BOLST PRIVACY POLICY
INTRODUCTION
Bolst is a mobile application that provides a range of services connecting contractors and clients. Our users (“Users”) share their personal identities and use Bolst to access a range of products, services, features and tools, including from partners and third parties.
This privacy policy (Policy) sets out how We (as defined below) use your personal data when you visit or use Bolst and the products, services, features and tools accessible via the application.
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IMPORTANT INFORMATION AND WHO WE ARE
“We” (or “Us” or “our”) are Indigo Platform Limited, a company registered in England and Wales with company number 12589888, whose registered office is at Bradbury House, Mission Court, Newport, United Kingdom, NP20 2DW.
PURPOSE OF THIS POLICY
It is important that you read this Policy together with any other privacy policy or fair processing policy We provide on specific occasions so that you are fully aware of how and why We are using your personal data. This Policy supplements the other notices and is not intended to override them.
CONTROLLER
Indigo Platform Limited is the controller and responsible for the Bolst application.
Where third-party services are provided, We share insights with entities who are partners and customers of Bolst. This includes certain User profile, transaction and usage data. Where this is the case, We may also be a controller of your data as well as the partner, customer or legal entity who administers the product and service. Further information can be obtained by emailing support@bolstplatform.com.
CHANGES TO THE POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep Our Policy under regular review. This version was last updated on 10 February 2025.
We can modify Our Policy at any time, and if We make material changes to it, We will provide notice through Bolst, or by other means, to provide you with the opportunity to review the changes before they become effective. If you object to any changes, you may delete your Bolst account.
You acknowledge that your continued use of Bolst after We publish or send a notice about Our changes to this Policy means that the collection, use and sharing of your personal data is subject to the updated Policy, as of its effective date.
It is important that the personal data We hold about you is accurate and current. Please keep Us informed if your personal data changes during your relationship with Us, for example a new postal address or email address.
THIRD-PARTY LINKS
Bolst may include links to third-party websites, plug-ins and other applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies or statements. When you leave Bolst, We encourage you to read the privacy notice of every website or application you visit.
COOKIES
For more information about the cookies We use and how to change your cookie preferences, please see here.
2. THE DATA WE COLLECT
Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed and cannot be reconstructed (anonymous data).
We may collect different kinds of personal data about you which We have grouped together follows:
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Identity Data: name, address, business address, telephone numbers, e-mail address, date of birth, nationality, National Insurance Number, passport, visa, immigration documents, residency status information, tax details, driving licence details, membership number, skills and qualifications information and job title;
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Contact Data: email, address and telephone number(s);
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Transaction Data: includes details about payments to and from You, and other details of products and services you have purchased from Us or purchased from or provided to Our partners and customers;
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Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access Bolst;
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Financial Data: bank account information (including account number, sort code, bank name and account holders name);
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Profile Data: includes your username and password, purchases made by you, your interests, preferences, feedback and survey responses, and verification results;
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Usage Data: includes information about how you use Bolst’s products and services;
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Marketing and Communications Data: includes your preferences in receiving marketing from Us and Our third parties, and your communication preferences.
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Special Categories: strictly as is necessary to enable Us to carry out Our rights and responsibilities, We may collect information about your medical history and any criminal convictions.
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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 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 Bolst feature or service.
Where identity verification checks are undertaken, We may process biometric data to verify your identity through a liveness test. Save as set out above, We do not collect any additional Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your genetic data).
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where We need to collect personal data by law, or under the terms of a contract We have with you and you fail to provide that data when requested, We may not be able to perform the contract with you. In this case, We may have to cancel a product or service you have with Us.
3. HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you, including:
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Direct interactions. You may give Us your Identity Data and Contact Data by filling in forms or by corresponding with Us by post, online, phone, email or otherwise. This includes personal data you provide when you:
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create an account on Bolst;
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subscribe to Our products, services, features or publications;
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enquire about or subscribe to Our partners products and services;
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respond to an invitation to provide information to Us;
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request marketing to be sent to you;
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enter a competition, promotion or survey;
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give Us some feedback.
