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Privacy Policy

(Last Updated: September 30, 2016)

We at Pluto Money, Inc. (“Pluto”, “Pluto Money”, “us” or “we”) are committed to protecting your privacy. This Privacy Policy describes how we gather, use, disclose and protect your information provided through our website located at https://gopluto.io (the “Site”), in connection with our Services offered through our mobile software application(“App”) (together, the “Services”). Any information collected via our Services is covered by this Privacy Policy at the time such information is collected. This Privacy Policy does not apply to any third-party websites, services or applications, even if accessible through our Services. The terms of our Privacy Policy are incorporated into and are subject to the Terms of Use. By using our Service and accepting the Terms of Use, you accept the terms of our Privacy Policy.

CHANGES & UPDATES TO THIS PRIVACY POLICY
 We reserve the right to revise this Privacy Policy at any time, with or without notice. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by sending you an email to the address you have on file with us, or by generating a pop-up or similar notification when you access the Service for the first time after such material changes are made. We’ll also indicate the date of our latest revision so you know when those changes will become effective. Your continued use of the Service after the revised Privacy Policy has become effective indicates your acceptance of the amended terms, regardless of if you opened or viewed any notice, email or postings. If you do not agree with any of the changes to the Privacy Policy, you must terminate use of our Service. Please review our Privacy Policy from time to time to stay aware of any changes to our privacy practices.

THE INFORMATION WE COLLECT AND/OR RECEIVE

By agreeing to this Privacy Policy, you authorize us to collect and/or receive the types of information specified below while you use our Services. Our goals for collecting information are to provide and improve our Services, to enable your use of the Services, and to make it enjoyable and easy for you to navigate our Services.

PERSONAL INFORMATION

When you register to create a Pluto Account and use our Services, you may provide to us“Personally Identifiable Information” (or “PII”) that we can collect and use to identify you. These include your “Contact Information” (name, email address, mailing address, phone number). Based on the Services you choose, you may be asked to provide “Sensitive Information” (date of birth, driver’s license number, social security number). If you want to link a bank account(s) you hold with a U.S. financial institution (“Bank Account”) to your Pluto Account, you will need to provide us with information about your Bank Account, such as the online login credentials required by your financial institution, your financial institution’s name, and which financial accounts, credit and/or debit card names you wish to track with our Services (collectively, “FI Access Information”). Once you agree to give us access to your Bank Account, you acknowledge and agree that we will have access to your “Financial Information” (transactions, balances, and other information from your financial accounts and statements that may be available through the relevant financial institution that we require in order to provide our Services to you). We may ask you to provide “Additional Personal Information” to verify your identity and financial information (such as a credit card number). All information we collect and/or receive as described in this section are collectively referred to herein as “Personal Information”. We do not collect any Personal Information from you when you visit our platform, unless you voluntarily provide such information.

VERIFICATION INFORMATION

For compliance purposes and depending on the Services you choose, we may collect documentation from you or from a third party that helps us to verify your identity and Bank Account details. These may include a copy of your government-issued photo ID, a copy of a utility bill or bank statement, or other documentation that contains PII. We may also obtain information about you from the financial institution providing your Bank Account.

ACTIVITY INFORMATION

We can automatically record information about how our users (each, a “User”) use our Services (we refer to this information as “Log Data”). Log Data can include mobile device ID, device user settings, Internet Protocol (IP) address, Internet Service Provider (ISP), operating system, browser type, date/time stamp, name of the domain that serves you access to our Services, pages or features of our Services to which a User browsed, frequency and time spent on those pages or features, links provided by our Services that a User clicked on and other statistics. The Log Data may be combined with other information we collect about you to help us expand and tailor our features and functionalities to our Uses’ needs and preferences, and to improve our marketing, analytics and Services.

GEOLOCATIONAL INFORMATION

When you use our App, we may, with your consent, automatically collect information about your location (collectively, “Geolocational Information”). We can access your mobile device’s GPS coordinates or coarse location if you enable location services on your device, or convert your IP address into a rough geolocation. Such information is only collected when our Services are running on your mobile device. The information is used to provide certain location-based features and functionalities, and to further improve and personalize our Services for you. If you do not want us to collect such information, you may disable that feature on your mobile device.

INFORMATION FROM COOKIES AND OTHER TRACKING TECHNOLOGIES

We may use automated data collection tools such as Cookies and Web Beacons to collect certain information from you. “Cookies” are small packets of information (text files) sent by the Service’s servers to your browser and then sent back by your browser each time you access the Service’s servers. The Cookies contain a variety of information such as search query contents, pages you have accessed with the Services, IP addresses and mobile device ID. We may use both session Cookies and persistent Cookies to identify that you’ve logged in to the Services to tell us how and when you interact with our Services. Other purposes include saving you the need to re-enter your username and password each time you log in, monitoring and aggregating usage and web traffic routing on our Services, customizing our Services to your personal preferences, verifying information, and for information security purposes. Session Cookies are deleted when you log off from the Services and exit your browser, and Persistent Cookies are saved on your computer’s or mobile device’s hard drive. Most browsers automatically accept Cookies, but if you wish to block the Cookies, you can go to the “settings” on your browser or mobile device to stop automatically accepting Cookies or get prompted before accepting Cookies. However, keep in mind that disabling Cookies may prevent you from having access to some or all portions or features of our Services, or complicate your use of our Services. We may also engage with some third-party service providers (including third-party advertisers) who may place their own Cookies on your hard drive. This Privacy Policy covers only our use of Cookies and does not include use of Cookies by such third parties.

