Bolt Privacy Notice: Drivers

Last Updated: 15 JULY 2022

This privacy notice lets you know how we promise to look after your personal data as a driver in the United Kingdom. This notice tells you things like what information we collect and process from you when using Bolt platform, in the course of your installation and use of the Bolt driver app, what personal data we use to register and onboard you, and how we use your data to provide you with our platform services, all in accordance with the relevant terms of use. This notice also lets you know how we use your information to keep you and others safe, and the choices and controls available to you. This notice tells you about your privacy rights and how data protection rules work to protect everyone’s interests. And if you need to get in touch, all the details follow below.

The term “you” or “driver” refers to an individual that has applied to act as an individual providing driver services via the Bolt platform (including where you are a driver that has applied to fulfill journeys in association with another driver’s account, in which case the exceptions stated below will apply).

Who we are

Bolt Services UK Limited trading as “Bolt” (a company registered in the United Kingdom, with company number 11063356, having its registered office at Studio 4 114 Power Road, London, W4 5PY) and, its parent entity

Bolt Technology OÜ (a limited company incorporated and registered in Estonia with registration code 124178434, having its registered office in Vana-Louna 15, Tallinn 10134, Estonia) and;

Bolt Operations OÜ (a limited company incorporated and registered in Estonia with registration code 14532901, having its registered office in Vana-Louna 15, Tallinn 10134, Estonia), together, “Bolt” or “we” set out below how we use your personal data.

1. Personal data we process

We only process information that we need to, so we can provide you with the very best service on our platform.

We process the following types of personal data:

Personal information: things like name and date of birth, and contact details like your address, email, and phone number.
Payment information: things like your bank details and transaction details such as transaction amounts, except where you are a driver that has applied to fulfill journeys in association with another driver’s account.
Information about your driving licence and the information on it, your vehicle, and your insurance details.
Background checks: things like medical certificates, topographical test certificates and English language test certificates, too.
Data regarding criminal convictions and offences.
Law enforcement engagement: things like any record of a police request for your personal data, a record of whether a disclosure was made by us, and the content of that disclosure.
Third party verification: Information collected from third parties about you in order to verify any information you supplied to Bolt during registration to Bolt platform.
Authentication and verification data: Things like the selfies you provide to us, from which identity authentication and verification checks can be undertaken and recorded.
Limited identification data of the device, like the IP address, on which the Bolt app has been installed.
Geolocation: things like where you are, the location of nearby passengers to you, the time, the journey progression and the final destination of a journey.
Feedback and ratings: a score (out of 5) provided by each passenger after a journey.
Data about your platform usage: things about your engagement and interaction with the app, such as details of journeys (date and time, number of confirmed journeys and cancellations), duration of fulfilling journeys on each day, and ratings (including your Driver Score, Confirmation Rate and Preferential Allocation Level where such features are available).
Driver records: things like where we withdraw your right to use the service, issue a notice, or provide a driver with additional guidance or require other actions to be taken, and information relating to any associated reviews or appeals.
Communication and correspondence records: such as when you engage with our in-app chat ("Send a Message" option), or speak with our customer service agents, the date and time of the communication, and its content.

We may receive and collect your data from another driver where you are a driver that has applied to fulfill journeys in association with another driver’s account.

2. Purpose of the processing

Bolt collects and uses personal data for the purposes of providing its services in accordance with the Bolt Driver Terms, and for ensuring the safety of passengers and drivers. This includes the following:

