Bolt App Disclosures

Privacy Policy

<h2>1. Information We Collect</h2><p><strong>Definition. </strong>“Personal Information” means information relating to an identified or identifiable natural person. “Process” or “Processing” means any operation performed on Personal Information. The categories and sources of Personal Information we collect depend on your relationship with Bolt, the services you use, and the requirements of applicable law.</p><p><br><strong>Information You Provide Directly.</strong> We collect information you provide when you create a Bolt Account, use the App, or interact with our services. This includes account information (such as your name, phone number, email address, login credentials, and linked payment methods) and verification information (such as government-issued identification, date of birth, and Social Security Number or ITIN). When you use the App to upload documents or images, for example via the camera on your device, Bolt receives the submission through secure channels. We also collect communications data when you contact customer support by chat, email, or phone.<br>&nbsp;</p><p><strong>Information from Other Sources.</strong> When you transact with a Bolt Merchant, we collect information about your purchases (order details, shipping information, rewards, discounts, and transaction frequency). We may obtain additional data from service providers (such as identity verification partners), publicly available databases, or commercially available sources. For example, when registering in the App, you may be asked to complete identity verification through a third-party provider. That provider may collect images of your government ID and conduct biometric checks, but Bolt only receives the verification result, not the biometric data itself.<br>&nbsp;</p><p><strong>Information Collected Automatically.</strong> When you use the App, we automatically collect device-specific and technical information, including IP address, device identifiers (IMEI, MAC address), advertising identifiers (IDFA/GAID), operating system version, carrier, and crash diagnostics. We also collect information about your interactions with the App, including session duration, features used, screens visited, and push notification tokens. If you enable location services, we may collect precise geolocation data to detect suspicious logins, prevent fraud, and comply with regulatory requirements. We may also deploy SDKs and cookies to support authentication, analytics, fraud detection, and security.<br>&nbsp;</p><p><strong>Gmail Integration.</strong> If you choose to integrate Gmail with the App, Bolt’s access to Gmail Information adheres to Google’s API Services User Data Policy. Bolt does not use Gmail Information for advertising, nor allow human review of Gmail Information except with your consent, for security purposes, or where required by law.<br>&nbsp;</p><p><strong>Passkeys and Biometric Authentication.</strong> If you use passkeys such as FaceID, TouchID, or device-based biometric authentication, Bolt only receives confirmation of successful or failed authentication. Bolt does not access or store biometric templates.</p><h2>2. How Bolt Uses Information</h2><p>We process Personal Information for the following business purposes:</p><p><br><strong>To Provide the Services.</strong> Bolt uses your Personal Information to facilitate transactions, process payments, manage wallets, and link accounts. For example, when you initiate a transfer through the App, Bolt processes your financial account information and shares necessary details with payment processors and banking partners.<br>&nbsp;</p><p><strong>To Verify Identity and Prevent Fraud.</strong> Bolt uses information collected through the App, including uploaded identity documents, location data, and device information, to verify your identity, conduct “Know Your Customer” checks, screen against OFAC and other sanctions lists, and detect fraudulent or suspicious activity. Automated decision-making tools may be used to assess unusual device patterns or locations that indicate potential account compromise.<br>&nbsp;</p><p><strong>For Administrative Purposes.</strong> We use Personal Information to provide customer support, send SMS login codes or push notification alerts, verify accounts, and manage account settings. For example, when you register on the App, your existing Bolt Account is linked to your App profile. Administrative use also includes quality control, responding to support tickets, sending service-related messages, and enforcing our Terms of Use.<br>&nbsp;</p><p><strong>To Market the Services.</strong> Subject to applicable law and your choices, we may use your Personal Information to notify you of promotions, personalize in-App offers, and measure interest in Bolt’s products. You may opt out of marketing at any time in the App settings.<br>&nbsp;</p><p><strong>Compliance and Legal Obligations. </strong>Bolt processes your Personal Information to comply with BSA/AML, OFAC, FinCEN, CFPB, and state Money Transmitter License requirements. This includes maintaining financial transaction records for legally mandated periods and filing Suspicious Activity Reports when required.