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: 2026-06-18

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 managed exclusively by Mottura itself and is hosted by a hosting provider located in France.

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)	Serial lock, Lock name, Username on lock, Type of lock, Date of first installation, Date of last installation, Lock operating mode, Lock battery, Lock status (bolts and latch), Door status, Last diagnostic data, Lock firmware version.	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)	Serial lock, Lock name, Username on lock, Type of lock, Date of first installation, Date of last installation, Lock operating mode, Lock battery, Lock status (bolts and latch), Door status, Last diagnostic data, Lock firmware version, Account name, Account email, Lock coordinates (latitude and longitude), Accessories list, Credentials list, Event list, Cloud event list, Smartphones (OS and UID).	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 available data is implemented through the bMOTTURA mobile app, in the Settings > Account section.

After logging in with their credentials, the user can download a copy of the available data associated with their account and connected devices, within the limits of the data actually generated, collected and stored by Mottura.

The download is available in JSON format, which is structured and machine-readable, or in PDF format, for easier consultation by the user.

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”.