Bolt Technology OÜ (hereinafter: “Bolt Head Office”)
Registered seat: Vana-Lõuna tn 15, Tallinn Harjumaa 10135, Estonia
E-mail: privacy@bolt.eu
Website: https://bolt.eu
Bolt AMW GmbH (hereinafter: “Bolt Austria”)
Registered seat: Hohlweggasse 30, Top/Tür Nr. GL2H1030 Vienna, Austria
E-mail: vienna@bolt.eu
Website: https://bolt.eu
The contact details of the data protection officer of Bolt Head Office: privacy@bolt.eu.
Bolt Head Office developed the Bolt application ("Bolt app"), while Bolt Austria provides Bolt Services in the Austrian territory. Bolt Head Office established the data processing conditions and is in charge of operating the IT infrastructure supporting the Bolt app, while Bolt Austria offers Bolt services locally.
For most of the data processing activities related to the Bolt Services, the data controllers under the General Data Protection Regulation (EU) 2016/679 ("GDPR") are Bolt Head Office and Bolt Austria, save where indicated otherwise in this privacy notice (the “Privacy Notice”).
Bolt Austria - as the entity in charge of offering Bolt Services in Austria - may be deemed as the (sole) data controller under GDPR for certain of the data processing activities indicated in the present Privacy Notice, in compliance with applicable legislation.
1. Personal data we process
Name, e-mail, phone number, place of residence.
Geolocation of drivers and driving routes (including geolocation of the device which is used by the Driver).
Information about vehicles (including registration number).
Driver’s efficiency and ratings.
Driver’s license, photo, profession and identity documents.
Information about disputes/complaints.
The financial data of providing transportation services is not considered as personal data, because drivers provide services in the course of economic and professional activities.
2. Purposes of the data processing
We collect and process personal data for the purpose of connecting passengers with Fleet Partners for their respective Drivers to enable them to provide transportation services more effectively.
Geolocation and driving routes are processed to analyse the geographical area and give suggestions to the drivers. If you do not want to disclose your geolocation for passengers, you must close the Bolt app or indicate in the Bolt app that you are offline and currently are not providing transportation services.
Driver’s license, profession and identity documents are processed to determine the compliance with the legal requirements and the suitability of pursuing a profession as a driver.
Bolt app displays driver’s photo, name and vehicle details for the passengers to identify driver and vehicle.
You will receive summaries from the Bolt Driver Portal, which will include your efficiency and ratings as a driver. Summary and ratings about driver are necessary to provide a reliable services for passengers.
We may use geolocation data to resolve quality issues related to transportation services.
We may use your contact details to notify you of updates to the Bolt app.
In case you lodge a complaint through the Bolt app or otherwise, we process the latter and run an investigation.
Bolt Head Office, acting as a data processor, processes and stores data in connection with the bookings and the provision of the transportation service.
Bolt Austria may use these data in case it is necessary in connection with the inspection by the local competent Authorities. The legal basis of the data processing is the compliance with a legal obligation of Bolt Austria.
Bolt Austria shall carry out investigations in connection with your complaints and upon completion, store all relevant results. The legal basis for this data processing is the compliance with a legal obligation by Bolt Austria. Although, the storage of personal data is executed on the IT systems operated by Bolt Head Office, Bolt Austria shall store the complaints and the relevant investigations’ results for the duration of ten (10) years.
The Austrian Authorities, in case of an investigation or audit, are entitled to request personal data from Bolt Austria in written form and Bolt Austria shall comply with such requests.
3. Legal basis
Personal data is processed for the performance of the contract concluded with the Fleet Partner / Driver. The prerequisite for the use of the Bolt services is (i) installing the Bolt app, (ii) allowing for the use of geolocation data within your device and (iii) agreeing to the processing of identification and geolocation data.
Personal data may be processed on the ground of Bolt Head Office's and Bolt Austria’s legitimate interest in investigating and detecting fraudulent payments.
