Personal Data Privacy and
Security Policy www.mytesy.com and
mobile application "tesyCloud", owned by Tesy OOD
25 May 2018, the General Data Protection Regulation (GDPR) entered
into force for all EU Member States. It applies directly in Bulgaria
just as any national law, and covers the rights and obligations of
administrators, processors and subjects of personal data; some of the
details are further regulated by the Bulgarian Data Protection Act.
are personal data subjects and have different rights in this
connection. This policy aims to tell more about MyTesy
personal data protection principles, about our responsibilities as a
personal data administrator, and about the measures we have taken to
prevent your data from being used without your knowing by whom and
for what purposes or without being able to object or withdraw your
consent to its processing. The policy will not remain the same
throughout the time MyTesy
is available; as the development of IoT ("the Internet of
Things") is making progress, and the regulation of data
processing relations is evolving. We at TESY OOD strive to constantly
improve and adapt our practices to this development, which in turn
will be reflected in our policy.
policy was approved by the TESY Manager ("TESY") on 25 May
2018 and covers all activities related to the processing of personal
data within the MyTesy service.
You can contact the personal
data protection officer at TESY regarding any ambiguities related to
the application of this policy or the exercise of your rights at
- this is any information that concerns users of
the “tesyCloud” mobile application, which, alone or in
combination with other information, can help us establish your
identity or link your user behavior to a specific device from which
you access www.mytesy.com and
"Subject of Personal Data"
- this is you, the visitor of www.mytesy.com and
of personal data" - this is any action we perform or can do with
your personal data, including, but not limited to, collecting,
analyzing, storing, destroying, etc.
of personal data” - "TESY OOD" (TESY), registered under
the laws of the Republic of Bulgaria, with a registered office and
business address: Republic of Bulgaria, town of Shumen, 48 Madara
Blvd., entered in the Commercial Register at the Registry Agency of
the Republic of Bulgaria with unified identification code (UIC):
040029337, owner of the tesyCloud mobile application and the domain
We determine the purpose of processing your data, on one of the
grounds provided for by the law; in essence, we also determine the
means by which this processing is carried out - for example, the
technical infrastructure and the applications with which the
processing is done.
Data Processor" - this is a third person processing your
personal data under our assignment, where TESY has strictly defined
the purpose of the processing, the means by which it is done, and has
verified that the person meets the GDPR requirements. Such a
processor can be, for example, an agency responsible for a TESY
marketing campaign on a social network and reports on its success.
are small text files stored in browser directories used by the user.
Cookies are used to help users effectively use Web sites and make
certain functionalities available. Cookies play an important role in
facilitating and improving the usability of websites; therefore, if
deleted or blocked, may cause some websites or certain
functionalities to become inaccessible to users.
society services" are services that are normally provided for
remuneration and at a distance, via electronic means. The recipient
of such a service must have requested it explicitly. E-commerce is
also a type of service.
of the policy
Policy is intended to inform you of the manner in which your data is
collected and processed, as well as of your rights relating to your
personal data. Your personal data is processed in accordance with the
principles of lawfulness,
good faith and transparency. TESY collects your personal data for
specific, explicit and legitimate purposes and does not process it
further in a manner inconsistent with these purposes. TESY processes
as much personal data as is needed in connection with the purposes
for which it was collected and you were notified.
strives to keep the data accurate and up to date, with each user
cooperating with TESY and updating their account when changed.
data shall be processed in such a way as to ensure an adequate level
of data security, including protection against unauthorized or
unlawful processing and against accidental loss, destruction or
damage, by applying appropriate technical or organizational measures.
personal data you fill in the registration form and modify/add after
creating your profile, as well as after connecting your appliances,
are necessary so that we can meet your needs or the requested service
that TESY provides, namely a remote connection with your appliances
and their management by you at any time of any place. In order for us
to provide this service in good quality, we collect and process your
registering an account for the MyTesy service, we have provided the
option of choosing whether we can use your E-mail address to inform
you about new services, available discounts on existing services, or
some facilitations in the service that we have created for you. The
messages we send the will be in compliance with applicable Bulgarian
and EU legislation. You can easily and conveniently object to such
use and we will terminate it immediately; the information on how to
withdraw an initially given agreement or to object to receiving an
unsolicited marketing message will always be placed in a prominent
position in the message. You can always withdraw your consent by
using the settings menu in your account. If
necessary, you can contact us at email@example.com.
of the third countries:
RO, GR, HR, RS, CZ, CH, DE, DK, EE, ES, FR, PT, PL, UA, HU, IT,
LT, LV, MK, NL, NO, RU, SK, SL, SV, TW
for spare parts in the service centers based on available
convectors in the country concerned
are small texts or data which are sent to the device (computer,
laptop, tablet, smartphone) to be stored and may be requested again
by the sender. Cookies may have different functions: from keeping
your “logged in” status while you are filling in a registration
form, through storing your language preferences for browsing our
website, to monitoring your behavior while you are surfing the
internet, sometimes for a long period of time and regardless of the
device used: in the latter case, as in all similar cases, cookies
cannot be used without your prior consent for this based on received
cookies we use are:
needed: without the cookies you cannot use the service and its
functionalities which we have developed for you;
these cookies make the website perform better. We do not monitor
your surfing habits;
they “live” only within a single user session.
