The mobile application MyKi allows you to identify the location of Device from the MyKi™ watch series and to connect with it via a call or a chat (“the Service”).
Be aware that you may not track the location of the Device without the consent of the person who is wearing it.
The following categories of personal data are being processed within the Service: data related to identification of the MyKi™ watch, twin (connected) devices and their location, namely via MSISDN (mobile number), IMEI (number of the mobile device) and IMSI (SIM card number), IP address (network number), MAC address (device number), production number of the embedded hardware, software number, location (geo-location); data in the consumer profile in the application for the purposes of authentication and subsequent control of the data access for the MyKi™ watch and provision of technical service and maintenance; pictures, voice messages, video streaming (when applicable for the relevant watch model MyKi™)
Controller of the personal data processed for the purposes related to the МyKi mobile application is ALLTERCO ROBOTICS EOOD, UIC: 202320104, having its seat and registered address in Sofia, No 103 Cherni Vruh 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: firstname.lastname@example.org
ALLTERCO ROBOTICS EOOD strives to expand and diversify its portfolio of goods and services by collaborating and going into partnerships with mobile carriers at different countries. We wish to inform you about our new products, services and promotions for which we need your consent:
I consent to receive messages for new products, services and promotions of ALLTERCO ROBOTICS EOOD:
via а telephone number populated in my profile via an email populated in my profile via Facebook all of the above
I consent to receive messages for new products, services and promotions from the mobile carriers servicing the mobile number populated in the profile and/or the number used by MyKi™ watch:
via a telephone number populated in my profile via an email populated in my profile all of the above
You may withdraw each and every consent provided above through the settings of the application MyKi. 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.
On a contractual basis for the provision of the Service:
1.2. Data concerning the МyKi™ watch and the mobile devices on which the application has been installed (Paired devices)
1.3. Location data of the МyKi™ watch
On the basis of your explicit consent, expressed via the device settings or by a deliberate action by populating certain fields on the application:
1.4. Location data of the Paired devices:
1.5. Data concerning the natural person wearing the МyKi™ watch:
1.6. Other data:
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):
1.7. Anonymised data:
2.1. Data concerning the profile for the purposes of:
2.2. Data concerning the MyKi™ watch and the connected devices for the purposes of:
2.3. Data concerning the paired mobile device for the purposes of:
2.4. Data concerning location of the МyKi™ watch for the purposes of:
2.5. Data concerning the natural person wearing the МyKi™ watch for the purposes of:
2.6. Other data for the purposes of:
2.7. Anonymised data for the purposes of:
3.1. The mobile operators, servicing the telephone number from your account and the telephone number of the MyKi™ watch – for the purposes of the service to the extent that their cooperation is necessary for guaranteeing the functioning of the MyKi™ watch and the application and for the purposes of direct marketing and advertisement to the extent that you have provided consent for it.
3.3. Call centres which help us assist you in the event of issues concerning handling, shipping, set up and functionalities of the mobile application and the MyKi™ watch;
3.4. 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;
3.5. 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 connectioned 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 or up to 3 years following the last log-in into the application. The time limit is determined in view of the need to allow the MyKi™ clock 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. Location data for the MyKi™ watch - after every hundredth record;
4.3. 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 limits, 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.
5.1.Right to access, including right to copy data undergoing processing:
5.2. Right to correct inaccurate personal data:
5.3. Right to delete („The right to be forgotten“) in the following cases:
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.
5.4. Right of limiting processing when:
In case of correction, deletion or restriction of processing, we will notify every recipient whose personal data has been disclosed unless this is impossible or requires disproportionately huge efforts.
5.5. Right of transferability of the data;
5.6. Right to object to the processing based on legitimate interest:
5.7. Right to object to the processing for the purposes of direct marketing:
5.8. 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 our request will be delivered in within one month of receiving your written request form.
We do not use any automated algorithms and/or profiling.