Privacy Policy
Last updated: 25th July, 20221: Introduction
District5 Ltd ("we", "our" or "us") are committed to protecting and respecting your privacy.
This Privacy Policy explains how we will use the personal data that we have obtained from you or others in connection with your use of our mobile application (referred to in this policy as "your personal data" or "information"), why we use your personal data in that way, who it will be shared with and other important information. Please read the following carefully.
This policy applies to our application software (the "App") and the services accessible through the App once you have downloaded or accessed it on your device ("Device").
District5 Ltd (Company No. 09960097) is the data controller in relation to the processing activities described below. This means that District5 Ltd decides why and how your personal information is processed.
2: Information We Collect From You
We ask you to provide us with information, and we also collect information about you during your registration to use the App and through your use of the App.
Information you give us
- Your full name, email address and password when you register for the App;
- Profile information gained when using a third party login provider (for example, Google) which contributes to your user account (e.g. name, email address, profile picture and biography) ("Profile Information"). This information is required for other App to recognise and identify you. You may receive emails when certain actions are undertaken on the App;
- User content (e.g. profile picture, name and any other data entered on the App) ("User Content");
- Notifications and communications from PassZero (e.g. updates to the App and security notices);
Information we collect about you and your Device
Each time you use the App we may automatically collect the following information:
- technical information, including a unique identification code for our authentication system, device IP address and device capabilities ("Device Information");
- details of your use of our App including, but not limited to, traffic data, weblogs and other communication data ("Log Information").
3: Use of your personal data
We use your personal data in the following ways:
| Category of personal data | Purpose of processing | Legal basis (i.e. reason) we have to process your personal data |
|---|---|---|
| Profile Information and User Content | To provide you with the services offered by the App, including the features of our App that allow you to add or control User Content (including any personal data it may contain) and (in the case of business related data) to share it with your colleagues or other members of your business. | This processing is necessary to perform the contract we have with you (and to take steps to enter into it). |
| Profile Information and User Content | To use or share personal data in User Content for the purposes of marketing, where we are unable to do this automatically under our Terms and Conditions of Use. | We will only share personal data in these circumstances with your prior consent. We may request this using a release/waiver form. |
| Sensitive personal data | To provide you with the services that you have requested in the App where this involves processing sensitive personal data with special legal protections (such as your religious or political views, information about your sex life or orientation or your health). | This processing is necessary to perform the contract we have with you (and to take steps to enter into it) but as it is sensitive personal data we only process it where we have your explicit consent (in relation to private information) and on the basis that you have decided to make the information publicly available (in the relation to User Content you decide to add using the settings on the App). |
| Location | To provide you with billing features | This processing is necessary to perform any financial transactions with you |
| Location data | To create third party analytics tools to help us measure traffic and usage trends for the service | We have a legitimate interest in understanding web traffic in order to assist us in improving our services. Categories of data is used with analytics information from other users and cannot reasonably be used to identify individual users |
Marketing: If you give your consent, we may use your personal data to contact you by email and/or push notifications through the App to send you newsletters or to notify you of special offers or promotions. We try to adapt any marketing material that we send to you for example by notifying you of special offers or promotions that apply to your interests and in your location. If you do not wish to receive email communications from us, please inform us by sending an email to hello@district5.co.uk or follow the instructions and change your account settings.
We do not disclose your personal data to third party advertisers on our App, but we may provide them with anonymous aggregate information about our users. We may also use such aggregate information to help advertisers reach the kind of audience they want to target. We will use your personal data to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
4: Disclosure of your personal data by us
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services to us or directly to you on our behalf. Such third parties may include cloud services providers (such as hosting and email management) or advertising agencies or other third parties who provide services to us.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service, and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
We may transfer your personal data to any of the third parties listed below:
| Category of data | Recipient | Purpose |
|---|---|---|
| Full name, email address, and ip address | ActiveCampaign, LLC. and its affiliates | To assist with email notifications and security alerts. |
| Full name, email address, and ip address | Google, Inc. and its affiliates | To assist with statistics and basic analytical tools for search engine optimization and marketing purpose in order to improve our services. |
Third parties who provide products and services
We may disclose the personal data to other third parties as follows:
- any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event; and
- if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request.
