Data Information Notice as per Regulation (UE) 2023/2854 (“Data Act”)

Information notice for: Mottura bTECHNOLOGY lock ecosystem.

Manufacturer/Service provider: Mottura Serrature di Sicurezza S.p.A., Strada Antica di Francia, 34 - 10057 Sant'Ambrogio (TO), Italy

Date: 2025-09-12

1. Introduction

1. Introduction

1.1 General

This information notice explains how data generated by, or collected through, the bTECHNOLOGY lock ecosystem (the “Connected Product”) is accessed, used, and shared including to provide the bMOTTURA Mobile App and bWEBTECHNOLOGY Web App (the “Related Service”) and how the data is otherwise processed, in line with the requirements under Article 3 of the EU Data Act.   

1.2 Product and service description

The Mottura bTECHNOLOGY range includes Bluetooth smart locks and accessories (connected products) that can be locked and unlocked using the bMOTTURA mobile and web applications (related services). The platform is designed to enhance the user experience for door-installed devices by enabling secure local connectivity and remote management via the Mottura Cloud. Usage data is stored locally on the lock and accessible only to the user (administrator); online access is available exclusively upon user request through a registered Mottura Cloud account. The cloud platform is hosted by Mottura.

1.3 Data holder

The following company receives data from the Connected Product and/or the Related Service and may use the data for their own purposes (‘Data Holder’): Mottura Serrature di Sicurezza S.p.A., Strada Antica di Francia, 34 - 10057 Sant'Ambrogio (TO) – Italy.

2. Data which the Connected Product is capable of generating

Product name Nature of data Format Estimated volume Collection frequency Data retention
bTECHNOLOGY locks (bNOVA and bMOTO) First use date lock, First pairing date, Master code, Invitation codes, Time slots invitation codes, Usernames invitation codes, Keypad codes, Openings and closing log locks, Lock operating mode, Lock battery, Lock status (door, bolts and latch), Diagnostic data, Lock firmware version, Accessories list. JSON Data is generated each time it is used. Every opening generates around 9 bytes in logs (max 1000 then oldest is deleted). Data is generated continuously and in real time. Data are saved until factory reset, indefinitely, except for opening and closing log locks (activity logs): there is no retention period but when lock reaches 1000, the oldest is deleted. 
bTECHNOLOGY locks (bOPEN and bBLOCK) Same as above except for Diagnostic data, which is not generated by these types of locks.  Same as above Same as above Same as above Same as above

3. Data obtained by Mottura Serrature di Sicurezza with the provision of the Related Service

Service name Nature of data Format Estimated volume Data retention
bMOTTURA Mobile App Online and bWEBTECHNOLOGY Web app (with the creation of Mottura cloud account)

Name, Surname (optional), email, password, Lock coordinates, smartphone model, smartphone UID, API logs. In addition, the data generated by the Product referred to in point 2 are sent to the Cloud, depending on the user's specific usage modes: Date of first use of the lock, Date of first pairing, Master Code, Invitation codes, Invitation code time slots, Invitation code user names, Keypad codes (only when using the bBRIDGE), Opening and closing log locks, Lock operating mode, Lock battery, Lock status (door, deadbolts, and latch), Diagnostic data, Lock firmware version, List of accessories (only when using the bBRIDGE).

JSON An average of approx-imately 0.3 KB per user can be estimated. The data are deleted at the moment of the deletion of the account - except for opening and closing log locks which are deleted automatically after 30 days.

4. Data Sharing and Use

Type of data use Data use Sharing of data Identity of data recipient
Same as point 3 In addition to the purposes of operation, security and assistance of the Service, the data may be used by the Data Controller for its own statistical analysis purposes to improve services and functionality.  Data are not shared with any third parties unless upon request of the user. Non applicable.

5. Data access and user capabilities

Direct access to data Indirect access to data Erasure of data

If the user has a Mottura Cloud account, direct access to the usage data stored in the Cloud is not provided. 

The usage data for products for which a Mottura Cloud account has not been created/used is stored locally in the lock and can be viewed by the user (administrator) via their device. However, data are not exportable in this case.

Where a user has a Mottura Cloud Account, they can make a request to access the data generated by their use of the Product and Service by sending an email to tecnico@mottura.it.

To help us manage your request, when submitting your request, please include: lock serial (or serials for multiple locks), email, phone number, name.

The data set out above can be deleted by deleting your Mottura Cloud User Account. You can delete your User Account by pressing the red button “Delete account” in the account section in your bMOTTURA mobile app.

The factory reset of your lock won’t erase data on cloud, to factory reset your device in bMOT-TURA app, in ‘Lock configuration’ section press the red button “Reset lock”.

6. How to request data sharing

6. How to request data sharing

You may request us to share data with a specific third party. In order to make a request, please follow the process explained in the ‘Indirect access to data’ section above.

7. Right to lodge a complaint

7. Right to lodge a complaint

If you believe our handling of your data infringes your rights under applicable legislation, you have the right to lodge a complaint with the competent authority in your jurisdiction.

8. Trade secrets

8. Trade secrets

In some cases, data from the connected products or related services may include trade secrets that we or our partners own. Trade secrets shall be preserved and disclosed only where all necessary measures prior to preserve their confidentiality are taken, in particular regarding third parties. In exceptional circumstances, our ability to grant access to data may be limited due to trade secrets. We maintain confidentiality obligations to protect any trade secrets contained within your data.  

9. Term and termination

9. Term and termination

Your contract with Mottura Serrature di Sicurezza is valid for as long as you use the devices in the bTECHNOLOGY line, only after having created a Mottura Cloud Account beginning on the date you sign up. To terminate your Related Service, you can delete your Mottura Cloud account by following the procedure indicated in point 5 above “data deletion”. 

10. Contact information

10. Contact information

Should you have any questions regarding the data generated by the Product or the Service, do not hesitate to contact us at tecnico@mottura.it