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Privacy and Cookies Policy

This Privacy Policy (together with the end-user license agreement -; and - (EULA)) and the documents below, specify the Terms & Conditions to use:
° Our website (website), as a guest,
° Our BuckleUp mobile application (App), as a registered user,
° Our Blog, BuckleUp (Blog) as a guest or registered user.

Part 1: Personal information and Privacy

1.1 We are committed to safeguarding the privacy of BuckleUp visitors and registered users; this policy sets out how we will treat your personal information. 1.2 By using BuckleUp and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

2.1 We may collect, store and use the following kinds of personal information:
(a) information about your computer/device and about your visits to and use of BuckleUp (including your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and BuckleUp navigation paths…);
 (b) information that you provide to us when registering with BuckleUp (including your email address and phone number);
 (c) information that you provide when completing your profile on our BuckleUp (including your name, profile pictures, gender, date of birth, relationship status, gender, sexual orientation, interests and hobbies, educational details and employment details,…);
 (d) information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (including your name and email address);
 (e) information that you provide to us when using the services on BuckleUp, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use);
 (f) information that you post on BuckleUp for publication on the internet (including your user name, your profile pictures and the content of your posts);
 (g) information contained in or relating to any communications that you send to us or send through our Website/App (including the communication content and meta data associated with the communication); 
(h) any other personal information that you choose to send to us;;
2.2 Before you disclose to us the personal information of another person, you must obtain that person's consent to both the disclosure and the processing of that personal information in accordance with the terms of this policy.

3.1 Personal information submitted to us through our Website/App will be used for the purposes specified in this policy or on the relevant pages of BuckleUp.
3.2 We may use your personal information to:
(a) administer our Website/App and business; (b) personalise BuckleUp for you; (c) enable your use of the services available on BuckleUp; (d) send you non-marketing commercial communications; (e) send you email notifications that you have specifically requested; (f) send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter); (g) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications); (h) provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information); (i) deal with enquiries and complaints made by or about you relating to BuckleUp; (j) keep our BuckleUp secure and prevent fraud; (k) verify compliance with the terms and conditions governing the use of our BuckleUp (including monitoring private messages sent through our App private messaging service);
3.3 If you submit personal information for publication on BuckleUp, we will publish and otherwise use that information in accordance with the licence you grant to us.
3.4 Your privacy settings can be used to limit the publication of your information on BuckleUp, and can be adjusted using privacy controls on BuckleUp.
3.5 We may, without your express consent, supply your personal information to any third party for the purpose of their or any other third party's direct marketing.

4.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, business partners, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.

4.2 We may disclose your personal information to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

4.3 We may disclose your personal information:
(a) to the extent that we are required to do so by law;
(b) in connection with any ongoing or prospective legal proceedings;
(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention);

(d) to the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e) to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.

4.4 Except as provided in this policy, we will not provide your personal information to third parties.

5.1 Information that we collect may be stored and processed in and transferred between any of the countries in which we operate in order to enable us to use the information in accordance with this policy.
5.2 Information that we collect may be transferred to the following countries which do not have data protection laws equivalent to those in force in the European Economic Area: the United States of America, Russia, Japan, China, India, and by extension any country not listed.
5.3 Personal information that you publish on our Website/App or submit for publication on our Website/App may be available, via the internet, around the world. We cannot prevent the use or misuse of such information by others.
5.4 You expressly agree to the transfers of personal information described in this Section 5.

6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
6.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 Notwithstanding the other provisions of this Section 6, we will retain documents (including electronic documents) containing personal data:
(a) to the extent that we are required to do so by law;
(b) if we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and

(c) in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

7.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
7.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
7.3 You acknowledge that the transmission of information over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.

7.4 Passwords and Login are managed by third party providers, Facebook and Facebook Account Kit. We don’t have any access to your Login details. You can access Facebook T&C and Privacy at the following link (

8.1 We may update this policy from time to time by publishing a new version on our Website/App.

8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of changes to this policy [by email or through the private messaging system on our Website/App.

