Bold Privacy Statement
version 1.6 - 11-2023
Bold Security Technology B.V., established at Leidseveer 2, 3511 SB Utrecht, is responsible for the processing of personal data as described in this privacy statement.
Contact details
www.boldsmartlock.com
Leidseveer 2
3511 SB Utrecht
+31850607337
Kevin Degeling is the Data Protection Officer of Bold Security Technology BV. You can reach our Data Protection Officer via privacy@boldsmartlock.com.
Personal data that we process
We process your personal data because you make use of our services and/or because you provide them to us yourself. Below you will find an overview of the personal data we process:
Personal details
- First name and surname
- Telephone number
- E-mail address
Telephone recordings with our customer service staff login and session management
- Telephone model and type
- Internet browser and device type
Lock use (logging)
- Number of activations
- Activation history (date and time) of our products
Discount code information
- Whether a user used a discount code
Additional Device permissions for Personal Data access
Depending on the device used, we may request certain permissions that allow access to your device data as described below.
By default, these permissions must be granted by you before the respective information can be accessed. Once permission has been given, it can be revoked at any time. In order to revoke these permissions, you may refer to the device settings or contact our support team via support@boldsmartlock.com. The exact procedure for controlling app permissions may be dependent on the used device and software.
If you grant any of the permissions listed below, the respective Personal Data may be processed (i.e. accessed to, modified, or removed) by this Application.
Location permission
Used for accessing the geolocation of your telephone. This Application may collect, use, and share User location Data in order to provide location-based services.
Bluetooth sharing permission
Used for accessing Bluetooth-related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.
Smart Home integration permissions
Used for accessing the Smart Home devices and enabling this application to interact with physical accessories in the surrounding environment.
Personal data of children under 16 years of age
Our service does not intend to collect information about users under the age of 16. Unless they have parental or guardian consent. However, we cannot verify whether a user is over 16 years of age. We encourage parents to be involved in their children's online activities to prevent collecting information about children without parental consent. If you believe that we have collected personal information about a minor without that consent, please get in touch with us at privacy@smartboldlock.com, and we will delete that information.
Legal basis for processing
We process your personal data for the following purposes and principles (as indicated in brackets):
- Being able to call or e-mail if this is necessary to carry out our services (necessary for the performance of the contract with you). We may record (parts of) your telephone conversation with our customer service staff for training purposes (necessary for the legitimate interest to improve our customer service). We will notify you before any recording starts.
- Informing you about changes to our services and products (necessary for the performance of the contract with you)
- Offering the possibility to create an account (necessary for the performance of the contract with you)
With your consent, to integrate your Bold products with existing applications, such as Google Home.
In order to guarantee the security of the platform and its users (necessary for the performance of the contract with you and the legitimate interest to secure computer systems) - To guarantee the security and the performance of specific optional app functionalities (necessary for the performance of the contract with you or consent). Users can freely decide to use optional app functionality. If an optional app functionality processes personal data, users are notified when they opt in and are required to give consent to processing personal data while the functionality is active in the app.
Automated decision-making
We do not take decisions based on automated processing on matters that may have (significant) consequences for individuals. These are decisions that are made by computer programs or systems without a human being (e.g., an employee of ours) being involved. We use the following computer programs or systems:
- Amazon AWS Cloud hosting: ISO 27001 certified. Data storage is in Ireland.
- Twilio SMS Services: ISO 27001 certified.
Retention period
We do not retain your personal data longer than is strictly necessary to achieve the purposes for which your data is collected. We apply the following retention periods for the following (categories of) personal data:
| Category | Retention period | Reason |
|
Login and session data Geolocation |
Not applicable | Geolocation data is only used for local data processing. Geolocation is only processed when the user activates optional app functionalities. |
| Personal details (Name/Phone/Email) | Until termination of the service | Offering our services |
| Lock data (activations) | 1 year, or until the lock is removed | Providing additional security for the platform and its users. |
| Login and session data (Reading/Writing) | 30 days | Ensuring stability and safety on the platform. |
| Telephone recordings with our customer service staff | max. 4 weeks | Improving our customer service (training purposes) |
Sharing with third parties
We do not provide any user data to third parties unless you gave us permission in order to enable additional services, or it is necessary for the performance of the contract with you, or to comply with a legal obligation.
Cookies, or similar techniques, that we use
We only use functional cookies (by means of local data storage) when using the app. This is necessary in order to offer our service and to offer things such as access and session management.
View, modify, or delete data
You have a right to access, correct, and delete your personal data. You can do this yourself via the personal settings of your account. In addition, you have the right to withdraw any previously given consent for data processing or, in certain cases, to object to the processing of your personal data by our company or to limit the processing. You also have the right to data transfer. This means that you can submit a request to us to send the personal data you have provided to us in a computer file to you or another organization named by you.
If you wish to exercise your rights or if you have any other questions/remarks regarding data processing, please send a (specified) request to privacy@boldsmartlock.com. We will respond to the request as soon as possible, but in any case, within four weeks. For your safety, we reserve the right to request additional personal data in order to establish your identity.
We would also like to point out that you have the possibility of lodging a complaint with the national supervisory authority, the Personal Data Authority. This can be done via the following link.
Reviews
We may contact you by e-mail to ask you to review our services and/or products so we can collect your feedback and improve our services and products. We use a third-party company, Trustpilot A/S ("Trustpilot"), to collect your feedback. For this purpose, we share your name, e-mail address, and reference number with Trustpilot. You can find the company’s Privacy Policy here if you want to know more about how Trustpilot processes your data. We are legitimately interested in this type of data processing to evaluate and improve our products and services. Occasionally we can use reviews in promotions and media for advertisement and promotional purposes.
How we secure personal data
We take the protection of your data seriously and take appropriate measures to prevent misuse, loss, unauthorized access, unwanted disclosure, and unauthorized modification. If you feel that your data is not properly protected or there are indications of misuse, please contact us at privacy@boldsmartlock.com.