4. Recipients of the personal data
Your personal data is only disclosed to passengers, whose order has been accepted by your employer / contractor (cf. Fleet Partner) for the purpose of you carrying on the transportation service; to Passengers whose orders have been fulfilled and that may have forgotten any of their belongings in the vehicle or to resolve a dispute between said passengers and the respective driver.
Passengers will see driver’s name, vehicle, phone number, photo and geolocation data. Passengers also see driver’s personal data in the receipt.
Depending on the location of the driver, the personal data may be disclosed to Bolt Head Office and its local subsidiaries, representatives, affiliates, agents etc). Processing of personal data by will occur under the same conditions as established in this privacy policy.
5. Security and access
Any personal data collected in the course of providing 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 territories of a Member States of the European Union. The contractual partners of Bolt Head Office undertake backups regularly and as may be required and, if it is necessary, participate in the restoration of the database.
Only authorised employees of Bolt Austria, Bolt Technology 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).
Bolt Technology group companies and partners can access personal data to the extent necessary to provide customer support in the respective country, see more https://bolt.eu/cities/.
For research and scientific purposes, the data is used in unidentified form (anonymized).
6. Processing passengers personal data
You may not process the personal data of passengers without our permission. You may not contact any passenger or collect, record, store, grant access, use or cross-use the personal data provided by the passenger or accessible to you via the Bolt app for any reason other than for the purposes of fulfilling the transportation services.
You must comply with the rules and conditions for processing of personal data of passengers as set forth in the Privacy Policy for Passengers (http://www.bolt.eu/legal/). If you violate the requirements for the processing of personal data of passengers, we may terminate your drivers account and claim damages from you.
7. Access, correction, retention, deletion and data portability
Personal data can be accessed and corrected in Bolt Driver Portal.
Your personal data will be stored by Bolt Head Office as long as you have an active driver's account. If your account is closed the personal data will be stored for an additional 3 year period, unless such data is required to be retained for accounting, dispute resolution or fraud prevention purposes.
Data necessary for accounting purposes shall be stored for 7 years after the last journey.
In the event of suspicions of a administrational or criminal offence, fraud or false information, the data shall be stored by Bolt Head Office for 10 years in order to hinder the renewed registration of the person who acted unlawfully.
In the event of disputes, the data shall be retained until the dispute has been resolved or until the statute of limitation of the claim has elapsed (in principle for 10 years).
We will respond to any request for transfer of personal data submitted by e-mail and proceed with the data transfer within a month. Such a deadline may be extended for good cause.
We may retain certain personal data as may be required by law and for legitimate business purposes permitted by law.
Please note that the deinstallation of Bolt app in your device does not cause the deletion of your personal data.
If the Bolt app has not been used for 3 years, you will be notified and asked whether the 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.
You can request information related to your personal data, in which case we will provide information in connection with the categories of personal data concerned, the purposes of the processing, the period for which the personal data is stored, your rights related to data processing and your rights to lodge a complaint with the supervisory Authority in charge (hereinafter: “Authority”). In case you believe that your rights have been violated by Bolt Austria you may lodge a complaint with the Austrian competent Authorities; if you believe that your rights have been violated by Bolt Head Office the Authority is the Estonian Data Protection Inspectorate.
You are entitled to request the restriction of the processing of your personal data according to Article 18 of GDPR, also where we no longer need your personal data for the purpose of processing, but they are required by you for the establishment, exercise or defence of legal claims.
8. Dispute resolution and remedies
Disputes relating to the processing of personal data are resolved through customer support (vienna@bolt.eu) or by contacting Bolt Head Office’s Data Protection Officer (privacy@bolt.eu).
In case you believe that the data processing is unlawful, you are entitled to start the procedure before the Austrian competent Authority (Austrian data protection authority: Österreichischen Datenschutzbehörde; Postal address: Barichgasse 40-42 , 1030 Wien; e-mail address:dsb@dsb.gv.at) and initiate judicial proceedings or before the Estonian Data Protection Inspectorate (www.aki.ee) which can be contacted by email: info@aki.ee.