In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, Pluto Security Inc., (“Pluto”, “we”, “our” or “us”) use, collect and store personal information that we collect or receive from or about you (“you”) in connection with https://pluto.security/ (the “Website”) and the services provided by Pluto (the “Services”).
We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal information. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement.
Table of contents:
- What personal information we collect, why we collect it, and how it is used
- Customer information
- How we protect and retain your personal information
- How we share your personal information
- Your privacy rights
- International transfers of personal information
- Use by children
- Interaction with third party products
- Analytic tools/ Cookies
- Contact us
This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement material changes in the way we use your personal information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.
1. WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
We Process the Following Personal Information:
- Personal information provided through the Website (e.g., contact us form, request a demo).
- Personal information that we collect: When you visit and use the Website, we collect and process your full name and business/personal email address and any other information that you decide to provide us with. For example, when you request a demo, request we contact you and/or make a request for us to search for websites related to your domain.
- For what purposes: We will use your information to allow you to make use of our Website, including, (i) if you request a demo, we will use your personal information to process and answer your request for a demo; (ii) to answer your questions and to allow you to communicate with us (e.g., by clicking “contact us”); (iii) to analyze your use of our Website and to improve our Website; and (iv) to customize your experience. In addition, we will use some of the information collected (e.g., your business email address) to generate a list of applications associated with your organization’s domain.
- Legal Bases (GDPR only, if applicable): Legitimate interest (e.g. respond to a query sent by you) and/or processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering a contract.
- Consequences of not providing the personal information: We will not be able to: receive and answer your questions; provide further information to the extent requested; allow you to download an asset; allow you to open an account; provide and operate the account; respond to your questions, comments, and other requests for ongoing customer assistance, technical support and maintenance of the Website and your account; to better understand your needs, both on an aggregated and individualized basis, in order to further develop, customize and improve our Services based on users’ preferences, experiences and difficulties; to communicate with you and contact you to obtain feedback from you regarding the Services; to establish a business relationship with you.
- Marketing communications: We will collect your full name and email address to send you marketing communications. If you do not provide us with the Personal Data, we cannot send marketing communications. Legal Bases (GDPR only, if applicable): The marketing communications are subject to your consent. You can withdraw consent at any time.
- Personal information that we collect when you sign up to our newsletter.
- Personal information that we collect: Your email address
- For what purposes: To send you updates, tips, news, and other relevant information.
- Legal Bases (GDPR only, if applicable): Depending on the context, legitimate interest or consent.
- Consequences of not providing the personal information: We will not be able to provide you with updates or send you marketing communications.
- Personal information provided through the Services (e.g., log-in data).
- Personal information that we collect: We collect personal information that you voluntarily provide, including your full name, email address, username and password, as well as any other personal information that you decide to provide us with. We also collect the contact and billing information of our customers.
- For what purposes: We will use the personal information, including, without limitation, for the following purposes: (i) allow you to create an account; (ii) to provide you the Services and to process your requests; (iii) communicate with you about your use of the Services and for support purposes; (iv) fulfill any instruction and/or request made by you in the context of the Services; (v) send you push notifications and/or emails and notifications regarding your account or certain features of the Services; (vi) to personalize your experience with our Services; (vii) to allow you to create more users and administrate your users; and (viii) to generally administer and improve the Services.
- Legal Bases (GDPR only, if applicable): Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering a contract, compliance with legal obligations (e.g. tax laws, bookkeeping laws, etc.), legitimate interest (to send you contract-related communication and in certain cases where permitted under applicable law).
- Consequences of not providing the personal information: We will not able to: allow you to register for and log-in to our platform and use the Services; monitor and secure following purposes, including for user authentication, logging and debugging; provide support (e.g. ticketing and chat functions); improve, enhance, and optimize our Services; customize your experience; allow you to send us feedback, reports and additional features.
- Marketing communications: We will collect your full name and email address to send you marketing communications. If you do not provide us with the Personal Data, we cannot send marketing communications. Legal Bases (GDPR only, if applicable): The marketing communications are subject to your consent. You can withdraw consent at any time.
- Personal information automatically collected.
- Personal information that we collect: We automatically collect certain information through your use of Pluto’s Services and Website, such as cookie, pixels, tracking technologies and similar identifiers (“Technologies”), your Internet protocol (IP) address, and other device identifiers that are automatically assigned to your device, browser type and language, hardware type, operating system, internet service provider and other personal information about actions taken through the use of the Services and Website.
