POLICY FOR PROTECTION OF PERSONAL DATA

( In force from 25.05.2018 )

Via the mobile app MyKi Care You can monitor the performance of the MyKi thermometer, as well as remotely handle the functionalities of the thermometer MyKi Care (The Service).

Controller of the personal data processed for the purposes related to MyKi Care mobile application is ALLTERCO ROBOTICS EOOD, UIC: 202320104, having its seat and registered address in 1407 Sofia, 103 Cherni Vrah Blvd.

The data protection officer of ALTERCO ROBOTICS EOOD 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@allterco.com

 

1. The types of personal data we process

 

On a contractual basis for the provision of the Service:

1.1 Profile data:

-           E-mail address;

-           Password;

-           Serial Number of the MyKi Care thermometer;

1.2.   Data concerning the MyKi Care thermometer and the mobile devices on which the application has been installed (paired devices):

-           Model and version of the operating system of the paired devices;

-           Model and serial number of the MyKi Care thermometer

-           Version of the installed application MyKi Care, language, time zone;

-           IP address;

1.3.   Data on the person wearing the thermometer MyKi Which:

-           Name;

-           History (previous temperature measurements and taken treatments)

 

On the basis of your explicit consent, expressed by allowing the application access to the data on your device or by a deliberate action by populating certain fields on the application for the use of certain functionality:

 

1.4.   Data on the person wearing the thermometer MyKi Which:

-           Gender, age, weight;

You may withdraw each and every consent provided above through the settings of the application 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.

 

ALTERCO ROBOTICS EOOD processes data for business analysis of the sales extrapolated from de-personified anonymous data (legitimate ground):

 

1.5.   Anonymised data

-           Statistical information concerning the total number of active thermometers and related economic indicators;

2. Purposes of personal data processing:

2.1.   Data concerning the profile for the purposes of:

-       Control of the data access for the MyKi Care thermometer and the person wearing the thermometer; entry authentication;

• Provision of servicing and maintenance for removal of technical defects, limiting the access to the Service, etc.;

-        Email or SMS verification to guarantee the security of the data access for your profile and the MyKi Care thermometer;

• Sending messages for the purposes of direct marketing and advertisement upon explicit consent on your part;

-        Account password  Change;

2.2.   Data concerning the MyKi Care thermometer and the paired devices for the purposes of:

-           Provision of connection between the thermometer MyKi Care and paired devices;

-           Provision of services concerning servicing and maintenance for the correct functioning of the MyKi Care thermometer;

-           Improving the MyKi Care service;

-           Provision of the functionalities of the MyKi Care service;

2.3.   Data on the person wearing the  MyKi Care thermometer 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.   Call centers which help us assist you in the event of issues concerning handling, shipping, set up and functionalities of the mobile application and the MyKi Care thermometer;

3.2.  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;

3.3.  State bodies and institutions in connection to checks and probes performed by them in compliance with the legal requirements and restrictions.

3.6.           Affiliated parties of ALLTERCO ROBOTICS EOOD 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. The Data is processed in regards of the following time limits:

4.1.   Data processed for the purpose of providing the Service - until the account is deleted or up to 3 years following the last log-in into and / or use of a functionality of the application. The time limit is determined in view of the need to allow the MyKi Care thermometer to be used in the event of its loss or theft and the subsequent rediscovery of the said item form its legal owner;

4.2.  Data provided on the basis of consent – until it is withdrawn, as provided, including through the settings of the application or the mobile device to which it is installed or deleted, as applicable) to the extent this data is required for the use of a certain functionality of the mobile application.

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.

 

 

5. Your rights as a data subject:
   1. Right to access, including right to copy data undergoing processing:

• At any time you have the right of information in regards to your personal data processed by us. You may contact us and after filling out a written request form and verifying your identity the requested information will be provided to you;

 

• 2. Right to rectification of inaccurate personal data:
• You have the right to request correction and/or supplementation of your personal data when the data is incorrect and/or incomplete. This you can accomplish via your profile in the MyKi Care mobile application or by contacting us, filling out a written request form and verifying your identity
  3. Right to erasure („The right to be forgotten“) in the following cases:
• Removal of the need to process;
• Withdrawal of consent when the processing of the data is on the legal bases of provided consent;
• Illegal data processing;
• Legal obligation to delete;

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.

• 4. Right of limiting processing when:
• The veracity of data is disputed, for the period for which their veracity should be checked; or
• Processing of data is without legal ground, but instead of deletion on our part, you want their restricted processing; or
• Need for data concerning establishment, exercise or protection of your legal claims; or
• Objection has been submitted as regards data processing pending check as to the legality of the grounds of the Controller.

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.

• 5. Right of transferability of the data;
• we provide the data directly to you
• at your request and technical possibility, the data is provided to another controller of your choice
  6. Right to object to the processing based on legitimate interest:
• You have the right to object to the processing of your personal data when the processing is based on legitimate interest of the Controller or a third party. ALLTERCO ROBOTICS EOOD will not continue processing your data, accept if there is a proof of founded legal basis for the continuation of it, which overrides your interests, rights and freedoms or the processing is required for the establishment, exercise or defence of legal claims.
  7. Right to object to the processing for the purposes of direct marketing:
• You have the right to object to receiving messages for the purposes of direct marketing, including to the profiling and analysis concerning the direct marketing
  8. Right to lodge a complaint with a supervisory in the Member State of your habitual residence, place of work or place of the alleged infringement if you considers that the processing of personal data relating to you infringes GDPR.

 

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.

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.

 

6. Used automated individual decision-making, including profiling (automated algorithms)

We do not use any automated algorithms and/or profiling.