Privacy Policy
Bolt Practice, operated by Athena Veritas Ltd
Last updated: 3 September 2026
Company number: 16429664
1. Introduction
Athena Veritas Ltd, trading as Bolt Practice (‘we’, ‘us’, ‘our’), is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, store, and protect personal data when you use our website at boltpractice.ai, register for our events and workshops, or participate in our programmes.
We are registered in England and Wales. Our registered office is at 10-12 Barnes High Street, London, SW13 9LW.
We process personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We act as the data controller for personal data processed under this policy.
If you have any questions about this policy or how we handle your data, please contact us at hello@athenaveritas.ai.
2. What Data We Collect
We collect personal data in the following circumstances:
2.1 When You Use Our Website Diagnostic or Enquiry Forms
- Name and email address
- Company name, company website, and postcode
- Business information such as number of staff and annual revenue band
- Your responses to diagnostic and survey questions
- Any information you voluntarily provide in open text fields
2.2 When You Register for an Event or Workshop
- Name and email address
- Company name and contact details
- Attendance and registration information
2.3 When You Enrol in a Programme
- Name, email address, and contact details
- Business and professional information relevant to programme delivery
- Payment information (processed securely via our payment provider; we do not store card details)
- Participation records, session notes, and progress information
- Testimonials or feedback you choose to provide
2.4 When You Visit Our Website
- IP address and browser type
- Pages visited and time spent on the site
- Referring website or search terms
- Cookie data (see our Cookie Policy for full details)
2.5 When You Contact Us Directly
- Name, email address, and any information you include in your message
3. How We Use Your Data
We use your personal data for the following purposes:
3.1 To Respond to Enquiries
Lawful basis: Legitimate interests. We use your contact details to respond to your enquiry and follow up as appropriate.
3.2 To Deliver Programmes and Workshops
Lawful basis: Contract performance. We use your data to organise and deliver the programmes and events you have registered for or enrolled in.
3.3 To Send Marketing Communications
Lawful basis: Consent. If you have opted in, we will send you newsletters, updates, and information about our programmes and events. You can withdraw consent at any time by clicking unsubscribe in any email or contacting us at hello@athenaveritas.ai.
3.4 To Improve Our Services
Lawful basis: Legitimate interests. We use aggregated and anonymised data from diagnostic surveys and programme participation to improve our content, delivery, and website.
3.5 To Meet Legal Obligations
Lawful basis: Legal obligation. We retain certain financial and contractual records as required by law.
3.6 To Manage Our Community Platform
Lawful basis: Contract performance and legitimate interests. If you join our community platform, your profile information is shared within the platform to enable participation.
4. Who We Share Your Data With
We do not sell your personal data to third parties. Where necessary, we share data with a small number of trusted third-party service providers to deliver our programmes and operate our business. These may include providers supporting community platforms, video conferencing, email and document management, website analytics, marketing communications, and payment processing. All providers are bound by data processing agreements and are required to handle your data securely and in accordance with applicable law.
Where service providers operate outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements, including Standard Contractual Clauses or reliance on adequacy decisions.
We may also disclose your data where required to do so by law, or to protect the rights, property, or safety of Bolt Practice, our participants, or others.
5. International Transfers
Some of our service providers may operate outside the UK. Where your personal data is transferred outside the UK, we ensure appropriate safeguards are in place, including Standard Contractual Clauses or reliance on adequacy decisions, in accordance with UK GDPR requirements.
6. How Long We Keep Your Data
- Enquiry and contact data: up to 12 months from last contact, unless you become a programme participant
- Programme participant data: up to 6 years from the end of your programme, for legitimate business and legal purposes
- Financial and payment records: 7 years, as required by HMRC
- Marketing data: until you withdraw consent or we have had no engagement with you for 24 months
- Website analytics data: as defined in our Cookie Policy
We review our data regularly and securely delete data that is no longer required.
7. Your Rights
Under UK GDPR, you have the following rights in relation to your personal data:
- Right of access: to request a copy of the personal data we hold about you
- Right to rectification: to ask us to correct inaccurate or incomplete data
- Right to erasure: to ask us to delete your data in certain circumstances
- Right to restriction: to ask us to limit how we use your data
- Right to data portability: to receive your data in a structured, machine-readable format
- Right to object: to object to processing based on legitimate interests or for direct marketing
- Rights related to automated decision-making: we do not use solely automated decision-making that produces legal or similarly significant effects
To exercise any of these rights, please contact us at hello@athenaveritas.ai. We will respond within one calendar month. We may need to verify your identity before processing your request.
If you are unhappy with how we have handled your data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at www.ico.org.uk or by calling 0303 123 1113.
8. Data Security
We take appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. These include:
- Secure, password-protected systems and accounts
- Restricted access to personal data on a need-to-know basis
- Use of reputable third-party platforms with their own security standards
- Regular review of our data handling practices
While we take all reasonable steps to protect your data, no online system is entirely without risk. You are responsible for keeping any login credentials confidential.
9. Children’s Data
Our standard programmes and website are intended for adults aged 18 and over. Our RiZE programme is designed for participants aged 18 to 30 and does not target individuals under 18. We do not knowingly collect personal data from children under 18. If you believe we have inadvertently done so, please contact us immediately at hello@athenaveritas.ai.
10. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will update the date at the top of this document when we do so. For significant changes, we will notify you by email if you are subscribed to our communications, or by a prominent notice on our website.
We encourage you to review this policy periodically.
11. Contact Us
For any questions, requests, or concerns relating to this Privacy Policy or your personal data:
- Email: hello@athenaveritas.ai
- Post: Athena Veritas Ltd (trading as Bolt Practice), 10-12 Barnes High Street, London, SW13 9LW
We aim to respond to all data-related requests within five working days and will resolve them within one calendar month.
Athena Veritas Ltd, trading as Bolt Practice · Company No. 16429664 · Registered in England and Wales · hello@athenaveritas.ai
