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PRIVACY POLICY

Version 11: Last revised Thursday, October 21, 2021




BOLT PRIVACY POLICY

Bolt Financial, Inc.(together with our subsidiaries and Affiliates, “Bolt,”
“we”, “our” and “us”) respects your privacy. This Privacy Policy explains the
kinds of information we may collect, how we use and share this information, and
how you can exercise your rights in relation to such information. Capitalized
terms not defined in this Privacy Policy have the meaning set forth in the Bolt
End User Terms of Use.

This Privacy Policy only applies to Personal Information that is Processed by
Bolt in our capacity as a “business” or other similar term under applicable data
protection laws. Except as otherwise stated herein, this Privacy Policy does not
apply to any uses of Personal Information by a Bolt Merchant or any Personal
Information that Bolt Processes on behalf of the Bolt Merchant pursuant to a
separate customer agreement. If you are a customer of a Bolt Merchant, you
should check the privacy policies of the Bolt Merchant to understand how they
may use your Personal Information. The Bolt Services may, from time to time,
contain links to and from the websites of other businesses. If you follow a link
to any of these websites, please note that these websites have their own privacy
notices and that we do not accept any responsibility or liability for their
privacy obligations. Please check their privacy notices before you submit any
Personal Information to these websites.


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:

 1. 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.
 2. 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.
 3. 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:

 1. 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.
 2. 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.
 3. 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.
 4. 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.
 5. Cookies and Similar Technologies. We, as well as third parties that provide
    content, advertising, or other functionality on the Bolt Services, may use
    cookies, pixel tags, local storage, and other technologies (“Technologies”)
    to automatically collect information through the Bolt Services. We use
    Technologies that are essentially small data files placed on your device
    that allow us to record certain pieces of information whenever you visit or
    interact with the Bolt Services. If you would like to opt out of the
    Technologies we employ on the Bolt Services, you may do so by blocking,
    deleting, or disabling them as your browser or device permits. See our
    Cookie Policy for more information.


3. SHARING YOUR INFORMATION.

We may share your information as set forth below:

 1. 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 your transaction. Your Personal
    Information will also be subject to the Bolt Merchant’s privacy policy. We
    are not responsible for the privacy and security practices of Bolt
    Merchants.
 2. 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.
 3. 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.
 4. 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.
 5. Advertising Partners. Through the Bolt Services, Bolt may allow third-party
    advertising partners to set Technologies (e.g., cookies) to collect
    information regarding your activities (e.g., your IP address, cookie
    identifier, page(s) visited, time of day). 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 “personalized advertising.”
    If you prefer that we do not share your Personal Information with third
    party advertising partners, you may opt out of such sharing by following the
    instructions in our Cookie Policy.
 6. 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.
 7. 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.
 8. 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:

 1. 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.
 2. 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.
 3. 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

Bolt retains the Personal Information we receive as described in this Privacy
Policy for as long as you use the Bolt Services or as necessary to fulfill the
purpose(s) for which it was collected, provide our services, resolve disputes,
establish legal defenses, conduct audits, pursue legitimate business purposes,
enforce our agreements, and comply with applicable laws.


6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in
accordance with this Privacy Policy. Unfortunately, the Internet cannot be
guaranteed to be 100% secure, and we cannot ensure or warrant the security of
any information you provide to us. To the fullest extent permitted by applicable
law, we do not accept liability for unauthorized disclosure.


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
privacy@bolt.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.


8. UPDATES TO THIS PRIVACY POLICY.

We may revise this Privacy Policy in our sole discretion. If we make material
changes to this Privacy Policy, we will notify you as required by applicable
law. We will post any Privacy Policy revisions on this web page, and the revised
version will be effective immediately when it is posted. If you continue to
visit our website or use the Bolt Services after such changes have been made,
the revised Privacy Policy will be applicable to you. If you are concerned about
how your information is used, bookmark this page and read this Privacy Policy
periodically.


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:

 1. Bolt takes reasonable steps to ensure that the Personal Information we
    collect is reliable for its intended use, accurate, complete, and up to
    date. Our legal basis for collecting and using the Personal Information
    described in this Privacy Policy will depend on the Personal Information
    concerned and the specific context in which we collect it. We collect and
    use your Personal Information to pursue our legitimate interests, in order
    to enter into or perform a contract with you, with your consent, or to
    comply with our legal obligations. If you wish to learn more about specific
    legal grounds we rely on to process your Personal Information for any
    particular purpose (including any legitimate interests we have to process
    this information), please contact us as provided in Section 11.
 2. 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.
 3. 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. HOW TO CONTACT US

If you have any questions, comments, or suggestions about our privacy practices,
this Privacy Policy, or if you wish to submit a request to exercise your rights
as detailed in this Privacy Policy, please contact Bolt by email at
privacy@bolt.com. We will address your concerns and attempt to resolve any
privacy issues in a timely manner.

You may also contact us by mailing us at:

Bolt Financial, Inc.
Attn: Legal Department
288 7th Street
San Francisco, CA 94103

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