- For what purposes: We use Technologies to automatically collect information through the Website and Services, which in certain cases could be considered personal information. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website and Services. If you would like to opt out of the cookies and similar technologies we employ on the Website, you may do so by blocking, deleting, or disabling them as your browser or device permits or by changing your setting and preferences on your browser. For more information about our use of cookies, please read our cookies notice at: https://pluto.security/cookies-notice/.
- Legal Bases (GDPR only, if applicable): Legitimate interest (e.g., essential cookies required for the operation of the Website) or Consent (e.g., non-essential cookies, to the extent required under applicable law).
- Consequences of not providing the personal information: Certain Website features may not be available.
- Personal information from Other Sources.
- Personal information we collect: Pluto also obtains information about you from other sources, including publicly – or commercially- available information, and through third-party data platforms, partners and service providers
- For what purposes: To establish a first business connection and to send marketing communications.
- Legal Bases (GDPR only, if applicable): Depending on the context, legitimate interest (e.g., B2B communications) or performance of a contract.
- Consequences of not providing the personal information: We will not be able to contact you regarding our services and establish a business relationship.
- Personal information you provide to us in person or by phone, or during an online video call (e.g., via Zoom).
- Personal information that we collect:
- When you provide us personal information in person: We collect your contact details, and business cards
- When you provide us personal information by speaking over the phone and/or during an online meeting, we will record the calls.
- For what purposes: We will use this information to establish a business relationship with you, contact you about our Services, send you marketing communications and answer your inquiries or provide additional information to you.
- Legal Bases (GDPR only, if applicable): Depending on the context, legitimate interest (e.g., B2B communications) or consent.
- Consequences of not providing the personal information: We will not be able to establish a business relationship or send you marketing communications.
- Personal information that we collect:
- Personal information that we collect from online interactions (e.g., via our social media accounts, such as X and LinkedIn).
- Personal information that we collect: For example, if you attend a webinar, contact us via social media or otherwise interact with our business, including as a representative of a current / prospective customer, supplier or partner, we track and make a record of those interactions, which may contain your contact details, such as full name, email address, messages and any other personal information that you decide to provide us with.
- For what purposes: To respond to your questions or request, establish a business relationship and send you marketing communications
- Legal Bases (GDPR only, if applicable): Depending on the context, legitimate interest or performance of a contract.
- Consequences of not providing the personal information: We will not be able to respond to your requests, establish a business relationship and send you marketing communications.
- When we use Personal Data of our service providers:
- Personal Data that we collect: Full name, business email address, business phone number, job title, business address, country, payment information, and any other Personal Data that you provide us.
- For what purposes: To perform our agreements with our service providers and communicate with them, and to comply with our legal obligations and record keeping requirements.
- Legal basis (GDPR only, if applicable): Performance of a contract to which the service provider is a party, compliance with a legal obligation (e.g. tax laws, bookkeeping laws, etc.), and/or legitimate interest (e.g. send you contract-related communications).
- Consequences of not providing the personal information: We will not be able to perform our agreements with our service providers and communicate with them, and to comply with our legal obligations and record keeping requirements.
Please note that some of the personal information mentioned in this Privacy Policy will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Personal information may also be used to comply with applicable laws, with investigations carried out by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize, aggregate and/or de-identify part or all of your personal information. This data may be used for analyzing, enhancing and improving Pluto’s product, Website and Services and for research purposes. We may also share this aggregated information and/or disclose it to third parties without restrictions.
2. YOUR CUSTOMER INFORMATION
- Pluto has a contractual relationship with its clients (“Client”). In the context of the Services, the Client can upload (at the Client’s discretion) information, technical data, and personal information to the Services, which generally speaking belongs to the customers or users of the Client (“Client Users Information”).
- For the avoidance of doubt, Pluto is considered a “Processor” and the Client a “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation (“GDPR”)) of such Client’s Users Information. Pluto is considered a “Service Provider” and the Client a “Business” (as both capitalized terms are defined in CCPA). Client is responsible for the security, integrity and authorized usage of personal information in the context of the Services about the Client’s Users Information, and also for obtaining consents, permissions and providing any required data subject rights and fair processing notices required for the collection and usage of such personal information. Please note that Pluto does not have any contractual relationship with the Client’s customers and users, therefore, Plutoa’s Clients are the responsible party for complying with all laws and regulations (including, without limitation, privacy laws) that apply to the collection and use of the Client’s Users Information. If you are a Client’s customer or user and have any questions about your personal information, please contact the Client directly.
