Privacy Policy
DISTRICT PRIVACY & COOKIES POLICY
Thank you for using our products and services, via our apps and websites (“District”). District is provided to you by District Technologies Limited, 59 Dalston Lane, London E8 2NG (“District Tech”, “we” or “us”).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us or via District, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will use it.
This policy is effective from 24th May 2018
1. INTRODUCTION
1.1 We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.
1.2 Our service incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via the profile page in the app.
1.3 You also have a range of privacy controls in the settings on your device, which you can exercise independently of the app.
2. HOW WE USE YOUR PERSONAL DATA
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 In this Section 2 we use the following definitions to describe the categories of data we collect:
(a) Identity Data includes title, first name, last name, username or similar identifier and an encrypted version of your password. If you interact with us through social media, this may include your social media user name;
(b) Contact Data includes billing address, email address and telephone numbers;
(c) Financial Data includes tokenised payment card details, but not actual card numbers, expiry dates or CVV numbers;
(d) Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us;
(e) Profile Data includes your username and password, purchases or orders made by you, preferences, feedback and survey responses, as well as any profile data which we have added (for example, using analytics and profiling);
(f) Technical Data includes internet protocol (IP) address, your login data, browser type and version, mobile device 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 this service;
(g) Usage Data includes information about how you use our website, products and services;
(h) Tracking Data includes information we or others collect about you from cookies and similar tracking technologies, such as web beacons, pixels, and mobile identifiers.
(i) Marketing and Communications Data includes your preferences in receiving direct marketing from us and our third parties and your communication preferences.
2.3 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 in law 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 website feature.
2.3 However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
2.4 We do not collect any 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 health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
2.5 Lawful basis for processing data by category and purpose / activity:
| Purpose / Activity | Type of Data | Lawful basis for processing |
|---|---|---|
| To register you as a new customer | Identity Contact |
Performance of a contract with you |
| To process and deliver your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us |
Identity Contact Transaction Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (including to recover debts due to us) |
| To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey |
Identity Contact Profile Marketing and Communications |
Performance of a contract with you 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 deliver direct marketing to you | Identity Contact Profile Marketing and Communications Tracking Technical |
Necessary for legitimate interests (to promote our business and services), except where the law requires consent for electronic direct marketing in certain circumstances |
| To enable you to take part in a prize draw, competition or complete a survey | Identity Contact Profile Usage Marketing and Communications |
Performance of a contract with you 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 and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Tracking Technical |
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 website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity Contact Profile Usage Marketing and Communications Technical Tracking |
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 our website, products/services, marketing, customer relationships and experiences | Technical Tracking Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website 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 Contact Technical Usage Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To prevent and detect unlawful acts | Identity Contact Transaction Technical Tracking |
Necessary for our legitimate interests (to protect our business and our customers by way of undertaking fraud monitoring and suspicious transaction monitoring) Necessary to comply with a legal or contractual obligation to share personal data for the purposes of law enforcement |
2.6 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.7 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.8 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.9 Please do not supply any other person’s personal data to us, unless we prompt you to do so (e.g. to share meeting invitations).
3. PROVIDING YOUR PERSONAL DATA TO OTHERS
3.1 We may disclose your personal data 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, and on the legal bases, set out in this policy.
3.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3.3 We may disclose your name, email address and employer to our suppliers or subcontractors who provide products and services (e.g. hosting events) insofar as reasonably necessary for us to be able to provide those products and services to you.
3.4 Financial transactions relating to our website and services are handled by our payment services providers, Stripe. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://stripe.com/gb/privacy.
3.5 We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
3.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
4.1 In this Section 4, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
4.2 The hosting facilities for our website are situated within the EEA in the United Kingdom, Ireland and Germany.
4.3 If we transfer personal data outside of the EEA we shall do so using the mechanics permitted by the General Data Protection Regulation, which may include EU approved contract clauses and Privacy Shield.
4.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
5. RETAINING AND DELETING PERSONAL DATA
5.1 This Section 5 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 data.
5.2 We will 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, accounting, or reporting requirements.
5.3 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 requirements. For example, details of your orders will be kept for as long as we need to retain that data to comply with our legal and regulatory requirements. This is generally 7 years unless the law prescribes a longer period.
5.4 In some circumstances you can ask us to delete your data: see 8.2 Right to Erasure in Your Rights section below for further information.
5.5 In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
5.6 Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
6. SECURITY OF PERSONAL DATA
6.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
6.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
6.3 The following personal data will be stored by us in encrypted form: your name, contact information, password(s) and cardholder data.
