Last revised April 2022
1. Information We Collect.
“Personal Information” is any information relating to an identified or identifiable natural person. “Process” or “Processing” means any operation which is performed upon Personal Information. The types or categories of Personal Information we collect and how we collect and Process it depends on the nature of the relationship you have with Bolt and the requirements of applicable law. We may collect the following information:
- Information You Provide Directly to Us. We collect Personal Information you provide directly to us, including Personal Information and transaction information when you use the Bolt Services, including your account information such as name, phone number, email address, and credit card number when you create a Bolt Account or a Bolt Merchant Account, your contact information when you communicate with us, and information you may provide to us in connection with surveys, contests, or sweepstakes. When you communicate with Bolt (via email or telephone) we collect the contents of those communications, including recording the call time, call duration, and contents of telephone calls.
- Information from Other Sources. When you make a purchase from a Bolt Merchant using your Bolt Account, Bolt collects information your purchase such as order information, shipping information, order updates, purchase frequency, Bolt Merchant account information, and any rewards or discounts applicable to your purchase. Bolt may also obtain information about you from other sources, including publicly- or commercially-available information and through third-party partners and service providers.
- Automatic Data Collection. We may collect certain information automatically through your use of the Bolt Services (including our websites),such as your Internet protocol (IP) address, Technologies including cookie identifiers and mobile advertising identifiers, mobile carrier, MAC address, IMEI, and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the Bolt Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Bolt Services, and other information about actions taken through use of the Bolt Services.
2. How Bolt Uses Information
We Process Personal Information for a variety of business purposes, including:
- To Provide the Bolt Services or Information Requested by You. Bolt will use your Personal Information to provide the Bolt Services. For example, if you have a Bolt Account, Bolt will use your Personal Information in connection with your transactions with Bolt Merchants, including to (i) process payments for purchases from Bolt Merchants; (ii) verify your identity to approve transactions, and monitor your online behavior to identify potentially fraudulent, prohibited or illegal transactions (including through the use of automated decision making technologies); (iii) communicate with you about your purchases, e.g. to provide shipping and returns updates; and (iv) to personalize your shopping experience with Bolt Merchants.
- For Administrative Purposes. Bolt may use your Personal Information for our administrative purposes, including (i) to respond to your questions, comments, and other requests for customer support, technical support, or information, including information about potential or future services; (ii) to send you an SMS login code; (iii) to provide you access to certain areas, functionalities, and features of the Bolt Services; (iv) for internal quality control purposes; (v) if you have a Bolt Account or Bolt Merchant Account, to communicate with you about your Bolt account and the Bolt Services, including by sending emails to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance, and changes to Bolt policies; (vi) to enforce our agreements; and (vii) to generally administer the Bolt Services.
- To Market the Bolt Services. Bolt may use Personal Information to market the Bolt Services as permitted by applicable law. Such uses include (i) notifying you about offers and services that may be of interest to you; (ii) tailoring content, advertisements, and offers for you; (iii) conducting market research; (iv) developing and marketing new products and services, and measure interest in Bolt’s services; (v) other purposes disclosed at the time you provide Personal Information; and (vi) as you otherwise consent.
- De-identified and Aggregated Information Use. Bolt may use Personal Information and other information about you to create de-identified and/or aggregated information. De-identified or aggregated information is not Personal Information, and Bolt may use such information in a number of ways, including the measurement of visitors’ interest in and use of various portions or features of the Bolt Services, for research, internal analysis, analytics, and any other legally permissible purposes.
3. Sharing Your Information.
We may share your information as set forth below:
- Service Providers. We may share any information we receive with service providers that help us provide the Bolt Services. The types of service providers to whom we entrust Personal Information include service providers for: (i) the provision of the Bolt Services; (ii) the provision of hosting, IT and related services; (iii) the provision of information and services you have requested; (iv) payment processing; and (v) customer service activities.
- Affiliates. Bolt may share Personal Information with our Affiliates for our and our Affiliates’ internal business purposes or to provide you with a service that you have requested. “Affiliate” means any entity that, directly or indirectly, controls, is controlled by, or is under common control with Bolt.
- Business Partners. Bolt may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. Bolt requires our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Bolt provided them.
- Disclosures to Protect Us or Others. We may access, preserve, and disclose any information we have associated with you if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect yours’, ours’ or others’ rights, property, or safety; (iv) enforce Bolt policies or contracts; (v) collect amounts owed to Bolt; (vi) prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) carry out actions that we believe are otherwise necessary or advisable. In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on our services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized or illegal activities.
- Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
- International Data Transfers. All Personal Information collected by Bolt will be transferred to and stored in the United States. By choosing to visit our website, utilize the Bolt Services or otherwise provide information to us, you acknowledge that your Personal Information may be transferred to countries outside of your country of residence, including the United States, which may have different data protection rules to those of your country.
4. How to Exercise Your Rights
You may have choices about our use and disclosure of your Personal Information:
- Direct Marketing: Email. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt. We may also send you certain non-promotional communications regarding Bolt and our services and you will not be able to opt out of those communications.
- Do Not Track. Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
- Your Privacy Rights. In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to or restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed Personal Information; (vi) withdraw your consent; and (vii) request erasure of Personal Information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
5. Data Retention
6. Security of Your Information
7. Children’s Privacy
Our services are not directed to children. If you are under the age of 16 you are not permitted to use the Bolt Services. We do not knowingly collect Personal Information from children under 16. If you learn that your child has provided us with Personal Information without your consent, you may alert us at email@example.com. If we learn that we have collected Personal Information of a child under 16, we will take steps to delete such information from our files as soon as possible and terminate the child’s account.
9. Additional Information for Individuals located in the European Economic Area, Switzerland, or the United Kingdom
If you are located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom:
- You have the right to lodge a complaint with the data protection authority about our collection and use of your Personal Information in relation to the General Data Protection Regulation (GDPR) and other applicable law. For more information or to submit a complaint, please contact your local data protection authority. Contact details for data protection authorities in the EEA and Switzerland are available here. Contact details for the Information Commissioner’s Office in the United Kingdom are available here.
- For more information about our Processing of Personal Information under the GDPR visit https://bolt.com/gdpr/.
10. Additional Information for California Residents
Visit bolt.com/ccpa to learn more about our Processing of Personal Information under the California Consumer Privacy Act of 2018.
11. California Shine the Light Law
Pursuant to California Civil Code Section 1798.83, if you live in the State of California, you may request certain information about the type of personal information we share with third parties for direct marketing purposes and the identity of any such third party. Once per calendar year, California residents may request this information by contacting us as directed in the Contact Us section below. However, we do not disclose personal information protected under the “Shine the Light” law to third parties for their own direct marketing purposes.
12. Additional Information for Nevada Residents
Nevada residents have the right to opt-out of the sale of their Personal Information under the rights granted to them in Chapter 603A of the Nevada Revised Statutes. Bolt does not sell your Personal Information and is used in accordance with this policy.
13. How to Contact Us
You may also contact us by mailing us at:
Bolt Financial, Inc.
Attn: Legal Department
288 7th Street
San Francisco, CA 94103