Category of personal data

Description of personal data

Profile Data

We collect personal data about you when you register to access the Bolt Platform and/or use the Bolt App including:

● Full Name

●  Email address

● Login name and password

● Phone number

● Profile photo (optional)

● Home or work address (optional)

● Saved favourite locations (optional)

● Date of birth (optional)

● Preferences and settings related to the account, such as language preferences, communication preferences and notification settings

Payment Data

We collect details of your payment methods including payment card type, bank name, bank account number, bank account sort code, related payment verification information and transaction history on the Bolt Platform. 

Identification / Verification Data

We collect identification documents including government-issued or national identity documents (such as passports, driver’s licences or national ID cards) and photographs/pictures (such as a selfie) you submit yourself.

Demographic Data

We collect demographic data such as your age and gender. 

Survey / Interview Data

We collect the content of your replies or attachments you may send us, during the course of surveys and interviews that we conduct.

Category of personal data

Description of personal data

Geolocation Data

We collect data about your precise and/or approximate geolocation (including GPS, and IP address) from your mobile device depending on your app settings and device permissions, when you open and use the Bolt App.

You may use the Bolt App without enabling collection of Geolocation Data from your mobile device. This may affect some features on the Bolt App and you may have, for example, to enter your pickup address.

App Usage Data

We collect personal data via the Bolt App about your use of the Bolt services. This includes: details of journeys (date and time, pick -up and drop-off addresses, journey distances and routes), payment history (including whether you used any coupons or promotional codes), cancellation history, dates and times you log-in and log-off the Bolt App and app features or pages viewed, browser type, app crashes and other system activity.

Communication Data

We collect communication and correspondence data when you engage with our Customer Support Team via the in-app chat function, report an incident, make a complaint, communicate via emails, web forms, or speak with our Customer Support agents, or communicate with Drivers via the Bolt App using the in-app chat function or via internet calls (where available).

We record the date and time of the communications and its content and your phone number (where you use the call feature). We will record calls, only where you are notified in advance that the call may be recorded. In the markets where we facilitate phone calls and text messages between Drivers and Passengers without sharing either party’s actual phone number with the other, we protect your personal data by using a masked numbers application.

User Generated Data

We collect personal data when you use certain features. For example to provide recordings such as audio recordings generated during the trip (as part of our safety toolkit trip audio recording feature, where such feature is, to the extent permitted by law, available - for more information, please visit https://bolt.eu/en-ee/driver/safety/), or to submit content like pictures, videos, files in connection with a Customer Support request or ratings or feedback about other users, including compliments that you have the option to give to Drivers,  when you  finish your ride, along with a 5 star review.  This also includes metadata relating to the method you use to communicate with Bolt.

Warning and Suspension Data

We collect details of warnings and suspensions that have been issued to a Passenger. This includes: the date(s) on which warnings or suspensions have been issued and the date of expiry of a warning or suspension.

Device Data

We collect data about the devices you use to access the Bolt App, including the hardware model, device IP address and other unique device identifiers (such as your UUID and advertising identifiers), device operating system, browser version, device vendor name, app version, identity of carrier and manufacturer and preferred languages.

Calendar Data

If you set your device permissions or choose to give Bolt access to your chosen calendar, we will collect information available in your calendar such as event details to use in providing you certain optional features. For example, to remind you of scheduled rides and get alerts to order a ride for your upcoming trip.

Cookies, SDKs, Analytics, and Third-Party Technologies Data

We collect information through the use of cookies, tracking pixels, data analytics tools, SDKs, and other third-party technologies like advertising IDs to understand how you navigate through the Bolt App, to make your experience safer, to improve your site and Bolt App experience, to serve you better ads on other sites (according to your marketing preferences), and to save your preferences. For more information about cookies, see our Cookie Declaration.

Category of personal data

Description of personal data

Contact Data

We collect contact data about you: when you connect to the Bolt App via a third party service such as LinkedIn, Facebook or Twitter, when another Passenger refers you through our referral campaigns or orders you a ride, or if you use the Bolt App through your employer’s Bolt Business account. This includes your:

● Full name

● Email address

● Phone number

Rider Rating Data

We collect ratings and feedback via comments about you from Drivers after each trip. Drivers are required to rate a Passenger from 1 to 5 stars, based on their trip experience and where a Driver assigns a low score to a Passenger (1-3 Stars), the Driver will be required to provide mandatory feedback for that Passenger. Your average Rider Rating is calculated based on the total sum of your ratings divided by the total number of journeys over a 365 day period and is accessible to you in the Bolt App. The rating will be linked to your account and only your average Rider Rating will be visible to Drivers in the Bolt App when they accept a journey. If we find out the rating or comment is not given in good faith, this rating or comment may not be included in the calculation of your rating.

