Global Privacy Notice for Bolt Rent

Category of Personal Data

Description of Personal Data

Personal Data provided by you to Bolt

Profile Data

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

• Name
• Email address
• Phone number
• Profile photo (optional)
• Home or work address
• Saved favourite locations
• Date of birth
• Preferences and settings related to the account, such as language preferences, communication preferences and notification settings, and privacy 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, including the amount paid, on the Bolt Platform.  

Identification / Verification Data

We collect identification documents including government-issued or national identity documents (such as passports, driver’s licences, international driver’s license 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.

Personal Data we collect about you when you use the Bolt App

App Usage Data

We collect personal data via the Bolt App about your use of the Bolt App. This includes: rental booking history (date and time, vehicle pick up/return locations, vehicle type, Fleet Owner chosen, rental booking price and currency), rental booking history (including rental booking status, 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.

Location Data

We collect location data that you provide when using the Bolt App, such as your selected pick-up and drop-off locations for rental services. This information is used to facilitate your booking and provide the requested services.

In limited cases, approximate or precise location data (such as coordinates) collected at a specific point in time during identity verification processes, for the purpose of fraud prevention and account security.

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 (including any accident, crash, damage, personal injury, stolen or lost hire-vehicle), communicate via emails, web forms, or speak with our Customer Support agents.

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.

User Generated Data

We collect personal data when you submit any other content like pictures, videos, files in connection with a customer support request. 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 User. 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.

Cookies, SDKs, Analytics, and Third-Party Technologies

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.

Personal Data we collect about you from other sources

Contact Data

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

• Full name
• Email address
• Phone number

Fines and Violations Data

We collect information about violations, traffic fines, parking fines, toll roads and other incidents from the Fleet Owners.

For the provision of the Bolt services

To create, update and maintain your Bolt account

We  will collect and process personal data provided by you when you install and use the Bolt App.

If you choose not to provide us with personal data, this may prevent us from performing our contract with you or from carrying out our legal obligations.

It may also mean that we cannot manage your 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.

To verify your identity quickly and securely, we use facial recognition technology to confirm that your selfie shows a clear face and matches the face on your identity document. This involves processing your facial measurements.

Your biometric data may be shared with trusted verification providers to confirm your identity. If you prefer not to use facial recognition technology, you can opt for your identity to be manually verified by a member of our team, though this may take longer. You can withdraw consent at any time by contacting our Customer Support.

We retain your selfie and identity document as long as you have an active user account.

• Performance of a Contract
• Compliance with Legal Obligations 
• Legitimate Interests - It is in our interest to prevent and address unauthorised uses of Bolt accounts and violations of our Terms and Conditions.
• 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
• Location Data
• App Usage Data

To enable, improve and customise the car rental services and other services/features  by helping you find a car

We get you to where you want to go.

We collect and process your Location Data to help you navigate pick-ups and drop-offs of the rental cars from Fleet Owners.

• Performance of a Contract

• Profile Data
• Location Data
• App Usage Data
• Device Data

To make sure the Bolt App works optimally

We use your Contact 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 calculate prices and process payments 

We collect Payment Data to process and enable payments and App Usage Data to calculate prices and bill correctly based on your pick-up, drop off and duration of the rental booking.

• Performance of a Contract

• Payment Data
• App Usage Data

To administer the use of and payment for the Bolt services you are offered by your employer (a Bolt Business Client)

We collect your Contact Data if you use the Bolt services through your employer who is a Bolt Business Client, and in addition we process and share with them the vehicle pick up/return locations.

• Legitimate Interests - It is in our interest and in the interest of our Business Clients,  to facilitate the use of our services through Bolt Business 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 the Bolt services through surveys and interviews

These surveys and interviews are designed to understand your feedback on the Bolt 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 Users to provide a satisfying user experience.

• Profile Data
• Demographic Data
• Survey/Interview Data

For customer support

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. We also use the data you share to address quality issues and to improve the Bolt services.

For safety related incidents reported by Fleet Owners, your Fines and Violations Data will be reviewed by Bolt’s Customer Support and/or Safety Teams when investigating a safety/criminal incident on the Bolt Platform involving you.

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 Users to support them throughout their use of the Bolt services and continuously  improve and develop the customer support we provide.

In addition it is in our interest and interest of our Users to address threats and abuse and promote safety, integrity and security on the Bolt Platform to ensure our services are used in accordance with our Terms and Conditions.

• 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.

• Communication Data
• User Generated Data
• Fines and Violations Data

For safety and security

To issue warnings and suspensions

When you use Fleet Owners’ rental vehicles, we process your personal data to ensure that our services are used safely and in accordance with applicable rules and agreements.