the "tesyCloud" mobile application use these cookies
because they are important for their operation. By registering we
of personal data
collect and process the following categories of data in order to
effectively provide our services:
Surname - not mandatory, but if you enter this information in the
empty fields, we will know how to address you
- is required for the purpose of communicating with you in
connection with the service provided
and Country - needed to identify the location of the user in order
to maintain service opportunities for the relevant market
on WI_FI Module - needed to identify the unique type of appliance
(its interface) by a unique code
ID - needed to identify the model of the appliance (its main
data above is required in connection with providing the MyTesy
service and in connection with Art. 6 (1) (b) of the General
you have checked that you wish to receive information materials when
registering for the service, we may use your e-mail address for
marketing purposes. The reason for this processing is your consent in
accordance with Art. Article 6 (1) (a) of the General Regulation.
a user, you have the right to receive information about important
features of your personal data processing, including the purposes,
timing, and reason, about the recipients and categories of recipients
of personal data, and others. Depending on how we first collected the
information, we will show the most important thing in this connection
in an appropriate and easily visible way every time.
You can access your personal
information in the user's profile www.mytesy.com and
the "tesyCloud” mobile application at any time through logging
into tour profile.
can provide you, on request, with information about all the personal
data we process in order to render the service at your request, or
collected from you with your consent, in a machine readable format.
The request shall be addressed at firstname.lastname@example.org
we will endeavor to respond to it within 30 days of receiving it via
an electronic communications channel that you have specified.
You have the right to ask us to
correct incorrectly recorded or stored personal data about you
through www.mytesy.com and
the "tesyCloud" mobile
The right to correction is exercised by logging into your profile and
correcting the entered data. If necessary, you can address
to request restrictions on the processing of your personal data
have the right to request that we temporarily suspend the processing
of your personal data (without deleting it) in the case of your
objection to a specific processing, or in the case of your filing a
claim or complaint with the competent supervisory authority. The
request shall be addressed email@example.com.
on the grounds of a legitimate interest on the part of TESY or a
third party and objection to such processing
TESY processes your data on the
basis of consent and for the purposes of performing the service you
have requested through your registration at www.mytesy.com
"tesyCloud” mobile application. When
your consent is not requested and given for the purpose of a
particular processing, or it is not immediately necessary to fulfill
the service you requested, we are most likely to have a legitimate
interest on our part or on the part of a third party, which we have
determined will not harm or otherwise adversely affect your right to
data protection. Such a judgment will always be documented by us and
will follow certain criteria and argumentation. You have the right to
acquaint yourself with the its key elements on request, as well as to
object that, given the peculiarities of your particular situation,
the processing in question affects your right to privacy and/or
protection of personal data in a way more substantial than foreseen
in justification. In these cases, we shall consider your objection
and give a well-grounded opinion on its acceptance or rejection
within 10 workdays. By objecting to this processing, you can also
exercise your right to objection above. The
objection may be addressed to us at firstname.lastname@example.org.
of your consent
cases where we have requested your consent to a particular processing
of your personal data, you can always withdraw it. If you are not
sure on what grounds we process your personal data, you can always
ask us, and you can also ask about the exact way you gave your
consent, we will respond within 7 workdays. We maintain an up-to-date
basis of personal data processing consents that we can refer to at
any time. Withdrawal of consent is done in the same as you gave it,
and we will provide you with information - a link or an email where
you can do this easily and conveniently in responding to your
to file a complaint with the competent personal data protection
you feel that your GDPR rights have been violated, you can file a
complaint with the personal data protection authority. In Bulgaria,
it is the Commission for personal data protection. However,
if you have any comments or complaints with TESY concerning the
processing of your personal data, you can first contact our Data
Protection Officer email@example.com,
to discuss the arisen issue.
are committed to responding to you within 30 workdays of receiving
your complaint or your question.
information, communication and actions in connection with your rights
is implemented and provided free of charge. When user requests are
clearly unfounded or excessive, in particular because of their
repetitiveness, TESY may either charge a reasonable fee, taking into
account the administrative costs of providing information or
communication or undertaking the requested action.
and organizational measures
a MyTesy User, it is important for us that you know that at the
moment, the MyTesy data server is located in Amsterdam. In developing
and delivering the service, we have undertaken, and on the basis of
technological progress, we will continue to develop and implement
appropriate technical and organizational measures, both at the design
stage of the various functionalities and the default ones, to ensure
the security and protection of your data.
will not disclose your data to third parties unless we are under an
obligation to do so by law. In such cases, you will be duly advised
of such disclosure.
The policy is available to any
User on www.mytesy.com and
the "tesyCloud" mobile application when creating a MyTesy
account, and after signing up in the account settings menu.
policy was last updated on 25 May 2018 and has been in force since
the date of its update.