Privacy Policy

Welcome to BOLT. This Privacy Policy (“Policy”) applies to your access and use of BOLT.com (“the Site”) and the software and services available on the Site or offered by our subsidiaries (“BOLT Services”). This Policy expressly discloses i) the types of personal and non-personal information collected as a result of your use of the Site and the BOLT Services; ii) how such data is used and stored; and iii) your choices and options regarding sharing and use of your data.

This Privacy Policy is incorporated as part of the BOLT Terms of Service.

We take your privacy seriously. If you have any questions about this policy or about privacy at BOLT, please contact us at info@BOLT.com.

1. What Information is Collected & How is it Used?

Data Collected When You Visit Our Site:

Tracking Data (“Tracking Information”)

Beacons (also known as pixel tags)

When a user visits the Site’s homepage, BOLT utilizes an electronic file, called a web beacon, to count users that have visited the Site. Beacons are tiny graphics with a unique identifier that may be included on our Site Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of the BOLT Services, to monitor how many visitors view our Site. Unlike Cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).

Cookies and our Cookie Policy

BOLT Cookie Policy. We use cookies, small strings of numbers and letters that are placed on your browser. We use Google analytics and Hubspot cookies to help us understand how users use our Site and to improve BOLT Services.

You can set your browser to remove or reject cookies; however, some Site features or Services may not work properly without cookies.

Personal Information

IP Addresses. When you visit the Site or use Services our servers automatically record information that your browser sends whenever you visit a website (“Log Data“). This Log Data may include information such as your computer’s Internet Protocol (“IP“) address, browser type or the webpage you were visiting before you came to the Services, pages of the Site that you visit, the time spent on those pages, information you search for on the Services, access times and dates and other statistics.

Data Collected When You Apply to Enter An Event. When you apply to enter an event that is powered by BOLT, you may be required to provide both Personal Information (such as your name, address, contact information, email, phone number, resume or biography) and information about your event background (such job experience, hackathons attended, and languages used) (“Event Information”).

With respect to Event Information, BOLT and our subsidiaries are occasionally the Data Processor acting on behalf of the Event Organizer or organiser identified in each applicable event (“Event Organizer’). The type of Event Information collected is determined by the Event Organizer in their sole and absolute discretion, and their collection and use of that information is governed by the rules, regulations, guidelines and privacy policy of a given Event Organizer. Entrants should review the applicable rules and policies of an Event Organizer to understand the scope of their collection, use and storage practices.

Events Sponsored and Organized by BOLT. In the event that an Event is sponsored and organized by us or a subsidiary, we will clearly identify and disclose how we intend to use the information from our Events so that you can decide if you want to enter and provide your Event Information to us as well as know who to contact regarding your Event Information. For Events that we sponsor, we will not ask for your race, ethnicity or health information or any other data that is classified as “Sensitive Information” under Article 9 of the General Data Privacy Regulation.

Data Collected When You Subscribe to or Purchase BOLT Software and Services. When you subscribe to or purchase any BOLT Services, BOLT may additionally collect your email, first and last name, billing address, credit card number and security code in order to process the transaction. BOLT may also, upon request, mail an invoice to the mailing address provided by a user to facilitate payment.

2. How is Collected Information Used?

Attendee Information: BOLT and its subsidiaries may utilize email addresses provided during registration to (i) confirm account creation and confirm the validity of information provided, (ii) send secure links to users to access the Site or BOLT Services, (iii) send confirmation of financial transactions; (iv) communicate with our users to provide information regarding BOLT Services or respond to user inquiries, or (v) notify users of material changes to our Terms of Service and Privacy Policy. With your consent, users will receive BOLT’s newsletters or targeted notifications regarding Events, programs and opportunities available by BOLT’s partners and clients. Users have the option to opt-out of these email updates if they prefer.

Event Information: You must provide your Event Information in order to enter into an Event as it is necessary to administer your applicable entry and the Event. We use your Attendee Information, Event Information and Tracking Information to administer the Services, Events, provide customer services, improve the Site and Services and recommend other Events that might be of interest to you. When you do enter an Event, you authorize BOLT to share your Attendee Information and applicable Event Information with applicable Event administrators and judges solely for the purpose of administering the Event unless you authorize or consent for the Event Organizers to do otherwise. Except for the Event Organizers, judges and administrators, We do not share your Event Information with any third parties.

Credit or Debit Card Information: BOLT and its subsidiaries do not store any credit card data associated with any purchases processed on their processing sites. BOLT companies utilize Eventbrite to process ticket payments.. You should review Eventbrite’s Privacy Policy and for more detail about how your information is collected, stored and maintained by this third party payment processor.