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Automated technologies or interactions. As you interact with Bolst, We may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see Our cookie policy here for further details.
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Partners, third parties or publicly available sources. We may receive personal data about you from various partners and public sources as set out below:
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approved partners of Bolst who have an ongoing business relationship with you (including any engaging parties who have a work or employment relationship with you);
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contact, financial and transaction Data from providers of technical, payment and delivery services;
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identity and contact data from data brokers, aggregators or publicly available sources;
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marketing data from third parties.
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Phone calls may also be recorded for security and for the purpose of assisting and enabling Us to perform any contract or obligation with you. We may also record calls for the purpose of internal training and information reasons.
4. HOW WE USE YOUR PERSONAL DATA
We only use your personal data when the law allows Us to. Most commonly, We use your personal data where:
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We are performing a contract We are about to enter into or have entered into with you;
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it is necessary for Our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
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We need to comply with a legal or regulatory obligation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, a description of the ways We may use your personal data, and which of the legal bases We rely on to do so.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
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To allow you to register for and manage access to your Bolst account, and to receive the core services under Our EULA. | Identity Data
Contact Data
Profile Data
Usage Data | Performance of a contract with you or a partner
Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our products/services)
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To manage Our relationship with you which will include:
Notifying you about changes to Our terms or privacy policy
Asking you to leave a review or take a survey | Identity Data
Contact Data
Transaction Data
Profile Data
Usage Data
Marketing and Communications | Performance of a contract with you or a partner
Necessary to comply with a legal obligation
Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our products/services) |
To allow Users to interact with and make use of Bolst’s services, functionality, features and tools | Identity Data
Contact Data
Transaction Data
Profile Data
Usage Data
Marketing and Communications Data | Performance of a contract with you or a partner
Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our products/services) |
To enable you to take part in a prize draw, competition or complete a survey | Identity Data
Contact Data
Transaction Data
Profile Data
Usage Data
Marketing and Communications Data | Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them and grow Our business) |
To administer and protect Our business (including troubleshooting, system security, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Data
Contact Data
Transaction Data
Technical Data
Financial Data
Profile Data
Usage Data | Necessary for Our legitimate interests (for running Our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
Necessary to comply with a legal obligation |
To deliver relevant content and advertisements to you and measure or understand the effectiveness of the advertising We serve to you | Identity Data
Contact Data
Transaction Data
Technical Data
Profile Data
Usage Data
Marketing and Communications Data | Necessary for Our legitimate interests (to study how customers use Our products/services, to develop them, to grow Our business and to inform Our marketing strategy) |
To use data analytics to improve Bolst, Our products and services, marketing, customer relationships and experiences | Technical Data
Usage Data | Necessary for Our legitimate interests (to define types of customers for Our products and services, to keep Our application updated and relevant, to develop Our business and to inform Our marketing strategy) |
To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity Data
Contact Data
Profile Data
Usage Data
Marketing and Communications Data
Technical Data | Necessary for Our legitimate interests (to develop Our products/services and grow Our business) |
To carry out identity checks, AML check or right to work checks on you | Identity Data
Contact Data
Financial Data | Performance of a contract with you or a partner
Necessary to comply with a legal obligation |
MARKETING
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Where you have indicated an interest in Our products or services, We may contact you from time to time about updates to Our products or services or related products or services that We think may interest you; this does not constitute direct marketing;
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We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what We think you may want or need, or what may be of interest to you;
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You may change your contact and marketing preferences at any time;
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We maintain a marketing preference list; You may unsubscribe from Our marketing communications at any time by clicking on the “unsubscribe link” in Our electronic communications.
THIRD-PARTY MARKETING
We will get your express opt-in consent before We share your personal data with any company for third-party marketing purposes.
OPTING OUT
You can ask Us or third parties to stop sending you marketing messages at any time by contacting Us at any time at support@bolstplatform.com.
