PRIVACY POLICY

PRIVACY POLICY

OF SHELLY GROUP SE

The website / (the “Site”) is the official website of Shelly Group SE (the “Company”). The Site offers corporate information and legally required information about the Company and its economic group companies.

Shelly Group SE is a public listed company and as such processes, among other data, personal data of its shareholders and potential investors.

The controller of the personal data is Shelly Group SE, UIC: 201047670, with its registered office and registered address in the city of Sofia №  51″Cherni Vrah” Blvd., building 3, floor 2 and 3. The Data Protection Officer will answer all your questions regarding the processing and protection of personal data. You can contact him by email at: dpo@shelly.com

Data subjects whose data may be processed – natural persons – shareholders, their legal representatives, in the case of shareholders legal entities, as well as their proxies for the purpose of their identification in connection with the exercise of their legal shareholder rights.

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

The types of personal data we process

On a lawful basis for the performance of our obligations under the law and to ensure the rights of the shareholders:

1.1. Shareholder Data:

– Names;

– PIN;

– Address;

– Identity document details;

– Tax identification number and other data for tax purposes;

– Bank account;

1.2.        Details of legal representatives and proxies;

– Names;

– PIN (personal identification number);

– date of birth;

– Details of identity document;

On the basis of expressly stated consent, for the purposes of investor relations and the provision of information on information published by the company:

– Email address;

– Contact telephone;

Anonymized data

– Statistical information on the total number of visits to the Site and determination of incoming traffic to the Site;

– Number of inquiries from shareholders and potential investors and meetings held;

Purposes of personal data processing:

3.1. Shareholder data for the purposes of:

– Identification in connection with the exercise of shareholder rights (e.g. participation in general meetings, payment of dividends, etc.);

– Correspondence in connection with the exercise of shareholder rights and exchange of documents;

– Provision of information on inspections or defending a legal interest in administrative and judicial proceedings;

– Handling of complaints, signals and claims received

– Issuing documents for tax purposes;

3.2.Details of legal representatives and proxies

– Identification in connection with the exercise of shareholder rights (e.g. participation in general meetings, payment of dividends, etc.);

– Correspondence relating to the exercise of shareholders rights and exchange of documents;

– Provision of information on inspections or defending our legal interests in administrative and judicial proceedings

3.3 Anonymized data for the purposes of statistical analysis of the total number of visits to the Site, enquiries received and communication with investors;

Third parties to whom we provide your personal data:

4.1. Payment service providers for the purpose of making dividend payments and for accounting purposes as required by law;

4.2. Consultants in various fields (lawyers, auditors, investment intermediaries, etc.) for the purposes of protecting our legitimate interests, meeting legal requirements, defending legal rights and interests in legal and administrative proceedings, financial reporting, etc.;

4.3. Judicial authorities, supervisory administrative authorities, government agencies and other public authorities and organizations in Bulgaria and Germany, upon request and to the extent permitted by law, including but not limited to the Central Depository, the Financial Supervisory Commission, the Bulgarian Stock Exchange, the Frankfurt Stock Exchange, the German Federal Financial Supervisory Authority and other persons authorized by law;

4.4. Marketing and PR agencies in connection with the provision of PR and marketing communications in relation to the Company;

With respect to private entities, we require and monitor that the said third parties implement all technical and organizational measures to protect such data.

Data is processed for the following periods:

5.1.Data in connection with the performance of the legal obligations of the public company – the periods required to comply with Bulgarian and European legislation;

5.2. Data processed for accounting purposes – 10 years, as required by law;

5.3. Data processed for the protection of our legitimate rights and interests or in fulfilment of our legal obligations, in the event that there are judicial, administrative and pre-trial proceedings pending at the date of expiry of the said period – until their conclusion by a final, non-appealable act, depending on the proceedings.

Your rights in relation to your personal data:

6.1. Right of access, including the right to a copy of the data being processed:

You have the right to request information about the personal data we hold about you at any time. You can contact us and, based on a written request and verification of your identity, the data will be provided to you;

6.2. Right of rectification of inaccurate personal data

You have the right to request the rectification of your personal data if it is incorrect, including the completion of incomplete personal data.

6.3. Right of erasure (“Right to be forgotten”) in the following cases:

– No longer necessary to process;

– Withdrawal of consent where processing is based on consent;

– Unlawful processing of data;

– Legal obligation to erase;

The right to be forgotten is not an absolute right and may not be upheld in the cases provided for by law, and may only be exercised upon proper authentication of your identity.

6.4. Right to restriction of processing where:

– the accuracy of the data is contested, for the period in which its accuracy must be verified; or

– the processing of the data is without legal basis, but instead of erasure, you request their limited processing; or

– the necessity of the data for the establishment, exercise or defense of your legal claims; or

– an objection to processing has been lodged, pending verification that the controller’s grounds are legitimate

In the event of rectification, erasure or restriction of processing, we will notify each recipient to whom the personal data has been disclosed, unless this is impossible or involves a disproportionate effort.

5.5. Right to portability of machine-readable data

Where we process your personal data in an automated way on the basis of your consent or on a contractual basis, you have the right to receive a copy of your data in a structured, commonly used and machine-readable format. The data will be provided directly to you or, upon your request and technical feasibility, the data will be provided to another controller of your choice.

5.6. You have the right to object to the processing of your personal data based on the legitimate interest of the Controller.  Shelly Group SE will not continue to process your personal data unless it can be demonstrated that there are compelling legal grounds for doing so which override your interests and rights, or because of litigation and other procedural or extra-procedural actions.

5.7. Right to object to direct marketing:

You have the right to object to receiving marketing communications, including profiling and analytics for direct marketing purposes.

5.8. Right to complain to the Data Protection Commission or to a regulatory authority in the EU Member State of your habitual residence, place of work or place of the alleged infringement.

5.9. The right to withdraw the consent provided for direct marketing and advertising – by sending a notice to the opt-out address provided in the direct marketing and advertising notice;

You will receive a response to your enquiry within one month of it being received by us. In case of factual and/or legal complexity, as well as in case of a large number of requests received by the Administrator, this period may be extended by another two months.

Methods used for automated individual decision-making, including profiling

We do not use automated algorithms and/or profiling.

Links to other websites

The Site contains links to third party sites. Shelly Group SE is not responsible for the protection of your data processed by these sites. Please familiarize yourself with the policies uploaded on these sites in relation to data protection and the grounds on which your data is processed by them.

TRANSFER OF DATA TO A THIRD COUNTRY OR INTERNATIONAL ORGANISATION:

Your personal data will not be transferred to third countries or international organizations outside the territory of the European Union.

Cookies

In order to provide certain functionalities, we use Cookies that are technically necessary for the functioning of the Site. To ensure the best possible user experience we also use optional Cookies which you have the option to accept or decline. For more detailed information about the cookies we use, see our Cookie Policy