This Policy applies to all of Bolt’s operating divisions, subsidiaries, affiliates, and branches, and any additional subsidiary, affiliate, or branch of Bolt that we may subsequently form.
3. Transparency/Notice — Types of Personal Information We Collect And How We Use It
The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Bolt and the requirements of applicable law. Some of the ways that Bolt may collect Personal Information include:
You may provide Personal Information directly to Bolt through interacting with the Services, participating in surveys, and requesting Services, or information.
You may provide Personal Information to Bolt through interacting with the Services via a Bolt Merchant.
As you navigate the Services, certain passive information may also be collected about your visit, including through cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
3.1 Types of Personal Information We Collect
Bolt collects Personal Information regarding its current, prospective, and former clients, users, visitors, guests (collectively “Individuals”).
Information You Provide Directly to Us. When you use the Services or engage in certain activities, such as registering for an account with Bolt (if you are a Bolt Merchant), responding to surveys, requesting Services or information, purchasing goods or services from a Bolt Merchant through the Services, or contacting us directly, we may ask you to provide some or all of the following types of information:
Communications with Us. We may collect Personal Information from you such as email address, phone number or mailing address when you choose to request information about our Services, request to receive customer or technical support, or otherwise communicate with us.
Surveys. From time to time, we may contact you to participate in online surveys. If you do decide to participate, you may be asked to provide certain information which may include Personal Information. All information collected from your participation in our surveys is provided by you voluntarily. We may use such information to improve our Sites and Services and in any manner consistent with the policies provided herein.
Automatic Data Collection. We may collect certain information automatically through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile carrier, mobile advertising identifiers, MAC address, IMEI, Advertiser ID, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, geo-location information, hardware type, operating system, Internet service provider, pages that you visit before and after using the 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 Services, and other actions taken through use of the Services such as preferences.
Purchasing Information. When you use the Services to purchase goods or services from a Bolt Merchant, we may also collect information about the goods or services you purchase, how frequently you purchase products or services, and any rewards earned due to such purchase.
Information Submitted Via Services. You agree that Bolt is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. Bolt will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Information from Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. We use this supplemental information primarily for security and fraud detection purposes. This supplemental information also allows us to verify information that you have provided to Bolt and to enhance our ability to provide you with information about our business and Services.
3.2 How Bolt Uses Your Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Services or Information Requested. Bolt may use information about you to fulfill requests for Services, or information, including information about potential or future Services, including to:
Generally manage Individual information and accounts;
Respond to questions, comments, and other requests;
Provide access to certain areas, functionalities, and features of Bolt’s Services;
Contact you to answer requests for customer support or technical support.
Administrative Purposes. Bolt may use Personal Information about you for its administrative purposes, including to:
Measure interest in Bolt’s Services;
Develop new products and Services;
Ensure internal quality control;
Verify Individual identity;
Communicate about Individual accounts and activities on Bolt’s Services and systems, and, in Bolt’s discretion, changes to any Bolt policy;
Send email 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;
Process payment for products or services purchased from Bolt Merchants;
Process applications and transactions;
Prevent potentially prohibited or illegal activities;
Enforce our Terms.
Marketing Bolt Services. Bolt may use Personal Information to provide you with materials about offers and Services that may be of interest, including new content or Services. Bolt may provide you with these materials by phone, postal mail, or email, as permitted by applicable law. Such uses include:
To tailor content, advertisements, and offers;
To notify you about offers and services that may be of interest to you;
To provide Services to you;
For other purposes disclosed at the time that Individuals provide Personal Information; or
Otherwise with your consent.
You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 5 below.
Research and Development. Bolt may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Bolt may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on Bolt’s or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 5 below.
Services via Mobile Devices. From time to time, Bolt may provide Services that are specifically designed to be compatible and used on mobile devices. Bolt will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Bolt’s Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts.
Anonymous and Aggregated Information Use. Bolt may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Bolt’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Bolt may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Bolt and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Automated Decision Making and Fraud Prevention. Bolt may use a variety of factors, including, but not limited to, your Personal Information, for the purposes of automated and non-automated decision-making related to fraud prevention and related activities. If we use automated decision making in other contexts, we will inform you of any such processing and provide you with an opportunity to object where required by law.
