This Site Privacy Notice Notice applies solely to information processed (a) when you visit or use Boltive’s Site or (b) regarding communications between you and Boltive. Any term defined in the Main Privacy Policy will have the same meaning when used in this notice. If you reside in the European Economic Area, United Kingdom, or Switzerland (collectively, the “EU”), please see the section below titled “Supplemental Notice to EU Data Subjects,” which contains information about your rights and how to contact us.

Types of Personal Data We Collect and How We Use It

The term “personal data” as used in this Site Privacy notice means data that relates to an identified or identifiable individual, including data that can be used on its own or in connection with other information to identify, contact, or locate an individual. The types of personal data we collect and process, the purposes for which we collect and process such personal data, and the legal bases of such processing are each described below.

• Request Data: The Site allows you to request more information about, and request a free trial of, our Services, and in connection with such request you are required to provide your name, your email address, and your company name. In addition, our Site will generate metadata associated with your request. We will process your Request Data to respond to your request. We may also process Request Data for the purposes of marketing, offering, and selling our Services to you.
• Communications Data: If you communicate with us via email, we may collect the email address used to communicate with us, the content of the communication, and any metadata associated with the communication. We may process Communications Data for the purpose of communicating with you, responding to requests you may make in such communications, for the purposes of marketing, offering, and selling our Services to you, and for record-keeping purposes.
• Usage Data: When you use our Site, we automatically collect information about your use of the Site. This information is collected in the form of server log files. The information we collect includes the name of any webpage and/or file accessed by you, the date and time of access, the duration of access, the amount of data transferred, the type of web browser used by you to access the Site, device type, device ID, your operating system, the referring URL (of the previous page linking to our Site), and your IP address. We process Usage Data for the purpose of analyzing the use of the Site, including how the Site is used and who uses it, and to improve the quality and relevance of the Site to users.
• We may process your personal data for the purposes of establishing, exercising or defending legal claims. The legal basis for such processing is our legitimate interests, namely, the protection of our legal rights.
• Additionally, we may also process your personal data where it is necessary to comply with applicable law or a legal obligation to which Boltive is subject, including valid subpoenas and court orders.

Cookies

Some of the personal data collected automatically is collected using cookies and similar tracking technologies (such as pixel tags and web beacons) utilized by Boltive and third parties that provide certain services to Boltive. Cookies are small text files containing a string of numbers and letters. Two types of cookies are utilized in connection with our Site: session cookies and persistent cookies. Session cookies are used to recognize your device during a single visit and are automatically removed when your web browser is closed. Persistent cookies are sent to your web browser and then stored on your computer’s hard drive.

We use cookies for the following purposes:

• to identify you when you visit the Site and as you navigate the Site;
• to help us to determine if you are logged into the Site;
• to store information about your preferences and to personalize the Site for you;
• for security measures to protect user accounts, including preventing fraudulent use of login credentials, and to protect the Site generally; and
• to help us to analyze the use and performance of the Site.

Most web browsers have settings that allow you to refuse some or all cookies, and/or to alert you when cookies are being applied.

Boltive uses Google Analytics to analyze the use of the Site. Google Analytics uses cookies to gather information about Site use and generates statistical information. The information generated relating to the Site is used to create reports about the use of the Site. Google will store and use this information. Boltive has configured Google Analytics to anonymize the IP addresses Google Analytics collects; therefore, Google Analytics will not store your IP address. Boltive views the statistical data that Google Analytics collects only in aggregate form (i.e., in a form that cannot identify an individual). To view Google’s privacy policies and cookie opt-out procedures, please visit these pages: http://www.google.com/analytics/learn/privacy.html and https://tools.google.com/dlpage/gaoptout.

Please note that if you choose to block cookies, this may impair use of the Site.

Disclosure of Your Personal Data to Third Parties

We may disclose your personal data to third parties as described below:

• We use Amazon Web Services to store Boltive data, including your personal data. The Amazon Web Services servers which store your personal data are located in the United States. You may view the Amazon Web Services privacy policy at: https://aws.amazon.com/privacy/).
• We use other third-party service providers to provide services to Boltive, and on behalf of Boltive. These service providers are located (and their servers may be located) in other countries throughout the world. Boltive requires each such service provider to maintain comprehensive privacy and data security policies, and strict compliance with applicable data protection laws.
• We may disclose your personal data to third parties if we have a legal obligation to do so or if an applicable law requires such disclosure.
• We may disclose your personal data to third parties that help us to detect, protect against and respond to fraud and security vulnerabilities.
• We may disclose your personal data to third parties where we reasonably believe it necessary to protect the rights, property, safety, or security of our business, visitors to our Site, and third parties.
• We may disclose your personal data to those third parties and for such purposes that we describe to you when you provide personal data to us or for which you provide your consent.
• We may disclose your personal data data if ownership of all or substantially all of our business changes, or we undergo a corporate reorganization (including, but not limited to, a merger or consolidation), the assets of our business, including your personal data, will be shared with the acquiring or new business entity.