If your use of our Services includes processing “personal data” that is subject to the GDPR or “personal information” that is subject to the CCPA, of Client Users Information, then the processing of such Clients Users Information shall be made in accordance with Pluto’s Data Processing Addendum (“DPA”) accessible here.
3. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION
- Security. We implement and maintain industry-standard technical, organizational and security measures designed to protect your personal information. However, please note that we cannot guarantee that the personal information will not be compromised as a result of unauthorized penetration of our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
- Retention of your personal information. Your personal information will be stored until we proactively delete it from our records, or until you send a valid deletion request. Please note that in some circumstances we store your personal information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, and/or (iii) if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.
4. HOW WE SHARE YOUR PERSONAL INFORMATION
We may share your personal information as follows:
- The personal information Pluto gathers may be shared with our partners and other third parties.
- We also share personal information about you with our affiliated companies.
- We use third party service providers to process your personal information for the purposes outlined above, including, without limitation:
- With cloud service providers for hosting purposes;
- With websites and web content creation platforms in order to help us manage our Website;
- With email providers, marketing, CRM, other similar tool providers;
- With artificial intelligence tools and features; and
- With analytic and monitoring tools, in order to help us understand and analyze information we collect in accordance with this policy.
- To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of Pluto, our Website and Services, customers, employees, property, and the public. We may use or disclose the personal information we collect in order to ensure that our users are complying with all applicable aspects of our policies.
- We may disclose personal information with our lawyers, accountants, auditors and other professional advisors where necessary to obtain legal or other advice or otherwise protect and manage our business interests;
- We may use or disclose the personal information to investigate, prevent, or take action regarding illegal activities, suspected fraud, cybersecurity threats, situations involving potential threats to the physical safety of any person, violations of this policy, or as otherwise required or allowed by law and regulations;
- If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal information in connection with the foregoing events.
- Where you have otherwise provided your consent to us for sharing or transferring your personal information.
5. YOUR PRIVACY RIGHTS
- The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by specific laws):
- You have the right to request access to your personal information held by us, along with details on how it is processed, subject to certain conditions.
- You have the right to request rectification of inaccurate personal information about you.
- You have the right to the erasure of personal information about you under certain conditions. Please note that there may be circumstances in which we are required to retain your personal information, for example for the establishment, exercise or defense of legal claims.
- You have the right to object, to or to request restriction, of the processing.
- You have the right to data portability. This means that you may have the right to receive your personal information in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller.
- You have the right to object to profiling.
- You have the right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
- You also have a right to request certain details of the basis on which your personal information is transferred outside the European Economic Area, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality.
- You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.
- You can exercise your rights by contacting us at privacy@pluto.security. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
- Marketing emails – opt:-out You may choose not to receive marketing email by unsubscribing link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt.
6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION.
In order to run our business and provide our Website and Services to you, we transfer personal information to certain countries around the world, including to our affiliates and service providers, many of whom are located outside of your jurisdiction. Therefore, your personal information may be processed in countries with privacy laws that are different from privacy laws in your country. Whenever personal information is transferred internationally, we ensure it is protected by executing data onward transfer instruments such as data processing and protection agreements.
7. USE BY CHILDREN.
We do not offer our products or Services for use by children and, therefore, we do not knowingly collect personal information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provided personal information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@pluto.security.
8. INTERACTION WITH THIRD PARTY PRODUCTS.
We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect personal information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.
9. ANALYTIC TOOLS/COOKIES
- Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
- Mixpanel. We collect personal information, such as your email address and user activity, through the use of Mixpanel when you use the Services. Mixpanel’s ability to use and share personal information is governed by the Mixpanel Terms of Use, available at here, and the Mixpanel Privacy Policy, available here. You can opt-out of Mixpanel’s services by clicking here.
- SWAN. When you visit or interact with our Website, we and selected service providers may use cookies or similar technologies to collect information about your visit. This may include your IP address, device information, and browsing activity. We may share this information with Swan who help us identify the companies and business contacts visiting our website. This allows us to better understand our website traffic and potentially reach out with relevant business communications. You can opt out of this data processing by visiting https://getswan.com/opt-out. If you are aa resident of the EU, EEA, UK, or California, you may have additional rights regarding your personal data. To exercise these rights, please refer to the contact information provided here.
- We use log files. We use such personal information to analyze trends, administer the Website, track user movement around the Website, and gather demographic information.
- We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.
10. CONTACT US.
For any questions, concerns, or to exercise your privacy rights, please contact us at privacy@pluto.security.