Global Privacy Notice for Bolt Food Clients (Eaters)

Global Privacy Notice for Bolt Food Clients (Eaters)

At Bolt, we are focused on making cities for people. To do this, we offer a number of alternative transport solutions including rides, shared cars, e-bikes and scooters, and food and grocery delivery. Your safety is our priority and this includes the safety of your personal data that we process when you use the Bolt services (that includes Bolt Food and Bolt Market Platforms and the Bolt Food App).

Date when this Privacy Notice was last updated: 1 June 2025

Table of Contents

1. About this Privacy Notice

2. How do you contact us?

3. What personal data do we process?

4. What purposes do we use your personal data for and what is our legal basis for processing?

5. Who do we share your personal data with?

6. Does Bolt transfer your personal data to other countries?

7. How do we keep your personal data safe?

8. How long do we retain your personal data for?

9. What are your rights?

10. How do we use your personal data for direct marketing?

11. How do we notify you of changes to this Notice?

1. About this Privacy Notice 

This Privacy Notice (“Notice”) describes how Bolt Operations OÜ (“Bolt”, “We” or “Us”) and its group companies and third party partners collect and use the personal data of persons arranging orders and delivery of food and goods through the Bolt Food and Bolt Market Platforms (“Bolt Food Platform” or “Bolt Food App”) – each known as a “Client”. More information about Bolt and its group companies, such as the relevant Bolt group company for your market, is set out here.

The term “you” or “your” refers to a Client. This Notice lets you know how we promise to look after your personal data and tells you about your privacy rights and the choices and controls available to you.

This Notice applies to all individuals globally who use the Bolt Food Platform to request and receive an order from a diverse selection of online delivery from restaurants, stores, and pharmacies (“Partner(s)”) via the Bolt Food App. This Notice should be read in combination with all terms and conditions, guidelines and policies that apply to your use of the Bolt services as are made available for your market at https://bolt.eu/legal

2. How do you contact us? 

Bolt (or the relevant Bolt group company for your market - as set out here in more detail) is the data controller of your personal data processed under this Notice. 

We have appointed a Global Data Protection Officer (“DPO”) and an Office of the Data Protection Officer Team. You can contact our DPO by raising a data subject rights request via the Privacy Web Form available at https://bolt.eu/en/privacy/data-subject/ or raising any privacy-related questions in the Bolt Food App when you go to the main menu and tap ‘Support’, our Customer Support Team will then escalate the issue internally to Bolt’s Privacy Legal Team. You can also email our Privacy Mailbox at privacy@bolt.eu - please mark the subject line of the email ‘For the attention of Bolt’s Data Protection Officer'.

3. What personal data do we process?

We collect and process personal data: 

  • provided by you to Bolt;
  • when you use the Bolt Food App; and
  • from other sources such as authorised third parties who administer services on behalf of Bolt, and in some countries, governmental or public databases.

 The table below sets out the different categories of personal data we process about you:

Personal data provided by you to Bolt

Category of personal data

Description of personal data

Profile Data

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

  • Full name
  • Email address
  • Phone number
  • Saved favorite delivery addresses (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). This data is submitted by you when you are required by Bolt to verify your age and identity when ordering age-restricted goods.

Demographic Data 

We collect demographic data such as your age when you are required to verify your age by Bolt.

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 Food App

Category of personal data

Description of personal data

Geolocation Data 

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

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

Order Data

We collect personal data via the Bolt Food App about your use of the Bolt services. This includes:

  • Details of orders or order history (including date and time of the order,  delivery addresses and geolocation data, details of the food or other delivery items ordered, your special instructions or preferences, the Partner’s name and location, order price, currency and your delivery notes)
  • Loyalty card information (including whether you used any coupons, loyalty cards or promotional codes)

App Usage Data

We collect personal data via the Bolt Food App about your use of the Bolt Food Platform. This includes: 

  • Log-in history (dates and times you log-in and log-off the Bolt Food App); and
  • Interaction with the Bolt Food App (features or pages viewed or proposed to be viewed, time spent interacting with a page, browser type 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; 
  • Communicate via emails, web forms, or speak with our Customer Support agents; 
  • Communicate with Delivery Partners via the Bolt Food 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 Clients and Delivery Partners 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. This includes:

  • Content like pictures, videos, files in connection with a Customer Support request.
  • Ratings and feedback about:
    • the Partners by evaluating the order on a scale from 1 (poor) to 5 (outstanding), and optional comments, when your order is delivered.
    • the delivery experience inside the Bolt Food App by evaluating the Delivery Partners with thumbs up or thumbs down, and optional comments, when your order is delivered.
  • Metadata related to the method you use to communicate with Bolt.