This may include information about violations, fines, or flags reported by our partners (such as fleet owners or authorities), as well as your communication and compliance history within the Bolt platform.

Based on this information, we may issue warnings or apply temporary or permanent suspensions. In such cases, you will be notified via push notification and/or in-app messages. Depending on the nature and severity of the issue, initial notifications may serve as warnings, while repeated or serious violations may result in stricter measures, including suspension from using Bolt rental services.

You are able to contest the block by contacting our Customer Service, if you do not agree or you think this is a mistake.

For information regarding how to object to the above processing activities, please see Section 9 “What are your rights” and contact the Customer Service.

• Legitimate interests - It is in our interest and the interest of our Users to ensure that our services are used in accordance with our and Fleet Owners’ Terms and Conditions.

• Communication Data
• Fines and Violations Data

To prevent, detect, investigate fraudulent accounts, fraudulent payments or other unlawful use of our 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 rental booking, or go through authentication processes.

For example, to enable us to investigate, a temporary suspension may be applied to a Bolt Account when we detect that the User 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 User are taken following human review, 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 Users 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 interests to prevent and address violations of our Terms and Conditions.

• Profile Data
• Identification / Verification Data
• Device Data
• Location Data
• Payment Data
• App Usage Data
• Communication Data

For marketing and advertising

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, integrations, 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 as a wrap-up marketing 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 Users to inform them about Bolt 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 Users  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.

• Profile Data
• App Usage Data
• Device Data
• Cookies, SDKs, Analytics, and Third-Party Technologies Data

For service communications

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 rental booking has been completed, to send you confirmation emails and receipts, and to let you know about important service updates.

• Performance of a Contract

• Profile Data

For research and improvement of the Bolt services

To perform research, testing, and analytics to better understand and improve our business and the Bolt Services

For example, we use 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 Bolt 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.

• 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 Users to develop and adopt new features to improve the Bolt Platform.

• Profile 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 Users to provide a hassle free and reliable service.

• Profile Data
• User Generated Content
• Communication Data
• Device Data
• App Usage Data

For legal proceedings and compliance with the law

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 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 or in the event of damage to our vehicles or of accidents involving our vehicles, we need to share information with insurance companies for claims settlement.  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 Users 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 Users to protect, guard and maintain Bolt’s security systems, respond to suspected or actual criminal acts and repair any technical issues.

• All Data

Bolt Group Companies and Partners

We may share your personal data with our Bolt Group Companies (including Bolt local subsidiaries), Partners, their affiliates and representatives, who may similarly 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 OÜ as the main data controller for Bolt.

Rental bookings requested or Paid by Bolt Business Clients or others

Some rental bookings you take may be requested or paid for by others. If you take one of those rental bookings 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 rental booking for you, we may share your rental booking details with that other party, including your name, phone number, a date, time, charge, and vehicle pick up/return locations.

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 rental bookings and would receive such information.

Fleet Owners offering car rental services on listed on the Bolt Platform

We share your personal data with Fleet Owners who provide car rental services via the Bolt platform to enable them to deliver the requested services. This includes facilitating your booking, providing the rental vehicle, managing the rental, and handling any related issues such as payments, fines, or violations.

These Fleet Owners process your personal data as independent controllers in accordance with their own privacy notices.

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 location 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. We will also share data with insurers, for the purposes of claims management and settlement to avert further damage to us.

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.

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” 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.

Accounting and financial reporting purposes  

We retain data for 10 years after the last rental booking if your personal data is necessary for accounting purposes and for 3 years after the last rental booking regarding Payment Data in relation to Bolt Rent services provided to Users.

Provision of services purposes

We retain your data as long as you have an active User 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.

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.

Customer Support

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

Country

Disclosures

Alternative Legal Bases

Dubai,

United Arab Emirates

(AE)

• We do not rely on Legitimate Interests in Dubai to process your personal data. We will instead rely on one or more Alternative Legal bases listed in this table, depending on the circumstances.
• By agreeing to this Privacy Notice, you are consenting to Bolt sending you marketing communications. You can unsubscribe from these communications at any time within the Bolt App.
• By agreeing to this Privacy Notice, you are explicitly consenting to Bolt transferring (exporting) your personal data from Dubai to other Bolt Group Companies.

• Consent.
• Performance of a contract.
• Compliance with legal obligations.
• Protection of your vital interests.
• For any defence or initiation of any actions, claims or legal proceedings, or related to judicial or security procedures.