Privacy Policy

Date last revised: Thu Nov 18 2021

1. Introduction

BOLT GLOBAL MEDIA UK LTD and its affiliates (“Bolt.Global”, “we” or “us”) cares about the privacy of your personal information and is committed to protecting it.

This Privacy Policy applies to information obtained by us through your use of our services (via our website, apps) branded as “BOLT”, “BOLT+”, “BOLT X”, “BOLT.Global” and any other brand/platform developed or offered by us (“Services”).

This Privacy Policy does not apply to websites, apps, destinations, or other offerings that we do not own or control, including those linked to or from the Services. If you submit Personal Information to any of those websites, your information is governed by their privacy policies.

By registering for our Services or otherwise accessing, visiting or using the Services or any part thereof, you consent and agree to be bound by the terms of this Privacy Policy.

For the purposes of the applicable data protection laws (the General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR), together with any implementing legislation, in particular, the Data Protection Act 2018), BOLT GLOBAL MEDIA UK LTD is the ‘data controller’ of your personal information so collected by us or provided by you.

This Privacy Policy explains what information we collect about you and why, what we do with that information, and how we handle that information.

2. Collection of your Personal Information

2.1 We have collected and may be collecting the following information:-

Information that you could have provided about yourself such as your first and last name, postal address, email address, telephone number, user ID, and payment processing information (if relevant), gender, nationality and country of origin

Information that you upload or contribute as a user on our Services such as live streaming, audio, audio-visual, videos, photos, comments, posts, messages and/or captions (“Posts”). Such Posts may contain your personal information, which we may collect and use for the purposes described herein;

Information that are automatically collected by using cookies and other types of technology when you access our Services such as your browser type, IP address, device ID, domain names, cookie information, pages and links you visited, geo-location data, website or app activity data and preferences; and

Information that we obtain from third parties and sources such as social media networks (when you access our Services through these platforms), where information such as your preferences of content viewed/uploaded on our Services may be collected.

(All such information shall be collectively referred to as “Personal Information”).

2.2 If have reason to believe that a child under the age of 18 has provided personal data to us through our Services, please contact us and we will endeavour to delete that information from our database. Otherwise all personal data provided by a user shall be deemed to have been submitted by a user above 18 or has obtained the relevant permission from their parent/guardian.

3. How we collect your Personal Information

3.1 Your Personal Information are collected in a number of ways, including:-

when you register for our Services, create a profile or account with us;

when you access and use our Services including the features and functionality thereof;

when you participate in the activities on our Services; and

when you contact us.

4. Use of your Personal Information

4.1 The Personal Information and other information which you provide or have provided for the use of the Services including any additional information you may subsequently provide, may be used and processed by us for the following purposes:-

to assess and process your requests for and use of our Services;

to operate our Services and conduct the activities therein;

to communicate with you about our Services as well as products and services of our business partners;

to respond to your inquiries and requests for assistance, including account verification support, send our Services information and updates;

to process your payment transactions, if relevant;

for conduct internal activities including any investigations, compliance or security purposes such as fraud, cheat, crime detection and prevention; and

for such other purposes as set out in our Terms of Service.

4.2 We also use Personal Information in particular, those automatically collected ones to analyse and use the information so that we can better understand how our users use or interact with our Services, to maintain and improve our Services, to source potential customer leads and to disclose aggregated statistics, analysis and trends regarding our Services. Such use includes:

to remember your information for future visits or access of our services;

to monitor the effectiveness of advertising and marketing campaigns so that we can endeavour to provide you with more relevant and customised content, advertising and information;

to track your activities on our Services; and

to update our apps on your system automatically.

(collectively “Purposes”)

5. Retention Period of Personal Information

5.1 Unless a longer retention period is permitted or required by law, we will only hold your Personal Information in our systems for the period necessary to fulfil the purposes outlined in this Privacy Policy, or until you request that the information be deleted in accordance with your right of erasure.

6. Personal Information Access And Disclosure

6.1 We may share your Personal Information within our group of companies and advisers such as lawyers, accountants for the Purpose set out in Clause 4 above.