6.4 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
6.5 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6.6 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our app).
7. AMENDMENTS
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
7.3 We may notify you of changes to this policy by email or through the private messaging system in our app.
8. YOUR RIGHTS
8.1 In this Section 8, we have summarised the rights that you have under data protection law.
8.2 Your rights are:
(a) The right to be informed – an obligation to tell you what we do with your personal data (which we do in our screens and forms and via this privacy policy).
(b) The right of access – a right to be told what personal data we hold about you and obtain copies of it.
(c) The right of rectification – an obligation in certain circumstances to correct your personal data if it’s inaccurate or incomplete.
(d) The right to erasure – an obligation in certain circumstances to delete or remove your personal data where there is no compelling reason for its continued processing (some people also call this right ‘the right to be forgotten’).
(e) The right to restrict processing – an obligation in certain circumstances to stop actively processing your personal data.
(f) The right to data portability – an obligation in certain circumstances to allow you to transfer your personal data from us to a third party.
(g) The right to object – an obligation in certain circumstances to allow you to object to us processing your personal data where we do not have an overriding reason.
8.3 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 clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
8.4 We may need to request specific 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. We may also contact you to ask you for further information in relation to your request to speed up our response.
8.5 We try to respond to all legitimate 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
8.6 You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues ( 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. If you are outside the UK, you may also make a complaint to a supervisory authority responsible for data protection where you are – you may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.7 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.8 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
9. THIRD PARTY WEBSITES
9.1 Our website and app includes hyperlinks to, and details of, third party websites.
9.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
10. PERSONAL DATA OF CHILDREN
10.1 Our website and services are targeted at adults.
10.2 If we have reason to believe that we hold personal data of a person who is not an adult, we will delete that personal data.
11. UPDATING INFORMATION
11.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
12. ABOUT COOKIES
12.1 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.
12.2 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.
12.3 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.
12.4 We use similar technology to cookies to identify you in our app which behave very similarly to cookies as outlined above
13. COOKIES THAT WE USE
13.1 We use cookies and similar technologies for the following purposes:
(a) strictly necessary – these are cookies that help us deliver our website;
(b) analysis of our website usage – we use cookies to help us to analyse the use and performance of our website. These cookies are provided by a third party (Squarespace). Please see section 14.2 for more information.
(c) analysis of our app usage – we use similar technologies to cookies to help us to analyse the use and performance of our app. This data is processed for us by a third party (Google Analytics). Please see section 14.3 for more information.
14. COOKIES USED BY OUR SERVICE PROVIDERS
14.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
14.2 We use Squarespace to analyse the use of our website. Squarespace gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Squarespace’s privacy policy is available at: https://www.squarespace.com/privacy/. The relevant cookies are cookies where the names start with ‘ss’ and include: ‘ss_cookiesAllowed’, ‘ss_cvr’, ‘ss_cvt’, ‘ss_cvisit’, ‘ss_cpvisit’, ‘ss_cid’.
14.3 We use Google Analytics to analyse the use of our website. Google Analytics gathers information about app use by means of an API from our app. The information gathered relating to our website is used to create reports about the use of our app. Google’s privacy policy is available at: https://www.google.com/policies/privacy/.
15. MANAGING COOKIES
15.1 Most browsers allow you to refuse to accept cookies and to delete cookies. If you want more information about this, please see allaboutcookies.org.
15.2 If you block cookies, you will not be able to use all the features on our website.
16. COOKIE PREFERENCES
16.1 You can manage your preferences relating to the use of cookies on our website by visiting district-tech.com and clearing the cookies in your browser. You will then be asked to opt in to analytics cookies again.
17. OUR DETAILS
17.1 This website and app is owned and operated by District Technologies Limited.
17.2 We are registered in England and Wales under registration number [number], and our registered office is at District Technologies Limited, Unit 7 59 Dalston Lane, E8 2NG, London.
17.3 Our principal place of business is at District Technologies Limited, Top Floor, 70-71 Wells Street, London, W1T 3QE.
17.4 You can contact us:
(a) by post, to the postal address given above;
(b) by email: support@district-tech.com.
18. DATA PROTECTION REGISTRATION
18.1 We are registered as a data controller with the UK Information Commissioner’s Office.
18.2 Our data protection registration number is ZA347344.
19. REPRESENTATIVE WITHIN THE EUROPEAN UNION
19.1 Our representative within the European Union with respect to our obligations under data protection law is District Technologies Limited and you can contact our representative by emailing support@district-tech.com.
(Version 2.0, last updated 24 May 2018)