9.1 You may instruct us to provide you with any personal information we hold about you; provision of such information will be subject to:
(a) the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).
(b) a clearly linked identification between your registered profile and your identity
9.2 We may withhold personal information that you request to the extent permitted by law.
9.3 You may instruct us at any time not to process your personal information for marketing purposes.
9.4 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

10.1 BuckleUp includes hyperlinks to, and details of, third party Websites/Apps.
10.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.

Please let us know if the personal information that we hold about you needs to be corrected or updated.

Part 2: Cookies

1.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

1.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
1.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
1.4 Cookies can be used by web servers to identity and track users as they navigate different pages on a Website and identify users returning to a Website.

We use both session and persistent cookies on our Website/App.

3.1 We use Google Analytics to analyse the use of BuckleUp.. 3.2 Our analytics service provider generates statistical and other information about Website use by means of cookies.
3.3 The information generated relating to BuckleUp is used to create reports about the use of our Website.
3.4 Our analytics service provider's privacy policy is available at: (

4.1 Our Website/App also uses third party cookies.
4.2 We may publish Google AdSense interest-based advertisements on BuckleUp. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on BuckleUp and on other Websites across the web using the DoubleClick cookie. / We may publish Google AdSense advertisements on our BuckleUp. To determine your interests, Google will track your behaviour on BuckleUp and on other s across the web using the DoubleClick cookie. This behaviour tracking allows Google to tailor the advertisements you see on other Website/Apps to reflect your interests (we do not publish interest-based advertisements on this Website). You can view, delete or add interest categories associated with your browser by visiting: You can also opt out of the AdSense partner network cookie using those settings or using the NAI's (Network Advertising Initiative's) multi-cookie opt-out mechanism at: ( However, these opt-out mechanisms themselves use cookies, and if you clear the cookies from your browser your opt-out will not be maintained. To ensure that an opt-out is maintained in respect of a particular browser, you may wish to consider using the Google browser plug-in available at:
4.3 Other third party cookies used by our Website/App in the future may be inserted in an updated version of this document.

5.1 Most browsers allow you to refuse to accept cookies; for example:
(a) in Internet Explorer (version 10) you can block cookies using the cookie handling override settings available by clicking "Tools", "Internet Options", "Privacy" and then "Advanced";
(b) in Firefox (version 24) you can block all cookies by clicking "Tools", "Options", "Privacy", selecting "Use custom settings for history" from the drop-down menu, and unticking "Accept cookies from sites"; and
(c) in Chrome (version 29), you can block all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Content settings", and then selecting "Block sites from setting any data" under the "Cookies" heading.
5.2 Blocking all cookies will have a negative impact upon the usability of many Website/Apps.
5.3 If you block cookies, you will not be able to use all the features on BuckleUp.

6.1 You can delete cookies already stored on your computer; for example:
(a) in Internet Explorer (version 10), you must manually delete cookie files (you can find instructions for doing so at;
(b) in Firefox (version 24), you can delete cookies by clicking "Tools", "Options" and "Privacy", then selecting "Use custom settings for history", clicking "Show Cookies", and then clicking "Remove All Cookies"; and
(c) in Chrome (version 29), you can delete all cookies by accessing the "Customise and control" menu, and clicking "Settings", "Show advanced settings" and "Clear browsing data", and then selecting "Delete cookies and other site and plug-in data" before clicking "Clear browsing data".

Part 3: Our details

1.1 We are registered as a data controller with the UK Information Commissioner's Office.
1.2 Our data protection registration number is ZA119636.

2.1 BuckleUp is owned and operated by EMCT Investments Ltd.
2.2 We are registered in England and Wales under registration number 9020108, and our registered office is at 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom.
2.3 You can contact us by writing to the registered address given above, by using BuckleUp contact form or by email to
The Terms were last updated on: 14 September 2017