( In force as from 25.05.2018 )
The Service Shelly Eye allows you to have access and control to/from the device – video camera Shelly Eye and the data associated with it.
Controller of the personal data processed by the Shelly Eye mobile application is "ALTERCO ROBOTICS" EOOD, UIC: 202320104, with headquarters and address of management in Sofia, 103, Cherni Vrah Blvd.
The Data Protection Officer will answer all your questions about the processing and protection of personal data and will make the process of using your rights as a data subject easier and more understandable. The e-mail address for direct contact is: dpo@allterco.com
The following information contains a brief description of the key facts about processing Your data provided for Your convenience:
On contractual basis for the provision of the Service we process as follows :
1.1. Profile data
- E-mail address;
- Serial number of the Shelly camera Eye
- MSISDN (phone number of the SIM card of the mobile device on which the Shelly Eye application is installed, and the Shelly Eye camera ) ;
- Password;
1.2. Data for the camera Shelly Eye and paired (connected) mobile devices
- Model and number of the camera Shelly Eye and mobile devices;
- MSISDN (of mobile devices with installed application and Shelly Eye camera )
- Mobile Operator (MNO) or Internet Service Provider providing Internet and / or Telecommunication for the purposes of the Service;
- version of the installed Shelly Eye application, language, time zone, IP address of connected mobile devices;
1.3. Location data:
- Location
On the basis of your explicit consent, expressed via allowing access of the application to the data in Your device or by a deliberate action - manually inputting data for the use of a certain functionality:
1.4. Video recording and / or streaming from the Shelly Eye camera
- Data contained in the Shelly Eye camera's main function of “video recording”
- Data, transmitted through a two-way sound (audio) channel without recording (audio stream)
You may withdraw each and every consent provided above through the settings of the application Shelly Eye. 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 sales derived from depersonalized , anonymous data (legitimate basis):
1.5. Anonymized data
- Statistical information on the total number of active cameras Shelly Eye and their overall geographical distribution .
2.1. Profile data for the purposes of:
- Remote control of the Shelly Eye camera;
- Provide service and support for troubleshooting, limiting access to the Service, etc.;
- Verification via email to guarantee the security of data access for your account and Shelly Eye camera ;
- Providing information via email for new products and / or services and joint promotions with our partners with your explicit consent;
- Send messages for the purposes of direct marketing and advertising with your explicit consent ;
- Authentication when logging in the mobile application Shelly Eye ;
- Change account password;
2.2. Data for Shelly Eye camera and connected mobile devices for the purpose of:
- Providing a connection between the Shelly Eye camera and the mobile device where the app is installed
- Shelly Eye camera access control ;
- Providing service and support services for the Shelly Eye camera to function properly ;
- Improving the Shelly Eye Service ;
- Providing information on new services and products.
2.3. Location data for:
- ensuring the functioning of the Shelly Eye camera and its remote control.
2.4. Other data for the purposes of:
- picture for the purposes of video recording;
- MSISDN of the Shelly Eye Camera and the connected mobile device for the purpose of bi-directional (two-way) non-recorded audio transmission;
- Setting a work/rest mode or activation of the sensor system through the settings of the Shelly Eye camera, revealing Your behavioral patterns. Behavioral patterns are not processed by the administrator and / or revealed to a third person beyond the functions for which they are set and are entirely under your control.
2.5. Anonymized data for the purposes of:
- Statistical analysis of consumption and consumer demand in different regions. Identifying a specific person from this information is impossible.
3.1. call centers that help us assist You in case of problems with the handling, setting and operation of the Shelly Eye mobile application and the Shelly Eye camera ;
3.2. consultants in different spheres for the purpose of protecting our legitimate interests in maintaining and improving the quality of service, meeting legal requirements, protecting legal rights and interests in judicial and administrative proceedings;
3.3. server service providers to allow you to view, upload and delete Your videos;
3.4. government bodies and institutions in connection with their inspections in accordance with legal requirements and restrictions ;
3.5. Allterco Robotics EOOD affiliated persons in connection with the use of shared technical and human resources , legal transformations and others.
As regards private entities, we require and enforce these third parties to apply all technical and organizational measures to protect this data.
4.1. Profile data - up to 3 years from the date of the last login and / or use of functionality in / from the application. The term is determined taking into account the need to allow the use of the Shelly Eye camera in the event of its loss or theft and its subsequent detection or return ;
4.2. Data on persons subject to recording and / or stream - the videos are stored seven days as of uploading them to the dedicated server and audio stream is not subject to recording and therefore the transmission / receipt and instant reproduction of data sent / received in this order, they are automatically deleted;
4.3. Data for Shelly Eye camera and connected devices - until termination of the Service;
4.4. Data provided on the basis of consent – until its withdrawal, in so far as it is required to use a certain functionality of the Shelly Eye mobile application ;
Once this deadline has expired, the data is deleted and cannot be recovered or used anymore. The Data shall not be deleted but shall continue to be processed solely for the purpose of protecting our legitimate rights and interests or in the process of fulfillment of our legal obligations in the event that, at the date of expiry of the said term, there is pending judicial, administrative and pre-trial proceedings - until their termination.
5.1. Right of access, including the right to a copy of the data being processed - based on a written request and authentication of your identity;
5.2. Right to correct inaccurate personal data;
5.3. Right of deletion ("Right to be forgotten") in the following cases:
- Dropping the need for processing;
- Withdrawal of consent;
- Illegal data processing;
- Legal obligation to delete;
The right to be forgotten is not an absolute right and may not be respected in the cases provided for by law.
5.4. Right to restrict processing when:
- the validity of the data is disputed - for the period during which its accuracy must be verified; or
- the processing of the data is without legal basis, but instead of deleting it, you want their limited processing; or
- need for data concerning the establishment, exercise or protection of your legal claims; or
- an objection to the processing of the data was filed, pending verification as to the legality of the grounds of the administrator.
In the event of correction, erasure, or limitation of processing, we will notify any recipient to whom the personal data has been disclosed, unless this is impossible or requires disproportionate effort.
5.5. Portability of machine readable data :
- we provide the data directly to you
- at your request and a technical opportunity, the data is provided to another administrator of your choice
5.6. Right to withdraw consent for data processing;
5.7. 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 override your interests, rights and freedoms or are required for the establishment, exercise or defence of legal claims.
5.8. 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
5.9. Right of appeal before the Commission for Protection of Personal Data or to regulatory authorities in the EU Member States of habitual residence, place of work or place of suspected violation.
We do not use automated algorithms and / or profiling.