Privacy Policy

This Privacy Policy (“Privacy Policy” and “Policy”) applies to the collection and use of Personal Information by Pluto Capital, Inc. (“Company”, or “we,” or“us,” or “our”). This Privacy Policy describes the Company’s practices regarding the collection, use, disclosure, and sale of Personal Information when you visit our websites or mobile applications (the “Sites”), when you communicate with us via email, and when you engage with us offline. It also describes the rights residents of California may have regarding their Personal Information. By accessing the Sites and using our services, you agree to our collection and use of personal data as described herein and agree to our Terms of Use at https://www.pluto.fi/terms-of-use.

This Policy does not apply to information we collect about employees, job applicants, and independent contractors, or individuals when acting as representatives (e.g., employees, contractors) of entities with which we do business.

For purposes of this Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include de-identified or aggregate information, or public information lawfully available from governmental records. ‍

Personal Information We Collect and Have Collected in the Past 12 Months – Sources and Categories

In the 12 months preceding the date of this Policy, we may have collected your Personal Information when you visited our Sites, entered our contests, requested information about our products or services, registered and/or activated your user and/or brokerage account, submitted reviews, comments or inquiries, or when you voluntarily provided information to us through our web portal or by email or phone number. We may also collect your Personal Information from other third-party sources, such as when you subscribed to our YouTube channel and/or other social media accounts or created an account by using your third-party social media accounts. We will continue to collect Personal Information from the same sources. The categories of Personal Information we may have collected from these sources during the 12 months preceding the date of this Policy, and will continue to collect, include the following:

Personal identifiers

‍Name, age, date of birth, email address, mailing address, telephone numbers, Social Security number, IP address or other unique identifier, account name and password, taxpayer or government identification number, a copy of your government-issued identification, and other similar information.‍

Commercial and financial information

‍Net worth and other financial information, including but not limited to your income, payment and bank account information.

Internet or other electronic activity information

‍Device and browser type, your browsing and search history on our Sites, and information regarding your interaction with our Sites and our advertisements.‍

Audio and visual information

‍Recordings of customer service calls.‍

Professional information

‍Job title, information about your employer, and employment status.‍

Other information

‍Political affiliation. ‍

Inferences drawn from any of the Personal Information identified above  

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Purposes for Collection of Personal Information

‍We use your Personal Information to provide you with information and/or services you request from us, to facilitate and manage your user account, to assist you in activating your brokerage account, to contact you from time to time, to provide you with customer support and/or news and other information about the Company, to verify your identity, to respond to your inquiries, to customize your experience, to process and deliver contest entries and rewards, and for marketing purposes, such as to determine the effectiveness of our marketing and promotional campaigns.

Additionally, we use Personal Information, including about your use of our Sites, to operate, monitor or improve our Sites; for internal business analysis; to prevent fraud, activities that violate our Terms of Use or that are illegal; and to protect our rights and the rights and safety of our users or others.

Disclosure of Personal Information For Business Purposes in the Past 12 Months

We may have disclosed Personal Information to third parties for a business purpose in the 12 months prior to the date of this Policy, including but not limited to our affiliates and service providers that help us operate our business through payment processing or by fulfilling your requests for certain products and services, providing brokerage and investment services, verifying customer information, managing customer information, providing customer service, facilitating email communications, providing security services and cloud-based data storage, hosting our Sites and providing assistance with other IT-related functions, advertising and marketing of our products and those of our affiliates, and providing business analytics information, legal and accounting services, among other business functions.

We may also share your Personal Information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also share your Personal Information with third parties to help detect and protect against fraud or data security vulnerabilities. And we may transfer your Personal Information to a third party in the event of a sale, merger, reorganization of our entity or other restructuring.  

‍Cookies and Other Tracking Technologies

Cookies are small, sometimes encrypted text files that are stored on computer hard drivesby websites that you visit. They are used to help users navigate websites efficiently as well as to provide information to the owner of the websites. To find out more about cookies, including how to see what cookies have been setand how to manage and delete them, please visit www.allaboutcookies.org.

When you visit our Sites, we may place a “cookie” or other online tracking devices (e.g. web beacons) that recognizes you. The cookies and other tracking technologies may also collect information about your IP address or actions taken inconnection with the Sites. We may use cookies or similar tracking technologies to capture information about the use of our Sites, including to improve your user experience. Accordingly, we may store and retrieve information on your device through the use of cookies and similar technologies.

We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects personal information, review Google’s Privacy Policy.

California Do Not Track

‍Some browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. At this time, our Sites do not respond to browsers’ do not track signals.

‍Personal Information of Minors

Our products and services are not directed to minors under the age of 13. We do not knowingly sell the Personal Information of minors under the age of 16.

‍Third Party Websites

‍Our Sites may contain links to other third-party websites or social media buttons, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policies posted on any website that you may access through our Sites. This Privacy Policy applies only to our business and the Personal Information we collect.

‍How We Keep Your Personal Information Secure

‍We implement and maintain reasonable security measures appropriate to the nature of the Personal Information that we collect, use, retain, transfer or otherwise process. Those measures include administrative, physical and technical safeguards to protect the security, confidentiality and integrity of Personal Information. However, data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

‍International Residents

‍Our Sites are operated in the United States. If you are located outside of the United States, any Personal Information collected from or provided by you, including via our Sites, will be transferred to the United States where the Sites are hosted. You hereby consent to the transfer of your Personal Information to the United States as described in this Privacy Policy. Please do not use the Sites if you do not agree to the transfer and processing of your Personal Information in the United States, which may not provide the same level of protection for your data as your home country.

‍Changes to This Policy

‍We will review and update this Policy periodically. We will notify you of material changes to it by posting on our Sites notification that the Policy has been updated and by updating the date of the Policy.

‍Accessibility

‍We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at legal@plutohq.io

‍Contact Us

‍If there are any questions regarding this Policy or to request a copy of this Policy in another format you may contact us at: legal@plutohq.io

‍Date Last Modified

‍‍These Terms were last modified on May 22nd, 2023