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Introduction

We, Bolt Insight Limited (“Bolt”), hereby inform you that we collect and process personal data in full compliance with the Regulation EU2016/679- General Data Protection Regulation, the Data Protection Act 2018 and other relevant UK legislations (“UK GDPR”). Bolt Insight Limited is a data controller within the meaning of the UK GDPR and we process personal data. Where we act as a data processor on behalf of a data controller, we provide an additional schedule setting out required information as part of that agreement. That additional schedule should be read in conjunction with this Privacy and Personal Data Protection Policy (“Privacy Policy”). We may amend this Privacy Policy from time to time. If we do so, we will supply you with and/or otherwise make available to you a copy of the amended Privacy Policy.

Bolt’s contact details are as follows;

E-mail: dpo@boltinsight.com
Address: C/O Ida & Co, Building 3 Chiswick Business Park, 566 Chiswick High Road, W4 5YA London, United Kingdom
Web Site: www.boltinsight.com

What does Bolt do?

Bolt runs various market research projects for global brands across industries. We create online surveys to collect authentic responses from consumers that fit the criteria provided to us by brands. We design customized questionnaires to ask for your feedback and opinions on different topics, such as new product ideas, personal preferences and shopping behaviour.

Bolt may collect, use, store, and transfer different kinds of personal data or information, which may be filtered or grouped into identity, contact, transaction, and technical data sets. We use this data to serve our legitimate business purpose, given your consent to participate and provide your personal information.

We offer innovative solutions to analyse data and provide meaningful insights to share with our clients, to efficiently help optimize business operations, product development, and decision-making.

What kinds of information do we collect from you?

If you engage with a brand that uses our Services (“Client”), we may collect;
• Identity: Age, gender, location (country, city) and demographics (employment, education, income, number of children and marital status),
• Contact: E-mail address,
• Technical: Internet Protocol (IP) address, browser type and operating system on the devices you use to access our web site,
• Profile: Your interests, preferences, feedback and survey responses,
• Usage: Information about how you use our web site, products and services.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific web site feature.

If you visit our web site, we may also collect;
• Identity: Name, company name, title (only if you fill contact form),
• Technical: Internet Protocol (IP) address, browser type and operating system on the devices you use to access our web site,
• Usage: Information about how you use our website, products and services,
• Marketing: Your preferences in receiving marketing from us and our third parties and your communication preferences.

How does Bolt collect information from you?


• Direct Interactions: People fill in our research surveys, forms on our website or correspond with us by email.
This includes personal data that people provide when they:


o Answer questions in our research surveys
o participate in gift card draws at end of surveys;
o request demo of products or services;
o apply for a job position with us;
o subscribe to our publications or newsletter; or
o give us some feedback.

• Automated technologies or interactions: As people interact with our websites, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.
• Third parties: We may receive personal data about you from various third parties as set out below: o Technical Data from the following parties: analytics providers such as Google based in Ireland and Hotjar based in Malta.

Does Bolt use cookies?

Yes, in our surveys and website;
• Technical cookies: Enable core functionality such as survey sessions, website visit sessions, security and verification of identity
• Marketing cookies: To store communication preferences.

How does Bolt use the information it collects about you?


• To optimize our website and surveys’ user experience, visual designs and content for better engagement and higher conversion.
• To contact you about other surveys we provide which may be relevant to you if you have consented to us doing so.
• To provide you with the marketing information you requested or respond to any sales enquiries you may have made.
• To send you your gift card if you have earned it at end of a survey.
• Screen out people from our surveys, who don’t fit the target audience criteria set out by our clients.
• Analyse survey responses, segment survey responses into different profile groups to generate insights and share them with our clients.
• To do quality checks in our surveys: prevent repeated survey completion, disqualify people who are speeding etc.
• To enable us to supply professional services to our clients.
• To process job application, you have made.
• To enable us to invoice you for our services and investigate/address any attendant fee disputes that may have arisen.
• The processing is necessary for the performance of our contract with any 3rd parties.
• To use in the investigation and/or defense of potential complaints, disciplinary proceedings and legal proceedings.
• To fulfil our obligations under relevant laws in force from time to time.

Persons / Organisations to whom we may give personal data

For Respondents We may share your personal data with:
• Our Clients
• Our Employees
• Our Subcontractors

For Employees We may share your personal data with:
• Our Clients
• Our Suppliers
• Our Other Employees
• Our Shareholders

For Suppliers and Subcontractors
• Our Employees If you ask us not to share your personal data with such third parties we may need to cease to act. If the law allows or requires us to do so, we may share your personal data with:
• The Police and Law Enforcement Agencies
• Courts and Tribunals
• Information Commissioner’s Office (“ICO”)

Requesting Personal Data we hold about you (Subject Access Requests)

You have a right to request access to your personal data that we hold. Such requests are known as “Subject Access Requests” (“SARs”). Please provide all SARs in writing marked for the attention of Data Protection Officer, Bolt Insight Limited. To help us provide the information you want and deal with your request more quickly, you should include enough details to enable us to verify your identity and locate the relevant information.
DPA 2018 requires that we comply with a SAR promptly and in any event within one month of receipt. There are, however, some circumstances in which the law allows us to refuse to provide access to personal data in response to a SAR (e.g. if you have previously made a similar request and there has been little or no change to the data since we complied with the original request). We will not charge you for dealing with a SAR.
You can ask someone else to request information on your behalf – for example, a friend, relative or solicitor. We must have your authority to respond to a SAR made on your behalf. You can provide such authority by signing a letter which states that you authorize the person concerned to write to us for information about you, and/or receive our reply.

Putting things right (Right to Rectification)

You have a right to obtain the rectification of any inaccurate personal data concerning you that we hold. You also have a right to have any incomplete personal data that we hold about you completed.

Deleting your records (Right to Erasure)

In certain circumstances you have a right to have the personal data that we hold about you erased. In certain circumstances we have the right to refuse to comply with a request for erasure. If applicable, we will supply you with the reasons for refusing your request.

The Right to Restrict Processing and the Right to Object

In certain circumstances you have the right to block or suppress the processing of personal data or to object to the processing of that information. If you want us to cease to process your information or you object to processing so that we can consider what action, if any, is appropriate.

Withdrawal of Consent

Where you have consented to our processing of your personal data, you have the right to withdraw that consent at any time.

Automated decision-making

We do not intend to use automated decision-making in relation to your personal data.

Requests and Complaints

In accordance with the applicable regulations, you have the right to access, update or request deletion of your Personal Data as we explained above. And also, if you are not happy with our response or you think we have not complied with the UK GDPR in some other way, you can complain to us.
Please send your requests and your complaints to dpo@boltinsignt.com. You can submit by filling this Complaint Form.
Further information is available on the ICO web site (www.ico.org.uk).

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