Privacy Statement

See also: Bold EU Transparency Act

version 1.8 - 01-2026

Bold Security Technology B.V. (Bold), established at Leidseveer 2, 3511 SB Utrecht, is responsible for the processing of personal data as described in this privacy statement. This privacy statement only applies to the processing of personal data for which we act as a controller, for example when you use our website or buy one of our products and use our Bold App or our online portal.

When our business customers use our services to collect and process personal data, we act as a processor on behalf of our customers, to which processing our Data Processing Terms as set out in our General Terms and Conditions for Business Customers will apply.

Contact details

www.boldsmartlock.com

Leidseveer 2

3511 SB Utrecht

+31850607337

Ruud Diterwich is the Privacy Officer of Bold Security Technology BV. You can reach our Privacy Officer via privacy@boldsmartlock.com.

Your personal data

Personal data is any kind of information that can be directly or indirectly attributed to you. For example, your name, address, contact details such as email address and phone number, a purchase order, usage data, and your customer or support ID.

We process your personal data because you make use of our services and/or because you provide them to us yourself, for several reasons.

Legal basis for processing

We process your personal data based on one of the following legal grounds:

You have consented to the processing of your personal data. For example, to integrate your Bold products with existing applications, such as Google Home.
The processing is necessary for the performance of a contract. For example, to be able to call or email if this is necessary to carry out our services, to offer the possibility to create an account, and to inform you about changes to our services and products.
The processing is necessary to comply with a legal obligation.
The processing is necessary for our legitimate interests. For example, we may record (parts of) your telephone conversation with our customer service staff for training purposes. We may also process personal data to guarantee the security of our platform and its users.

Personal data that we process

Below you will find an overview of the personal data we process, including the purposes and legal basis thereof.

Buying our products via our website

When you buy one of our products via our website, we process your contact information such as your name, delivery and billing address, email address and phone number, and payment related data to process your order and handle the payment, to manage deliveries or returns, or warranty matters. We will also use your contact details to inform you on your order status or about changes to our services and products. We will process your personal data for these purposes to perform our contact with you.

When you choose to pay via Klarna Bank AB and use its credit payment method(s), we might in the checkout pass your personal data in the form of contact and order details to Klarna, in order for Klarna to assess whether you qualify for their payment methods and to tailor those payment methods for you. Your personal data transferred is processed in line with its Privacy Policy (here).

You may also leave your email address to register to receive a notification per email when an item comes back in stock. Once the item is back in stock and we have sent a notification thereof, we will no longer keep your email address for this purpose.

As a customer of our products, we may send you marketing communications on related products or services, unless you choose to opt-out.

Creating a Bold App account

You can connect your products, such as your Bold Smart Lock, to your smartphone or other device via our Bold App. When you create an account for the Bold App, you may use your existing account from Apple, Google or Microsoft to log in, or you may create a separate account on the basis of your email address or phone number. After registration, you will receive a code via the email address or phone number provided by you, which you must use to verify your Bold App account. A support ID will be automatically assigned to your Bold App account.

We also collect information on the choices you have made to receive marketing communications. We may communicate important updates and changes to your products or Bold App account via e-mail as this is necessary to perform our contract with you.

This data will be stored until you delete your Bold App account.

Using our Bold App

Via our Bold App, we may collect automatically any logging data relating to your lock use, consisting of the number of activations and the date and time of these activations of our products by you (or your added users). Your login and session data (consisting of your session ID or token, a timestamp of your last activity and your permissions/role info) will be deleted after 30 days. The lock data, consisting of number and time of activations and access rights, will be deleted after one year or after the Bold Smart Lock to which the data is related is removed from the Bold App.

Depending on the device used, you may grant certain permissions that allow access to your device data as described below.

Location permission

We may request permission to access your device’s location to provide location-based features, such as automatic entry. This permission is used only for specific, optional Bold App features. All location data is processed locally on your device and is never stored on Bold’s servers.

Bluetooth sharing permission

To connect your products to your Bold App account, our Bold App must access Bluetooth-related functions to scan for devices, connect with devices, and to allow data transfer between devices.

Smart Home integration permissions

You may allow our Bold App to interact with Smart Home devices and other physical accessories in the surrounding environment.

You may share access to your Bold Smart Lock with other people and may invite someone by providing their first and last name, the type of access rights you want to grant, whether you wish to receive a notification whenever this user activates the lock, and its contact details, depending on how you wish to send the invitation (via SMS, email or other platforms).

Creating a Bold Pro subscription

If you or the organisation you work for is a business customer of Bold, you may use a Bold Pro subscription on behalf of your company for our web portal to manage users directly from your browser instead of via the Bold App. To use the Bold Pro subscription for your organisation, you must have a Bold App account and provide your company name to manage the web portal.

Using the Bold Pro subscription

The Bold Pro subscription allows you to create lock groups, assign user permissions, and track activity across your business from a centralized platform. Via the web portal you may share access to your users via a web link.

All logs relating to access events and lock activity are retained for up to one year.

The users you have invited must create their own Bold App accounts. We act as a data processor for any personal data related to such users (e.g. our business customers’ employees, guests, customers or other end users) in accordance with the instructions of our business customers.

Using the Bold Callspot

Bold Callspot is an extension of the Bold App that enables visitors to contact the owner of a Bold Smart Lock by scanning a tag (QR or NFC) displayed at the location. When a visitor initiates a call, neither the phone number of the lock owner nor that of the visitor is disclosed to the other party. Communication takes place via the Bold Callspot service.