Purpose of processing

Legal Basis

Categories of Personal

Data

To create, update and maintain your Bolt account

● Performance of a Contract

● Profile Data

● Device Data

To authenticate your account and verify your identity

We collect information to verify who you say you are and in certain circumstances to verify your age and eligibility for a Bolt account, when required by local law. If we ask you to verify your identity (either upon registration or as a result of unusual activity being detected on your Bolt account) and you are not able to verify, the Bolt services will be suspended to prevent fraud until the verification process is completed. As part of the verification process, you may be asked to submit a selfie and/or ID document to prove your identity.

● Performance of a Contract

● Compliance with Legal Obligations

● Legitimate Interests - It is in our interest and in the interest of our Drivers to prevent and address unauthorised uses of Bolt accounts and violations of our Terms and Conditions which increases Drivers’ safety.

● Consent  - Your opt-in consent will be required in order for us to proceed with biometric verification checks.

● Profile Data

● Identification / Verification Data

● Device Data

● Geolocation Data

● App Usage Data

To enable, improve and customise the transportation services and other services/features by connecting Passengers with Drivers

We help get you to where you want to go. We use Geolocation Data to navigate Passenger pick-ups and drop-offs, calculate estimated time, and track the progress of rides. We match available Drivers with Passengers based on their Geolocation Data to enable efficient pick-up and drop-off, and make the journey and route transparent.

Refusing to share Geolocation Data via the Bolt App may prevents us from fulfilling the contract with you and means we may not be able to direct a Driver to your location for pick-up.

The Passenger’s Profile Data is displayed to the Driver as part of the matching process so that they know how to locate the Passenger at their pick-up destination. Communication Data may be processed if the Driver and Passenger need to contact each other to coordinate the pick-up.

● Performance of a Contract

● Consent - we will require your consent when you use certain features of the Bolt App. For example, if you choose to upload a profile photo on the Bolt App (viewable to Driver’s during pick-up).

● Profile Data

● Geolocation Data

● App Usage Data

● Device Data

● Communication Data

To make sure that your journey goes smoothly

We use Geolocation Data to make sure you get to your destination and data on the routes taken during the journey to analyse geographic coverage. This lets us improve recommendations to Drivers about the most efficient routes and facilitate your journey in the best possible way. We also collect App Usage Data to resolve quality issues related to your use of the Bolt App.

● Legitimate Interests - It is in our legitimate interests and in the interests of our Passengers to offer you the most convenient journey.

● Geolocation Data

● App Usage Data

To make sure the Bolt App works optimally

We use your Profile Data to notify you of updates to the Bolt App so you can keep using the Bolt services. We also use Device Data and App Usage Data to ensure you can connect to the Bolt App and to help keep your account safe through authentication and verification checks.

● Performance of a Contract

● Consent - Your opt-in consent is required for the use of Cookies, SDKs, Analytics, and Third-Party Technologies Data.

● Profile Data

● Device data

● App Usage Data

● Identification / Verification data

● Cookies, SDKs, Analytics, and Third-Party Technologies Data

To suggest new rides and destinations and to schedule rides based on your upcoming events

We use your previous journey history, your saved favourite locations (such as home or work addresses) and real time Geolocation Data (even when the Bolt App is closed provided you have consented to 'enable location services in the background') to provide suggestions on new rides. You can always disable these specific notifications, without disabling all Bolt notifications.

In addition, after you schedule a ride on Bolt, we will provide an integration with your phone’s native calendar app, allowing you to add your scheduled ride to your calendar of choice seamlessly. The Bolt App will be able to detect and extract calendar events from your native calendar app and this includes retrieving event titles, start and end times, and location details. Based on your calendar events, the Bolt App will provide you with suggestions for rides that align with your calendar schedule.

● Consent - Your opt-in consent is required to use real time Geolocation Data and to allow access to your calendar.

● Legitimate Interests - It is in our legitimate interests and in the interests of our Passengers to further enrich your journey experience and suggest new features and services.