Other Uses. Bolt may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
3.3 Cookies, Pixels Tags/Web Beacons, Analytics Information, and Interest-Based Advertising
Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
Google. We may use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop Site content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Mixpanel. We may use services by Mixpanel, Inc. (“Mixpanel”) to obtain analytics data regarding users’ interactions with our Site and Services. You may opt-out of Mixpanel’s automatic retention of data that is collected while using the Site or Services by visiting https://mixplanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out cookie placed on your device. Please note that if you get a new computer, install a new browser, erase or otherwise alter the browser’s cookie file (including upgrading certain browsers), you may delete the Mixpanel opt-out cookie.
Mouseflow. We may also use Mouseflow, a Third-Party analytics tool, to track page content and click/touch, movement, scroll, and keystroke activity. You can opt-out at https://mouseflow.com/opt-out/.
Our uses of such Technologies fall into the following general categories:
Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our Sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ on our Sites, Services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
3.4 Third-Party Websites
The Site may contain links to other websites and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and Bolt does not endorse or make any representations about Third-Party websites or social media platforms. We encourage our users to read the privacy policies of each and every website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
4. Onward Transfer — Bolt May Disclose Your Information
4.1 Information We Share
Bolt Merchants. We may share any information we receive from you with the Bolt Merchant from whom you purchase or seek to purchase products or services in order to facilitate and support the transaction you have requested. In addition, the Bolt Merchant may have access to your information on its Merchant Dashboard or through our API so it can properly provide its own products or services to you.
We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers. The types of service providers to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site and Services. Bolt has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
Business Partners. Bolt may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a Service that you have requested. 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. In such cases, our business partner’s name will appear, along with Bolt. 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.
Marketing – Interest-Based Advertising and Third Party Marketing. Through our Services, Bolt may allow Third-Party advertising partners to set tracking tools (e.g., cookies) to collect information regarding your activities (e.g., your IP address, page(s) visited, time of day). We may also share such de-identified information (such as demographic information and past purchase history) as well as selected Personal Information we have collected with Third-Party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non Bolt related websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We may allow access to other data collected by the Site to facilitate transmittal of information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer that we do not share your Personal Information with Third-Party advertising partners, you may opt out of such sharing at no cost by following the instructions in Section 5 below.
Disclosures to Protect Us or Others (e.g., as Required by Law and Similar Disclosures). We may access, preserve, and disclose your Personal Information, other account information, and content 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) to enforce Bolt policies or contracts; (v) to collect amounts owed to Bolt; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is 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 the 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 activities.
4.2 International Data Transfers
You agree that all Personal Information collected via or by Bolt may be transferred, Processed, and stored anywhere in the world, including but not limited to, the United States, the European Union, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Bolt, you explicitly consent to the storage of your Personal Information in these locations.
5. Opt-Out (Right to Object to Processing)
You have the right to object to and opt out of certain uses and disclosures of your Personal Information. Where you have consented to Bolt’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by contacting email@example.com. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Sites and/or information from the advertisements on Third-Party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.
5.2 Email and Telephone Communications
We maintain telephone “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.
5.3 “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.
5.4 Cookies And Interest-Based Advertising
As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
6. Rights of Access, Rectification, Erasure, and Restriction
Although Bolt makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Bolt is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Bolt determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Bolt will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
7. Data Retention
8. Security of Your Information
By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
9. International Users
If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and to Processing of your data globally. By providing your Personal Information, you consent to any transfer and Processing in accordance with this Policy.
10. Children’s Privacy
Our Services are not directed to children under 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect Personal Information from children under 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected Personal Information of a child under 13 we will take steps to delete such information from our files as soon as possible and terminate the child’s account.
11. Redress/Compliance and Accountability
12. Other Rights and Important Information
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Bolt will endeavor to comply with the law or contract.
The following capitalized terms shall have the meanings herein as set forth below.
“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Bolt or to which Bolt discloses Personal Information for use on its behalf.
“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Bolt or Bolt’s Agents.
Please feel free to contact us with any comments, questions or suggestions you might have regarding the information described in the Sites.
You may contact us at:
Bolt Financial, Inc., 288 7th Street, San Francisco, CA 94103