Bold Privacy Statement

version 2.0 – 11-2020

Bold Security Technology B.V., established at Proostwetering 41 3543 AC Utrecht, is responsible for the processing of personal data as described in this privacy statement.

Contact details
www.boldsmartlock.com
Proostwetering 41
3543 AC Utrecht
+31850607337

Thom van Beek is the Data Protection Officer of Bold Security Technology B.V. He can be reached via tvanbeek@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

Login and session management

  • Telephone model and type
  • Internet browser and device type
  • Geolocation of telephone (only processed when the user activates optional app functionalities)

Lock use

  • Times of activations
  • Number of activations

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 in order to prevent the collection of information about children without parental consent. If you believe that we have collected personal information about a minor without that consent, please contact us at privacy@boldsmartlock.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).
  • 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)
  • 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. 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 processing personal data while the functionality is active in the app.

Automated decision-making

We do not take decisions on the basis of 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:

CategoryRetention periodReason

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
  • Telephone number
  • e-mail address
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 data
  • Writing data
30 daysEnsuring stability and safety on the platform.

Sharing with third parties

We do not provide any user data to third parties, unless this 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 organisation 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.

How we secure personal data

We take the protection of your data seriously and take appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised modification. If you feel that your data is not properly protected or there are indications of misuse, please contact us at privacy@boldsmartlock.com 

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