Anonymous Data – Analytics: BOLT companies utilizes Tracking Information, Log Information and Google Analytics to access anonymous data to help us understand how our Services are used. We use Tracking Information to customize content for you and improve our Services. Google Analytics is a web analytics tool that helps BOLT understand how users engage with our Site, so that we can review and improve our Services. Google Analytics collects information anonymously. It provides a report to BOLT with website trends without identifying individual visitors.

Data Retention. We retain data as long as your account is active. If you do not use your account for one year, we reserve the right to delete your information. We may de-identify and anonymize data you provide to us to use for the purposes of research and analyzing trends which we may share with third parties, and improving the Services.

3. Third Party Websites.

Our site contains links to other websites. When you click on one of these links, you are ‘clicking’ to another website. BOLT does not control the data collection or privacy practices of such third party sites. We encourage you to read the privacy policies of any third party sites, as their collection, use and storage practices and policies may differ from ours.

4. How is Information Shared

Third Party Services

We may work with third parties to administer the Site and Services.

We use data storage services in the United Arab Emirates to store your Attendee Information, to allow us to provide our Services.

We use customer management tools to help us manage our customer relationships and manage our projects using Attendee Information, Profiles, Event Information and Event Organizer information to provide the Services from servers in the United Arab Emirates.

We take steps to ensure that these parties take protecting your privacy as seriously as we do, including entering into a Data Processing Addendum.

In addition to our Event Organizers, we also use the following third party services that provide Personal Data to us.

Hubspot. We use Hubspot to process our attendee and email information. We also use Hubspot tracking information to help us manage our customer relationships and projects. Hubspot is self-certified under the EU-U.S. and Swiss-US Privacy Shield and has a Data Processing Addendum in place.

Google Analytics. BOLT utilizes Google Analytics to collect information about the use of this service only on the Site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site, but in anonymous form. Google Analytics collects only the IP address assigned to you on the date you visit this site and assigns a user ID code, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google uses this information to analyze your use of the website, to generate reports about website activities for website operators and to provide further services related to website and internet use. Google may also share such information with third parties to the extent it is legally required to do so and/or to the extent third parties process data on behalf of Google. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy as well as the Google Analytics Data Processing Agreement. Site usage is tracked using Google Analytics in accordance with their Privacy Policy. However, if you do not want your data to be used by Google Analytics, you may opt-out by installing Google Analytics Opt-out Browser Add-on. Data processing takes place in the United Arab Emirates and Google is self-certified under the EU-U.S. and Swiss-US Privacy Shield. You may deactivate Google Analytics with the help of a browser add-on if you do not want this website analysis.

Eventbrite. BOLT utilizes Eventbrite as an attendee management and payment gateway for payments collecting Attendee Information and payments information to validate payment. BOLT does not store your credit card information. Data Processing takes place in the United Arab Emirates and Eventbrite is self-certified under the EU-U.S. and Swiss-US Privacy Shield. Users should review Eventbrite’s Privacy Policy before initiating transactions on the Site.

Additional Circumstances When Disclosures May Be Made to Third Parties

Information collected by BOLT may be disclosed when (i) we are required to do so by law, or (ii) in the event of a change of ownership.

When Disclosure or Use is Otherwise Permitted. Attendee Information or Event Information may be provided where we are required to do so by law, or if we believe in good faith that it is reasonably necessary (i) to respond to claims asserted against BOLT or to comply with the legal process (for example, discovery requests, subpoenas or warrants); (ii) to enforce or administer our policies and agreements with users; (iii) for fraud prevention, risk assessment, investigation, customer info, product development and de-bugging purposes; or (iv) to protect the rights, property or safety of BOLT, its users or members of the general public. We will use commercially reasonable efforts to notify users about law enforcement or court ordered requests for data unless otherwise prohibited by law. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to any third party request to compel disclosure of your information.

Acquisition/Merger/Assignment or other Business Transfer: BOLT may sell, transfer or otherwise share some or all of its assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy. Under such circumstances, BOLT will use commercially reasonable efforts to notify its users if their personal information is to be disclosed or transferred and/or becomes subject to a different privacy policy.

5. How is my Data Stored and Kept Secure?

Security Measures: We have implemented reasonable administrative, technical and physical security measures to protect your personal information against unauthorized access, destruction or alteration. For example:

– SSL encryption (https) everywhere where we deal with personal data.

– Data is kept on secure servers, located in the US.