If you are ordering or paying for food at the restaurant’s place (where applicable) via the Dine-in feature and you rate the food with 4 or 5 stars, you will receive a prompt message  to share your feedback on Google and TripAdvisor. In this case, Bolt will not access or store the feedback you share on Google and Trip Advisor. Your review will remain exclusively with the platform you share it on.

Warning and Suspension Data

We collect details of warnings and suspensions that have been issued to a Client. This includes: 

  • Date(s) on which warnings or suspensions have been issued.
  • Date of expiry of a suspension.
  • Reason for the warning or suspension.

Device Data 

We collect data about the devices you use to access the Bolt Food App, including:

  • Hardware model
  • Device IP address
  • 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 Data

We collect information through the use of cookies (to the extent you use Bolt Food website services), tracking pixels, data analytics tools, SDKs, and other third-party technologies like advertising IDs to understand how you navigate through the Bolt Food App, to make your experience safer, to improve your site and Bolt Food 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 

Category of personal data

Description of personal data

Contact Data

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

  • Full name 
  • Email address
  • Phone number

4. What purposes do we use your personal data for and what is our legal basis for processing? 

The table below sets out:

  • our purpose for processing your personal data; 
  • our legal grounds (known as a 'legal basis') under data protection law, for each purpose; and 
  • the categories of personal data we use for each purpose. Learn more about what personal data these categories include in Section 3 “What personal data do we process?” above.

Here is a general explanation of each 'legal basis' that Bolt relies on to process your personal data to help you understand the table below:

  • Performance of a Contract: When it is necessary for Bolt (or a third party) to process your personal data to provide you with the Bolt services we promised you and meet our obligations under the Terms and Conditions for Clients. Where the legal basis for processing your personal data is performance of a contract, and you choose not to provide the information, you may be unable to use the Bolt services.
  • Legitimate Interests: When we process your personal data relying on legitimate interest grounds. This includes our commercial and non-commercial interests in providing an innovative, personalised and safe service to you, other Clients, and other third parties (including Delivery Partners or Partners). Where the table below states that we rely on legitimate interests, we have provided a brief description of the legitimate interest. If you would like more information about this (including the balancing test), please contact us using the methods set out in Section 2 “How do you contact us?” above. In countries where legitimate interest is not an available lawful basis for Bolt’s processing activities, we will instead rely on an alternative valid legal basis.
  • Consent: When we ask you to actively indicate your agreement to our use of your personal data for a certain purpose of which you have been informed of. ​​Where we rely on consent to process your personal data, you can withdraw your consent to such activities at any time. Withdrawal of the consent does not affect the lawfulness of any processing which took place prior to you giving your consent to us.
  • Compliance with Legal Obligations: When we must process your personal data because it is required by a law or regulation in the markets we operate in, such as to comply with our licensing conditions and our obligations under tax and accounting laws. Where the legal basis for processing your personal data is compliance with legal obligations, and you choose not to provide the information, you may be unable to use the Bolt services.
  • Vital Interests: When we process your personal data where it is necessary to protect your vital interests or those of others, for example in the event of an emergency or an imminent threat to life.

For the provision of the Bolt services

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 Bolt Food services (such as purchasing age-restricted items), 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 Food account) and you are not able to verify, the Bolt Food 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.

  • Compliance with Legal Obligations 
  • Legitimate Interests - It is in our interest and in the interest of our Clients to prevent and address  unauthorised uses of Bolt accounts and violations of our Terms and Conditions for Clients.
  • Consent  - Your opt-in consent will be required in order for us to proceed with biometric verification checks.
  • Profile Data
  • Identification / Verification Data
  • Demographic Data 
  • Device Data
  • Geolocation Data
  • App Usage Data
  • Suspension Data

To enable, improve and customise the services for the purposes of managing and delivering your order by connecting Clients with Partners and Delivery Partners

We help you forward your order to the preferred Partner (i.e., restaurant,store, or pharmacy), and conclude an order  preparation contract with this Partner. Also, we find and allocate the Delivery Partner to fulfill the delivery of your order request. 

