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Bluetooth provides for a personal angle of attack against the targeted individuals and their friends and associates. By attacking their personal communication devices, an attacker can listen in on confidential business transactions and even copy off text messages, e-mails, and calendar invites.
At the very least, poor Bluetooth security can allow an attacker to monitor for random devices that come near an established listening post. Depending on the target's device, further attacks could lead to a large cache of information. Much of this risk can be reduced by simply leaving a cell phone, or any other Bluetooth device, in a nondiscoverable mode at all times and only placing it into discoverable mode when you actually want to sync it with a device.