Your privacy and trust are important to us. We're committed to keeping your personal data safe and confidential both online and offline.
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.
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.
You can contact us if you have any questions or complaints in relation to our privacy practices: email us at firstname.lastname@example.org (which includes notification to our Data Processing Officer), call us on 020 7566 1194 or write into District 34 Limited, Kemp House, 152-160 City Road, London, EC1V 2NX.
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 District 34 Limited, Kemp House, 152-160 City Road, London, EC1V 2NX.
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 you read this Privacy Notice in full to understand how we treat your personal data and our purposes for processing it. However, if you're short on time and need a brief overview, the key points are as follows:
The personal data we process includes technical data (such as your internet protocol (IP) address, your use of our website and geographic location), and data that we request that you may choose to provide, including your name, email address, UK residency status, household income, housing deposit saved, current rental payments, and house type preference;
We process your data where we have a lawful basis to do so – this varies from 1) consent, that the processing is necessary to provide our services under an agreement to you; 2) that the processing is necessary for our compliance with legal obligations; and 3) that the processing is necessary for our legitimate interests;
We process your data for a number of purposes including on-boarding you to our various products; 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 defending our legal rights;
We share your data with third party data processors (such as Zoom, Calendly and ActiveCampaign; for the full list scroll to section 8 below) where they perform certain business functions on our behalf;
We only share your data with third party data processors outside of the European Economic Area where they have signed Data Processing Addenda and Standard Contractual Clauses with District 34 to protect your personal data; 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 interact with District 34 (for example when you fill in the forms on our website; browse our website; sign up for our events; contact us; or download our app) we typically process the following types of data about you:
Your name and email address;
Your ‘homebuying stage’ (ie how close you are to buying your first home)
UK residency status;
Tube or train station closest to your workplace;
Your eligibility for our products (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 household income;
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 (for example, flat or house; studio, 1-bedroom, 2-bedroom);
Your discount code (for example, when referred by an existing Home Buying Club member);
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 forms on our website; or when you have signed up for marketing communications via our chosen events platform, Eventbrite);
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 crowdbuying 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 understand which types of customer find our Home Buying Club or Community most helpful or which articles on our website are the most viewed and therefore most helpful for our customers).
5. Our purposes for processing your personal data
Typically, we’ll process your personal data in order to:
On-board you to our products where we need personal data in order to offer homebuying suggestions around budgeting and searching for affordable properties or; where personal data is necessary in contemplation of an agreement with you in order to pre-qualify you for suitable properties or products, to prepare you for later phases of our crowdbuying schemes; or to produce a bespoke homebuying 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;
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.
6. How your data is collected
1. Website usage data
2. Contact forms
When you request information from us or via our website, we use Google Forms, ActiveCampaign, Campaign Monitor and Typeform forms to collect this data.
3. Newsletter subscription
If you subscribe to our newsletter, we will collect your email address, name and home buying stage in ActiveCampaign (previously Campaign Monitor).
Any email links on our website simply launch your local email client and your email is sent directly from your email platform to our Exchange server.
Any conversations you have via the chatbox on our website are run through Hubspot which will keep a record of the conversation.
6. Social media
Should you choose to view or interact with our posts on social media, or send us a message this will be recorded by Twitter, LinkedIn, Facebook or Instagram (the four channels we currently use).
Your ticket purchases (free or paid) are logged in Eventbrite, your (virtual) attendance and participation is logged in Zoom and both of these actions are recorded with your email address in ActiveCampaign.
Your payment information is stored in Stripe, our payments provider.
If you book a meeting with us you’ll be using Calendly for bookings and Zoom for the meeting itself. We will collect your name, email address and notes from you.
The information you share within https://community.district34.com (such as your name, email address and homebuying stage) is recorded in Mighty Networks and ActiveCampaign.
We will use your personal data to send you marketing communications 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 above/below or clicking the unsubscribe link in our emails. Unsubscribing is not the same as having your data permanently deleted. If you wish to have it deleted please scroll to section 11, below.
8. Third-party data processors
ActiveCampaign is a third-party data processor and is used to manage our enquiry forms, Customer Relationship Management (CRM) platform, email marketing and website traffic.