● Profile Data

● App Usage Data

● Geolocation Data

● Calendar Data

To calculate prices and process payments

We collect Payment Data to process and enable Passenger payment on behalf of Drivers and Geolocation Data to calculate prices based on the pickup and drop-off location of the Passengers taking into account distance, duration and other factors.

● Performance of a Contract

● Payment Data

● Geolocation Data

To administer the use of and payment for the Bolt services you are offered by a Bolt Business Client or another Bolt account owner

We collect your Contact Data if you use our services  through your employer who is a Bolt Business Client.

In addition, if an organisation or another Bolt account owner has ordered a ride for you using our Ride Booking service, we will collect from them your Contact Data and the pickup and drop-off location of your ride.

● Legitimate Interests - It is in our interest and in the interest of our Business Clients, Customers and Passengers to facilitate the use of our services through Bolt Business accounts and other Bolt accounts and process your personal data for the provision and payment of these services.

● Contact Data

● App Usage Data

To get your feedback on your level of satisfaction with Bolt services through surveys and interviews

These surveys and interviews are designed to understand your feedback on our services, to measure customer satisfaction and perception of safety and enable us to take actions to improve the experience. The Survey and Interview Data may be shared with research partners we use to understand your feedback.

● Consent - Your opt-in consent will be required.

●  Legitimate Interests - It is in our interest and in the interest of our Passengers to provide a satisfying passenger experience.

● Profile Data

● Demographic Data

● Survey/Interview Data

Purpose of processing

Legal Basis

Categories of Personal

Data

To provide customer support services and receive and process feedback

We process your personal data to investigate and address your queries including reported safety incidents/alleged criminal acts and complaints (including resolving disputes between Drivers and Passengers). We also use the data you share to address quality issues and to improve our services.

For safety related incidents, your Warning and Suspension Data will only be reviewed by Bolt’s Customer Support and/or Safety Teams when investigating a safety/criminal incident on the Bolt Platform involving you. The teams will also review Drivers’ reasons for issuing low-ratings to Passengers, and the circumstances surrounding potential safety incidents.

We may use automated processes for complaint resolution purposes via our automated chat function. For further information regarding how to object to the above activities, please see Section 9 “What are your rights?” below. 

● Performance of a Contract

● Legitimate Interests - It is in our interest and in the interest of our Passengers to support them throughout their use of the Bolt App and continuously  improve and develop the customer support we provide. In addition it is in our interest and interest of our Passengers and Drivers to address threats and abuse and promote safety, integrity and security on the Bolt Platform to ensure our services are used in accordance with the Terms and Conditions for Passengers.

● Compliance with Legal Obligations - We process personal data to comply with our legal obligation to cooperate with law enforcement when there is a safety incident.

● Profile Data

● Communication Data

● User Generated Data

● Warning and Suspension Data

● Rider Rating Data

Purpose of processing

Legal Basis

Categories of Personal

Data

To enable and provide safety features

We use data to ensure Bolt services are secure and have implemented a variety of safety features to enhance the safety of our Passengers, including: 

● Audio Trip Recording - enabling Passengers and Drivers to record audio if they feel unsafe during a trip and submit it to Bolt when reporting a safety incident. These recordings are encrypted and can only be listened to by Bolt, if submitted by a Passenger or Driver;

●  Rider Emergency Assist - enabling you to call the Police, the local authorities or emergency services via our Rider Emergency Assist feature. If you use this feature, Bolt’s Customer Support Team will follow up with you to check if you need any assistance;

●  Trip Safety Monitoring- enabling Bolt to send Passengers and Drivers notifications and check if you are okay or need assistance from Bolt Customer Support or the Local Authority;

● Trip Sharing enabling you to share a link with real-time journey information (email, SMS, WhatsApp, Telegram), so friends and family can follow your ride status and live location; and

●  Women for Women Category - enabling women Passengers to select a preference to only be matched with women Drivers.

● Legitimate Interests - It is in our interest and in the interests of our Passengers to enhance the safety and security of the Bolt services by offering safety functionalities as part of Bolt’s Safety Toolkit. It is also in the interests of our Passengers or Drivers to use the Audio Trip Recording feature for their own (or others) safety and to provide evidence of a safety or security incident.

● Vital Interests - We process this personal data where your vital interests require protection, such as in the case of emergencies and safety incidents, when using safety features like Rider Emergency Assist or Trip Safety Monitoring.