Where you opt out of receiving these marketing messages, you will still receive service-related communications that are essential for administrative or customer service purposes, for example relating to order confirmations for a service, updates to Our Terms and Conditions, or checking that your contact details are correct.
HOW YOU CAN CONTROL YOUR DATA
When you give Us consent to use your personal data, you can withdraw that consent at any time. You can withdraw your consent via your account settings in Bolst, or by contacting Us at support@bolstplatform.com. When you withdraw your consent, this won’t affect Our use of your data up to that point.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which We collected it, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose.
If We need to use your personal data for an unrelated purpose, We will notify you and We will explain the legal basis which allows Us to do so.
Please note that We may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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Internal third parties including Our affiliated companies who may assist Us in providing Our services;
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Our partners where you have asked Us to submit your details to such partner;
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Service providers acting as processors or joint controllers based in the United Kingdom who provide IT and system administration services;
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Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services;
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HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances;
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Data Providers who provide part of Our or third party service providers’ identity verification services;
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Approved partners and customers of Bolst where you have a business relationship with them (including any engaging parties who have a work or employment relationship with you);
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Third parties to whom We may choose to sell, transfer, or merge parts of Our business or Our assets. Alternatively, We may seek to acquire other businesses or merge with them.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law.
6. INTERNATIONAL TRANSFERS
We may transfer personal data outside of the UK as part of Our service to you. In order to protect your data, where We do so We will always use a lawful transfer mechanism to transfer your data outside of the UK including transfers based on an adequacy decision by an approved authority, standard contractual clauses or, where appropriate, derogations permitted by law.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on Our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where We are legally required to do so.
8. DATA RETENTION
We only retain your personal data for as long as necessary to fulfil the purposes We collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if We reasonably believe there are ongoing, or potential legal or regulatory proceedings related to your Bolst account.
To determine the appropriate retention period for personal data, We consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which We process your personal data and whether We can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
You can delete data from your profile or your activity on Bolst. If you close your account with Bolst, it is closed immediately. However, it may take up to 72 hours for your profile to be removed fully. Where We share your data with other third parties, as set out in this Policy, they may retain data in accordance with their own retention policies, or in line with Our contractual agreements with them.
For data that We collect using cookies, you can see how long We processes it for by checking the expiration periods in Our Cookies Policy.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data We hold about you;
Request correction of the personal data that We hold about you. Subject to Us verifying your request, this enables you to have any incomplete or inaccurate data We hold about you corrected;
Request erasure of your personal data. This enables you to ask Us to delete or remove personal data where there is no good reason for Us continuing to process it. We may not always be able to comply with your request of erasure for specific legal reasons;
Object to processing of your personal data where We are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where We are processing your personal data for direct marketing purposes. In some cases, We may demonstrate that We have compelling legitimate grounds to process your information which override your rights and freedoms;
Request restriction of processing of your personal data. This enables you to ask Us to restrict the processing of your personal data: (a) if you want Us to establish the data’s accuracy; (b) where Our use of the data is unlawful but you do not want Us to erase it; (c) where you need Us to hold the data even if We no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to Our use of your data but We need to verify whether We have overriding legitimate grounds to use it;
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for Us to use or where We used the information to perform a contract with you;
Withdraw consent at any time where We are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, We may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact Us at support@bolstplatform.com.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, We may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request information from you to help Us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
TIME LIMIT TO RESPOND
We try to respond to requests within one month. Occasionally it may take Us longer than a month if your request is particularly complex or you have made a number of requests. In this case, We will notify you and keep you updated.
10. CONTACT US
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, you can reach Us in the following ways:
By Email: DPO@bolstplatform.com
By Post: DPO, Indigo Platform Limited, 4th Floor, Harlequin House, High Street, Teddington, TW11 8EE
By Telephone: 08085 013799
You have the right to complain at any time to the UK data protection regulator, the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact Us in the first instance.
Last updated: 10.02.2025