Last updated on: 1 AUGUST 2022

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. Bolt collects and processes personal data of: passengers in the course of their installation and use of the Bolt app in accordance with the relevant terms of use.

The term “driver” in this Privacy Notice refers to an individual that has applied to act as an individual providing driver services via the Bolt platform (including an individual that has applied to fulfill journeys in association with another driver’s account).

The processing of geographical location data is necessary for use of the Bolt app.

WHAT TYPES OF PASSENGER PERSONAL DATA WE COLLECT AND PROCESS

Personal data is processed in order to provide the service contracted with passengers. Bolt collects data about you which may include:

• Name, telephone number, e-mail address, as collected during installation of the app;
• Where you access and use the app from;
• Where you register for an account, your user ID and password;
• Where you choose to connect to the service from a third party service, such as LinkedIn, Facebook or Twitter, your information from that service;
• Feedback ratings (including information provided to resolve disputes), payment information and payment history;
• Information regarding your booking requests, including geographical location of the user, the time of provision of service, details of the route and destination; estimates of fares for your journey and price paid;
• Data about the usage of the transportation services: things like data about journey status, times and data about your conduct as assessed by drivers;
• Text, images and other user content you provide;
• If we ban or suspend you from use of the service, a record of that ban or suspension;
• Identification data of the device on which the relevant Bolt app has been installed;
• Details of app support queries you make including record of any reported lost items;
• Data related to communication through instant messages directly in the Bolt app ("Chat with Driver" option): date and time of the communication and its content.

PASSENGER PERSONAL DATA RETENTION

Your personal data will be stored as long as you have an active passenger account. If your account is closed, personal data will be deleted (according to the policies set out in this section) from the databases, unless such data is required to be retained for accounting, dispute resolution or fraud prevention purposes. This follows that:

• Booking records will be retained for 12 months as per the PHV Operator license requirements.
• Journey history data will be stored for 3 years, after which the data will be anonymized.
• Data required for accounting purposes will be stored for 7 years after the last journey.
• Financial data regarding transportation services provided to passengers will be stored for 3 years after the last journey.
• If the Bolt app has not been used for 3 years, we will notify you and ask you to confirm whether account is still active. If no reply is received, the account will be closed and personal data will be deleted unless such data is required to be stored for accounting, dispute resolution or fraud prevention purposes.
• 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 case of payment disputes, data will be retained until the claim is satisfied or the expiry date of such claims;
• The retention period for the data about instant messages directly in the Bolt app messages is 90 days, except cases where messages are related to a reported incident - in which case we will store them for 6 month..

Please note that the deinstallation of Bolt app in your device does not cause the deletion of your personal data.

HOW AND WHY WE USE THIS PERSONAL DATA

Bolt collects and uses personal data for purposes of providing the Bolt apps and for ensuring the safety of passengers and drivers. This includes the following:

• We collect and process personal data for the purpose of accepting your journey request and offer a driver to fulfil your journey request;
• We forward the data on geographic location of the passenger to drivers to enable them to decide whether to fulfil the passenger’s requested journey and once the journey has been confirmed, we also collect your telephone number in order for a driver to be able to contact the passenger after the driver has confirmed the journey;
• We may use the personal data provided to resolve service quality issues or to improve our apps or for reasons related to security including but not limited to complying with law enforcement information requests when applicable;
• We use contact details to notify you of updates to the Bolt app;
• If you have consented, we may contact you with promotional messages regarding the Bolt app;
• We collect data of the routes taken by the Bolt app users to analyse the geographic coverage in order to make recommendations to the drivers;
• Personal data related to instant messages directly in the Bolt app are processed in order to provide service and customer support (including resolving disputes between driver and passenger), for security purposes as well as to improve our products and services, and for analysis.
• We will hold and process your personal data for at least the time during which your account is activated and then in accordance with our legal obligations;
• We collect data about journey statuses, time and passenger ratings from driver 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.
• Data may be processed on the ground of legitimate interest in investigation detecting and preventing fraud and other malicious activities
• Record of any requests for your information made by law enforcement.

Personal data is processed in order to provide the service contracted with passengers. We collect and processes the personal data submitted by the passengers in the course of installation and use of the Bolt app. The prerequisite for the use of Bolt services is passengers agreeing to the processing of identification and geolocation data.