● Compliance with Legal Obligations - We may process this personal data to comply with legal and regulatory obligations.

● Identification / Verification Data

● Device Data

● Geolocation Data

● Profile Data

● App Usage Data

● User Generated Data

● Communication Data

To prevent, detect and investigate fraudulent accounts, fraudulent payments or other unlawful use of Bolt services and apply suspensions and blocks as needed

Our automated anti-fraud system will identify fraudulent accounts, payments and other malicious activity on the Bolt Platform, like for example when you top up your balance, start or finish a ride, or go through authentication processes. To enable us to investigate, a temporary suspension may be applied to a Bolt account when for example we detect that the Passenger is requesting a high amount of requests that are not humanly possible indicating a potential denial of service attack is taking place. 

While Bolt may use automated processes for fraud detection purposes, decisions to block a Passenger are taken following human review by our staff, and no account is blocked automatically without first undergoing a verification process. For further information regarding how to object to the above activities, please see Section 9 “What are your rights?” below.

● Legitimate Interests - It is in our interest and in the interests of our Passengers to detect, prevent and address fraud, unauthorised use of Bolt accounts or other harmful or illegal activity and maintain the safety and security of our systems, by responding to suspected or actual criminal acts. It is also in our interest and in the interests of our Passengers to prevent and address violations of our Terms and Conditions.

● Profile Data

● Identification / Verification Data

● Device Data

● Geolocation Data

● App Usage Data

● Payment Data

● Communication Data

To determine an average Rider Rating and encourage positive, safe and respectful interactions between Passengers and Drivers on the Bolt Platform, and unmatch Passengers and Drivers

In order to provide additional reassurance to Drivers and to provide a safe and accountable marketplace environment, Drivers provide you with a rating and leave feedback regarding their experience with you after each ride.

The Rider Ratings feature empowers Drivers to make informed decisions about accepting or declining ride requests and exercise greater control over their working environment, as they can assess the average Rider Rating of a Passenger based on ratings provided by other Drivers before they accept a ride.

For further information about your Rider Rating, the behavioural guidelines to follow and guidance how to improve your rating, please read these FAQs: https://bolt.eu/en/rider-rating/ and https://bolt.eu/en/blog/new-bolt-app-features/.

In addition, both the Passenger and the Driver have the option to unmatch from each other if either party rates the other with a 1-star rating after a journey. To initiate this, the party giving the 1-star rating can select the 'Block Future Requests' button. Once this option is chosen, the Passenger and Driver won't be matched again for future journeys. Despite this, the Passenger retains the ability to request rides with other Drivers. The unmatching will be in place until either the Passenger’s or the Driver’s account is deleted.

● Legitimate Interests - It is in our interest and in the interest of our Passengers and Drivers to enhance quality, safety and trust within the Bolt Platform. To encourage positive and respectful interactions between Passengers and Drivers on the platform and provide a safe, hassle-free and pleasant environment and experience. It is also in our interest to ensure and to enforce our services are used in accordance with the Terms and Conditions for Passengers and the Marketplace Conduct Guidelines.

● Rider Rating Data

● Profile Data

To issue warnings and temporary suspensions when the average Rider Rating drops below a specified threshold (where this feature is available)

To balance the interests of Passengers and Drivers, if the average Rider Rating drops below a certain threshold (which differs per country), an automatic warning will be issued.  If the average Rider Rating is not improved within 90 days following a warning, a 6-month temporary suspension will be issued. This will be based on an automated decision but does not produce legal or similarly significant effects. For information regarding how to object to this activity, please see Section 9 “What are your rights?” below.

You will get temporality suspended only if you appear (based on your average Rider Rating) to repeatedly:

● violate the Terms and Conditions for Passengers and Marketplace Conduct Guidelines for Riders; and

● have a negative impact on Drivers' interests and the integrity of the Bolt Platform as a whole.

The suspension only limits your ability to order a ride, and does not limit your access to the rest of the Bolt App, or to any other of our services.

● Legitimate Interests (for warnings) - It is in our interest and in the interest of Drivers for Bolt to automatically send a warning notice to ensure a reliable and trustworthy service and Platform sustainability, along with Drivers empowerment. It is also in our interest to ensure and to enforce our services are used in accordance with the Terms and Conditions for Passengers and the Marketplace Conduct Guidelines.