Restricting staff access to Collected Information and Attendee Information

Despite our best efforts, users should be advised that no method of transmission over the Internet and no method of storing electronic information can ever by 100% secure.

6. Your Choices: How Do I Review or Revise Attendee Information or Withdraw Consent?

Viewing or Correcting Your Information

You can access and update Attendee Information at any time by emailing info@BOLT.com. If you need assistance to delete inaccuracies within your personal information or would like to know what information about you was collected, please contact us at info@BOLT.com. We will respond to your request within 10 business days. We reserve the right to charge for copies of data undergoing processing.

Removal or Withdrawing Consent

Since we use your Attendee Information to provide the Services to you, if you completely delete all such information, then your account may become deactivated. If you would like us to delete your Attendee Information, submit a request that we delete your Attendee Information to info@BOLT.com. In such cases we will only retain your Attendee Information as required by law, or for legitimate business purposes permitted by law or de-identify and anonymize information that we wish to retain so that it cannot be connected to you.

If you provided your Personal Information in connection with an Event sponsored by a third party and wish to delete your information or withdraw from an Event, please contact the Event Organizer. If we are organizing the Event you may make the request directly to us via info@BOLT.com.

All deletion and rectification requests are subject to BOLT procedures to confirm your identity.

Marketing Communications

Users have the option to opt-out of email updates if they prefer.

Data Portability

If you would like us to transmit your personal data to another company providing similar services, we will work with them to do so upon request and verification of such request with both the requestor and the company receiving the Personal Data.

Right to Redress.

BOLT has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United Arab Emirates and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit BBB EU Consumer Page for more information and to file a complaint.

Your California Privacy Rights

California residents who have an established business relationship with BOLT may make a written request to BOLT about whether BOLT has disclosed any Personal Information to any third parties for the third parties’ direct marketing purposes during the prior calendar year. To make such a request, please send an email or write us:

BOLT Headquarters

1459 18th Street

PMB#192

San Francisco CA, 94107

By Phone:(800) 897-0179

By Email: info@BOLT.com

7. COPPA and Access by Minors.

BOLT does not knowingly collect or store any personal information from or about children under the age of 16.

If you believe a child under the age of 16 has under any circumstances provided us with personal information and data, a parent or legal guardian can email us at info@BOLT.com to request that their children’s information be deleted from our records.

8. EU-U.S. and Swiss-US Privacy Shield Frameworks Summary

BOLT complies with the EU-US and Swiss-US Privacy Shield Frameworks as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union and Switzerland to the United Arab Emirates, respectively. BOLT has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit PrivacyShield.gov

In compliance with the EU-US and Swiss-US Privacy Shield Principles, BOLT commits to resolve complaints about your privacy and our collection or use of your personal information Subjects of the European Union i with inquiries or complaints regarding this privacy policy should first contact BOLT at info@BOLT.com.

Please note that if your complaint is not resolved through these channels, under limited circumstances, EU and/or Swiss individuals may seek a binding arbitration option before a Privacy Shield Panel.

BOLT receives information from users, in our case attendees, and then that information is shared with the organizers of the programs, which are our direct clients. When attendees share information with BOLT, they are fully aware and intentional in providing it to the organizers of the programs.

BOLT commits to cooperate with the Swiss Federal Data Protection and Information Commissioner (FDPIC) and comply with the advice given by such authorities with regard to human resources data transferred in the context of the employment relationship.

User have the right to access, correct and delete their personal information as stated in our Privacy Policy and Terms of Service.

Users have the right to edit or delete their information and request additional information be deleted unless otherwise permitted by law.

Additionally, users can opt-into or out of email communications.

BOLT is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

BOLT also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

9. How Does BOLT Respond to “Do Not Track” Signals?

“Do Not Track” or DNT is a feature enabled on some browsers that sends a signal to request that a web application disable its tracking or cross-site user tracking. At present, our Site does not respond to or alter its practices when a DNT signal is received.

10. How Will I Be Notified of Any Changes to this Privacy Policy?

BOLT reserves the right to amend this Privacy Policy at any time. If BOLT makes material changes to its Privacy Policy, we will notify you by (1) changing the Effective Date on our Privacy Policy and provide additional notification either (1) via email or other means as we may deem commercially reasonable.

Your continued use our Site and/or the BOLT Services after such changes have been made to the Privacy Policy constitutes your consent to our modified data collection and use practices.

11. Questions?

If you have any questions about our Privacy Policy or need to contact us for any reason, we can be reached:

In Writing:

BOLT Headquarters

Wework Dubai, One Central

Dubai, UAE

By Email: info@boltconsultancy.io