Your privacy and trust are important to us and this Privacy Notice provides important information about how District 34 (referred to in this Privacy Notice as "District 34", "we", "us" and "our") treats your personal data. We're committed to keeping your personal data safe and confidential both online and offline.
The purpose of this Privacy Notice is to make you aware of the types of personal data we collect, how we process it, who it may be transferred to and the rights you have in relation to it. Please read this Privacy Notice carefully and contact us using the details in paragraph 14 below if you have any questions or complaints in relation to our privacy practices.
1. Who we are
We are District 34 Limited, a private limited company registered in England and Wales under company number 11279814 and our registered office is 20-22 Wenlock Road, London, N1 7GU.
We are a "data controller" for the purposes of the General Data Protection Regulation 2016/679 ("GDPR"). This means we decide the "how" and "why" of the processing of your personal data and are responsible for making sure it is handled in accordance with data protection law.
We are listed on the Information Commissioner's Office register of fee payers and our registration number is ZA464395.
2. Summary of this notice
We recommend that you read this Privacy Notice in full to understand how we treat your personal data and the purposes for which it is processed. However, if you're short on time and need a brief overview, the key points are as follows:
- The personal data we process includes your name, email address, UK residency status, household income, housing deposit saved, current rental payments, house type preference and technical data (such as your internet protocol (IP) address) and geographic location);
- We process your data where we have a lawful basis to do so – this varies from consent, that the processing is necessary to provide our services under an agreement to you, that the processing is necessary for our compliance with legal obligations and that the processing is necessary for our legitimate interests;
- We process your data for a number of purposes including on-boarding you to our property accelerator scheme, data analytics to inform and improve our products, services and marketing, providing you with our newsletter and marketing information, maintaining a suppression list if you decide to opt out of our marketing, notifying you of changes to our website, terms of business and privacy notice and complying with court orders and defend our legal rights;
- We share your data to third parties where they perform certain business functions on our behalf;
- We do not transfer your data outside of the European Economic Area; and
- This notice sets out your rights in relation to personal data we collect (such as rectification, deletion, access, restriction of processing, portability and withdrawing your consent). It also sets out how to contact us and/or the data protection regulator.
3. What personal data we process about you
When we use the term "personal data", we mean any information which relates to a living person from which they can be identified. Your name, address and birth date are all examples of personal data.
"Processing" means any handling or operation involving your personal data. For example collection, recording, storage, alteration, use, and transmission are all examples of "processing" of personal data.
When you fill in the forms on or otherwise browse our website, we typically process the following types of data about you:
- Your name and email address;
- UK residency status;
- tube or train station closest to your workplace;
- your eligibility for our accelerator (whether you work in London; whether you own a property; confirmation that you are at least 18 years old; and confirmation that you want to buy a home for your own residence);
- your age bracket (allocated into: 18 to 24 years old; 25 to 34 years old; 35 to 44 years old; and 45 years old and above);
- Your household income (allocated into: under £20,000; between £20,000 and £29,999; between £30,000 and £39,999; between £40,000 and £49,999; between £50,000 and £59,999; between £60,000 – £69,999; and more than £70,000);
- Whether you are saving for a housing deposit, and if so, how much you have saved so far;
- Your current rental payments;
- Your house type preferences (allocated into: studio, 1 bedroom, 2 bedroom, family (2+ bedroom));
- your referral ID (the Bring-Your-Own-Neighbour Cash Bonus loyalty programme run by District 34);
- Technical data, such as your internet protocol address, geographic location, web browser type, version and language, operating system type and version, user device type and other similar identifying information required for your device(s) to communicate our website; and
- details of your visits to our website, such as the full uniform resource locators clickstream to, through and from our site (including date and time), download errors, lengths of visit to certain pages, page interaction information, methods to browse away from the page.
4. How we process your data lawfully
We must have a valid lawful basis for using your personal data and we will only process your personal data where:
- You have given your consent to such processing (for example, when you opt-in to receive our marketing communications via the form on our website);
- The processing is necessary to provide our services under an agreement with you or in order to take steps at your request prior to entering an agreement with you (for example, where you provide us with details in contemplation of committing to our incubator scheme);
- The processing is necessary for compliance with our legal obligations (for example, where we may need to share your personal data for the purposes of fraud prevention);
- the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal data (e.g. where we have a legitimate interest in processing your personal data to improve our services or develop our products or website).
