Last updated: 20 July 2026
This policy explains how Simpled ("we", "us", "our") handles personal data when you visit our Ireland website, buy a product, create an account, use the Simpled app or a Simpled smart lock or accessory, or contact our support team. It is intended to be read alongside our Cookie Policy.
1. Who we are
Simpled Tech Limited (registered in England and Wales, company number 13391034, registered office 2 Eastbourne Terrace, London, W2 6LG, United Kingdom) is the controller of your personal data under the EU General Data Protection Regulation ("GDPR") and the Irish Data Protection Act 2018.
EU representative (Article 27 GDPR). Because we are established outside the EU, we are required to designate a representative in the European Union. Our EU representative is Regloop Solutions Limited, Office 1, Unit 17, Western Parkway Business Centre, Ballymount Road, Lower Ballymount Road, Dublin 12, D12 NF89, Ireland. These details are also available from us on request. (This is a data-protection appointment, separate from any environmental producer-responsibility registration, which relates to WEEE, batteries and tyres, not to your personal data.)
Contact us about privacy at support@simpled.tech (mark your message "Privacy") or by post to the registered office above.
2. Personal data we collect
- Identity and contact data — name, email address, phone number, billing and delivery address.
- Order and transaction data — products purchased, order value, delivery, returns and refunds. Payments are processed by our payment providers; we do not receive or store your full card number.
- Account data — login credentials (passwords are designed to be stored in hashed form), settings and preferences.
- Product and app data — when you set up and use a Simpled lock with the Simpled app: device identifiers and model, firmware version, battery status, configuration settings, lock/unlock event logs and access history (including which registered user or credential operated the lock and when), diagnostic and error logs, and Bluetooth/Wi-Fi connection data.
- Location data — the app may request location permission for features such as auto-unlock or locating your devices. This is optional, controlled by your device permissions, and can be switched off at any time.
- Support data — the content of your emails, calls, chats and reviews.
- Technical and usage data — IP address, browser and device type, operating system, pages viewed, referral source and site interactions (see our Cookie Policy).
- Marketing preferences — your subscription choices and email interactions.
3. Biometric data
Where your lock has a biometric reader, biometric data such as your fingerprint and, where your device supports it, facial or palm recognition is converted into a biometric template — a mathematical representation, rather than an image of your fingerprint, face or palm. How that template is held and where it is stored depends on the specific model and its firmware, and we set out the position for a given model on its product page and here once verified for that model. Where, for a particular model, the template is created and remains solely on your device and is not transmitted to or processed by us, we would not process special-category biometric data within the meaning of Article 9 GDPR in respect of that biometric data. Where a model transmits biometric data off-device, or where it is otherwise processed by us or on our behalf, we will describe that here and give it an Article 9 lawful basis and additional safeguards.
4. How we use it and our legal bases (Article 6 GDPR)
- To fulfil your order, deliver products, process payments and provide warranty and support — Art. 6(1)(b), performance of a contract.
- To operate the Simpled app and your devices, including syncing settings, access logs and firmware updates — Art. 6(1)(b).
- To provide security updates and notify you of safety or security issues — Art. 6(1)(f), legitimate interests, and Art. 6(1)(c) where legally required.
- To handle withdrawals, returns and refunds — Art. 6(1)(b) and (c); and to keep tax, accounting and customs records — Art. 6(1)(c).
- To prevent fraud, secure our systems and enforce our terms, and to improve our products, website, app and support — Art. 6(1)(f), and consent (Art. 6(1)(a)) where required for non-essential cookies.
- To send you marketing — consent (Art. 6(1)(a)), or the existing-customer exemption for similar products under the Irish ePrivacy Regulations (S.I. 336/2011) with an opt-out in every message.
We do not sell personal data and do not use lock access logs for advertising.
5. Cookies
We use cookies and similar technologies on our website. Full details of the categories we use and how to manage them are set out in our Cookie Policy.
6. Who we share it with
We share personal data with service providers under Article 28 contracts: payment processors, delivery carriers and customs brokers, cloud hosting and infrastructure, app and firmware infrastructure, email and customer-support platforms, analytics and fraud-prevention providers. We may also share with professional advisers, and with authorities, regulators and law enforcement where the law requires or permits (including legally valid requests relating to lock access logs, the validity and scope of which we check before responding), and with a buyer or successor on a sale or restructuring of the business.
