Privacy Notice.

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.

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.

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.

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.

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.

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.

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.