We do not sell your personal data to third parties or provide it to third parties for their own direct marketing purposes.

How We Protect Personal Data

We have implemented commercially reasonable physical, electronic, and procedural measures designed to secure your personal data from accidental loss and from unlawful or unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. However, the transmission of information via the Internet is not completely secure, and we do not guarantee the security of any personal data transmitted to or through our Site. The safety and security of your personal data also depends on you. Where you have chosen a password for access to the Services, you are responsible for keeping the password confidential. You should not share your password with anyone. We are not responsible for circumvention of any privacy settings or security measures that we provide. ANY TRANSMISSION OF PERSONAL DATA IS AT YOUR OWN RISK.

Supplemental Notice to EU Data Subjects

For those users of the Site who reside in the EU and who are subject to any one of (i) the General Data Protection Regulation, (ii) data protection laws implemented by member states of the EU in harmony with the General Data Protection Regulation,  or (iii) the UK Data Protection Act of 2018, as amended and incorporated into UK law (collectively, the “GDPR”), we have implemented the practices described below to provide you with control over your data that comprises “Personal Data” under the GDPR. Under the GDPR you are defined as a “Data Subject” and Boltive is a “Data Controller” for Personal Data that Boltive obtains and processes pursuant to this Site Privacy Notice. If you are not an EU Data Subject, the provisions below do not apply to you.

Lawful Grounds for Processing Personal Data of Data Subjects

We rely upon the following legal grounds to process Personal Data under the GDPR: (a) your consent; (b) the legitimate interest of Boltive or a third party; or (c) at your request prior to entering a contract or performance of a contract.

Data Transfer Notice

We use servers located in the United States to process your Personal Data. By accessing our Site you transfer your Personal Data to the United States for processing in the United States. Under the GDPR, the transfer of Personal Data to a country outside the EU may take place where the European Commission has determined that the country ensures an adequate level of protection. The transfer of your Personal Data to the United States in the absence of an adequacy decision by the European Commission is made because it is necessary for the performance of a contract with you, or with your explicit consent.

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Individual Rights and Data Subject Requests

If you are an EU Data Subject and we process your Personal Data, you may exercise certain rights, described below, under the GDPR.

In order to exercise any of the rights described below, please contact us at support@boltive.com and provide specific and detailed information about your request necessary for us to respond to and carry out your request.

We will endeavor to address your request within 30 days from receipt, but in some instances it may take longer. We will inform you within 30 days from receipt of your request if an extension is necessary and the reason for the delay.

• You may object to processing: you may object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).
• You may request to be informed about our processing: you may request information about how we process your Personal Data and your rights under the GDPR. This Site Privacy Notice is intended to provide you with such information, but you may contact us if you believe this Site Privacy Notice does not do so.
• You may obtain access to your Personal Data: you may obtain access to your Personal Data that we process.
• You may request rectification: if you believe any Personal Data we process is incorrect or incomplete, you may request that we correct it.
• You may request deletion of your Personal Data: under certain conditions, you may request that we remove or delete your Personal Data, for example if there is no legitimate reason for us to continue processing it. We may retain certain Personal Data to keep a record of our compliance with your request.
• You may restrict our processing of your Personal Data: you may request that we cease further processing of your Personal Data. If you make such a request, we may continue to store your Personal Data but will not make further use of it.
• You may withdraw consent: if we are relying on consent as the lawful ground to process your Personal Data, you may withdraw your consent for such processing at any time without affecting the lawfulness of processing based upon your consent before it is withdrawn.

In addition to the above rights, you may submit a complaint about our processing of your Personal Data to your national data protection regulator.

Retention of Personal Data

Pursuant to the GDPR, we will permanently erase your Personal Data at such time there is no lawful basis or legal obligation for us to store or process the Personal Data.

Children

Our Site is not intended for persons under 18 years of age, and we do not knowingly collect personal data from persons under 18 years of age. If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us at support@boltive.com. If we become aware that a person under 18 years of age has provided us with personal data, we will delete such information from our systems.

Third-Party Processors

We periodically use third parties to provide digital marketing services to us. Such third parties may process your personal information in connection with providing their services to us. Our data processors may include (without limitation):

(i)Prospect Global Ltd (trading as “Sopro”) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io.  Sopro is registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

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Changes to this Site Privacy Notice

If we make changes to this Site Privacy Notice, we will post a revised version of the notice on this page. If we make material changes regarding our collection, use, protection, or disclosure of your personal data, we will notify you by email if you have provided us with your email, or through a notice posted on the Site. We encourage you to review this Site Privacy Notice frequently to see if it has been updated.