5. Our purposes for processing your personal data
Typically, we will process your personal data in order to:
- On-board you to our property accelerator scheme where it is necessary in contemplation of an agreement with you in order to internally allocate and pre-qualify you for suitable properties or products, to prepare you for later phases of our incubator, and to produce a bespoke savings plan on your behalf;
- Use data analytics to inform and improve our products, services, and marketing, where this is necessary for our legitimate interests in developing our products and services and in informing our marketing and corporate strategy (we may anonymise and aggregate your data as part of this process);
- Provide you with our newsletter or other marketing information via email, SMS or post where we you have provided us with your consent to do so;
- Maintain a suppression list if you decide to opt-out of our communications where this is necessary for our legitimate interest in ensuring that we do not breach data protection laws by communicating with you when you have asked us not to;
- Notify you about changes to our website, terms of business, Privacy Notice or similar where this is necessary for our legitimate interest in ensuring our customers are up to date with our most recent policies, our legitimate interest in maintaining our network security and administering our IT services, where it is necessary for us to comply with a legal obligation, and/or where it is necessary or provide our services under an agreement with you; and
- Comply with court orders and exercise and/or defend our legal rights where this is necessary for compliance with a legal obligation or necessary for our legitimate interest in establishing, exercising or defending our legal rights.
We will use your personal data to send you marketing communications and/or our newsletters where we have your consent to do so. Where we have your consent, we will use personal data which you have provided to us to ensure that our marketing is accurate and relevant to you.
You have the right to withdraw your consent to our marketing communications at any time. This can be done by contacting us at the details below or clicking the unsubscribe link in our emails.
7. When we share your personal data
We do not and will not sell, rent out or trade your personal data.
We may use third parties to carry out certain business functions on our behalf (such as our hosting providers) and may transfer your personal data to these third parties so that they can perform those functions.
We will only share your personal data in the ways set out in this notice, and in particular, with the following recipients:
- Third parties who process your personal data on our behalf (such as cloud or hosting providers, and analytics and search engine optimisation providers);
- Any of our group companies (meaning our parent company, any subsidiaries or our parent company, and any of their subsidiaries);
- Any third party to whom we assign or novate any of our rights or obligations;
- Any prospective buyer in the event we sell any part of our business or assets; and
- Law enforcement agencies and/or courts where we are required to do so by applicable law or regulation or at their request.
8. How we protect your personal data
We are committed to safeguarding and protecting personal data and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any personal data provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access.
9. Your rights in relation to the personal data we collect
If you wish to:
- rectify, delete or obtain a copy of the personal data that we hold on you;
- restrict or stop us from using any of the personal data which we hold on you, including by withdrawing any consent you have previously given to the processing of such data; or
- where any personal data has been processed on the basis of your consent or as necessary to perform a contract to which you are a party, request a copy of such personal data in a suitable format which can be ported to another operator,
you can request this by contacting us at the details below. We endeavour to respond to such requests within one month or less, although we reserve the right to extend this period for complex requests.
In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of data.
We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your personal data, and for any additional copies of the personal data you request from us.
Withdrawing your consent
Where you have provided us with your consent, you have the right to withdraw this at any time. This will not affect the lawfulness of any processing performed before your withdrawal.
If you withdraw your consent for marketing communications and/or our newsletter (see paragraph 6 above), we will not be able to send you any further marketing communications unless you re-subscribe, and you may miss out on important offers and deals which are of interest to you.
Failure to provide personal data
In certain circumstances it will be necessary for you to provide us with your personal data, to enable us to manage our operations, to provide services to you or to comply with our statutory obligations. In other circumstances, it will be at your discretion whether you provide us with personal data or not. However, failure to supply any of the personal data we request may mean that we are unable to maintain or provide services or products to you.
10. Keeping your personal data up to date
We are under an obligation to keep your personal data accurate and up–to-date and you have the right to ask us to correct inaccurate personal data about you and to restrict our processing of such data until it has been corrected.
We make every effort to maintain the accuracy and completeness of your personal data and to ensure all of your personal data is up-to-date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal data or if you become aware that we have inaccurate personal data relating to you.
11. How long we will hold your personal data for
We will only retain your personal data as long as necessary to fulfil the purpose for which it was collected or to comply with legal, regulatory or internal policy requirements.
12. How we update or change this privacy notice
We may change or update parts of this Privacy Notice in order to maintain our compliance with applicable law and regulation or following an update to our internal privacy practices.
We will do this by updating this Privacy Notice on our website. You will not necessarily be directly notified of such a change. Therefore, please ensure that you regularly check this Privacy Notice so you are fully aware of any changes or updates.
13. How you can contact us
If you have any queries about the contents of this Privacy Notice, wish to inform us of a change or correction to your personal data, would like a copy of the personal data we collect on you or would like to raise a complaint or comment, please contact us via email at firstname.lastname@example.org.
14. How to lodge complaint to the regulator
You are entitled to lodge a complaint with our data protection regulator if you consider that we have breached your data protection rights. Our data protection regulator is the Information Commissioner's Office, which can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
15. Changes to this privacy notice
We keep our Privacy Notice under regular review. This Privacy Notice was last updated on November 2018.