PRIVACY POLICY
(in force as of 11 November 2019)


The website https://shelly.cloud together with its sub-pages https://shop.shelly.cloud/, https://shopusa.shelly.cloud/ and https://shopasia.shelly.cloud/ („The Website“) constitute the official Internet page and electronic shops
of the products bearing the commercial name Shelly. The Website offers information about the products
from the Shelly series, a possibility for online purchase directly from the producer or its authorized
distributor, as well as technical support regarding Shelly Devices. These services are related to the
processing of various types of data for different purposes:
The personal data controller is ALLTERCO ROBOTICS EOOD, UIC: 202320104, having its seat and
registered address in the city of Sofia, No 103 Cherni Vrah Blvd.
The Data Protection Officer will respond to all your queries regarding the processing and protection
of personal data. You can contact him/her via email at the following address: dpo@allterco.com
Data subjects, whose data can be processed – individuals – consumers or representatives of legal
entities for the purposes of an order and purchase of products from the Website.
ALLTERCO ROBOTICS EOOD in its capacity of administrator of the Website and producer of the
Devices branded “Shelly” processes personal data mainly for the purposes of processing and delivering
of Orders and assisting the users of the Devices with technical support for the activation, maintenance
and service of the Devices.
For more information regarding the types of data, purposes, and means of their processing, please
read below.
Submission of an Order through the Website constitutes an offer for the conclusion of a distance contract
for the purchasing of goods. We process personal data for the purposes of conclusion of the Contract and
its performance on our part.

1. Types of personal data that we process
On the contractual and pre-contractual basis for the purposes of the processing of an order and its
delivery:
1.1. Data concerning the person ordering (the Client):
- Name and family name;
- Delivery address;
- Phone number;
- Email address;
- IP address;
- Account’s data (for registered Clients)
1.2. Payment data (according to the preferred method of payment)
- Payment data via bank (bank transfer or card payment)
- Payment data via Pay Pal account;
On a legal basis, when payment requires an n accounting document to be issued:
1.3. Accounting data pursuant to the Value Added Tax Act:
- Full name of the Client when the latter is an individual or a representative when the person
ordering is a legal entity, with the exception of a statutory representative, registered in the
Commercial Register;
- VAT identification number.
Based on legitimate interest, in order to provide you with the necessary administrative and
technical support in respect of future or current Orders, as well as in case of difficulties when
using our Services and Devices (to the extent this is applicable to the Shelly Device in
question):
1.4. Consumer data:
- Chat conversations with a contact center;
- Contact phone number
- Email address;
- Calls to the call center;
- Order details;
1.5. Device data:
- Model and serial number of the Shelly Device;
- IMEI (unique number of the Shelly product)
- Information stored on the Shelly Device (when the Device is provided to the repair shop
without it being deleted by the consumer in advance)
Based on explicitly stated consent, for the purposes of creation of Account and use of its
functionalities, to the extent that registration on the Website is not mandatory for its use and
creation of Account is a matter of free choice on the part of the Client for tracking and managing
his/her Orders:
1.6. Account data;
- Name and family name;
- Email address;
- Phone number;
- Password;
- A list of chosen products;
- A list of delivery and invoice addresses entered by the Client;
- Order history;
- History of profile visits;
- Downloaded applications;
- Discount vouchers;
- A list of payments (without stating transaction data);
- A list of reimbursed amounts for returned or canceled Orders;
- Publishing of feedback/reviews
ALLTERCO ROBOTICS EOOD processes data for business analysis of the sales extrapolated as
depersonalized anonymous data (on the basis of legitimate interest):
1.7. Anonymized data
1. Statistical information for the total number of visits on the Websites and determination fo the
incoming traffic to the Websites, effected deliveries, requests for assistance and complaints
accepted;
2. Improvement of the services and products provided by ALLTERCO ROBOTICS EOOD.