App and lock-connectivity platform. Some app, connectivity and remote-management features of your Simpled lock may be provided through a third-party smart-lock software platform (currently including, where applicable, TTLock, operated by Sciener) and/or through Simpled's own software and cloud services. Where the TTLock platform is used, the data it may receive and process on its own servers includes your account information, the credential identifiers you create (for example passcode values, eKey grants, and the name/label of a fingerprint, rather than the biometric template itself), unlock and access records (logs), and connection and log data including your IP address and general location. This data may be processed outside the EU: TTLock's policy states data may be sent to the United States and possibly other countries, and that the policy is governed by the law of Singapore (see https://ttlock.app/data-privacy-and-security-policy/). Where TTLock supplies infrastructure that operates your lock under our instructions, it acts as our processor under an Article 28 arrangement and this Policy applies. If you choose to install and use the TTLock app directly (rather than the Simpled app), you accept TTLock's own terms and privacy policy, and TTLock — not Simpled — is the controller of the personal data you provide to it in that capacity.
7. International transfers
We are established in the United Kingdom, so your data is transferred to the UK. The UK currently benefits from a European Commission adequacy decision, and transfers to us are lawful on that basis while that decision stands. If it is withdrawn or lapses, we may implement EU Standard Contractual Clauses or another valid mechanism. Some of our providers may process data in other third countries; where they do, we use adequacy decisions or EU Standard Contractual Clauses with supplementary measures as needed. You may request details of the safeguards we use.
8. Retention
We keep personal data only as long as needed: order and transaction records for approximately 6–7 years (tax, customs and legal claims); account and device data while your account is active and briefly after closure; lock event logs per your app settings and our retention schedule; support records up to around 6 years; marketing data until you unsubscribe or after prolonged inactivity. We then delete or irreversibly anonymise it.
9. Security
We apply technical and organisational measures appropriate to a security product, designed to include: encryption in transit and at rest for sensitive data, access controls and least-privilege administration, hashed credentials, signed firmware updates, and a coordinated vulnerability-disclosure programme. No system is perfectly secure, and we cannot guarantee absolute security. If a breach occurs that risks your rights, we will notify the competent supervisory authority and, where required, you, in line with Articles 33 and 34 GDPR.
10. Your rights
Under the GDPR you have the right to: access your personal data (Art. 15); rectification (Art. 16); erasure (Art. 17); restriction (Art. 18); data portability (Art. 20); object to processing based on legitimate interests, and to direct marketing at any time (Art. 21); and withdraw consent at any time without affecting prior processing (Art. 7(3)). To exercise a right, contact support@simpled.tech or our EU representative. We aim to respond within one month (extendable by two months for complex requests, with notice). You may also ask us to delete your account and associated data; before disposing of or reselling a device, deregister it from your app account and factory-reset it so credentials and local data are cleared.
11. Connected-product data (EU Data Act)
Your Simpled lock is a connected product that generates data such as access and event logs. Under the EU Data Act (Regulation (EU) 2023/2854), where applicable, you may have the right to access and port certain data generated by your device. Where such access is available, we will describe how to obtain it. (Design-access duties for products placed on the EU market apply from 12 September 2026; this section will be expanded as those duties take effect.)
12. Automated decision-making
We do not make decisions producing legal or similarly significant effects based solely on automated processing (Art. 22). Automated fraud screening may be applied to orders; a declined order is reviewable by a human on request.
13. Children
Our website, store and app are intended for adults aged 18 or over. We do not knowingly collect personal data from children. A lock owner may issue access credentials to household members, including minors, under the owner's responsibility.
14. Complaints & contact
Controller: Simpled Tech Limited, 2 Eastbourne Terrace, London, W2 6LG, United Kingdom — support@simpled.tech — +44 (0)20 7096 0094. EU representative (Art. 27): Regloop Solutions Limited, Office 1, Unit 17, Western Parkway Business Centre, Ballymount Road, Lower Ballymount Road, Dublin 12, D12 NF89, Ireland — available on request.
We would welcome the chance to resolve any concern first. You also have the right to lodge a complaint with the Irish Data Protection Commission (DPC): dataprotection.ie / 21 Fitzwilliam Square South, Dublin 2, D02 RD28 / +353 (0)1 765 0100 — or with the supervisory authority of the EU member state where you live or work. If you have questions about this policy, please get in touch.