Unless required by law, we will not otherwise share, transfer or distribute your personal data without your consent.
Disclosure of your personal data by you
Please note that District5 does not monitor communications between users. Any messages expressed by other users are theirs alone, and do not reflect the opinions of District5. District5 will not tolerate defamatory/obscene/abusive/or otherwise intimidating content and such content may result in removal from the App, without warning and without prejudice to any other accrued rights.
5: Transfers to third countries
All information you provide to us is stored on our secure servers which are located within the European Economic Area (EEA).
If at any time we transfer your personal data to, or store it in, countries located outside the EEA (for example, if our hosting services provider changes) we will ensure that appropriate safeguards are in place for that transfer and storage as required by applicable law. This is because some countries outside the EEA do not have adequate data protection laws equivalent to those in the EEA. If we transfer your personal data to the United States of America, we will only send the personal data to companies that participate in the Privacy Shield framework (or such other framework that may replace it from time to time) or for which we have an alternative safeguard in place in accordance with applicable law.
6: Security
We employ security measures to protect the information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. When we have provided (or you have chosen) a password allowing you to access to certain benefits of the App, you are responsible for safeguarding it and keeping it confidential, and you undertake not to allow it to be used by third parties. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information you disclose online. You accept the inherent security implications of using the Internet and will not hold us responsible for any breach of security unless we have been negligent and only within the limits set out in the terms and conditions of this App.
7: Links to other websites
Our App may contain links to other websites run by other organisations which we do not control. This policy does not apply to those other websites and Apps, so we encourage you to read their privacy statements. We are not responsible for the privacy policies and practices of other websites and Apps (even if you access them using links that we provide) and we provide links to those websites solely for your information and convenience. We specifically disclaim responsibility for their content, privacy practices and terms of use, and we make no endorsements, representations or promises about their accuracy, content or thoroughness. Your disclosure of personal information to third party websites is at your own risk.
In addition, if you linked to our website from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
8: Retention
We do not retain personal information in an identifiable format for longer than is necessary.
We store the personal data until you request that your account on the App is deleted.
We retain an anonymised version of the submitted personal data for as long as we require it for statistical and analytical purposes. Such anonymised personal data may be derived from personal data that was contained within accounts that have subsequently been deleted.
9: Rights over your personal data
You have the following rights (which may not always apply or be subject to certain circumstances and exemptions, and some only apply from 25 May 2018):
- to be informed about the processing of your personal data (this is what this statement sets out to do);
- to have your personal data corrected if it's inaccurate and to have incomplete personal data completed;
- to object to processing of your personal data;
- to withdraw your consent to processing your personal data;
- to restrict processing of your personal data;
- to have your personal data erased;
- to request access to your personal data and information about how we process it;
- from 25th July, 2022 only, to move, copy or transfer your personal data ("data portability"); and
- rights relating to automated decision making, including profiling.
To exercise these rights, please contact us using the details at the end of this policy.
You have the right to lodge a complaint with the Information Commissioner's Office where your personal data has or is being used in a way that you believe does not comply with data protection laws. However, we encourage you to contact us before making any complaint, and we will seek to resolve any issues or concerns you may have.
10: Changes to our Privacy Policy
We may make changes to this Privacy Policy at any time by providing a notice of the amended policy within the App. In some cases, we may choose to email these notifications. Any changes take effect from the date on which we post the modified terms. Your continued use of the App means that you agree to be bound by the modified policy.
11: Contact
To contact us for any reason, including to exercise any of your rights in relation to your personal data, please email us at hello@district5.co.uk.