2. Purposes of personal data processing:
2.1. Data concerning the Client for the purposes of:
1. Receipt, processing, and performance of purchase Orders;
2. Delivery by courier or post services to the delivery address stated in the order or additionally
stated by the person ordering via a call center or order form;
3. Invoicing and payment (including by payment on delivery);
4. Making contact with the person ordering regarding the order made and subsequent delivery;
5. Sending notifications regarding the status of the order and delivery-related issues;
6. Provision of coupon codes;
7. Sending notifications for direct marketing and advertising upon explicit consent on your part,
including the provision of information via email or SMS concerning new products and/or services
and joint promotions with our partners upon explicit consent on your part;
8. Provision of warranty service;
9. Servicing inquiries related to the Product and Services offered on the Website;
10. Servicing the order process in case of technical disruption, as well as for the
purposes of ensuring the security of the Website and the services provided through it;
11. Provision of information concerning checks or protection of legal interest in administrative or
court proceedings;
12. Improving the service;
2.2. Payment data for the purposes of:
1. issuance of accounting document (invoice) containing the requisites required by law in case its
issuance is necessitated by law or as explicitly required by the person ordering;
2. Certifying incoming payments made by a bank, PayPal or payment on delivery;
3. Making payments in relation to the exercised right of cancellation, complaint, compensation, etc.
2.3. Consumer data for the purposes of:
1. Provision of information concerning the services and products, including information regarding
orders, receiving of signals and complaints via calls to a call center or a chat channel;
2. Provision of support and warranty services if necessary for removal of technical malfunction,
including remotely via a call to a call center or a chat channel;
3. Email verification or SMS message for ensuring the security of access to data concerning your profile
and Shelly Device upon provision of repair service;
4. Processing of submitted complaints, pleas, signals, and statutory claims;
5. Improvement of servicing;
2.4. Device data for the purposes of:
1. Provision of repair services and maintenance as regards the correct functioning of the products
and applications, including remotely. To facilitate our clients and to the extent that the Devices
and Applications allow so, it is possible that technical issues concerning their functioning be
removed remotely. Remote diagnostics is not possible without data for the Device in question;
2. Provision of repair services of the Device on the spot in our service center;
3. Processing of submitted complaints, pleas, signals, and legal claims.
2.5. Profile data for the purposes of:
1. Provision of information for tracking and management of Orders;
2. Provision of discount vouchers (coupon codes);
3. Direct marketing (when the Account owner has consented to receive such marketing
notifications);
4. Providing new, better products and services, customized for the individual needs of the ClIent;
2.6. Anonymized data for the purposes of:
1. Statistical analyses of the total number of website visits affected deliveries, accepted requests
for assistance and complaints;
2. Analysis of consumer experience upon the use of the Devices and Applications in view of their
improvement in response to consumer expectations.

3. Third parties to whom we provide your personal data:
3.1. Courier companies and post services, affecting the delivery of confirmed orders through the
Website and payments made thereto;
3.2. Payment services suppliers for the purposes of effecting payment or reimbursement of
amounts upon exercising a right of cancellation of a product purchase, as well as for accounting
purposes in accordance with the legal requirements;
3.3. Call (contact) centers which help us assist you in cases of issues concerning use, settings, and
functioning of the Application and Device, as well as for servicing of applications for delivery,
responses to queries and notification in cases of orders made;
3.4. Consultants in various fields for the purposes of protection of our legitimate interests in the
maintenance and improvement of service quality, compliance with statutory requirements,
protection of legal rights and interests in court and administrative proceedings; financial and
accountancy reporting;
3.5. State bodies and authorities in relation to checks performed by them in accordance with
statutory requirements and limitations;
3.6. Persons affiliated with ALLTERCO ROBOTICS EOOD in connection to the use of shared
technical and human resources, transformations and others.
3.7. Marketing agencies and suppliers of services concerning sending of messages for marketing
and advertising.
As regards private individuals, we require from and monitor the third parties mentioned above so that
they apply all technical and organizational measures for the protection of such data.

4. Data is processed within the following time limits:
4.1. Data processed for the purposes of conclusion and performance of the distant sales
contract – the limitation periods for asserting legal claims as provided by Bulgarian law;
4.2. Data processed for accounting purposes – as provided by Bulgarian law;
4.3. Data provided on the basis of consent – until its withdrawal by way of written application
directed to ALLTERCO ROBOTICS EOOD at the management address of the company. In
cases of consent granted for direct marketing and advertising, you can withdraw your consent
with a click on the link “unsubscribe” or by sending an e-mail to the address for cancellation
stated in the notification. You can always withdraw your consent also online through the
options of your Account.
4.4. Data for and in the Account – until the Client deletes its Account;
Following the expiration of the time limits stated above, the data shall be deleted and cannot be restored or
used any longer. The data shall not be deleted but continue to be processed only for the purposes of
protection of our legal rights and interests or in performance of our legal obligations in the event that as
of the date of expiry of the time limit stated above there is the pending court, administrative or pre-court
proceedings – until its completion by way of a final and non-appealable act depending on the type of
proceedings.