We obtain your consent when you order prescription or non-prescription medical items. Some of these items may reveal information about your health. Therefore, your consent is necessary for us to process the order. This enables Bolt to manage your request, coordinate with the Partner, and ensure a smooth and reliable delivery.

If you choose not to provide consent for processing an order containing such items, Bolt will not be able to fulfil the order. In that case, we recommend purchasing the product directly from the Partner’s official website or visiting the Partner in person.

We use Geolocation Data to facilitate orders and deliveries, calculate estimated time, and track the progress of your orders and deliveries. We match available Delivery Partners and Partners with Clients based on their Geolocation Data to enable efficient delivery. 

You may use the Bolt Food App without enabling collection of Geolocation Data from your mobile devices but this can prevent you from accessing  some features.

Communication Data may be processed if the Delivery Partners or Partners and Clients need to contact each other to coordinate order and delivery. 

We also help you to order food in a restaurant using the Bolt Food App, through the Dine-in feature available in certain countries. For guest users, we will only collect table number and ID, order details, address of the restaurant, email address (to the extent you choose to receive a receipt or opt-in for the marketing communication), feedback shared and payment data. The data specified above is not linked to a specific user, unless you are a registered user or provide your email address.

  • Performance of a Contract 
  • Consent - Your consent will be required when ordering prescription or non-prescription medical items.
  • Profile Data
  • Geolocation Data
  • Order Data 
  • App Usage Data 
  • Device Data
  • Payment Data
  • Communication Data

To make sure the Bolt Food App works optimally

We use your Profile Data to notify you of updates to the Bolt Food 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 Food  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
  • Legitimate Interest
  • Profile Data 
  • Device data
  • App Usage Data
  • Identification / Verification data 
  • Cookies, SDKs, Analytics, and Third-Party Technologies Data

To improve our websites and apps

We collect and may use your App Usage Data to improve our websites and Bolt Food App (including their security features) by analysing it to better understand our business and services.

  • Legitimate Interest
  • App Usage Data

To calculate prices and process payments 

We collect Payment Data to process and facilitate payment between Clients and Partners and Delivery Partners, and Geolocation Data to calculate prices based on the delivery address of the Clients 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 Bolt services  through your employer who is a Bolt Business Client. 

In addition, if an organisation or another Bolt account owner has made an order for you, we will collect from them your Contact Data, Order Data and Geolocation Data.

  • Performance of a contract
  • Contact Data
  • Order Data
  • Geolocation 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 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 Clients to provide a satisfying delivery experience.
  • Profile Data 
  • Demographic Data
  • Survey/Interview Data 

For Customer Support

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 Clients and Partners and Delivery Partners). We also use the data you share to address quality issues and to improve our services.

For safety related incidents, your 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  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 Clients to support them throughout their use of the Bolt Food App and continuously  improve and develop the customer support we provide. In addition it is in our interest and interest of our Clients and Delivery Partners 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 Clients
  • 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
  • Order Data
  • Communication Data
  • User Generated Data
  • Suspension Data 

For safety and security

Purpose of processing 

Legal Basis

Categories of Personal 

Data

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

Our automated anti-fraud system will identify fraudulent accounts, payments, abuse of Bolt’s services and other malicious activity on the Bolt Food Platform, like, for example, when you top up your balance, request multiple refunds or go through authentication processes. To enable us to investigate, a temporary suspension may be applied to a Bolt Food account.  

While Bolt may use automated processes for fraud detection purposes, decisions to block a Client 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 Clients to detect, prevent and address fraud, unauthorised use of Bolt Food 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 Clients 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
  • Order Data

To issue temporary suspensions

In order to provide a safe and reliable marketplace, we monitor Clients’ compliance with our Terms and Conditions for Clients and use App Usage Data to temporarily suspend access to the Bolt Food App:

  • If the Client causes any abuse or harm to the Bolt Food Platform, 
  • If Bolt has reasonable belief of fraudulent acts by the Client when using the Bolt Food Platform, 
  • If the Client otherwise fails to comply with his/her obligations under the General Terms, or 
  • If the Client creates any safety concerns or risks to the Delivery Partners.

Suspension or termination from the Bolt Food Platform means also suspension or termination from other Bolt platforms (e.g. ride-hailing platform).