● Performance of a Contract (for suspensions)

● Profile Data 

● Rider Rating Data

● Warning and Suspension Data

● User Generated Data

Purpose of processing

Legal Basis

Categories of Personal

Data

To market and advertise Bolt services and those of partners according to your preferences and measure the effectiveness of Bolt’s ads

This includes using your personal data to send emails, text messages (including WhatsApp messages), push notifications, in-app messages and other communications marketing Bolt’s products, services, features, offers, promotions, sweepstakes, news and events of Bolt and our partners. In addition, we will analyse, aggregate your App Usage Data and provide it to you in a summarised way each year for the wrap-up marketing campaign connected to the End of Year campaign.

We use pixels and similar technologies to track which emails are opened and which links are clicked by you, to help us measure the results of our campaigns. We may also share your personal data with third parties, or collect data regarding your visits and actions on third-party apps or websites, for the purposes of personalised ads.

● Legitimate Interests - It is in our interest and in the interest of our Passengers to inform them about our services and features or those offered by Bolt partners. It is also in our interest to promote and advertise our services, including engaging in contextual (non-data driven) and personalised advertising, analytics, and measurement of ad performance, in order  to expand our user base by deepening relationships with existing Passengers  and developing new ones. You can opt out of these communications at any time by clicking the 'unsubscribe' link at the bottom of our emails, typing “STOP” for messages and SMS, or updating your communication preferences in your account settings.

● Consent - Your opt-in consent will be required for example, when the law requires consent for email marketing and for certain tracking technologies.

● Contact Data

● AppUsage Data

● Device Data

● Cookies, SDKs, Analytics, and Third-Party Technologies Data

Purpose of processing

Legal Basis

Categories of Personal

Data

To communicate with you, including sending you service-related communications and to keep you informed

Your name, phone number and email address will be used to communicate with you to let you know that your journey has been completed, to send you trip confirmation emails and receipts, and to let you know about important service updates.

● Performance of a Contract

● Profile Data

Purpose of processing

Legal Basis

Categories of Personal

Data

To perform research, testing, and analytics to better understand and improve our business and services

For example, we use Geolocation Data and App Usage Data to perform research and improve our algorithms, machine learning, and other modelling. We use Communication Data related to incidents to monitor our security practices and improve our operations and processes.

● Legitimate Interests - It is in our interest to measure the use of our services in order to inform business decisions and to enable provision of accurate and reliable reporting and to continuously improve and develop the services we provide.

● Consent - For certain analytics we may require your consent. If so, you'll be prompted to provide consent for specific purposes and processing activities, with details on how to withdraw consent, including through your profile settings.

● Geolocation Data

● App Usage Data

● Communication Data

● User Generated Content

● Device Data

To develop new products, features, partnerships and services

● Legitimate Interests - It is in our interest and in the interest of our Passengers to develop and adopt new features to improve the Bolt Platform.

● Profile Data

● Geolocation Data

● App Usage Data

● Communication Data

● User Generated Content

● Device Data

To prevent, find, and resolve software or hardware bugs and issues

● Legitimate Interests - It is in our interest and in the interest of our Passengers to provide a hassle free and reliable service.

● Profile Data

● Geolocation Data

● User Generated Content

● Communication Data

● Device Data

● App Usage Data

Purpose of processing

Legal Basis

Categories of Personal

Data

To investigate and respond to claims and disputes relating to the use of Bolt services, and/or necessary for compliance with applicable legal requirements or with requests from government/law enforcement bodies

Depending on the claim, All Data may be processed for establishing, exercising or defending legal claims, including:

● supporting external and our own internal investigations;

● the assignment of claims and the use of debt collecting agencies; and

● the use of legal advisors.

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 also respond to requests, such as those from law enforcement agencies, when the response is required by law or furthers a public interest task such as an emergency situation or where someone’s life is at risk. We will take steps to ensure that we have a lawful basis on which to share the information, and we’ll make sure that we document our decision.

● Compliance with Legal Obligations - We process personal data to comply with an obligation, when there is a request from a regulator, law enforcement or other governmental body.

● Legitimate Interests - In the context of litigation or other disputes, it is in our interest to protect our interests and rights,  our Passengers or others, including as part of investigations,  regulatory inquiries or litigation.

