) GDPR for newsletter delivery and related engagement tracking where applicable; where member features are provided on request, performance of a contract or steps at your request under Art. 6(1)(b) GDPR may also apply; platform security relies on legitimate interests under Art. 6(1)(f) GDPR
Orders, payment, invoicing, and delivery	To enter into and perform the sales contract, confirm payment status, issue invoices, keep legally required records, and arrange delivery	Performance of a contract under Art. 6(1)(b) GDPR and legal obligation under Art. 6(1)(c) GDPR
Warranty, repairs, and support	To verify purchases, handle support, warranty and repair requests, and communicate with you about your request	Performance of a contract under Art. 6(1)(b) GDPR, legal obligation under Art. 6(1)(c) GDPR where applicable, and legitimate interests under Art. 6(1)(f) GDPR in handling support and related claims
Website operation, security, and analytics	To operate and secure the website, prevent abuse, troubleshoot issues, and improve performance and user experience	Legitimate interests under Art. 6(1)(f) GDPR; where analytics rely on non-essential cookies or similar technologies, consent under Art. 6(1)(a) GDPR

Our legitimate interests include maintaining the security and stability of our website and systems, preventing abuse, troubleshooting technical issues, and improving website performance, content, and user experience.

5. Cookies and similar technologies

Our website may use cookies or similar technologies.

Strictly necessary cookies may be used where needed to operate the website.
Analytics cookies or similar technologies may be used only if enabled and, where required by law, only on the basis of your consent.
You can usually control cookies through your browser settings. Blocking strictly necessary cookies may affect website functionality.

We may share personal data, as necessary, with the following recipients or categories of recipients.

6.1 Tally (waitlist / raffle forms)

To manage waitlist or raffle subscriptions, we use the form service Tally, operated by Tally BV (Ghent, Belgium).

When you submit a waitlist or raffle form, the information you enter into the form (for example, your email address, name if provided, and sign-up or consent timestamp) is transmitted to and stored by Tally.

We use Tally only to collect and manage sign-ups and to maintain a record of your subscription or consent. We have a data processing agreement in place with Tally. According to Tally's published documentation, data is stored on secure servers located within the European Union.

Further information: Tally Privacy Notice

Our website and newsletter services are powered by Ghost, operated by Ghost Foundation Ltd.

When you subscribe to our newsletter or create a member account, Ghost may process your email address, name (if provided), IP address, registration metadata, and newsletter engagement data such as email opens and link clicks.

We use Ghost to manage our subscriber list, send newsletters, and provide member-only content. We have a data processing agreement in place with Ghost. Ghost may process data globally and, where transfers outside the EEA occur, appropriate safeguards such as Standard Contractual Clauses may be used. If you no longer want us to process newsletter engagement data, you can unsubscribe from the newsletter.

Further information: Ghost Privacy Policy and Ghost GDPR Data Processing Agreement

6.3 Other recipients

We may also share personal data with:

courier and delivery providers (for example, GLS or DHL) for shipping and delivery;
accounting and invoicing providers for bookkeeping and invoicing support;
IT, hosting, email, and cloud providers that help us operate and secure our systems;
payment service providers, if applicable, to process payments. Payment providers may act as independent controllers for parts of the payment process;
professional advisers, such as legal, tax, or audit advisers; and
public authorities where required by law, for example tax authorities or law enforcement.

Where recipients act as processors, we use contracts requiring them to protect personal data and process it only on our instructions.

We do not sell personal data.

7. International data transfers

We primarily aim to use service providers located in the European Economic Area (EEA). However, some providers, especially cloud, email, analytics, or newsletter providers, may process personal data outside the EEA.

Where personal data is transferred outside the EEA, we use appropriate safeguards, such as:

an adequacy decision adopted by the European Commission; and/or
the European Commission's Standard Contractual Clauses (SCCs), together with supplementary measures where necessary.

You can request additional information about relevant safeguards by contacting us.

8. How long we keep personal data

We keep personal data only for as long as necessary for the purposes described in this Privacy Notice, and then delete or anonymise it, unless we must keep it longer for legal reasons.

In general:

waitlist / raffle data is kept for as long as needed to manage the waitlist or raffle and maintain an appropriate record of consent, or until you withdraw your consent, whichever is applicable;
newsletter and member data is kept until you unsubscribe or delete your account, and for a limited period afterwards where necessary for suppression lists, security, record-keeping, or legal compliance;
order, payment status, and invoice data is kept for as long as necessary to perform the contract and for any statutory accounting, tax, and record-keeping periods;
warranty, repair, and support data is kept for as long as necessary to handle your request and for any applicable warranty, limitation, or dispute periods; and
server logs and security-related technical data are kept for as long as reasonably necessary for security, troubleshooting, and abuse prevention; and
analytics data is kept for as long as necessary for the relevant analytics purpose or until you withdraw consent, where applicable.

9. Whether you must provide personal data

Providing personal data is generally voluntary, but some data is necessary for us to provide specific services.

Waitlist / raffle: voluntary. If you do not provide your email address, you cannot participate or receive related notifications.
Newsletter / member account: voluntary. If you do not provide the relevant data, we cannot subscribe you or provide the relevant member feature.
Orders and delivery: required to enter into and perform the sales contract. Without the necessary details (for example, your name and address), we cannot process and deliver your order.
Invoicing and accounting: certain data is required by law so that we can issue invoices and keep records.
Warranty / support: the relevant data is required if you want us to handle your request, for example proof of purchase or a serial number.

10. Your rights

Under the GDPR, you may have the right to:

access your personal data;
rectify inaccurate or incomplete data;
request erasure in certain cases;
request restriction of processing in certain cases;
object to processing based on legitimate interests;
receive data portability for data processed by automated means on the basis of consent or contract; and
withdraw consent at any time where processing is based on consent.

Withdrawing consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise your rights, contact us at: hello@shmoergh.com

We may need to verify your identity before fulfilling your request. We will respond within one month, unless the request is complex and the deadline may lawfully be extended.

11. Right to lodge a complaint

You have the right to lodge a complaint with your local supervisory authority.

In Hungary, the supervisory authority is:

National Authority for Data Protection and Freedom of Information (NAIH)

Website: https://naih.hu

You may also have the right to seek a judicial remedy.

12. Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or loss.

These measures may include, for example:

access controls;
encryption in transit where supported;
restricted administrative access; and
regular software updates and general security maintenance.

13. Changes to this Privacy Notice

We may update this Privacy Notice from time to time.

The updated version will be published on our website with a revised Last updated date.