  • Performance of a Contract 
  • Legitimate interests-It is in our interest and in the interests of our Clients and Delivery Partners to ensure a reliable and trustworthy service and Platform sustainability. It is also in our interest to ensure and to enforce our services are used in accordance with the Terms and Conditions for Clients.
  • Profile Data  
  • Suspension Data
  • App Usage Data

For marketing and advertising

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 ads

This includes using your personal data to send you targeted emails, text messages (including WhatsApp messages), push notifications, in-app messages and other communications marketing Bolt’s and its partners’ products, services, features, offers, promotions, sweepstakes, news and events that could be of interest. 

It also includes using your App Usage Data like order history, Device Data and Geolocation Data to show you targeted or personalised advertisements or personalised recommendations through the Bolt services. For example, we may display ads for Partners that are available on the Bolt Food App. We may also display ads on the Bolt Food App based on observed or inferred data such as location, interests and behaviors and ads for third party products that are not available on our Apps.

We will further display personalised ads about our products on third- party apps and collect data about  your visits and actions on these third-party apps or websites. 

We will use pixels and similar technologies to track which emails were opened and which links were clicked by you, to help us measure the results of our campaigns and we will also use data to measure the effectiveness of our ads, and of third parties’ displayed in the Bolt Food App or in connection with Bolt services.

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.

  • Legitimate Interests - It is in our interest and in the interest of our Clients 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 Clients  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
  • Profile Data 
  • Order Data
  • App Usage Data 
  • Device Data
  • Geolocation Data
  • Cookies, SDKs, Analytics, and Third-Party Technologies Data

For service communications

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 send you order  confirmation emails and receipts, to provide you with delivery updates, to let you know that your order has been completed, and to inform you about important service updates.

For guest users, if you share your email address, we will use it just to send you a cost summary.

  • Performance of a Contract 
  • Profile Data
  • Contact Data

For research and improvement of the Bolt Food Platform

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, Order Data, Communication Data and App Usage Data to conduct research to develop or improve our products, services, technology, 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
  • Order 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 Clients  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 Clients to provide a hassle free and reliable service.
  • Profile Data
  • Geolocation Data
  • User Generated Content
  • Communication Data
  • Device Data
  • App Usage Data

For legal proceedings and compliance with the law

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 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 Clients or others, including as part of investigations,  regulatory inquiries or litigation.
  • All Data

To fulfill 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 Clients to protect, guard and maintain Bolt’s security systems, respond to suspected or actual criminal acts and repair any technical issues.
  • All Data

When we process your personal data for a new purpose different from the purpose your personal data was originally collected for and we haven't asked for your consent, we will have to ensure that this new purpose is compatible with the initial purpose we collected it for. We will take into account any link between the two purposes and decide if the personal data can be used for this new purpose. Otherwise, we will take appropriate steps to ask for your consent or refrain from processing your personal data.

5. Who do we share your personal data with?

We may share your personal data with the following categories of recipients.

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 OÜ as the main data controller for Bolt.

Partners

Your personal data is only disclosed to the respective Partner (i.e., restaurant, store, or pharmacy) when you place an order in the Bolt Food App. 

In such a case, the Partner will see:

  • Your first name and the letter of the last name
  • Contact phone number
  • Your delivery address (in case the Partner uses their own delivery method and do not leverage Delivery Partners partnering with Bolt)
  • Order Data, together with any information submitted by you together with Order Data (for example information about food preference, cooking preferences, information about any allergies if such information is disclosed by you in the course of submitting the order) 
  • Once the order is completed and to the extent you leave feedback on the Partner, we share it with the Partner.
  • After fulfilling the order, your first name and the telephone number will remain visible to the Partner for 24-48 hours. This is necessary to resolve any issues with you regarding your order, such as issuing an electronic receipt for your order, or contacting you about availability of items you ordered. 

Clients may also opt-in to share their contact and order details with a specific Partner to receive marketing communications from such Partners..

To the extent you use Dine-in service as the registered user, your personal data will be shared with the restaurant such as your table number and ID, your order details, your status of payment and any feedback you submit to rate the food and service.

Delivery Partners

Your delivery address, first name and the letter of the last name and contact phone number (to the extent the Delivery Partner reaches out to you using the Bolt Food App button “Call” during the active order) will be shared for the order delivery with the Delivery Partner.

After fulfilling the order, your first name and the telephone number is not visible to the Delivery Partner.

