Bold Data Act Transparency Notice

 

Version 1.0 - 01-2026

Bold Security Technology B.V. (“Bold”) is committed to providing transparent information regarding data generated by your use of Bold products and the Bold App in accordance with the EU Data Act.

This notice explains what data is generated, who can access it, and how you can use it.

 

Data generated by Bold products and the Bold App

When you use Bold products and the Bold App, the following data is generated:

  • Device usage data: activation history (date and time), number of activations, lock status
  • Device performance data: logs and technical metrics required for correct product functioning

Note: This includes both personal and non-personal data. Non-personal data cannot identify you individually.

 

Who can access the data

  • You (the user): Through the Bold App, you can view device usage and activation history.
  • Bold: To operate, maintain, and improve our products and services.
  • Service providers acting on behalf of Bold. These providers access data only to support Bold’s operations:
  • Amazon AWS Cloud hosting (ISO 27001 certified, data storage in Ireland)
  • Twilio SMS Services (ISO 27001 certified)
  • Other users you grant access to: For example, if you invite a family member or coworker to use a Bold lock, that person can see some product-generated data, such as lock activations.
  • Optional integrations: Third-party apps or services you explicitly connect with the Bold App (e.g., smart home platforms)

 

Purpose of data use

The generated data is used exclusively for:

  • Enabling and improving product functionality
  • Monitoring and maintaining performance and security of Bold products and services
  • Providing access and usage information to you as the product owner

No generated data is used for unrelated purposes, marketing, or profiling without your explicit consent.

 

Retention period

We do not retain your personal data longer than is strictly necessary to achieve the purposes for which your data is collected. The table below summarizes data collected as described in our Privacy Statement (v1.6). We apply the following retention periods for the following (categories of) personal data:

Category Retention period Reason

 

Personal details (Name, Telephone number, e-mail address)

 

 Until termination of the service. Offering our services.

Lock data (Activations, Access rights)

 1 year, or until the lock is removed. Providing additional security for the platform and its users.

Login and session data (Reading data, Writing data)

 30 days Ensuring stability and safety on the platform.
Geolocation data Not applicable. Geolocation data is only used for local data processing. Geolocation is only processed when the user activates optional app functionalities.
Telephone recordings with our customer service staff max. 4 weeks Improving our customer service (training purposes)

 

Your rights and access

  • User access via the Bold App: You can view device usage and activation history directly in the Bold App.
  • Backend access by Bold: Bold can access additional product-generated data in its backend platform, such as timestamps, error logs, and performance metrics, which are used solely to operate, maintain, and improve Bold products and services.
  • You can grant or revoke third-party access at any time through the App settings.
  • Questions regarding access to product-generated data can be sent to privacy@boldsmartlock.com.

 

How to find this notice

  • This notice is cross-referenced in the Bold Privacy Statement and the EULA for the Bold App. The latest versions are accessible online on www.boldsmartlock.com.
  • It is intended to be clear and easily accessible for all users prior to using Bold products or services.

 

Contact:
Bold Security Technology B.V.
Leidseveer 2, 3511 SB, Utrecht, Netherlands
privacy@boldsmartlock.com