5. Your rights as regards your personal data:
5.1. Right of access, including the right of a copy of the data that are being processed:
At any given time you have the right to request information regarding your personal data which we
store. You can contact us and based on a written request and proving of your identity your data will be
provided to you.
When you have signed up for an Account, you can also exercise this right through the options of the
Account.
5.2. Right to correct inaccurate personal data
You have the right to request the correction of your personal data if the data is inaccurate, including
supplementing incomplete personal data. This you may do through your profile via the mobile
application or by referring to us by way of a written request, following due certifying of your identity.
When you have signed up for an Account, you can also exercise this right through the options of the
Account.
5.3. Right of erasure („The right to be forgotten“) in the following cases:
1. Removing the need for processing;
2. Withdrawal of consent when processing is on the basis of consent;
3. Illegal processing of data;
4. Statutory obligation for erasure;
The right to be forgotten is not an absolute right and may not be respected in cases provided by law, its
exercise is exercised following due certification of your identity.
When you have signed up for an Account, you can also exercise this right through the options of the
Account.
5.4. Right to restrict processing when:
1. the veracity of data for the period when their veracity should be checked is being disputed; or
2. processing of data has no legal ground and instead of erasing it you want to restrict their
processing; or
3. data is necessary for establishing, exercising or protecting your personal legal claims; or
4. objection for processing of data has been submitted pending a check as to whether the grounds
of the controller are legal;
in the event of correction, erasure or restriction of processing we will notify each recipient whose
personal data has been disclosed unless this is not possible or requires disproportionate efforts.
5.5. Right to transfer of machine-readable data
When processing your personal data in an automated manner on the basis of your consent or a
contractual ground, you have the right to receive a copy of your data in a structured, widely used and
machine-readable format. The data will be provided directly to you or, at your request, it is technically
possible to submit it to another controller of your choosing.
When you have signed up for an Account, you can also exercise this right through the options of the
Account.
5.6. Right to object to processing on the basis of legitimate interest:
You have the right to object to the processing of your personal data on the basis of the legitimate interests of
the controller. ALLTERCO ROBOTICS EOOD will not continue to process your personal data unless
it is proven that there are convincing legal grounds therefor, which prevail over your interests and rights
or due to court disputes and other proceedings-related or non-proceedings-related actions.
5.7. Right to object to direct marketing:
You have the right to object to receiving of marketing communications, including profiling
and analysis for the purposes of direct marketing.
5.8. Right to a complaint before the Personal Data Protection Commission or before a
the regulatory body in a Member State of the EU at the place of habitual residence, workplace or place of
the alleged violation.
5.9. The right to withdraw the consent granted.
- Consent to direct marketing and advertising – by sending of a notification to the address
for cancellation stated in the direct marketing and advertising communication or using the options of
your Account;
- Consent to access a Profile in the Application – by changing the password to access the
Application;
- Consent to sign up for and maintain an account – by deleting it.
Upon withdrawal of consent processing of the respective type of personal data for the stated purposes
shall be terminated. Withdrawal of consent shall not prejudice the legality of the processing based on the
consent granted prior to its withdrawal.
Unless it is stated otherwise, the above-mentioned rights shall be exercised by way of a written request
in a format determined by ALLTERCO ROBOTICS EOOD which may be accessed at the seat of the
controller or electronically the following query to the Data Protection Officer at dpo@allterco.com and
filling in an electronic form received in response.
A reply to your query shall be sent within a month as of receipt of the written request on our side. In the
event when the request presents a factual and/or legal difficulty, as well as in the case of a large number
of requests received by the Controller this time limit might be prolonged by two months.

6. Methods used for automated making of individual decisions, including profiling
We do not use automated algorithms and/or profiling.

7. Referrals to other websites
The Websites contain referrals to websites of third parties. ALLTERCO ROBOTICS EOOD shall not
be liable for the protection of your personal data processed by these websites. Please acquaint yourself
with the policies uploaded on these websites in connection to the protection of your personal data and
the grounds for processing your personal data applied by them.
 

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