Bolt Business Clients or other Clients

Some orders you take may be requested or paid for by others. If you take one of those orders 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 an order  for you, we may share Order Data and your Contact Data with that other party.

The data shared with Bolt Business Clients will be disclosed via reports they can access on their Business Accounts. In addition, we share this data so you can expense your orders to the Bolt Business Profile Account. Processing of personal data will occur under the same conditions as established in this Notice. 

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, 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 with Google in connection with the use of Google maps in our apps.

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.

Please note, that our websites and apps may contain links to other third-party websites. If you follow a link to any of those third-party websites, please be aware that those websites may have their own privacy notices and that we do not accept any responsibility or liability for their notices or their processing of your personal data. Please check these notices before you submit any personal data to such third-party websites. 

6. Does Bolt transfer your personal data to other countries?

We operate internationally and as a result, your personal data may be transferred to, stored and/or processed by Bolt Group Companies, subcontractors and partners when undertaking the activities described in this Notice outside the country where you are located. Please see our Bolt Group Companies table for details of the countries where your personal data may be transferred to within the Bolt Group. 

When we transfer your personal data outside of a country or region, such as the European Economic Area (“EEA”), we will make sure that we take steps necessary to comply with applicable legal requirements and rely on the following transfer mechanisms: 

  • Adequacy Decisions: We will rely on decisions from the European Commission where they recognise that certain countries and territories outside of the European Economic Area ensure an adequate level of protection for personal information. Please click here to see the list of countries deemed ‘adequate’ by the European Commission and click here to see the list of countries deemed ‘adequate’ by the UK Government. We rely on these adequacy decisions when we transfer personal data we collect from the EEA and the United Kingdom to the United States (where some of our third party service providers are based).
  • Standard Contractual Clauses (SCCs): We will utilise standard contractual clauses approved by the European Commission for transfers outside the EEA and by the UK Government for transfers outside of the United Kingdom. Please click here to see the EEA SCCs and click here to see the UK SCCs. We will rely on SCCs when we transfer personal data we collect from the EEA and the United Kingdom to the United States, Singapore and Nigeria where some of our third party service providers are based. 

There may be certain situations (such as responding to law enforcement requests - see Section 4 “What purposes do we use your personal data for and what is our legal basis for processing?” above) where a transfer of personal data will take place on the basis of exemptions provided for under applicable data protection legislation. In these circumstances, we will take steps to minimise and protect the personal data transferred.   

7. How do we keep your personal data safe?

The security of your personal data is very important to us, and we have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. We have implemented data encryption in transit and at rest, data privacy and security training, information security policies and controls around the confidentiality, integrity and availability of our data/systems. 

Any personal data collected in the course of providing Bolt services is transferred to and stored in our data centres which are located within the EEA. 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 delivery services and customer support services in the respective countries  https://bolt.eu/cities/).

For our research and scientific purposes, all data, like bulk Geolocation Data, is anonymised so you can never be identified from it. Regarding anonymised data, we will not attempt to re-identify your personal data that has been deidentified, in the course of sharing your data with other organisations. 

You are responsible though for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site.

8. How long do we retain your personal data for?

We keep your personal data only as long as necessary to provide you with our services and for the purposes described above in Section 4 “What purposes do we use your personal data for and what is our legal basis for processing?”.

This means that the retention periods will vary according to the type, the amount and sensitivity of your personal data, the potential risk of harm from unauthorised use or disclosure of your personal data and the reason that we have collected the personal data in the first place.

Here are the key criteria we use for determining our retention periods:

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 Food 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. 

We have listed below the specific retention periods that apply to the personal data we process about you:

Category of Retention Periods

Description 

Tax, accounting and financial reporting purposes  

We retain your financial data for up to 10 years after the last order 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 account. If your account is deleted, 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 Food 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 for the purposes of investigating and detecting fraudulent, criminal or unlawful activities, or  false information having been provided.

Disputes

We retain data for the purpose of exercising or defending legal claims, including supporting our own internal investigations, including claims related to the unlawful processing or collection of user’s consent,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 Food App for 60 days from the last communication and in Bolt’s databases for 3 years from the last communication. 

Instant messages between Clients and Delivery Partners  are kept in the Bolt Food App only until the order is completed and for 30 days after in our systems. 

Customer Support 

We retain data in relation to support tickets submitted via instant messages, phone calls, web forms, and emails for 3 years from the last communication. 