DIRECT MARKETING TO USERS

We only use your email address and phone number for sharing our product related marketing messages if you have given your consent on the bolt.eu website or in the Bolt app. If you no longer wish to receive direct marketing messages, please click the “Unsubscribe from direct marketing messages” link in the header of our e-mail or Profile section of Bolt mobile App.

AUTOMATED DECISION MAKING: PASSENGERS

We use help of automated decision-making in case of issuing warnings and implementing service suspension. Using automated decision-making is less error-prone, more efficient and safer than using our employees. Data about your usage of the transportation services (data about journey status incl. cancellations and no-shows and data about your conduct as assessed by drivers) is considered when assessing the need for a warning or suspension. You can read more about automated decision-making here. Suspension will stay in force for 6 months, after which access to service will be restored.

You will always have the right for human review of the decision and to contest the decision, express your point of view and obtain an explanation by contacting our customer support in our app.

DISCLOSURE OF PERSONAL DATA TO LAW ENFORCEMENT

Bolt is committed to ensuring the safety of all passengers and drivers using our service. We take all reports of misconduct seriously and we reserve the right, at our discretion, to volunteer information to law enforcement when we feel is necessary.

If we are made aware that law enforcement requires information about your personal data for a criminal investigation we will comply, to the extent that their request is reasonable and we are able to supply such information.

Personal data that we may provide includes:

• passenger’s name(s)
• date of birth (if available)
• contact number
• home address (if available)
• journey details including ie. start and finish time, pickup and drop off point
• details of the complaint made by the passenger, driver, or applicable third party

Bolt may, at our discretion, provide you with notice that we have provided law enforcement with your personal data.

We reserve the right to proactively initiate police reports if we become aware of action or behaviour that may constitute a threat to safety or criminal concern.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

The personal data of users is only disclosed to those drivers who have activated the Bolt app; in such case, they will see the first name and geographic location of the user. The driver will be able to contact the user once they have confirmed the journey, however they will not be able to view the users phone number as we use a process called number masking to keep the users contact information hidden;

After the journey, the name of the user will remain visible to the driver for 24 hours. This is necessary for drivers to resolve any issues associated with the journey, e.g., to contact the customer through selecting to do so in app if something was left behind in the car. At no point will the phone number of a passenger be disclosed to a driver without the passenger’s consent;

Any feedback on the quality of the service is anonymous and drivers do not receive information on the names and telephone numbers of the users who provided feedback;

Bolt may disclose personal data to our third party service providers, who may be located in countries outside of the EEA, subject to contracts with those third parties. These may include IT or payment services providers or verification and authentication checks providers , NextWealth Inc., Telecom Service Centres Limited and Amazon Web Services, Inc.). Our payment provider, Adyen, is fully PCI DSS 3.2 compliant as a Level 1 Service Provider;

We may also share personal data with local licensing bodies, law enforcement, for legal reasons or if there is a change in ownership if our business or assets.

YOUR RIGHTS AND DELETION OF DATA

Any personal data collected in the course of providing services is transferred to and stored in the data centres provided by, inter alia, Zone Media LTD and/or Amazon Web Services Inc. which are located in the territories of a Member States of the European Union. Only authorised employees of Bolt group companies and partners ​have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation services).

If you would like to delete the personal data collected by us, please submit a written request to our customer support via privacy@bolt.eu After receiving the request we will delete the account if there are no outstanding payments or as required for legal reasons. After account deletion the associated personal data will be anonymized.

Please note that the deinstallation of the Bolt app in your device does not cause the deletion of your personal data. If you want to delete your personal data collected by Bolt, please send a written request by email as indicated above. You should also bear in mind that the request to delete personal data is possible only if we delete your account and always subject to our legal requirements to retain any personal data. As a result of that you will not be able to use Bolt services under your existing account. We respond to the request for deleting and transferring of personal data submitted by an e-mail within a month and specify the period of data deletion and transfer.

If you wish to access or correct your personal data or have any other concerns about the processing of your personal data by Bolt, please contact us privacy@bolt.eu.

QUESTIONS AND UPDATES

Personal data can be viewed and corrected in the Bolt App. If you have any disputes, questions or concerns about this privacy statement or your personal data, please contact us at privacy@bolt.eu.

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/

This privacy notice was last updated on 1 August 2022. Any changes we may make to this privacy notice in the future will be posted on this page and, where appropriate, notified by email. Please check back regularly to keep informed of updates or changes to this privacy notice.