6.2 We may also disclose your Personal Information:-

to third parties for the Purposes set out in Clause 4 above such as our business partners and/or service providers, vendors and advisers (collectively “Service Providers”) to assist us in our business or operating needs. Such needs include hosting and maintenance of our website and app, communication with users, delivery/transmission of our Services, processing of payments (if any), customer support services and other advertising systems, tracking and analytics needs. These Service Providers may only access, process or store your Personal Information pursuant to our instructions and to perform their duties to us, and in accordance with applicable laws and regulations;

to prospective investors or buyers of any part of our business or assets for the purposes of due diligence exercises (but we will not sell nor trade your Personal Information); and

to government and law enforcement authorities if required by law or for health, safety and public interest reasons.

6.3 Further, please be informed that if required for any of the foregoing Purposes, your Personal Information may be transferred to locations outside the United Kingdom or disclosed to our group of companies, Service Providers and other permitted persons , who may be located within or outside the United Kingdom.

6.4 We will employ appropriate safeguards and procedures with the third parties we share your Personal Information with, to ensure that your Personal Information is treated by those third parties in a way that is consistent with data protection laws

7. Data security & integrity

7.1 We are committed to taking reasonable and appropriate steps to protect the Personal Information that we hold from misuse, loss, or unauthorised access. We do this by using technical and organisational measures. These measures may vary based on the sensitivity of your Personal Information.

7.2 However, while we do our best to protect your Personal Information, we cannot guarantee the security of information you provide to us over the internet or similar connection as no security precautions or systems can be completely secure. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our technical or organisational safeguards and measures.

8. Your Rights

8.1 How To Update Your Personal Information. If you have registered or created an account on any part of our Services, you may be able to access, review, update, rectify, delete your information or preferences, disable your account, or otherwise limit our use of information under the Settings page, if available. If no such mechanism is available, please contact us at contact@bolt.global. You will be required to provide your name, address and telephone number and specify the relevant changes you wish to make. Prior to making any changes, we may need to verify your identity before granting you access or making corrections to your information. Please note that where you have requested for deletion of any of the Personal Information, you may no longer be able to access or use our Services or certain features and functionality thereof.

8.2 How to Opt-Out of Marketing Messages from Us. If you do not wish to receive future marketing materials from us, simply follow the unsubscribe instructions contained within the message you received, select your preferences under the Settings page, if available or contact us at the Contact details below. However, please note that you may continue to receive certain communications from us that are necessary for the Services, such as technical notices, updates, security alerts, and support and administrative service bulletins.

8.3 If you are a past user who have registered for our Services or any part thereof, please be informed that we will continue to process your Personal Information in accordance with this Privacy Policy unless we hear otherwise from you. You may exercise your rights in respect of your Personal Information in the manner described above.

9. Use of Cookies

9.1 We use analytical/performance cookies such as Google analytics. They allow us to recognise and count the number of users and to see how users move around our website and app when they are using it. Our websites and apps may contain third party tracking and data collection and analytics tools from our Service Providers who may use cookies and other software in our Services to enable them to collect and analyse user and device related data and information on our behalf. The third parties may have access to and collect data and information about you, such as your device identifier, geo-location information, IP address, application usage, access and session times, and your viewing of and activity with advertising, for the purpose of providing their services.

9.2 If you want to check or change what types of cookies you accept, this can usually be done within your browser settings. Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

9.3 If you do not wish to receive cookies, you can reject them by opting out or modifying your browser settings.

10. Changes to this Policy

We may change or update this Privacy Policy from time to time, to reflect company and customer feedback. We encourage you to periodically review this Privacy Policy to be informed of how we are protecting your Personal Information.

11. Contact

If you have any queries and complaints regarding this Privacy Policy or your data protection rights, we can be contacted at contact@bolt.global, or write to us at BOLT GLOBAL MEDIA UK LTD, Building 3 Chiswick Park, 566 Chiswick High Road, London, England W4 5YA.