We make sure you are who you say you are, and that you are licensed to provide driver services (where applicable): Driver's license, professional qualifications and certifications, identity documents and criminal convictions and offences are processed to determine driver compliance with legal requirements and regulatory conditions that apply to driver services. We use the information on your driving licence data and the selfies you provide to us to verify and authenticate your identity on an ongoing basis for safety and security purposes. When you create a new account on the Bolt app and prior to taking your first journey, you will be asked to upload a picture of your driving licence and submit a selfie; and then on an ongoing basis at appropriate intervals, you will be asked to submit another selfie. We use biometric software to achieve this purpose.
We connect you with a passenger: We collect and process personal data for the purpose of connecting drivers with passengers to fulfill a journey,.
We provide a platform: We collect and use information about a driver’s engagement and interaction on the platform, and their ratings (including Driver Score where this feature is available to you) to encourage user safety, ensure the compliance with the Driver Terms, and make sure we’re providing a quality and enjoyable service to everyone. Where your Driver Score (when available) drops below a specified threshold, we may issue you with a notification to digest some further guidance. We also use driver ratings, including the Driver Score and Confirmation Rate, to determine the preferential allocation of drivers to passengers (where this feature is available): this is indicated by the drivers' Preferential Allocation Level in the Bolt app. Drivers can see their own Driver Score and Preferential Allocation Level (when available), as well as more information about how these are calculated and used via the Bolt app.
We make sure the journey goes smoothly: We use geolocation data to make sure you get to your destination and resolve quality issues related to our services.
We make sure the app is optimal: We use contact details to notify drivers of updates to the Bolt app so you can keep using our services. We also gather limited data from the device that you use to connect you with our internet, mobile and telephone services, and to help keep your account safe through authentication and verification checks.
We make sure that journeys are quick and convenient: We collect data on the routes taken by drivers to analyse geographic coverage. This lets us do things like improving recommendations to drivers about the most efficient routes.
We process payments: We process payment details to make payments, except where you are a driver that has applied to fulfill journeys in association with another driver’s account.
We maintain and promote standards: We collect data about journey status, time and ratings from passenger feedback to encourage user safety, promote compliance with our terms and conditions, and make sure we’re providing a quality and enjoyable service to everyone. Customer support data and correspondence is collected for the purposes of feedback and resolving disputes and service quality issues.
We talk and keep you informed: Your name, phone number and email address will be used to communicate with you our most important service-related messages. Personal data related to instant messages directly in the Bolt app are processed in order to provide assistance and customer support, including where we need to resolve any dispute between driver and passengers.

3. Lawful Basis

We are allowed to use personal information in the ways described above if we have a proper reason to do so. We always make sure we have a good reason for doing anything with your data.

We collect and process the personal data of drivers to comply with our legal and regulatory obligations, such as to comply with relevant legislation that applies to us and to meet our own licensing conditions and for verifying a driver’s qualifications for providing driver services.

Personal data is processed to provide the driver services available via the Bolt platform in accordance with our terms and conditions that apply to drivers in the United Kingdom. This includes, for example, connecting you with a passenger, operating our platform, resolving any service quality issues and monitoring compliance with terms.

We generally in other circumstances process your personal data relying on legitimate interest grounds. Legitimate interests include our interests in providing an innovative, personalised and safe service to you and others. Our legitimate interests include things like investigating, detecting and preventing fraudulent and other malicious activities, maintaining the security of our network and systems, and responding to suspected or actual criminal acts.

We may from time to time rely on alternative lawful bases for processing your data when:

It is necessary to protect your vital interests or those of others, for example in the event of an emergency or an imminent threat to life; or
you have given us clear consent to do so for another specific purpose in which you have been fully informed. Where we rely on consent to process personal data, you can withdraw your consent to such activities at any time.

If you choose not to give us personal information it may prevent us from fulfilling the contract with you, or stop us from doing something expected of us in law. It may also mean that we cannot operate your account. For example, we collect and process the personal data submitted by you in the course of installing and using the Bolt app; refusing to share geolocation data via the App means we cannot direct you to a passenger location for pick-up. We will not be able to fulfil our obligations to you in other circumstances, for example, should you refuse to undertake an identity verification check to ensure the integrity of your account, then the account may be suspended or terminated to prevent fraud.

4. Recipients

We only work with trusted partners and authorities. We only share when there is a proper reason to do so. We limit sharing to only that which is required. We do not sell your personal information.

Your personal data is disclosed to passengers when:

you have confirmed the offer to fulfill the journey; in which case they will see your name, vehicle details, photo, geolocation data (e.g. ETA), fare and rating (out of 5 stars).

In some circumstances, we are legally obliged to share information with external recipients. For example, under a Court Order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. We can also respond to requests, such as those from law enforcement agencies, when the response is required by law or furthers a public interest task. In any scenario, we’ll always satisfy ourselves that we have a lawful basis on which to share the information, and we’ll make sure that we document our decision.

We may share your personal data with Bolt group companies to provide our services and for internal administrative purposes.

Bolt may provide personal data to our service providers and business partners, which include:

Business partners who offer their partnership or promotional offering in collaboration with Bolt;
Drivers, where you are a driver that has applied to fulfill journeys in association with another driver’s account;
Payment processors and facilitators;
Background check and identity verification providers;
Cloud service providers and other IT support and infrastructure service providers;
Telecommunication service providers;
Research partners.

