Your privacy is important to us. This is the reason why we have developed this Privacy Policy to provide you with all the needed information about why and how we process your personal data, and to provide you with the services available through our mobile Application MyKi Care.
Via the mobile Application MyKi Care (the MyKi Care App) You can monitor the performance of the MyKi thermometer (the Device), as well as remotely handle the functionalities of the thermometer MyKi Care (The Service).
“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person, as that term is defined under the General Data Protection Regulation (GDPR).
“Data subject” means the MyKi Care App User (the App User), the secondary MyKi Care App User/s (if applicable).
Controller of the personal data processed for the purposes related to the MyKi Care App is Shelly Europe Ltd., UIC: 202320104, having its seat and registered address in 1407 Sofia, 103 Cherni Vrah Blvd.
The data protection officer of Shelly Europe Ltd. shall reply to all your queries concerning processing and protection of personal data and shall make the process of exercising your data subject rights easier and more comprehensible. Establishing direct contact with him/her for your convenience and ease is being facilitated via email: dpo@shelly.com
On a contractual basis for the provision of the Service:
1.1 Profile data:
- User name;
- E-mail address;
- Password;
- Serial Number of the Device;
1.2. Data concerning the Device and the mobile devices on which the MyKi Care App has been installed (paired devices):
- Model and version of the operating system of the paired devices;
- Model and serial number of the Device;
- Version of the installed MyKi Care App, language, time zone;
- IP address;
1.3. Data on the person wearing the Device:
- Name;
- History (previous temperature measurements).
On the basis of your explicit consent, expressed by allowing the MyKi Care App access to the data on your Device or by a deliberate action by populating certain fields on the MyKi Care App for the use of certain functionality:
1.4. Data on the person wearing the Device:
Gender, age, weight;
Treatments.
You may withdraw each and every consent provided above through the settings of the MyKi Care App and your mobile device. Upon withdrawal of the consent, processing of the respective type of personal data shall be terminated for the stated purposes. Withdrawal of consent shall not prejudice the legality of processing based on consent given prior to its withdrawal.
1.5. Anonymised data
- Statistical information concerning the total number of active thermometers and related economic indicators;
2.1. Data concerning the App User for the purposes of:
- Control of the data access for the Device and the person wearing the thermometer; entry authentication;
- Email or SMS verification to guarantee the security of the data access for your profile and the Device;
- Account password Change;
2.2. Data concerning the Device and the paired devices for the purposes of:
- Provision of connection between the Device and paired devices;
- Provision of services concerning servicing and maintenance for the correct functioning of the Device;
- Improving the MyKi Care service;
- Provision of the functionalities of the MyKi Care service;
2.3. Data on the person wearing the Device for the purposes of:
- Usage of the functionalities of the MyKi Care service, such as information on sex, age and weight (for example, calculation of a recommended caloric intake);
- Facilitating the individualization measurement data by naming a thermometer in case it used by more than one person, and for customization of the Service and user experience;
- Ensuring the functionalities responsible for preservation and follow-up of medical history (past measurements and received medication and / or treatment) for one year;
2.4. Anonymised data for the purposes of:
- Statistical analysis of consumption and consumer demand in various regions. Identification of a specific person from this information is impossible.
3. Third parties to which we provide your personal data:
3.1. Consultants in various fields in view of protection of our legitimate interests in the maintenance and improving the quality of the service, compliance with regulatory requirements, protection of legitimate rights and interests in court and administrative proceedings;
3.2. State bodies and institutions in connection to checks and probes performed by them in compliance with the legal requirements and restrictions.
3.3. Affiliated parties of Shelly Europe Ltd. in a connection with usage of shared technical and human resources, transformations and others.
In regards to private individuals, we require and pay attention that the above stated third parties apply all required technical and organizational measures for protection of such data.
4.1. Data processed for the purpose of providing the Service - until the account is deleted;
4.2. Data provided on the basis of consent – until it is withdrawn, as provided, including through the settings of the MyKi Care App or the mobile device to which it is installed or deleted, to the extent this data is required for the use of a certain functionality of the MyKi Care App.
Following expiration of the above stated time limit, the data is deleted and may not be retrieved and used any longer. The data shall not be deleted but shall continue to be processed only for the purposes of protection of our legitimate rights and interests or in compliance with our legitimate obligations, in the event that as of the date of expiration of the above stated time limit there is pending court, administrative and pre-court proceedings – until its termination.
The right to be forgotten is not an absolute right and might not be respected in cases provided for by law and because of a lack of reliable verification of your identity.
You may exercise your right to erasure your data according to the procedures prescribed below or by contacting us, filling out a written request form and verifying your identity. Deleted data cannot be recovered by Shelly Europe Ltd.
ACCOUNT DELETION:
You may request the deletion of Your account: by clicking on the web link below: Delete Myki Care Account <- CLICK HERE
Follow our instructions during the process of deletion of your account. Once we have verified your personal identity, we shall proceed further with your request, and shall provide you with the relevant instructions for successful completion of the process for account deletion if the requirements imposed by law are met.
Upon successful completion of the procedure for account deletion, your account data, as well as any other data associated with your account shall be IRREVERSIBLY DELETED.
MANAGE DATA FOR THE DEVICE:
In case You do not want to delete your account entirely, by using the features of the MyKi Care App through the Settings You may choose to remove the information for the Device from your account in the MyKi Care App.
Upon successful completion of the selected procedure the collected data will be IRREVERSIBLY DELETED.
In case of correction, deletion or restriction of processing, we will notify every recipient to whom personal data has been disclosed unless this is impossible or requires disproportionately huge efforts.
You may exercise the aforementioned data subject rights after filling out a written predefined request form which you may receive from the business address of the Controller or via electronic means after contacting the data protection officer and filling out the electronic form which you will receive in response.
Only a person who can be identified by Shelly Europe Ltd. as an App User may exercise their rights under section 5. In the event that we have legitimate concerns regarding the identity of the individual submitting a request, we may request the provision of additional information necessary to verify the identity of the person.
Response of the subject’s request will be delivered in within one month of receiving your written request form and may be extended with additional two months in case of a factual and / or legal complexity, as well as a large number of requests has received by the Controller.
We do not use any automated algorithms and/or profiling.
We may update this Privacy Policy from time to time due to changes to the MyKi Care App, the applicable laws etc.
Any changes will become effective upon posting of the last version in the MyKi Care App.
If you have any additional question, please do not hesitate to contact us at: dpo@shelly.com