ZEE PRIVACY POLICY

The mobile application MyKi Watch 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 Watch 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: dpo@allterco.com

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 Watch. 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.

1. The types of personal data we process:

On a contractual basis for the provision of the Service:

• 1.1. Profile data
• User name;
• Email address;
• IMEI (unique number of the watch), for which the profile has been created
• MSISDN (telephone numbers of the SIM cards placed in the watch and the mobile device on which the application has been installed)

1.2. Data concerning the МyKi™ watch and the mobile devices on which the application has been installed (Paired devices)

• Model and number of the МyKi™ watch and the paired mobile devices;
• Name of the МyKi™ watch;
• IMEI (unique number of the МyKi™ watch);
• MSISDN (telephone numbers of the watch and mobile devices having installed application);
• IMSI (SIM card number) of the МyKi™ watch and the paired mobile devices;
• Mobile carriers  (MNO) or Internet provider, which provide connectivity  for the purposes of the Service;
• a version of the installed application МyKi Watch, language, time zone, IP address of the devices from which the profile can be accessed;
• Identification of a grid cell;
• IP address;

1.3. Location data of the МyKi™ watch

• Geo-location;
• Location history;

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:

• Geo-location;

1.5. Data concerning the natural person wearing the МyKi™ watch:

• Photo;
• Gender, age, weight, height;
• Behaviour history (movement, rest, sleep, and information regarding other activities populated by you on your own volition)

1.6. Other data:

• Telephone directory (Phone book);
• Chat services – text and voice messages when applicable;
• Video streaming (when applicable);
• Pictures (when applicable);

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:

• Statistical information concerning the total number of active watches and their geographical allocation (general dispersal).

 

2. Purposes of personal data processing;

2.1. Data concerning the profile for the purposes of:

• Control of the data access for the MyKi™ watch. Each watch is supported by only one unique profile.
• 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 watch;
• Provision of information via email or SMS for new products and/or services  and mutual promotions with our partners upon explicit consent on your part;
• Sending messages for the purposes of direct marketing and advertisement upon explicit consent on your part;

2.2. Data concerning the MyKi™ watch and the connected devices for the purposes of:

• Provision of connection between the MyKi™ watch and the paired devices;
• Control of data access for the MyKi™ watch;
• Provision of services concerning servicing and maintenance for the correct functioning of the watch;
• Improving the MyKi™ service;
• Provision of information for new services and products and mutual activities with mobile carriers which provide the mobile service of the number registered within the account of the application and the number of the Paired devices;

2.3. Data concerning the paired mobile device for the purposes of:

• depiction of the active data regarding the location of the paired device on a map, provided by Google LLC

2.4. Data concerning location of the МyKi™ watch for the purposes of:

• ensuring the functioning of MyKi™ watch as GSM/GPS tracker;
• determining and tracking of access to “Security zones”;
• alarm activation for entering the “Security zones”;
• depiction of the active and/or historic data regarding the location of the МyKi™ watch on a map, provided by Google LLC

2.5. Data concerning the natural person wearing the МyKi™ watch for the purposes of:

• facilitation in the individualization of more than one watch in the profile (each watch can be connected to one profile only for security reasons);
• using the functionality of the MyKi™ Service such as information for the physical activity and daily habits in view of attaining a more healthy and balanced lifestyle;
• history of location for retrieving information in cases of unexpected loss of connection with the server as well as for determination and tracking in the “Security zones”;

2.6. Other data for the purposes of:

• making incoming and outgoing calls from and to the watch by a limited number of “Allowed numbers”;
• sending and receiving of incoming and outgoing messages (including voice messages);
• transmission, dispersing or exchange of contentvia electronic messages (including pictures);
• video streaming (when applicable)

2.7. Anonymised data for the purposes of:

• Statistical analysis of consumption and consumer demand in various regions. Identification of a concrete person from this information is impossible.

3. Third parties to which we provide your personal data:

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.

3.2. Google LLC, Google Ireland ltd. and other affiliates of Google LLC for the purposes of depiction of the active and/or historic data regarding the location of the МyKi™ watch and the paired devices on a map, provided by Google LLC. The privacy policy of Google LLC is accessible at the address:  http://www.google.com/policies/privacy

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. 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 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. Your rights as a data subject:

5.1.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;
•  

5.2. Right to correct 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 Watch application or by contacting us, filling out a written request form and verifying your identity

5.3. Right to delete („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.

5.4. 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 administrator.

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;

• we provide the data directly to you
• at your request and technical possibility, the data is provided to another administrator of your choice

5.6. 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 override your interests, rights and freedoms or are required for the establishment, exercise or defence of legal claims.

5.7. 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

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.

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

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