● All Data

To fulfil our tax obligations and comply with tax legislation

● Compliance with a Legal Obligation

● Profile Data

● Payment Data

● App Usage Data

To reorganise or make changes to our business

● Legitimate Interests - It is in our interest to process personal data for organisational and business planning purposes.

● All Data

To ensure the security of the Bolt services (including the Bolt Platform and Bolt App)

Depending on the issue, All Data may be used for technical and cyber security reasons: for example measures for combating piracy and ensuring the security of the service, website, Bolt Platform and App as well as for making and storing back-up copies and preventing/repairing technical issues.

● Legitimate Interests - It is in our interest and in the interest of our Passengers to protect, guard and maintain Bolt’s security systems, respond to suspected or actual criminal acts and repair any technical issues.

● All Data

Category of Recipients

Description

Bolt Group Companies and partners

We may share your personal data with our Bolt Group Companies (including Bolt local subsidiaries), third party partners, their affiliates and representatives, who may use your personal data in the manner described in this Notice. If Bolt local subsidiaries are responsible for processing your personal data, they may share your personal data with Bolt Operations OU as the main data controller for Bolt.

Drivers

Your personal data is only disclosed to the Drivers (whether acting on their own behalf as an independent service provider, or acting on behalf of another service provider (for example, acting on behalf of a fleet or another individual)) when you engage with a ride in the Bolt App; in such a case, the Driver will see your name, phone number (in many countries the number is masked), pickup, destination and geolocation data. Once the ride is finished, we also share ratings and feedback with the Driver. (We remove your identity associated with ratings and feedback when we share it with Drivers). After providing the transportation service, your name and the telephone number will remain visible to the Driver for 24-48 hours. This is necessary for Drivers to resolve any issues with you like getting something special back to you which might have been left in the car. Depending on your location, and if our audio recording safety feature is available, we may also share an audio recording initiated by a Driver with the Driver or law enforcement authorities.

Bolt Business Clients or other Passengers

Some rides you take may be requested or paid for by others. If you take one of those rides using the Bolt Business Profile account of your employer, a code or coupon, a corporate credit card linked to another account, or another user or entity otherwise requests or pays a ride for you, we may share your ride details with that other party, including your name, phone number, the date, time, charge, rating given, region of trip, and pick up and drop off locations of your ride. The data shared with Bolt Business Clients will be disclosed via reports they can access on their Business Accounts. Processing of personal data will occur under the same conditions as established in this Notice.

Referrers

If you refer someone to the Bolt App, we will let them know that you generated the referral. If another user referred you, we may share information about your use of the Platform with that user. For example, a referral source may receive a bonus when you join the Bolt App or complete a certain number of rides and would receive such information.

Promotional, marketing and strategic partners

We may share limited data like your email address with our promotional, marketing and strategic partners so that they can inform you about promotional events and provide you with information and marketing messages about products or services that may interest you.

In addition, we may share your personal data with marketing platform providers, including social media advertising services, advertising networks, third-party data providers, to reach or better understand our users and measure the effectiveness of our ads on other platforms and with social media platforms, including Facebook and Google, for sign-in purposes.

Third-party service providers

Our third-party vendors and other service providers and contractors have access to your personal data to help carry out the services they are performing for us or on behalf of us. This may include vendors and providers who provide email or moreover electronic communication services, tax, legal and accounting services, product fulfilment, background checks and identity/verification processes, payment processing, customer support, fraud prevention and detection, data enhancement, web hosting and cloud storage, research, including surveys, analytics, crash reporting, performance monitoring and artificial intelligence, machine learning and statistical services. In addition, we will share data like your geolocation and the journey routes with Google in connection with the use of Google maps in our apps.

Insurers

We will share your data with insurers, where you, or a family member in your absence, request for a claim to be processed, for the purposes of facilitating the processing of insurance claims and for reporting purposes due to contractual requirements from the insurers.

Other third parties

In the event of a likely change of control of the business (or a part of the business) such as negotiations for a sale, an actual sell, a merger, and acquisition, or any transaction, or reorganisation, we may share your personal data with interested parties, including as part of any due diligence process with new or prospective business owners and their respective professional advisers. We may also need to transfer your personal data to that third party or re-organised entity after the sale or reorganisation for them to use for the same purposes as set out in this Notice.

