PRIVACY POLICY

(in force as of  5.10.2021)

The website https://usa.shelly.cloud/ together with all its sub-domains and sub-pages dedicated to marketing and promotional campaigns, contests, survey etc. (“the Website”) constitutes the informational Internet page of the products bearing the commercial name Shelly. The Website offers detailed technical information about the products of the Shelly series. This Website does not provide the opportunity for online purchase directly from the manufacturer or its authorized distributor, nor technical support regarding Shelly Devices. The access to this Website is related to the processing of personal data.

This Privacy Policy describes how we process personal data related to access to this Website. “Personal data” is an information that identifies or can reasonably be linked directly or indirectly to an identifiable person. For purposes of this Privacy Statement, “personal data” and “personal information” have the same meaning and are used interchangeably.

We reserve the right, from time to time, to update and amend this Policy to reflect any changes in the way we process your personal data or changes in relation to applicable regulations. In the event of such changes, we publish the amended version of the Policy on this Website.

The personal data controller is ALLTERCO ROBOTICS EOOD, a company registered in the Republic of Bulgaria and entered in the Commercial Register at the Register Agency with the headquarter and managing address in the city of Sofia, 103 Cherni Vrah Blvd., UIC 202320104.

The Data Protection Officer (DPO) will respond to all your queries regarding the processing and protection of personal data. You can contact the DPO via email at the following address: dpo@allterco.com.

For more information regarding the types of data, purposes and means of their processing, please read below.

1. Personal data:

Types of personal data that we process:

You can browse the public content of this Website without entering any personal data on it. However, if you want to get into contact with our team you will need to enter your  personal data  in the contact form on the Website and provide the following information:

• Name;
• Email address;
• Subject;
• State;
• Message.

 

In this case, we collect and process your personal data in order to provide you with the information you have requested. By submitting an enquiry, insofar as this is not mandatory for using the Website, but a matter of free choice on the part of the user, you expressly consent to the data provided to be used. The personal data that we process when we receive your request are:

 Consumer Data:

• Name;
• Email address;
• State.

User Data:

• IP address.

What is IP address (Internet Protocol Address)? IP address is unique identification number that computing devices such as personal computers, tablets, and smartphones use to identify itself and communicate with other device in the IP network. Any device connected to the IP network must have a unique IP address within the network. It allows the localization of the device in the global Internet network.

 By your expressly consent to receive direct marketing communication, including personalized offers, promotions and marketing activities. Your personal data that you give us consent to process for these purposes is:

• Email address

Data subject: current and potential users of the Website that have accessed to the Website.

 

Legal basis for processing of personal data: consent

Purpose of processing:

User data for the purposes of:

1. A response to your enquiry;
2. Direct marketing, including personal offer upon explicit consent on your part, including provision of information via email concerning new products and/or services;
3. Direct marketing and administration of joint promotions/marketing campaigns etc. with our partners upon explicit consent on your part;
4. А counting the site traffic.

2. Anonymized data

ALLTERCO ROBOTICS EOOD processes data for business analysis as depersonalized anonymous data (on the basis of legitimate interest).

1. Statistical information for the total number of visits on the Websites and determination for 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.

3. Third parties to whom we provide your personal data

1. State bodies and authorities in relation to checks performed by them in accordance with statutory requirements and limitations;
2. Personal affiliated with ALLTERCO ROBOTICS EOOD in connection to the use of shared technical and human resources, transformations and others;
3. Law enforcement, legal counsel, or other reasonably necessary when we have a good faith belief that the disclosure is necessary to prevent or respond to fraud or software piracy, defend ourselves against attacks, or protect the rights, property, and safety of our company and the public;
4. Persons to whom we are required by the law to provide information, such as according to subpoena or a court order.

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:

Data provided on the basis of consent – until withdrawal by way of 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 you consent with a click with a click on the link “unsubscribe” in the e-mail marketing massage or by sending an e-mail to support@usa.shelly.cloud.

Following 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 pending court, administrative or pre-court proceeding – until its completion by way of a final and non-appealable act depending on the type of proceedings.

Withdrawal of consent shall not prejudice the legality of processing based on the consent granted prior to its withdrawal.

  

5. Your rights as regards your personal data:
   1. Right of access, including right of copy of the data that are being processed:

At any time given 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.

1. 2. Right of correct inaccurate personal data

You have the right to request correction of your personal data if the data is inaccurate, including supplementing incomplete persona; data. This you may do by referring to us way of a written request, following due certifying of your identity.

• 3. Right of erasure (“The right to be “forgotten”) in the following cases:
• Removing the need for processing;
• Withdrawal of consent when processing in on the basis of consent;
• Illegal processing of data;
• 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.

1. 4. Right to restrict processing when:

1.  the veracity of data for the period when their veracity should be checked is be checked is being disputed;

2.  processing of data has no legal ground and instead of erasing it you want to restrict their processing; or

3. data in 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 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.

1. 5. Right to transfer of machine-readable data

When processing your personal data in an automated manner on the basis of your consent you have the right to receive a copy of your data in a structure, which 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.

1. 6. Right to object to processing on the basis of a legitimate interest:

You have the right to object to processing of your personal data on the basis of the legitimate interest of the controller. ALLTERCO ROBOTICS EOOD will continue to process your personal data unless it is proven that there are convincing legal grounds thereof, which prevail over your interests and right or due to court disputes and other proceeding – related or non – proceeding- related actions. 

1. 7. Right to object of direct marketing

You have the right to object marketing communication, including to profiling and analysis for the purpose of direct marketing.

1. 8. Right to withdraw the consent granted

A consent to direct marketing and advertising – you can withdraw your consent with a click on the link “unsubscribe” in the e-mail marketing massage or by sending an e-mail to support@usa.shelly.cloud.

Upon it is stated otherwise, the above-mentioned right shall be exercised by way of a written request in a format determined by ALLTERCO ROBOTICS EOOD which may accessed at the seat of the controller or electronically 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 present a factual /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. Method user for automated taking of individual decisions, including profiling.

We do not use automated algorithms, including profiling.

7. Data security

We maintain a combination of reasonable and appropriate physical, administrative, and technological controls to protect your data from unauthorized access or malicious actions.

We take reasonable steps to limit the access employees, contractors, and agents have to your data to those who need to know this this data to perform their assigned functions.

ALLTERCO ROBOTICS EOOD reserves the right to change this Privacy Policy to reflect changes in the law, out data handling practices, or the features of our business. The updated Privacy Policy will be available on this Website. We will show the date the Privacy Policy was last updated to help you know when we changes it.