Please note that the deinstallation of Bolt App in your device does not cause the deletion of your personal data. See Section 9 “What are your rights?” to exercise your Right of Erasure.

9. What are your rights? 

 As a data subject you have following rights:

  • Access your personal data (known as “Right of Access”): You have the right to access and to request copies of your personal data by contacting our Customer Support Team. 
  • Update/correct your personal data (known as “Right of Rectification”): You have the right to request us to correct personal data that is inaccurate or incomplete. You can change and correct certain personal data yourself within the Bolt App or by contacting our Customer Support Team. 
  • Delete your personal data (known as “Right of Erasure”): You have the right to request that we erase your personal data, under certain conditions (e.g., we are processing your personal data under your consent). Personal data that is processed pursuant to a legal obligation or where we have an overriding legitimate interest may not be deleted upon request. You can request erasure of your personal data by contacting our Customer Support Team.
  • Restrict use of your personal data (known as “Right to Restrict Processing”): You have the right to request that we restrict the processing of your personal data, under certain conditions (e.g., we are processing your personal data under consent). You can request restriction of the use of your personal data by contacting our Customer Support Team.
  • Object to use of your personal data (known as “Right to Object”): You have the right to object to our processing of your personal data, under certain conditions (e.g., we are processing your personal data under legitimate interests). You may submit an objection to the use of your personal data by contacting our Customer Support Team. 
  • Object to solely automated decisions being made about you which has legal or similarly significant effect on you (known as “Right to object to automated decision making”) - You have the right, under certain circumstances, to object to any solely automated decisions we have made which have a legal effect or similarly significant effect which does not involve human review. You can ask that a person review the decision, obtain an explanation of the decision reached after such assessment and challenge the decision by contacting our Customer Support Team. Please note that certain exceptions and limitations may apply to your right to object to automated decision-making, as permitted by applicable laws and regulations. We will provide you with clear information regarding the implications of exercising your rights and the processes involved in objecting to solely automated decision-making.
  • Port your personal data (known as “Right to Data Portability”): You have the right to request that we transfer the personal data that you have given us to another organisation, or directly to you, under certain conditions. This only applies to information you have given us. You can request for your personal data to be ported by contacting our Customer Support Team.
  • Withdraw your consent: If we process your personal data using consent as legal basis, then you have the right to withdraw your consent at any time (e.g., by unsubscribing from marketing communications or by updating your communication preferences in the Bolt App). Withdrawing your consent won’t change the legality of processing undertaken by Bolt before you withdraw your consent.
  • File a complaint: If you have any concerns regarding the processing of your personal data, you have the right to lodge a complaint with the Estonian Data Protection Inspectorate (“AKI”) who is our lead supervisory authority or your local data protection authority. You may also have a right to seek a judicial remedy.

To exercise any of the above rights, you can contact us via the Privacy Web Form available at https://bolt.eu/en/privacy/data-subject/ or in the Bolt Food App when you go to the main menu and tap ‘Support’, the Customer Support Team will then forward the issue internally to Bolt’s Privacy Legal Team.

10. How do we use your personal data for direct marketing?

Please be aware that you may from time to time receive updates about special offers and promotions related to our services. We send these communications based on our legitimate interests (soft opt-in) in providing you with information about opportunities that could be beneficial to you. In countries where soft opt-in is not an available lawful basis for Bolt’s processing activities, we will instead rely on an alternative valid legal basis. 

You have complete control over these communications, and if you decide at any time that you do not wish to receive them, you can stop them 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 by navigating to the main menu, taping ‘My Account’ and ‘Communication Preferences’.

If you experience issues with changing your communication preferences, you can contact us via the Web Form available at https://bolt.eu/en/privacy/data-subject/ or the Bolt Food App and choose the reason for contacting us ‘I want to unsubscribe from emails and SMS’.

Additionally, we may seek your opt-in consent for specific direct marketing activities where this is required by law. For example, we might request your consent to send you information regarding third-party promotions and offers that we think might be of interest to you. You always have the ability to opt out by changing your communication preferences in your account settings. We also personalise direct marketing messages using information about how you use the Bolt services (for example, how often you use the Bolt Food App).

11. How do we notify you of changes to this Notice?

We may make changes to this Notice from time to time. If we make significant changes, we will notify you (as required) via the Bolt Food App, website or via another method such as email.