</p><p><br><strong>Improvement and Analytics. </strong>We use de-identified and aggregated information to improve the App, conduct analytics, and develop new financial products. Mobile telemetry data such as crash logs and feature usage may be aggregated to optimize user experience.</p><h2>3. &nbsp;Disclosing Your Information</h2><p>Bolt may disclose Personal Information as follows:</p><ul><li><strong>Bolt Merchants. </strong>To complete your transactions and provide order-related updates, your information is shared with the relevant Merchant.</li><li><strong>Service Providers.</strong> Bolt shares information with vendors who provide hosting, payment processing, identity verification, customer support, fraud detection, and analytics services.</li><li><strong>Affiliates.</strong> Information may be shared with Bolt’s affiliates for internal business and compliance purposes.</li><li><strong>Business Partners. </strong>Where Bolt jointly offers services (such as integrated financial tools or rewards), we may share your information with those partners.</li><li><strong>Advertising Partners.</strong> Bolt may allow advertising partners to collect information via cookies and SDKs to serve personalized offers, subject to opt-out rights.</li><li><strong>Regulators and Law Enforcement.</strong> Bolt discloses Personal Information as necessary to comply with subpoenas, investigations, SAR obligations, or other legal requirements.</li><li><strong>Corporate Transactions. </strong>If Bolt is involved in a merger, acquisition, or reorganization, your information may be transferred as permitted by law.</li></ul><h2>4. How to Exercise Your Rights</h2><p>Depending on your jurisdiction, you may have rights to confirm whether Bolt is processing your Personal Information; access, correct, or delete that information; request portability; object to processing; or withdraw consent. These rights may be exercised directly through the App or by contacting us at <a href="mailto:privacy@bolt.com">privacy@bolt.com</a>. Bolt will verify your identity before responding to any request.</p><h2>5. Data Retention</h2><p>Bolt retains Personal Information for as long as needed to provide services and comply with legal obligations. Financial records are generally maintained for 5–7 years as required under BSA/AML and state MTL laws. Diagnostic and device data collected through the App is typically retained for 12–24 months. Once retention periods expire, Bolt securely deletes or anonymizes the data.</p><h2>6. Security of Your Information</h2><p>Bolt applies industry-standard technical, administrative, and physical safeguards to protect Personal Information. These measures include encryption in transit and at rest, role-based access controls, secure API calls between the App and backend systems, device sandboxing, regular penetration testing, and monitoring for unauthorized access. Although no system is completely secure, Bolt’s layered defenses are designed to protect against unauthorized disclosure, alteration, or destruction of data.</p><h2>7. Children’s Privacy</h2><p>The Bolt Services, including the App, are not directed to children. Individuals under 18 are not permitted to use the App, and Bolt does not knowingly collect Personal Information from children under 16. If we become aware that such information has been collected, we will promptly delete it.</p><h2>8. Updates to this Privacy Policy</h2><p>Bolt may revise this Privacy Policy from time to time. Material changes will be communicated in-App (e.g., push notifications or banners) and via email, where required by law.</p><h2>9. Additional Information for the EEA, Switzerland, and UK</h2><p>Bolt complies with GDPR and related laws. Where Bolt transfers data outside these regions, we rely on Standard Contractual Clauses, adequacy decisions, or equivalent safeguards. Individuals in these regions may lodge complaints with their local data protection authority.</p><h2>10. Additional Information for California Residents</h2><p>Bolt provides a dedicated CCPA/CPRA Privacy Notice (<a href="https://www.bolt.com/ccpa">https://www.bolt.com/ccpa</a>). California residents may also exercise rights to opt out of sale or sharing of data, request information, or delete their Personal Information as outlined therein.</p><h2>11. California Shine the Light Law</h2><p>California residents may request information once per year about Bolt’s disclosures of Personal Information to third parties for marketing purposes. Bolt does not share Personal Information with third parties for their own direct marketing without your consent.</p><h2>12. Additional Information for Nevada Residents</h2><p>Nevada residents may opt out of the sale of their Personal Information. Bolt does not currently sell Personal Information as defined by Nevada law.</p><h2>13. Additional Information for Virginia Residents</h2><p>Under Virginia’s CDPA, residents may request access, correction, deletion, portability, and may opt out of targeted advertising or profiling. Bolt does not sell Personal Information. Requests may be submitted to privacy@bolt.com.</p><h2>14. Contact us</h2><p><strong>Bolt Financial, Inc.</strong><br>Attn: Legal Department<br>268 Bush Street #4214<br>San Francisco, CA 94104<br>Email: <a href="mailto:privacy@bolt.com">privacy@bolt.com</a></p>