We may also use “Web Beacons” on the Services to improve product service and evaluation and to provide more user security. Web Beacons are tiny graphics with unique IDs that are invisibly inserted into web pages or emails. They allow us to monitor whether a user has viewed the page or e-mail, to track and measure the performance of our Services and website traffic more effectively, and to monitor the effectiveness of our advertising.

AUTOMATIC DATA COLLECTION

Our service providers may perform automatic data collection on our behalf and provide us with reports on the data collected. We may also associate Personal Information provided by you with automatically collected data to help improve our Services.

THE INFORMATION WE SHARE WITH THIRD PARTIES

We will never sell, lease or rent your PII or Financial Information with third parties.

We will provide access to your Personal Information for Third Party Providers that may administer or provide certain features or services we offer. The access is authorized only for the benefit of your use of the Services and on a need-to-know basis. Our primary Third Party Provider is Plaid (www.plaid.com), a company that enables us to gather and aggregate data for you about your financial accounts. By using our Services, you grant Plaid or any other Third Party Provider the right, power and authority to act on your behalf to access and transmit your personal and financial information from the relevant financial institution according to the terms of Plaid’s privacy policy (www.plaid.com/legal), or that of any other Third Party Provider.

We may disclose any information about you, at our discretion, to government or law enforcement officials or private parties as required by law, including but not limited to in response to court orders or subpoenas. We may also disclose such information to government officials or relevant third parties to: (1) protect our property, rights and safety, and property, rights and safety of a third party or general public; (2) prevent or stop illegal and unethical activity.

We may disclose or transfer information we collect from you, including PII, to a third party acquirer as part of a business transaction should we get acquired by the third party, because such information is considered to be a business asset. This can happen by (but not limited to) merger, acquisition, asset sale, sale of equity interests, change of control transactions, or bankruptcy.

We may hire other companies to perform certain business functions critical to Pluto. Such functions include hosting services, processing payments, mailing information, and maintaining databases. We may provide them with information on a need-to-know basis so they can perform their specific function. Such companies are authorized to use the information we provide them under terms similar to those outlined in this Privacy Policy. 
 ACCESSING AND MODIFYING PERSONAL INFORMATION

You can access and modify the PII stored in your Pluto Account through your Pluto Account Settings in our App. Remember that false, inaccurate, incomplete or outdated information may prevent you from creating a Pluto Account or prevent us from properly providing you with our Services. If you are unable to access or update your information in our App, please send us an email at help@gopluto.io with adequate details or your request. There may be instances where the information in your account cannot be updated, but we will notify you if that happens.

ACCOUNT DELETION AND DATA RETENTION

If you want to delete your Pluto Account and PII, please email us your request at support@gopluto.io. When your account is terminated, we’ll do our best to delete your PII and disconnect the financial institutions you have linked with your Pluto Account. Once those are deleted, you will no longer have access to your account or our Services. It is important to note that some information may remain in archived/backup copies for your information protection purposes and our administrative purposes, but we will take measures to make sure the information cannot identify you.

LINKS TO OTHER SITES

Our Services may contain links to Third Party websites or services (“Third-party Service”). We do not endorse the sites, and any information you provide on or to a Third-party Service or that is collected by them is subject to the owner’s or operator’s privacy policy. We are not responsible for the content, privacy or security practices and policies of such Third-party Services. To make sure your information is protected, you are encouraged to review the privacy policies of any Third-party services you access.

THE SECURTY OF YOUR INFORMATION

We take commercially reasonable measures to protect the information we collect from or about you from any unlawful or unauthorized access, use, disclosure or interceptions. We encrypt any sensitive information you enter on our forms with SSL and other technologies. Other security methods include storing your information on cloud services, authentication procedures, and prevention of unnecessary access to your data. However, please be aware that no security system is completely secure. Thus, we cannot guarantee the absolute security of our databases or the information you supply us with. The same thing applies with any emails you may send us, so we recommend you to be careful with what content you send to us via email. There may also be certain Personal Information or other information related to your usage of our App that is stored on your mobile device (even if we do not collect that information). We are not responsible for preventing unauthorized access to your mobile device, so you should take measures to ensure the security of your device.

OUR CHILDREN’S POLICY

We do not knowingly collect Personal Information from children under 18 through our Services. If we learn that we have collected Personal Information from children under 18, we will take steps to delete that information from our databases as soon as we can. We recommend parents and legal guardians to make sure their children never provides Personal Information through our Services without their permission.

HOW TO CONTACT US

Please email us at support@gopluto.io or contact us through our App if you have any questions, requests, responses or complaints regarding our Privacy Policy and practices.