During the call, the lock owner may choose to remotely activate the Bold Smart Lock to grant the visitor access. For security purposes, an image of the visitor is captured at the moment the call is initiated, together with a timestamp. No additional personal data of the visitor is stored. Live video and audio data are processed only for the duration of the call and are not recorded or retained after the call ends.

Lock owners access Bold Callspot through a separate Bold Callspot application and authenticate using their existing Bold App account credentials. Access to device features such as camera, microphone, and network connectivity is required to enable the Callspot functionality.

Using one of our products as added user

If one of our customers has added you as a user to a Bold Smart Lock via the Bold App, we have obtained your personal data such as your first and last name, type of access rights granted, and contact details from this customer.

If you have received a web key or invitation from one of our business customers with a Bold Pro subscription, we have obtained your assigned name via this business customer. We will act as a data processor for any personal data in this regard.

Contacting our customer service

You may request a business order or quote (or contact with our sales team) via our website by providing your first name, your email address, company name and the subject you wish to discuss.

If you contact us by phone, we may take notes. The personal data we process depends on the nature of the conversation, for example your name, phone number, and other data necessary to assist you further. We may also record (parts of) your telephone conversation with our customer service staff for training purposes. We will notify you before any recording starts, and you have the right to object to the recording itself. We will keep these telephone recordings for a maximum of 4 weeks, after which they will be deleted.

When you send us an email, we will process your email address and any other personal data you include in your message, such as your name and the organisation you work for. We use this information solely to respond to your email.

Reviews

After buying one of our products, we may contact you by email to ask you to review our services and/or products so we can collect your feedback and improve our services and products on the basis of our contract with you, as this is compatible with the purpose for which the data were collected. We use a third-party company, Trustpilot A/S ("Trustpilot"), to collect your feedback. For this purpose, we share your name, email 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. You may object to such use.

Cookies, or similar techniques, that we use

We only use functional cookies (by means of local data storage) when using our website, our web portal, and the Bold App. This is necessary in order to offer our service and to offer things such as access and session management. We do not need to request your consent to use these functional and analytical cookies that have a limited impact on your privacy.

Our website and our online portal

In addition to purely functional and essential cookies, our website also uses cookies for which we request your consent, such as cookies that may track your activity across our website, to display relevant advertisements. You can find more information about these cookies and how to manage your consent in our Cookie Statement via the following link: https://boldsmartlock.com/cookie-statement.

Our Bold App

We do not use any tracking or marketing cookies via our Bold App.

Children

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@boldsmartlock.com, and we will delete that information.

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.

Retention period

We do not retain your personal data longer than is strictly necessary to achieve the purposes for which your data is collected, unless there is a legal requirement for us to keep your personal data longer.

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, Access rights)	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)
Bold Callspot data (Image storage (snapshot), timestamp)	1 year, or until the product is removed.	Processing is carried out for security and operational purposes based on our legitimate interest. Visitor images are automatically deleted.

Sharing with third parties

We may provide personal data to third parties to accomplish the intended processing purpose and/or if this is permitted by law, e.g. because 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. For example, if the police or judicial authorities demand certain data, we must provide this data.

If your personal data is provided to a party outside the European Economic Area, we will ensure that an adequate level of protection applies in that territory, or that other appropriate safeguards are implemented to protect your personal data.

In this regard, we may provide your contact details to a third-party logistics and courier service provider for order fulfilment and shipping, or we may provide your contact and order details to Klarna if you choose to their payment methods.

We may use certain data processors to process your personal data on our behalf. We will then ensure that the processing and protection of your personal data is governed by a data processing agreement.

For example, we make use of Twilio Inc. to provide our SMS services and use HubSpot, Inc. for providing our online forms. Both entities are in the US and participate in the EU-U.S. Data Privacy Framework. Further, all data is hosted via Amazon AWS Cloud. Data storage is in Ireland.

If you wish to receive further information about the transfer of your personal data to countries outside the European Economic Area and the applicable safeguards, you can contact us at privacy@boldsmartlock.com.

Your rights in relation to your personal 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 or submit a request to us. 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, you may use your personal account on our app or send a (specified) request to privacy@boldsmartlock.com. We will respond to the request as soon as possible, but in any case, within one month after receiving your request. For your safety, we reserve the right to request additional personal data to establish your identity.

Depending on the complexity of the requests and the number of requests, this period may be extended by up to two months if necessary. You will be informed of this as well. If your request is rejected or we do not comply with it, we will inform you of the reasons why. We would also like to point out that you have the possibility of lodging a complaint with the national supervisory authority. In the Netherlands, this is the Autoriteit Persoonsgegevens. This can be done via the following link: https://www.autoriteitpersoonsgegevens.nl/en/submitting-a-tip-off-or-a-complaint-to-the-ap.

If your request or complaint relates to personal data we process as a data processor on behalf of a business customer, we may direct you to this customer to address this request or complaint.

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.

Updates to our privacy statement

We may need to update our privacy statement. The latest version of our privacy statement is always available on our website, with the date indicating when it was last updated.

In the latest update of January 2026, we have improved the structure of the privacy statement to enhance readability, and we have added several processing descriptions in relation to the processing activities via our website and our app, more information on the third parties with whom we may share certain personal data.

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