Privacy Policy

  • We, Mirrorinfo Tech Pvt Ltd, Further referred as BoltPe. BoltPe is located at Office No 314, Bramha Majestic, NIBM Road, Kondhwa, Pune 411048. We are committed to safeguarding your trust and protecting your privacy.

  • This Privacy Policy explains how we collect, store, and process your information. Please review this document carefully. By accessing or using the BoltPe mobile application, website, or WAP site, you acknowledge and consent to the collection and use of your personal data as described herein.

  • If you do not agree with any part of this Policy, you should discontinue use of BoltPe’s services.

  1. What aspects does the Privacy Policy Cover?

  • This Privacy Statement applies consistently across all BoltPe platforms, including our desktop website, mobile WAP site, and mobile applications. It explains how BoltPe collects, uses, shares, retains, transfers, and stores your Personal Data.

  • By accessing or using our products or services, you acknowledge and accept the terms of this Privacy Statement and provide clear, informed, and voluntary consent to the data practices outlined here.

  • BoltPe collects only the Personal Data necessary to fulfil your requests, as detailed in this Privacy Statement and in compliance with applicable laws.

  • If you choose not to provide the required Personal Data, we may be unable to deliver certain products or services to you.

  1. What are the Governing Laws and Jurisdiction?

  • Our dedication to protecting your privacy is detailed in this Privacy Statement. It is governed by the Information Technology Act, 2000, along with all other applicable laws of India, and is subject to the exclusive jurisdiction of the Courts in New Delhi. Additionally, this Privacy Statement has been formulated in accordance with the compliance standards required under ISO 27001.

  1. What Personal Data does BoltPe collect?

  • BoltPe collects the Personal Data you choose to share with us in order to deliver and continually enhance our products and services. The types of Personal Data we may gather include, but are not limited to, the following:

    • Contact Information – Your name, mobile number, home address, date of birth, and identification documents such as identity cards, passport details, Aadhaar information, PAN, Voter ID, driving license, and educational records.

    • Transaction and Financial Information – Details related to your transactions, payment history, and other financial information such as income, expenditure, and credit history, as required for specific services or products.

    • Audio and Visual Data – Images of documents or photographs submitted for availing our services, along with voice recordings of interactions with our customer support team to assist in resolving queries or grievances.

    • Employment Information – Your occupation, job title, employment history, salary details, and related information maintained for record-keeping purposes.

    • Signature – Specimen signatures used to process instructions received through our payment or service channels.

    • Survey Responses – Feedback, opinions, and responses that you voluntarily provide through surveys or questionnaires.

    • Mobile Device Information – Data obtained from your mobile device when using the BoltPe app, such as device location, communication details (including phone number, SIM serial number, contacts and call logs), device specifications (including storage, model, IMEI, network carrier), as well as transactional and promotional SMS/app notification metadata.

    • In-app Functionalities –

      • Camera access for features such as video KYC, scan-and-pay, and other functionalities requiring video capture.

      • Microphone access for audio recording during video KYC or voice-typing features.

      • File access (audio, video, documents) for features such as in-app chat.

    • Other access-

      • Wi-Fi information (SSID) to notify you about network security status.

      • Near Field Communication (NFC) access to support tap-to-pay and related services.

  1. How does BoltPe process your personal Data?

  • BoltPe processes your Personal Data with your consent or for legitimate business purposes in order to deliver our products and services effectively. Your information may be used for activities such as:

    • Fulfilling the purpose for which the data was voluntarily shared. For instance, if you complete a purchase and request a receipt, we will process your Personal Data accordingly.

    • Facilitating and recording transactions, including reporting and reconciliation activities.

    • Conducting research, analytics, and performance assessments to enhance existing products, services, security measures, and overall service quality.

    • Developing new offerings and periodically reviewing existing ones.

    • Evaluating and processing applications or instructions submitted by you for availing BoltPe’s products or services.

    • Responding to your inquiries, requests, or feedback.

    • Verifying your identity before providing or offering products or services.

    • Keeping you informed about updates, changes to products/services, and revisions to BoltPe’s terms and conditions.

    • Investigating complaints, disputes, or claims raised by you or third parties.

    • Alerting you about suspicious activity or blocking transactions based on risk assessment mechanisms.

    • Conducting audits, screenings, due-diligence checks, and maintaining records as required by law.

    • Preparing financial, regulatory, or management reports, and operating various risk management models.

    • Presenting advertisements, promotional offers, search results, and location-based features tailored to your preferences and interests.

    • Auto-populating third-party pages, when you click advertisements on the BoltPe platform that redirect you externally.

    • Complying with legal orders, judgments, or directives issued under Indian or applicable foreign laws.

    • Providing information required for state services, including subsidies, benefits, certificates, licenses, or for safeguarding sovereignty, integrity, and national security.

    • Meeting legal obligations to disclose information to government authorities or regulatory bodies.

    • Responding to medical emergencies or situations involving imminent risk, such as disasters, epidemics, or public health threats, to ensure safety and provide necessary assistance.

  1. How does BoltPe handle personal data of children and persons with disability?

  • BoltPe’s services are not intended for individuals under the age of 18, and we do not knowingly request or collect Personal Data from anyone in this age group.

