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DistrictNine Privacy Notice

Last Updated: February 2026 

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At DistrictNine (STREAMWORX, LDA), we don't just optimize advertising; we prioritize the integrity of the data that powers it. This notice explains how we handle personal data collected through our website, direct communications, and our service delivery.

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The "Quick View" Summary:

  • Website Visitors: We don't track you. We have analytics for our website, but no invasive cookies.

  • Clients: We collect only what’s needed to run your campaigns and manage our partnership.

  • Our Role: For our clients' end-users, we act as a Data Processor. We follow strict instructions and keep data siloed.

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1. Information We Collect

A. Information You Provide Directly

  • Inquiries: If you contact us via email or phone, we collect your name, contact details, and the substance of your inquiry.

  • Client Relationships: For our partners and their employees, we collect professional contact information (name, work email, phone number) necessary for account management and billing.

B. Information Collected Automatically

  • Our Website: We believe in "Privacy by Design." Our website does not track, we only have web analytics. 

  • Essential Cookies: Our hosting provider, Wix, uses limited functional cookies strictly necessary for site stability and security. You can view their technical list here.

 

2. Why We Process Your Data (Legal Basis)

We only process data when we have a valid legal reason to do so:

  • Contractual Necessity: To fulfill our obligations to you as a client (e.g., campaign management, reporting, and billing).

  • Legitimate Interests: To respond to your inquiries and improve our professional services.

  • Legal Compliance: To meet tax, audit, and legal obligations.

 

3. Data Retention & Storage

We don’t keep data longer than necessary.

  • General Inquiries: Retained for up to 5 years to ensure continuity of service should you return.

  • Client Records: Retained for 7 years to comply with statutory tax and commercial record-keeping requirements.

 

4. How We Share & Protect Data

We do not sell your personal data. We only share it with:

  • Service Providers: We use Google Workspace for professional communication. We have Data Processing Agreements (DPAs) in place to ensure they treat your data with the same level of care we do.

  • Corporate Evolution: If DistrictNine is involved in a merger or sale, your data may be transferred to the new owner as part of the business assets.

  • Legal Mandates: We will disclose data if required by law or a valid court order.

Security: We utilize industry-standard technical and organizational measures (encryption, access controls, and siloing) to ensure your data remains confidential.

 

5. International Transfers

As a Portuguese company, we primarily store data within the EEA. If we transfer data to countries outside the EEA/UK (such as the US), we ensure "Appropriate Safeguards" are in place, typically through Standard Contractual Clauses (SCCs) approved by the European Commission.

 

6. Your Global Rights

Regardless of where you live, DistrictNine supports your right to control your data. You may:

  • Access & Rectify: Ask what we have and fix mistakes.

  • Erasure ("Right to be Forgotten"): Request we delete your data (subject to legal retention requirements).

  • Portability: Request a digital copy of your data.

  • Object/Restrict: Challenge how we use your data.
     

California-Specific Rights (CCPA/CPRA)

  • No Sale of Data: We do not "sell" or "share" (for cross-contextual behavioral advertising) your personal information.

  • Do Not Track: Our website is built for privacy and does not track users; therefore, it does not specifically alter behavior in response to DNT signals.

 

7. Children’s Privacy

Our services are strictly B2B (Business-to-Business) and are not directed at individuals under the age of 18. If we learn we have inadvertently collected data from a minor, we will delete it immediately.

 

8. Contact & Complaints

If you have questions or wish to exercise your rights, please reach out to our Privacy Team:

Email: privacy@districtnine.com

Response Time: We aim to respond within 4 weeks.

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If you are in the EU, you also have the right to lodge a complaint with the Comissão Nacional de Protecção de Dados (CNPD) in Portugal or your local supervisory authority.

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