5. Security and access

Any personal data collected in the course of providing our services is transferred to, and stored, in the data centres of Zone Media Ltd. and/or Amazon Web Services, Inc., which are located in the United Kingdom and/or the territories of the Member States of the European Union. Only authorised employees of Bolt have access to the personal data and they may access the data only for the specified purposes.

Bolt may, on occasion, need to transfer personal data to its third-party service providers, who may be located in countries outside of the UK and EEA. Whenever we transfer your personal data out of the UK and/or EEA, we ensure the same degree of protection is afforded to your data by ensuring at least one of the following safeguards is implemented:

we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government (in the case of transfers out of the UK), and/or the European Commission (in the case of transfers out of the EEA); and/or
where we use certain service providers, we may use specific contracts approved by the UK Government (in the case of transfers out of the UK) and/or the European Commission (in the case of transfers out of the EEA).

6. Your rights and controls

We want you to stay in control of your personal data. Bolt provides you with controls through the app and Driver Portal where you can view and change your personal information. We also offer in-app settings like marketing opt-ins, and transparent cookie consent controls on our website.

Your right to access

You can access your personal data via the Driver Portal. You have the right to ask us for copies of your personal information. There are some exemptions, such as when we have to balance the rights of others, which means you may not always receive all the information we process.

Your right to rectification

You can access and update your personal data via Driver Portal. You have the right to ask us to rectify information you think is otherwise inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure

You have the right to ask us to erase your personal information in certain circumstances. After receiving the request we will delete the account so long as there are no payments due, and no outstanding contractual or legal obligations. Following account deletion, any associated personal data related to you will be anonymised.

Your right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances. This means that your data can only be used for certain things, such as legal claims or to exercise legal rights.

Your right to object to processing

You may have the right to object to processing if we are processing your information on the basis of legitimate interests.

Your right to data portability

You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you, in certain circumstances. This only applies to the information you have given us.

7. Retention

Bolt retains driver personal data for only as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data and the purposes for which we collected the data.

Booking records are retained for 12 months in line with PHV Operator license requirements.
Data necessary for accounting purposes is retained for 7 years.
In the event that there are suspicions of a criminal offence, fraud or false information having been provided, the data will be stored as long as necessary according to the internal, legal, and regulatory requirements.
In the event that your account is closed the personal data associated with your driver profile will be stored for 3 years before deletion.
Correspondence data in the Bolt app instant-messaging service is retained for 90 days, except in cases where messages are related to a reported incident in which case we will store them for 6 months, or in the event, they are related to a dispute.
In the event of disputes, the data shall be retained until the claim is satisfied or until the expiry date of such claims.

Please note that uninstalling the Bolt app on your device does not cause the deletion of your personal data. If the Bolt app has not been used for three years, we’ll get in touch and ask you to confirm whether you wish to keep your account active for future use. If no reply is received in a reasonable time, the account will be closed and personal data will be deleted unless the data’s retention is required for any other purpose mentioned earlier in this privacy notice. In the event you wish to have your account deleted, please submit a written request to customer support in the first instance at <a href="mailto:privacy@bolt.eu" rel ="nofollow">privacy@bolt.eu</a>

8. Direct marketing

We may send direct marketing messages to your e-mail address and/or phone number when you have given us permission to do so, or under a soft opt-in basis. We may personalise direct marketing messages using the information on how you use Bolt’s services, such as how frequently you use the Bolt app, and other preferences.

If you no longer wish to receive direct marketing messages, please click the "Unsubscribe" link in the footer of one of our emails, or opt-out in the profile section of the Bolt app.

9. Dispute resolution

Disputes relating to the processing of personal data are resolved through customer support in the first instance.
We have nominated a Data Protection Officer, and you can contact him at <a href="mailto:privacy@bolt.eu" rel ="nofollow">privacy@bolt.eu</a> or at our postal address. Please mark the subject line or envelope ‘UK Data Protection Officer’.
You have the right to make a complaint at any time to the supervisory authority which is the UK Information Commissioner’s Office (ICO), who can be contacted here: https://ico.org.uk/global/contact-us/ ↗

10. Making this notice great

We hope you have found this privacy notice easy to understand.

Data protection laws are important. They strengthen rules and enhance your information rights. Many of these rules may appear complicated, but most are grounded in common sense. We take our responsibilities with your data seriously. Bolt will continue to make changes to this privacy notice as part of our commitment to protecting your privacy and affording you even more transparency.