Hopp Operations Limited trading as “Bolt” (a company registered in the United Kingdom, with company number 11063356) 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 39/1, 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 39/1, Tallinn 10134, Estonia), together, “Bolt” or “we” set out below how we use your personal data. Bolt collects and processes personal data of: (i) passengers in the course of installation and use of the Bolt app; and (ii) drivers in the course of installation and use of the Bolt driver app, and in their registration and on-boarding and provision of services; in accordance with the relevant terms of use.

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;
• 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;
• Cookies of the https://bolt.eu website save the website user’s telephone number and geographic location data; and
• Details of app support queries you make including record of any reported lost items.

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 for 10 years. In case of payment disputes, data will be retained until the claim is satisfied or the expiry date of such claims.

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

WHAT TYPE OF PERSONAL DATA OF PHV DRIVERS WE COLLECT AND PROCESS

Personal data is processed for the performance of the contract concluded with the driver.

We collect the following types of personal data:

• Name, telephone number, email address and banking or financial information;
• Geographical locations when drivers are logged into the app;
• Username and password for the app;
• Information collected from third parties about you in order to verify any information you supplied to Bolt during registration;
• Details of journeys and feedback ratings and duration of provision of journeys on each day;
• Fare estimates, actual fares and payments made to drivers;
• Text, images, and other user content you provide;
• If we withdraw your right to use the service, issue a warning a record of that withdrawal or warning;
• Identification data of the device on which the relevant Bolt app has been installed
• Cookies of the Bolt.eu website save the website user’s telephone number and geographic location data;
• Details of app support queries you make;
• Passenger complaints including lost property;
• Information about your driving licence, your vehicle and your insurance;
• Background checks information in accordance with local licensing requirements, which may include medical certificates, topographical test certificates and English language test certificates;
• Data regarding criminal convictions and offences is processed for compliance with legal obligation;
• Data may be processed on the ground of legitimate interest in investigation and detecting fraudulent payments; and
• Record of any requests for your information made by law enforcement.

We collect and process personal data of drivers to ensure regulatory compliance, for verifying the driver’s qualifications for pursuing this professional activity and safeguarding the contractual relations associated with the Bolt app service, including resolving any driver service quality issues and monitoring your compliance on an ongoing basis.

Bolt’s operations team can see the geographic location of a driver, information on dispatches and the times of using the service. If a driver would like for his or her geographic location not to be visible to the dispatch operator, he or she can disable the app by tapping the “Quit” button.

DRIVER PERSONAL DATA RETENTION

Personal data can be viewed and corrected in Bolt Driver Portal. Your personal data will be stored as long as you have an active driver's account. This follows that:

• Booking records will be retained for 12 months as per the PHV Operator license requirements.
• If your account will be closed the personal data will be stored for additional 3 year period.
• Data necessary for accounting purposes shall be stored for 7 years.
• In the event of suspicions of a administrational or criminal offence, fraud or false information, the data shall be stored for 10 years.
• In the event of disputes, the data shall be retained until the claim is satisfied or the expiry date of such claims.

We respond to the request for deleting and transferring personal data submitted by an email within a month and specify the period of data deletion and transfer.

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 finding and allocating 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 allocated, we also collect your telephone number in order for a driver to be able to contact the passenger after the driver has accepted the journey;
• We may use the personal data provided to resolve driver 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;
• The personal data collected via the Bolt app will be used for identification of passengers and their location(s) to drivers;
• 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;
• Data may be processed on the ground of legitimate interest in investigation and detecting fraudulent payments; and
• 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.

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 and/or driver’s name(s)
• date of birth (if available)
• contact number
• home address (if available)
• trip details including ie. start and finish time, pickup and drop off point
• details of the complaint made by the rider, 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 accepted 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 providing the service, 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 service provision, 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 will 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 driver verification checks providers. 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 via a service called Zendesk. 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 london@bolt.eu After receiving the request we will delete the account if there are no any 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 london@bolt.eu. Please be aware that Bolt may charge you a small fee of £10 for any such service.

QUESTIONS AND UPDATES

Personal data can be viewed and corrected in the Bolt App for Passengers or the Driver Portal. If you have any disputes, questions or concerns about this privacy statement or your personal data, please contact us at london@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 policy was last updated on 31 May 2019. Any changes we may make to this privacy policy 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 policy.