  • Before processing the Personal Data of a minor, we obtain explicit and verifiable consent from the parent or legal guardian.

  • If you provide us with Personal Data belonging to a person under 18 years of age, you confirm that you are authorized to do so and that you consent to its use as outlined in this Privacy Statement.

  • Similarly, when handling the Personal Data of Persons with Disabilities, BoltPe seeks verifiable consent from their parent or lawful guardian prior to processing such information.

  • BoltPe does not engage in tracking, behavioural profiling, or targeted advertising based on the Personal Data of children.

  1. Down BoltPe use Cookies and Other Tracking Technologies?

  • BoltPe may use cookies and similar tracking technologies based on the features available on the platform to improve your experience, understand usage behaviour, and tailor content to your preferences. These technologies do not independently collect Personal Data; however, if you have already shared Personal Data with us, certain cookies may be linked to that information.

  1. Does BoltPe share personal data with third parties/ subsidiaries/ affiliates?

  • We share your information strictly on a need-to-know basis with authorized personnel, trusted third parties, and our Affiliates or Subsidiaries as required for business and operational purposes.

  • For instance, when you complete a transaction on the BoltPe platform, the system may collect and store certain details to process your request and to help auto-fill information during future transactions.

  • Your data may also be shared with third-party service providers involved in processing or completing your requests—such as PCI-compliant payment gateway partners—or with entities that help deliver products or services tailored to your needs and preferences.

  1. Does BoltPe share your personal data internationally?

  • BoltPe may process, store, and retain your Personal Data on its own servers located in approved data centre locations, or on servers operated by third parties with whom we have valid contractual arrangements. We do not transfer your Personal Data to any country or region outside India that is restricted or prohibited by the Government of India.

  1. How does BoltPe keep your personal data safe?

  • BoltPe implements appropriate security measures to safeguard your Personal Data from loss, misuse, unauthorised access, alteration, or disclosure. Our systems use advanced encryption technologies, secure server layers, and strict access controls. Some of the key protections we apply include:

    • Encryption of payment data: Whenever you provide credit or debit card information, the data is encrypted in accordance with PCI Data Security Standards.

    • Multiple layers of in-app security: The BoltPe app includes features such as login/logout controls and an optional app lock for payment protection, which you may choose to activate.

    • Device-specific access controls: After you sign in on one device, your account cannot be accessed on another device without additional security checks, such as extra authentication or an OTP.

  • While BoltPe follows industry-standard practices and takes reasonable precautions to protect your Personal Data, no system can offer complete security. External factors such as hacking, malware, breaches, or unforeseen events may still pose risks

  1. How long does BoltPe keep your data?

  • You may delete your account at any time through BoltPe’s desktop website, mobile WAP site, or mobile application. Once your account is deleted, we stop any further external processing of your Personal Data. We retain your Personal Data only for as long as it is required for the purpose for which it was collected, or until you withdraw consent, or until you exercise your right to have your data erased—whichever happens first. However, certain information may be retained for a longer duration under the following circumstances:

    • When it is essential for fulfilling the original purpose for which the data was collected, or to comply with applicable laws.

    • If any legal or regulatory proceedings are ongoing.

    • For ensuring safety, security, and system integrity.

    • For purposes such as judicial or governmental inquiries or investigations.

    • To safeguard our rights, property, or services.

11. How will you know the changes in Privacy Statement?

  • BoltPe may revise this Privacy Statement from time to time to reflect changes in our business operations, industry practices, or legal and regulatory requirements. The most recent version will always be available under BoltPe’s “Terms & Conditions”. You can refer to the “Document Last Updated” date at the top of this page to know when the Policy was last modified.

  • If any material changes are made, we will inform you either through email or by displaying a notice on our website. You will have the chance to review the updated Privacy Statement before choosing whether to continue using our products or services.

12. How to Contact Us?

  • For any questions regarding this Privacy Statement or for addressing concerns related to your Personal Data, you may reach out to us via email at: support@boltpe.money



DEFINITIONS

  • Affiliate – In relation to another company, an Affiliate refers to an entity over which that company has significant influence but which is not its subsidiary. This also includes entities operating as joint ventures.

  • Data Principal – The individual to whom the Personal Data pertains.

    • In the case of a child, the child’s parent or lawful guardian.

    • In the case of a person with disability, the individual and/or their lawful guardian acting on their behalf.

  • The term applies to BoltPe users, employees, and any other individuals whose Personal Data is processed by the Company.

  • Persons with Disability – Individuals who have long-term physical, mental, intellectual, or sensory impairments which, when combined with various barriers, may limit their full and effective participation in society on an equal basis with others.

  • Subsidiary – A subsidiary company, with respect to another company (the holding company), refers to an entity in which the holding company:

    • Has control over the composition of its Board of Directors; or

    • Exercises or controls more than half of its total share capital, either independently or along with one or more of its subsidiaries.

  • This is subject to applicable regulations that may restrict the number of subsidiary layers a holding company is permitted to maintain.

  • Third Parties –  Any individual or entity that processes Personal Data on behalf of BoltPe. This includes, but is not limited to, Partners, Service Providers, and other contracted entities.