Law Enforcement

We may disclose information under a court order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. For example, we may also share your personal data with law enforcement or other public authorities, including responding to requests when the information is required by law or furthers a public interest task. In any

scenario, we will take steps to ensure that we have a lawful basis on which to share the information, and we’ll make sure that we document our decision.

Retention Periods Criteria

Description

Personal data retained until you remove/delete it

It's your right to request that we delete certain of your personal data. See Section 9 “What are your rights?” below for more information.

Personal data that expires after a specific period of time

We have set certain retention periods so that some data is not retained after a specific period of time. See table below for further details.

After a retention period has lapsed, the personal data is securely deleted, unless it is necessary for the establishment, exercise or defence of legal claims.

Personal data retained until your Bolt account is deleted

We keep your data until your Bolt account is deleted unless further retention of certain personal data are required for the purposes described in the second table below.

Category of Retention Periods

Description

Tax, accounting and financial reporting purposes 

We retain data for 10 years after the last journey if your personal data is necessary for tax, accounting and financial reporting purposes.

Provision of services purposes

We retain your data as long as you have an active passenger account. If your account is closed, personal data will be deleted (according to our retention schedule and rules), unless such data is still required to meet any legal obligation, or for accounting, dispute resolution or fraud prevention purposes.

You may request deletion of your account at any time through the Bolt App. See Section 9 “What are your rights?” below for more information.

Formal investigations of a criminal offence, fraud or false information

We retain data for as long as necessary according to the internal, legal, and regulatory requirements, in the event that there are formal investigations of a criminal offence, fraud or false information having been provided.

Disputes

We retain data in the event of disputes, until the claim is satisfied or the expiry date of such claims.

Complaints

We retain a record of all complaints which we make available to an authorised officer of the licensing authority on request in the case of an investigation for 24 months.

Instant Messages

We retain data about instant messages between you and the Customer Support Team directly in the Bolt App for 90 days, except in cases where messages are related to a reported incident or in the event, they are related to a dispute, in which cases we will store them for 6 months. Instant messages between Passengers and Drivers are kept in the Bolt App only until the order is completed and for 3 months after in our systems.

Audio Trip Recording

We retain Audio Recording Data through our Audio Trip Recording Feature:

24 hours, while stored locally on the device of the person who generates the recording. The recordings are automatically deleted after 24 hours if a report to Bolt’s Customer Support team is not created and the recording is not explicitly shared with Bolt’s Customer Support team as part of the report.

Recordings shared and investigated by Bolt will be automatically deleted after 7 days unless the retention period is manually extended for investigation/legal reasons under the applicable law.

Customer Support

We retain data in relation to support tickets, phone calls and chats for 3 years.

Rider Ratings

We retain Rider Rating Data for:

● 3 years for specific ratings and comments

● for the duration of Passenger or Driver account for the unmatching status

Country

Disclosures

Alternative Legal Bases

New Zealand

●Legal Bases: Bolt adheres to the Information Privacy Principles of the Privacy Act 2020 by ensuring that it collects and processes your data using lawful means as set out in this Notice or as otherwise permitted under that Act. Where applicable, Bolt may rely on an alternative legal basis to collect and process your personal data.

●Mandatory Provision of Personal Data: Provision of your personal data may be mandatory for Bolt to provide its services in order to comply with applicable laws, including the Land Transport Act 1998 and any land transport rules that are given effect by that Act. To the extent that the provision of your personal data is required for Bolt to provide its services, if you do not provide such personal data, you will not be able to use the ride-hailing services available on the Bolt App.

●Marketing communications: As a valued user of our services, you may occasionally receive updates about special offers and promotions related to Bolt. We send these communications where you have an existing relationship with us and only where the communications are relevant to and relate to the Bolt services you are using. You have full control over these communications and can unsubscribe at any time by clicking the “unsubscribe” link at the bottom of our emails, replying “STOP” to SMS messages, or updating your communication preferences in your account settings.

● International data transfers: Bolt NZ believes, based on reasonable grounds, that the overseas recipients are subject to privacy laws that, overall, provide comparable safeguards to those in the Privacy Act.

●Enquiries and Complaints: you may contact Bolt’s Data Protection Officer (Privacy Officer) by sending an email to privacy@bolt.eu. Our supervisory authority in New Zealand jurisdiction is the New Zealand Privacy Commissioner https://www.privacy.org.nz/ ↗ (https://www.privacy.org.nz/).

Consent (where legally permitted to do so).