If you make an enquiry using any form on this website, book a ticket for a District 34 event or join our Community (via Mighty Networks) your provided information will remain within the ActiveCampaign database until you specifically request removal.
You can request that we edit or remove any information from our ActiveCampaign database at any time by emailing us at email@example.com.
We use Amazon Web Services to run our app database and website servers. On this database we save information you have shared with us (such as your name, email address, salary and savings). After the District 34 app is discontinued on 29 January 2021 for most customers we will no longer store your data in this database, but rather in ActiveCampaign.
If you join the Home Buying Club your data will be stored in both ActiveCampaign and AWS as Amazon Web Services allows us to create rewards for members (referral codes and discounts) that aren’t currently available through our other platforms.
You can request that we edit or remove any information from our AWS database at any time by emailing us at firstname.lastname@example.org.
Calendly is a third-party data processor and is used to manage the booking of meetings, in conjunction with Zoom.
No data is saved within the Calendly platform – it is merely shared with our Zoom account to book a meeting and with ActiveCampaign, our CRM (Customer Relationship Management platform). The data you share with us will remain within the ActiveCampaign and Zoom databases until you specifically request removal.
Campaign Monitor is a third-party data processor and is used to manage our email marketing.
If you sign up for our newsletter or for email notifications (for example in the case of asking to be notified when a new product – such as the Home Buying Course – will launch) your provided information will remain within the Campaign Monitor database until you specifically request removal.
We will be discontinuing our use of Campaign Monitor in March 2021 at which point all data will be permanently deleted from the database.
Before then you can request that we edit or remove any information from our Campaign Monitor database at any time by emailing us at email@example.com.
Eventbrite is a third-party data processor and is used to manage our event sign-ups.
If you sign up for a District 34 event using Eventbrite, your provided information will remain within the Eventbrite database until you specifically request removal, and will also be shared with ActiveCampaign, as described above.
Hubspot is a third-party data processor and is used to manage the live chat on our website.
If you start a conversation with the live chat on the District 34 website your provided information will remain within the Hubspot database until you specifically request removal.
Should you wish to remove your data from the Community you can at any time by following this guidance from Mighty Networks Delete or Deactivate Your Account and you can also ask us to permanently delete your data from ActiveCampaign at any time too.
If you contact District 34 on social media these third-party data processors will store the messages you send until you specifically request removal.
Stripe is a third-party data processor and is used to manage payments on our website.
If you make a payment through our website your provided information will remain within the Stripe database.
Zoom is a third-party data processor and is used to broadcast our online events.
If you sign up for an online event via Eventbrite or Zoom your provided information will remain within the Zoom database.
9. 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, payment providers or Customer Relationship Management platform) 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.
10. 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.
Only authorised District 34 employees have access to your personal data.
We will report any unlawful data breach of this website’s database or the database(s) of any of our third-party data processors to any and all relevant persons and authorities within 72 hours of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.
11. Your rights in relation to the personal data we collect
You have the following rights:
Right of access – We’re transparent about the data we have and how we use it. If you’d like to access your data or if you have any questions about your data and how we’re using it then please contact us.
Right to be forgotten – After receiving a request to be forgotten, we will permanently delete your record and all data associated with it within 30 days of receiving the request.
Right to object – At any time, you may object (via opt-out or contacting us) to your personal data being used for specific purposes such as direct marketing.
Right of portability – If requested, we will export your data so that you can transfer it to a third party.
Right to rectification – You can request that we edit or remove any information at any time by emailing us at firstname.lastname@example.org.
You can request any of the above by contacting us. We endeavour to respond to such requests within 30 days 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 paragraphs 6 and 7 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.
12. Keeping your personal data up-to-date
We are obliged to keep your personal data accurate and up–to-date. You have the right to ask us to correct inaccurate personal data 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 it is up-to-date. You can assist us with this 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.
13. 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.
14. How you can contact us
If you have any queries about 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 email@example.com for the attention of our Data Protection Officer, John Lim.
15. 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.
16. 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.
We keep our Privacy Notice under regular review. This Privacy Notice was last updated in January 2021##